# C R CSA INTERNATIONAL

Standards QMl Certification Development Management Systems Registration and Testing June 14, 2001

U.S. Department of Energy Office of Building Research and Standards EE-41, 1000 Independence Avenue, S.W. Washington, D.C. 20585-0121 via Courier

Attention : Mr. James Rata Subject: CSA International
- Motor Efficiency Verification Service Program Dear Mr. Raba: In response to the Department of Energy subject letter dated May 14, 2001, CSA International submits the following clarification and data to address the six objections identified therein: 1) Documents DQD 316, 384, 385 and others relevant to the motor efficiency evaluation procedure which have been processed and approved by the CSAI Engineering Quality Assurance group. • DQD 050 dated October 4, 2000 - Certification Division Quality/Management System Manual. • DQD 308 dated March 12, 2001 - Guidelines For The Selection Of Test And Measurement Equipment And Validation Of Borderline Test Measurements. - Paragraph 4.5.33 provides more detail on Electric Motor Efficiency Evaluation (Significant Parameters). • DQD 308.01 dated March 12, 2001 - Selection Of Test And Measurement Equipment/SignificantParameters - CSA Energy Efficiency Verification Program For ThreePhase Induction Motors.

We Answer With Solutions Page 1 of 7

178 Rexdale Boulevard, Toronto, ON, Canada M9W 1 R3 Telephone: 416.747.4000 Fax: 416.747.4149 Website: www.cso-international.org• DQD 316 dated January 22, 2001

- Witness Testing. - This guideline applies to all Certification Division programs and services where testing related activities can be witnessed outside of CSA facilities. • DQD 384 dated January 23, 2001

- Electric Motor Efficiency Evaluation. - This guideline provides a method of testing and evaluating electric motor efficiency to CSA C390. • DQD 385 dated January 24, 2001 - Application Process - CIGA Energy Efficiency Verificatio,i Program For Three
- Phase Induct? on Motors. - This guideline provi d es a method of ensuring that the application process for three
- phase induction motors is followed by designated staff. • DQD 431 dated October 17, 2000

- Review Of Work And Designation Of Signatories. - This guideline specifies the responsibilities, authorities and the process for conducting routine checks and sign - off of certification and testing work. • Refer to Attachment A for copies of above-referenced DQDs. 2) Documents of policy or procedure that would provide further assurance of CSAI's independence from manufacturers , importers , or private labelers. a) The CSA International combined energy efficiency and product safety certification process. • CSA Corporate Policy Manual dated December 1996 -^ Section 3

. 3 - Occupational Health and Safety Internal and External -^ Section 3

. 4 - Standards of Conduct • Standards of Business dated May 1993 -+ Support to Section 3

. 4 above Certification Division Policies and Practices Manual dated February 1999 Page 2 of 7-^ -+ Part I - General Part II - Certification Services

• Certification and Testing Services Overview

-► Support to Part II above

• DQD 050 dated October 4, 2000

-► Certification Division Quality/Management System Manual -^ Section 1.2.1.3 - covers organizational values, integrity, confidentiality and impartiality

• Application for CSA Certification Services -+ Product Service Agreement (reverse side of Application)

• Refer to Attachments A and B for respective documents b) An outright member of CSA International ender Article 2, "By-Laws of the Canadian Standards Association", such as under Article 2 section 2.3, "Certification Member", or manufacturers representative that serves on a CSA International technical or standards development committee. • Certification Division Policies and Procedures Manual dated February 1999 Appendix B - Certification Board Organization and Terms of Reference Appendix C - Standards Committees and Advisory Councils • Annual Report 2000

Leading Change Through Knowledge

-► 1999/2000 CSA International Board of Directors

-► CSA International Leadership Team • Statement of Independence dated 4 June 1998 -+ signed by Corporate Secretary • DQD 301 dated 31 March 2001 (Guidelines for Certification Division Representation on Standards Committees) -+ describes process of Certification Division staff participating in standards development where it is in the best interest of CSA International and the Certification Division DQD 050, Section 1.2.1.3

-► CSA International Executive Team
Page 3 of 7-► direct links from Standards, QMI, and Certification to President

• Refer to Attachments A and B for associated documents c) Shared certification whereby a manufacturer could perform unwitnessed motor testing and submit an initial certification report to CSA for review. • Initial certification always involves Testing Facility Qualification as per DQD 316, para 6.1. • DQD 316, in conjunction with DQD 385, addresses the evaluation and monitoring of a Testing Facility's laboratory capability. • Refer to Attachment A for copies of DQD 316 and DQD 385. 3) Evidence that the CSAI Toronto test facility is at present operational, initial compliance testing is in fact witnessed by CSAI Staff and procedures are in place for regular quality inspections. a) Operational - the Toronto test facility is fully operational under the direction of Mr. John Chin, Sr. Laboratory Technologist for Motors, Controls and Switchgear Group. • The laboratory work order, with attached test details, for master contract #151041 was completed June 4, 2001 (Elektrim). • Testing in progress is addressed under the laboratory work order for master contract #152058 (Leeson Canada). • Refer to Attachment C for copies of laboratory work orders identified above. b) Initial compliance testing is witnessed by CSAI staff.

DQD 385, Attachment I, Page 3 - Para. 6 of Guide to the CSA Energy Efficiency Verification Service addresses the Qualification of Manufacturers' Testing Facilities. In the past, initial compliance testing involved comparing the design predictions with actual test data at the manufacturer's site. If test results were favourable, a sample motor would be selected for additional testing and evaluation at the CSAI subcontractor LTEE. A final report was then generated to compare both the testing results from the manufacturer and LTEE. The CSAI test lab in Toronto can
Page 4 of 7now perform similar testing for motors up to 50 HP. • DQD 316 now covers the formal process for initial compliance and will be used in conjunction with DQD 385 for future evaluation activities. • Verification Reports : Report No. EEV 79018-3 and Report No. EEV 7961 1-4 provide details of witnessed testing. • Refer to Attachments A and C for support details. c) Procedures are in place for regular quality inspections. • DQC' 385, Attachment I, Guide to the CSA Energy Efficiency Verification Service, para. 12, addresses Follow-up Vi.-,its. • DQD 385 will be used in conjunction with DQD 316 for the required inspections criteria. • The most current Motor Energy Efficient Verification Schedule is attached and identified in Attachment C. • Refer to Attachment A, for copies of DQD 385 and DQD 316. 4) Notification of CSAI's intent to assign additional expert staff to its motor efficiency verification service, and evidence as to the nature and extent of its training of current staff involved with the motor efficiency evaluation service. • CSA International has identified additional staff for participation in the operation of our Motor Energy Efficiency Verification (MEEV) Program. They have been involved in some of the work done under the Program, as part of their training. There will be a minimum of three of these additional staff who will continue to be trained. Until trained and experienced, these staff will, in accordance with our quality procedures, work under the direction of the Senior Engineer or Fully Qualified Project Holder. CSA International will continually monitor and manage our staff resources to ensure they are appropriate to the volume of work to be performed, as dictated by our program requirements. 5) A plan and procedures to evaluate a manufacturer's alternative efficiency determination methods (AEDMs). • Verification of Manufacturers Software Calculations - CSA International verifies that the manufacturers software energy efficiency calculations are in agreement with our independent calculated values using the methods
Page 5 of 7described in CSA Standard C390. That is, we use the test data measurements (e.g., torque output, power input, line current, speed, etc.) and then: (a) perform our own calculations to determine the efficiency of the tested motor; (b) match it with the manufacturers software calculated efficiency. If the two values, Items (a) and (b), are in agreement for all the tested motors then we are confident that the manufacturers software is calculating the efficiency values as intended by the Standard. • DQD 385, Attachment I, further addresses the approach CSAI uses in application process through evaluation and qualification of test facilities, test audit. (Refer to Attachment A for a copy of DQD 385.) • A more formal insight to AEDMs is under review by the respective project management with emphasis on respective training and hiring of additional staff with that background. Substantiation that the CSAI motor sampling procedures are statistically valid, use random selection, and render confidence limits such that the true mean energy efficiency of a basic model meets or exceeds the motor's represented energy efficiency level. • DQD 384, para. 6.2, addresses the sampling procedure for electric motor efficiency evaluation. (Refer to Attachment A for a copy of DQD 384.) • CSAI project personnel are establishing a database to review/verify/substantiate that the sampling criteria is valid, uses random selection and provides confidence levels appropriate to requirements. Please advise soonest if any further clarification or documentation is required. The processing of this response and resolution of any subsequent action items, well in advance of 01 November 2001, is very crucial to the CSA International Business Plan.

Page 6 of 7CSA International appreciates your support and cooperation and eagerly anticipates

our recognition by DOE for electric motor efficiency verification. Yours truly,

Otto C. Krepps, P.Eng., P.Adm. Manager, Accreditations CSA International Tel: 416-747-2798 Fax: 416 -747-4173 E-mail: Otto

. krepps @ csa-internatiornal .oro 0 K/dv Enclosures

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