1 January 20, 2015

Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, MS EE

- 5B 1000 Independence Avenue, S.W. Washington, D.C. 20585

- 0121

Re: Raypak Comments on the Preliminary Technical Support Document on Commercial Pack aged

Boilers

Docket No. EERE

– 2013

– BT

- STD

– 0030

Dear Ms. Edwards,

Raypak is a manufacturer of Commercial Boilers, Commercial Water Heaters, Residential Boilers, Gas Pool Heaters and Heat Pump Pool Heaters with facilities in Oxnard, CA and Ft. Myers, FL. We submit the following comments in response to the preliminary Technical Support Document (TSD) issued in the November 20, 2014 Federal Register and the Executive Summary of this analysis which included a list of questions and concerns related to the rul emaking on which DOE is seeking information or data.

General Comments:

Raypak is concerned that the lack of a finalized revised efficiency test procedure (as DOE indicated at the December 9, 2014 public meeting that it expected to issue the Notice of P roposed Rulemaking (NOPR) for revising the efficiency test procedures for commercial boilers sometime in the next few months and prior to the NOPR for this efficiency standard rulemaking) will adversely affect the ability of DOE (and all interested parties ) to properly evaluate potential efficiency standard changes. Raypak believes that DOE should NOT conduct these 2 potential rulemakings in parallel, but should decide if changes to the efficiency test procedure will be done and then finalize that rulemaki ng before embarking on energy standard changes. It is impossible to evaluate the effect that various design options might have on efficiency and energy savings if the test procedure changes. We no longer have a baseline efficiency model if changes in the test procedure adversely affect the measured efficiency. If this means that DOE must delay the efficiency standard rulemaking because of this conflict, it should be done.

Raypak understands that there is a newer 2012 Commercial Building Energy Consumpti on Survey (CBECS) that has not yet been officially published. The use of data from the CBECS is the critical component to the estimated annual energy consumption values used in this analysis. This rulemaking will be affecting boilers manufactured in 2019 and beyond and the advances in commercial building construction to reduce energy consumption will not be recognized if the 2003 CBECS data is used. The continued use of 2003 CBECS data will not properly present the energy use of commercial boilers being installed in 2019 and beyond. If this means that the DOE rulemaking must be delayed to await the official publication of the 2012 CBECS, it should be done.2 Comments on Executive Summary Questions:

Question #2

- DOE requests comment on the appropriatenes s of its tentative decision to classify CPBs into 16 equipment classes as described in Table ES.3.2.

Raypak believes that the current 10 equipment classes are appropriate. The addition of separate product classes for natural draft gas and oil boilers i s unnecessary as the industry has recognized that natural draft boilers have been a covered product under EPAct for the many years. There should be no question that natural draft commercial packaged boilers are covered equipment subject to the DOE’s effici ency standards.

Question #3

- DOE seeks comment on CPB standby mode and off mode energy consumption and, in particular, data on the magnitude of energy consumed in the different operational modes.

Raypak supports the preliminary finding that standby mo de and off mode energy consumption of commercial boilers is a very small percentage of the total boiler energy usage. The magnitude of the energy consumption as noted in the analysis at 0.02% of the total energy consumption is negligible and

we recommend that DOE not pursue the development of standby and off mode energy conservation standards for commercial packaged boilers.

Question #4

– DOE is interested in views regarding the technological and economic feasibility of the technology options which succes sfully passed the screening analysis. In particular, DOE seeks information regarding technology options which can be applied to improve the efficiency of natural draft

boilers.

Raypak generally agrees with the list of options that successfully passed the screening analysis in the TSD with the exception of pulse combustion. Pulse combustion is simply a boiler design that some manufacturers have chosen to pursue. It is no different than choosing a water

- tube versus fire

- tube design. This choice is just s omething that manufacturers chose when designing boilers for market use. Many of the options listed are already employed by manufacturers to attain their current efficiency ratings. DOE needs to be very careful in their assumptions that these can continu e to be increased to yield higher efficiency levels. Any additional restrictions of the heat exchanger MUST be balanced to ensure the safe operation and venting of the boiler. It is very possible that these design options have been

maximized and there is little or no opportunity to increase these beyond current ratings.

Question #8

- DOE welcomes suggestions and comments concerning its proposed approach to developing estimates of future commercial packaged boiler retail prices.

Raypak believes that th e approach to start with the cost of a mechanical draft model and subtract the cost of components that would not be employed on a natural draft model to estimate the price of a natural draft model is severely flawed. It does not account for different comp onents and construction that would be found on a natural draft models but which are not used on mechanical draft models. Examples include flue or vent dampers and draft hoods that are used on natural draft models but not mechanical draft

boilers. In add ition, the burner designs for natural draft boilers are significantly different than mechanical draft boilers and the cost differences cannot be estimated from this subtraction process. We encourage

DOE to contact contractors and others involved in sellin g and installing commercial boilers to obtain more information on retail prices for natural draft models. Raypak notes that the analysis currently extrapolates prices assuming a linear relationship between input rate and price. That assumption is

incorrec t. As boilers get larger in input, the cost of gas, burner and blower components is almost3 exponential. The volumes of these components is much smaller and more specialized with fewer manufacturers supplying these components and hence the prices are sign ificantly higher.

Question #10

- DOE seeks data on representative annual profiles of return water temperature, supply water temperature, and boiler percent loading.

Raypak notes that this information is unique to every boiler application, building desig n and engineering plans for building operation. In essence there is no such “typical” or “representative” profile that can be submitted. ASHRAE 90.1 is employed in building system requirements and as long as those minimums are met, anything else is a fu nction of the design.

Question #11

- DOE seeks data on what return water temperatures boilers are tested at under the test conditions prescribed by the DOE test procedure.

Raypak notes that the range of return water temperature ranges provided in the B TS

- 2000 standard are meant to address the wide range of ground water temperatures available throughout the year across the country. This allows manufacturers to test products without excessive and expensive means to heat/cool water for efficiency tests. Since this range of temperatures is available through the BTS

- 2000 standard, manufacturers will test at the temperature which provides the best results under the current test procedure.

Question #13

- DOE welcomes any data from interested parties about ty pical boiler sizing practices, including how often multiple boilers instead of a single boiler are installed to cover the building heating load, and how the number of boilers suitable for a specific installation is determined.

Raypak notes that there is no such thing as “typical” boiler sizing practice. As noted earlier in these comments, engineers, architects and designers are responsible for creating buildings the way the owner desires. However, Raypak believes that trends show that more buildings, ne w and existing, are being provided with multiple smaller boilers instead of a single larger boiler. Raypak believes that some of this trend is to allow for better system operation during the “shoulder months” of the year when a large boiler would be opera ting a very small part of the time, but would have many cycles. Using smaller boilers allows better load tracking for the system requirements. It should also be noted that ASHRAE 90.1

- 2013 now requires all boiler systems with an input rate of 1MM Btu/hr or more to have an input turndown ratio of at least 3:1. It goes on to note that this turndown ratio can be accomplished by the use of modulating or

multi

- stage boilers or by multiple single stage boilers.

Question #14

- DOE seeks input on how boilers are controlled, particularly in multiple

- boiler

installations.

Raypak notes that there are a variety of control systems used to control multi

- boiler systems. Some of these are provided by the boiler manufacturer. Some systems, such as building energy m anagement systems, are independent of the control system provided on the boiler. Raypak notes that an assumption used by DOE in the analysis involves that when multiple boilers are used on a job

– they are exactly the same type and size. This assumption is incorrect. Raypak is seeing much more of “Hybrid” type systems which include both condensing and non

- condensing boilers on the same system. This is to take advantage of condensing (when possible) and then use the non

- condensing at the height of the bo iler season when system temperatures may be much higher than normal due to outdoor reset functionality of controls. These systems also include the use of controls which know the return water temperature and bring on condensing boilers when possible to mai ntain the highest system efficiency.4 Question #15

- DOE seeks historical shipment

- weighted commercial packaged boiler efficiency data and/or shipment data by efficiency bins. DOE is primarily interested in data during the last 10 years in order to capture the impact of the most current technologies on the boilers market.

Raypak does not currently have the requested data, however, we make note that 10 years ago, Raypak had a single boiler system that was condensing. Today, we have 6 series of boilers tha t are condensing. This increase in demand for condensing boilers is due to market demands. It has nothing to do with minimum efficiency standards as set by DOE. The market is moving in the direction of more condensing boilers

because of the inferred ene rgy and cost savings. However, Raypak also is aware of many installations that have been installed with condensing boilers (due to rebates offered for installation of condensing boilers or the hopes of energy savings due to higher rated efficiencies), but the system temperatures will not allow condensing to take place and so the desired savings will never be fully realized. The use of condensing boilers can only realize the anticipated savings if the entire system is set up to work with the lower temperat ures required in condensing systems. DOE should be aware of this issue about installing condensing boilers without having a distribution system capable of properly operating with the lower boiler water temperatures as needed for condensing system to yield the maximum cost/energy savings. In replacement markets, replacing a non

- condensing boiler with a condensing boiler without making changes to the distribution system will yield little or no cost/energy savings.

Question #16

- DOE requests input on ancil lary energy use by commercial boilers (i.e., in addition to fuel energy use) that should be included in the energy use analysis.

The BTS

- 2000 test procedure does not account for electrical consumption in the measurement of Thermal Efficiency or Combustio n Efficiency, so there is no use in collecting this information. Also as noted earlier in these comments, the electrical consumption of commercial boilers (both standby and OFF mode electrical consumption as well as operating electrical consumption) is sm all in comparison to the gas/oil energy consumption of these commercial packaged boilers.

Question#17

- DOE seeks input on what fractions of hot

- water commercial packaged boilers are used both for space heating and hot water.

Although we have no specifi c data, Raypak believes that the fraction of hot

- water commercial packaged boilers used both for space heating and hot water is far less than the 50% assumed in the analysis. While this is very popular for residential condensing boilers in Europe and othe r parts of the world, this is not practiced very often in commercial boiler applications in the US. In addition, there is additional efficiency losses by running the boiler water through a heat exchanger to supply hot water and these losses can be mitigat ed by using separate water heating systems (either individual point

- of

- use or storage tank water heaters or large system water heaters with separate storage tanks). The one exception to this might be on steam systems where water heating can be provided as one of the zones.

Question #19

- DOE requests comment on frequency and cost of maintenance, major repair issues, repair frequency, and repair costs for commercial packaged boilers that meet the minimum efficiency standards, as well as for higher

- efficien cy boilers.

Raypak believes that the frequency and cost of maintenance, major repairs, etc. presented in the analysis may be representative of older technology boilers. However, newer technology boilers (condensing) requires a higher level of expertise from technicians, specialized equipment and hence a higher cost of service/repair. Additionally as noted earlier in these comments, DOE should not assume that there is a linear relationship between the size of the boiler and the costs of its components.5 Question #20

- DOE seeks input on how often boiler maintenance is performed by on

- site staff versus external contractors, specifically for hot water boilers versus steam boilers and small boilers versus large

boilers.

Raypak has no data on this, but we believe that the vast majority of maintenance/service is performed by manufacturer factory trained personnel due to the specialized equipment and expertise required to properly diagnose and repair current commercial packaged boilers. There may a list o f general maintenance items that can be accomplished on

– site (checking for blockages in vent/air intake, looking at burner flame and notifying service company if changes take place, maintaining and adjusting water quality as required, etc) but little else

.

Question #21

- DOE seeks input as to how often, in the event of a heat exchanger failure, the heat exchanger alone is replaced versus the entire boiler being replaced. DOE is interested in knowing whether this varies with equipment class or varies with condensing versus non

- condensing boilers.

Raypak has no reliable data to provide an answer for this. If a heat exchanger fails under warranty, the manufacturer would know whether it was replaced versus the entire boiler. However, for heat exchanger

fai lures out of warranty, the manufacturer has no knowledge of whether the heat exchanger was replaced or the boiler replaced. A replacement heat exchanger would show up simply in replacement parts orders and a replacement boiler would show up simply as a bo iler shipment.

Question #23

- DOE seeks input on how often plastic versus stainless steel venting is installed for condensing boilers.

Raypak notes that this decision is really a function of system design and boiler location. However, there

is a size l imit for plastic venting. When the required vent size is 8” or larger the vent is typically stainless steel because plastic vent materials (ULC S636 certified) are not readily available in these larger sizes. When the required vent size is 4” or smaller, plastic vent materials are often used. Sizes in between are really a function of the boiler system design, vent length, configuration, etc. The most economical vent materials are generally used in these intermediate sizes.

Question #24

- DOE seeks inpu t on how often boilers have direct venting, for both condensing and non

condensing boilers.

Raypak is confused as to why DOE is asking for this information. Direct venting has nothing to do with boiler efficiency. Many mechanical draft boilers and some natural draft boilers are designed to accommodate standard venting or direct venting depending on the installation requirements, but the manufacturer will have no idea as to the percentage installed either way. Raypak also has many boilers

which are desi gned for outdoor installation, so that is another venting configuration not addressed by

DOE.

Question #25

- DOE seeks input on the fraction of stainless steel venting in existing boiler installations by efficiency.

For existing installations of commerc ial boilers with efficiencies below condensing, stainless steel venting is rarely used. Stainless steel venting is much more costly than standard “B” vent which is used for most

non

- condensing boilers vented in Category I venting configurations. However, many boilers are designed for Category I if vented vertically and Category III if vented horizontally. In this case, stainless steel would be used for horizontal vented boilers in order to comply with categorization requirements for6 boilers. However, th e manufacturer has limited to no knowledge of the final installation and whether the boilers are vented vertically or horizontally.

Question #26

- DOE seeks input on where boilers are typically located within buildings and where the vents typically termin ate. DOE is interested in whether such placements change by geographic region or boiler type.

As noted previously in these comments, there is really no such thing as a “typical” boiler installation. Boilers can be located in the basement, mechanical roo m, penthouse or outdoors. In high

- rise buildings boilers are often located on intermediate floors because of other system limitations.

Question #27

- DOE seeks data on how often common venting occurs in multiple

- boiler installations and

whether commercia l water heaters are commonly vented with commercial boilers.

The National Fuel Gas Code (NFGC) addresses common venting of non

- condensing Category I equipment. When it comes to common venting of condensing boilers or other Category boilers), the

NFGC ca lls for “Engineered Vent Systems”. This requires a Registered Professional Engineer to sign off on the vent system design when combining multiple condensing boilers into a common vent. This adds cost for the design, PE stamp and equipment over and above the cost of the vent materials alone. Again, the boiler manufacturer does not know how often this occurs because they are generally not associated

with the end installation.

Question #28

- DOE seeks comments on the methodology used to determine equipmen t lifetimes for commercial packaged boilers.

Raypak notes that the assumption developed by DOE in the analysis of an average life of 24.8 years for

BOTH non

- condensing and condensing boilers is incorrect. There are two distinct classes of gas

commercial packaged boilers on the market today

- non

- condensing and condensing. While there is sufficient history to warrant determining an average life for non

- condensing boilers, there is insufficient history to make that determination for condensing boilers. C ondensing boilers have only been on the market for about 15 years, so to use an average life of 24.8 years in the analysis is unwarranted. Raypak believes that the average life of condensing boilers will be in the neighborhood of 15 years based on the

his tory that we have seen to date.

Question #31

- DOE requests data on the efficiency distribution and welcomes comment on the likelihood and degree of improvement in efficiency of commercial packaged boilers in the next 5 to 10 years as a result of market f orces or industry trends (in the absence of amended energy conservation standards).

Raypak does not have data available on the efficiency distribution as requested as previously noted in our comments to Question #15. However, we believe that the market will continue to push for condensing systems as a cost/energy saving opportunity. There will be little improvement in efficiency from current condensing boiler levels due to the fact that manufacturers are approaching max tech efficiency levels.

There wil l be other things that the marketplace will start using besides efficiency to decide between products available on the market. These include diagnostics information, communications, plug

- n

- play installation, system design and system efficiencies, etc. Ho wever, DOE also needs to be aware that non

condensing boilers are still a significant part of the market due to (1) simpler operation and maintenance, (2) higher design water temperature in the application that would not benefit from condensing boilers, (3 ) lower first cost and installed cost, (4) longer anticipated product life, (5) significant costs of retrofit to change to condensing boilers, among others. It is due to these and other concerns that Raypak would like7 to encourage DOE to maintain the atmo spheric or natural draft boiler classification and that efficiency levels are not adjusted to a level which would not be able to support this very important product classification. The largest part of the commercial packaged boiler market is replacement. Many of the existing installations are not suitable for condensing boilers and therefore the market needs to maintain

this classification of boilers.

Question #35

- DOE seeks input on the potential impact of amended standards on commercial packaged

boile r shipments.

Raypak believes that incremental increases in the standard are not likely to have significant effect on shipments. Large increases in the standard will likely result in lower shipments since more existing installations will choose to repair t he boiler rather than replace it when the existing boiler is not operating properly. This is particularly true if the large increase results in the elimination of the atmospheric,

natural draft classification of boilers.

Raypak appreciates this opportuni ty to provide comments and participate in this rulemaking. We will be open to discuss any of the comments presented here at your convenience.

Respectfully submitted,

Robert S. Glass Sr. Staff Engineer

R aypak, Inc., 2151 Eastman Avenue, Oxnard, CA 93030 (805) 278

- 5300 FAX (800) 872

- 9725 • www.r aypak.com