CHAPTER 4. SCREENING ANALYSIS

TABLE OF CONTENTS

4.1 INTRODUCTION

........................................................................................................... 4-1 4.2 DISCUSSION OF TECHNOLOGY OPTIONS

.............................................................. 4-1 4.2.1 Screened-Out Technology Options

.................................................................................. 4-2 4.2.2 Remaining Design Options

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LIST OF TABLES

Table 4.2.1 Retained Design Options for Comm ercial Clothes Washers

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4-iCHAPTER 4. SCREENING ANALYSIS

4.1 INTRODUCTION
This chapter discusses the screening anal ysis conducted by the U.S. Department of Energy (DOE) of the technology options identified in the market and technology assessment for commercial clothes washers (CCWs) (chapter 3 of this final ru le technical support document (TSD)). In the market and technology assessment, DOE presented an ini tial list of technology options that can be used to reduce energy consumption of CCWs. The goal of the screening analysis is to identify any technologies that will be eliminated from further consideration in the rulemaking analyses. As described in section 1.3 of chapter 1 of this TSD, DOE is continuing the rulemaking for energy conservation standards fo r microwave oven standby power, and analyses related to these products will be published in a separate TSD. In addition, DOE issued a final rule adopting energy conservation standa rds for conventional cooking products ( i.e. , cooktops and ovens) and microwave oven energy factor (EF), and details of the analyses for these products are contained in the corr esponding final rule TSD.

The candidate technology options are assessed based on DOE analysis as well as inputs from interested parties including manufacturers, trade organizations, and energy efficiency advocates. Technology options that are judged to be viable approaches for improving energy efficiency are retained as inputs to the subseque nt engineering analysis, and are designated as design options. Technology options th at are not incorporated in commercial equipment or in working prototypes, or that fail to meet certain criteria as to pr acticability to manufacture, install and service, as to impacts on equi pment utility or availability, or as to health or safety will be eliminated from consideration in accordance with Energy Conservation Program for Consumer Products: Procedures for Consideration of New or Revised Energy Conservation Standards for Consumer Products . 61 FR 36974 (July 15, 1996). The rationale for either screening out or retaining each technology option is de tailed in the following sections.

4.2 DISCUSSION OF TECHNOLOGY OPTIONS

For CCWs, the screening criteria specified in section 4.1 were applie d to the technology options to either retain or eliminate each tec hnology from the engineeri ng analysis. DOE derived these by reviewing the technology options for re sidential clothes washers (RCWs) listed in chapter 3 of the 1997 Technical Support Document for Clothes Washers (1997 TSD). DOE believes that these technology options would likely apply to the current CCW rulemaking because the Energy Policy Act of 2005 (EPA CT 2005) (Pub. L. 109-58) amended the Energy Policy and Conservation Act (EPCA or the Act) of 1975 (42 U.S.C. 6291 et seq. ) to require that CCWs be rated with the same test procedur e established for RCWs. (42 U.S.C. 6314(a)(8))

4-14.2.1 Screened-Out Technology Options
The following section details the specific techno logy options that were screened out prior to the engineering analysis, along wi th the rationale for elimination.

The technologies identified in the market and technology assessment were evaluated pursuant to the criteria set out in EPCA. ( 42 U.S.C. 6311-6317) EPCA provides criteria for prescribing new or amended standards, which will achieve the maximum improvement in energy efficiency the Secretary of Energy determines is technologically feasible. (42 U.S.C. 6313(a)(6)(A)) It also establishes guidelines for determining whether a standard is economically justified. (42 U.S.C. 6313(a)(6)(B)) In view of the EPCA requirements for determining whether a standard is technologically feasible and economical ly justified, appendix A to subpart C of Title 10 Code of Federal Regula tions part 430 (10 CFR part 430), Procedures, Interpretations and Policies for Consideration of New or Revise d Energy Conservation Standards for Consumer Products (the Process Rule), sets forth procedur es to guide DOE in the consideration and promulgation of new or revised product ener gy conservation standard s under EPCA. These procedures elaborate on the statut ory criteria provided in 42 U.S.C. 6313 and in part eliminate problematic technologies early in the process of revising an en ergy conservation standard. Under the guidelines, before publis hing an advance notice of pr oposed rulemaking (ANOPR), DOE eliminates from consideration technologies that present unacceptable problems with respect to the following four factors:

(1) Technological feasibility. If it is determined that a technology has not been incorporated in commercial equipment or in working prototypes, then that technology will not be considered further.

(2) Practicability to manufacture, install, and service. If it is determined that mass production of a technology in commercial equipmen t and reliable installation and servicing of the technology could not be achieved on the scale n ecessary to serve the relevant market at the time of the effective date of the standard, then that technology will not be considered further.

(3) Impacts on equipment utility to consumers. If a technology is determined to have significant adverse impact on the utility of the equipment to significant subgroups of consumers, or results in the unavailability of any covered equipment type with performance characteristics (including reliability), features, size, capacities, and volumes that are substantially the same as equipment generally available in the United States at the time, it will not be considered further.

(4) Safety of technologies. If it is determined that a technology will have significant adverse impacts on health or safety, it will not be considered further.

Based on these factors, DOE screened out bubbl e action, electric disassociation of water, ozonated laundering, reduced thermal mass, suds saving, and ultrasonic washing for the reasons that follow.

4-2Bubble action

Although bubble washing has been incorporated into commercial equipment, production is extremely limited and further commercializat ion would require manufacturers to develop entirely new platforms. Therefore, DOE does not believe that this technology would be practicable to manufacture, instal l, and service on the scale n ecessary to serve the relevant market at the time of the effectiv e date of an amended standard.

Electric disassociation of water

Electric disassociation of water is in the rese arch stage, so DOE be lieves that it would not be practicable to manufacture, in stall and service this technology on the scale necessary to serve the relevant market at the time of the effective date of an ame nded standard. Also, because this technology is in the research stage, it is not possi ble to assess whether it will have any adverse impacts on equipment utility to consumers or equi pment availability, or any adverse impacts on consumers' health or safety.

Ozonated laundering

Ozonated laundering is in the research stag e, so DOE believes that it would not be practicable to manufacture, instal l and service this tec hnology on the scale necessary to serve the relevant market at the time of the effective da te of an amended standard. Also, because this technology is in the research stage, it is not possi ble to assess whether it will have any adverse impacts on equipment utility to consumers or equi pment availability, or any adverse impacts on consumers' health or safety.

Reduced thermal mass

Reduced thermal mass has not been incorporat ed into commercial equipment, so DOE believes that it would not be practicable to ma nufacture, install and se rvice this technology on the scale necessary to serve the relevant market at the time of the effective date of an amended standard. Also, because this technology has not been incorporated into clothes washers, it is not possible to assess whether it will have any advers e impacts on equipment utility to consumers or equipment availability, or any adverse im pacts on consumers' health or safety.

Suds saving

Suds-saving RCWs were previously commercia lly available, but re quired an adjacent wash tub to store suds in between wash cycl es. Due to these installation requirements, DOE believes that suds-saving clothes washers would be impractical to install in many locations. Suds-saving clothes washers reduce consumer utility by requiring consumers to occupy space adjacent to the washer with an additional wash tub. In a commercial setting, this may limit the number of clothes washers that may be instal led. In order to fully capture the energy saving benefits of suds saving, consumers must wash multiple loads of laundry sequentially. Delays between washing cycles allow the saved water to cool, reducing wash performance and energy

4-3savings. Finally, suds-saving washers can carry over heavy soiling between clothing loads, reducing wash performance as well. Therefor e, DOE will not consider suds saving as a technology option for improving the energy efficiency of CCWs.

Ultrasonic washing

Ultrasonic washing has been demonstrated in clothes washers, but the ultrasonic clothes washer did not adequately remove soil from the clothes. Ultrasonic clothes washing would therefore reduce consumer utility by not ade quately washing clothes. In addition, bubble cavitations caused by standing ultrasonic waves c ould potentially damage some fragile clothing or clothing fasteners, further reducing cons umer utility. Since no manufacturers currently produce ultrasonic clothes washers, it is impossibl e to assess whether it will have any impacts on consumer’s health or safety, or equipment availability.

4.2.2 Remaining Design Options
Table 4.2.1 lists the technology options for CCWs that were retained by DOE and subsequently designated as design options. Each of these technologies will be evaluated further in the subsequent engineering analysis.

Table 4.2.1 Retained Design Options for Commercial Clothes Washers

1. Adaptive control systems 2. Added insulation 3. Advanced agitation concepts for top-loading machines 4. Automatic water fill control 5. Direct-drive motor 6. Front-loading design with recirculation 7. Improved fill control 8. Improved front-loading-washer drum design 9. Improved water extraction to lower remaining moisture content 10. Increased motor efficiency 11. Low-standby-power el ectronic controls 12. Spray rinse or similar water-reducing rinse technology 13. Steam washing 14. Thermostatically controlled mixing valves 15. Tighter tub tolerance

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