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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EE-RM-96-400-UL COMMENT 26
/7/02 16: 20 `$847 509 6226

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

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(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 service

EE-RM-96-400-UL COMMENT 26
oe 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

EE-RM-96-400-UL COMMENT 26