CR

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/Significant

Parameters - CSA Energy Efficiency Verification Program For ThreePhase Induction Motors.

We Answer With Solutions

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178 Rexdale Boulevard, Toronto, ON, Canada M9W 1 R3

Telephone: 416.747.4000 Fax: 416.747.4149 Website: www.cso-international.org

EE-RM-96-400-CSA COMMENT 61
• 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 provides 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

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EE-RM-96-400-CSA COMMENT 61
-^

-+

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

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EE-RM-96-400-CSA COMMENT 61
-► 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

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EE-RM-96-400-CSA COMMENT 61
now 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

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EE-RM-96-400-CSA COMMENT 61
described 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.

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EE-RM-96-400-CSA COMMENT 61
CSA 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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EE-RM-96-400-CSA COMMENT 61