Robert K. Asdal, The Hydraulic Institute, Inc.
January 22, 2014
Significantly, HI believes that the data set collected by the DOE and its consultants is unrealistic and includes many pump product classifications that are currently regulated by other entities. It is HI’s view that forcing certain pumps—such as chemical processing, oil, gas and fire pumps—to meet efficiency DOE regulations would compromise their mechanical integrity, posing a danger to public health and safety. Well-established standards for such pumps—including American National Standards Institute (ANSI) B.73, American Petroleum Institute (API) 610 and National Fire Protection Association (NFPA) 20—address the unique characteristics and service of these pumps, which are not associated with pumping clean water (in the case of ANSI B.73 and API 610) or focused on the reliability needed for fire protection (NFPA 20)—in which case, such pumps are rarely used and only used in the event of a fire. These pumps will not be used for clean water service for many reasons, not the least of which is the higher cost associated with their unique designs.