t^t' . 3rsq ► ) 2 3l200t

ATTACHMENT 2

(1 Page)

MEEV - SAMPLING PROCEDURE

General: The samples shall be selected and marked from the manufacturer's production line or stock, and are

identified with permanent marking (by means of labels, seals or equivalent method) by CSA International staff

during a regular follow-up inspection visit or beginning of the qualification visit. This is to ensure that the

sample was not pre-tested for CSA International Qualification testing or re-testing.

Samples Required for Motor Model Qualification Testing:

Test 1 to 5 of each basic motor model type. The average efficiency of the sample lot must equal or exceed the

required efficiency rating. The individual sample efficiencies must comply with the nominal efficiency

tolerance required by CSA Standard C390.

Selection of Basic Model Types to Represent A Series of Motors

A minimum of five(5) basic model types are required to be tested to verify the efficiency ratings of a series of

motors. The basic model types are to be selected such that they represent the complete range of motors within

the series. This may require that more than 5 basic model types are selected. High volume production motors

are to be represented in the basic model types selected.

Example Scope of Certification: 230/460, 575 or 600V, 60Hz motors, 1 to 200hp, 143 to 449 frame sizes, 2, 4

and 6 pole, TEFC.

The representative samples are selected as follows:

• One sample motors at each frame size series with rated maximum output ratings. This will result in

approximately 9 sample motors (e.g. NEMA frame sizes 140, 180, 210, 250, 280, 320, 360, 400 &

440). It will b,: 4 motors at 4 pole. 3 motors at 2 pole and 2 motors at 6 pole construction. We will

have to mix the voltages with the 9 samples already selected above. Some will be at 230V, some will

be at 460V and some will be at 575 or 600V.

The above is usually one week (5 days) trip to the test facility and we qualify the facility as per EEV program.

Samples Required for Scheduled Motor Re-testing

The initial sample lot shall :onsis : of one motor. If the result equals or exceeds the minimum result from the

qualification tests, then no further samples are required. If the result is less than the minimum result from the

qualifying tests, then select samples per the qualifying test procedure.

Comment on Re-testing

The goal is to retest high volume motors at least once every 2 years. Other motors are to be re-tested at least

once every 5 years or as per customer demand.

Page 1 of I

EE-RM-96-400-CSA COMMENT 59
"Ken Stricklett" To: Jim.Raba@EE.DOE.GOV

<stricklett@nist.gov> cc:

12/10/01 12:04 PM

Subject: Re: Does this more clear?

Jim,

Draft text for the CSA notice follows.

Please let me know if you have any questions or comments.

Ken

On August 30, 2001, the Department received from CSA International an

electronic message containing a revised sampling plan and procedure DQD

384, "Attachment 2, MEEV ? Sampling Procedure for U.S., Part 431 ? DOE

Energy Efficiency Program for Motors," dated August 29, 2001, for motor

compliance testing, substantiation of an AEDM, and re-testing. The

Department has examined the above DQD 384 Attachment 2 and, in general,

finds it to be consistent with sections 431.24(a)(l)-(4)(i) and

431.24(b)(1) of 10 CFR Part 431. Notwithstanding, where the CSA

International sampling procedures follow section 431.24 of 10 CFR Part 431,

the Department recommends that DQD 384 Attachment 2 clearly state that (1)

the average full load efficiency of each basic model of electric motor must

be determined either by testing or by the application of an alternative

efficiency determination method, (2) the section entitled "Samples Required

for Motor Model Qualification Testing" should be modified to read "Samples

of Units Required for Motor Model Qualification Testing," (3) the section

entitled "Selection of Basic Model Types to Represent a Group of Motors"

should be modified to read "Selection of Basic Models for Testing," and (4)

the specific example provided under "Example Scope of Certification" should

be corrected to accurately depict the sampling guidelines that precede it

in DQD 384 Attachment 2. Also, DQD 384 Attachment 2, entitled "Samples

Required for Scheduled Motor Re-testing," states: "The initial re-test

sample lot shall consist of one motor. If the measured full load

efficiency from re-test meets or exceeds the lowest full load efficiency

determined from the qualification testing, then no further samples are

required for testing." It is not clear whether the "lowest full load

efficiency determined from the qualification testing" refers to the results

of actual tests or some other criterion, and the Department therefore

requests that the procedures to be used during re-testing be clarified. The

Department believes that the testing criteria established in sections

431.24(b)(2)(i) and (ii) of 10 CFR Part 431 provide reasonible assurance

that the average full load efficiency of the basic model being re-tested

meets or exceeds the mandated efficiency level and accordingly may be

applied during re-testings. The Department recommends that CSA

International adopt these sampling procedures for re-testing. Thus, when

testing samples of one motor during re-testing, the efficiency of that unit

must not be less than the full load efficiency described in section

431.24(b)(2)(ii); and, when samples of two or more motors are tested during

re-testing, the average efficiency of the lot must not be less that the

full load efficiency described in section 431.24(b)(2)(i) and the lowest

efficiency of any unit in the lot must not be less than the full load

efficiency described in section 431.24(b)(2)(ii) .

Ken Stricklett

National Institute of Standards and Technology

100 Bureau Dr Stop 8113

Gaithersburg, MD 20899-8113

EE-RM-96-400-CSA COMMENT 59
PH: 301-975-3955

FAX: 301-869-6846

MailTo:stricklett@nist.gov

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

EE-RM-96-400-CSA COMMENT 59
Jim Raba

12/20/01 10:45 AM

To: "Otto Krepps" <otto . krepps@csa-intemational.org>

cc:

Subject: Re: CSA International Petition

Merry Christmas, Otto:

Here are the items we discussed this morning. You may wish to send an e-message, or use FEDEX or

some other convenient means to submit the information.

r

CSAI I nterim2.wpd

1) Clari`y that reference to Institute of Electrical and Electronics Engineers (IEEE)

Standard 112 iia Divirional Quality Document (DQD) No. 308.1, section 6, in fact means the

IEEE Standard 112-1996 Test Method B with the modifications described under appendix

A to subpart B c f 10 CFR Part 431, paragraph 2.(2).

CSA Inteniationa' should confirm the Department's understanding of the following

provision contained in DODs No. 308.01:

DQD No. 308.01, section 6.0, Procedure, states that "where any inconsistencies are

identified within the above documents, preference shall be given to IEEE Standard 112 and NIST

150-10." The Department understands that this refers to IEEE Standard 112-1996 Test Method

B and the corrections that are set forth under paragraph 2.(2) of appendix A to subpart B of 10

CFR Part 431. CSA International should confirm that the Department's understanding is

correct.

2) Change any reference to CAN/CSA C390-M85 test procedures and motor

efficiency values in DQD No. 385, Attachment 1, to C390-93 Test Method (1) and resubmit.

DQD No. 385, section 5.0, Definitions/Terminology, and section 6.0, Procedure to

Facilitate Application Process, both refer to an "Attachment 1" that would ostensibly provide

definitions and procedures relevant to the CSA International Program for electric motors. The

Department finds "Attachment 1" to be comprised of seemingly independent documents, of

which those entitled Application Information and Guide to the CSA Energy Efficiency

Verification Service (Guide) are not dated. Further, none of the documents presented as

"Attachment 1" contain the definitions and terminology referred to at sections 5.0 and 6.0 of

DQD No. 385. Also, the subject line, sections 1.(b) and 2., "Illustration No. 2" dated August 19,

1992, and Table 1 under "Attachment 1 " require a motor to be tested for efficiency according to

CSA Standard C390-M85, whereas section 431.23 of 10 CFR Part 431 requires the use of CSA

Standard C390-93 Test Method (1). Also, the energy efficiency values prescribed in "Illustration

No. 2" of "Attachment 1" are not consistent with section 431.42(a) of 10 CFR Part 431. Also,

the CSA International Verification Report No. EEV 79018-1, dated August 18, 1993, is a report

of compliance with CSA Standard C390-M1985 that is obsolete. CSA International should

correct "Attachment 1" to DQD No. 385 and Verification Report No. EEV 79018-1 to include

relevant definitions, verification procedures, and references to current Department

acknowledges that CSA C390-98 has superseded CSA C390-93 in Canada as the current CSA International test

EE-RM-96-400-CSA COMMENT 59
procedure for motors. The Department understands that the test procedures contained in CSA C390-93 Test Method

(1) and C390-98 Test Method (1) are equivalent. Nevertheless, until section 431.23 of 10 CFR Part 431 is revised,

the Department is required to follow CSA C390-93.

CSA International test procedures for motor efficiency and efficiency values. Then, after these

documents have been approved by the CSA International Engineering Quality Assurance group,

CSA International should submit them to the Department.

3) Confirm that under DQD No. 385, dated January 24, 2001 , and DQD No. 316,

dated January 22, 2001 , all compliance and follow up testing of motors for energy efficiency

is witnessed by a technically qualified CSA International representative.

CSA International submitted a copy of DQD No. 385, Application Process - CSA Energy

Efficiency Verification Program for Three Phase Induction Motors, Attachment 1, paragraph 6.,

Qualification of a ManufacturersTesting Facilities, and paragraph 12., Follow -up Visits, which

set forth guidelines for initial and subsequent evaluation of a manufacturer's testing facility. The

Department understands that when those are used in conjunction with the policies and

procedures set forth in DQD No. 31 6, Witness Testing, dated January 22, 2001, whereby both

initial compliance and periodic follow yip testing are witnessed by qualified CSA International

technical staff. Further , CSA Internatio ntal asserts, on page 12 of its Certification and Testing

Services booklet, that tests are conducted "in the presence of a CSA International representative"

to ensure that test procedures are correct and results are accurately reported . Also, the

Certification Division of CSA International , in its June 14 letter, asserts that procedures are in

place for regular quality inspections. Further, CSA International submitted DQD 385,

Attachment No. 1, "Guide to the CSA Energy Efficiency Verification Service," that states in

paragraph 12.1 "a minimum of one visit to each manufacturing plant will be carried out each

year."

CSA International should confirm that under DQD No. 385, dated January 24, 2001,

and DQD No. 316, dated January 22, 2001, all compliance and follow up testing of motors for

energy efficiency is witnessed by a technically qualified CSA International representative.

4) Certain documents listed in the June 14, 2001 , CSA International letter to the

Department refer to DQDs that have not been submitted for examination , and which may

be significant to the CSA International Motor Efficiency Verification Program.

Of those DQDs, CSA International should submit the following documents to the

Department:

DOD No. 305 - Quality/Management System Audit Program

DOD No. 313 - Guidelines on Re-Testing

DOD No. 332 - Document Control Procedure

DOD No. 424 - Technical Training

DOD No. 425 - Periodic Technical and Process Review

DOD No. 513 - Factory Audit Report

5) Clarify DQD 384 Attachment 2, "MEEV- Sampling Procedure " for U.S., Part

EE-RM-96-400-CSA COMMENT 59
I

431 - DOE Energy Efficiency Program for Motors," dated August 29, 2001.

The Department finds that the example set forth under the section entitled "Example

Scope of Certification " is not consistent with the section entitled " Samples Required for Motor

Model Qualification Testing."

On August 30, 2001 , the Department received from CSA International an electronic

message containing a revised sampling plan and procedure DQD 384 , "Attachment 2, MEEV -

Sampling Procedure for U.S ., Part 431 - DOE Energy Efficiency Program for Motors ," dated

August 29, 2001 , for motor compliance testing, sul;stantiation of an AEDM, and re-testing. The

Department has examined the above DQD 384 Attachment 2 and , in general, finds it to be

consistent with sections 431.24 (a)(1)-(4)(i and 431.24(b)(1) of 10 CFR Part 431.

Notwithstanding, where the CSA International sampling procedures follow section 431.24

of 10 CFR Part 431, the Department recommend:, that DQD 384 Attachment 2 clearly state:

(1) the average full load efficiency of each basic model of electric motor must be determined

either by testing or by the application of an alternative efficiency determination method;

(2) the section entitled "Samples Required for Motor Model Qualification Testing" should be

modified to read "Samples of Units Required for Motor Model Qualification Testing;"

(3) the section entitled "Selection of Basic Model Types to Represent a Group of Motors " should

be modified to read "Selection of Basic Models for Testing;" and

(4) the specific example provided under "Example Scope of Certification " should be corrected to

accurately depict the sampling guidelines that precede it in DQD 384 Attachment 2.

Also, DQD 384 Attachment 2, entitled "Samples Required for Scheduled Motor

Re-testing," states: "The initial re -test sample lot shall consist of one motor . If the measured full

load efficiency from re-test meets or exceeds the lowest full load efficiency determined from the

qualification testing, then no further samples are required for testing." It is not clear to the

Department whether the " lowest full load efficiency determined from the qualification testing"

refers to the results of actual tests or some other criterion , and the Department therefore requests

that the procedures to be used during re-testing be clarified.

The Department believes that the testing criteria established in sections 431.24(b)(2)(i)

and (ii) of 10 CFR Part 431 provide reasonable assurance that the average full load efficiency of

the basic model being re-tested meets or exceeds the mandated efficiency level and accordingly

may be applied during re-testings . The Department recommends that CSA International adopt

these sampling procedures for re-testing. Thus, when testing samples of one motor during

re-testing, the efficiency of that unit must not be less than the full load efficiency described in

section 431 .24(b)(2)(ii); and, when samples of two or more motors are tested during re-testing,

the average efficiency of the lot must not be less that the full load efficiency described in section

431.24(b)(2)(i) and the lowest efficiency of any unit in the lot must not be less than the full load

EE-RM-96-400-CSA COMMENT 59
efficiency described in section 431.24(b)(2)(ii) .

In view of the above, the Department requests that CSA International revise the section

entitled "Samples Required for Motor Model Qualification Testing." The Department further

recommends that the testing criteria established for re-testing should be consistent with those

established under "Samples Required for Motor Model Qualification Testing. "

"Otto Krepps" <otto.krepps@csa-international.org>

'Otto Krepps " To: Jim. Raba@EE.DOE.GOV <Jim.Raba@EE.DOE.GOV>

tto.krepps@csa-inter cc:

nhional .org> Subject: CSA Intemational ?etitioi

Good afternoon, Jim:

Just touching ba to see if a gift wrapped "Interim

Determination" pa kage is enroute to us for Xmas.

All the best for t festive season!

Regards.

OK

Otto C. Krepps, P.Eng., '.Adm.

Manager, Accreditations

Conformity Assessment , CSA International

Tel: 416-747-2798

Fax: 416-747-4173

E-mail: otto.krepps@csa-int national.org

<mailto:otto.krepps@csa-inte ational.org>

Web: www.csa-international.or <http://www.csa-international.org/>

Post: CSA International

178 Rexdale Boulevard

Toronto ON, Canada M9V 1R3

EE-RM-96-400-CSA COMMENT 59
CSA INTERNATIONAL

DIVISIONAL QUALITY DOCUMENTS

Rev. 2002-02-28 Page 40 of 43

ELECTRIC MOTOR EFFICIENCY EVALUATION

ATTACHMENT 2

(Page 1 of 2)

MEEV - SAMPLING PROCEDURE FOR U.S.

Part 431 - DOE Energy Efficiency Program far Motors

DQD NO.

385

General: The average full load efficiency of each basic model of electric motor must be determined

either by testing or by the application of an alternative efficiency determination method.

CSA International staff shall randomly select motor samples and identify them from the

manufacturer's production line or stock at the beginning of the qualification visit or during a regular

follow-up audit. Labels, seals or other equivalent means shall be used to permanently identify the

selected motor samples for testing.

Samples of Units Required for Motor Model Qualification Testing:

The number of samples selected shall be at least five for each basic modela, unless testing of fewer

samples as permitted by paragraph 431.24(b)2 of the Federal Register Vol. 64, No. 192 or

demonstrated to be statistically valid.b

Compliance to Energy Conservation Standards (see paragraph 431.42 of the Federal Register Vol. 64,

No. 192) ,hall be determined using the average full load efficiency of the sample lot and lowest full

load efficiency of the sample lot as described in paragraph 431.24(b)2(i) and (ii) of the Federal

Register Vcl. 64, No. 192.

Notes:

(a) Manufacturers requesting verification of compliance to U.S. electric motors regulations for a

group of motors using AEDM procedures refer to Attachment 3. Plan and Procedure Relative to

Alternative Efficiency Determination Methods (AEDMs).

(b) U.S. Department of Energy is required to approve the statistical information before fewer than 5

motors are to be tested

Selection of Basic Model for Testing

A minimum of five basic models shall be tested to determine the average full load efficiency of each

basic model or for the application of the AEDM procedures.

EE-RM-96-400-CSA COMMENT 59
CSA INTERNATIONAL

DIVISIONAL QUALITY DOCUMENTS

Rev. 2002-02-28

ELECTRIC MOTOR EFFICIENCY EVALUATION

ATTACHMENT 2

(Page 2 of 2)

Page 41 of 43

DQD NO.

385

CSA International staff selection of at least five basic models shall be determined as follows:

(a) two models must be the highest unit volumes of production by the manufacturer in the prior year;

(b) different horsepower ratings;

(c) different frame number series;

(d) each basic model should have the lowest nominal full load efficiency among those basic models

with the same ratings.

Note: it is recommended that CSA International staff select more than 5 basic models, w,'wre

practical.

Example Scope of Certification: 230/460, 60Hz motors, 1 to 200hp, 143 to 449 frame sizes, 2, 4 and

6 pole, TEFC.

The representative basic models are selected as follows:

One basic model for each frame size series with maximum output ratings. This will result in

selection of approximately 9 basic models (e.g. NEMA frame sizes 140, 180, 210, 250, 280, 320,

360, 400 and 440).' Typically we would select 4 basic models with 4 pole design, 3 basic

models with 2 pole design and 2 basic models with 6 pole design. We will also select samples

with various operating voltages.

samples Required for Scheduled Motor Re-testing

The iritial re-test sample lot shall consist of one motor. If the measured full load efficiency from retest meets or exceeds the lowest full load efficiency test data recorded durin&the qualification testing,

then no further samples are required for testing. If the result from the measured full load efficiency

test is less than the lowest full load efficiency test data recorded during_the qualification testing, then

the motor and the range of motors, shall be re evaluated by testing a sample lot size same as during

the initial qualification testing. Non complying products shall be addressed using the applicable

requirements specified in Clause 5.4.8 of DQD 320.

Note: The goal is to retest high volume motors at least once every 2 years. Other motors are to be

re-tested at least once every 5 years or as per customer demand.

EE-RM-96-400-CSA COMMENT 59
Rev. 2002-02-28

CSA INTERNATIONAL

DIVISIONAL QUALITY DOCUMENTS

Page 42 of 43

DQD NO.

ELECTRIC MOTOR EFFICIENCY EVALUATION

ATTACHMENT 3

(Page 1 of 2)

Plan and Procedure Relative to Alternative Efficiency

Determination Methods (AEDMs).

385

The following is a summary of the CSAI Motor Efficiency Verification Program use of AED Vs to

reduce testing and accommodate the large number of motors to be covered by Motor Manufacturers.

1. We require that the motor manufacturer provide us with predicted energy efficiency (AEDM)

values representative of the group of motors that they are seeking to have included in the CSAI

Motor Efficiency Verification Program. The baseline nominal efficiency values shall not be less

than those in Table 2 of C390. The list shall include series name, frame sizes, enclosure types,

ranges of speeds, ranges of horsepower etc. Typically the initial application by the manufacturer

does not include all of the 113 common ratings.

2. Basic models representing the complete range of motors within the group for which the AEDM is

being evaluated are selected for testing. The number of basic models selected will be at least five.

Seven to nine basic models is a typical selection for groups of motors that are being evaluated.

The test data will be used, in accordance with item 4 below, to determine the correlation between

the predicted values and the test results, thereby establishing a range of motors for which the

AEDM has a demonstrated effectiveness.

3. These tests may be performed at the manufacturer's previously evaluated testing facility with

some testing witnessed by CSAI staff, or at the CSAI designated test facility.

4. Of the basic models selected in item 2, CSAI will require testing of 5 samples of each basic

model unless testing of fewer samples is shown to be statistically valid. The individual and

average efficiency of the motors tested shall be in accordance with paragraph 431.24(b)(2)(i) and

(ii) of the Federal Register Vol. 64, No. 192. For substantiation of the AEDM, the predicted total

power loss for each such basic model, calculated by the AEDM, must be within 10 percent of the

mean total power loss determined from the testing of the basic model. In addition, some motors

tested at a manufacturer's facility also shall be tested at an independent CSA designated

laboratory to maintain validation of the manufacturers test facility.

EE-RM-96-400-CSA COMMENT 59
CSA INTERNATIONAL

DIVISIONAL QUALITY DOCUMENTS

Rev. 2002-02-28

ELECTRIC MOTOR EFFICIENCY EVALUATION

ATTACHMENT 3

(Page 2 of 2)

Page 43 of 43

DQD NO.

385

5. CSAI will review the test data, and correlation of the test data to the AEDM. If all of the basic

models tested correlate with the AEDM as specified in item 4, then the manufacturer's AEDM

will be accepted. Where individual basic models tested do not demonstrate a satisfactory

correlation to the AEDM per item 4, CSAI will not allow the use of the AEDM for predicting

motor efficiencies for the range of motors represented by those basic models. Additional basic

models shall be required to be tested to establish the acceptable boundary of the range of models

for which the AEDM does apply.

6. The CSAI Motor Efficiency Verification Program requires that the motor manufacturer establish

and implement a re-testing program. CSAI performs auditing of the manufacturer's facilities,

which includes review of the test data generated by the facilities. The re-testing program

includes the basic models selected for the initial substantiation of the AEDM together with other

basic models that are routinely produced. In essence, the CSAI prograrn uses the manufacturer's

AEDM when found to be acceptable, and also includes continued monitoring of the correlation

of AEDM and actual test results, which is recognized in page 54155 of the Federal Register Vol.

64, No. 192 paragraph 431.27(b)(1).

a

7. During CSAI follow-up audits, manufacturers must provide records of the AEDM predicted

values and test records generated since the previous CSAI audit. CSAI staff shall review the test

records and compare test values to the AEDM predicted values. Discrepancies are brought to

the attention of the CSAI Senior Engineer responsible for the Program for determination of

additional testing or the adjustment of the range of motors for which the AEDM predicted values

are permitted to be used.

8.. As a part of the CSAI Motor Efficiency Verification Program we require annual requalification of

the manufacturers test facility. During this CSAI re-qualification audit at least one motor for

which both AEDM predicted values and manufacturer's re-test values are available, will be

selected for an audit test.

9. As stated previously, the range of motors covered in the initial application may be less than the

113 ratings. The manufacturer may request an expansion of his scope to cover additional ratings.

As a part of the subsequent evaluation of the new range to be covered at least two basic models

within the expanded range shall be examined following the above procedures.

EE-RM-96-400-CSA COMMENT 59