We do not agree with the classification of Automatic Steam System Fault Detection and Diagnostics (FDD) as an
appropriate EE measure, and therefore discussions surrounding the proposed 15-year measure life are
irrelevant.
While FDD systems play a role in identifying failed steam traps more promptly than routine inspections might,
the mere presence of an alarm indicating a fault does not, in itself, guarantee energy savings. The critical factor
in realizing energy savings is the timely repair or replacement of the identified faulty traps. It is the action taken
in response to the FDD alarms—not the alarms themselves—that result in energy conservation.
In facilities that are common users of steam systems (such as refineries and hospitals), it is common practice to
conduct routine audits—often facilitated by steam trap manufacturers or site personnel—to identify and
replace failing steam traps. However, operational protocols often dictate that replacements are carried out on a
scheduled basis. This means that even if FDD systems detect a failed trap, the facility may wait until a significant
number of failures accumulate or until a scheduled shutdown to address these issues. The existence of FDD
systems, which may identify failures earlier, does not alter the frequency of these scheduled replacements,
thus not contributing to immediate energy savings.