Underwriters Laboratories Inc. ®

September 17, 2001

333 Pfingsten Road

Northbrook, Illinois 60062-2096

(847) 272-8800

MCI Mail No. 254-3343

Telex No. 6502543343

all

log' a century of

public safety

A 1694.1994

Subject: Test Procedure in accordance with Federal Register 10 CFR Part 431

This is in regard to discussions concerning the qualifications of UL Engineering staff to

conduct efficiency testing in accordance with the Final Ruling of Federal Register 10

CFR, Part 431 (FR).

The FR requires motors to have the efficiency measured in accordance with IEEE,

Standard 112-1996 (with modifications as outlined in Parts II(B)(2)(a-c), or as outlined in

CSA Standard C390-93, method B.

Based on years of experience evaluating products in accordance with Canadian

Standards, and the industry practice of using CSA Standard, C390-93, method B for

energy efficiency calculation, UL trained the staff using this document.

The test procedures outlined in CSA C390-93 are similar to those procedures already in

place in other Canadian standards as well as UL standards. The data and information

recorded for energy verification testing, is some of the same data and information

required under our current test procedures. The only exception is the measurement of the

motor torque, which is 1) available for recording at UL and 2) easily recorded using a

standard Dynamometer and Power Analyzer setup, and the actual calculation of

efficiency, which has been converted into an automated spreadsheet to avoid errors

common to data-intensive calculations.

The testing UL conducts on a routine basis are covered under UL, 1004 (Electric Motors),

UL 2111 (Overheating Protection for Motors, formerly UL 5 19 (Impedance Protected

Motors) and UL 547 (Thermally Protected Motors)), CSA C22.2 No. 77 (Overheating

Protection for Motors), and CSA C22.2 No. 100 (Motors and Generators).

The attached appendix A is a tabulation of the test procedure in CSA C390-93, method

B, with reference to similar procedures in UL and/or CSA Standards.

A not-for-profit organization

dedicated to public safety and

committed to quality service

EE-RM-96-400-UL COMMENT 12
Page Two September 17, 2001

C390 Test Procedure Familiarity (cont.)

Each person involved in the Energy Efficiency Verification Program had a minimum of 3

years experience evaluating motors in accordance with the above standards. The average

number of new projects handled per year using these standards is estimated to be more

than 60 projects per person. Each person also received training on thermocouple

placement, temperature recording, and the use of common data acquisition equipment for

approximately three months.

Below is a summary of the current years experience with the relevant documents:

Lenore Berman: 10 years experience with UL 1004, UL, 2111 (UL, 519, UL 547); and

5 years experience with CSA C22.2 No. 77, 100.

Roberta King : 13 years experience with UL 1004, UL 2111 (UL 519, UL 547);

7 years experience with CSA C22.2 No. 77, 100; and

5 years experience with IEC 34, 335.

Kirk Anderson: 5 years experience with UL 1004, UL, 2111 (UL 519, UL 547); and

5 years experience with CSA C22.2 No. 77, 100.

Darrin Conlon: 9 years experience with UL, 1004, UL 2111 (UL 519 and UL 547) and

7 years experience with CSA 22.2 No. 77, 100

M-like Rizzo: 4 years experience with UL. 1004, UL 2111 (UL 519, UL 547); and

4 years experience with CSA C22.2 No. 77, 100.

Additionally provided is a photograph of UL's motor test setup. This shows some of the

equipment that is used on a regular basis to conduct our standard motor investigations.

For additional information, please contact us.

EE-RM-96-400-UL COMMENT 12
September 17, 2001

Appendix A, CSA C390- 93, Method B Test Procedure Breakdown

CSA C390 Test Procedure: Equivalent:

Install thermocouples UI. 2111,

Winding Slots (located outside air path) CSA C22.2 No. 100

Winding Ends (located outside air path)

Ambient

Measure Stator Resistance UL 2111, Section 5.4;

CSA C22.2 No. 100, Table 4

Operate at rated Voltage, frequency, and Full load UL 2111, Section 13, UI. 1004,

(Current or Torque) until thermal equilibrium Section 22;

CSA C22.2 No. 77, Clause 5.3,

CSA C22.2 No. 100. Clause 6.2

Operate at 2 load points above 100% and not UL 2111, Section 13;

exceeding 150%, followed by 4 load points between CSA C22.2 No. 77, Clause 5.3

100% and 25% equally spaced (in descending order) I

Measure voltage (for each phase), current (for each UL 2111, Section 13;

phase), input wattage, speed, output (corrected), CSA C22.2 No. 77, Clause 5.3

frequency, torque, stator resistance (measured or

calculated), maximum winding temperature, and

ambient

Disconnect load and operate at rated voltage and UL 2111, Section 13;

frequency until thermal equilibrium CSA C22.2 No. 77, Clause 5.3

Vary the voltage at three points between 125 and UL 1004, Section 22, UL 2111,

60%, and three points between 50 and 20% Section 13;

CSA C22.2 No. 77, Clause 5.3

Measure voltage (for each phase), current (for each UL 1004, Section 23, UL 2111,

phase), input wattage, speed, output (corrected), Section 13;

frequency, torque, stator resistance (measured or CSA C22.2 No. 77, Clause 5.3

calculated), maximum winding temperature, and

ambient

Measure watts, speed, torque, current, voltage, and UL 2111, Section 13;

stator line resistance (motor coupled to dyno, and CSA C22.2 No. 77, Clause 5.3

uncoupled)

Calculate efficiency Use Eff33.xls program

EE-RM-96-400-UL COMMENT 12
APPENDIX A:

Comparison of CSA C390 Test Procedures to

Safety Test Procedures for Electric Motors

CSA C390 Test Procedure: Equivalent safety test

procedure:

Install thermocouples UL 2111,

Winding Slots (located outside air path) CSR C22.2 No. 100

Winding Ends (located outside air path)

Ambient

Measure Stator Resistance UL 2111, Section 5.4;

CSA C22.2 No. 100, Table 4

Operate at rated Voltage, frequency, and UL 2111, Section 13, UL 1004,

Full load (Current or Torque) until thermal Section 22;

equilibrium CSA C22.2 No. 77, Clause

5.3, CSA C22.2 No. 100,

Clause 6.2

Operate at 2 load points above 100% and UL 2111, Section 13;

not exceeding 150%, followed by 4 load CSA C22.2 No. 77, Clause 5.3

points between 100% and 25% equally

spaced (in descending order)

Measure voltage (for each phase), current UL 2111, Section 13;

(for each phase), input wattage, speed, CSA C22.2 No. 77, Clause 5.3

output (corrected), frequency, torque, stator

resistance (measured or calculated),

maximum winding temperature, and ambient

Disconnect load and operate at rated voltage UL 2111, Section 13;

and frequency until thermal equilibrium CSA C22.2 No. 77. Clause 5.3

Vary the voltage at three points between 125 UL 1004, Section 22, UL 2111,

and 60%, and three points between 50 and Section 13;

20% CSA C22.2 No. 77, Clause 5.3

Measure voltage (for each phase), current UL 1004, Section 23, UL 2111,

(for each phase), input wattage, speed, Section 13;

output (corrected), frequency, torque, stator CSA C22.2 No. 77, Clause 5.3

resistance (measured or calculated),

maximum winding temperature, and ambient

Measure watts, speed, torque, current, UL 2111, Section 13;

voltage, and stator line resistance (motor CSA C22.2 No. 77, Clause 5.3

coupled to dyno, and uncoupled)

Calculate efficiency Use Eff33.xls program

UL 2111 is comprised of requirements formerly found in UL 519 and UL 547, which have

been superceded by UL 2111.

EE-RM-96-400-UL COMMENT 12
APPENDIX B

Personnel Experience in test standards/methods related to CSA C 390.

UL 1004 UL 2111 CSA 22.2 No.

77

CSA 22.2 No

100

Lenore Berman 10 10 5 5

Roberta King 13 13 7 7

Kirk Anderson 5 5 5 5

Darrin Conlon 9 9 7 7

Mike Rizzo 1 4 14 1 4 , 4

EE-RM-96-400-UL COMMENT 12
Underwriters Laboratories Inc. @)

September 20, 2001

333 Pfingsten Road

Northbrook, Illinois 60062-2096

(847) 272-8800

MCI Mail No. 254-3343

Telex No. 6502543343

a Comm of

public Sato

1894-1 994

Subject: Test Procedure in accordance with Federal Register 10 CFR Part 431

This is in regard to discussions concerning the qualifications of UL Engineering staff to

conduct efficiency testing in accordance with the Final Ruling of Federal Register 10

CFR, Part 431 (FR).

The FR requires motors to have the efficiency measured in accordance with IEEE

Standard 112-1996 (with corrections as outlined in Parts II(B)(2)(a-c) of the FR), or CSA

Standard C390-93 method B.

Based on our experience evaluating motors in accordance with CSA International motor

Standard C22.2 Nos. 77 and 100, and the industry practice of using CSA Standard C390-

93 method B for energy efficiency calculations, UL staff were trained in the CSA C390-

93 document.

The test procedures outlined in CSA C390-93 method B are similar to those procedures

already in place in other CSA standards as well as UL standards used for motor

evaluations. The data and information recorded for energy verification testing is some of

the same data and information required under our current test procedures. The only

exception is the measurement of the motor torque, which is 1) available for recording at

UL and 2) easily recorded using a standard Dynamometer and Power Analyzer setup,

equipment used in our current testing, and 3) the actual calculation of efficiency, which

has been converted into an automated spreadsheet to avoid errors common to dataintensive calculations.

The testing UL conducts on a routine basis are covered under UL 1004 (Electric Motors),

UL 2111 (Overheating Protection for Motors , formerly UL 519 (Impedance Protected

Motors) and UL 547 (Thermally Protected Motors)), CSA C22.2 No. 77 (Overheating

Protection for Motors), and CSA C22.2 No. 100 (Motors and Generators).

A not-for-profit organization

dedicated to public safety and

committed to quality service

EE-RM-96-400-UL COMMENT 12
Page Two September 20, 2001

Test Procedure (cont.)

The attached Appendix A tabulates a comparison of the test procedures in IEEE 112-

1996 with corrections, and CSA C390-93 method B, with similar procedures in UL

Standards. This table shows that the data required for energy efficiency calculation by the

IEEE and CSA Standards is also measured and recorded when testing products in

accordance with UL Standards, specifically UL 2111.

Prior to their involvement in the Energy Efficiency Verification program, each of the

following UL staff had a minimum of three years experience evaluating motors in

accordance with the above safety standards. Also, each person handles an average of 60

new project evaluations annually. All staff received training on thermocouple placement,

temperature recording, and the use of common data acquisition equipment.

Below is a summary of the experience with the CSA and UL safety standards:

Lenore Berman: 10 years experience with UL 1004, UL 2111 (UL 519, UL 547); and

5 years experience with CSA C22.2 No. 77, 100.

4 years experience with CSA C390-93 and IEEE 112-1996

Roberta King: 13 years experience with UL 1004, UL 2111 (UL 519, UL 547);

7 years experience with CSA C22.2 No. 77, 100; and

3 years experience with CSA C390-93 and IEEE 112-1996

Darrin Colon: 9 years experience with UL 1004, UL 2111 (UL 519, UL 547);

7 years experience with CSA C22.2 No. 77, 100.

1 year experience with CSA C390-93 and IEEE 112-1996

Kirk Anderson: 5 years experience with UL 1004, UL 2111 (UL 519, UL 547); and

5 years experience with CSA C22.2 No. 77, 100.

2 years experience with CSA C390-93 and IEEE 112-1996

Mike Rizzo: 4 years experience with UL 1004, UL 2111 (UL 519, UL 547); and

4 years experience with CSA C22.2 No. 77, 100.

1 year experience with CSA C390-93 and IEEE 112-1996

Also provided is a photograph of UL's motor test setup. This shows some of the

equipment, including dynamometer and power analyzer, used on a regular basis to

conduct our standard motor investigations.

For additional information, please contact us.

EE-RM-96-400-UL COMMENT 12
September 20, 2001

Appendix A, FR Data Measurement Requirements Versus

UL Data Measurement Requirements

IEEE 112-1996 CSA C390-93 Method B UL 2111(tt)

5.1.1 (measure stator resistance) 5.1.1 (install thermocouples 5.2 -5.3 (install minimum 4 thermocouples

and measure stator resistance) 5.4 (measure stator resistance for COR

measurements)

5.3 (operate motor at rated V. Hz 5.1.2 (apply rated V,Hz, and 13.1.1.1 (apply nominal V, Hz, and full load

and no-load until TE full load to motor until TE) to motor until TE)

6.4.1.1-6.4.1.2 (operate at 6 5.1.3 (operated at total 6 load 13.1.1.1 (operate at full load, increase

equally spaced points between points between 150%-25% of loading, measure W, A, S, T, Am)

150%-25%, measure W, A, V, full load, equally spaced,

Hz, SL, TO, Am, T) measure TO, W. A. S, T, Am)

6.4.1.3 (operate under no-load, 5.1.4-5 (operate under no-load 13.3 (operate motor under no-load

vary voltage, measure V, A, W) conditions, vary voltage, conditions, measure V, A, W, T)

measure V, A, W, T) 7.6 (vary voltage for increased heating,

measure V, A, W, T)

A - Current

Am - Ambient

COR - Change-of-Resistance

Hz - Frequency

S - Speed

SL - Slip

T - Temperature

TE - Thermal Equilibrium

TO - Torque

V - Voltage

W - Input Power

(if) - Note, CSA Standard C22.2 No. 77-95 (Overheating Protection for Motors), has

similar requirements, except covered under Clauses 5.3 and 5.3.3 of UL 2111. UL 1004 (Electric

Motors),and CSA C22.2 No. 100 (Motors and Generators) contain testing that covers temperature testing at

rated load, voltage, frequency and speed (similar to UL 2111, Sec. 13.1 and CSA C22.2 No. 77, Clause

5.3).

Calculation Of Motor Efficiency:

Data obtained (Voltage, Frequency, Speed, Temperature, etc.) is used in standard

formulas to calculate the stray load loss, windage friction loss, core loss, etc. These

formulas (taken from IEEE 112-1996) have been put into a program to reduce the time

needed to perform these calculations. An example of the utilization of the program is

provided as Appendix B.

EE-RM-96-400-UL COMMENT 12
Lenore.J.Berman@us . To: Jim.Raba@ee.doe.gov

ul.com cc:

Jim,

10/02/01 05:44 PM

Subject: Competency and Statistical Documents

Based on our discussion this afternoon, I've attached the documents that

Gordon Gillerman had brought to you on September 20th.

If you have any questions regarding the content of the documents, please

contact me.

1. Staff Competency documentation:

(See attached file: c390b•doc)(See attached file: 2pole•eff)

2. Statistical Sampling

(See attached file: sampling cover.doc)(See attached file: Statistical

Sample Selection•doc)

Regards,

E-Mail Message From:

Lenore Berman

Associate Manager

Underwriters Laboratories Inc.

Phone: (847) 272-8800 Ext. 42848

Fax: (847) 509-6226

Email: lenore•j•berman@us•ul•com

(See attached file: c390b.doc)

(See attached file: 2pole.eff)

(See attached file: sampling cover.doc)

(See attached file: Statistical Sample Selection.doc)

********* Internet E-mail Confidentiality Disclaimer **********

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*****************************************************************

c390b.doc

2pole.eff

sampling cover.doc

EE-RM-96-400-UL COMMENT 12
Underwriters Laboratories Inc.®

333 Pfingsten Road

Northbrook, Illinois 60062-2096

(847) 272-8800

MCI Mail No. 254-3343

Telex No. 6502543343

®®; a century of

^c public safety

1894-1994

A not-for-profit organization

dedicated to public safety and

committed to quality service

September 20. 2001

Subject: Test Procedure in accordance with Federal Register 10 CFR Part 431

This is in regard to discussions concerning the qualifications of UL Engineering staff to

conduct efficiency testing in accordance with the Final Ruling of Federal Register 10

CFR, Part 431 (FR).

The FR requires motors to have the efficiency measured in accordance with IEEE

Standard 112-1996 (with corrections as outlined in Parts II(B)(2)(a-c) of the FR), or CSA

Standard C390-93 method B.

Based on our experience evaluating motors in accordance with CSA International motor

Standard C22.2 Nos. 77 and 100. and the industry practice of using CSA Standard

C390-93 method B for energy efficiency calculations, UL staff were trained in the CSA

C390-93 document.

The test procedures outlined in CSA C390-93 method B are similar to those procedures

already in place in other CSA standards as well as UL standards used for motor

evaluations. The data and information recorded for energy verification testing is some of

the same data and information required under our current test procedures. The only

exception is the measurement of the motor torque, which is 1) available for recording at

UL and 2) easily recorded using a standard Dynamometer and Power Analyzer setup.

EE-RM-96-400-UL COMMENT 12
equipment used in our current testing, and 3) the actual calculation of efficiency, which

has been converted into an automated spreadsheet to avoid errors common to

data-intensive calculations.

The testing UL conducts on a routine basis are covered under UL 1004 (Electric Motors).

UL 2111 (Overheating Protection for Motors, formerly UL 519 (Impedance Protected

Motors) and UL 547 (Thermally Protected Motors)), CSA C22.2 No. 77 (Overheating

Protection for Motors), and CSA C22.2 No. 100 (Motors and Generators).

EE-RM-96-400-UL COMMENT 12
Page Two September 20, 2001

Test Procedure (cont.)

The attached Appendix A tabulates a comparison of the test procedures in IEEE 112-

1996 with corrections, and CSA C390-93 method B, with similar procedures in UL

Standards. This table shows that the data required for energy efficiency calculation by

the IEEE and CSA Standards is also measured and recorded when testing products in

accordance with UL Standards, specifically UL 2111.

Prior to their involvement in the Energy Efficiency Verification program, each of the

following UL staff had a minimum of three years experience evaluating motors in

accordance with the above safety standards. Also, each person handles an average of 60

new project evaluations annually. All staff received training on thermocouple placement,

temperature recording, and the use of common data acquisition equipment.

Below is a summary of the experience with the CSA and UL safety standards:

Lenore Berman: 10 years experience with UL 1004, UL 2111 (UL 519, UL 547); and

5 years experience with CSA C22.2 No. 77, 100.

Roberta King : 13 years experience with UL 1004, UL 2111 (UL 519, UL 547);

7 years experience with CSA C22.2 No. 77 , 100; and

Darrin Colon: 9 years experience with UL 1004, UL 2111 (UL 519, UL 547);

7 years experience with CSA C22.2 No. 77, 100.

Kirk Anderson : 5 years experience with UL 1004, UL 2111 (UL 519, UL 547); and

5 years experience with CSA C22.2 No. 77, 100.

Mike Rizzo: 4 years experience with UL 1004, UL 2111 (UL 519, UL 547); and

4 years experience with CSA C22.2 No. 77, 100.

Also provided is a photograph of UL's motor test setup. This shows some of the

equipment, including dynamometer and power analyzer, used on a regular basis to

conduct our standard motor investigations.

For additional information, please contact us.

EE-RM-96-400-UL COMMENT 12
September 20, 2001

Appendix A. FR Data Measurement Requirements Versus

UL Data Measurement Requirements

IEEE 112-1996 CSA C390-93 Method B UL 2111(+t )

5.1.1 (measure stator resistance ) 5.1.1 (install thermocouples 5.2 -5.3 (install minimum 4 thermocouples

and measure stator resistance ) 5.4 (measure stator resistance for COR

measurements)

5.3 (operate motor at rated V, Hz 5.1.2 (apply rated V,Hz, and 13.1.1.1 (apply nominal V. Hz, and full load

and no-load until TE full load to motor until TE) to motor until TE)

6.4.1.1-6.4.1.2 (operate at 6 5.1.3 (operated at total 6 load 13.1.1.1 (operate at full load, increase

equally spaced points between points between 150%-25% of loading, measure W, A, S, T, Am)

150%-25%. measure W. A. V, full load. equally spaced,

Hz, SL, TO, Am, T) measure TO. W, A. S, T. Am)

6.4.1.3 (operate under no-load, 5.1.4-5 (operate under no-load 13.3 (operate motor under no-load

vary voltage, measure V, A. W) conditions. vary voltage, conditions, measure V, A, W, T)

measure V. A, W, T) 7.6 (vary voltage for increased heating,

measure V, A, W. T)

A - Current

Am - Ambient

COR - Change-of-Resistance

Hz - Frequency

S - Speed

SL - Slip

T - Temperature

TE - Thermal Equilibrium

TO - Torque

V - Voltage

W - Input Power

(t 1i') - Note, CSA Standard C22.2 No. 77-95 (Overheating Protection for Motors), has

similar requirements, except covered under Clauses 5.3 and 5 .3.3 of UL 211 1. UL 1004 ( Electric

Motors).and CSA C22.2 No. 100 ( Motors and Generators) contain testing that covers temperature testing at

rated load , voltage. frequency and speed (similar to UL 2111. Sec. 13.1 and CSA C22.2 No. 77, Clause

5.3).

Calculation Of Motor Efficiency:

Data obtained (Voltage, Frequency, Speed, Temperature, etc.) is used in standard

formulas to calculate the stray load loss, windage friction loss, core loss, etc. These

formulas (taken from IEEE 112-1996) have been put into a program to reduce the time

needed to perform these calculations. An example of the utilization of the program is

provided as Appendix B.

EE-RM-96-400-UL COMMENT 12