21580 Federal Register / Vol. 76, No. 73 / Friday, April 15, 2011 / Rules and Regulations 

DEPARTMENT OF ENERGY 

10 CFR Part 431 

[Docket No. EERE–2008–BT–TP–0014] 

RIN 1904–AB85 

Energy Conservation Program: Test 

Procedures for Walk-In Coolers and 

Walk-In Freezers 

AGENCY: Office of Energy Efficiency and 

Renewable Energy, Department of 

Energy. 

ACTION: Final rule. 

SUMMARY: On January 4, 2010, the U.S. 

Department of Energy (DOE) issued a 

notice of proposed rulemaking (January 

2010 NOPR) to establish new test 

procedures for walk-in coolers and 

walk-in freezers (WICF or walk-ins). On 

September 9, 2010, DOE issued a 

supplemental notice of proposed 

rulemaking (September 2010 SNOPR) to 

propose changes to the test procedures 

that it proposed in the NOPR. Those 

proposed rulemakings serve as the basis 

for today’s action. DOE is issuing a final 

rule that establishes new test procedures 

for measuring the energy efficiency of 

certain walk-in cooler and walk-in 

freezer components including panels, 

doors, and refrigeration systems. These 

test procedures will be mandatory for 

product testing to demonstrate 

compliance with energy standards that 

DOE is establishing in a separate, but 

concurrent rulemaking, and for 

representations starting 180 days after 

publication. This final rule incorporates 

by reference industry test procedures 

that, along with calculations established 

in the rule, can be used to measure the 

energy consumption or performance 

characteristics of certain components of 

walk-in coolers and walk-in freezers. 

Additionally, the final rule clarifies the 

definitions of ‘‘Display door,’’ ‘‘Display 

panel,’’ ‘‘Door,’’ ‘‘Envelope,’’ ‘‘K-factor,’’ 

‘‘Panel,’’ ‘‘Refrigerated,’’ ‘‘Refrigeration 

system,’’ ‘‘U-factor,’’ ‘‘Automatic door 

opener/closer,’’ ‘‘Core region,’’ ‘‘Edge 

region,’’ ‘‘Surface area,’’ ‘‘Rating 

condition,’’ and ‘‘Percent time off’’ as 

applicable to walk-in coolers and walkin freezers. 

DATES: The effective date of this rule is 

May 16, 2011. The final rule changes 

will be mandatory for product testing 

starting October 12, 2011. 

The incorporation by reference of 

certain publications listed in this rule 

was approved by the Director of the 

Federal Register on May 16, 2011. 

ADDRESSES: The public may review 

copies of all materials related to this 

rulemaking at the U.S. Department of 

Energy, Resource Room of the Building 

Technologies Program, 950 L’Enfant 

Plaza, SW., Suite 600, Washington, DC 

(202) 586–2945, between 9 a.m. and 

4 p.m., Monday through Friday, except 

Federal holidays. Please contact Ms. 

Brenda Edwards at the above telephone 

number, or by e-mail at 

Brenda_Edwards@ee.doe.gov, for 

additional information regarding 

visiting the Resource Room. 

Docket: The docket is available for 

review at regulations.gov, including 

Federal Register notices, framework 

documents, public meeting attendee 

lists and transcripts, comments, and 

other supporting documents/materials. 

All documents in the docket are listed 

in the regulations.gov index. However, 

not all documents listed in the index 

may be publicly available, such as 

information that is exempt from public 

disclosure. 

A link to the docket web page can be 

found at: http://www1.eere.energy.gov/ 

buildings/appliance_standards/ 

commercial/wicf.html. This web page 

will contain a link to the docket for this 

notice on the regulations.gov site. The 

regulations.gov web page will contain 

simple instructions on how to access all 

documents, including public comments, 

in the docket. 

FOR FURTHER INFORMATION CONTACT: 

Mr. Charles Llenza, U.S. Department of 

Energy, Office of Energy Efficiency 

and Renewable Energy, Building 

Technologies Program, EE–2J, 1000 

Independence Avenue, SW., 

Washington, DC 20585–0121. 

Telephone: (202) 586–2192. E-mail: 

Charles.Llenza@ee.doe.gov. 

Mr. Michael Kido, U.S. Department of 

Energy, Office of the General Counsel, 

GC–71, 1000 Independence Avenue, 

SW., Washington, DC 20585–0121. 

Telephone: (202) 586–8145. E-mail: 

Michael.Kido@hq.doe.gov or Ms. 

Elizabeth Kohl, U.S. Department of 

Energy, Office of the General Counsel, 

GC–71, 1000 Independence Avenue, 

SW., Washington, DC 20585–0121. 

Telephone: (202) 586–7796. E-mail: 

Elizabeth.Kohl@hq.doe.gov. 

SUPPLEMENTARY INFORMATION: This final 

rule incorporates by reference into 

subpart R of Title 10, Code of Federal 

Regulations, part 431 (10 CFR part 431), 

the following industry standards: 

(1) AHRI 1250 (I–P)–2009, ‘‘2009 

Standard for Performance Rating of 

Walk-In Coolers and Freezers,’’ 

approved 2009. 

(2) ASTM C1363–05, ‘‘Standard Test 

Method for Thermal Performance of 

Building Materials and Envelope 

Assemblies by Means of a Hot Box 

Apparatus,’’ approved May 1, 2005. 

(3) DIN EN 13164:2009–02, ‘‘Thermal 

insulation products for buildings— 

Factory made products of extruded 

polystyrene foam (XPS)—Specification,’’ 

approved February 2009. 

(4) DIN EN 13165:2009–02, ‘‘Thermal 

insulation products for buildings— 

Factory made rigid polyurethane foam 

(PUR) products—Specification,’’ 

approved February 2009. 

(5) NFRC 100–2010[E0A1], 

‘‘Procedure for Determining Fenestration 

Product U-factors,’’ approved 2010. 

Copies of ASTM standards can be 

obtained from ASTM International, 100 

Barr Harbor Drive, West Conshohocken, 

PA 19428–2959, (610) 832–9585, or 

http://www.astm.org. 

Copies of AHRI standards can be 

obtained from AHRI. Air-Conditioning, 

Heating and Refrigeration Institute, 2111 

Wilson Boulevard, Suite 500, Arlington, 

VA 22201, (703) 600–0366, or http:// 

www.ahrinet.org. 

Copies of DIN EN standards can be 

obtained from CEN. European 

Committee for Standardization (French: 

Norme or German: Norm), Avenue 

Marnix 17, B–1000 Brussels, Belgium, 

Tel: + 32 2 550 08 11, Fax: + 32 2 550 

08 19 or http://www.cen.eu. 

Copies of NFRC standards can be 

obtained from NFRC. National 

Fenestration Rating Council, 6305 Ivy 

Lane, Ste. 140, Greenbelt, MD 20770, 

(301) 589–1776, or http://www.nfrc.org. 

You can also view copies of these 

standards at the U.S. Department of 

Energy, Resource Room of the Building 

Technologies Program, 950 L’Enfant 

Plaza, SW., 6th Floor, Washington, DC 

20024, (202) 586–2945, between 9 a.m. 

and 4 p.m., Monday through Friday, 

except Federal holidays. 

Table of Contents 

I. Authority and Background 

II. Summary of the Final Rule 

III. Discussion 

A. Overall Approach: Component-Based 

Testing 

1. Test Metrics 

2. Responsibility for Testing and 

Compliance 

3. Basic Model 

B. Test Procedures for Envelope 

Components 

1. Definition of Envelope 

2. Heat Transfer Through Panels 

3. Energy Use of Doors 

4. Heat Transfer via Air Infiltration 

5. Electrical Components 

C. Test Procedures for Refrigeration 

Systems 

1. Definition of Refrigeration System 

2. Refrigeration Test Procedure: AHRI 1250 

(I–P)–2009 

3. Alternative Efficiency Determination 

Method 

D. Other Issues—Definition of Walk-In 

Cooler or Freezer 


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Federal Register / Vol. 76, No. 73 / Friday, April 15, 2011 / Rules and Regulations 21581 

IV. Procedural Issues and Regulatory Review 

A. Review Under Executive Order 12866 

B. Review Under the Regulatory Flexibility 

Act 

1. Statement of the Need for, and 

Objectives of, the Rule 

2. Summary of the Significant Issues 

Raised by the Public Comments, DOE’s 

Response to These Issues, and Any 

Changes Made in the Proposed Rule as 

a Result of Such Comments 

3. Description and Estimated Number of 

Small Entities Regulated 

4. Description and Estimate of Compliance 

Requirements and Description of Steps 

To Minimize the Economic Impact on 

Small Entities 

C. Review Under the Paperwork Reduction 

Act of 1995 

D. Review Under the National 

Environmental Policy Act of 1969 

E. Review Under Executive Order 13132 

F. Review Under Executive Order 12988 

G. Review Under the Unfunded Mandates 

Reform Act of 1995 

H. Review Under the Treasury and General 

Government Appropriations Act, 1999 

I. Review Under Executive Order 12630 

J. Review Under Treasury and General 

Government Appropriations Act, 2001 

K. Review Under Executive Order 13211 

L. Review Under Section 32 of the Federal 

Energy Administration Act of 1974 

M. Congressional Notification 

N. Approval of the Office of the Secretary 

I. Authority and Background 

Title III of the Energy Policy and 

Conservation Act (42 U.S.C. 6291–6317; 

‘‘EPCA’’ or, ‘‘the Act’’) sets forth a variety 

of provisions designed to improve 

energy efficiency. (All references to 

EPCA refer to the statute as amended 

through the Energy Independence and 

Security Act of 2007 (EISA 2007), Public 

Law 110–140 (Dec. 19, 2007)). Part C of 

Title III (42 U.S.C. 6311–6317), which 

was subsequently redesignated as Part 

A–1 for editorial reasons, establishes an 

energy conservation program for certain 

industrial equipment. This includes 

walk-in coolers and walk-in freezers, the 

subject of today’s notice. (42 U.S.C. 

6311(1), (20), 6313(f), and 6314(a)(9)) 

Under EPCA, this program consists 

essentially of three parts: (1) Testing, (2) 

labeling, and (3) Federal energy 

conservation standards. The testing 

requirements consist of test procedures 

that manufacturers of covered products 

or equipment must use (1) as the basis 

for certifying compliance with the 

applicable energy conservation 

standards adopted under EPCA, and (2) 

for making representations about the 

efficiency of those products. Similarly, 

DOE must use these test requirements to 

determine whether the products comply 

with any relevant standards 

promulgated under EPCA. 

Section 312 of the Energy 

Independence and Security Act of 2007 

(‘‘EISA 2007’’) amended EPCA by adding 

certain equipment to this energy 

conservation program, including walkin coolers and walk-in freezers 

(collectively ‘‘walk-in equipment,’’ 

‘‘walk-ins,’’ or ‘‘WICF.’’). (42 U.S.C. 

6311(1), (20), 6313(f), and 6314(a)(9)) As 

amended by EISA 2007, EPCA requires 

DOE to establish new test procedures to 

measure the energy use of walk-in 

coolers and walk-in freezers. (42 U.S.C. 

6314(a)(9)(B)(i)) The new test 

procedures for WICF equipment are the 

subject of this rulemaking. EPCA also 

directs DOE to publish performancebased standards and promulgate 

labeling requirements (42 U.S.C. 

6313(f)(4)(A) and 42 U.S.C. 6315(e), 

respectively). These actions will be 

covered in separate rulemakings. 

In the notice of proposed rulemaking 

published January 4, 2010 (January 2010 

NOPR or, in context, NOPR), DOE 

proposed to establish test procedures to 

measure the energy efficiency of walkin coolers and freezers. 75 FR 186. DOE 

identified several issues in its proposal 

based on the public comments 

submitted in response to the January 

2010 NOPR and further research. These 

issues included: (1) The proposed 

definition of a walk-in cooler or freezer 

with regards to the upper temperature 

limit; (2) the proposal to create test 

procedures for the envelope and 

refrigeration system of a walk-in cooler 

or freezer; (3) the proposal to group 

walk-in envelopes and refrigeration 

systems with essentially identical 

construction methods, materials, and 

components into a single basic model; 

and (4) the proposed calculation 

methodology for determining the energy 

consumption of units within the same 

basic model. 75 FR 186, (Jan. 4, 2010). 

On March 1, 2010, DOE held a public 

meeting to receive comments, data, and 

information on the January 2010 NOPR. 

Through their comments, interested 

parties raised significant issues and 

suggested changes to the proposed test 

procedures. DOE determined that some 

of these comments warranted further 

consideration and published a 

supplemental notice of proposed 

rulemaking on September 9, 2010 

(September 2010 SNOPR or, in context, 

SNOPR). 75 FR 55068. DOE received 22 

written comments on the September 

2010 SNOPR. This final rule addresses 

comments from the January 2010 NOPR 

that were not addressed in the 

September 2010 SNOPR and comments 

received on the September 2010 

SNOPR. 

General Test Procedure Rulemaking 

Process 

Under 42 U.S.C. 6314, EPCA sets forth 

the criteria and procedures DOE must 

follow when prescribing or amending 

test procedures for covered equipment. 

EPCA provides that test procedures 

‘‘shall be reasonably designed to 

produce test results which reflect energy 

efficiency, energy use and estimated 

annual operating costs of a type of 

industrial equipment (or class thereof) 

during a representative average use 

cycle as determined by the Secretary [of 

Energy], and shall not be unduly 

burdensome to conduct.’’ (42 U.S.C. 

6314(a)(2)) 

Additionally, EPCA notes that if the 

procedure determines estimated annual 

operating costs, the procedure ‘‘shall 

provide that such costs shall be 

calculated from measurements of energy 

use in a representative average use cycle 

(as determined by the Secretary), and 

from representative average-unit costs of 

the energy needed to operate such 

equipment during such cycle.’’ (42 

U.S.C. 63114(a)(3)) Further, the statute 

provides that DOE ‘‘shall provide 

information to manufacturers of covered 

equipment respecting representative 

average unit costs of energy.’’ Id. 

With respect to today’s rulemaking, 

the test procedure DOE is prescribing 

today is a new test procedure. Today’s 

rule establishes a comprehensive testing 

regime to ensure minimum levels of 

performance by applying the 

component-based approach detailed in 

EISA 2007. The separate but concurrent 

energy conservation standards 

rulemaking for walk-in coolers and 

walk-in freezers will be based on the 

performance of walk-in coolers and 

walk-in freezers as measured by the test 

procedure set forth in this final rule. 

II. Summary of the Final Rule 

Today’s final rule establishes a new 

test procedure for measuring the energy 

efficiency of walk-in cooler and walk-in 

freezer equipment. The test procedure is 

essentially composed of tests for the 

principal components that make up a 

walk-in: Panels, doors, and refrigeration. 

Testing individual components of walkin coolers and walk-in freezers is 

simpler and less burdensome to 

manufacturers than testing an entire 

walk-in. In this test procedure, DOE also 

provides a method for calculating the 

energy use of an entire envelope, or the 

efficiency of a refrigeration system, 

based on the results of the component 

tests. 

The test procedure incorporates by 

reference the industry test procedures 

ASTM C1363–05, ‘‘Standard Test 


srobinson on DSKHWCL6B1PROD with RULES3
21582 Federal Register / Vol. 76, No. 73 / Friday, April 15, 2011 / Rules and Regulations 

Method for Thermal Performance of 

Building Materials and Envelope 

Assemblies by Means of a Hot Box 

Apparatus,’’DIN EN 13164:2009–02, 

‘‘Thermal insulation products for 

buildings—Factory made products of 

extruded polystyrene foam (XPS)— 

Specification,’’ DIN EN 13165:2009–02, 

‘‘Thermal insulation products for 

buildings—Factory made rigid 

polyurethane foam (PUR) products— 

Specification,’’ NFRC 100–2010[E0A1], 

‘‘Procedure for Determining Fenestration 

Product U-factors,’’ and AHRI 1250 (I– 

P)–2009, ‘‘2009 Standard for 

Performance Rating of Walk-In Coolers 

and Freezers.’’ 

Concurrently, DOE is undertaking an 

energy conservation standards 

rulemaking to address the statutory 

requirement to establish performance 

standards for walk-in equipment by 

2012. (42 U.S.C. 6313(f)(4)(A)) DOE will 

use this test procedure in the concurrent 

process of evaluating potential 

performance standards for the 

equipment. After the compliance date of 

the performance standards, this walk-in 

cooler and walk-in freezer test 

procedure, along with any future 

statistical sampling plans that may be 

adopted, must be used by manufacturers 

to determine compliance with the 

standards, and by DOE to ascertain 

compliance with the standards in any 

enforcement action. Moreover, once any 

final test procedure is effective, any 

representation of the energy use of walkin equipment or components must 

reflect the results of testing that 

equipment using the test procedure. 

III. Discussion 

In this section, DOE describes the 

overall approach it followed in 

developing today’s test procedure for 

walk-in cooler and freezer equipment, 

including envelope components and 

refrigeration systems. The following 

section also addresses issues raised by 

interested parties, which consisted of 

the following entities: 

• Manufacturers: American Panel, 

Craig Industries, CrownTonka, Heatcraft 

Refrigeration Products (Heatcraft), Hill 

Phoenix, International Cold Storage 

(ICS), Kysor Panel Systems (Kysor 

Panel), Manitowoc, Master-Bilt, Owens 

Corning, Nor-Lake, ThermalRite, 

Thermo-Kool, and Zero Zone; 

• Material suppliers: Carpenter 

Company (Carpenter); 

• Trade associations: AHRI, Center 

for the Polyurethanes Industry (CPI); 

• Utility companies: Pacific Gas & 

Electric Company (PG&E), Southern 

California Edison (SCE), Sacramento 

Municipal Utility District (SMUD), and 

San Diego Gas and Electric (SDG&E); 

• Advocacy groups: Appliance 

Standards Awareness Project (ASAP), 

Alliance to Save Energy (ASE), 

American Council for an EnergyEfficient Economy (ACEEE), Natural 

Resources Defense Council (NRDC), 

Northeast Energy Efficiency 

Partnerships (NEEP), and Northwest 

Energy Efficiency Alliance (NEEA); 

• Other parties: Oak Ridge National 

Laboratory (ORNL), and the Small 

Business Administration (SBA). 

A. Overall Approach: Component-Based 

Testing 

In the framework document, DOE 

contemplated developing a single test 

for an entire walk-in cooler or freezer. 

See http://www1.eere.energy.gov/ 

buildings/appliance_standards/ 

commercial/pdfs/ 

wicf_framework_doc.pdf. However, 

feedback from interested parties 

indicated that a single test procedure for 

the entire WICF would not be practical 

because many walk-ins are assembled 

on site with components from different 

manufacturers, which would make onsite testing infeasible. DOE then 

proposed in the January 2010 NOPR and 

September 2010 SNOPR to develop 

separate tests for the envelope and 

refrigeration system of a walk-in, which 

in aggregate would represent the 

performance of the entire walk-in (75 FR 

186, 191 (Jan. 4, 2010) and 75 FR 55068, 

55070 (Sept. 9, 2010)). DOE proposed to 

have one metric for the refrigeration 

system, which would be an efficiency 

metric, and one metric for the envelope, 

which would be an energy use metric. 

The envelope metric would account for 

electrical use of envelope components, 

as well as any energy used by the 

refrigeration system to reject the heat 

contributed by conduction, infiltration, 

and other heat sources. In this way, DOE 

intended to capture the energy impact of 

components, such as panels, that do not 

themselves consume electricity. 

DOE received comments on the 

September 2010 SNOPR from interested 

parties stating that the walk-in cooler 

and walk-in freezer main components 

could be further broken down into their 

own constituent components: panels 

and doors of envelopes and unit coolers 

and condensing units of refrigeration 

systems. Commenters explained that all 

of these components could be produced 

by separate manufacturers and then 

assembled into a complete walk-in. 

Because of this situation, it would be 

difficult to determine who should test 

the walk-in envelope, the refrigeration 

system, or both. It would also be 

difficult to determine who would be 

best positioned to ensure the walk-in 

cooler or freezer complied with an 

energy conservation standard. DOE 

acknowledges these and similar 

concerns from the stakeholders. 

Based on the information provided by 

commenters and DOE’s own research, 

DOE has determined that a componentbased approach would address the 

unique challenges posed in regulating 

the energy efficiency performance of 

walk-in envelopes. As noted above, 

these challenges include the fact that 

walk-in units are frequently assembled 

using components made by multiple 

manufacturers, and walk-in installers 

may not be equipped to test all the 

components that comprise a walk-in. 

These factors indicate that a componentbased approach would not only help 

ensure compliance with whatever 

energy conservation standards that DOE 

sets, but also reduce the overall testing 

burden on the manufacturers, including 

small businesses who are involved in 

producing walk-in units, either in full or 

in part. 

Moreover, DOE notes that the 

adoption of such an approach is 

consistent with the component-based 

approach that Congress took when it 

enacted EISA 2007. Thus, DOE is 

adopting a component-level approach 

for this rule and discusses the specific 

component metrics in greater detail in 

section III.A.1. 

1. Test Metrics 

As stated previously, DOE initially 

proposed separate test procedures for 

envelopes and refrigeration systems of 

walk-ins along with different test 

metrics for each. The metric for the 

refrigeration system would be an 

efficiency metric, and the metric for the 

envelope would be an energy use metric 

that would account for the electrical use 

of envelope components and the energy 

used by the refrigeration system to reject 

the heat contributed by conduction, 

infiltration, and other heat sources. To 

account for different sizes of envelopes, 

DOE further proposed that the result of 

the envelope test procedure should be a 

normalized energy use metric—the total 

energy use divided by the external 

surface area of the envelope (energy use 

per square foot). 

Several interested parties disagreed 

with the proposed metrics. NEEA stated 

that regulating walk-in coolers and 

walk-in freezers on the basis of annual 

energy use would not accurately 

estimate actual energy use, and 

therefore such estimates would be 

misleading for almost all installed 

systems. NEEA suggested using an 

overall U-value for the entire envelope 

and a spreadsheet that calculates the 

overall U-factor of a walk-in by 

weighted area. (NEEA, No. 0061.1 at 


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Federal Register / Vol. 76, No. 73 / Friday, April 15, 2011 / Rules and Regulations 21583 

p. 1 and 9; NEEA, No. 0061.2 at p. 1) 

(In this and subsequent citations, the 

document number refers to the number 

of the comment in the Docket for the 

DOE rulemaking on test procedures for 

walk-in coolers and freezers, Docket No. 

EERE–2008–BT–TP–0014; and the page 

references refer to the place in the 

document where the statement 

preceding appears.) NRDC also 

disagreed with the annual energy use 

metric because of the number of 

assumptions that would be required and 

the potential to confuse customers. 

(NRDC, No. 0064.1 at p. 7) NRDC further 

stated that normalizing energy use to the 

surface area would be unusual and may 

not be useful. (NRDC, No. 0064.1 at p. 

2) NEEA suggested that the envelope 

metric should be a U-factor (which is a 

characterization of the heat loss 

performance). (NEEA, No. 0061.1 at p. 

7) A comment submitted jointly by SCE, 

SDG&E, PG&E, and SMUD, hereafter 

referred to as the Joint Utilities, 

suggested an area-based conductance 

metric for the envelope that would 

consider both opaque and transparent 

surfaces. (The Joint Utilities, No. 0059.1 

at p. 2) NRDC also suggested a metric for 

refrigeration systems that would 

encompass the total equivalent warming 

impact and measure the heat loads from 

refrigeration systems impacting a 

building’s heating, ventilation, and air 

conditioning (HVAC) system. (NRDC, 

No. 0064.1 at p. 8) A comment 

submitted jointly by ACEEE, ASAP, 

ASE, NRDC, NEEP, and NEEA on the 

September 2010 SNOPR (hereafter 

referred to as The Joint SNOPR 

comment) stated that the energy 

conservation standard for envelopes 

should be the overall heat gain (Uoverall) with separate standards for 

walk-in coolers and walk-in freezers. 

(Joint SNOPR Comment, No. 0074.1 at 

p. 2) 

While other interested parties 

suggested specific metrics for walk-in 

components, manufacturers also offered 

suggestions for overall walk-in metrics. 

Craig Industries recommended 

combining the envelope and 

refrigeration calculations to calculate 

the overall efficiency of the complete 

walk-in system and labeling each walkin with that efficiency metric. (Craig, 

No. 0068.1 at p. 6) Zero Zone stated that 

the test procedure should include 

performance testing to verify adequate 

temperatures inside the walk-in. (Zero 

Zone, No. 0077.1 at p. 1) 

In view of the component-level 

approach being adopted today, DOE is 

not establishing an overall energy use 

metric for the envelope in this test 

procedure. Instead, DOE is establishing 

separate metrics for the individual 

components of the walk-in: the wall and 

ceiling panels (hereafter referred to as 

non-floor panels); floor panels; the 

display and non-display doors; and the 

refrigeration system. Regarding Zero 

Zone’s suggestion that the procedure 

verify that adequate internal 

temperatures are used in evaluating a 

walk-in unit’s efficiency, DOE does not 

believe that such a requirement is 

necessary in light of the componentbased approach being adopted today. 

The panel metric determined by the 

test procedure accounts for the 

conductance and is in terms of U-factor 

(that is, the thermal transmittance) 

measured in Btu/h-ft2-°F, as NEEA, the 

Joint SNOPR Comment, and the Joint 

Utilities recommended. The metric for 

display and non-display doors accounts 

for the thermal transmittance through 

the door and the electricity use of any 

electrical components associated with 

the door, and is in terms of energy use, 

measured in kWh/day. DOE believes 

that requiring separate metrics for 

specific individual walk-in components 

does not constitute a substantive change 

from what was proposed in the 

September 2010 SNOPR because this 

Final Rule only requires tests that were 

proposed for components in the 

September 2010 SNOPR. Also, the 

September 2010 SNOPR and this final 

rule contain similar calculation 

methodologies. 

2. Responsibility for Testing and 

Compliance 

DOE proposed to adopt separate tests 

for the envelope and refrigeration 

system of a walk-in and require the 

manufacturers of each to test and certify 

the part they manufacture. 75 FR 186, 

191 (Jan. 4, 2010) and 75 FR 55068, 

55070 (Sept. 9, 2010). In response to this 

proposed approach, DOE received 

multiple comments regarding who 

should assume testing, certification, and 

compliance responsibilities. The Joint 

SNOPR Comment recommended that 

DOE focus on factory-produced 

products (i.e. kits) instead of walk-ins 

that are assembled on-site from 

components from different 

manufacturers. (Joint SNOPR Comment, 

No. 0074.1 at p. 1) The Joint SNOPR 

Comment further suggested that panel, 

refrigeration system, and door 

manufacturers each be responsible for 

compliance and certification 

responsibilities for their own products. 

(Joint SNOPR Comment, No. 0074.1 at 

pp. 2–3) Thermo-Kool agreed with this 

approach and submitted a copy of a 

regulatory framework proposed by 

NEEA, in which envelope, door, and 

refrigeration manufacturers would be 

responsible for testing and complying 

with the standards for the components 

they manufacture. (Thermo-Kool, No. 

0072.1 at p. 1) 

DOE received several other comments 

which it summarized in the 

certification, compliance, and 

enforcement (CCE) final rule, published 

on March 7, 2011. 76 FR 12422, 12444. 

In brief, some of those comments agreed 

with the approach suggested by the Joint 

SNOPR Comment and Thermo-Kool that 

individual component manufacturers 

should test, certify, and ensure 

compliance of their respective 

components. Other commenters 

recommended that the manufacturer, 

the assembler, or the system designer of 

the overall walk-in should be 

responsible for the compliance of the 

walk-in with the standards. 76 FR 

12442–12446. 

In the CCE final rule, DOE addressed 

these comments by defining the 

manufacturer of a walk-in at 10 CFR 

431.302. 76 FR 12504. 

The definition extends the 

compliance responsibility to both the 

component manufacturer and the 

assembler. In the CCE final rule, DOE 

clarified that component manufacturers 

would be the entity responsible for 

certifying compliance of the 

components they manufacture for walkin applications and ensuring 

compliance with the applicable Federal 

standards of those components. 

Assemblers of the complete walk-in 

system are required to use only 

components that are certified to meet 

the applicable Federal standards. DOE 

also adopted a flexible enforcement 

framework in which it will determine 

who is responsible for noncompliance 

on a case-by-case basis. 76 FR 12444. 

DOE notes that the provisions and 

clarifications in the CCE final rule were 

made in the context of component 

manufacturers certifying their 

components to the existing standards in 

EPCA, which prescribe requirements on 

a component-level basis. DOE has 

decided to continue this approach in 

developing test procedures and 

performance-based standards for walkin coolers and freezers. DOE believes 

that, within the very limited context of 

walk in equipment, EPCA created a 

means for DOE to set performance-based 

standards for certain walk-in component 

manufacturers. In particular, because 

Congress set requirements for specific 

components used in walk-in 

applications, it provided DOE with the 

implicit authority to set performancebased standards at the component level 

for these specific components. This 

unique ability stems from the manner in 

which Congress set standards for walkin equipment by prescribing, among 


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other things, specific performance-based 

requirements for wall, ceiling, door, and 

floor insulation panels used in walk-ins. 

See 42 U.S.C. 6313(f). 

Because interested parties, including 

entities who produce these components 

and are subject to today’s requirements, 

have indicated to DOE that the energy 

efficiency performance of WICF 

components would be most readily and 

easily tested and certified by component 

manufacturers, DOE intends to take this 

approach for WICF test procedures and 

performance standards. DOE 

acknowledges the numerous difficulties 

that commenters have noted with 

alternative proposed approaches. By 

requiring individual component 

manufacturers to certify that their 

components satisfy specified 

performance-based standards, DOE can 

ease the overall burden on walk-in 

manufacturers relative to the 

alternatives that were under 

consideration as part of the January 

2010 NOPR and September 2010 

SNOPR. Therefore, in this test 

procedure, DOE is establishing tests for 

the components of a walk-in (i.e. panels, 

doors, and refrigeration systems) and 

anticipates that component 

manufacturers will test their equipment 

using the applicable procedure and, in 

the future, will certify that they comply 

with the appropriate standard. DOE 

emphasizes that until performance 

standards are established, 

manufacturers are not required to use 

this test procedure to certify equipment 

to DOE (although they must use this test 

procedure in making representations as 

to the performance of their 

components). However, because the 

prescriptive standards established by 

the 2007 amendments to EPCA are 

already in effect, manufacturers must 

demonstrate compliance with them 

using the method specified in the CCE 

final rule. 76 FR 12422. 

3. Basic Model 

DOE proposed a definition of basic 

model for both envelopes and 

refrigeration systems. 75 FR 186, 188– 

189 (Jan. 4, 2010) and 75 FR 55068, 

55071–55073 (Sept. 9, 2010). DOE 

received comments from interested 

parties on the definition and 

summarized them in the CCE final rule. 

76 FR 12422. Consistent with its 

component-level approach to 

certification, discussed in section 

III.A.2, and taking the comments from 

interested parties into consideration, 

DOE decided to define a basic model for 

each of the key components of a walkin, rather than defining a basic model 

for the entire walk-in. DOE emphasized 

that although the term ‘‘basic model’’ is 

defined on the component level, it is 

still implemented in the same manner 

as it is in the rest of DOE’s appliance 

standards program; that is, a basic 

model consists of equipment that is 

essentially the same with respect to 

energy consumption, efficiency, or other 

measure of performance. 76 FR 12444– 

12446. 

DOE provided, in relevant part, the 

definition of basic model in the CCE 

final rule at 76 FR 12504 (providing 

definition of ‘‘basic model’’ for walk-ins) 

(to be codified at 10 CFR 431.302). 

DOE believes applying the basic 

model concept at the component level 

will reduce the testing burden on 

manufacturers while ensuring that their 

products meet any applicable standard, 

because it removes the difficulty of 

testing and/or certifying different sized 

walk-ins that would have different 

energy consumption levels. 76 FR 

12445. The CCE final rule provides that 

manufacturers may elect to group 

individual models into basic models at 

their discretion to the extent the models 

have essentially identical characteristics 

that affect energy efficiency or energy 

consumption. Manufacturers may also 

rate models conservatively—i.e. the 

tested performance of the model(s) must 

be at least as good as the certified 

rating—after applying the appropriate 

sampling plan. 76 FR 12429. The basic 

model concept is applied slightly 

differently to panels, doors, and 

refrigeration systems because of their 

different characteristics. These 

differences are explained below. 

a. Basic Model of Panels 

Panels are construction components 

that are not doors and that are used to 

construct the envelope of the walk-in. 

These components comprise the 

elements separating the interior 

refrigerated environment of the walk-in 

from the exterior environment. In this 

test procedure, panels are classified as 

either floor panels, non-floor panels, or 

display panels. A display panel is a 

panel that is entirely or partially 

comprised of glass, a transparent 

material, or both and is used for display 

purposes. Floor and non-floor panels are 

mostly comprised of insulating material 

and are not primarily used for display 

purposes. For all types of panels, the 

energy efficiency metric is the U-factor, 

which is a measure of conductive, 

convective, and radiative heat transfer 

and which takes into account composite 

panel characteristics, which may 

include the insulation type, structural 

members, any type of transparent 

material (e.g. glass), and panel 

thickness. See section III.B.2 for details 

on how the U-factor is determined. DOE 

considers a panel basic model to 

include panels which do not have any 

differing features or characteristics that 

affect the U-factor. 76 FR 12504. 

DOE notes that manufacturers who 

make customized panels may 

experience a higher certification burden 

than manufacturers of standardized 

panels. For example, under today’s 

procedure, a panel’s U-factor is a surface 

area-independent metric, which implies 

that variation in panel width and height 

alone would not be expected to affect 

the U-factor rating if all other 

characteristics were equal. In those 

instances where no changes in energy 

efficiency would occur, these panels 

could be grouped as a basic model. In 

contrast, smaller floor and non-floor 

panels may have a higher proportion of 

framing material to non-framing 

material, or other structural members, 

which could affect the overall panel Ufactor rating if the framing material or 

framing geometry has different thermal 

conductivity performance than the 

neighboring insulation. Therefore, for 

two or more floor or non-floor panels 

that are equivalent in materials and 

other characteristics but differ in their 

frame to insulation proportions such 

that they have different U-factor ratings, 

the panels would be considered 

different basic models and would need 

to be certified independently to DOE, if 

the manufacturer chooses to claim 

different U-factor ratings. However, DOE 

emphasizes that as explained in section 

III.3, manufacturers may group models 

into basic models at their discretion as 

long as the tested performance of the 

models is at least as good as the certified 

rating. 

DOE has also introduced additional 

provisions to reduce the testing and 

certification burden on floor and nonfloor panel manufacturers. See section 

III.B.2.a for details. 

As explained above, the energy 

efficiency metric for display panels is 

the U-factor, as for floor and non-floor 

panels. However, unlike a floor, ceiling, 

or wall panel, a display panel is 

essentially a window. Therefore, in this 

test procedure, DOE is requiring the Ufactor of display panels to be tested 

using NFRC 100–2010[E0A1], 

‘‘Procedure for Determining Fenestration 

Product U-factors,’’ which DOE 

proposed in the SNOPR for measuring 

the U-factor of doors and windows, 

including their framing materials. 75 FR 

55083. (Sept. 9, 2010) As with floor and 

non-floor panels, the basic model 

concept allows manufacturers to group 

display panels that are essentially 

identical in U-factor into one basic 

model, which DOE anticipates will 

reduce the testing burden on display 


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panel manufacturers. Also, NFRC 100– 

2010[E0A1] allows verified computer 

models to simulate a display panel’s 

energy consumption, another factor that 

reduces the manufacturer’s testing 

burden. 

b. Basic Model of Doors 

A door is an assembly installed in an 

opening on an interior or exterior wall 

that is used to allow access or close off 

the opening and that is movable in a 

sliding, pivoting, hinged, or revolving 

manner of movement. For walk-in 

coolers and walk-in freezers, a door 

includes the door panel, glass, framing 

materials, door plug, mullion, and any 

other elements that form the door or 

part of its connection to the wall. This 

test procedure defines two types of 

doors, display and non-display doors. 

Display doors are doors designed for 

product movement, display, or both, 

rather than the passage of persons, and 

non-display doors are considered to be 

all other types of doors. For all doors, 

the energy consumption metric that 

DOE is adopting in today’s rule 

incorporates the U-factor and any 

electrical components built into the 

door. (See section I.A.1.a for details.) 

Calculating this metric requires the use 

of NFRC 100–2010[E0A1], ‘‘Procedure 

for Determining Fenestration Product Ufactors,’’ which DOE proposed in the 

SNOPR for measuring the U-factor of 

doors and windows, including their 

framing materials. 75 FR 55083. (Sept. 9, 

2010) Applying the NFRC test yields an 

overall U-factor for the tested door. 

Then, through calculations outlined in 

Appendix A, the U-factor and the 

electrical energy consumption are 

combined to create a rating for the door. 

As with panels, doors with essentially 

identical energy consumption levels 

may be grouped into a basic model and 

rated conservatively. 76 FR 12429 and 

12504. The basic model concept can be 

used to reduce the testing and 

certification burdens by allowing 

manufacturers to group doors that are 

essentially identical in energy 

consumption but cosmetically different. 

The NFRC procedure also permits either 

a physical test or a verified computer 

model to be used when determining the 

U-factor of the door. The latter of these 

options would be expected to reduce 

testing burden because only a series of 

calculations would need to be run by an 

NFRC-approved computer modeling 

program. DOE also notes that the 

calculations for energy consumption of 

door components are not based on 

testing, which reduces the general 

testing burden for doors. Any results 

from physical tests, computer 

simulations, and calculations must be 

retained as required by the CCE final 

rule. 76 FR 12494. 

c. Basic Model of Refrigeration Systems 

The refrigeration system consists 

primarily of a compressor, condenser, 

unit cooler, valves, and piping. It is 

considered a component under the 

component level approach (see section 

III.A) that DOE is adopting in today’s 

final rule. As with the panels and doors, 

and consistent with the approach 

promulgated in the CCE final rule, 

manufacturers may elect to group 

individual models into basic models at 

their discretion to the extent the models 

have essentially identical electrical, 

physical, and functional characteristics 

that affect energy efficiency or energy 

consumption. Furthermore, 

manufacturers may rate models 

conservatively, meaning the tested 

performance of the model(s) must be at 

least as good as the certified rating, after 

applying the appropriate sampling plan. 

76 FR 12429. DOE believes these 

provisions will reduce the burden of 

testing for refrigeration manufacturers, 

including those who make customized 

equipment. DOE may also consider 

methods which allow manufacturers to 

use an alternate method of determining 

the energy use of the refrigeration 

system in a future rulemaking. This 

concept is further discussed in section 

III.C.3. 

B. Test Procedures for Envelope 

Components 

The envelope consists of the insulated 

box in which items are stored and 

refrigerated. In the NOPR and SNOPR, 

DOE proposed methods for evaluating 

the performance characteristics of 

insulation, testing thermal energy gains 

related to air infiltration, and 

determining direct electricity use and 

heat gain due to internal electrical 

components. The proposed procedure 

used these methods to determine the 

energy use associated with the envelope 

by calculating the effect of the 

envelope’s characteristics and 

components on the energy consumption 

of the walk-in as a whole. Those 

characteristics and components 

included the energy consumption of 

electrical components present in the 

envelope (such as lights) and variation 

in the energy consumption of the 

refrigeration system due to heat loads 

introduced as a function of envelope 

performance (such as conduction of heat 

through the walls of the envelope). The 

impact on the refrigeration system 

energy consumption was determined by 

calculating the energy consumption of a 

theoretical or ‘‘nominal’’ refrigeration 

system when paired with the tested 

envelope. 75 FR 186, 191 (Jan. 4, 2010) 

and 75 FR 55068, 55074 (Sept. 9, 2010). 

As described in section III.A, DOE is 

no longer requiring manufacturers to 

determine the energy consumption of 

the entire envelope in this final rule. 

Rather, DOE is establishing metrics for 

the principal components of the 

envelope (i.e. the panels and doors) as 

described in section III.A.1. In doing so, 

DOE is requiring manufacturers to use 

the same physical tests for the 

components that it proposed in the 

NOPR and SNOPR, but is introducing 

revisions to the calculations in 

Appendix A of the new procedure. 

These revisions will enable 

manufacturers to calculate the required 

component metrics from the results of 

those tests. 

For panels, DOE is adopting separate 

approaches depending on whether a 

given panel is a display or non-display 

panel. Display panels are panels that are 

primarily made of transparent material 

and used for display purposes. Display 

panels are considered equivalent to 

windows because of their transparent 

characteristics and associated thermal 

heat transfer properties, and therefore 

the U-factor will be measured by NFRC 

100–2010[E0A1], ‘‘Procedure for 

Determining Fenestration Product Ufactors,’’ which DOE proposed in the 

SNOPR for measuring the U-factor of 

doors and windows, including their 

framing materials. 75 FR 55083. (Sept. 9, 

2010) Non-display panels are floor and 

non-floor panels. Since both floor and 

non-floor panels are typically made out 

of a composite of insulation, framing, 

and facer material, both types of panels 

will be tested using the same 

methodology. In today’s rule, the 

physical tests pertaining to the 

performance of non-display panels are 

from ASTM C1363–05, ‘‘Standard Test 

Method for Thermal Performance of 

Building Materials and Envelope 

Assemblies by Means of a Hot Box 

Apparatus’’ and, for foams that 

experience aging, DIN EN 13164:2009– 

02, ‘‘Thermal insulation products for 

buildings—Factory made products of 

extruded polystyrene foam (XPS)— 

Specification’’ or DIN EN 13165:2009– 

02, ‘‘Thermal insulation products for 

buildings—Factory made rigid 

polyurethane foam (PUR) products— 

Specification,’’ as applicable. These tests 

were proposed in the SNOPR. 75 FR 

55068, 55075–55076 and 55081 (Sept. 9, 

2010). In this final rule, panel 

performance is denoted by its overall Ufactor, or thermal transmittance, which 

is determined by the test procedures 

and calculation methodologies 

described in section III.B.2. 


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DOE is requiring one test for door 

performance, NFRC 100–2010[E0A1], 

‘‘Procedure for Determining Fenestration 

Product U-factors,’’ which was proposed 

in the SNOPR. 75 FR 55083 (Sept. 9, 

2010). This test measures conduction 

through a door, whether it is a display 

door or a non-display door. The total 

energy consumption of a door is 

calculated as the effect of a door’s 

thermal load on the refrigeration system 

combined with the door’s electrical 

energy use, as described in section 4.5 

and section 4.4 of Appendix A of this 

final rule. The effect on the refrigeration 

system is determined by calculating the 

energy consumption that a theoretical or 

‘‘nominal’’ refrigeration system would 

use to reject the heat that was 

transmitted through the door. The 

energy that would be used by the 

theoretical refrigeration system to reject 

a given amount of heat is represented by 

the energy efficiency ratio (EER) of the 

refrigeration system. The test procedure 

uses the same nominal refrigeration 

system EER for all tested doors to enable 

direct comparisons of the performance 

of walk-in doors across a range of sizes, 

product classes, and features. The 

nominal EER values for cooler and 

freezer refrigeration (i.e. 12.4 Btu/W-h 

and 6.3 Btu/W-h for coolers and 

freezers, respectively) are the same as 

those proposed in the SNOPR for 

calculating the energy use of the 

envelope. See 75 FR 55013 (Sept. 9, 

2010). 

1. Definition of Envelope 

In the January 2010 NOPR, DOE 

proposed the following definition of 

‘‘envelope:’’ 

Envelope means (1) a piece of equipment 

that is the portion of a walk-in cooler or 

walk-in freezer that isolates the interior, 

refrigerated environment from the ambient, 

external environment; and (2) all energyconsuming components of the walk-in cooler 

or walk-in freezer that are not part of its 

refrigeration system. 

75 FR 186, 192 (Jan. 4, 2010). 

The walk-in envelope was proposed 

to include, but not be limited to, walls, 

floors, ceilings, seals, windows, doors, 

or any combination thereof, composed 

of single or composite materials. DOE 

did not propose any changes to this 

definition in the September 2010 

SNOPR. 

Master-Bilt, BASF, ThermalRite, 

ACEEE, and ICS submitted written 

comments supporting the proposed 

definition for the walk-in envelope. 

(Master-Bilt, No. 0027.1 at p. 1; BASF, 

No. 0021.1 at p. 3; ThermalRite, No. 

0049.1 at p. 1; ACEEE, No. 0052.1 at p. 

2; ICS, No. 0045.1 at p. 1) However, NorLake asked that the definition of 

envelope exclude components of the 

envelope purchased separately by the 

end user to enable the manufacturer of 

the envelope to avoid compliance 

responsibility for the performance of 

those components. (Nor-Lake, No. 

0023.1 at p. 2) ICS requested 

clarification on the preemption of 

energy codes by building, electrical, and 

mechanical codes and stated that the 

definition must allow for structural and 

electrical safety code compliance over 

energy compliance when in conflict. 

(ICS, No. 0045.1 at p. 1) A 

representative from Gonzaga Law 

argued that the definition proposed by 

the DOE was too inclusive but did not 

propose an alternative definition. 

(Gonzaga Law, No. 0018 at p. 1) At the 

public meeting for the January 2010 

NOPR, ICS suggested that DOE’s 

standards and definitions should align 

with NSF’s (formerly known as the 

National Sanitation Foundation) 

definition of envelope and 

requirements. (ICS, Public Meeting 

Transcript, 0016 at p. 30) (In this and 

subsequent citations, ‘‘Public Meeting 

Transcript’’ refers to the transcript of the 

March 1, 2010, public meeting on the 

proposed test procedures for walk-in 

coolers and freezers. ‘‘No. 0016’’ refers to 

the document number of the transcript 

in the Docket for the DOE rulemaking 

on test procedures for walk-in coolers 

and freezers, Docket No. EERE–2008– 

BT–TP–0014; and the page number 

refers to the place in the transcript 

where the statement preceding appears.) 

DOE notes the comments and 

suggestions from Master-Bilt, BASF, 

ThermalRite, ACEEE, ICS, and Gonzaga 

Law. However, because DOE is taking a 

component-based approach, the 

proposed envelope definition is no 

longer applicable for the purpose of this 

test procedure. As suggested by ICS, 

when evaluating potential standards 

applicable to walk-ins, DOE will also 

consider their related requirements that 

manufacturers need to satisfy. In 

response to Nor-Lake’s comment 

regarding components not supplied by 

the envelope manufacturer, DOE 

clarifies that each component 

manufacturer is responsible for testing 

its component with the appropriate test 

procedure as discussed in section 

III.A.2. The envelope component 

manufacturer is not responsible for the 

end user’s implementation of the 

component; rather, the manufacturer 

would be responsible only for the 

component’s compliance as designed. 

Also, the envelope assembler is 

responsible for using WICF-compliant 

components to assemble the total 

envelope. 

2. Heat Transfer through Panels 

a. U-Factor of Composite Panels 

Including Structural Members of Panels 

EPCA specifies that ASTM C518–04, 

‘‘Standard Test Method for Steady-State 

Thermal Transmission Properties by 

Means of the Heat Flow Meter 

Apparatus,’’ must be used to determine 

the K-factor of walk-in insulation. The 

statute defines the R-value as equal to 

the value of 1/K-factor multiplied by the 

thickness of the panel. (42 U.S.C. 6314 

(a)(9)(A)(i)¥(ii)) In response to the 

January 2010 NOPR, interested parties 

commented that the heat conduction 

through structural members must be 

considered because this factor could 

affect the conductance through the 

composite walk-in insulation panel. 

Accordingly, DOE proposed in the 

September 2010 SNOPR to use ASTM 

C1363–05, ‘‘Standard Test Method for 

Thermal Performance of Building 

Materials and Envelope Assemblies by 

Means of a Hot Box Apparatus,’’ to 

measure the overall U-factor of fully 

assembled panels to help account for 

the impact that structural members have 

on the overall U-factor. 75 FR 55074. 

Several interested parties—NEEA, 

AHRI, Master-Bilt, Thermo-Kool, 

Carpenter, and Bally—supported the use 

of ASTM C1363–05 to measure the 

overall panel U-factor. (NEEA, No. 

0061.1 at p. 2; AHRI, No. 0070.1 at p. 

2; Master-Bilt, No. 0069.1 at p. 1; 

Thermo-Kool, No. 0072.1 at p. 1; 

Carpenter, No. 0070.1 at p.2; Bally, No. 

0078.1 at p. 2)) 

Other interested parties, however, 

disagreed with DOE’s proposal to use 

ASTM C1363–05 to measure panel 

performance. At least some of these 

concerns were premised on a mistaken 

belief that DOE’s proposal would result 

in the elimination of structural members 

embedded into panels. For example, a 

comment submitted jointly by the 

manufacturers CrownTonka, 

ThermalRite, and ICS (collectively 

referred to as the Joint Manufacturers) 

recommended that structural members 

be excluded from the stated R-value 

requirements for overall envelope 

thermal resistance. The Joint 

Manufacturers explained that many 

walk-ins require the use of structural 

members to comply with building codes 

and to help support loads placed on the 

building from factors such as snow and 

wind. The Joint Manufacturers stated 

that ASTM C518–04 should be used to 

measure the K-factor of foam, as 

specified in EPCA. (42 U.S.C. 6314 

(a)(9)(A)(i)–(ii)) (Joint Manufacturers, 

No. 0062.1 at p. 1) 

While American Panel agreed with 

DOE’s general approach that the R-value 


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of structural members should be 

considered in determining the overall 

U-factor and submit data to demonstrate 

the impact of structural members on the 

overall U-factor, it stated that the 

composite panel must meet the 

minimum R-value requirement. 

American Panel continued to state that 

the R-value should be calculated by 

using a weighted percentage of foam Rvalue and structural R-value based on 

the percentage each material represents 

in the panel. (American Panel, No. 

0057.1 at p. 1; American Panel, No. 

0057.1 at p. 2; American Panel, No. 

0057.3 at p. 1) It asserted that ASTM 

C1363–05 is not the appropriate test 

method for measuring the insulating 

values of foam, and added, along with 

Craig Industries and Carpenter, that 

ASTM C518–04 should be used to 

measure heat conduction through 

panels. (American Panel, No. 0057.1 at 

p. 2; Craig, No. 0068.1 at p. 2; Carpenter, 

No. 0067.1 at p. 2) Craig Industries was 

concerned that using ASTM C1363–05 

to calculate the heat conduction through 

structural members may not take the 

reduction of joints (that is, panel to 

panel interfacing members) into 

consideration. Craig Industries 

recommended that the structural 

members should be tested with a 

procedure to represent the real R-value, 

which would replace the R-value of the 

insulation where it is replaced with 

structural members. (Craig, No. 0057.13 

at p. 2) Carpenter further asserted that 

ASTM C518–04 is simpler and less 

costly to perform than C1363–05. 

(Carpenter, No. 0067.1 at p. 2) ThermoKool, on the other hand, disagreed with 

the approach of using R-value testing of 

different components of the composite 

panel to determine heat loss. (ThermoKool, No. 0072.1 at p. 1) Bally, who 

agreed with DOE’s proposed approach, 

requested clarification specifically 

regarding how the two tested areas 

would be used to represent the 

performance of a panel. (Bally, No. 

0078.1 at p. 2) 

None of the interested parties offered 

any further explanation for their views 

other than those already described. 

In this final rule, the terms ‘‘foam’’ and 

‘‘insulation’’ are used synonymously, but 

a panel is the fully manufactured 

product that contains, but is not limited 

to, the insulating material, metal skin, 

framing material, other structural 

members, or any combination thereof. 

To address the Joint Manufacturers’ 

concerns about the potential elimination 

of structural members, DOE emphasizes 

that the overall U-factor testing required 

by today’s final rule will not prevent 

manufacturers from including structural 

members in panels because the existing 

standards in EPCA only regulate the Rvalue of the foam and do not restrict the 

overall panel U-factor or the R-value of 

the structural components. The R-value 

of insulation, which is 1/K-factor as 

determined by ASTM C518–04, will still 

have to comply with the existing EPCA 

requirements for insulation. (42 U.S.C. 

6314 (a)(9)(A)(i)–(ii)) However, the 

overall U-factor of the fully assembled 

panel, including structural members, 

may be used to meet an energy 

conservation standard for panels, which 

will be determined in a parallel 

rulemaking. Including ASTM C1363–05 

will provide a more accurate means to 

represent the overall heat transfer 

performance of panels. DOE believes 

this procedure will be beneficial 

because it will capture the effects of 

structural members that incorporate 

insulation or otherwise contribute to the 

efficiency of the walk-in. 

Additionally, while DOE 

acknowledges the concerns raised by 

American Panel, the Joint 

Manufacturers, Craig Industries, and 

Carpenter, the final rule includes ASTM 

C1363–05 as part of the test procedure 

in order to determine the overall Ufactor of the panel. DOE is including 

this protocol as part of the test 

procedure because heat conduction 

through structural members is a 

significant panel characteristic that is 

not addressed under the statutorilyprescribed testing requirements (i.e. 

ASTM C518–04). While ASTM C518–04 

could be used to individually measure 

the R-value of structural members, or 

any other material, as Craig Industries 

suggested, DOE believes that this 

approach would be more costly because 

of the many materials that could 

comprise a panel and the need to test 

each material separately under that 

approach. Furthermore, DOE believes 

that panel geometry could make 

calculations to combine the R-value of 

each material into an overall panel Rvalue complicated and burdensome. 

DOE also acknowledges Craig 

Industries’ concern that ASTM C1363– 

05 does not account for the reduction of 

joints (that is, panel to panel interfacing 

members). Since DOE is adopting an 

approach to ensure the energy efficiency 

performance of particular components, 

an approach suggested by numerous 

commenters, and is no longer 

considering the effects of infiltration, 

panel joint issues are outside of this 

approach. 

DOE notes that American Panel 

supported the inclusion of structural 

members in calculating the overall Ufactor. Furthermore, DOE would like to 

clarify the calculation methodology to 

address the comment from Bally. 

Today’s final rule adopts a weighted 

percentage of the panel edge (which 

may contain structural members) and 

panel core region (which may also 

include structural members) in order to 

calculate the panel’s total U-factor. DOE 

believes that using the weighted 

percentage of edge U-factor and core Ufactor to calculate the total U-factor will 

help reduce the manufacturer’s testing 

burden. 

In applying this weighted percentage 

approach, today’s final rule provides 

that for floor or non-floor panels of the 

same thickness, construction methods, 

and materials, manufacturers must test 

a pair of 4 ft. by 8 ft. ‘‘test panels’’ to 

obtain a core U-factor and an edge Ufactor. The manufacturer must then 

calculate the overall U-factor of other 

floor or non-floor panels with the same 

panel thickness, construction methods, 

and materials using the U-factor results 

for the core and edge region ‘‘test 

panels.’’ For example, a manufacturer 

tests a 4 ft. by 8 ft. test panel and finds 

the edge region and core region Ufactors. The same manufacturer also 

produces 6 ft. by 8 ft. panels that have 

identical core and edge region 

thickness, construction methods and 

materials. Therefore, the manufacturer 

may apply the core and edge region 

factors to the 6 ft. by 8 ft. panel to 

calculate the overall U-factor of the 6 ft. 

by 8 ft. panel instead of performing an 

additional test. DOE notes that any 

calculations that support the certified 

ratings must be retained along with the 

test data for the ‘‘test panels’’ for all basic 

models pursuant to the requirements for 

the maintenance of records promulgated 

in the CCE final rule. 76 FR 12494. DOE 

expects that, based on the information it 

has collected, including information 

made available by manufacturers on 

their Web sites and submitted 

comments, most manufacturers use the 

same panel thickness, materials, and 

construction methods for many of their 

panels, which results in a minimal 

testing burden. 

In regard to American Panel’s 

comment that the composite panel must 

meet the minimum R-value 

requirement, DOE clarifies that EPCA 

states that only the insulation material 

(that is, the foam) must meet the 

prescribed R-value. (42 U.S.C. 

6313(f)(1)(C)) The test procedure is 

prescribing ASTM C1363–05 as a 

method of measuring the overall Ufactor of the entire panel. For EPCA 

compliance, the R-value of the 

insulation must be separately 

determined in accordance with ASTM 

C518–04 as specified in EPCA. (42 

U.S.C. 6313(f)(1)(C)) 


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Finally, interested parties suggested 

changes to the test methodology DOE 

proposed. NRDC stated that irregular or 

non-homogeneous foam products 

should be tested for actual R-value 

where there is no quality control to 

maintain the orientation of the foam in 

the finished product. To clarify, DOE 

believes that when NRDC noted the 

concern about the orientation of the 

foam, they were referring to bun-stock 

foam products. Bun-stock products are 

manufactured in ‘‘buns’’ that may have 

foam cell structure similar to the grains 

in wood. Like wood, depending on how 

the buns are cut into boards, the 

orientation of the cell ‘‘grains’’ may vary 

by finished board. NRDC continued to 

suggest that if a foam product cannot be 

tested, then the stated R-value should be 

a conservative number representing the 

lowest R-value for a tested material. 

(NRDC, No. 0064.1 at p. 4) NRDC also 

suggested that DOE review the impact of 

testing the final fabricated panel rather 

than requiring manufacturers to 

specially construct units for testing, 

because specially constructed units may 

not represent the typical product. 

(NRDC, No. 0064.1 at p. 4) Master-Bilt 

suggested changing the width and 

length of the panel to 8 x 4 ft. +/- 1 ft. 

to have more tolerance and allow for the 

testing of standard width panels. 

(Master-Bilt, No. 0069.1 at p. 2) 

In response to NRDC’s comment about 

irregular or non-homogeneous foam 

products, DOE anticipates that the 

prescribed sampling procedures for 

certification will accurately capture the 

foam’s R-value. A sampling plan is 

intended to ensure accurate and 

statistically repeatable results are 

achieved when using the test procedure. 

DOE notes NRDC’s concern that 

specifically constructed units may not 

represent an actual product. However, 

in order to reduce the testing burden 

presented by ASTM C1365–05, DOE is 

maintaining the approach of specifying 

two test regions of a pair of 

representative panels. At one test 

region, the tester measures the U-factor 

of the perimeter that may contain 

structural members and panel-to-panel 

interface area (the ‘‘Panel Edge’’), while 

at the other region the tester measures 

the U-factor of the core area of the panel 

(the ‘‘Panel Core’’) which may also 

contain structural members. The Ufactor for each region is then applied to 

panels of the same type (that is, same 

foam type, framing material, and panel 

thickness) to obtain an overall U-factor 

that is representative of actual products 

sold by the panel manufacturer. DOE 

applies a calculation methodology to 

extrapolate the core and edge U-factor to 

determine the U-factor of any panel 

produced by a manufacturer. 

In response to Master-Bilt’s comment, 

DOE agrees that increasing the tolerance 

of the 8 ft x 4 ft test panel to +/¥ 1 ft 

will provide manufacturers with a 

greater range of standard sized panels. 

DOE conducted a mathematical analysis 

to determine how changing the 

tolerance would affect the U-factor as 

determined by ASTM C1363–05. DOE 

found that increasing the size tolerance 

of the test panel results in less than a 

0.5 percent change to the U-factor as 

determined by ASTM C1363–05. 

Therefore, DOE has amended the 

standard size of a test panel for ASTM 

C1363–05 to be 8 ft x 4 ft +/¥ 1 ft. 

b. Long-Term Thermal Resistance 

In the January 2010 NOPR and 

September 2010 SNOPR, DOE cited 

several studies that conclude that lateral 

gas diffusion, which causes a reduction 

in R-value, occurs in impermeably faced 

foams. See 75 FR 192–194 and 75 FR 

55075–55079. These types of foams are 

common to walk-ins. The lateral gas 

diffusion occurs over time and affects 

the energy efficiency performance of the 

foam as diffusion continues. To account 

for this aging effect on a foam’s 

insulation performance—and, by 

extension, the energy consumption of a 

walk-in due to thermal losses 

attributable to this reduced 

performance—DOE, consistent with its 

proposed approach, is adopting a 

method to account for this phenomenon 

in walk-in applications. Hill Phoenix 

added that different methods of 

manufacturing panels should be taken 

into account when determining the test 

procedure. (Hill Phoenix, No. 0063.1 at 

p. 2) 

The most significant factor affecting 

the efficiency of a walk-in panel is the 

insulating foam in a panel, and 

accurately capturing the foam’s R-value 

is critical to measuring the overall 

performance of the panel. Panels can be 

in use for 10 to 20 or more years before 

they are replaced. Performance metrics 

for a panel based on initial foam R-value 

will tend to overestimate the amount of 

energy saved over this equipment’s 

lifetime. Research on panel aging has 

shown that a 5-year aged R-value found 

by LTTR testing is representative of the 

panel’s insulation performance over its 

lifetime, and there are industry tests for 

walk-in foam that estimate the aged Rvalue over time. Using these industrydeveloped protocols will enable 

manufacturers to more accurately 

capture the lifetime performance of a 

walk-in panel. 

Incorporating a long term thermal 

resistance degradation factor improves 

the reliability of test results for walk-in 

panels. While EPCA contains standards 

for the R-value or insulating 

performance of the foam, these 

standards do not specify when the 

insulating foam must be tested. (42 

U.S.C. 6313(f)(1)(C)) Variables that 

impact the time at which panels are 

tested include shipping time, 

production time, shipment of completed 

panels to test lab, and test facility 

availability. Changing any one of these 

variables could result in significantly 

different test results and measured Rvalues. This is in contrast to most other 

types of equipment within the appliance 

standards program, which would not 

exhibit significant differences in 

performance based on the length of time 

between manufacture and testing. 

Because of the unique aging profile of 

certain foam types, the timing of a walkin panel test would affect both 

manufacturers’ certification of the panel 

U-factors and any enforcement testing 

undertaken by DOE. Therefore, using 

LTTR values to measure foam 

performance eliminates the ‘‘time’’ 

variable that could affect whether a 

panel is shown to comply with an 

overall performance standard that DOE 

may set. The purpose of the LTTR 

testing is to accelerate foam aging to the 

point where the R-value changes 

relatively slowly over time and to then 

measure its performance, thus 

improving the repeatability of the test 

because the timing of the test is no 

longer critical. 

In the January 2010 NOPR, DOE 

proposed to use ASTM C1303–08, 

‘‘Standard Test Method for Predicting 

Long-Term Thermal Resistance of 

Closed-Cell Foam Insulation,’’ to 

calculate the long-term thermal 

resistance (LTTR) of walk-in foam 

insulation. 75 FR 186, 193–94 (Jan. 4, 

2010). In the September 2010 SNOPR, 

DOE proposed to use the updated 

version of ASTM C1303–08, which was 

ASTM C1303–10. 75 FR 55068, 55075 

(Sept. 9, 2010). In that notice, DOE also 

offered an alternative method, Annex C 

of either DIN EN 13164:2009–02, 

‘‘Thermal insulation products for 

buildings— Factory made products of 

extruded polystyrene foam (XPS)— 

Specification’’ or DIN EN 13165:2009– 

02, ‘‘Thermal insulation products for 

buildings—Factory made rigid 

polyurethane foam (PUR) products— 

Specification,’’ as applicable, to test for 

the LTTR. This alternative was offered 

in response to concerns raised in 

response to the NOPR. The SNOPR 

requested comments on both of these 

alternative methods. 75 FR 55079 (Sept. 

9, 2010). 


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In light of the comments that DOE 

received on all of these various testing 

methods, which are addressed below, 

DOE has decided to adopt DIN EN 

13165:2009–02 or DIN EN 13164:2009– 

02, as applicable, as the test procedure 

for determining LTTR. The LTTR value 

determined by DIN EN 13165:2009–02 

or DIN EN 13164:2009–02 will be used 

to determine a degradation factor, which 

will be the LTTR R-value divided by the 

initial R-value of the foam. The initial 

R-value will be determined in 

accordance with ASTM C518–04 as 

specified in the EISA 2007 amendments 

to EPCA and used to establish 

compliance with those statutorilyprescribed requirements. (42 U.S.C. 

6313(f)(1)(C)) The degradation factor is 

applied to the U-factor of the panel 

found by ASTM C1365–05; see section 

4.2 and 4.3 in Appendix A.These 

protocols are preferable to ASTM 

C1303–10 because they account for the 

effect of impermeable facers, which 

ASTM C1303–10 does not. 

In response to this approach, DOE 

received a number of comments. 

Thermo-Kool noted the general need to 

consider LTTR. It also suggested that the 

potential for thermal degradation is 

more likely to occur at the panel joints 

than from actual polyurethane (i.e. 

foam) issues. (Thermo-Kool, 0072.1 at p. 

1) The Joint Manufacturers 

recommended that structural members 

be considered in the long-term thermal 

resistance performance of any panels 

with structural edges because they may 

lessen or slow off-gassing over time. 

(The Joint Manufacturers, No. 0062.1 at 

p. 1). 

American Panel and Bally opposed 

DOE’s inclusion of a test procedure that 

measured LTTR. (American Panel, No. 

0057.2 at p. 1; Bally, No. 0078.1 at p. 2) 

American Panel explained that 

impermeable or metal skins protect the 

polyurethane foam from aging and that 

little change will occur in the long term 

R-value. In support of its claim that 

impermeably faced metal skins protect 

foam from aging, American Panel 

submitted the results of a study 

conducted by Carpenter. That study 

found a 3.6 percent loss in insulating 

value of a panel after 9 years in a walkin application. (American Panel, No. 

0057.2 at p. 1) American Panel also 

asserted that none of its customers 

complained about R-value loss in the 

panels that American Panel sold to 

them. (American Panel, No. 0057.1 at p. 

2) 

One interested party recommended 

that DOE collect test data before 

prescribing a particular test method. 

Bally stated that more data from actual 

walk-in panels with intact metal skins 

and sealed edges should be collected 

before DOE includes a test procedure for 

long-term thermal resistance. (Bally, No. 

0078.1 at p. 2) 

DOE acknowledges Thermo-Kool’s 

assertion that most aging occurs at the 

panel joints and Bally’s suggestion that 

DOE collect more data to support long 

term thermal aging. DOE notes, 

however, that polyurethane itself has 

the potential to age significantly. DOE 

cited multiple studies, in both the 

January 2010 NOPR and September 

2010 SNOPR, that conclude that aging 

occurs in most types of foams 

commonly used in walk-in applications, 

including polyurethane. 75 FR 192–194 

(Jan. 4, 2010) and 75 FR 55075–55079 

(Sept. 9, 2010). In response to the Joint 

Manufacturers’ comment about 

accounting for the effect structural 

members have on LTTR, DOE also notes 

that no known test procedures are 

available that address edge sealing at 

this time but that this factor could be 

considered in a future rulemaking. 

DOE also considered the merits of the 

submissions in support of American 

Panel’s contention that impermeably 

faced foams do not undergo significant 

aging. After evaluating this information, 

however, DOE continues to believe that 

the inclusion of LTTR testing in the test 

procedure is necessary to accurately 

measure the R-value of foam. DOE notes 

that the samples in the Carpenter study 

cited by American Panel were taken 

from the center of the panel. As DOE 

noted in the SNOPR, another study (the 

Ottens study, ‘‘Industrial Experiences 

with CO2 Blown Polyurethane Foams in 

the Manufacture of Metal Faced 

Sandwich Panels’’) found that core 

samples do not represent the overall 

aging of foam in panels because most 

aging occurs at the panel’s perimeter. 75 

FR 55068, 55077 (Sept. 9, 2010) (citing 

Ottens et al., ‘‘Industrial Experiences 

with CO2 Blown Polyurethane Foams in 

the Manufacture of Metal Faced 

Sandwich Panels,’’ Polyurethane World, 

1997.) As a result, the data from this 

study indicate that the Carpenter study’s 

results do not necessarily provide an 

accurate portrayal of the likely effects of 

panel aging. 

Additionally, while American Panel 

asserted that the lack of customer 

complaints about R-value loss in panels 

indicates that the deterioration of LTTR 

values is insignificant, the lack of 

customer complaints may be influenced 

by a variety of factors. For example, a 

panel is normally only replaced when 

visibly damaged. However, a panel may 

have reduced thermal performance 

without any accompanying visual cues 

suggesting problems with the panel. 

Accordingly, DOE does not believe that 

the statements and materials cited by 

American Panel support the premise 

that LTTR of foam is negligible for walkin panels. 

Interested parties also made 

comments on the specific test methods 

that DOE proposed. DOE received some 

comments from interested parties in 

favor of using ASTM C1303–10 to 

determine the LTTR of foam insulation. 

Owens Corning agreed that DOE should 

use the most current version of 

whichever ASTM standards it planned 

to use. (Owens Corning, No. 0058.1 at p. 

1) Craig Industries agreed with the use 

of ATSM C1303–10, but stated that DOE 

should evaluate if ASTM C1303–10 is 

appropriate for all present and future 

foam insulation products. (Craig, No. 

0068.1 at p. 4) NRDC supported testing 

insulated products to determine 

whether the R-value degraded over time, 

and stated that the proposed ASTM 

standard is acceptable and known in the 

industry. (NRDC, No. 0064.1 at p. 4) 

NEEA stated that although some 

interested parties have concerns about 

LTTR values derived from ASTM 

C1303–10, NEEA believed that carefully 

specifying the physical characteristics of 

the tested panel samples will address 

their concerns. (NEEA, No. 0061.1 at 

p. 2) 

Some interested parties disapproved 

of ASTM C1303–10. American Panel, 

Hill Phoenix, Thermo-Kool, and the 

Joint Manufacturers opposed using 

ASTM C1303–10 as the test procedure 

to measure LTTR. (American Panel, No. 

0057.1 at p. 2; Hill Phoenix, No. 0063.1 

at p. 2; Thermo-Kool, 0072.1 at p. 1; the 

Joint Manufacturers, No. 0062.1 at p. 1) 

American Panel asserted that any testing 

to determine R-value must allow the 

foamed-in-place polyurethane to remain 

encapsulated by the metal facers to 

resemble the real-world application. 

(American Panel, No. 0057.1 at p. 2) Hill 

Phoenix and Thermo-Kool did not 

recommend the use of ASTM C1303–10 

because, as noted in section 1.3 of 

ASTM C1303–10, the standard does not 

apply to impermeably faced foams; 

therefore, applying the results from 

ASTM C1303–10 to impermeably faced 

foams would be misleading. Hill 

Phoenix also suggested that ASTM 

C1303–10 would significantly 

overestimate foam aging of foamed-inplace polyurethane panels. (Hill 

Phoenix, No. 0063.1 at p. 2) The Joint 

Manufacturers opposed the use of 

ASTM C1303–10 for measuring longterm R-value decline because it is not 

intended for use with faced panels and 

unfairly penalizes foamed-in-place 

polyurethane that has minimal or zero 

exposure of permeable surfaces (the 

Joint Manufacturers, No. 0062.1 at p. 1) 


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Owens Corning stated that the 

prescriptive and research methods of 

ASTM C1303–10 are not comparable 

and will not generate comparable 

results. It added that the Canadian test 

procedure CAN/ULC S770, which is 

based on various versions of ASTM 

C1303, has a positive bias and may overpredict foam aging, and submitted foam 

aging data and an article about the CAN/ 

ULC S770 test to support this comment. 

(Owens Corning, No. 0058.1 at p. 2; 

Owens Corning, No. 0058.1 at p. 1; 

Owens Corning, No. 0058.5 at p. 19; 

Owens Corning, No. 0058.2 at p. 2) 

Carpenter and Master-Bilt also 

opposed the use of ASTM C1303–10 for 

LTTR testing and suggested possible 

alternatives. Carpenter suggested testing 

initial and aged K-factors per ASTM 

C518 at 20 °F and 55 °F for freezers and 

coolers, respectively. (Carpenter, No. 

0067.1 at p. 3) Carpenter stated that 

ASTM C1303–10 would underestimate 

the LTTR of impermeably faced panels 

and that LTTR tests should be 

performed on samples with intact 

facers. (Carpenter, No. 0067.1 at p. 2) 

Similarly, Master-Bilt explained that 

panel edges are not 100 percent 

exposed, but are tight against one 

another and sealed with caulk and vinyl 

gaskets. Collectively, the caulk and 

gaskets significantly reduce gas 

migration, thus reducing the effects of 

aging. Therefore, in its view, the testing 

of skinned panels with exposed edges 

still considerably overstates the 

insulation degradation. Master-Bilt 

suggested that a formula based on test 

data from actual walk-in panels that 

have been installed could be used 

instead of ASTM C1303–10. (MasterBilt, No. 0068.1 at p. 2) 

DOE agrees with the assessment that 

ASTM C1303–10 is not adequate for 

testing impermeably faced foams. DOE 

believes that the concerns about ASTM 

C1303–10 expressed by American Panel, 

Hill Phoenix, Thermo-Kool, Master-Bilt, 

the Joint Manufacturers, Carpenter, and 

Owens Corning are addressed by DIN 

EN 13165:2009–02 and DIN EN 

13164:2009–02, which account for 

impermeably faced foams, reduce the 

testing burden, and are appropriate for 

different types of foam. DIN EN 

13165:2009–02 and DIN EN 

13164:2009–02 partially rely on a 

formula based on test data, as suggested 

by Master-Bilt. DOE agrees with Owens 

Corning that the prescriptive and 

research methods of ASTM C1303–10 

are not comparable, and notes that DIN 

EN 13165:2009–02 and DIN EN 

13164:2009–02 do not have this 

problem. 

One interested party expressed 

concerns about two of the studies DOE 

referenced in the September 2010 

SNOPR. One study was the Ottens 

study, in which an experiment was 

completed on polyurethane foamed-inplace panels to assess their long-term 

insulating behavior. 75 FR 55068, 55077 

(Sept. 9, 2010). (Ottens et al., ‘‘Industrial 

Experiences with CO2 Blown 

Polyurethane Foams in the Manufacture 

of Metal Faced Sandwich Panels,’’ 

Polyurethane World, 1997.) In the 

SNOPR, DOE estimated that the test was 

likely representative of panels aged for 

at least 5 years. 75 FR at 55077 (Sept. 

9, 2010). ORNL challenged this estimate 

and stated that the results from the 

Ottens study cannot be correlated to a 

particular aging period. (ORNL, No. 

0060.1 at p. 2) 

The second study DOE referenced was 

a round robin test using CAN/ULC– 

S770–03, a standard with the same test 

methodology as a previous version of 

ASTM C1303. DOE referenced the test 

to address concerns raised by various 

interested parties that the thin slicing 

method, CAN/ULC–S770–03. Results 

from the round-robin study predicted 

that polyurethane would perform at a 

lower level than extruded polystyrene 

or even at a level as low as expanded 

polystyrene. 75 FR 55079 (Sept. 9, 

2010). ORNL stated the testing used in 

the referenced study relied on the 

original version of S770, which has been 

shown to over-predict thermal 

resistance. ORNL added that the test 

was performed on foams created with 

blowing agents that are no longer used, 

and the results are not representative of 

current products. (ORNL, 0060.1 at p. 2) 

Regarding ORNL’s comment about the 

Ottens study, DOE agrees that the 

method in the study cannot be 

accurately correlated to a particular 

aging period. However, in DOE’s view, 

the conclusions reached in those studies 

illustrate that impermeably faced foams 

are subject to aging. DOE agrees with 

ORNL’s evaluation of the flaws in the 

round robin test data but notes that the 

same test was used on each type of foam 

evaluated, which permits a comparison 

of the results from each type of tested 

foam. DOE used the results of the round 

robin test to demonstrate that there were 

no performance differences between 

polyurethane and polystyrene foams— 

not to predict the level of thermal 

resistance over time. 

Interested parties also commented on 

the specific testing conditions for ASTM 

C1303–10. ORNL proposed that, if 

adopted, ASTM C1303–10 should be 

modified to allow the user to take 

multiple 12 inch x 12 inch specimens 

from the 48 inch x 96 inch panel, at 

least 12 inches away from the edge of 

the 48 inch x 96 inch source. (ORNL, 

No. 0060.1 at p. 2) ORNL suggested 

specifying the aging conditioning 

temperatures for foam insulation. ORNL 

explained that while most insulation 

foams must follow aging condition 

requirements, the conditions used to age 

bun stock foam, which is used in 

producing foam insulation, may be 

freely modified. This situation could 

lead to skewed comparisons between 

products. (ORNL, No. 0060.1 at p. 2) 

Manufacturers also offered views 

regarding these proposed testing 

conditions. Craig Industries, Carpenter, 

and Owens Corning stated that the 

procedures detailed in ASTM C1303–10 

should be conducted at the specified 

EPCA mean temperatures 55 °F and 20 

°F for a cooler and freezer, respectively. 

(Craig Industries, 0068.1 at p. 4; 

Carpenter, No. 0067.1 at p. 3; Owens 

Corning, No. 0058.1 at p. 2) Carpenter 

also suggested modifying DOE’s 

proposal by adding a provision for 

molding test panels using unprimed 

aluminum facers. (Carpenter, No. 0067.1 

at p. 3) NRDC asserted that the proposed 

temperatures for testing insulation 

needed to be substantiated. (NRDC, 

0064.1 at p. 4) Craig Industries asserted 

that the modifications to ASTM C1303– 

10 proposed by DOE in the September 

2010 SNOPR test were acceptable, but 

wanted DOE to ensure that the changes 

would also apply to expanded 

polystyrene insulation. (Craig 

Industries, No. 0068.1 at p. 4) Bally 

suggested that the initial panel size 

should be changed to 48 inches ± 3 

inches and 96 inches ± 2 inches so that 

a standard panel configuration could be 

used for the test panel. Bally stated that 

manufacturers could incur significant 

costs from manufacturing test panels. 

(Bally, No. 0078.1 at p. 2) 

While DOE appreciates ORNL’s and 

Bally’s suggested improvements to 

ASTM C1303–10, these 

recommendations are no longer relevant 

since DOE has decided to adopt DIN EN 

13165:2009–02 and DIN EN 

13164:2009–02, which collectively 

address some of the shortcomings of 

ASTM C1303–10. For example, DIN EN 

13165:2009–02 and DIN EN 

13164:2009–02 provide for inclusion of 

metal facers, while ASTM C1303–10 

does not. In regard to Bally’s concern 

about the size of the test panel, a test 

panel is no longer required to be a 

certain size as long as the panel is large 

enough for the test sample to be cut 

from its geometric center, as prescribed 

in Appendix A. Additionally, given the 

comments from Craig Industries, 

Carpenter, Owens Corning, and NRDC 

about the temperature conditions for 

testing, DOE has decided to adopt the 

EPCA mean temperatures of 55 °F and 


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20 °F for a cooler and freezer, 

respectively for the DIN EN 

13165:2009–09 and DIN EN 

13164:2009–02 testing conditions. This 

means that when a manufacturer tests a 

panel for LTTR, the manufacturer will 

determine the initial and aged R-value 

as specified by DIN EN 13165:2009–09 

and DIN EN 13164:2009–02 except the 

panel will be rated at 55 °F and 20 °F 

for a cooler and freezer, respectively. By 

deviating from the temperature 

condition specified in DIN EN 

13165:2009–09 and DIN EN 

13164:2009–02, the fixed increment 

values and safety increment values will 

be slightly more conservative than the 

values that would be expected if the 

LTTR test were performed at the 

temperature condition specified in DIN 

EN 13165:2009–09 and DIN EN 

13164:2009–02, when applied to freezer 

panels. 

In response to Craig Industries’ 

comment that whatever method is 

adopted should be applicable to 

expanded polystyrene foam, DOE notes 

that the foam aging procedures it 

proposed are only applicable to foams 

that rely on low conductivity blowing 

agents that are intended to stay within 

the foam for the life of the product. 

Because it is DOE’s understanding that 

expanded polystyrene foam is not 

blown with low conductivity blowing 

agents that are intended to remain in the 

product for its usable life and does not 

exhibit long term changes in thermal 

resistance, these tests would not apply, 

nor would they be needed to assess the 

long term thermal resistance of this type 

of foam. 

One commenter did not agree with 

the proposed use of any of the protocols. 

Thermo-Kool disagreed with both 

ASTM C1303–10 and DIN EN 

13165:2009–02 and DIN EN 

13164:2009–02 because none of these 

protocols, in its view, is designated for 

testing composite panels faced with 

metal skins. (Thermo-Kool, 0072.1 at p. 

1) DOE agrees with Thermo-Kool that 

ASTM C1303–10 was not designed to 

test panels with metal facers. However, 

DIN EN 13165:2009–02 and DIN EN 

13164:2009–02 were designed to 

account for metal facers on foam. DIN 

EN 13165:2009–02 and DIN EN 

13164:2009–02 allow all metal skins or 

facers to remain on the foam during 

aging and testing. See, e.g., DIN EN 

13165:2009–02, Annex C (instructing in 

relevant part to ‘‘select a product sample 

including any product facing.’’). 

DOE notes that many of the interested 

parties that opposed using ASTM 

C1303–10 to measure LTTR supported 

using DIN EN 13165:2009–02 and DIN 

EN 13164:2009–02 instead. Carpenter 

agreed with using DIN EN 13165:2009– 

02 and DIN EN 13164:2009–02 as an 

alternative to ASTM C1303–10. 

(Carpenter, No. 0067.1 at p. 2) Hill 

Phoenix and AHRI requested more time 

to review the European test procedure, 

but Hill Phoenix’s initial assessment 

was that DIN EN 13165:2009–02 was a 

better option than ASTM C1303–10. 

(Hill Phoenix, No. 0063.1 at p. 2; AHRI, 

No. 0070.1 at p. 2) Hill Phoenix added 

that DOE should adopt test procedures 

that are appropriate for the insulation 

materials that could be found in walkin panels, which DOE interprets to 

mean that Hill Phoenix is suggesting 

that DOE adopt both DIN EN 

13165:2009–02 and DIN EN 

13164:2009–02 if DOE uses these 

standards instead of ASTM C1303–10. 

(Hill Phoenix, No. 0063.1 at p. 2) 

Master-Bilt also stated DIN EN 

13165:2009–02 and DIN EN 

13164:2009–02 seemed to better account 

for long-term degradation of foam 

performance, though they 

acknowledged they did not fully 

understand DIN EN 13165:2009–02 and 

DIN EN 13164:2009–02. (Master-Bilt, 

No. 0069.1 at p. 2) 

Other stakeholders had reservations 

about DIN EN 13165:2009–02 and DIN 

EN 13164:2009–02. Craig Industries 

stated that the alternatives to ASTM 

C1303–10 may ignore the fact that 

different plastic foam product 

insulations in the marketplace respond 

differently to heat. (Craig Industries, No. 

0068.1 at p. 4) It added that DOE should 

prevent foamed-in-place walk-in 

manufacturers from picking the most 

efficient part of the panel for testing. 

(Craig, No. 0068.1 at p. 4) Owens 

Corning noted that DIN EN 13165:2009– 

02 and DIN EN 13164:2009–02 appeared 

to be material standards and not test 

methods, and Owens Corning asked for 

clarification on what the test method 

would be. (Owens Corning, 0058.1 at p. 

1) NRDC suggested that DOE review the 

proposed standards, ASTM C1303–10, 

DIN EN 13165:2009–02, and DIN EN 

13164:2009–02, to determine which 

standard yields better results, and what 

the related testing burden would be to 

adopt a foreign standard. (NRDC, No. 

0064.1 at p. 4) 

DOE notes Carpenter’s, Hill 

Phoenix’s, AHRI’s, and Master-Bilt’s 

approval of DIN EN 13165:2009–02 and 

DIN EN 13164:2009–02, and in light of 

the criticisms that DOE has received 

about ASTM C1303–10 and the support 

for DIN EN 13165:2009–02 and DIN EN 

13164:2009–02, DOE has decided to 

adopt DIN EN 13165:2009–02 and DIN 

EN 13164:2009–02 as the test procedure 

for determining LTTR of polyurethane 

products and extruded polystyrene 

products, respectively (polyisocyanurate 

products are covered by the test for 

polyurethane products). Today’s final 

rule provides that the LTTR value 

determined by Annex C of DIN EN 

13165:2009–02 or DIN EN 13164:2009– 

02 shall be used to determine a 

degradation factor. The degradation 

factor will be the LTTR R-value divided 

by the original R-value of the foam. The 

original R-value of the foam will be 

tested with ASTM C518–04, as specified 

by the EISA 2007 amendments to EPCA, 

and can be used for compliance with the 

relevant R-value requirement 

established by those amendments. (42 

U.S.C. 6313(f)(1)(C)) The degradation 

factor is applied to the U-factor of the 

panel found by ASTM C1365–05; see 

section 4.2 and 4.3 in Appendix A. 

In response to Owens Corning’s 

comment that DIN EN 13165:2009–02 

and DIN EN 13164:2009–02 appeared to 

be material standards and not test 

methods, DOE notes that Annex C of 

both DIN EN 13165:2009–02 and DIN 

EN 13164:2009–02 provide the 

methodology for testing. DOE also notes 

Craig Industries’ concern about using 

heat to test for LTTR and NRDC’s 

recommendation that DOE compare the 

different standards that were proposed; 

however, DOE believes DIN EN 

13165:2009–02 and DIN EN 

13164:2009–02 are more accurate and 

appropriate for assessing the long-term 

performance of impermeably faced 

foams used in walk-in coolers and 

freezers because they permit panels to 

be tested with their facers, and accounts 

for impermeably faced foam. Also, to 

address Craig Industries’ concern about 

manufacturers not all choosing the same 

part of the panel, DOE is requiring that 

this test sample should be taken from 

the geometric center of the test 

specimen. 

DOE is largely incorporating DIN EN 

13165:2009–02 and DIN EN 

13164:2009–02 except for the 

requirement that the thermal resistance 

measurement is conducted at a mean 

temperature of 10 °C. DOE has decided 

to adopt the EPCA mean temperatures of 

55 °F and 20 °F for a cooler and freezer, 

respectively for the DIN EN 

13165:2009–09 and DIN EN 

13164:2009–02 testing conditions. 

However, the manufacturer will still 

have to follow any applicable aging 

conditions prescribed by DIN EN 

13165:2009–09 and DIN EN 

13164:2009–02. By deviating from the 

temperature condition specified in DIN 

EN 13165:2009–09 and DIN EN 

13164:2009–02, the fixed increment 

values and safety increment values will 

be slightly more conservative than the 

values that would be expected if the 


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LTTR test were performed at the 

temperature condition specified in DIN 

EN 13165:2009–09 and DIN EN 

13164:2009–02, when applied to freezer 

panels. 

c. Moisture Absorption 

In the January 2010 NOPR, DOE 

discussed the possibility of testing the 

impact of moisture absorption on the Rvalue of different insulation materials, 

evaluated various tests developed by 

ASTM, and reviewed a research paper 

completed by the U.S. Army Corps of 

Engineers’ Cold Regions Research and 

Engineering Laboratory (CRREL), which 

Owens Corning submitted to the docket. 

(Owens Corning, No. 0054.3 at p. 1) 

DOE initially concluded that testing the 

effect of moisture absorption on the Rvalue of insulation foam would be 

complex, costly, and time-consuming, 

and that there was no well-accepted 

testing method. As a result, DOE 

proposed that the impact of water 

absorption on R-value not be included 

in the test procedure. 75 FR 186, 194 

(Jan. 4, 2010). 

DOE received many comments from 

interested parties that supported the 

inclusion of some means to account for 

the effect of water infiltration. At the 

NOPR public meeting, and in several 

written comments, Craig Industries 

urged DOE to test for and include the 

impact of moisture absorption in foam. 

(Craig Industries, Public Meeting 

Transcript, No. 0016 at p. 248; Craig 

Industries, No. 0035.1 at p. 3; Craig 

Industries, No. 0068.1 at p. 5; Craig 

Industries, No. 0057.13 at p. 5) ACEEE 

also stated that it was imperative to 

include the effect of moisture 

absorption. (ACEE, No. 0052.1 at p. 2) 

Kysor maintained that moisture did not 

affect the R-value of poured-in-place 

polyurethane, but laminated panels 

would be severely affected by water 

because of the water-based glue used to 

bond the insulation to the metal skins. 

(Kysor, No. 0053.1 at p. 3) 

Some interested parties suggested 

possible tests and studies that could be 

used to measure the effect of water 

absorption. For example, Craig 

Industries and Owens Corning referred 

to the CRREL study for information 

about the performance of various 

materials with water. (Craig Industries, 

No. 0054.1 at p. 2; Owens Corning, 

Public Meeting Transcript, No. 0016 at 

p. 250) Nor-Lake suggested that an 

adequate test for water absorption 

would be ASTM D2842–06, ‘‘Standard 

Test Method for Water Absorption of 

Rigid Cellular Plastics.’’ (Nor-Lake, No. 

0047.1 at p. 3) Owens Corning suggested 

that ASTM E96, ‘‘Standard Test Methods 

for Water Vapor Transmission of 

Materials,’’ could be used to test water 

vapor permeability rates and determine 

the effect of moisture absorption on 

foam. (Owens Corning, Public Meeting 

Transcript, No. 0016 at p. 253; Owens 

Corning, No. 0048.1 at p. 1; Owens 

Corning, No. 0032.1 at p. 3) Owens 

Corning also suggested that ASTM E96 

could be used to identify suitable 

materials for walk-in cooler and walk-in 

freezer applications. (Owens Corning, 

No. 0048.1 at p. 1 and No. 0032.1 at p. 

3) 

Additionally, joint comments filed by 

SCE, SMUD, SDG&E, and SCG on the 

January 2010 NOPR, hereafter referred 

to as the Joint Comment, added that 

although ASTM E96 produces a 

conservatively low estimate of moisture 

permeance at high vapor pressures, DOE 

should evaluate whether using ASTM 

E96 is better than not accounting for the 

effect of moisture on insulating foam. 

(Joint Comment, No. 0037.1 at p. 11) 

The Joint Comment added that there 

may be difficulties in testing and 

characterizing R-value deterioration in 

foams due to moisture absorption, but 

DOE should still consider a requirement 

for testing vapor permeability. (Joint 

Comment, No. 0037.1 at p. 1) Owens 

Corning also stated that, since DOE 

raised the proposed relative humidity 

assumption for the test condition from 

45 percent to 75 percent in the 

September 2010 SNOPR, DOE implicitly 

acknowledged the high humidity 

conditions present in walk-in cooler and 

freezer environments, which, in its 

view, supported the consideration of the 

impact of moisture on the thermal 

performance of a walk-in over its 

lifetime. (Owens Corning, No. 0058.1 at 

p. 2) ACEEE suggested that because a 

major threat to moisture control for 

panels is the integrity of the exterior 

skin, a minimally intrusive method to 

determine the impact of moisture 

absorption would be to assess the vapor 

diffusion integrity of the sealed panel. 

(ACEEE, No. 0052.1 at p. 2) 

Other interested parties did not 

support including water absorption in 

the test procedure. ThermalRite stated 

that moisture infiltration was unlikely 

to occur in properly constructed panels, 

water infiltration would most likely be 

the result of improper materials or 

manufacturing, and that moisture 

infiltration should be considered 

inconsequential and removed from 

proposed test procedures. (ThermalRite, 

No. 0045.1 at p.1; ThermalRite, No. 

0045.1 at p. 2; ThermalRite, No. 0049.1 

at p.2) ICS commented that water 

infiltration is related to panel 

installation and that there were no data 

to support that moisture infiltration is 

caused by the walk-in’s manufacture or 

design. (ICS, Public Meeting Transcript, 

No. 0016 at p. 253; ICS, No. 0045.1 at 

p. 1) ICS went on to state that, under 

actual and average usage conditions, 

water absorption in foam is negligible 

and it recommended that the impact of 

moisture absorption should be removed 

from the proposed test procedure. (ICS, 

No. 0045.1 at p. 1; ICS, No. 0045.1 at p. 

2) Hill Phoenix commented that 

moisture absorption was not an issue 

and any moisture issues were generally 

reported by the walk-in cooler or walkin freezer user and were quickly 

repaired. (Hill Phoenix, No. 0041.1 at p. 

2) Carpenter agreed with DOE that the 

impact of water absorption of foam 

would be difficult to study and quantify, 

and added that polyurethane foam has 

an inherently low permeability, which 

would minimize water absorption. 

(Carpenter, No. 0043.1 at p. 2) TAFCO 

concurred that moisture infiltration into 

polyurethane foam is not an issue, and 

that it would not cause the R-value to 

degrade significantly over time. 

(TAFCO, No. 0040.1 at p. 2) TAFCO also 

stated that they have installed panels in 

high-humidity environments and they 

did not encounter any cases of water 

absorption by panels. It urged that DOE 

not pursue this issue further. (TAFCO, 

No. 0040.1 at p. 2) 

DOE understands that interested 

parties have concerns regarding the 

potential impact of moisture absorption 

on the thermal performance of 

insulating material over the lifetime of 

a walk-in cooler or freezer. Prior to the 

publication of the January 2010 NOPR, 

DOE reviewed several methods for 

testing vapor permeance and water 

absorption in foam insulation materials. 

However, this review of various test 

methods showed that there were 

disparities among the different methods, 

and that there was no general agreement 

upon a single approach. 75 FR 186, 194 

(Jan. 4, 2010). Moreover, while these 

tests are designed to measure the 

performance of insulating foam by itself, 

they would not account for the many 

unique construction methods and 

combinations of materials employed by 

manufacturers of panels to minimize 

moisture infiltration. 

At this time, test procedures for 

measuring the impact of water on foam 

R-value are not yet recognized by a 

national organization such as ASTM. 

DOE notes that because of the absence 

of any nationally recognized testing 

standards, it would need to develop 

such a protocol. To this end, one of 

DOE’s national labs is in the process of 

developing procedures to evaluate the 

impact of moisture on insulation Rvalues. Accordingly, because of the 

potential ambiguities that are currently 


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present with respect to the means by 

which to assess the impact of moisture 

absorption on the thermal performance 

of insulating material over time, DOE is 

not incorporating a method to account 

for moisture absorption at this time. 

DOE may, however, consider adopting 

such a procedure in the future. 

d. Display Panels 

In the September 2010 SNOPR, DOE 

proposed that glass walls (‘‘display 

panels’’) would be tested using NFRC 

100–2001–E0A to measure their thermal 

transmittance, or U-factor. 75 FR 55068, 

55098 (Sept. 9, 2010). Display panels are 

typically found on beer caves and share 

many characteristics with display doors. 

Notably, they are readily tested or 

simulated using the procedure in NFRC 

100–2001–E0A. DOE received no 

comments regarding its proposed 

approach for display panels. 

Consequently, DOE is including this test 

procedure (to be codified in section 4.1 

of Appendix A) to measure the thermal 

transmittance of display panels or walls. 

Additionally, to improve clarity, DOE is 

defining ‘‘display panels’’ as a panel that 

is entirely or partially comprised of 

glass, a transparent material, or both and 

is used for display purposes. 

e. Open Areas of Walk-Ins 

The test procedure DOE is 

establishing today contains tests for 

components of walk-ins that separate 

the interior refrigerated environment of 

the walk-in from the exterior. Zero Zone 

stated that the test procedure should 

include a method to determine the 

energy use for walk-ins that have open 

areas to display food. (Zero Zone, No. 

0077.1 at p. 1) Because an open area 

does not, by definition, separate the 

interior refrigerated environment of the 

walk-in from the exterior, an open area 

is not a component of the walk-in that 

is covered under this test procedure. 

Accordingly, DOE is not adopting Zero 

Zone’s suggestion. 

3. Energy Use of Doors 

a. U-Factor of Doors 

In the September 2010 SNOPR, DOE 

proposed to rate the total thermal 

transmittance (i.e. U-factor) of doors, 

including their framing materials or 

complete door plug, using the test 

procedure NFRC 100–2010[E0A1], 

‘‘Procedure for Determining Fenestration 

Product U-factors.’’ 75 FR 55068, 55083 

(Sept. 9, 2010). DOE specified internal 

and external rating conditions for the 

test procedure to closely match 

conditions that would be experienced 

by the door when it is part of a walkin. 

NEEA strongly supported DOE’s use 

of NFRC 100–2010[E0A1] procedures 

for testing the performance of walk-in 

cooler and freezer doors. (NEEA, No. 

0061.1 at p. 2) NRDC agreed with DOE’s 

use of NFRC 100–2010[E0A1] for rating 

doors with the proposed changes to the 

temperatures used for the testing 

procedure. (NRDC, No. 0064.1 at p. 6) 

DOE notes NEEA’s and NRDC’s 

support and has incorporated the use of 

NFRC 100–2001–E0A1 in this final rule. 

DOE also notes that none of the 

interested parties submitted comments 

that disagreed with using NFRC 100– 

2001–E0A1. The thermal transmittance 

result from NFRC 100–2001–E0A1 is 

then used to calculate the corresponding 

energy consumption of a refrigeration 

system whose efficiency is given in 

sections 4.4 and 4.5 of Appendix A for 

display and non-display doors, 

respectively. This energy metric is 

combined with the electricity 

consumption from electrical door 

components to calculate the door’s total 

energy consumption. 

b. Electrical Components of Doors 

As described in section III.A.1, the 

test metric for doors includes the energy 

consumed by electrical components 

associated with a walk-in door. The 

electricity consumed by the door will be 

the sum of the rated power associated 

with each electricity consuming device 

multiplied by the assumed time the 

device will be operational. Percent time 

off (PTO) assumptions are given in 

sections 4.4.2 and 4.5.2 of Appendix A 

for display and non-display doors, 

respectively. PTO assumptions are 

specified for some electrical 

components, such as anti-sweat heater 

wire. For any electricity consuming 

devices for which a PTO is not specified 

in Appendix A, today’s final rule 

provides that if a manufacturer can 

demonstrate that the device is 

controlled by a preinstalled timer, 

control system or other auto-shut-off 

system, the PTO is assumed to be 25 

percent. For example, if a door has a 

thermometer mounted on it that 

consumes electricity, but the 

thermometer has a built in timer so that 

it shuts off at certain times, then the 

manufacturer of the door can use the 

PTO value of 25 percent when 

calculating the energy consumption of 

the thermometer. 

The test procedure also provides a 

means for measuring the heat generation 

of door electrical components that are 

located on the inside surface of the 

door. This heat is added to the heat 

transmitted through the door and the 

corresponding refrigeration energy use 

is calculated using the method 

described in section III.B.3.c. The 

refrigeration energy use is added to the 

electrical energy use to calculate the 

total energy consumption of the door. 

DOE received a comment challenging 

its assumptions about heat from 

electrical devices. Zero Zone disagreed 

with the assumption that all anticondensate heat contributes to the walkin heat load, and instead suggested that 

50 to 75 percent of the anti-condensate 

heat going into the display case would 

be a more appropriate assumption. (Zero 

Zone, No. 0077.1 at p. 2) After further 

analysis, DOE agrees with Zero Zone’s 

observation that not all anti-condensate 

heat necessarily contributes to the walkin heat load because the anti-condensate 

heat is applied to the transparent 

surface of the display case. Because one 

side of the transparent surface is in 

contact with the surrounding external 

environment, a portion of the heat is 

transmitted from the display case to the 

surrounding environment. Therefore, 

DOE has revised the equations in 

sections 4.4.2and 4.5.2of Appendix A to 

capture only 75 percent of the power 

from anti-sweat heaters as an additional 

compressor load. 

c. Energy Efficiency Ratio 

In the January 2010 NOPR, DOE 

proposed to require that manufacturers 

measure the energy use of walk-in 

cooler and walk-in freezer envelopes in 

kWh/day. However, most metrics used 

to describe heat transfer losses are in 

units of British thermal units (Btu) per 

unit time. In order to convert the 

thermal energy transmission calculation 

(Btu/hr) into a measure of electrical 

energy consumed by the refrigeration 

equipment, DOE proposed to use an 

energy efficiency ratio based on a 

nominal efficiency of an assumed 

refrigeration system. The EER values 

proposed for coolers and freezers were 

12.4 Btu/W-h and 6.3 Btu/W-h 

respectively. The values were selected 

to provide a means of comparison and 

were not intended to represent the 

actual efficiency of the refrigeration 

system with which the envelope would 

ultimately be paired. 75 FR 186, 197 

(Jan. 4, 2010). Although the test 

procedure no longer requires one to 

calculate the overall envelope energy, 

the concept is still relevant for 

calculating door energy. 

DOE received comments in response 

to the January 2010 NOPR regarding the 

use of an EER value, the assumptions 

used to calculate the EER value, and the 

proposed EER values for coolers and 

freezers. BASF commented that the 

proposed EER assumptions were 

reasonable. (BASF, No. 0021.1 at p. 4) 

Nor-Lake agreed with DOE’s use of a 


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nominal EER value to convert the 

thermal energy transmission to 

electrical energy consumption. (NorLake, No. 0047.1 at p. 5) Master-Bilt also 

agreed with the proposed use of a 

nominal EER but stated that the 

proposed EER values are not achievable. 

(Master-Bilt, No. 0027.1 at p. 2) Kason 

requested that the nominal EER values 

be reassessed to represent real world 

values. (Kason, No. 0055.1 at p. 4) NorLake commented that the EER values on 

their refrigeration models did not match 

DOE’s proposed nominal values. (NorLake, 0023.1 at p. 4) 

DOE considered these comments and, 

in conjunction with the supportive 

comments from Master-Bilt, Nor-Lake, 

and BASF, continues to use an EER 

value to relate the thermal energy 

transmission to the electrical energy 

consumed for doors. Despite the 

comments from Kason, Master-Bilt, and 

Nor-Lake, DOE finds 12.4 Btu/W-h and 

6.3 Btu/W-h to be appropriate 

conversions for walk-in coolers and 

walk-in freezers, respectively, because 

these EER values correspond to nominal 

EER values contained in the 

refrigeration test procedure for unit 

coolers connected to multiplex 

condensing systems (AHRI 1250 (I–P)– 

2009). DOE is aware that the nominal 

values for this configuration may not 

represent all walk-ins, but notes that 

these EER values are intended to 

provide a means of comparison and not 

directly reflect a real walk-in 

installation. In particular, these EER 

assumptions are not intended to 

represent the expected efficiency of any 

particular refrigeration system produced 

by a manufacturer and are provided as 

a method to converting thermal energy 

to electrical energy consumed by a 

refrigeration system. 

4. Heat Transfer via Air Infiltration 

In the January 2010 NOPR, DOE 

stated that, compared with other energy 

consumption factors such as conduction 

losses through insulation, air infiltration 

may be the largest contributing factor to 

envelope thermal load. That notice 

identified two infiltration pathways: 

steady state leakage and air losses due 

to door-opening events. To address this 

issue, DOE proposed to include test 

procedures to measure the steady state 

infiltration and infiltration from door 

opening events and subsequently 

modified these test procedures in 

response to comments to the September 

2010 SNOPR. See 75 FR 196–197 (Jan. 

4, 2010) and 75 FR 55084–55086 (Sept. 

9, 2010). Interested parties submitted 

comments pertaining to the topic of 

envelope infiltration, including steady 

state infiltration, door opening 

infiltration, calculations, and empirical 

methodologies for quantifying the 

effects of infiltration. 

a. Steady State Infiltration 

In the January 2010 NOPR, DOE 

proposed that steady state infiltration of 

fully assembled envelopes must be 

tested using the method described in 

ASTM E741–06, ‘‘Standard Test Method 

for Determining Air Change in a Single 

Zone by Means of a Tracer Gas 

Dilution.’’ 75 FR 196 (Jan. 4, 2010). 

Some interested parties stated that 

steady state infiltration should not be 

included in the test procedure. Hill 

Phoenix maintained that an insufficient 

amount of infiltration would occur in a 

properly installed walk-in, essentially 

suggesting that DOE abandon the 

inclusion of infiltration in the test. (Hill 

Phoenix, No. 0063.1 at p. 2) AHRI 

concurred, stating that a steady-state 

infiltration test is not necessary due to 

the insignificant amount of infiltration 

present in a walk-in * * * (AHRI, No. 

0070.1 at p. 3) Master-Bilt agreed, 

suggesting that testing steady-state 

infiltration is unnecessary because this 

infiltration is insignificant compared 

with infiltration from door openings. 

(Master-Bilt, No. 0069.1 at p. 2) NRDC 

suggested that DOE confirm the 

assumption that the impact of 

infiltration and exfiltration through the 

envelope is minimal compared to the 

infiltration through the doors, and 

suggested that DOE should weigh each 

impact. (NRDC, No. 0064.1 at p. 6) 

Other interested parties commented 

on the specific test methods DOE 

proposed in the January 2010 NOPR for 

measuring steady-state infiltration of 

walk-in envelopes. TAFCO stated that 

ASTM E741–06, Standard Test Method 

for Determining Air Change in a Single 

Zone by Means of a Tracer Gas Dilution, 

is an acceptable method for determining 

steady state air infiltration. (TAFCO, No. 

0040.1 at p. 3) ACEEE also agreed with 

using ASTM E741–06. (ACEEE, 0052.1 

at p. 3) NEEA commented that either 

ASTM E741–06 or a standard blower 

test is a reasonable method of 

calculating steady state infiltration, but 

noted that the blower test would be 

faster and less costly to administer. 

Therefore, NEEA recommended that 

DOE test ASTM E741–06 and the 

standard blower door test before 

prescribing which methodology must be 

used. (NEEA, No. 0061.1 at p. 2) Kysor, 

on the other hand, stated that it is 

neither necessary nor cost effective to 

assemble an entire walk-in to test for air 

infiltration. Kysor stated that each 

component should be tested separately 

and recommended that DOE use ASTM 

E1424–08, Standard Test Method for 

Determining the Rate of Air Leakage 

Through Exterior Windows, Curtain 

Walls, and Doors Under Specified 

Pressure and Temperature Differences 

Across the Specimen, and ASTM 

E2357–05, Standard Test Method for 

Determining Air Leakage of Air Barrier 

Assemblies, because either can test any 

assembly that will become part of a 

walk-in. (Kysor, No. 0053.1 at p. 3) 

In the January 2010 NOPR, DOE 

proposed that ASTM E741–06 should be 

used to measure infiltration; however, 

in the September SNOPR, DOE 

determined that ASTM E741–06 could 

present an undue burden for 

manufacturers with respect to the many 

door combinations that are possible. 

Therefore, DOE proposed in its 

September 2010 SNOPR to also consider 

measuring steady state infiltration 

through doors using NFRC 400–2010– 

E0A1, ‘‘Procedure for Determining 

Fenestration Product Air Leakage.’’ 75 

FR 55068, 55084 (Sept. 9, 2010). 

Interested parties commented on 

NFRC 400–2010–E0A1 and suggested 

alternatives. NRDC agreed with using 

NFRC 400–2010–E0A1 to determine 

infiltration of individual envelope 

components, but also recommended 

using a pressurization test to determine 

infiltration of fully assembled 

envelopes, based on ASTM D6670, 

‘‘Standard Practice for Full-Scale 

Chamber Determination of Volatile 

Organic Emissions from Indoor 

Materials/Products.’’ (NRDC, No. 2.3.008 

at p. 6) AHRI recommended that 

infiltration could be estimated for a 

family of doors by using a scaling 

methodology based on a limited number 

of tests. AHRI cautioned DOE against 

requiring the manufacturer to test every 

single door because it would be 

burdensome. (AHRI, No. 2.3.015 at p.3) 

Some interested parties commented on 

the prescribed testing conditions to be 

implemented with NFRC 400–2010– 

E0A1. American Panel stated that the 

proposed steady state infiltration test 

unit is not representative of the average 

walk-in size and suggested a more 

representative size of 8 feet by 12 feet 

by 8 feet high. (American Panel, No. 

2.3.001 at p. 3) American Panel, NEEA, 

and Bally concurred with DOE’s 

assumption of 75 percent relative 

humidity, which DOE proposed as a 

condition of testing. (American Panel, 

No. 2.3.001 at p. 3; NEEA, No. 2.3.005 

at p. 5; Bally, No. 0078.1 at p.2) 

DOE notes the specific comments and 

suggestions from TAFCO, NEEA, 

ACEEE, Kysor, NRDC, AHRI, and 

American Panel, but has decided not to 

include steady state infiltration in the 

WICF test procedure at this time. In 

response to NRDC’s suggestion that DOE 


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weigh the impact of steady-state 

infiltration against other sources of 

infiltration, DOE believes that the 

contribution of steady state infiltration 

towards the aggregate energy 

consumption of a well-constructed 

factory-built walk-in unit is most likely 

negligible compared to other energy 

consumption pathways for current 

WICF designs. Higher steady-state 

infiltration across the envelope for siteassembled walk-in coolers and freezers 

appears to be generally caused by poor 

installation and construction practices. 

As such, DOE is not incorporating an 

overall infiltration measurement, which 

is a factor that relies heavily on on-site 

assembly practices rather than the 

performance of individual components. 

Given that today’s final rule includes a 

means to assess the performance of 

specific individual components, the 

performance of these components will 

be captured under the new procedure 

and should be sufficiently adequate 

prior to their installation as part of a 

completed walk-in unit. Should this 

prove not to be the case, DOE may reexamine the procedure and consider 

modifications to address its potential 

shortcomings. 

b. Door Opening Infiltration 

In the January 2010 NOPR, DOE 

proposed to calculate air infiltration 

associated with each door-opening 

event using established analytical 

methods based on equations and 

computational values published in the 

ASHRAE Refrigeration Handbook. DOE 

also made several assumptions in the 

test procedure that could have a 

significant impact on the predicted air 

exchange. The assumptions with the 

most impact were the number of 

doorway passages (the number of dooropening cycles for a given door), door 

open-close time, and the amount of time 

the door is held or propped open. 75 FR 

186, 196 (Jan. 4, 2010). In the September 

2010 SNOPR, DOE did not propose to 

change the basic methodology, but 

modified some of the assumptions in 

order to differentiate door types. 75 FR 

55068, 55085 (Sept. 9, 2010). 

Some interested parties supported the 

proposed method. Hired Hand agreed 

with the methodology used for 

calculating the air infiltration from door 

openings. (Hired Hand, Public Meeting 

Transcript, No. 0016 at p. 309) Hired 

Hand emphasized that air infiltration 

may be the largest contributing factor to 

envelope energy losses. (Hired Hand, 

Public Meeting Transcript, No. 0016 at 

p. 28; Hired Hand, Public Meeting 

Transcript, No. 0016 at p. 279; Hired 

Hand, Public Meeting Transcript, No. 

0016 at p. 285) American Panel 

suggested the use of ASHRAE values for 

heat load as the best way to account for 

the effects of air infiltration. (American 

Panel, No. 0042.1 at p. 2) ThermalRite, 

Nor-Lake, and Master-Bilt agreed with 

American Panel’s suggestion. 

(ThermalRite, No. 0049.1 at p. 2; NorLake, No. 0047.1 at p.4; Master-Bilt, 

Public Meeting Transcript, No. 0016 at 

p. 311) Master-Bilt and Zero Zone also 

agreed with DOE’s assumptions 

regarding infiltration attributed to door 

openings. (Master-Bilt, No. 0069.1 at p. 

2; Zero Zone, No. 0077.1 at p. 2) 

Other interested parties questioned 

the applicability of the method to walkin cooler and freezer doors, or 

questioned DOE’s assumptions in 

calculating door opening infiltration. 

Schott Gemtron contended that 

ASHRAE equations may be based on 

supermarket display cases, implying 

that they may not be applicable to some 

walk-in doors. (Schott Gemtron, Public 

Meeting Transcript, No. 0016 at p. 314) 

Hired Hand was concerned that the 

proposed test procedures do not account 

for the effect of fast-acting doors on air 

infiltration. (Hired Hand, Public 

Meeting Transcript, No. 0016 at p. 286) 

SCE and Hired Hand both stated that the 

parameters used to calculate air 

infiltration should clearly show the 

benefit of fast-acting doors. (SCE, Public 

Meeting Transcript, No. 0016 at p. 320; 

Hired Hand, Public Meeting Transcript, 

No. 0016 at p. 320) Hired Hand also 

recommended that the equations used to 

calculate air infiltration should be based 

on the operational time the doors are 

opened over an assumed 24-hour day. 

(Hired Hand, No. 0051.1 at p. 4) Zero 

Zone stated that any air infiltration 

calculations should include additional 

air infiltration if the evaporator is 

discharging air in the direction of the 

display doors. (Zero Zone, No. 0077.1 at 

p. 1) Bally stated that hybrid walk-ins, 

that is, walk-ins sited within another 

walk-in, should be given beneficial 

consideration. Bally explained that a 

walk-in freezer sited inside a walk-in 

cooler would experience less infiltration 

because of the smaller temperature 

differential between the interior and 

exterior of the freezer. (Bally, No. 0078.1 

at p.2) 

Interested parties also made specific 

comments on the effect of infiltration 

reduction devices (IRDs). ACEEE and 

ThermalRite supported the infiltration 

device effectiveness test methodology. 

(ACEEE, No. 0052.1 at p. 3; 

ThermalRite, No. 0049.1 at p. 2) TAFCO 

also stated that ASTM E741–06 is an 

acceptable method for determining IRD 

effectiveness. (TAFCO, No. 0040.1 at p. 

3) NRDC stated that the proposed door 

opening infiltration calculation from 

ASHRAE Fundamentals 2009 is 

acceptable for conventional doors, but 

when doorways are protected by an air 

curtain or other infiltration reduction 

device, calculations should include the 

effect of such devices on energy use. 

(NRDC, No. 0064.1 at p. 6) 

Master-Bilt commented that air 

infiltration from door openings cannot 

be modeled in a meaningful way and 

should be excluded from the test 

methodology. (Master-Bilt, No. 0027.1 at 

p. 2) Hill Phoenix noted that the panel 

manufacturer has no bearing on door 

opening frequency, which accounts for 

the majority of the infiltration. (Hill 

Phoenix, No. 0063.1 at p. 2) NEEA 

suggested that DOE should not make 

assumptions about the nature of the use 

of a particular walk-in. (NEEA, No. 

0061.1 at p. 5) Instead, it recommended 

that DOE include a prescriptive 

requirement for infiltration reduction 

devices. (NEEA, No. 0061.1 at p. 5) 

DOE has decided not to include any 

test procedure for door opening 

infiltration following its decision to 

have component-level test procedures 

and standards. Door infiltration is 

primarily reduced by incorporating a 

separate infiltration reduction device at 

the assembly stage of the complete 

walk-in. Based on DOE’s understanding 

of the door manufacturing industry, a 

typical door manufacturer has very few 

direct means for reducing the door 

infiltration on its own since IRDs are 

generally designed and manufactured 

independently from doors and they 

require proper field installation to 

achieve rated performance. 

Consequently, at this time, DOE is not 

incorporating provisions that would 

require measuring the effectiveness of 

the infiltration reduction devices and 

door infiltration, as suggested by 

Master-Bilt, Hill Phoenix, and NEEA. 

Likewise, reduction of door infiltration 

due to the location of the walk-in is not 

captured, as suggested by Bally. 

In response to NEEA’s comment 

recommending a prescriptive standard, 

DOE notes that EPCA has already 

established a prescriptive requirement 

for infiltration reduction devices, and 

there may be limited if any benefit to 

DOE adding additional prescriptive 

standards for infiltration reduction 

devices. (42 U.S.C. 6313(f)(1)(B)) 

Nevertheless, DOE will consider the 

need for these types of standards within 

the context of its ongoing energy 

standards rulemaking. 

5. Electrical Components 

In the January 2010 NOPR, DOE 

proposed to calculate the energy 

consumption of electrical devices using 

their nameplate rating and duty cycle 


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assumptions about their daily operation. 

In addition, the heat loads from 

electrical devices were factored into the 

envelope refrigeration load calculations. 

DOE proposed to incorporate 100 

percent of the electrical energy 

consumed to operate the devices that 

are internally located and to convert the 

electrical energy consumed to a thermal 

load. The associated thermal load was 

then used to calculate the additional 

refrigeration load using the nominal 

refrigeration EER values described in 

section III.B.3.c. DOE also proposed a 

variety of PTO values in the NOPR to 

account for reductions in energy use 

due to component control and hours of 

usage. 75 FR 186, 198 (Jan. 4, 2010). 

BASF supported including electricity 

consumption as part of the energy 

calculation, and concurred with the 

duty cycle assumptions. (BASF, No. 

0021.1 at p. 5) Master-Bilt and Nor-Lake 

also agreed with the electrical duty 

cycle equation proposed by DOE. 

(Master-Bilt, No. 0027.1 at p. 2; NorLake, No. 0023.1 at p. 4) ACEEE 

supported the methods and assumptions 

for PTO values and electrical loads and 

agreed with the use of nameplate power 

ratings because it encouraged load 

reduction. (ACEEE, No. 0052.1 at p. 3) 

ThermalRite noted that while it did not 

fully understand how the proposed PTO 

values listed in the January 2010 NOPR 

were developed, it believed that the 

proposed values represented a fair 

method of comparison among 

manufacturers because the same 

assumptions are made for all users. 

ThermalRite asked that DOE ensure that 

the values include all device types. 

(ThermalRite, No. 0049.1 at p. 2) ORNL 

requested that DOE include the ground 

heater below the floor insulation as part 

of the energy use calculation. (ORNL, 

No. 0028.1 at p. 2) Craig Industries 

requested that DOE accommodate highefficiency heater wires that apply heat 

on demand. (Craig Industries, Public 

Meeting Transcript, No. 0016 at p. 325 

and No. 0054.1 at p. 3) Finally, NorLake expressed the opinion that the 

proposed PTO values for lights are low 

because in most applications the lights 

would be shut off each night for 8 hours. 

(Nor-Lake, No. 0047.1 at p. 5) 

DOE notes support from BASF, 

Master-Bilt, Nor-Lake, ACEEE, and 

ThermalRite for its methodology and 

assumptions. DOE is also aware of the 

concerns presented by ORNL, Craig 

Industries, and Nor-Lake. However, 

since DOE will implement a 

component-based standard, electrical 

components not part of a door are not 

included in the component test or 

component metric. DOE notes that 

assemblers or manufacturers of 

complete walk-ins must still use 

lighting that complies with the efficacy 

standard prescribed in EPCA. (42 U.S.C. 

6313(f)(1)(G)) DOE will continue to use 

the method proposed in the January 

2010 NOPR to calculate the energy 

consumption of lights, sensors, and 

other miscellaneous electrical devices 

associated with walk-in doors. 

Regarding Craig Industries’ specific 

comment about door heater wire, DOE’s 

PTO assumptions take into account 

demand-based control of components, 

which includes the loads from door 

heater wires. PTO assumptions are 

given in sections 4.4.2 and 4.5.2 of 

Appendix A for display and non-display 

doors, respectively. See section III.B.3.b 

for further discussion of electrical 

components of doors. 

C. Test Procedures for Refrigeration 

Systems 

The refrigeration system is the 

equipment that performs the mechanical 

work necessary to cool the interior 

space of a walk-in cooler or freezer. As 

previously discussed, DOE considers 

the refrigeration system an individual 

component of the walk-in cooler or 

walk-in freezer. Therefore, in this test 

procedure, DOE establishes a test of the 

performance of a refrigeration system 

itself, assuming nominal envelope 

characteristics. In the concurrent 

standards rulemaking, DOE intends to 

establish energy conservation standards 

for the refrigeration system. See 

generally 75 FR 17080 (April 5, 2010). 

The following sections address issues 

raised by interested parties on the 

January 2010 NOPR and September 

2010 SNOPR. 

1. Definition of Refrigeration System 

In the January 2010 NOPR, DOE 

proposed a definition of refrigeration 

system that described three types of 

systems that would be covered: (1) 

Single-package systems containing the 

condensing and evaporator units; (2) 

split systems with the condensing unit 

and unit cooler physically separated 

and connected via refrigerant piping; or 

(3) unit coolers that receive refrigerant 

from a compressor rack system shared 

with other refrigeration equipment. 75 

FR at 200 (Jan. 4, 2010). In the 

September 2010 SNOPR, DOE proposed 

minor revisions to that definition to 

clarify some of these terms. That notice 

proposed the following definitions: 

Refrigeration system means the mechanism 

(including all controls and other components 

integral to the system’s operation) used to 

create the refrigerated environment in the 

interior of a walk-in cooler or freezer, 

consisting of (1) a packaged system where the 

unit cooler and condensing unit are 

integrated into a single piece of equipment, 

(2) a split system with separate unit cooler 

and condensing unit sections, or (3) a unit 

cooler that is connected to a multiplex 

condensing system. 

75 FR 55068, 55093 (Sept. 9, 2010). 

NRDC, Craig Industries, and MasterBilt agreed with the revisions proposed 

in the September 2010 SNOPR. (NRDC, 

No. 0064.1 at p. 7; Craig Industries, No. 

0068.1 at p. 5; Master-Bilt, No. 0069.1 at 

p. 3) Other interested parties did not 

agree with the classification contained 

in the definition or the types of systems 

covered. NEEA stated that the three 

refrigeration types do not accurately 

represent the market, and recommended 

that the equipment classification should 

instead match the classifications 

contained in DOE’s regulations for 

commercial refrigeration equipment. 

(NEEA, No. 0061.1 at pp. 2 and 4) The 

Joint Utilities also disagreed with the 

concept of defining systems as 

‘‘matched’’ (‘‘packaged’’ or ‘‘split’’ 

systems as termed in the proposed 

definition) or ‘‘remote’’ (a unit cooler 

connected to a multiplex condensing 

system as in the proposed definition). 

(Joint Utilities, No. 0059.1 at p. 2) Like 

NEEA, the Joint Utilities suggested that 

DOE change its proposed definition by 

adopting the approach taken with the 

commercial refrigeration equipment 

efficiency regulations: ‘‘packaged’’ 

systems should be termed ‘‘selfcontained condensing units’’ and all 

other condensing units should be 

considered ‘‘remote condensing units.’’ 

The Joint SNOPR comment also agreed 

with this approach, suggesting that DOE 

classify refrigeration systems as selfcontained (packaged systems) or unit 

coolers connected to remote condensing 

units (both dedicated and multiplex). It 

also suggested that for remote 

condensing systems, any applicable 

energy conservation standards should 

only apply to the unit cooler. (Joint 

SNOPR Comment, No. 0074.1 at p. 3) 

DOE believes the three types of 

refrigeration systems described in the 

definition accurately represent the range 

of refrigeration equipment that is used 

in walk-in coolers and freezers. 

Although the definition differs from the 

definition for commercial refrigeration 

equipment, there are key differences 

between commercial refrigeration 

equipment refrigeration systems and 

walk-in refrigeration systems that make 

a new definition necessary. NEEA and 

the Joint Utilities refer to two common 

types of commercial refrigeration 

equipment refrigeration units. Some are 

‘‘self-contained’’ (meaning the entire 

refrigeration system is built into the 

case). Others are ‘‘remote condensing’’ 

(meaning the unit cooler is built into the 


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case, but the whole case is connected to 

a central system of compressors and 

condensers (called a ‘‘rack’’ or 

‘‘multiplex condensing system’’) that is 

connected to most or all of the 

refrigeration units in a building). The 

latter configuration is common in 

supermarkets. For all remote 

condensing systems, the commercial 

refrigeration equipment test procedure 

rulemaking assumed a certain efficiency 

of the multiplex condensing system and 

the standards rulemaking did not 

regulate this part of the equipment. 71 

FR 71340 and 74 FR 1092. 

However, ‘‘remote condensing’’ can 

also refer to a configuration in which 

the unit cooler is connected to a 

dedicated (that is, only serving that one 

unit) compressor and condenser that are 

located somewhere away from the walkin. This configuration is very rare for 

commercial refrigeration equipment but 

comprises a large proportion of walk-in 

refrigeration system applications. For 

this reason, DOE does not agree with the 

suggestion of NEEA and the Joint 

Utilities that this configuration should 

be classified as ‘‘remote condensing’’ 

and does not agree that the compressor 

and condenser parts should not be 

covered under the walk-in coolers and 

freezers rulemaking. Rather, DOE 

believes that a dedicated condensing 

unit should be included in the rule, 

even if it is remotely located, because it 

could be viewed as part of the walk-in 

cooler as long as it is connected only to 

that cooler and not to other refrigeration 

equipment. For systems where the walkin is connected to a multiplex 

condensing system that runs multiple 

pieces of equipment, the compressor 

and condenser would not be covered 

because they are not exclusively part of 

the walk-in. 

In consideration of the above, DOE 

believes the commercial refrigeration 

equipment definition cannot be applied 

to walk-ins, because there is a certain 

type of walk-in refrigeration—namely, a 

split system with a dedicated but 

remotely located condensing unit—that 

is highly represented in walk-ins but 

rarely, if ever, represented in 

commercial refrigeration equipment. 

Thus, while the Joint Comment 

compares walk-in refrigeration systems 

to commercial refrigeration equipment, 

DOE believes this is not a relevant 

comparison. A closer comparison would 

be to residential central air 

conditioners—an example of equipment 

that almost always has a dedicated, but 

remotely located, condensing unit. In 

that instance, DOE’s definition covers 

this type of remote condensing unit. 

Furthermore, DOE notes that 

manufacturers can optimize the 

dedicated, remote condensing unit with 

the unit cooler to take advantage of 

certain conditions such as low ambient 

outdoor temperatures. Therefore, DOE 

has retained the proposed definition’s 

coverage of dedicated remote 

condensing systems. To further clarify 

this coverage, DOE has added the term 

‘‘dedicated’’ to describe packaged 

systems and split systems in the 

definition it is adopting today. 

2. Refrigeration Test Procedure: AHRI 

1250 (I–P)–2009 

DOE proposed to incorporate the 

industry standard AHRI 1250–2009, 

‘‘2009 Standard for Performance Rating 

of Walk-In Coolers and Freezers,’’ into 

the test procedure. (The January 2010 

NOPR referred to the preliminary 

version of this standard, AHRI 1250P– 

2009. The SNOPR updated this 

reference to the final version.) 75 FR 

186, 200–201 (Jan. 4, 2010) and 75 FR 

55068, 55086 (Sept. 9, 2010). DOE 

proposed that manufacturers use this 

standard to rate the refrigeration 

systems of walk-in coolers and freezers. 

AHRI 1250–2009 covers the testing of 

refrigeration systems for walk-in coolers 

and freezers, which includes unit 

coolers and condensing units that are 

sold together as a matched system, unit 

coolers and condensing units that are 

sold separately, and unit coolers 

connected to compressor racks. The 

procedure describes the method for 

measuring the refrigeration capacity and 

the electrical energy consumption for 

the condensing unit and the unit cooler, 

as well as the off-cycle fan energy and 

the defrost subsystem under specified 

test conditions. The standard test 

conditions specify the dry-bulb and wetbulb temperatures of the air surrounding 

the unit cooler and the condensing unit. 

The standard test conditions are 

different for indoor and outdoor 

locations for the condensing unit and 

for coolers and freezers. 

The AHRI procedure also specifies the 

calculations used to ascertain the 

nominal box loads under typical lowload and high-load conditions, 

expressed as a function of the ambient 

air temperature. (The ‘‘nominal box 

load’’ refers to the refrigeration load 

imposed on the system by the walk-in 

envelope.) During the test, the system 

must operate under steady-state 

conditions. For systems in which the 

condensing unit is located outdoors, the 

test procedure uses bin temperature data 

and bin hour data to represent the 

impact of the seasonal variation in 

outside ambient air temperature on 

energy use. The test procedure provides 

a calculation methodology to compute 

an annual walk-in efficiency factor 

(AWEF) for the refrigeration system 

under a specified load profile. For unit 

coolers and condensing units sold 

separately, the test procedure allows for 

testing the components individually and 

then calculating the system AWEF from 

the component test results. 

Several interested parties agreed with 

DOE’s proposed methodology. AHRI 

urged DOE to allow a rating of walk-in 

refrigeration systems using the 

calculation methodologies in the 

proposed protocols contained in AHRI 

1250. (AHRI, No. 0070.1 at p. 2) 

American Panel, Thermo-Kool, Bally, 

and NRDC also supported DOE’s 

proposal to allow the evaporator and 

condensing unit to be tested separately 

according to the proposed methodology. 

(American Panel, No. 0057.1 at p. 1; 

Thermo-Kool, No. 0072.1 at p. 1; Bally, 

No. 0078.1 at p. 3; NRDC, No. 0064.1 at 

p. 3) Craig Industries supported a 

formula that would allow the efficiency 

of the refrigeration system to be 

calculated from testing data provided by 

each component supplier. (Craig, No. 

0068.1 at p. 3) Heatcraft advised that the 

refrigeration system procedure should 

allow for testing new components. 

(Heatcraft, No. 0065.1 at p. 1) However, 

the Joint Utilities disagreed with the 

assumption in AHRI 1250–2009 that 

unit coolers and remote condensing 

units that are sold separately will be 

matched and installed together, and 

stated that AHRI 1250–2009 does not 

allow unit coolers to be compared with 

each other unless they have been tested 

on the same condensing unit. (Joint 

Utilities, No. 0059.1 at p. 2) No parties 

opposed DOE’s proposal to allow 

evaporator and condensing unit to be 

tested separately. 

DOE notes the support of AHRI, 

American Panel, and NRDC for the 

proposed method and incorporates it 

into this final rule. In response to 

Heatcraft’s suggestion that the 

procedure should allow for testing new 

components, DOE anticipates that the 

method will lead to manufacturers 

testing unit coolers and condensing 

units when they are manufactured 

separately, so that they can be used in 

new systems. Regarding the issues 

raised by Craig Industries and the Joint 

Utilities, DOE emphasizes that the 

proposed procedure contains a 

calculation method by which the overall 

refrigeration performance can be 

calculated using testing data from a 

condensing unit and unit cooler, even if 

the two components are provided by 

different suppliers. The test results for 

a unit cooler or condensing unit are 

independent from whichever 

condensing unit or unit cooler is 

matched with the tested component. In 


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contrast, the test results for each 

component are in the form of a 

performance curve to facilitate 

calculation of matched performance, 

which, as suggested by the Joint 

Utilities, does not lend itself to 

meaningful comparisons between unit 

coolers without matching the particular 

unit coolers with the same condensing 

unit. DOE acknowledges this limitation 

but believes it is important to maintain 

the results in terms of the performance 

curve to facilitate calculation of the 

performance of the system as a whole, 

because the entire refrigeration system 

is treated as a component under the 

approach adopted in today’s final rule. 

Given that the refrigeration system is 

treated as a single component under the 

procedure, the procedure offers a simple 

method for determining the energy 

efficiency profile of the walk-in 

refrigeration system because it allows 

the unit cooler and condensing unit to 

be tested separately. 

Additionally, DOE notes that if unit 

coolers are tested and rated as if they 

were to be combined with a multiplex 

condensing system, they could be 

compared against each other. The test 

data for unit coolers in a mix-match 

system include the data necessary for 

calculating the unit cooler’s 

performance when paired with a 

multiplex condensing system. Thus, it 

would be relatively simple for 

manufacturers of unit coolers to provide 

both the performance data for matching 

purposes and the performance as 

connected to a multiplex condensing 

system. DOE may consider requiring 

this information as part of any related 

labeling requirements for WICF 

equipment. 

While interested parties generally 

agreed with the adoption of AHRI 1250– 

2009, others disagreed with how that 

method would be applied to different 

system configurations. The Joint 

Utilities and NEEA both recommended 

that all remote condensing systems be 

tested using the ‘‘walk-in unit cooler 

match to parallel rack system’’ test 

method and noted that the matched 

system approach only be used for selfcontained condensing units. (Joint 

Utilities, No. 0059.1 at p. 3; NEEA, No. 

0061.1 at p. 4) The Joint Utilities further 

stated that the proposed AHRI 1250– 

2009 test method for rating dedicated 

remote condensing systems would 

create confusion and additional testing 

burden because there are many different 

test methods and categories for different 

locations and types of condensing units. 

(Joint Utilities, No. 0059.1 at pp. 2 and 

5) Other interested parties questioned 

the methodology for rating unit coolers 

connected to multiplex condensing 

systems. American Panel stated that the 

exemption of multiplex equipment 

would give that equipment an unfair 

advantage over single piece equipment. 

(American Panel, No. 0057.1 at p. 3) 

Master-Bilt stated that the multiplex 

exemption seemed to suggest that any 

condensing unit connected to more than 

one unit cooler would not be covered. 

(Master-Bilt, No. 0069.1 at p. 3) NRDC 

stated that the proposed equations for 

evaluating the energy use of units with 

indoor condensing units and those 

connected to multiplex condensing 

systems should account for differences 

in the systems’ ability to reject heat. 

(NRDC, No. 0064.1 at p. 7) 

Addressing the comments from the 

Joint Utilities and NEEA, as discussed 

in section III.C.1, DOE considers 

dedicated remote condensing units as 

distinct from multiplex condensing 

systems in that dedicated remote 

condensers are part of only one walk-in, 

while multiplex condensing systems are 

connected to more than one walk-in or 

other unit of refrigeration equipment. 

DOE believes that dedicated remote 

condensing units represent a substantial 

opportunity for energy savings in a 

regulation for walk-in components 

because the configuration of a dedicated 

remote condensing unit is widespread 

in several market segments such as 

restaurants. Manufacturers can optimize 

the dedicated remote condensing unit 

with the unit cooler to take advantage of 

certain conditions such as low ambient 

outdoor temperatures. The approach 

suggested by the Joint Utilities and 

NEEA would exclude dedicated remote 

condensing units from this regulation, 

but DOE views these units as part of the 

walk-in cooler or freezer if the unit is 

connected only to the walk-in and not 

to any other refrigeration equipment. 

Therefore, the test procedure for walkin refrigeration equipment accounts for 

these units. 

To address Master-Bilt’s request for 

clarification, for systems where the 

walk-in is connected to a central 

multiplex condensing system that runs 

multiple pieces of equipment, the 

compressor and condenser would not be 

covered because they are not 

exclusively part of the walk-in. DOE 

realizes there are certain condensing 

units that are connected to more than 

one unit cooler inside a single walk-in. 

These systems would not be considered 

‘‘multiplex condensing systems’’ because 

they are connected to a single walk-in. 

However, if the condensing unit were 

connected to more than one unit cooler 

inside more than one walk-in or other 

piece of equipment, DOE would 

consider that a multiplex condensing 

system because the system’s 

performance could not be attributed to 

one walk-in alone. While DOE 

understands American Panel’s concern 

that multiplex condensing systems 

could have an advantage because those 

condensing units would not need to be 

tested, the condensing unit and 

compressor part of a multiplex 

condensing system is not exclusively 

part of a walk-in unit. Therefore, DOE 

is not covering them in this test 

procedure. DOE notes that unit coolers 

connected to the multiplex condensing 

systems would still be considered part 

of the walk-in and would need to be 

tested. The procedure considers the 

different performance of multiplex 

condensing systems and indoor 

condensing systems as recommended by 

NRDC. For multiplex condensing 

systems, the calculation of energy use 

includes a nominal efficiency that 

accounts for that type of system’s ability 

to reject heat. The rating conditions for 

indoor condensing units provide an 

opportunity for crediting energy savings 

that result from an increased ability to 

reject heat. 

Finally, one interested party proposed 

to expand the test procedure to provide 

more information than DOE previously 

proposed. NRDC suggested that testing 

data should be input into standardized 

calculations that would determine the 

overall system performance for each 

application and recommended that 

performance data should be able to be 

interpolated or extrapolated for hot 

climates. (NRDC, No. 0064.1 at p. 3) 

DOE notes that standardized rating 

conditions are not typically applicationspecific and may not be useful for 

determining the performance of the 

system in conditions outside the rating 

conditions. To provide this flexibility, 

as suggested by NRDC, the AHRI 1250 

test procedure contains provisions for 

conducting testing with application 

ratings to obtain the performance for a 

particular application. However, DOE 

emphasizes that the standardized rating 

conditions are useful for comparing 

systems with each other and must be 

used for evaluating a product’s 

compliance with a particular standard. 

3. Alternative Efficiency Determination 

Method 

For some covered equipment, DOE 

has allowed manufacturers to use their 

own methods, whether a calculation or 

computer simulation, to rate their 

equipment after they substantiate those 

calculation or simulation methods with 

test data. The purpose of this provision 

is to reduce the burden of testing 

customized, low-volume equipment. 

DOE has allowed rating methods in the 

form of alternate rating methods (ARMs) 


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or alternative efficiency determination 

methods (AEDMs). An ARM, which is 

allowed for rating residential central air 

conditioners and heat pumps, must be 

a representation of the test data and 

calculations of a mechanical vaporcompression refrigeration cycle. 

Manufacturers may use an ARM after 

submitting documentation to DOE and 

receiving specific approval from DOE to 

use that ARM to rate their equipment. 

(10 CFR 430.24(m)(4)-(6)) An AEDM, 

which is allowed for certain products 

and commercial equipment—including 

electric motors, distribution 

transformers, and commercial heating, 

ventilating, air-conditioning, and water 

heating (HVAC and WH) equipment—is 

a rating method derived from a 

mathematical model that represents the 

mechanical and electrical characteristics 

of the equipment and is based on 

engineering or statistical analysis, 

computer simulation or modeling, or 

other analytical evaluations of 

performance data. An AEDM must be 

substantiated by test data before it can 

be used to rate equipment. (10 CFR 

431.17(a)(2)–(3); 10 CFR 431.197(a)(2); 

and 10 CFR 431.197(a)(2)–(3)) 

For the walk-in coolers and freezers 

rulemaking, DOE introduced the 

concept of an AEDM at the Framework 

public meeting (February 4, 2009) and 

requested comment on whether it could 

be applied to walk-ins. At the 

Framework public meeting, DOE asked 

how an AEDM could be implemented 

for walk-ins, what a sufficient test 

sample size for validating an AEDM 

would be, and how accurate (to what 

percentage) an AEDM should be. DOE 

did not receive any feedback regarding 

these questions. Several interested 

parties did, however, raise concerns in 

written comments on the Framework 

and during the Framework public 

meeting about the potential for 

inconsistency among manufacturers’ 

rating methods. For example, Owens 

Corning stated that a single AEDM 

should be accepted to keep comparisons 

consistent (instead of different AEDMs 

from different manufacturers), and Craig 

said that requiring manufacturers to 

follow the same model (that is, not 

allowing manufacturers to use their own 

AEDMs) would provide consistent 

information to end users. (Owens 

Corning, No. EERE–2008–BT–STD– 

0015–0034.1 at p. 2; Craig, No. EERE– 

2008–BT–STD–0015–0025.1 at p. 5) 

DOE summarized and addressed these 

comments in the January NOPR. 75 FR 

186, 190 (Jan. 4, 2010).As a result, DOE 

did not propose any specific provisions 

regarding AEDMs or any other 

provisions that would allow 

manufacturers to develop their own 

rating methods for walk-ins. Instead, 

DOE proposed its own calculation 

methodology for manufacturers to use in 

rating similar units of walk-in 

equipment. 75 FR 186, 191 (Jan. 4, 

2010). 

While the procedure divides the 

envelope into its major components, the 

refrigeration system is considered as a 

single component. Consistent with this 

approach, DOE is incorporating a single 

metric to cover the performance of the 

refrigeration system. DOE noted in the 

September 2010 SNOPR that the 

proposed refrigeration test procedure, 

AHRI 1250 (I–P)-2009, ‘‘2009 Standard 

for Performance Rating of Walk-In 

Coolers and Freezers,’’ allows 

manufacturers to test condensing units 

and unit coolers separately in certain 

situations, and to calculate the 

performance of the combined system. 

DOE anticipated that this approach 

would reduce the overall testing burden 

by eliminating the need to test the many 

possible unit cooler and condensing 

unit combinations that could comprise 

a complete refrigeration system. 75 FR 

55073 (Sept. 9, 2010). In proposing this 

approach, DOE also recognized that 

there could still be some burdens due to 

system variations. To mitigate these 

burdens, DOE noted that it might 

consider allowing manufacturers of 

refrigeration to use AEDMs to rate their 

equipment. 75 FR 55089 (Sept. 9, 2010). 

In comments on the September 2010 

SNOPR, interested parties commented 

on the burden of testing refrigeration 

systems because a manufacturer’s 

product line may have many different 

condensing units and unit coolers, 

which may be similar, but not identical, 

and need to be tested individually. Craig 

Industries stated that even if unit 

coolers and condensing units could be 

tested separately, testing each 

component with all the options 

available would substantially increase 

the need for testing and would 

discourage manufacturers from 

improving their equipment. (Craig 

Industries, No. 0068.1 at p. 3) AHRI 

requested that DOE allow manufacturers 

to rate their equipment and demonstrate 

compliance with the Federal standard 

through the use of an AEDM to 

minimize testing burden. (AHRI, No. 

0070.1 at p. 3) Manufacturers were also 

concerned about how they would rate 

custom units. Heatcraft stated that 

refrigeration system manufacturers 

would face an undue testing burden and 

asserted that manufacturers would not 

be able to sell a particular piece of 

equipment if it had been tested. 

(Heatcraft, No. 0065.1 at p. 2) DOE 

acknowledges that when a refrigeration 

system is tested, it undergoes some 

modifications in order to accommodate 

the apparatus for taking test 

measurements. As a result, these units 

can no longer be sold as new equipment 

after testing and are typically destroyed. 

This situation, in Heatcraft’s view, 

would prevent them from selling 

custom equipment if the inclusion of a 

custom piece requires a separate test of 

the refrigeration system. 

DOE recognizes the potential for 

variability with respect to walk-in 

components, in terms of their physical 

characteristics and, consequently, their 

energy performance or efficiency. To 

address Craig’s concern that testing all 

equipment variations would be 

burdensome, and AHRI’s request that 

DOE allow manufacturers to use 

AEDMs, DOE will continue to consider 

the application of AEDMs or ARMs. 

DOE recognizes the value of permitting 

the use of AEDMs and ARMs in limited 

instances and may consider the 

adoption of such methods for walk-in 

equipment, including the statistical 

basis and the sample size required to 

validate them, in a future rulemaking. 

D. Other Issues—Definition of Walk-In 

Cooler or Freezer 

EPCA defines walk-in equipment at 

42 U.S.C. 6311(20), codified at 10 CFR 

431.302. 

During the public meeting for the 

January 2010 NOPR, Hired Hand and 

several interested parties stated that 

DOE should clarify the definition of 

walk-in coolers and walk-in freezers 

with respect to temperature limits. 

Multiple interested parties commented 

that DOE should set an upper 

temperature limit for walk-ins. After 

reviewing the comments from interested 

parties, DOE proposed in the September 

2010 SNOPR to modify the definition of 

‘‘refrigerated’’ within the definition of 

walk-in cooler or freezer to mean at or 

below 55 °F. 75 FR 55068, 55069 (Sept. 

9, 2010). 

The Joint Utilities, AHRI, American 

Panel, the Joint Manufacturers, NEEA, 

Craig Industries, Thermo-Kool, MasterBilt, and Bally agreed to the proposed 

upper temperature limit of 55 °F for 

walk-ins. (Joint Utilities, No. 0059.1 at 

p. 6; AHRI, No. 0070.1 at p. 1; American 

Panel, No. 0057.1 at p. 1; Joint 

Manufacturers, No. 0062.1 at p. 1, 

NEEA, No. 0061.1 at p. 2; Craig 

Industries, No. 0068.1 at p. 1; ThermoKool, No. 0072.1 at p. 1; Master-Bilt, No. 

0069.1 at p. 1; Bally, No. 0078.1 at p. 1) 

The Joint Utilities also recommended 

that DOE develop definitions for walkin coolers and freezers that are similar 

to California Title 24, Buildings 

Efficiency Standards, which contain a 


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21600 Federal Register / Vol. 76, No. 73 / Friday, April 15, 2011 / Rules and Regulations 

definition for ‘‘refrigerated warehouse’’ 

that clarifies a temperature of 55 degrees 

or less. (Joint Utilities, No. 0059.1 at p. 

6) NEEA suggested that walk-in coolers 

and freezers are essentially buildings 

and should be modeled as such. (NEEA, 

No. 0061.1 at p. 5) 

DOE notes that any regulation it 

develops must be consistent with, and 

fall within the parameters of, the 

statutory provisions set by Congress. 

Working within the confines of the 

statutorily-prescribed definition of the 

walk-in definition, DOE is clarifying 

what the term ‘‘refrigerated’’ means in 

the context of the walk-in definition to 

help address the concerns raised by 

commenters. In particular, DOE is 

defining ‘‘refrigerated’’ for purposes of 

walk-ins to mean ‘‘held at a temperature 

at or below 55 degrees Fahrenheit using 

a refrigeration system’’ as suggested by 

commenters. Adopting this approach 

should enable DOE to sufficiently 

account for the range of walk-in 

equipment that exist. 

In comments on the January 2010 

NOPR, interested parties expressed 

concern about the potential for abuse in 

light of the breadth of the exclusion in 

the statute and requested that DOE 

clarify the scope of this clause. At the 

public meeting for the January 2010 

NOPR, Craig Industries stated that the 

definition of ‘‘medical, scientific, and 

research walk-ins’’ should be better 

defined, and Hired Hand agreed that the 

definition is unclear. (Craig Industries, 

Public Meeting Transcript, No. 0016 at 

p. 19; Hired Hand, Public Meeting 

Transcript, No. 0016 at p. 26) These 

commenters were concerned because 

the current statutory language does not 

account for the fact that, in practice, 

walk-ins may be used interchangeably 

for either food storage or medical, 

scientific, or research usage. Because a 

given walk-in sold by a company could 

be used in any of these types of 

applications, Craig Industries and Hired 

Hand were both concerned that a 

company could market its walk-in as 

medical equipment and avoid having to 

meet any energy efficiency standards. 

Craig Industries and Hired Hand 

requested that DOE work to improve the 

definition of exempted uses for walk-ins 

because the definition could create 

ambiguity and loopholes. (Craig 

Industries, Public Meeting Transcript, 

No. 0016 at p. 4; Hired Hand, No. 0051.1 

at p. 2) 

DOE is sensitive to the potential for 

abuse regarding walk-ins. To ensure that 

such abuse does not occur and to help 

clarify the scope of the exclusion 

created by Congress, DOE notes that for 

any walk-in—including those 

components that are covered by today’s 

test procedure and any applicable 

standards that DOE may promulgate—a 

manufacturer seeking to avail itself of 

the statutory exclusion would, 

consistent with the statute, need to 

affirmatively demonstrate to DOE that 

its equipment is ‘‘designed and 

marketed exclusively for medical, 

scientific, or research purposes.’’ 42 

U.S.C. 6311(20)(B). Further, while DOE 

is currently unaware of any instances 

where this exclusion is being abused, 

DOE will monitor the situation and take 

steps to prevent these types of activities 

from occurring when it receives 

sufficient information substantiating the 

existence of such activities. In 

examining whether a given walk-in 

satisfies the statutory exclusion, DOE 

may consider a number of factors, 

including, but not limited to, how a 

particular walk-in has been designed, 

how it has been marketed, to whom the 

equipment has been distributed, and 

steps taken by manufacturers. 

Accordingly, while DOE appreciates the 

concerns raised by Craig Industries and 

Hired Hand, DOE has decided that, at 

this time, the exclusion set by Congress 

is sufficiently clear. DOE may revisit 

this issue in the future if necessary. 

One commenter requested 

clarification of the 3,000 square foot 

provision. Bally suggested that DOE add 

a corroborating cubic foot threshold, 

and stated that the large variability in 

panel heights could impact the energy 

conservation standards. (Bally, No. 

0078.1 at p. 1) Under the componentlevel test procedures established today, 

a cubic foot threshold for a walk-in is 

not necessary. Rather, a panel is 

considered as an individual component 

and its dimensions, including its height, 

are accounted for in the calculation 

methodology that DOE developed. 

IV. Procedural Issues and Regulatory 

Review 

A. Review Under Executive Order 12866 

The Office of Management and Budget 

has determined that test procedure 

rulemakings do not constitute 

‘‘significant regulatory actions’’ under 

section 3(f) of Executive Order 12866, 

Regulatory Planning and Review, 58 FR 

51735 (Oct. 4, 1993). Accordingly, this 

action was not subject to review under 

the Executive Order by the Office of 

Information and Regulatory Affairs 

(OIRA) in the Office of Management and 

Budget (OMB). 

B. Review Under the Regulatory 

Flexibility Act 

The Regulatory Flexibility Act (5 

U.S.C. 601 et seq.) requires preparation 

of an initial regulatory flexibility 

analysis (IFRA) for any rule that by law 

must be proposed for public comment, 

unless the agency certifies that the rule, 

if promulgated, will not have a 

significant economic impact on a 

substantial number of small entities. As 

required by Executive Order 13272, 

‘‘Proper Consideration of Small Entities 

in Agency Rulemaking,’’ 67 FR 53461 

(August 16, 2002), DOE published 

procedures and policies on February 19, 

2003, to ensure that the potential 

impacts of its rules on small entities are 

properly considered during the DOE 

rulemaking process. 68 FR 7990. DOE 

has made its procedures and policies 

available on the Office of the General 

Counsel’s Web site: http:// 

www.gc.doe.gov. 

DOE reviewed the test procedures 

considered in today’s final rule under 

the provisions of the Regulatory 

Flexibility Act and the procedures and 

policies published on February 19, 

2003. 

As discussed in detail below, DOE 

found that because these test procedures 

have not previously been required of 

manufacturers, all manufacturers, 

including small manufacturers, could 

experience a financial burden associated 

with new testing requirements. While 

examining this issue, DOE determined 

that it could not certify that this rule 

would not have a significant effect on a 

substantial number of small entities. 

Therefore, DOE prepared an Initial 

Regulatory Flexibility Analysis (IRFA) 

for this rulemaking. 75 FR 55068, 55087. 

The Final Regulatory Flexibility 

Analysis (FRFA) set forth below, which 

describes potential impacts on small 

businesses associated with walk-in 

cooler and freezer testing requirements, 

incorporates the IRFA and changes 

made to the IRFA in response to the 

comments from interested parties, 

including the Small Business 

Administration (SBA), on the September 

2010 SNOPR. 

1. Statement of the Need for, and 

Objectives of, the Rule 

A statement of the need for, and 

objectives of, the rule is stated 

elsewhere in the preamble and not 

repeated here. 

2. Summary of the Significant Issues 

Raised by the Public Comments, DOE’s 

Response to These Issues, and Any 

Changes Made in the Proposed Rule as 

a Result of Such Comments 

The comments received on the IRFA 

and the economic impacts of the rule 

and responses thereto are provided in 

the analysis below. 


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3. Description and Estimated Number of 

Small Entities Regulated 

DOE uses the SBA small business size 

standards published on January 31, 

1996, as amended, to determine whether 

any small entities would be required to 

comply with the rule. 61 FR 3286; see 

also 65 FR 30836, 30850 (May 15, 2000), 

as amended. 65 FR 53533, 53545 

(September 5, 2000). The size standards 

are codified at 13 CFR Part 121. The 

standards are listed by North American 

Industry Classification System (NAICS) 

code and industry description and are 

available at http://www.sba.gov/idc/ 

groups/public/documents/ 

sba_homepage/serv_sstd_tablepdf.pdf. 

In the January 2010 NOPR and 

September 2010 SNOPR, DOE classified 

walk-in cooler and freezer equipment 

manufacturing under NAICS 333415, 

‘‘Air-Conditioning and Warm Air 

Heating Equipment and Commercial 

and Industrial Refrigeration Equipment 

Manufacturing,’’ which has a size 

standard of 750 employees. 75 FR 186, 

204 (Jan. 4, 2010) and 75 FR 55068, 

55087 (Sept. 9, 2010). After reviewing 

industry sources and publicly available 

data, DOE identified at least 37 small 

manufacturers of walk-in cooler and 

freezer envelopes and at least 5 small 

manufacturers of walk-in cooler and 

freezer refrigeration systems that met 

this criterion. DOE also noted that the 

walk-in industry can be characterized 

by a few manufacturers that are 

subsidiaries of much larger companies 

(that would not be considered small 

businesses) and a large number of small 

companies as categorized by NAICS 

code 333415. Furthermore, more than 

half of small walk-in manufacturers 

have 100 or fewer employees. 75 FR at 

55088 (Sept. 9, 2010). 

Interested parties commented on the 

market characterization DOE presented 

in the September 2010 SNOPR. SBA 

agreed with DOE’s characterization of 

the walk-in manufacturing industry. 

(SBA, No. 0066.1 at p. 2) American 

Panel stated that most walk-in 

companies are small businesses and 

would be at a disadvantage compared to 

the large conglomerates. American 

Panel characterized the majority of 

small walk-in manufacturers as making 

between $10 and $25 million in sales 

while large manufacturers represent $75 

million in walk-in sales and $250 

million in overall sales. (American 

Panel, No. 0057.1 at p. 3) American 

Panel stated that the cost of testing 

would be passed down to the product 

selling price, which would trickle down 

and seriously impact small business 

restaurant owners. (American Panel, No. 

0057.1 at p. 4) Zero Zone agreed that 

small manufacturers would be impacted 

by the regulations and stated that many 

will not be able to stay in business once 

they are burdened with the costs of 

certification. (Zero Zone, No. 0077.1 at 

p. 2) 

In response to comments on the 

January 2010 NOPR and September 

2010 SNOPR regarding DOE’s proposed 

standards for WICF, DOE is taking a 

component-level approach in the WICF 

test procedure rulemaking. Specifically, 

DOE is establishing test procedures for 

individual components of a walk-in: 

Panels, doors, and refrigeration systems. 

Manufacturers of these components will 

be required to test the components they 

manufacture for walk-ins and certify 

that they meet any applicable 

component performance standard. This 

approach will mitigate the overall 

burdens posed by this regulation and 

ensure that those burdens are borne on 

those manufacturers who are best suited 

and positioned to conduct these types of 

tests. See section III.A for further details 

on this approach. 

As a result of this approach, DOE reevaluated the number of small 

manufacturers it identified in the 

September 2010 SNOPR for this final 

rule. Because DOE is considering 

refrigeration systems as a single 

component under the proposed 

approach, DOE estimates that there are 

4 small manufacturers of refrigeration 

systems. Furthermore, DOE notes that 

entities it previously considered walk-in 

envelope manufacturers also 

manufacture the panels. As a result, 

DOE estimates that there are 37 small 

manufacturers of panels. For doors, DOE 

notes that some of the panel 

manufacturers make doors and others 

buy doors from suppliers. DOE 

researched manufacturers who solely 

manufacture the doors of WICF, and 

estimates that there are four small 

manufacturers of walk-in doors who do 

not also manufacture panels. DOE notes 

SBA’s and American Panel’s 

characterization of the walk-in industry 

as being composed mainly of small 

manufacturers. DOE believes the new 

approach of regulating WICFs at the 

component level will reduce burden on 

small manufacturers because the testing 

and compliance burden will be reduced 

due to an enhanced ability to apply the 

basic model concept. See section 

III.A.3.a for details. In response to 

American Panel’s comment that the cost 

of testing would affect small restaurant 

owners, DOE notes that this analysis 

considers entities who are directly 

regulated by this test procedure 

rulemaking (i.e., manufacturers). The 

concurrent energy conservation 

standards rulemaking will address 

effects on walk-in manufacturers’ 

customers. 

4. Description and Estimate of 

Compliance Requirements and 

Description of Steps To Minimize the 

Economic Impact on Small Entities 

DOE recognizes the particular burden 

of the test procedures on small 

manufacturers. DOE does not expect 

that small manufacturers would have 

fewer basic models or component types 

than large manufacturers. Therefore, a 

small manufacturer could have the same 

total cost of testing as a large 

manufacturer, but this cost would be a 

higher percentage of a small 

manufacturer’s annual revenues. Thus, 

the differential impact associated with 

walk-in cooler and walk-in freezer test 

procedures on small businesses may be 

significant even if the overall testing 

burden is reduced as described 

elsewhere in the preamble. 

Due to the nature of walk-in coolers 

and freezers within the appliance 

standards program, DOE is considering 

use of a component-based approach to 

walk-in standards, setting individual 

performance standards for each 

component. This approach would 

require the component manufacturers to 

test the components they manufacture 

for walk-in applications, comply with 

the applicable performance standard for 

those components, and certify to DOE 

that those components meet the 

standard. See section III.A for details on 

this approach. At this time there are no 

performance standards in place for 

walk-in equipment, as those standards 

are being developed in a concurrent 

rulemaking. Details on the performance 

standards rulemaking can be found on 

the DOE Web site at http:// 

www1.eere.energy.gov/buildings/ 

appliance_standards/commercial/ 

wicf.html. However, manufacturers will 

be required to use these test procedures 

to certify performance once any final 

standards are issued and must use the 

test procedures outlined in this final 

rule if they make representations as to 

the performance of their components. 

To further address concerns about 

costs, DOE is anticipating developing a 

sampling plan in a future rulemaking to 

determine how many units of each 

walk-in component must be tested. In 

such a rulemaking, DOE will consider 

the impacts to small businesses. 

a. Panel and Door Manufacturer Testing 

Impacts 

In the September 2010 SNOPR, DOE 

proposed to require envelope 

manufacturers to test their equipment in 

accordance with several industry test 

standards: ASTM C1363–05, ‘‘Standard 


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Test Method for Thermal Performance 

of Building Materials and Envelope 

Assemblies by Means of a Hot Box 

Apparatus;’’ DIN EN 13164:2009–02, 

‘‘Thermal insulation products for 

buildings—Factory made products of 

extruded polystyrene foam (XPS)— 

Specification;’’ DIN EN 13165:2009–02, 

‘‘Thermal insulation products for 

buildings—Factory made rigid 

polyurethane foam (PUR) products— 

Specification;’’ and NFRC 100– 

2010[E0A1], ‘‘Procedure for Determining 

Fenestration Product U-factors.’’ 

DOE spoke with industry experts to 

determine the approximate cost of each 

test. Under the new component level 

approach to testing, entire walk-ins are 

not required to be tested or certified. 

Rather, component manufacturers are 

required to test and certify their own 

components. Therefore, DOE evaluated 

the cost of each test to the component 

manufacturer. For foam used in panels, 

a test using DIN EN 13164:2009–02 or 

DIN EN 13165:2009–02 costs 

approximately $5,000 for each type of 

foam, though DOE has found that most 

manufacturers use only one type. The 

test result would be used to calculate 

the LTTR for all the manufacturer’s 

panels that use that type of foam. For 

the panels themselves, a test using 

ASTM C1363–05 costs approximately 

$5,000. Manufacturers would need to 

test the core and edge U-factor of a pair 

of 4 ft. by 8 ft. panels, for each foam 

type, frame type, and panel thickness 

they manufacture. DOE estimated that 

manufacturers use either one or two 

types of foam and may have up to nine 

different combinations of frame type 

and panel thickness. Using this 

estimate, the total cost of testing 

compliance with a panel standard could 

be up to an average of $5,000–$10,000 

for the foam panels and $45,000 to test 

the U-factors of the different panel 

configurations. However, for 

manufacturers who have fewer unique 

combinations of frame type and panel 

thickness, the testing cost would be 

substantially less. DOE has incorporated 

other burden reducing measures to 

reduce cost. Specifically, it incorporated 

a method that allows manufacturers to 

test a reference panel that is 4 ft. by 8 

ft. and then calculate the U-factor of 

other panels of different dimensions 

from those test results as long as certain 

aspects of the panels are the same. See 

section III.B.2 for details. 

For doors, a test of door U-factor using 

NFRC 100 costs approximately $5,000. 

DOE estimates that a typical door 

manufacturer would have to certify up 

to 20 to 40 basic models of doors, which 

would cost $100,000 to $200,000 if each 

door were to be physically tested. 

However, NFRC 100 also permits 

computer modeling of a door’s U-factor, 

which could further reduce the testing 

cost. See section III.B.3 for discussion of 

the NFRC testing requirements for 

doors. 

The estimated costs only include the 

cost of one test on each basic model, 

and do not include additional testing on 

the same basic model that may be 

required as part of a sampling plan. As 

mentioned above, DOE anticipates 

developing sampling plans in a future 

rulemaking to determine how many 

tests need to be performed on the same 

type of envelope component, to ensure 

the test results are repeatable and 

statistically valid. 

b. Refrigeration System Manufacturer 

Testing Impacts 

The test procedure for refrigeration 

systems will require manufacturers to 

perform testing in accordance with a 

single industry test standard: AHRI 1250 

(I–P)–2009, ‘‘2009 Standard for 

Performance Rating of Walk-In Coolers 

and Freezers.’’ DOE researched the cost 

of performing this test and, based on 

discussions with experts, estimates that 

a test using AHRI 1250 (I–P)–2009 

would likely cost approximately $8,500. 

DOE estimates that the total testing cost 

for a typical refrigeration manufacturer 

could be approximately $425,000, based 

on an estimate of 50 basic models, but 

that it could be higher for manufacturers 

of more customized equipment. For 

instance, a manufacturer with 200 basic 

models would incur a testing cost of 

approximately $1.7 million. 

To address concerns of manufacturer 

impact, DOE is including burdenreducing measures for refrigeration 

system manufacturers. The test 

procedure referenced in this final rule, 

AHRI 1250–2009, allows for rating the 

condensing unit and the unit cooler 

separately and then calculating their 

combined efficiency. This reduces 

testing burden by not requiring testing 

of every combination. Allowing such a 

calculation to be used will significantly 

decrease the number of tests. See 

section III.C.2 for details. DOE also 

notes that the CCE final rule, published 

March 7, 2011, allows that in general, 

manufacturers may elect to group 

individual models of equipment into 

basic models at their discretion to the 

extent the models have essentially 

identical electrical, physical, and 

functional characteristics that affect 

energy efficiency or energy 

consumption. Furthermore, 

manufacturers may rate models 

conservatively, meaning the tested 

performance of the model(s) must be at 

least as good as the certified rating, after 

applying the appropriate sampling plan. 

76 FR 12429. DOE believes these 

provisions will reduce the burden of 

testing for refrigeration manufacturers 

because they will reduce the number of 

basic models a manufacturer must test. 

DOE may also consider allowing 

manufacturers to use validated 

alternative methods to rate their 

equipment. See section III.C.3 for 

further discussion of these methods. 

DOE also considered a number of 

alternatives to these test procedures, 

including test procedures that 

incorporate industry test standards 

other than the referenced standards, DIN 

EN 13164:2009–02, DIN EN 

13165:2009–02, ASTM C1363–05, and 

AHRI 1250–2009, all previously 

described in section III. (DOE also notes 

that NFRC 100, the test method adopted 

for determining the U-factor of doors, 

was the least burdensome test DOE 

identified.) Instead of requiring DIN EN 

13164:2009–02 or DIN EN 13165:2009– 

02 for testing the long-term thermal 

properties of insulation, DOE could 

require only ASTM C518–04, ‘‘Standard 

Test Method for Steady-State Thermal 

Transmission Properties by Means of 

the Heat Flow Meter Apparatus,’’ which 

tests the thermal properties of insulation 

at a certain point in time (that is, the 

point of manufacture). This test could 

also be used in place of ASTM 1363–05. 

A test conducted as per ASTM C518–04 

would cost approximately $500 to 

$1,000, as compared to $5,000 for a test 

conducted as per DIN EN 13164:2009– 

02 or DIN EN 13165:2009–02 and $5,000 

for a test conducted as per ASTM 

C1363–05. DOE is including ASTM 

C1363–05 as part of the test procedure 

because heat conduction through 

structural members is a significant panel 

characteristic that is not addressed 

under ASTM C518–04. See section 

III.B.2.a for details. DOE is including 

DIN EN 13164:2009–02 and DIN EN 

13165:2009–02 as part of the test 

procedure because these methods 

account for the effect of aging on foam’s 

insulation performance, a phenomenon 

that is not captured under ASTM C518– 

04. See section III.B.2.b for details. 

C. Review Under the Paperwork 

Reduction Act of 1995 

Manufacturers of walk-in cooler and 

walk-in freezer components must certify 

to DOE that their equipment complies 

with any applicable energy conservation 

standard. In certifying compliance, 

manufacturers must test their 

equipment according to the DOE test 

procedure for walk-in cooler and walkin freezer components, including any 

amendments adopted for that test 

procedure. DOE has adopted regulations 


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for the certification and recordkeeping 

requirements for all covered consumer 

products and commercial equipment, 

including walk-in cooler and walk-in 

freezer components. 76 FR 12442 

(March 7, 2011). The collection-ofinformation requirement for the 

certification and recordkeeping has been 

approved by OMB under control 

number 1910–1400. The public 

reporting burden for the certification is 

estimated to average 20 hours per 

response, including the time for 

reviewing instructions, searching 

existing data sources, gathering and 

maintaining the data needed, and 

completing and reviewing the collection 

of information. 

Public comment is sought regarding: 

Whether this proposed collection of 

information is necessary for the proper 

performance of the functions of the 

agency, including whether the 

information shall have practical utility; 

the accuracy of the burden estimate; 

ways to enhance the quality, utility, and 

clarity of the information to be 

collected; and ways to minimize the 

burden of the collection of information, 

including through the use of automated 

collection techniques or other forms of 

information technology. Send comments 

on these or any other aspects of the 

collection of information to Charles 

Llenza (see ADDRESSES) and by e-mail to 

Christine_J._Kymn@omb.eop.gov. 

Notwithstanding any other provision 

of the law, no person is required to 

respond to, nor shall any person be 

subject to a penalty for failure to comply 

with, a collection of information subject 

to the requirements of the PRA, unless 

that collection of information displays a 

currently valid OMB Control Number. 

D. Review Under the National 

Environmental Policy Act of 1969 

In this final rule, DOE establishes a 

new test procedure for walk-in coolers 

and walk-in freezers. DOE has 

determined that this rule falls into a 

class of actions that are categorically 

excluded from review under the 

National Environmental Policy Act of 

1969 (42 U.S.C. 4321 et seq.) and DOE’s 

implementing regulations at 10 CFR part 

1021. Specifically, this rule establishes 

a test procedure without affecting the 

amount, quality or distribution of 

energy usage, and, therefore, will not 

result in any environmental impacts. 

Thus, this rulemaking is covered by 

Categorical Exclusion A5 under 10 CFR 

part 1021, subpart D, which applies to 

any rulemaking that does not result in 

any environmental impacts. 

Accordingly, neither an environmental 

assessment nor an environmental 

impact statement is required. 

E. Review Under Executive Order 13132 

Executive Order 13132, ‘‘Federalism,’’ 

64 FR 43255 (August 4, 1999) imposes 

certain requirements on agencies 

formulating and implementing policies 

or regulations that preempt State law or 

that have Federalism implications. The 

Executive Order requires agencies to 

examine the constitutional and statutory 

authority supporting any action that 

would limit the policymaking discretion 

of the States and to carefully assess the 

necessity for such actions. The 

Executive Order also requires agencies 

to have an accountable process to 

ensure meaningful and timely input by 

State and local officials in the 

development of regulatory policies that 

have Federalism implications. On 

March 14, 2000, DOE published a 

statement of policy describing the 

intergovernmental consultation process 

it will follow in the development of 

such regulations. 65 FR 13735. DOE 

examined this final rule and determined 

that it will not have a substantial direct 

effect on the States, on the relationship 

between the national government and 

the States, or on the distribution of 

power and responsibilities among the 

various levels of government. EPCA 

governs and prescribes Federal 

preemption of State regulations as to 

energy conservation for the products 

that are the subject of today’s final rule. 

States can petition DOE for exemption 

from such preemption to the extent, and 

based on criteria, set forth in EPCA. (42 

U.S.C. 6297(d)) No further action is 

required by Executive Order 13132. 

F. Review Under Executive Order 12988 

Regarding the review of existing 

regulations and the promulgation of 

new regulations, section 3(a) of 

Executive Order 12988, ‘‘Civil Justice 

Reform,’’ 61 FR 4729 (Feb. 7, 1996), 

imposes on Federal agencies the general 

duty to adhere to the following 

requirements: (1) Eliminate drafting 

errors and ambiguity; (2) write 

regulations to minimize litigation; (3) 

provide a clear legal standard for 

affected conduct rather than a general 

standard; and (4) promote simplification 

and burden reduction. Section 3(b) of 

Executive Order 12988 specifically 

requires that Executive agencies make 

every reasonable effort to ensure that the 

regulation: (1) Clearly specifies the 

preemptive effect, if any; (2) clearly 

specifies any effect on existing Federal 

law or regulation; (3) provides a clear 

legal standard for affected conduct 

while promoting simplification and 

burden reduction; (4) specifies the 

retroactive effect, if any; (5) adequately 

defines key terms; and (6) addresses 

other important issues affecting clarity 

and general draftsmanship under any 

guidelines issued by the Attorney 

General. Section 3(c) of Executive Order 

12988 requires Executive agencies to 

review regulations in light of applicable 

standards in sections 3(a) and 3(b) to 

determine whether they are met or it is 

unreasonable to meet one or more of 

them. DOE has completed the required 

review and determined that, to the 

extent permitted by law, this final rule 

meets the relevant standards of 

Executive Order 12988. 

G. Review Under the Unfunded 

Mandates Reform Act of 1995 

Title II of the Unfunded Mandates 

Reform Act of 1995 (UMRA) requires 

each Federal agency to assess the effects 

of Federal regulatory actions on State, 

local, and Tribal governments and the 

private sector. Public Law 104–4, sec. 

201 (codified at 2 U.S.C. 1531). For a 

regulatory action resulting in a rule that 

may cause the expenditure by State, 

local, and Tribal governments, in the 

aggregate, or by the private sector of 

$100 million or more in any one year 

(adjusted annually for inflation), section 

202 of UMRA requires a Federal agency 

to publish a written statement that 

estimates the resulting costs, benefits, 

and other effects on the national 

economy. (2 U.S.C. 1532(a), (b)) The 

UMRA also requires a Federal agency to 

develop an effective process to permit 

timely input by elected officers of State, 

local, and Tribal governments on a 

proposed ‘‘significant intergovernmental 

mandate,’’ and requires an agency plan 

for giving notice and opportunity for 

timely input to potentially affected 

small governments before establishing 

any requirements that might 

significantly or uniquely affect small 

governments. On March 18, 1997, DOE 

published a statement of policy on its 

process for intergovernmental 

consultation under UMRA. 62 FR 

12820; also available at http:// 

www.gc.doe.gov. DOE examined today’s 

final rule according to UMRA and its 

statement of policy and determined that 

the rule contains neither an 

intergovernmental mandate, nor a 

mandate that may result in the 

expenditure of $100 million or more in 

any year, so these requirements do not 

apply. 

H. Review Under theTreasury and 

General Government Appropriations 

Act, 1999 

Section 654 of the Treasury and 

General Government Appropriations 

Act, 1999 (Pub. L. 105–277) requires 

Federal agencies to issue a Family 

Policymaking Assessment for any rule 


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that may affect family well-being. 

Today’s final rule will not have any 

impact on the autonomy or integrity of 

the family as an institution. 

Accordingly, DOE has concluded that it 

is not necessary to prepare a Family 

Policymaking Assessment. 

I. Review Under Executive Order 12630 

DOE has determined, under Executive 

Order 12630, ‘‘Governmental Actions 

and Interference with Constitutionally 

Protected Property Rights’’ 53 FR 8859 

(March 18, 1988), that this regulation 

will not result in any takings that might 

require compensation under the Fifth 

Amendment to the U.S. Constitution. 

J. Review Under Treasury and General 

Government Appropriations Act, 2001 

Section 515 of the Treasury and 

General Government Appropriations 

Act, 2001 (44 U.S.C. 3516 note) provides 

for agencies to review most 

disseminations of information to the 

public under guidelines established by 

each agency pursuant to general 

guidelines issued by OMB. OMB’s 

guidelines were published at 67 FR 

8452 (Feb. 22, 2002), and DOE’s 

guidelines were published at 67 FR 

62446 (Oct. 7, 2002). DOE has reviewed 

today’s final rule under the OMB and 

DOE guidelines and has concluded that 

it is consistent with applicable policies 

in those guidelines. 

K. Review Under Executive Order 13211 

Executive Order 13211, ‘‘Actions 

Concerning Regulations That 

Significantly Affect Energy Supply, 

Distribution, or Use,’’ 66 FR 28355 (May 

22, 2001), requires Federal agencies to 

prepare and submit to OMB, a 

Statement of Energy Effects for any 

significant energy action. A ‘‘significant 

energy action’’ is defined as any action 

by an agency that promulgated or is 

expected to lead to promulgation of a 

final rule, and that: (1) Is a significant 

regulatory action under Executive Order 

12866, or any successor order; and (2) 

is likely to have a significant adverse 

effect on the supply, distribution, or use 

of energy; or (3) is designated by the 

Administrator of OIRA as a significant 

energy action. For any significant energy 

action, the agency must give a detailed 

statement of any adverse effects on 

energy supply, distribution, or use if the 

regulation is implemented, and of 

reasonable alternatives to the action and 

their expected benefits on energy 

supply, distribution, and use. 

Today’s regulatory action is not a 

significant regulatory action under 

Executive Order 12866. Moreover, it 

would not have a significant adverse 

effect on the supply, distribution, or use 

of energy, nor has it been designated as 

a significant energy action by the 

Administrator of OIRA. Therefore, it is 

not a significant energy action, and, 

accordingly, DOE has not prepared a 

Statement of Energy Effects. 

L. Review Under Section 32 of the 

Federal Energy Administration Act of 

1974 

Under section 301 of the Department 

of Energy Organization Act (Pub. L. 95– 

91; 42 U.S.C. 7101), DOE must comply 

with section 32 of the Federal Energy 

Administration Act of 1974, as amended 

by the Federal Energy Administration 

Authorization Act of 1977. (15 U.S.C. 

788; FEAA) Section 32 essentially 

provides in relevant part that, where a 

proposed rule authorizes or requires use 

of commercial standards, the notice of 

proposed rulemaking must inform the 

public of the use and background of 

such standards. In addition, section 

32(c) requires DOE to consult with the 

Attorney General and the Chairman of 

the Federal Trade Commission (FTC) 

concerning the impact of the 

commercial or industry standards on 

competition. 

The procedures addressed by this 

action incorporate the following 

commercial standards: ASTM C1363– 

05, AHRI 1250 (I–P)–2009, DIN EN 

13164:2009–02, DIN EN 13165:2009–02, 

and NFRC 100–2010[E0A1]. DOE has 

evaluated these standards and is unable 

to conclude whether they fully comply 

with the requirements of section 32(b) of 

the FEAA (i.e. whether they were 

developed in a manner that fully 

provides for public participation, 

comment, and review.) DOE has 

consulted with both the Attorney 

General and the Chairman of the FTC 

about the impact on competition of 

using the methods contained in these 

standards and has received no 

comments objecting to their use. 

M. Congressional Notification 

As required by 5 U.S.C. 801, DOE will 

report to Congress on the promulgation 

of today’s rule before its effective date. 

The report will state that it has been 

determined that the rule is not a ‘‘major 

rule’’ as defined by 5 U.S.C. 804(2). 

N. Approval of the Office of the 

Secretary 

The Secretary of Energy has approved 

publication of this final rule. 

List of Subjects in 10 CFR Part 431 

Administrative practice and 

procedure, Confidential business 

information, Energy conservation, 

Incorporation by reference, Reporting 

and recordkeeping requirements. 

Issued in Washington, DC, on March 30, 

2011. 

Kathleen Hogan, 

Deputy Assistant Secretary for Energy 

Efficiency, Office of Technology 

Development, Energy Efficiency and 

Renewable Energy. 

PART 431—ENERGY EFFICIENCY 

PROGRAM FOR CERTAIN 

COMMERCIAL AND INDUSTRIAL 

EQUIPMENT 

■ 1. The authority citation for part 431 

continues to read as follows: 

Authority: 42 U.S.C. 6291–6317. 

■ 2. Section 431.302 is amended by 

adding, in alphabetical order, new 

definitions for ‘‘Display door,’’ ‘‘Display 

panel,’’ ‘‘Door’’, ‘‘Envelope,’’ ‘‘K-factor,’’ 

‘‘Panel,’’ ‘‘Refrigerated,’’ ‘‘Refrigeration 

system,’’ and ‘‘U-factor’’ to read as 

follows: 

§ 431.302 Definitions concerning walk-in 

coolers and walk-in freezers. 

* * * * * 

Display door means a door designed 

for product movement, display, or both, 

rather than the passage of persons. 

Display panel means a panel that is 

entirely or partially comprised of glass, 

a transparent material, or both and is 

used for display purposes. 

Door means an assembly installed in 

an opening on an interior or exterior 

wall that is used to allow access or close 

off the opening and that is movable in 

a sliding, pivoting, hinged, or revolving 

manner of movement. For walk-in 

coolers and walk-in freezers, a door 

includes the door panel, glass, framing 

materials, door plug, mullion, and any 

other elements that form the door or 

part of its connection to the wall. 

Envelope means— 

(1) The portion of a walk-in cooler or 

walk-in freezer that isolates the interior, 

refrigerated environment from the 

ambient, external environment; and 

(2) All energy-consuming components 

of the walk-in cooler or walk-in freezer 

that are not part of its refrigeration 

system. 

K-factor means the thermal 

conductivity of a material. 

* * * * * 

Panel means a construction 

component that is not a door and is 

used to construct the envelope of the 

walk-in, i.e., elements that separate the 

interior refrigerated environment of the 

walk-in from the exterior. 

Refrigerated means held at a 

temperature at or below 55 degrees 

Fahrenheit using a refrigeration system. 

Refrigeration system means the 

mechanism (including all controls and 

other components integral to the 


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system’s operation) used to create the 

refrigerated environment in the interior 

of a walk-in cooler or freezer, consisting 

of: 

(1) A packaged dedicated system 

where the unit cooler and condensing 

unit are integrated into a single piece of 

equipment; or 

(2) A split dedicated system with 

separate unit cooler and condensing 

unit sections; or 

(3) A unit cooler that is connected to 

a multiplex condensing system. 

U-factor means the heat transmission 

in a unit time through a unit area of a 

specimen or product and its boundary 

air films, induced by a unit temperature 

difference between the environments on 

each side. 

* * * * * 

■ 3. Section 431.303 is amended by: 

■ a. Redesignating paragraph (b) as 

paragraph (c); 

■ b. Adding at the end of the sentence 

in redesignated paragraph (c)(1), ‘‘and 

Appendix A to Subpart R of Part 431’’. 

■ c. Adding new paragraphs (b), (c)(2), 

(d), and (e) to read as follows. 

§ 431.303 Materials incorporated by 

reference. 

* * * * * 

(b) AHRI. Air-Conditioning, Heating, 

and Refrigeration Institute, 2111 Wilson 

Boulevard, Suite 500, Arlington, VA 

22201, (703) 600–0366, or http:// 

www.ahrinet.org. 

(1) AHRI 1250 (I–P)-2009, (‘‘AHRI 

1250’’), 2009 Standard for Performance 

Rating of Walk-In Coolers and Freezers, 

approved 2009, IBR approved for 

§ 431.304. 

(2) [Reserved] 

(c) * * * 

(2) ASTM C1363–05, (‘‘ASTM 

C1363’’), Standard Test Method for 

Thermal Performance of Building 

Materials and Envelope Assemblies by 

Means of a Hot Box Apparatus, 

approved May 1, 2005, IBR approved for 

Appendix A to Subpart R of part 431. 

(d) CEN. European Committee for 

Standardization (French: Norme or 

German: Norm), Avenue Marnix 17, B– 

1000 Brussels, Belgium, Tel: + 32 2 550 

08 11, Fax: + 32 2 550 08 19 or 

http://www.cen.eu/. 

(1) DIN EN 13164:2009–02, (‘‘DIN EN 

13164’’), Thermal insulation products 

for buildings—Factory made products of 

extruded polystyrene foam (XPS)— 

Specification, approved February 2009, 

IBR approved for Appendix A to 

Subpart R of part 431. 

(2) DIN EN 13165:2009–02, (‘‘DIN EN 

13165’’), Thermal insulation products 

for buildings—Factory made rigid 

polyurethane foam (PUR) products— 

Specification, approved February 2009, 

IBR approved for Appendix A to 

Subpart R of part 431. 

(e) NFRC. National Fenestration 

Rating Council, 6305 Ivy Lane, Ste. 140, 

Greenbelt, MD 20770, (301) 589–1776, 

or http://www.nfrc.org/. 

(1) NFRC 100–2010[E0A1], (‘‘NFRC 

100’’), Procedure for Determining 

Fenestration Product U-factors, 

approved June 2010, IBR approved for 

Appendix A to Subpart R of part 431. 

(2) [Reserved] 

■ 4. Section 431.304 is amended by 

redesignating paragraphs (b)(2), (b)(3), 

(b)(4), and (b)(5) as (b)(1), (b)(2), (b)(3), 

and (b)(4), respectively, and by adding 

new paragraphs (b)(5), (b)(6), (b)(7), and 

(b)(8) to read as follows. 

§ 431.304 Uniform test method for the 

measurement of energy consumption of 

walk-in coolers and walk-in freezers. 

* * * * * 

(b) * * * 

(5) Determine the U-factor, 

conduction load, and energy use of 

walk-in cooler and walk-in freezer 

display panels, floor panels, and nonfloor panels by conducting the test 

procedure set forth in Appendix A to 

this subpart, sections 4.1, 4.2, and 4.3, 

respectively. 

(6) Determine the energy use of walkin cooler and walk-in freezer display 

doors and non-display doors by 

conducting the test procedure set forth 

in Appendix A to this subpart, sections 

4.4 and 4.5, respectively. 

(7) Determine the Annual Walk-in 

Energy Factor of walk-in cooler and 

walk-in freezer refrigeration systems by 

conducting the test procedure set forth 

in AHRI 1250 (incorporated by 

reference; see § 431.303). 

(8) Determine the annual energy 

consumption of walk-in cooler and 

walk-in freezer refrigeration systems: 

(i) For systems consisting of a 

packaged dedicated system or a split 

dedicated system, where the condensing 

unit is located outdoors, by conducting 

the test procedure set forth in AHRI 

1250 and recording the annual energy 

consumption term in the equation for 

annual walk-in energy factor in section 

7 of AHRI 1250: 

where tj and n represent the outdoor 

temperature at each bin j and the number 

of hours in each bin j, respectively, for 

the temperature bins listed in Table D1 

of AHRI 1250. 

(ii) For systems consisting of a 

packaged dedicated system or a split 

dedicated system where the condensing 

unit is located in a conditioned space, 

by performing the following calculation: 

where BL ̊H and BL ̊L for refrigerator and 

freezer systems are defined in sections 

6.2.1 and 6.2.2, respectively, of AHRI 

1250 and the annual walk-in energy 

factor is calculated from the results of 

the test procedures set forth in AHRI 

1250. 

(iii) For systems consisting of a single 

unit cooler or a set of multiple unit 

coolers serving a single piece of 

equipment and connected to a multiplex 

condensing system, by performing the 

following calculation: 


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where BL ̊Hand BL ̊L for refrigerator and 

freezer systems are defined in section 

7.9.2.2 and 7.9.2.3, respectively, of AHRI 

1250 and the annual walk-in energy 

factor is calculated from the results of 

the test procedures set forth in AHRI 

1250. 

■ 5.Appendix A to subpart R of part 431 

is added to read as follows: 

Appendix A to Subpart R of Part 431— 

Uniform Test Method for the 

Measurement of Energy Consumption of 

the Components of Envelopes of WalkIn Coolers and Walk-In Freezers 

1.0 Scope 

This appendix covers the test requirements 

used to measure the energy consumption of 

the components that make up the envelope 

of a walk-in cooler or walk-in freezer. 

2.0 Definitions 

The definitions contained in § 431.302 are 

applicable to this appendix. 

3.0 Additional Definitions 

3.1 Automatic door opener/closer means 

a device or control system that 

‘‘automatically’’ opens and closes doors 

without direct user contact, such as a motion 

sensor that senses when a forklift is 

approaching the entrance to a door and opens 

it, and then closes the door after the forklift 

has passed. 

3.2 Core region means the part of the 

panel that is not the edge region. 

3.3 Edge region means a region of the 

panel that is wide enough to encompass any 

framing members and edge effects. If the 

panel contains framing members (e.g. a wood 

frame) then the width of the edge region must 

be as wide as any framing member plus 2 in. 

± 0.25 in. If the panel does not contain 

framing members then the width of the edge 

region must be 4 in. ± 0.25 in. For walk-in 

panels that utilize vacuum insulated panels 

(VIP) for insulation, the width of the edge 

region must be the lesser of 4.5 in. ± 1 in. 

or the maximum width that does not cause 

the VIP to be pierced by the cutting device 

when the edge region is cut. 

3.4 Surface area means the area of the 

surface of the walk-in component that would 

be external to the walk-in. For example, for 

panel, the surface area would be the area of 

the side of the panel that faces the outside 

of the walk-in. It would not include edges of 

the panel that are not exposed to the outside 

of the walk-in. 

3.5 Rating conditions means, unless 

explicitly stated otherwise, all conditions 

shown in Table A.1. For installations where 

two or more walk-in envelope components 

share any surface(s), the ‘‘external 

conditions’’ of the shared surface(s) must 

reflect the internal conditions of the adjacent 

walk-in. For example, if a walk-in component 

divides a walk-in freezer from a walk-in 

cooler, then the internal conditions are the 

freezer rating conditions and the external 

conditions are the cooler rating conditions. 

3.6 Percent time off (PTO) means the 

percent of time that an electrical device is 

assumed to be off. 

TABLE A.1—TEMPERATURE

CONDITIONS

Value 

Internal Temperatures (cooled 

space within the envelope): 

Cooler Dry Bulb Temperature .. 35 °F 

Freezer Dry Bulb Temperature ¥10 °F 

External Temperatures (space external to the envelope): 

Freezer and Cooler Dry Bulb 

Temperatures.

75 °F 

Subfloor Temperatures: 

Freezer and Cooler Dry Bulb 

Temperatures.

55 °F 

4.0 Calculation Instructions 

4.1 Display Panels 

(a) Calculate the U-factor of the display 

panel in accordance with section 5.3 of this 

appendix, Btu/h-ft2¥°F. 

(b) Calculate the display panel surface area, 

as defined in section 3.4 of this appendix, 

Adp, ft2, with standard geometric formulas or 

engineering software. 

(c) Calculate the temperature differential, 

DTdp, °F, for the display panel, as follows: 

Where: 

TDB,ext,dp = dry-bulb air external temperature, 

°F, as prescribed in Table A.1; and 

TDB,int, dp = dry-bulb air temperature internal 

to the cooler or freezer, °F, as prescribed 

in Table A.1. 

(d) Calculate the conduction load through 

the display panel, Qcond-dp, Btu/h, as follows: 

Where: 

Adp= surface area of the walk-in display 

panel, ft2; 

DTdp= temperature differential between 

refrigerated and adjacent zones, °F; and 

Udp = thermal transmittance, U-factor, of the 

display panel in accordance with section 

5.3 of this appendix, Btu/h-ft2¥°F. 

(e) Select Energy Efficiency Ratio (EER), as 

follows: 

(1) For coolers, use EER = 12.4 Btu/W-h 

(2) For freezers, use EER = 6.3 Btu/W-h 

(f) Calculate the total daily energy 

consumption, Edp, kWh/day, as follows: 

Where: 

Qcond, dp = the conduction load through the 

display panel, Btu/h; and 

EER = EER of walk-in (cooler or freezer), Btu/ 

W-h. 

4.2 Floor Panels 

(a) Calculate the surface area, as defined in 

section 3.4 of this appendix, of the floor 

panel edge, as defined in section 3.3, Afp edge, 

ft2, with standard geometric formulas or 

engineering software as directed in section 

5.1 of this appendix. 

(b) Calculate the surface area, as defined in 

section 3.4 of this appendix, of the floor 

panel core, as defined in section 3.2, Afp core, 

ft2, with standard geometric formulas or 


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engineering software as directed in section 

5.1 of this appendix. 

(c) Calculate the total area of the floor 

panel, Afp, ft2, as follows: 

Where: 

Afp core = floor panel core area, ft2; and 

Afp edge = floor panel edge area, ft2. 

(d) Calculate the temperature differential of 

the floor panel, DTfp, °F, as follows: 

Where: 

Text, fp = subfloor temperature, °F, as 

prescribed in Table A.1; and 

TDB,int, fp = dry-bulb air internal temperature, 

°F, as prescribed in Table A.1. If the 

panel spans both cooler and freezer 

temperatures, the freezer temperature 

must be used. 

(e) Calculate the floor foam degradation 

factor, DFfp, unitless, as follows: 

Where: 

RLTTR,fp = the long term thermal resistance 

R-value of the floor panel foam in 

accordance with section 5.2 of this 

appendix, h-ft2-°F/Btu; and 

Ro,fp = the R-value of foam determined in 

accordance with ASTM C518 

(incorporated by reference; see section 

§ 431.303) for purposes of compliance 

with the appropriate energy conservation 

standard, h-ft2-°F/Btu. 

(f) Calculate the U-factor for panel core 

region modified by the long term thermal 

transmittance of foam, ULT,fp core, Btu/hft2¥°F, as follows: 

Where: 

Ufp core = the U-factor in accordance with 

section 5.1 of this appendix, Btu/h-ft2-°F; 

and 

DFfp = floor foam degradation factor, unitless. 

(g) Calculate the overall U-factor of the 

floor panel, Ufp, Btu/h-ft2-°F, as follows: 

Where: 

Afp edge = area of floor panel edge, ft2; 

Ufp edge = U-factor for panel edge area in 

accordance with section 5.1 of this 

appendix, Btu/h-ft2-°F; 

Afp core = area of floor panel core, ft2; 

ULT,fp core = U-factor for panel core region 

modified by the long term thermal 

transmittance of foam, Btu/h-ft2-°F; and 

Afp = total area of the floor panel, ft2. 

(h) Calculate the conduction load through 

floor panels, Qcond-fp, Btu/h, 

Where: 

DTfp = temperature differential across the 

floor panels, °F; 

Afp = total area of the floor panel, ft2; and 

Ufp = overall U-factor of the floor panel, Btu/ 

h-ft2-°F. 

(i) Select Energy Efficiency Ratio (EER), as 

follows: 

(1) For coolers, use EER = 12.4 Btu/W-h 

(2) For freezers, use EER = 6.3 Btu/W-h 

(j) Calculate the total daily energy 

consumption, Efp, kWh/day, as follows: 

Where: 

Qcond-fp = the conduction load through the 

floor panel, Btu/h; and 

EER = EER of walk-in (cooler or freezer), Btu/ 

W-h. 

4.3 Non-Floor Panels 

(a) Calculate the surface area, as defined in 

section 3.4, of the non-floor panel edge, as 

defined in section 3.3, Anf edge, ft2, with 

standard geometric formulas or engineering 

software as directed in section 5.1 of this 

appendix. 

(b) Calculate the surface area, as defined in 

section 3.4, of the non-floor panel core, as 

defined in section 3.2, Anf core, ft2, with 

standard geometric formulas or engineering 

software as directed in section 5.1 of this 

appendix. 

(c) Calculate total non-floor panel area, Anf, 

ft2: 

Where: 

Anf edge = non-floor paneledge area,ft2; and 

Anf core = non-floor panel core area, ft2. 

(d) Calculate temperature differential, DTnf, 

°F: 

Where: 

TDB,ext, nf = dry-bulb air external temperature, 

°F, as prescribed in Table A.1; and 

TDB,int, nf = dry-bulb air internal temperature, 

°F, as prescribed in Table A.1. If the nonfloor panel spans both cooler and freezer 

temperatures, then the freezer 

temperature must be used. 

(e) Calculate the non-floor foam 

degradation factor, DFnf, unitless, as follows: Where: 

RLTTR,nf = the R-value of the non-floor panel 

foam in accordance with section 5.2 of 

this appendix, h-ft2-°F/Btu; and 


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21608 Federal Register / Vol. 76, No. 73 / Friday, April 15, 2011 / Rules and Regulations 

Ro,nf = the R-value of foam determined in 

accordance with ASTM C518 

(incorporated by reference; see section 

§ 431.303) for purposes of compliance 

with the appropriate energy conservation 

standard, h-ft2-°F/Btu. 

(f) Calculate the U-factor, ULT,nf core, Btu/hft2-°F, as follows: 

Where: 

Unf core = the U-factor, in accordance with 

section 5.1 of this appendix, of non-floor 

panel, Btu/h- ft2-°F; and 

DFnf = the non-floor foam degradation factor, 

unitless. 

(g) Calculate the overall U-factor of the 

non-floor panel, Unf, Btu/h-ft2-°F, as follows: 

Where: 

Anf edge = area of non-floor panel edge, ft2; 

Unf edge = U-factor for non-floor panel edge 

area in accordance with section 5.1 of 

this appendix, Btu/h-ft2-°F; 

Anf core = area of non-floor panel core, ft2; 

ULT,nf core = U-factor for non-floor panel core 

region modified by the long term thermal 

transmittance of foam, Btu/h-ft2-°F; and 

Anf = total area of the non- floor panel, ft2. 

(h) Calculate the conduction load through 

non-floor panels, Qcond-nf, Btu/h, 

Where: 

DTnf = temperature differential across the 

non-floor panels, °F; 

Anf = total area of the non-floor panel, ft2; and 

Unf = overall U-factor of the non-floor panel, 

Btu/h-ft2-°F. 

(i) Select Energy Efficiency Ratio (EER), as 

follows: 

(1) For coolers, use EER = 12.4 Btu/W-h 

(2) For freezers, use EER = 6.3 Btu/W-h 

(j) Calculate the total daily energy 

consumption, Enf, kWh/day, as follows: 

Where: 

Qcond-nf = the conduction load through the 

non-floor panel, Btu/h; and 

EER = EER of walk-in (cooler or freezer), Btu/ 

W-h. 

4.4 Display Doors 

4.4.1 Conduction Through Display Doors 

(a) Calculate the U-factor of the door in 

accordance with section 5.3 of this appendix, 

Btu/h-ft2-°F 

(b) Calculate the surface area, as defined in 

section 3.4 of this appendix, of the display 

door, Add, ft2, with standard geometric 

formulas or engineering software. 

(c) Calculate the temperature differential, 

DTdd, °F, for the display door as follows: 

Where: 

TDB,ext, dd = dry-bulb air temperature external 

to the display door, °F, as prescribed in 

Table A.1; and 

TDB,int, dd = dry-bulb air temperature internal 

to the display door, °F, as prescribed in 

Table A.1. 

(d) Calculate the conduction load through 

the display doors, Qcond-dd, Btu/h, as follows: 

Where: 

DTdd = temperature differential between 

refrigerated and adjacent zones, °F; 

Add = surface area walk-in display doors, ft2; 

and 

Udd = thermal transmittance, U-factor of the 

door, in accordance with section 5.3 of 

this appendix, Btu/h-ft2-°F. 

4.4.2 Direct Energy Consumption of 

Electrical Component(s) of Display Doors 

Electrical components associated with 

display doors could include, but are not 

limited to: Heater wire (for anti-sweat or antifreeze application); lights (including display 

door lighting systems); control system units; 

and sensors. 

(a) Select the required value for percent 

time off (PTO) for each type of electricity 

consuming device, PTOt (%) 

(1) For lights without timers, control 

system or other demand-based control, PTO 

= 25 percent. For lighting with timers, 

control system or other demand-based 

control, PTO = 50 percent. 

(2) For anti-sweat heaters on coolers (if 

included): Without timers, control system or 

other demand-based control, PTO = 0 

percent. With timers, control system or other 

demand-based control, PTO = 75 percent. For 

anti-sweat heaters on freezers (if included): 

Without timers, control system or other autoshut-off systems, PTO = 0 percent. With 

timers, control system or other demand-based 

control, PTO = 50 percent. 

(3) For all other electricity consuming 

devices: Without timers, control system, or 

other auto-shut-off systems, PTO = 0 percent. 

If it can be demonstrated that the device is 

controlled by a preinstalled timer, control 

system or other auto-shut-off system, PTO = 

25 percent. 

(b) Calculate the power usage for each type 

of electricity consuming device, Pdd-comp,u,t, 

kWh/day, as follows: 


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Federal Register / Vol. 76, No. 73 / Friday, April 15, 2011 / Rules and Regulations 21609 

Where: 

u = the index for each of type of electricityconsuming device located on either 

(1) the interior facing side of the display 

door or within the inside portion of the 

display door, (2) the exterior facing side 

of the display door, or (3) any 

combination of (1) and (2). For purposes 

of this calculation, the interior index is 

represented by u = int and the exterior 

index is represented by u = ext. If the 

electrical component is both on the 

interior and exterior side of the display 

door then u = int. For anti-sweat heaters 

sited anywhere in the display door, 75 

percent of the total power is be attributed 

to u = int and 25 percent of the total 

power is attributed to u = ext; 

t = index for each type of electricity 

consuming device with identical rated 

power; 

Prated,u,t = rated power of each component, of 

type t, kW; 

PTOu,t = percent time off, for device of type 

t, %; and 

nu,t = number of devices at the rated power 

of type t, unitless. 

(c) Calculate the total electrical energy 

consumption for interior and exterior power, 

Pdd-tot, int (kWh/day) and Pdd-tot, ext (kWh/day), 

respectively, as follows: 

Where: 

t = index for each type of electricity 

consuming device with identical rated 

power; 

Pdd-comp,int, t = the energy usage for an 

electricity consuming device sited on the 

interior facing side of or in the display 

door, of type t, kWh/day; and 

Pdd-comp,ext, t = the energy usage for an 

electricity consuming device sited on the 

external facing side of the display door, 

of type t, kWh/day. 

(d) Calculate the total electrical energy 

consumption, Pdd-tot, (kWh/day), as follows: 

Where: 

Pdd-tot,int = the total interior electrical energy 

usage for the display door, kWh/day; and 

Pdd-tot,ext = the total exterior electrical energy 

usage for the display door, kWh/day. 

4.4.3 Total Indirect Electricity Consumption 

Due to Electrical Devices 

(a) Select Energy Efficiency Ratio (EER), as 

follows: 

(1) For coolers, use EER = 12.4 Btu/Wh 

(2) For freezers, use EER = 6.3 Btu/Wh 

(b) Calculate the additional refrigeration 

energy consumption due to thermal output 

from electrical components sited inside the 

display door, Cdd-load, kWh/day, as follows: 

Where: 

EER = EER of walk-in cooler or walk-in 

freezer, Btu/W-h; and 

Pdd-tot,int = The total internal electrical energy 

consumption due for the display door, 

kWh/day. 

4.4.4 Total Display Door Energy 

Consumption 

(a) Select Energy Efficiency Ratio (EER), as 

follows: 

(1) For coolers, use EER = 12.4 Btu/W-h 

(2) For freezers, use EER = 6.3 Btu/W-h 

(b) Calculate the total daily energy 

consumption due to conduction thermal 

load, Edd, thermal, kWh/day, as follows: 

Where: 

Qcond, dd = the conduction load through the 

display door, Btu/h; and 

EER = EER of walk-in (cooler or freezer), Btu/ 

W-h. 

(c) Calculate the total energy, Edd,tot, kWh/ 

day, 


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21610 Federal Register / Vol. 76, No. 73 / Friday, April 15, 2011 / Rules and Regulations 

Where: 

Edd, thermal = the total daily energy 

consumption due to thermal load for the 

display door, kWh/day; 

Pdd-tot = the total electrical load, kWh/day; 

and 

Cdd-load = additional refrigeration load due to 

thermal output from electrical 

components contained within the 

display door, kWh/day. 

4.5 Non-Display Doors 

4.5.1 Conduction Through Non-Display 

Doors 

(a) Calculate the surface area, as defined in 

section 3.4 of this appendix, of the nondisplay door, And, ft2, with standard 

geometric formulas or with engineering 

software. 

(b) Calculate the temperature differential of 

the non-display door, DTnd,°F, as follows: 

Where: 

TDB,ext, nd = dry-bulb air external temperature, 

°F, as prescribed by Table A.1; and 

TDB,int, nd = dry-bulb air internal temperature, 

°F, as prescribed by Table A.1. If the 

component spans both cooler and freezer 

spaces, the freezer temperature must be 

used. 

(c) Calculate the conduction load through 

the non-display door: Qcond-nd, Btu/h, 

Where: 

DTnd = temperature differential across the 

non-display door, °F; 

Und = thermal transmittance, U-factor of the 

door, in accordance with section 5.3 of 

this appendix, Btu/h-ft2-°F; and 

And = area of non-display door, ft2. 

4.5.2 Direct Energy Consumption of 

Electrical Components of Non-Display Doors 

Electrical components associated with a 

walk-in non-display door comprise any 

components that are on the non-display door 

and that directly consume electrical energy. 

This includes, but is not limited to, heater 

wire (for anti-sweat or anti-freeze 

application), control system units, and 

sensors. 

(a) Select the required value for percent 

time off for each type of electricity 

consuming device, PTOt (%) 

(1) For lighting without timers, control 

system or other demand-based control, PTO 

= 25 percent. For lighting with timers, 

control system or other demand-based 

control, PTO = 50 percent. 

(2) For anti-sweat heaters on coolers (if 

included): Without timers, control system or 

other demand-based control, PTO = 0 

percent. With timers, control system or other 

demand-based control, PTO = 75 percent. For 

anti-sweat heaters on freezers (if included): 

Without timers, control system or other autoshut-off systems, PTO = 0 percent. With 

timers, control system or other demand-based 

control, PTO = 50 percent. 

(3) For all other electricity consuming 

devices: Without timers, control system, or 

other auto-shut-off systems, PTO = 0 percent. 

If it can be demonstrated that the device is 

controlled by a preinstalled timer, control 

system or other auto-shut-off system, PTO = 

25 percent. 

(b) Calculate the power usage for each type 

of electricity consuming device, Pnd-comp,u,t, 

kWh/day, as follows: 

Where: 

u = the index for each type of electricityconsuming device located on either (1) 

the interior facing side of the display 

door or within the inside portion of the 

display door, (2) the exterior facing side 

of the display door, or (3) any 

combination of (1) and (2). For purposes 

of this calculation, the interior index is 

represented by u = int and the exterior 

index is represented by u = ext. If the 

electrical component is both on the 

interior and exterior side of the display 

door then u = int. For anti-sweat heaters 

sited anywhere in the display door, 75 

percent of the total power is attributed to 

u = int and 25 percent of the total power 

is attributed to u = ext; 

t = index for each type of electricity 

consuming device with identical rated 

power; 

Prated,u,t = rated power of each component, of 

type t, kW; 

PTOu,t = percent time off, for device of type 

t, %; and 

nu,t = number of devices at the rated power 

of type t, unitless. 

(c) Calculate the total electrical energy 

consumption for interior and exterior power, 

Pnd-tot, int (kWh/day) and Pnd-tot, ext (kWh/day), 

respectively, as follows: 

Where: t = index for each type of electricity 

consuming device with identical rated 

power; 

Pnd-comp,int, t = the energy usage for an 

electricity consuming device sited on the 

internal facing side or internal to the 


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Federal Register / Vol. 76, No. 73 / Friday, April 15, 2011 / Rules and Regulations 21611 

non-display door, of type t, kWh/day; 

and 

Pnd-comp,ext, t = the energy usage for an 

electricity consuming device sited on the 

external facing side of the non-display 

door, of type t, kWh/day. For anti-sweat 

heaters, 

(d) Calculate the total electrical energy 

consumption, Pnd-tot, kWh/day, as follows: 

Where: 

Pnd-tot,int = the total interior electrical energy 

usage for the non-display door, of type 

t, kWh/day; and 

Pnd-tot,ext = the total exterior electrical energy 

usage for the non-display door, of type 

t, kWh/day. 

4.5.3 Total Indirect Electricity Consumption 

Due to Electrical Devices 

(a) Select Energy Efficiency Ratio (EER), as 

follows: 

(1) For coolers, use EER = 12.4 Btu/Wh 

(2) For freezers, use EER = 6.3 Btu/Wh 

(b) Calculate the additional refrigeration 

energy consumption due to thermal output 

from electrical components associated with 

the non-display door, Cnd-load, kWh/day, as 

follows: 

Where: 

EER = EER of walk-in cooler or freezer, Btu/ 

W-h; and 

Pnd-tot,int = the total interior electrical energy 

consumption for the non-display door, 

kWh/day. 

4.5.4 Total Non-Display Door Energy 

Consumption 

(a) Select Energy Efficiency Ratio (EER), as 

follows: 

(1) For coolers, use EER = 12.4 Btu/W-h 

(2) For freezers, use EER = 6.3 Btu/W-h 

(b) Calculate the total daily energy 

consumption due to thermal load, End, thermal, 

kWh/day, as follows: 

Where: 

Qcond-nd = the conduction load through the 

non-display door, Btu/hr; and 

EER = EER of walk-in (cooler or freezer), Btu/ 

W-h. 

(c) Calculate the total energy, End,tot, kWh/ 

day, as follows: 

Where: 

End, thermal = the total daily energy 

consumption due to thermal load for the 

non-display door, kWh/day; 

Pnd-tot = the total electrical energy 

consumption, kWh/day; and 

Cnd-load = additional refrigeration load due to 

thermal output from electrical 

components contained on the inside face 

of the non-display door, kWh/day. 

5.0 Test Methods and Measurements 

5.1 Measuring Floor and Non-Floor Panel 

U-Factors 

Follow the test procedure in ASTM C1363, 

(incorporated by reference; see § 431.303), 

exactly, with these exceptions: 

(1) Test Sample Geometry Requirements 

(i) Two (2) panels, 8 ft. ± 1 ft. long and 

4 ft. ± 1 ft. wide must be used. 

(ii) The panel edges must be joined using 

the manufacturer’s panel interface joining 

system (e.g., camlocks, standard gasketing, 

etc.). 

(iii) The Panel Edge Test Region, see figure 

1, must be cut using the following 

dimensions: 

1. If the panel contains framing members 

(e.g. a wood frame), then the width of edge 

(W) must be as wide as any framing member 

plus 2 in. ± 0.25 in. For example, if the face 

of the panel contains 1.5 in. thick framing 

members around the edge of the panel, then 

width of edge (W) = 3.5 in. ± 0.25 in and the 

Panel Edge Test Region would be 7 in. 

± 0.5 in. wide. 

2. If the panel does not contain framing 

members, then the width of edge (W) must 

be 4 in. ± 0.25 in. 

3. Walk-in panels that utilize vacuum 

insulated panels (VIP) for insulation, width 

of edge (W) = the lesser of 4.5 in. ± 1 in. or 

the maximum width that does not cause the 

VIP to be pierced by the cutting device when 

the edge region is cut. 

(iv) Panel Core Test Region of length Y and 

height Z, see Figure 1, must also be cut from 

one of the two panels such that panel length 

= Y + X, panel height = Z + X where X = 

2W. 


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21612 Federal Register / Vol. 76, No. 73 / Friday, April 15, 2011 / Rules and Regulations 

(2) Testing Conditions 

(i) The air temperature on the ‘‘hot side’’, 

as denoted in ASTM C1363, of the non-floor 

panel should be maintained at 75 °F ± 1 °F. 

1. Exception: When testing floor panels, 

the air temperature should be maintained at 

55 °F ± 1 °F. 

(ii) The temperature on the ‘‘cold side’’, as 

denoted in ASTM C1363, of the panel should 

be maintained at 35 °F ± 1 °F for the panels 

used for walk-in coolers and ¥10 °F ± 1 °F 

for panels used for walk-in freezers. 

(iii) The air velocity must be maintained as 

natural convection conditions as described in 

ASTM C1363. The test must be completed 

using the masked method and with surround 

panel in place as described in ASTM C1363. 

(3) Required Test Measurements 

(i) Non-floor Panels 

1. Panel Edge Region U-factor: Unf, edge

2. Panel Core Region U-factor: Unf, core

(ii) Floor Panels 

1. Floor Panel Edge Region U-factor: 

Ufp, edge

2. Floor Panel Core Region U-factor: Ufp, core

5.2 Measuring Long Term Thermal 

Resistance (LTTR) of Insulating Foam 

Follow the test procedure in Annex C of 

DIN EN 13164 or Annex C of DIN EN 13165 

(as applicable), (incorporated by reference; 

see § 431.303), exactly, with these 

exceptions: 

(1) Temperatures During Thermal 

Resistance Measurement 

(i) For freezers: 35 °F ± 1 °F must be used 

(ii) For coolers: 55 °F ± 1 must be used 

(2) Sample Panel Preparation 

(i) A 800mm × 800mm square (× thickness 

of the panel) section cut from the geometric 

center of the panel that is being tested must 

be used as the sample for completing DIN EN 

13165. 

(ii) A 500mm × 500mm square (× thickness 

of the panel) section cut from the geometric 

center of the panel that is being tested must 

be used as the sample for completing DIN EN 

13164. 

(3) Required Test Measurements 

(i) Non-floor Panels 

1. Long Term Thermal Resistance: RLTTR,nf

(ii) Floor Panels 

1. Long Term Thermal Resistance: RLTTR,fp

5.3 U-factor of Doors and Display Panels 

(a) Follow the procedure in NFRC 100, 

(incorporated by reference; see § 431.303), 

exactly, with these exceptions: 

(1) The average convective heat transfer 

coefficient on both interior and exterior 

surfaces of the door should be based on the 

coefficients described in section 4.3 of NFRC 

100. 

(2) Internal conditions: 

(i) Air temperature of 35 °F (1.7 °C) for 

cooler doors and ¥10 °F (¥23.3 °C) for 

freezer doors 

(ii) Mean inside radiant temperature must 

be the same as shown in section 5.3(a)(2)(i), 

above. 

(3) External conditions 

(i) Air temperature of 75 °F (23.9 °C) 

(ii) Mean outside radiant temperature must 

be the same as section 5.3(a)(3)(i), above. 

(4) Direct solar irradiance = 0 W/m2 (Btu/ 

h-ft2). 

(b) Required Test Measurements 

(i) Display Doors and Display Panels 

1. Thermal Transmittance: Udd

(ii) Non-Display Door 

1. Thermal Transmittance: Und

[FR Doc. 2011–8690 Filed 4–14–11; 8:45 am] 

BILLING CODE 6450–01–P 


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