EE-TP-98-101 COMMENT 01B

US DEPARTMlliNT OF ENERGY B 

Workshop Regarding Energy Efficiency Test Procedures, Labeling, Standards 

Compliance and Related Matters for Commercial Water Heaters, Boilers, Furnaces, 

Air Conditioners and Heat Pumps 

Forrestal Building, Room lE-245 

1000 Independence Avenue, SW 

Washington, DC 20585 

April 14 and 15, i998 

PRELIMINARY AGENDA 

Purpose of the Workshop The purpose of the workshop is to discuss test procedures 

for commercial water heaters, boilers and furnaces, and air 

conditioners and heat pumps, as well as related issues 

involving sampling, certification, labeling and 

enforcemel1l. The Department will consider the views 

presented and the comments submitted informulating its 

proposed rule for lest procedures covering these products 

and in suggesting revisions to ASHRAE Standard 90.1. 

Tuesday, April 14, 1998 

9:00 - 9: 15 Opening remarks and introduction 

9: 15 - 9:30 Overview of the rulemaking process 

9:30 - 9:40 Agenda review 

Test Protocols for commercial water heaters 

9:40 -10:00 DOE introduction and NIST overview 

10:00 - 10:45 Clarification of coverage and definitions 

The table of coverage in ASHRAE 90.1 b - 1989 (Table 11.1) can be 

confusing, and the subcategories do not always mesh with EPCA, or the 

corresponding recommended test procedures. 
EE-TP-98-101 COMMENT 01B

Questions and request for comments 

1) How should Table 11.1 be interpreted or clarified to ensure that relevant 

test procedures are applied to EPCA-covered products? Does the 

corresponding table in the proposed ASHRAE 90.1 provide a clearer 

representation? 

2) Should equipment that can be used alternatively for either space heating 

or domestic hot water be defined as a boiler or as a water heater for test 

procedure purposes? 

10:45 - 11:00 Break 

11:00 - 12:00 Unfired storage tanks 

EPCA exempts certain unfired storage tanks and storage water heaters 

based on tank volume, thermal insulation value and use of a standing pilot 

light, and it establishes a maximum heat loss of 6. 5 Btu/hr/ft2 for nonexempt unfired storage tanks. ASHRAE 90.1 currently references no 

procedure for determining either the insulation value or the heat loss. 

Questions and request for comments 

1) How should the insulation value be determined? 

2) What procedure should be employed to measure the heat loss? 

12:00 - 12:30 Other issues raised by participants 

12:30 - 1 :30 Lunch (on your own) 

Test Protocols for commercial boilers and furnaces 

1 :30 -:- 2:00 DO~ introduction and NIST overview 

2:00 - 2:30 Defioitron of "packaged" boiler 

EPCA defines generally what is meant by "packaged boiler," but it does 

not specifY an upper limit on boiler rated capacity for coverage under the 

statute. The Hydronics Institute and Underwriters Laboratories both have 

different definitions with similar meanings. 

Questions and request for comments 

1) Does the definition of "packaged boiler" need clarification? 

2) Does the definition of "commercial packaged boiler" imply an upper 

capacity limit, and if so, is it the same for steam and hot water boilers? 

2:30 - 3:00 Thermal vs. combustion efficiency; jacket losses 

Boilers and furnaces can be rated either in terms of combustion efficiency, 

based on a measure of flue loss, or in terms of thermal efficiency, based on 

an input-output method that accounts for jacket losses. 
EE-TP-98-101 COMMENT 01B

Questions and request for comments 

1) Since EPCA calls for combustion efficiency, and outdoor boilers are 

now rated in terms of thermal efficiency, should a combustion efficiency be 

calculated for outdoor boilers, with a jacket loss measurement, to satisfy 

EPCA? 

2) If jacket losses are to be measured, what method is appropriate, e.g., 

ANSI Z21.4.7 or ASME PTC 4.1? 

3) Should DOE adopt default jacket losses from ASME PTC 4.1 in lieu of. . 

actual tests or allow it as an option? 

4) Should parasitic electric consumption be considered as an energy input 

in calculating efficiencies? 

3:00 - 3: 15 Break 

3: 15 - 3 :45 Uniformity of test conditions, procedures and setup requirements 

ASHRAE 90.1-1989 references several industrial test standards with 

different testing requirements, and ASHRAE 90.1 R references yet another 

set of standards. 

Questions and request for comments 

1) Since UL-727 does not specify a method for calculating flue losses in 

oil-fired furnaces, should DOE adopt the method in HI-1989 for this 

purpose? 

2) Insulation of the vent pipe and elbow are not required in the referenced 

standard for furnaces. Does this introduce a serious inaccuracy in the 

measurement of flue gas temperature? 

3) Should DOE allow a thermocouple grid as an optional alternative to a 

single thermocouple traversing nine sample points, as specified in the 

referenced standard for measuring flue gas temperature in furnaces? 

3:45 - 4: 15 Provisions for unusual design features 

Some boilers and furnaces are designed for unique applications or have 

features that do not lend themselves perfectly to referenced test 

procedures. 

Questions and request for comments 

1) Should DOE specify two boiler rating conditions, one for high 

temperature (steam and hot water) and another for low temperature water? 

2) Should condensing boilers and furnaces be considered? If so, should 

condensate be measured according to ASHRAE 103-1993? 
EE-TP-98-101 COMMENT 01B

3) Should DOE's procedure specify tests at both maximum and minimum 

rated input for modulating boilers and furnaces? 

4) If modular boiler systems are sold as a package, should the individual 

boilers be tested, or the installation as a whole? 

5) Should a steamlhot water boiler be tested on both steam and hot water, 

or on steam only? 

4: 15 - 4:45 Other issues raised by participants 

Wednesday, April 15, 1998 

Test protocols for commercial air conditioners and heat pumps 

9:00 - 9: 15 DOE introduction and NIST overview 

9: 15 - 9:45 External static pressure requirements 

Critics have observed that ARI Standard 210/240 calls for external static 

pressures under test conditions that are lower than generally encountered in 

commercial buildings, potentially leading to an overstated efficiency rating. 

Others counter that the present procedure is adequate for purposes of 

comparing products relative to one another, and a change would be 

unnecessarily burdensome. 

Questions and request for comments 

1) Does the present ARI procedure introduce an error, and if so, is it 

significant? 

2) If so, what is the appropriate external static pressure? 

J) ~ow burdensome would a change in the specification be? 

9:45 10: 15 Other issues raised by participants 

10: 15 - 10:30 Break 

Sampling, certification and enforcement 

10:30 10:50 DOE introduction and NIST overview 

. 10:50 - 11 :30 Statistical sampling 

DOE is seeking to establish sampling regimes for certification and 

enforcement that strike an appropriate balance between cost and reliability 

of efficiency determination. 

Questions and request for comments 

1) What is the appropriate sample size for each product to be tested? 
EE-TP-98-101 COMMENT 01B

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2) How should sample units be selected? 

3) Where should testing be performed and by whom? 

4) How should compliance be determined from test results, e.g. by 

employing arithmetic averaging or statistical confidence intervals? 

5) Should derating or other special adjustment factors be used? 

6) Should the scheme applied in enforcement differ from that used for 

certification? 

11:30 - 12: 10 Sampling limited populations 

Many products to be covered by the test procedure are produced in limited 

numbers, either because of their large size or because of the number of 

variations in design demanded by their purchasers. This complicates the 

determination of statistical sampling plans due to concerns of cost and 

testing burden. 

Questions and request for comments 

1) Are special provisions needed for very large capacity, site-assembled, or 

low production quantity units? 

2) Can products be grouped as minor variations on a more limited number 

of basic models? If so, how many models need to be tested, and what is the 

best way to extrapolate the results to other products within a group? Is 

simulation testing a valid approach? Should limitations be placed on its 

use? 

3) What relevant experience do other organizations, like the Gas Appliance 

Manufacturers Association, Air-Conditioning and Refrigeration Institute, 

Amencan·Boiler Manufacturers Association, or the California Energy 

Commission, have to address this problem? 

12: 10- 12:30 Other issues raised by participants 

12:30 - 1 :30 Lunch (on your own) 

Labeling 
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1 :30 - 1:45 DOE introd.uction and overview 

1:45 - 2: 10 Justification for labeling 

Before requiring a label, DOE must first determine that such a requirement 

would be technically feasible and economically justified, that significant 

energy savings would result, and that labeling would be likely to assist 

consumers in making purchasing decisions. 

Questions and request for comments 

1) would labels be technically feasible and economically justified for all 

. classes of equipment discussed at this workshop? 

2) What energy savings, ifany, would result if labels were required? 

3) Would labels assist consumers in making purchasing decisions? 

2: 10 - 2:35 Label location and content 

Under EPCA, the Secretary of Energy has some latitude in specifying 

information that will appear on permanent nameplates or on labels . 

permanently affixed to tested products. DOE seeks suggestions concerning 

the location of labels, the appropriate level of detail for informat.ion that 

might appear on them, as well as the potential burden imposed on 

manufacturers by requiring alternative labeling schemes. 

Questions and request for comments 

1) What information should appear on the manufacturer's nameplate, and 

what should appear on a separate label? Is the answer the same for all 

equipment classes? 

2) Should DOE consider including any additional data beyond the 

efficiency rating for purposes of enforcement of standards. These might 

. include a compliance certification number or message, reference to the test 

prqcedure, operating conditions under which the efficiency rating applies, 

com~arative efficiency ranking within a class of products, or other 

consumer information. 

3) How should DOE account for special purpose labels that may be 

required under ASHRAE 90.1R, e.g., labels indicating that certain package 

terminal air conditioners and heat pumps are restricted to replacement 

installation only? 

2:35 - 3:00 Labeling mixed component systems 

Some systems covered by these test procedures are made up of separate 

components, often furnished by different manufacturers, raising questions 

of how these products should be labeled and by whom. 

Questions and request for comments 

1) Should component manufacturers or system integrators be responsible 

for affixing labels? 
EE-TP-98-101 COMMENT 01B

2) If manufacturers are responsible for labeling, is there a way for them to 

account for the fact that they do not control how the balance of the system 

is designed? 

3) If system integrators are responsible, is there a way for them to make 

custom labels corresponding to the different combinations of components 

they might specify? 

3 :00 - 3: 15 Other issues raised by participants 

3:15 - 3:30 . Next steps and closing remarks 

3:30 Adjournment