02/27 / 02 16 : 20 =847 509 6226 UNDERWRITERS LAB 4-34 DOE CODES & STAN to 001



### Date: Name: Organization: Fax Number: From: 

# UNDER WRITERS LAB ORA TORIES INC.

NORTHBROOK, IL U.S.A.

February 27, 2002 Mr. Jim Raba U.S. Department of Energy (202) 586-4617 

### Lenore J. Berman Transmission consists of cover sheet, plus 2 pages. Subject: UL 's Automated Motor Efficiency Calculation Spreadsheet
Dear Mr. Raba: Attached is UL' s response to your e-mail dated February 13. 2002 regarding UL' s automated motor efficiency calculation spreadsheet.

Lenore . Berman Associate Manager Office Phone No. (847) 272- 8800 , Ext. (42848) Section Fax No. (847) 509-6226 Lenore.J.Berman a

@ us-uI_com
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## Underwriters Laboratories Inc. cF, February 27, 2002


### Mr. James Raba US Department of Energy Office of Building Research and Standards Mail Station EE-41 

### 1000 Independence Ave. S. W. Washington, DC 20585-0121 UNDERWRITERS LAB --*-► DOE CODES & STAN W002
333 Kingston Road Northbrook, Illinois 60062-2096 United States Country Code (1) (847) 272-8800 FAX No, (847) 272-6129 htip;//www.ul.com

Subject: UL's Automated Motor Efficiency Calculation Spreadsheet Dear Mr. Raba: 

### This is in response to your February 13, 2002 E-mail regarding UL's automated motor efficiency calculation spreadsheet. As noted in our February 2nd e-mail message addressing your earlier comments, we provided the example spreadsheet to demonstrate how UL intends to process the necessary measurements gathered from the testing, The examples were not submitted to demonstrate UL's technical competency nor were they submitted as an indication of a decision to either accept or reject certification of the motors for compliance with 10 CFR, Part 431.

### We have further reviewed the example spreadsheet submitted via our February 6th email message. Relative to the core loss value and use of the 529-volt value versus the 460-volt value, we did note that a modification was necessary to ensure that the program uses the data from the column that contains the 100% of rated data points as inputted on the data input page. Including this modification into the February 6th example results in a correct calculated core loss value. As observed in the thread of e-mails on this subject, the data, as submitted from the motor manufacturer, that was inputted in the first example of use of the spreadsheet was insufficient to determine compliance with the ruling. While submitted to us for review, since it was preliminary, unofficial data, we had not fully analyzed it prior to providing it to you to determine if sufficient data points were provided and correspondingly, that all the data and results were relevant to the calculations. Instead, in light of the urgency to fulfill your ongoing request for additional information, we used the available values as a means to demonstrate the program, not as supporting material for declaring the efficiency rating of the motors.

A not-for-profit organization dedicated to public safety and committed to quality serviceoe 10. Z1 US47 508 6226 UNDERWRITERS LAB -s-i- ► DOE CODES & STAN Id1003



### Page Two February 27, 2002 Efficiency Calculation Spreadsheet (cont.) You also expressed a concern regarding resistance measurements taken while the motor is in the heated condition
. Equipment is available that can provide resistance measurements while the motor is energized . Thus, the while

-energized measurements can be taken , recorded and then inputted into the spreadsheet. The availability of such values , while not required as part of the ruling , provides for increased accuracy in the overall calculations . If while-energized resistance measuring equipment is not available, a modified version of this program will be necessary to extrapolate the resistance values necessary to complete the efficiency calculations
. We expect to further develop these modifications as the process of the Department of Energy's Recognition of UL' s Energy Verification Service proceeds. As noted above , the calculation spreadsheet is an example of how UL will process the test data . As the need for, use of, and specifications for such a spreadsheet is not covered as part of the Final Ruling , further discussion relative to it is not central to UL's petition for Recognition of the Service
. Accordingly , we agree that submission of further example documents is not warranted , nor necessary for the Department to determine their acceptance of UL' s petition. UL indeed takes on the responsibility of our certification decisions and correspondingly, we effectively take on the responsibility of the test methods, data and results, as these are the basis of our decision to authorize the use of a UL Mark on compliant products. Unlike the alternative independent testing program for energy efficiency verification wherein the responsible agency is not identified on the final product, motors found in compliance with the Ruling by UL, are authorized to bear UL's Energy Verification Mark. Sincerely yours, Reviewed by:
Lenore Berman Raymond E. Burg Associate Manager Manager-CAS-3095 Phone: (847) 272-8800 x42848 Phone: (847) 272-8800 x42257 Email: Lenore.J.Berman(a us.ul.com Email: Raymond.E.Burg@us.ul.com



### cc: Edward Pollock - DOE