1 [6450-01-P]
DEPARTMENT OF ENERGY
10 CFR Part 431 [Docket No. EERE- 2008-BT-TP-0014]
RIN: 1904-AB85

Energy Conservation Program: Test Proce dures 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 estab lish 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. Thos e proposed rulemakings serve as the basis for today’s action. DOE is issuing a final rule that es tablishes 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 pro cedures will be mandatory for product testing to demonstrate compliance with energy standards th at DOE is establishing in a separate, but2 concurrent rulemaking, and for re presentations starting 180 days af ter 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 consum ption or performance characteristics of certain components of walk-in coolers and walk-in freezer s. Additionally, the final rule clarifies the definitions of “Display door,” “Display pane l,” “Door,” “Envelope,” “K-factor,” “Panel,” “Refrigerated,” “Refrigeration system,” “U-factor,” “Automa tic door opener/closer,” “Core region,” “Edge region,” “Surface area,” “Rating co ndition,” and Percent time off” as applicable to walk-in coolers and walk-in freezers.

DATES: The effective date of this rule is [INSERT DATE 30 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER]

. The final rule changes will be mandatory for product testing starting [INSERT DATE 180 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER]

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The incorporation by reference of certain publica tions listed in this ru le was approved by the Director of the Federal Register on [INSERT DATE 30 DAYS AFTER DATE OF PUBLICATION IN FEDERAL REGISTER]

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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 email at Brenda_Edwards@ee.doe.gov , for additional information regarding visiting the Resource Room.3 Docket: The docket is available for review at regulations.gov, including Federal Register notices, framework documents, public meeting at tendee 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: 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. De partment of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Pr ogram, EE-2J, 1000 Independence Avenue, SW., Washington, DC, 20585-0121. Tele phone: (202) 586-2192. E-mail: Charles.Llenza@ee.doe.gov

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Mr. Michael Kido, U.S. Department of Ener gy, Office of the General Counsel, GC-71, 1000 Independence Avenue, SW., Washingt on, DC, 20585-0121. Telepho ne: (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 Independen ce Avenue, SW., Washington, DC, 20585-0121. Telephone: (202) 586 -7796. E-mail: Elizabeth.Kohl@hq.doe.gov4 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 Te st 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 (X PS)—Specification,” a pproved February 2009.

(4) DIN EN 13165:2009-02, “Thermal insulation products for buildings—Factory made rigid polyurethane foam (PUR) products—Specification,” a pproved February 2009.

(5) NFRC 100-2010[E0A1], “Procedure for Deter mining 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 www.astm.org

.5 Copies of AHRI standards can be obtained from AHRI

. Air-Conditioning, Heating and Refrigeration Institute, 2111 Wilson Boul evard, Suite 500, Arlington, VA 22201, (703) 600- 0366, or www.ahrinet.org

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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 www.cen.eu
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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 www.nfrc.org

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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 Model6 B. Test Procedures fo r 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 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 Pape rwork Reduction Act of 1995 D. Review Under the National E nvironmental Policy Act of 1969 E. Review Under Executive Order 131327 F. Review Under Executive Order 12988 G. Review Under the Unfunde d Mandates Reform Act of 1995 H. Review Under the Treasury and Gene ral Government Appr opriations Act, 1999 I. Review Under Executive Order 12630 J. Review Under Treasury and Genera l Government Appropriations Act, 2001 K. Review Under Executive Order 13211 L. Review Under Section 32 of the Fe deral 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 Cons ervation 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), Pub. L. 110-1 40 (Dec. 19, 2007)). Part C of Title III (42 U.S.C. 6311–6317), which was subsequently redesign ated as Part A-1 for editorial reasons, establishes an energy conservation program for ce rtain industrial equipment. This includes walkin 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 consis ts essentially of three parts: (1) testing, (2) labeling, and (3) Federal energy conservation standards. The te sting requirements consis t of test procedures that manufacturers of covered pr oducts or equipment must use (1) as the basis for certifying8 compliance with the applicable energy conserva tion 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 pr oducts comply with any relevant standards promulgated under EPCA.

Section 312 of the Energy Independen ce and Security Act of 2007 (“EISA 2007”) amended EPCA by adding certain equipment to this energy conservation program, including walk-in coolers and walk-in fr eezers (collectively “walk-in equipment,” “walk-ins,” or “WICF.”). (42 U.S.C 6311(1), (20), 6313(f), a nd 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 di rects DOE to publish performance-based standards and promulgate labeling re quirements (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 pub lished January 4, 2010 (January 2010 NOPR or, in context, NOPR), DOE proposed to establish test procedures to measure the energy efficiency of walk-in coolers and freezers. 75 FR 186. DOE id entified 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 pr oposed definition of a walk-in cool er or freezer with regards to the upper temperature limit; (2) the proposal to cr eate test procedures for the envelope and refrigeration system of a walk-in cooler or freez er; (3) the proposal to group walk-in envelopes and refrigeration systems with essentially identical constr uction methods, materials, and components into a single basic model; and (4) the proposed calculation methodology for9 determining the energy consumption of units w ithin the same basic model. 75 FR 186, (Jan. 4, 2010). On March 1, 2010, DOE held a public me eting to receive comments, data, and information on the January 2010 NOPR. Through th eir comments, interest ed parties raised significant issues and suggested changes to the proposed test procedures. DOE determined that some of these comments warranted further cons ideration and published a supplemental notice of proposed rulemaking on September 9, 2010 (Septe mber 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 th e January 2010 NOPR that were not addressed in the September 2010 SNOPR and comments received on the September 2010 SNOPR.

General Test Procedur e 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. EP CA provides that test procedures “shall be reasonably designed to produ ce 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, th e statute provides that DOE “shall provide10 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 com ponent-based approach detailed in EISA 2007. The separate but concurrent energy conservati on 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. Th e 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 walk-in coolers and walk-in freezers is simpler and less burdensome to manufacturers than testing an entir e 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 re sults of the component tests.

The test procedure incorporates by refere nce the industry test procedures ASTM C1363- 05, “Standard Test Method for Thermal Perform ance of Building Materials and Envelope Assemblies by Means of a Hot Box Appara tus,” DIN EN 13164:2009-02, “Thermal insulation11 products for buildings— Factory made produ cts of extruded polystyrene foam (XPS)— Specification,” DIN EN 13165:2009-02, “Thermal in sulation products for buildings— Factory made rigid polyurethane foam (PUR) pr oducts—Specification,” NFRC 100-2010[E0A1], “Procedure for Determining Fenestration Pr oduct U-factors,” and AHRI 1250 (I-P)-2009, “2009 Standard for Performance Rating of Walk-In Coolers and Freezers.”

Concurrently, DOE is undertaking an ener gy 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 te st procedure in the concurrent process of evaluating potential performance standards for the equipment. After the compliance date of the performance standards, this walk-i n 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, on ce any final test procedure is effective, any representation of the energy use of walk-in equi pment or components must reflect the results of testing that equipment using the test procedure.

III. Discussion

In this section, DOE describes the overall appr oach it followed in developing today’s test procedure for walk-in cooler and freezer e quipment, including envelope components and refrigeration systems. The following section also a ddresses issues raised by interested parties, which consisted of the following entities:12 • Manufacturers: American Panel, Craig Indus tries, CrownTonka, He atcraft Refrigeration Products (Heatcraft), Hill Phoenix, Interna tional 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 fo r 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 Aware ness Project (ASAP), Alliance to Save Energy (ASE), American Council for an Energy-Efficient Economy (ACEEE), Natural Resources Defense Council (NRDC), Northeast Energy Efficien cy 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 i ndicated that a single test procedure for the entire WICF would not be practical because many walk-ins are assembled on site with13 components from different manufacturers, which would make on-site te sting infeasible. DOE then proposed in the January 2010 NOPR and Sept ember 2010 SNOPR to deve lop 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 envelo pe, which would be an energy use metric. The envelope metric would a ccount for electrical use of envelope components, as well as any energy used by the refrigeration system to reject th e heat contributed by conduction, inf iltration, 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 a nd doors of envelopes and unit coolers and condensing units of refrigeration systems. Comme nters explained that all of these components could be produced by separate manufacturers and then assemb led 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 determin e who would be best positioned to ensure the walk-in cooler or fr eezer complied with an energy conservation standard. DOE acknowledges these and simila r concerns from the stakeholders.

Based on the information provided by co mmenters and DOE’s own research, DOE has determined that a component-based approach would address the unique challenges posed in14 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 component -based approach would not only help ensure compliance with whatever energy conservation standards that DOE sets, but also reduce the overall testing burden on the manufact urers, including small businesses who are involved in producing walk-in units, either in full or in part.

Moreover, DOE notes that the adoption of su ch an approach is consistent with the component-based approach that Congress t ook when it enacted EISA 2007. Thus, DOE is adopting a component-level approach for this rule and discusses the spec ific component metrics in greater detail in section III.A.1.

1. Test Metrics As stated previously, DOE initially proposed separate test procedur es 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 el ectrical use of envelope components and the energy used by the refrigeration system to reje ct 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 shoul d be a normalized energy use metric—the total energy use divided by the external surface area of the envelope (energy use per square foot).15 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 th erefore such estimates would be misleading for almost all installed systems. N EEA 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 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 metr ic because of the number of assumptions that would be required and the poten tial to confuse customers. (N RDC, 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 sugges ted that the envelope metric should be a Ufactor (which is a characterization of the h eat 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 conductan ce 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) syst em. (NRDC, No. 0064.1 at p. 8) A comment submitted jointly by ACEEE, ASAP, ASE, NR DC, NEEP, and NEEA on the September 2010 SNOPR (hereafter referred to as The Joint SNOPR comment) stated that the energy conservation16 standard for envelopes should be the overall heat gain (U-overall) with separate standards for walk-in coolers and walk-in freezers. (J oint SNOPR Comment, No. 0074.1 at p. 2)

While other interested par ties suggested specific metrics for walk-in components, manufacturers also offered suggestions for overall walk-in metrics. Craig Industries recommended combining the envelope and refrige ration calculations to calculate the overall efficiency of the complete walk-in system and labeling each walk-in 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 in side the walk-in. (Zero Zone, No. 0077.1 at p. 1)

In view of the component-level approach be ing adopted today, DOE is not establishing an overall energy use metric for the envelope in th is test procedure. Instead, DOE is establishing separate metrics for the indi vidual components of the walk-i n: the wall and ceiling panels (hereafter referred to as non-floor panels), fl oor 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 eval uating a walk-in unit’s efficiency, DOE does not believe that such a requirement is necessary in light of the component-based 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 therma l transmittance) measured in Btu/ h-ft 2

- o F, as NEEA, the Joint SNOPR Comment, and the Joint Utilities recommended. The metric for display and nondisplay doors accounts for the thermal transmittance through the door and the electricity use of17 any electrical components a ssociated 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 chan ge 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 Septembe r 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 regardin g who should assume te sting, certification, and compliance responsibilities. The Joint S NOPR 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. (Joi nt SNOPR Comment, No. 0074.1 at p. 1) The Joint SNOPR Comment further suggested th at panel, refrigeration system, and door manufacturers each be responsible for complianc e 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 regulato ry framework proposed by NEEA, in which envelope, door, and refrigeration manufacturers would be responsib le for testing and complying with the standards for the components they manufacture. (Thermo-Kool, No. 0072.1 at p. 1)18 DOE received several other comments wh ich 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 indivi dual component manufacturers should test, certify, and ensure compliance of their respec tive components. Other commenters recommended that the manufacturer, the assembler, or the syst em designer of the overall walk-in should be responsible for the compliance of the wa lk-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 as follows: Manufacturer of a walk-in cooler or walk-in freezer means any person who: (1) Manufactures a component of a walk-in cooler or walk-in freezer that affects energy consumption, including, but not limited to, refrige ration, doors, lights, windows, or walls;

or (2) Manufactures or assembles the complete walk-in cooler or walk-in freezer
76 FR 12504.

The definition extends the compliance res ponsibility 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 walk-in applications and ensuring compliance with the ap plicable Federal standard s 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 enforcement19 framework in which it will dete rmine who is responsible for noncompliance on a case-by-case basis. 76 FR 12444.

DOE notes that the provisions and clarificati ons 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 a nd performance-based standards for walk-in coolers and freezers. DOE believes that, within the very limited context of walk in equipment, EPCA created a means for DOE to set performance-bas ed standards for certain walk-in component manufacturers. In particular, because Congress se t requirements for specific components used in walk-in applications, it provided DOE with the implicit authority to set performance-based standards at the component level for these speci fic components. This unique ability stems from the manner in which Congress set standards for wa lk-in equipment by prescribing, among 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 a nd easily tested and certified by component manufacturers, DOE intends to ta ke this approach for WICF te st procedures and performance standards. DOE acknowledges the numerous diff iculties that commenter s have noted with alternative proposed approaches. By requiring individual component manufacturers to certify that their components satisfy specified performan ce-based standards, DOE can ease the overall20 burden on walk-in manufacturers rela tive 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 manuf acturers 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 certif y equipment to DOE (although they must use this test procedure in making repres entations 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 complianc e with them using the method specified in the CCE final rule. 76 FR 12422.

3. Basic Model DOE proposed a definition of basic model fo r 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 compone nt-level approach to certification, discussed in section III.A.2, and taking the comments from interested parties in to consideration, DOE decided to define a basic model for each of the ke y components of a walk-in, rather than defining a basic model for the entire walk-in. DOE emphasi zed 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 is21 essentially the same with respect to energy consumption, efficiency, or other measure of performance. 76 FR 12444-12446.

DOE provided, in relevant part, the following definition of basic model in the CCE final rule: Basic model means all components of a given ty pe of walk-in cooler or walk-in freezer (or class thereof) manufactured by one manufa cturer, having the same primary energy source, and which have essentially identi cal electrical, physical, and functional (or hydraulic) characteristics that affect ener gy consumption, energy efficiency, water consumption, or water efficiency; and (1) with respect to panels, which do not have any differing features or characteristics that affect U-factor.
* * * 76 FR 12504 (providing definition of “basic m odel” for walk-ins) (to be codified at 10 CFR § 431.302).

DOE believes applying the basic model con cept 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 al so rate models conservatively – i.e. the tested performance22 of the model(s) must be at least as good as th e 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 com ponents that are not doors and that are used to construct the envelope of the walk-in. These components comp rise the elements separating the interior refrigerated environment of the walk-in from the ex terior environment. In this test procedure, panels are classified as either floor panels, non-floor panels, or di splay 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 ar e 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 conductiv e, 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 mate rial (e.g. glass), and pa nel thickness. See section III.B.2 for details on how the U-factor is dete rmined. DOE considers a panel basic model to include panels which do not have any differing feat ures or characteristics that affect the U-factor.
76 FR 12504.

DOE notes that manufacturers who make cu stomized panels may experience a higher certification burden than manufact urers of standardized panels. For example, under today’s procedure, a panel’s U-factor is a surface area-i ndependent metric, which implies that variation23 in panel width and height alone w ould 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, sm aller floor and non-floor panels may have a higher propor tion of framing material to non-framing material, or other structural members, which could affect the overa ll panel U-factor rating if the framing material or framing geometry has different thermal c onductivity performance than the neighboring insulation. Therefore, for two or more floor or non -floor panels that are eq uivalent in materials and other characteristics but differ in their fram e to insulation proportions such that they have different U-factor ratings, the panels would be co nsidered 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 ex plained 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 non-floor pa nel 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 re quiring the U-factor of display panels to be tested using NFRC 100-2010[E0A1 ], “Procedure for Determining Fenestration Product U-factors,” which DOE proposed in the S NOPR for measuring the U-factor of doors and windows, including their framing materials. 75 FR 55083. (Sept. 9, 2010) As with floor and non-24 floor panels, the basic model c oncept 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 pane l manufacturers. Also, NFRC 100-2010[E0A1] allows verified computer models to simulate a display panel’s energy consumpti on, another factor that reduces the manufacturer’s testing burden.

b. Basic Model of Doors A door is an assembly installe d 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 c oolers and walk-in freezers, a door includes the door panel, glass, fra ming materials, door plug, mullion, and any other elements that form the door or part of its connection to the wall. This test procedure defines tw o types of doors, display and non-display doors. Display doors are doors desi gned for product movement, display, or both, rather than the passage of pers ons, and non-display doors are consider ed to be all other types of doors. For all doors, the energy consumption me tric that DOE is adopting in today’s rule incorporates the U-factor and any electrical components built in to the door. (See section I.A.1.a for details.) Calculatin g this metric requires the use of NFRC 100-2010[E0A1], “Procedure for Determining Fenestration Pr oduct 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) 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.25 As with panels, doors with essentially identical energy consumption levels may be grouped into a basic model and rated conserva tively. 76 FR 12429 and 12504. The basic model concept can be used to reduce the testing and ce rtification burdens by allowing manufacturers to group doors that are essentially identical in ener gy 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 cal culations would need to be run by an NFRCapproved 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 primari ly of a compressor, condenser, unit cooler, valves, and piping. It is considered a com ponent under the component level approach (see section III.A) that DOE is adopting in today’s final rule. As with th e 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 th eir discretion to the extent the models have essentially identical electrical, physical, and functional characteristics that affect energy efficiency or energy consump tion. Furthermore, manufacturers ma y rate models conservatively, meaning the tested performance of the model(s) mu st be at least as good as the certified rating, after applying the appropriate sampling pla n. 76 FR 12429. DOE believes these provisions will reduce the burden of testing for refrigeration manufacturers, including those who make26 customized equipment. DOE may also consider methods which allow manufacturers to use an alternate method of determining the energy us e of the refrigeration system in a future rulemaking. This concept is furthe r discussed in section III.C.3.

B. Test Procedures for Envelope Components

The envelope consists of the insulated box in which items ar e stored and refrigerated. In the NOPR and SNOPR, DOE proposed methods fo r evaluating the performance characteristics of insulation, testing thermal energy gains rela ted to air infiltration, and determining direct electricity use and h eat gain due to internal electrical co mponents. The proposed procedure used these methods to determine the energy use associat ed with the envelope by calculating the effect of the envelope’s characteristic s and components on the energy c onsumption of the walk-in as a whole. Those characteristics and components in cluded the energy consumption of electrical components present in the envelope (such as ligh ts) and variation in the energy consumption of the refrigeration system due to heat loads in troduced 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” refrige ration 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 lo nger 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 section27 III.A.1. In doing so, DOE is requiring manufacture rs to use the same physical tests for the components that it proposed in the NOPR and S NOPR, but is introducing revisions to the calculations in Appendix A of the new procedure. These revisions will enable manufacturers to calculate the required com ponent metrics from the resu lts 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 ar e panels that are primar ily made of transparent material and used for display purposes. Displa y 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 U-factors,” which DOE propos ed in the SNOPR for m easuring the U-factor of doors and windows, including their framing materials. 75 FR 55083. (Sept. 9, 2010) Nondisplay panels are floor and non-floor panels. Si nce both floor and non-floor panels are typically made out of a composite of insu lation, 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 product s of extruded polystyrene foam (XPS)— Specification” or DIN EN 13165:2009-02, “Thermal insulation products for buildings—Factory made rigid polyurethane foam (PUR) products—Sp ecification,” as applicab le. These tests were proposed in the SNOPR. 75 FR 55068, 55075-55076 and 55081 (Sept. 9, 2010). In this final rule,28 panel performance is denoted by its overall U-factor, or thermal transmittance, which is determined by the test proce dures and calculation methodologie s described in section III.B.2.

DOE is requiring one test for door pe rformance, NFRC 100-2010[E0A1], “Procedure for Determining Fenestration Produc t U-factors,” which was proposed in the SNOPR. 75 FR 55083 (Sept. 9, 2010). This test measures conduction th rough 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 sec tion 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 theo retical refrigeration syst em to reject a given amount of heat is represented by the energy e fficiency ratio (EER) of the refrigeration system. The test procedure uses the same nominal refrige ration system EER for all tested doors to enable direct comparisons of the performance of walk-i n 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 en velope. See 75 FR 55013 (Sept. 9, 2010).

1. Definition of Envelope In the January 2010 NOPR, DOE proposed th e following definition of “envelope:”

Envelope means (1) a piece of equipment that is the portion of a walk-in cooler or walk-29 in freezer that isolates the interior, refrigerated environment from the ambient, external environment; and (2) all energy-consuming com ponents 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 in clude, but not be limited to, walls, floors, ceilings, seals, windows, doors, or any combinatio n 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, AC EEE, 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, Nor-Lake 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 perfor mance 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 alternativ e 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 Nationa l Sanitation Foundation) definition of envelope and require ments. (ICS, Public Meeting Transcript, 0016 at p. 30) (In this30 and subsequent citations, “Public Meeting Transcript” refers to the transcript of the March 1, 2010, public meeting on the proposed test procedur es for walk-in coolers and freezers. “No. 0016” refers to the document number of the transc ript in the Docket for the DOE rulemaking on test procedures for walk-in coolers and freez ers, 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, be cause DOE is taking a component-based approach, the proposed envelope de finition is no longer applicable for the purpose of this test procedure. As suggested by ICS, when evalua ting potential standards applicable to walk-ins, DOE will also consider their rela ted 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 implement ation of the component; rather, the manufacturer would be responsible only for the component’s compliance as designed. Also, the envelope assembler is responsible for us ing WICF-compliant components to assemble the total envelope.

2. Heat Transfer through Panels

a. U-Factor of Composite Panels Includi ng Structural Members of Panels EPCA specifies that ASTM C518-04, “Standard Test Met hod 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. Th e statute defines the R-value as equal to the31 value of 1/K-factor multiplied by the thickn ess 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 Te st 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 assemble d 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; Mast er-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, disagr eed 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 e limination 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 explai ned 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 C518-32 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 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 R-value and structural Rvalue based on the percentage each material re presents 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 appropr iate 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 th rough panels. (American Pa nel, 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 c onduction through structural members may not take the reduction of joints (tha t is, panel to panel in terfacing 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) Thermo-Kool, on the other hand, disagreed with the approach of using R-value testing of different components of the co mposite panel to determine h eat loss. (Thermo-Kool, No. 0072.1 at p. 1) Bally, who agreed with DOE’s proposed approach, requested clarification specifically33 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 “i nsulation” 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 pot ential elimination of stru ctural 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 R-value 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, w ill 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 struct ural members, may be used to meet an energy conservation standard for panels, which will be determined in a parallel ru lemaking. Including ASTM C1363- 05 will provide a more accurate means to represent the overall heat transfer performance of panels. DOE believes this pro cedure 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.34 Additionally, while DOE acknowledges the con cerns 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 U-factor of the panel. DOE is including this protocol as part of the test procedure be cause heat conduction through structural members is a significant panel characteristic that is not addressed under the statutorily-prescribed testing requirements (i.e. ASTM C518-04). While AS TM 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 co stly because of the many materials that could comprise a panel and the need to test each materi al 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 R-va lue complicated and burdensome.

DOE also acknowledges Craig Industri es’ concern that ASTM C1363-05 does not account for the reduction of joints (that is, pane l to panel interfacing members). Since DOE is adopting an approach to ensure the energy effici ency performance of particular components, an approach suggested by numerous commenters, and is no longer considering the effects of infiltration, panel joint issues ar e outside of this approach.

DOE notes that American Panel supported the inclusion of structural members in calculating the overall U-factor. Furthermore, DOE would like to clarify the calculation methodology to address the comment from Ball y. Today’s final rule adopts a weighted percentage of the panel edge (which may cont ain structural members) and panel core region (which may also include structural members) in order to calculate the panel’s total U-factor.35 DOE believes that using the weighted percentage of edge U-factor and core U-factor to calculate the total U-factor will help reduce the manufacturer’s testing burden.

In applying this weighted percentage approa ch, 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 U-factor. The manufacturer must then calculate the overall U-fact or of other floor or non- floor panels with the same panel thickness, cons truction methods, and mate rials using the U-factor results for the core and edge region “test panels.” For example, a manu facturer tests a 4 ft. by 8 ft. test panel and finds the edge region and core region U-factors. The same manufacturer also produces 6 ft. by 8 ft. panels that have identical core and edge re gion 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 cer tified 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 websites and submitted comments, most manufacturers use the same panel thickness, materials, and constructi on 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 material36 (that is, the foam) must meet the prescrib ed R-value. (42 U.S.C. 6313(f)(1)(C)) The test procedure is prescribing ASTM C1363-05 as a met hod of measuring the overall U-factor of the entire panel. For EPCA compliance, the R-value of the insulation must be separately determined in accordance with ASTM C518-04 as speci fied in EPCA. (42 U.S.C. 6313(f)(1)(C))

Finally, interested parties suggested ch anges to the test methodology DOE proposed. NRDC stated that irregular ornon-homogeneous foam products should be tested for actual Rvalue where there is no quality control to maintain the orientation of the foam in the finished product. To clarify, DOE believes that when NR DC noted the concern a bout 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 s imilar to the grains in wood. Like wood, depending on how the buns are cut into boards, the orientatio n of the cell “grains” may vary by finished board. NRDC continued to suggest that if a fo am product cannot be tested, then the stated Rvalue should be a conservative number representin g 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 manuf acturers to specially construct units for testing, because specially constructed units may not re present 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 proc edures for certification will accurately capture37 the foam’s R-value. A sampling plan is intended to ensure accurate and statistically repeatable results are achieved when using the test procedur e. DOE notes NRDC’s con cern that specifically constructed units may not represen t an actual product. However, in order to reduce the testing burden presented by ASTM C1365-05, DOE is mainta ining 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 measur es the U-factor of the core area of the panel (the “Panel Core”) which may also contain structural members. The U-factor 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 re presentative 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 agre es 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 AS TM 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 th e standard size of a test panel for ASTM C1363-05 to be 8 ft x 4 ft +/- 1 ft.38 b. Long-Term Thermal Resistance In the January 2010 NOPR and September 2010 SNOPR, DOE cited several studies that conclude that lateral gas diffu sion, which causes a reduction in R- value, occurs in impermeably faced foams. See 75 FR 192-194 and 75 FR 5507 5-55079. 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 diffu sion continues. To account for this aging effect on a foam’s insulation performance -- and, by extension, the en ergy 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 manuf acturing 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 us e 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 th is equipment’s lifetime. Research on panel aging has shown that a 5-year aged R-value found by LT TR testing is represen tative of the panel’s insulation performance over its lifetime, and there are industry tests for walk-in foam that estimate the aged R-value over time. Using thes e industry-developed protocols will enable manufacturers to more accurately capture the lifetime performance of a walk-in panel.39 Incorporating a long term thermal resistance degradation factor improves the reliability of test results for walk-in panels. While EPCA c ontains 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, a nd test facility availability. Changing any one of these variables could result in significantly different test results and measured R-values. This is in contrast to mo st other types of equipment within the appliance standards program, which would not exhibit sign ificant 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 walk-in 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 perfo rmance 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 Resist ance of Closed-Cell Foam Insulation,” to calculate the long-term thermal resistance (L TTR) of walk-in foam insulation. 75 FR 186,
193

− 94 (Jan. 4, 2010). In the September 2010 SN OPR, DOE proposed to use the updated version of ASTM C1303-08, which was AS TM C1303-10. 75 FR 55068, 55075 (Sept. 9, 2010). In that notice, DOE also offered an altern ative method, Annex C of either DIN EN 13164:2009-40 02, “Thermal insulation products for buildings— F actory made products of extruded polystyrene foam (XPS)—Specification” or DIN EN 13165: 2009-02, “Thermal insulation products for buildings—Factory made rigid polyurethan e foam (PUR) products —Specification,” as applicable, to test for the LTTR. This alternativ e was offered in response to concerns raised in response to the NOPR. The SNOP R requested comments on both of these alternative methods. 75 FR 55079 (Sept. 9, 2010).

In light of the comments that DOE receive d on all of these various testing methods, which are addressed below, DOE has decide d to adopt DIN EN 13165:2009-02 or DIN EN 13164:2009-02, as applicable, as the test proce dure 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 Ufactor 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 becaus e 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 sugg ested 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 Manufact urers recommended that structural members41 be considered in the long-term thermal resistan ce 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 inclus ion 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 walk-in 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 met hod. Bally stated that more data from act ual walk-in panels with intact metal skins and sealed edges should be collected befo re 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 da ta 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 Septem ber 2010 SNOPR, that conclude that aging42 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 cons idered 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 unde rgo 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, “I ndustrial Experiences with CO 2 Blown Polyurethane Foams in the Manufacture of Me tal Faced Sandwich Pane ls”) 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 CO 2 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 deteriorati on of LTTR values is insignificant, the lack of customer complaints may be influenced by a vari ety of factors. For example, a panel is normally43 only replaced when visibly damaged. However, a panel may have reduced thermal performance without any accompanying visual cues suggesti ng problems with the panel. Accordingly, DOE does not believe that the statem ents and materials cited by Am erican Panel support the premise that LTTR of foam is negligible for walk-in panels.

Interested parties also made comments on th e specific test methods that DOE proposed. DOE received some comments from interested pa rties 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 pr esent 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 th e 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 di sapproved of ASTM C1303-10. Amer ican 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 Manufact urers, No. 0062.1 at p. 1) American Panel asserted that any testing to determine R-value must allow the foamed-in-place polyurethane to44 remain encapsulated by the metal facers to resemb le the real-world applic ation. (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 Phoeni x also suggested that ASTM C1303-10 would significantly overestimate foam aging of foam ed-in-place polyurethane panels. (Hill Phoenix, No. 0063.1 at p. 2) The Joint Manufacturers oppose d the use of ASTM C1303-10 for measuring long-term R-value decline because it is not in tended 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) Owen s Corning stated that the prescriptive and research methods of ASTM C1303-10 are not co mparable and will not generate comparable results. It added that the Canadian test pr ocedure CAN/ULC S770, which is based on various versions of ASTM C1303, has a positive bias and may over-predict 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 th e use of ASTM C1303-10 for LTTR testing and suggested possible alternatives. Carpenter su ggested 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 w ould underestimate the LTTR of impermeably faced panels and that LTTR tests should be perfo rmed on samples with intact facers. (Carpenter, No. 0067.1 at p. 2) Similarly, Master-Bilt explai ned that panel edges are not 100 percent45 exposed, but are tight against one another and sealed with caulk a nd vinyl gaskets. Collectively, the caulk and gaskets significantly reduce gas mi gration, thus reducing the effects of aging. Therefore, in its view, the testing of skinned panels with exposed edges still considerably overstates the insulation degrada tion. Master-Bilt suggested that a formula based on test data from actual walk-in panels that have been inst alled could be used instead of ASTM C1303-10. (Master-Bilt, No. 0068.1 at p.2)

DOE agrees with the assessment that AS TM C1303-10 is not adequate for testing impermeably faced foams. DOE believes that th e 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, re duce 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 Otte ns study, in which an experiment was completed on polyurethane foamed-in-place panels to assess their long-term insulating behavior. 75 FR 55068, 55077 (Sept. 9, 2010). (Ottens et al., “Industrial Experiences with CO 2 Blown Polyurethane Foams in the Manufacture of Meta l Faced Sandwich Panels,” Polyurethane World., 1997.) In the SNOPR, DOE estimated that the test wa s likely representative of panels aged for at46 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 correla ted to a particular ag ing 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 te st 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 polys tyrene 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 b een 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 representa tive 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 partic ular 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 resu lts of the round robin test to demonstrate that there were no performance differences between po lyurethane and polystyrene foams -- not to predict the level of thermal resistance over time.47 Interested parties also commented on the specific testing conditions for ASTM C1303-10. ORNL proposed that, if adopted, ASTM C1303-10 shoul d be modified to allow the user to take multiple 12 inch × 12 inch specimens from the 48 inch × 96 inch panel, at least 12 inches away from the edge of the 48 inch × 96 inch source. (ORNL, No. 0060.1 at p. 2) ORNL suggested specifying the aging conditioning temperatures fo r foam insulation. ORNL explained that while most insulation foams must follow aging conditio n requirements, the conditions used to age bun stock foam, which is used in producing foam in sulation, 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 su ggested modifying DOE’s proposal by adding a provision for molding test panels using unprime d 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 Industri es asserted that the modifications to ASTM C1303-10 proposed by DOE in the September 2010 SNOPR test were acce ptable, but wanted DOE to ensure that the changes would also a pply to expanded polystyrene insulation. (Craig Industries, No. 0068.1 at p. 4) Bally suggested th at 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)48 While DOE appreciates ORNL’s and Ball y’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 co llectively address some of the shortcomings of ASTM C1303-10. For ex ample, DIN EN 13165:2009-02 and DIN EN 13164:2009-02 provide for inclusion of metal face rs, while ASTM C1303-10 does not. In regard to Bally’s concern about the size of the test pa nel, 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. Additiona lly, given the comments from Craig Industries, Carpenter, Owens Corning, and NRDC about th e temperature conditions for testing, 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. This means that when a manufacturer tests a pane l 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 th at whatever method is adopted should be applicable to expanded polystyrene foam, DOE no tes that the foam aging procedures it proposed49 are only applicable to foams that rely on low c onductivity 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 conductivit y blowing agents that are intended to remain in the product for its usable life and does not exhi bit long term changes in thermal resistance, these tests would not apply, nor would they be ne eded 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. ThermoKool 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 a ll 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 sa mple 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 opti on than ASTM C1303-10. (Hill Phoenix, No.50 0063.1 at p. 2; AHRI, No. 0070.1 at p.2) Hill P hoenix added that DOE should adopt test procedures that are appropriate for the insulation materials that could be found in walk-in 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) Mast er-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 reservati ons about DIN EN 13165:2009-02 and DIN EN 13164:2009-02. Craig Industries stated that the alte rnatives 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, an d what the related tes ting 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 received51 about ASTM C1303-10 and the support fo r 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 polyureth ane products and extruded polystyrene products, respectively (polyisocyanurate products are cove red 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 comp liance 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 materi al 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 In dustries’ 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 requi ring that this test sa mple should be taken from the geometric center of the test specimen.52 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 ma nufacturer 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 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 th e possibility of testing the impact of moisture absorption on the R-value of different insulation materials, ev aluated 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 Corn ing, No. 0054.3 at p. 1) DOE initially concluded that testing the effect of moisture absorpti on on the R-value 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 ab sorption on R-value not be included in the test procedure. 75 FR 186, 194 (Jan. 4, 2010).53 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 Indus tries, No. 0068.1 at p. 5; Craig Industries, No. 0057.13 at p. 5) ACEEE also stated that it was imper ative to include the effect of moisture absorption. (ACEE, No. 0052.1 at p. 2) Kysor mainta ined that moisture did not affect the Rvalue 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 sugges ted possible tests and studies th at could be used to measure the effect of water absorption. For example, Cr aig 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. (Owe ns 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-in54 cooler and walk-in freezer applications. (Owe ns Corning, No. 0048.1 at p. 1 and No. 0032.1 at p. 3)

Additionally, joint comments filed by SC E, SMUD, SDG&E, and SCG on the January 2010 NOPR, hereafter referred to as the Jo int 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 require ment 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 implic itly acknowledged the high humidity conditions present in walk-in cooler and freezer envi ronments, which, in its view, s upported 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 minima lly intrusive method to determine the impact of moisture absorption would be to assess the va por diffusion integrity of the sealed panel. (ACEEE, No. 0052.1 at p. 2)

Other interested parties did not support includi ng 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,55 and that moisture infiltration should be considered inconseque ntial 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 infiltra tion is related to pane l installation and that there were no data to support that moisture infiltr ation is caused by the wa lk-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 co nditions, water absorption in foam is negligible and it recommended that the impact of moistu re 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 walk-in freezer user and were quickly repaired. (Hill Phoenix, No. 0041.1 at p. 2) Carpenter agreed with DOE th at the impact of water absorption of foam would be difficult to study and quantify, and adde d that polyurethane foam has an inherently low permeability, which would minimize water abso rption. (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 publi cation of the January 2010 NOPR, DOE reviewed several methods for testing vapo r permeance and water absorption in foam insulation materials.56 However, this review of vari ous test methods showed that there were disparities among the different methods, and that there was no gene ral agreement upon a single approach. 75 FR 186, 194 (Jan. 4, 2010). Moreover, while these tests ar e designed to measure the performance of insulating foam by itself, they would not acc ount 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 R-values. Accordingly, because of the potential ambiguities that are currently present with respect to the means by which to assess the impact of moisture absorption on the thermal performance of in sulating 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 th at glass walls (“display panels”) would be tested using NFRC 100-2001-E0A to measure th eir thermal transmittance, or U-factor. 75 FR 55068, 55098 (Sept. 9, 2010). Display panels are typi cally 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 proposed57 approach for display panels. Consequently, DOE is including this test procedure (to be codified in section 4.1 of Appendix A) to measure the th ermal 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 materi al, or both and is used for display purposes.

e. Open Areas of Walk-Ins The test procedure DOE is establishing toda y contains tests for components of walk-ins that separate the interior refri gerated environment of the walk-i n 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 Z one, No. 0077.1 at p. 1) Because an open area does not, by definition, separate the interior refrigera ted environment of the walk-in from the exterior, an open area is not a component of the walk-in that is covered under th is 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 ma terials or complete door plug, using the test procedure NFRC 100-2010[E0A1], “Procedure for De termining Fenestrati on Product U-factors.” 75 FR 55068, 55083 (Sept. 9, 2010). DOE specified inte rnal and external rating conditions for the test procedure to closely match conditions th at would be experienced by the door when it is part of a walk-in.58 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 a nd has incorporated the use of NFRC 100- 2001-E0A1 in this final rule. DOE also notes that none of the intere sted 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 co mponents 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 incl udes the energy consumed by electrical components asso ciated 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 displa y 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 dem onstrate that the device is controlled by a preinstalled timer, control system or other auto-shut-off system, the PTO is assumed to be 2559 percent. For example, if a door has a thermome ter mounted on it that c onsumes 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 locat ed on the inside surface of the door. This heat is added to the heat transmitted through the door and the correspo nding refrigeration energy use is calculated using the method described in section III.B.3.c. Th e 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 assu mptions about heat fro m electrical devices. Zero Zone disagreed with the assumption that a ll anti-condensate heat contributes to the walk-in heat load, and instead suggested that 50 to 75 pe rcent 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 walk -in heat load because the anti-c ondensate 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 por tion of the heat is transmitted from the display case to the surrounding environment. Therefore, DOE has revised the equations in sections 4.4.2 and 4.5.2 of Appendix A to capture only 75 percent of the power from anti-sweat heaters as an additional compressor load.60 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 comparis on 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 procedur e 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 th e EER value, and the proposed EER values for coolers and freezers. BASF commented that th e proposed EER assumptions were reasonable. (BASF, No. 0021.1 at p. 4) Nor-Lake agreed with DOE’s use of a nominal EER value to convert the thermal energy transmission to electrical en ergy consumption. (Nor-Lake, 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 represen t real world values. (Kason, No. 0055.1 at p. 4) Nor-Lake commented that the EER values on th eir refrigeration models did not match DOE’s proposed nominal values. (Nor-Lake, 0023.1 at p. 4)61 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 Bt u/W-h and 6.3 Btu/W-h to be appropriate conversions for walk-in coolers and walk-in freez ers, respectively, because these EER values correspond to nominal EER values contained in th e refrigeration test procedure for unit coolers connected to multiplex condensing systems (A HRI 1250 (I-P)-2009). DOE is aware that the nominal values for this configuration may not re present all walk-ins, but notes that these EER values are intended to provide a means of comp arison and not directly reflect a real walk-in installation. In particular, thes e EER assumptions are not intende d 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 electri cal 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 in sulation, 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 infiltra tion and infiltration from door opening events and subsequently modified th ese 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 submitte d comments pertaining to the t opic of envelope infiltration,62 including steady state infiltration, door openi ng 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 desc ribed in ASTM E741-06, “Standard Test Method for Determining Air Change in a Sing le 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 Phoe nix maintained that an insufficient amount of infiltration would occur in a properly installed walk-in, esse ntially suggesting that DOE aba ndon 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 amountof infiltration present in a walkin... (AHRI, No. 0070.1 at p. 3) Master-Bilt agreed, suggesting that testing steady-state infiltration is unnecessary because this infiltration is insignifi cant 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 infiltr ation of walk-in envelopes. TAFCO stated63 that ASTM E741-06, Standard Test Method for De termining Air Change in a Single Zone by Means of a Tracer Gas Dilution, is an accepta ble 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 eith er 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 a nd recommended that DOE use ASTM E1424-08, Standard Test Method for Dete rmining 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, Sta ndard 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 Septembe r 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 throug h doors using NFRC 400-2010-E0A1, “Procedure for Determining Fenestration Product Air Leakage.” 75 FR 55068, 55084 (Sept. 9, 2010).64 Interested parties commented on NFRC 400-2010-E0A1 and sugges ted alternatives. NRDC agreed with using NFRC 400-2010-E0A1 to de termine infiltration of individual envelope components, but also recommended using a pressuri zation test to determin e infiltration of fully assembled envelopes, based on ASTM D6670, “Standard Prac tice for Full-Scale Chamber Determination of Volatile Organic Emissions from Indoor Materials/Pr oducts.” (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 num ber 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 prescrib ed testing conditions to be implemented with NFRC 400-2010-E0A1. American Pa nel 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 w ith 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 weigh the impact of steady-state infiltration agai nst other sources of in filtration, 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 the65 envelope for site-assemb led walk-in coolers and freezers app ears 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 indi vidual components, the performance of these components will be captured under the new procedure and should be su fficiently adequate prior to their installation as part of a completed walk-in unit. Should th is prove not to be the case, DOE may re-examine the procedure and consider modifications to address its potential shortcomings.

b. Door Opening Infiltration In the January 2010 NOPR, DOE proposed to cal culate air infiltrati on associated with each door-opening event using established an alytical methods based on equations and computational values published in the AS HRAE Refrigeration Handbook. DOE also made several assumptions in the test procedure that c ould have a significant impact on the predicted air exchange. The assumptions with the most impact were the number of doorway passages (the number of door-opening 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 methodolog y, 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 infiltr ation from door openings. (Hired Hand, Public Meeting Transcript, No. 0016 at p. 309) Hired Hand emphasized that air infiltration may be the66 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; No r-Lake, No. 0047.1 at p.4; Master-Bilt, Public Meeting Transcript, No. 0016 at p. 311) Master-B ilt and Zero Zone also agreed with DOE’s assumptions regarding in filtration attributed to door openings. (Master-Bilt, No. 0069.1 at p. 2; Zero Zone, No. 0077.1 at p. 2)

Other interested parties ques tioned the applicability of the method to walk-in cooler and freezer doors, or questioned DOE’s assumptions in calculating door openi ng 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 ai r 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 th at the equations used to calculate air infiltration should be based on the operational time the door s 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 infiltra tion if the evaporator is discharg ing air in the direction of the67 display doors. (Zero Zone, No. 0077.1 at p. 1) Bally st ated that hybrid walk-ins, that is, walk-ins sited within another walk-in, s hould be given beneficial consid eration. 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; ThermalR ite, No. 0049.1 at p. 2) TAFCO also stated that ASTM E741-06 is an acceptable method for determining IRD effec tiveness. (TAFCO, No. 0040.1 at p. 3) NRDC stated that the propos ed door opening infiltration calculation from ASHRAE Fundamentals 2009 is acceptable for co nventional doors, but when doorways are protected by an air curtain or other infiltration reduc tion 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 th e test methodology. (Master-Bilt, No. 0027.1 at p. 2) Hill Phoenix noted that the panel manufact urer has no bearing on door opening frequency, which accounts for the majority of the infiltr ation. (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 infiltra tion reduction devices. (NEEA, No. 0061.1 at p. 5)68 DOE has decided not to include any test pro cedure 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 fo r reducing the door infiltration on its own since IRDs are generally designed and manufactured i ndependently from doors a nd 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 infiltr ation, 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 cont ext 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 assumptions about their daily operation. In addition, the heat loads from electri cal devices were factored into the envelope refrigeration load calculations. DOE proposed to in corporate 100 percent of the electrical energy69 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 re frigeration EER values described in section III.B.3.c. DOE also proposed a variety of PTO va lues 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 consump tion as part of the energy calculation, and concurred with the duty cycle assumptions. (BASF, No. 0021.1 at p. 5) Master-Bilt and NorLake also agreed with the electrical duty cy cle equation proposed by DOE. (Master-Bilt, No. 0027.1 at p. 2; Nor-Lake, No. 0023.1 at p. 4) ACE EE 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 ma de 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 high-efficiency heater wires that apply heat on demand. (Craig Industr ies, Public Meeting Transcript, No. 0016 at p. 325 and No. 0054.1 at p. 3) Finally, Nor-Lake expressed the opinion that the proposed PTO values for lights are low be cause in most applications the lights would be shut off each night for 8 hours. (Nor-Lake, No. 0047.1 at p. 5)70 DOE notes support from BASF, Master-Bilt, Nor-Lake, ACEEE, and ThermalRite for its methodology and assumptions. DOE is also awar e of the concerns presented by ORNL, Craig Industries, and Nor-Lake. However, since DO E 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 th e January 2010 NOPR to calculate the energy consumption of lights, sensors, and other miscellaneous electrical devices associated with walkin doors. Regarding Craig Industries’ specifi c comment about door heater wire, DOE’s PTO assumptions take into account demand-based control of compone nts, 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 indi vidual component of the walk-i n cooler or walk-in freezer. Therefore, in this test procedure, DOE establis hes a test of the performance of a refrigeration system itself, assuming nominal envelope char acteristics. In the concurrent standards rulemaking, DOE intends to establish energy c onservation standards for the refrigeration system.71 See generally 75 FR 17080 (April 5, 2010). The follo wing 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 sy stems 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. Th at notice proposed the following definitions:

Refrigeration system means the mechanism (inc luding 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 cool er 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 Master-Bilt ag reed 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 classification72 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 ma tch the classifications contai ned 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 “rem ote” (a unit cooler connected to a multiplex condensing system as in the proposed definiti on). (Joint Utilities, No. 0059.1 at p. 2) Like NEEA, the Joint Utilities suggested that DOE ch ange its proposed definition by adopting the approach taken with the commercial refrigerati on equipment efficiency regulations: “packaged” systems should be termed “self-contained cond ensing 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 re frigeration systems as self-contained (packaged systems) or unit coolers connected to remote condensing units (both dedicated and multiplex). It also suggested that for remote condensing system s, 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 fro m 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).73 Others are “remote condensing” (meaning the unit cooler is built into the case, but the whole case is connected to a central system of co mpressors 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 walk-in. 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 agr ee with the suggestion of NEEA and the Joint Utilities that this config uration should be classified as “r emote condensing” and does not agree that the compressor and condenser parts should not be covered under th e 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 walk-in 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.74 In consideration of the above, DOE belie ves the commercial refrigeration equipment definition cannot be applied to wa lk-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, re presented in commercial re frigeration equipment. Thus, while the Joint Comment compares walk-in refrigeration systems to commercial refrigeration equipment, DOE belie ves 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 loca ted, condensing unit. In that in stance, DOE’s definition covers this type of remote condensing unit. Furtherm ore, 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 Freeze rs,” into the test procedure. (The January 2010 NOPR referred to the preliminary versi on 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 manuf acturers use this standard to rate the refrigeration systems of walk-in coolers and freezers.75 AHRI 1250-2009 covers the testing of refri geration systems for walk-in coolers and freezers, which includes unit cooler s and condensing units that ar e sold together as a matched system, unit coolers and condensing units that are sold separately, and un it coolers connected to compressor racks. The procedure describes the method for measuring the refrigeration capacity and the electrical energy consumption for the co ndensing unit and the unit cooler, as well as the off-cycle fan energy and the defrost subsystem un der specified test conditions. The standard test conditions specify the dry-bulb and wet-bulb temper atures of the air surrounding the unit cooler and the condensing unit. The standard test c onditions 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 low-load and high-load conditi ons, 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 sy stem must operate under steady-state conditions. For systems in which the condensing unit is lo cated 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 e fficiency factor (AWEF) for the refrigeration system under a specified load profile. For unit coolers and conden sing units sold separate ly, the test procedure allows for testing the components individually and then calculating the system AWEF from the component test results.76 Several interested parties agreed with DOE’s proposed methodology. AHRI urged DOE to allow a rating of walk-in refrigeration syst ems using the calculation methodologies in the proposed protocols contained in AHRI 1250. (A HRI, 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 form ula that would allow the efficiency of the refrigeration system to be calculated from testin g 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, N o. 0065.1 at p. 1) However, the Joint Utilities disagreed with the assumption in AHRI 1250-2009 th at unit coolers and re mote condensing units that are sold separately will be matched and insta lled 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 U tilities, No. 0059.1 at p. 2) No pa rties 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 res ponse 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. Regard ing 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 a77 condensing unit and unit cooler, ev en if the two components are provided by different suppliers. The test results for a unit cool er or condensing unit are indepe ndent from whichever condensing unit or unit cooler is ma tched with the tested component. In contrast, the test results for each component are in the form of a performance curve to facilitate ca lculation 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 importa nt 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 refrigera tion 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 refrigera tion system because it allows the unit cooler and condensing unit to be te sted separately.

Additionally, DOE notes that if unit coolers ar e 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 c oolers to provide both the performance data for matching purposes and the performance as c onnected to a multiplex condensing system. DOE may consider requiring this information as part of any related labeling requirements for WICF equipment.78 While interested parties generally agreed with the adoption of AHRI 1250-2009, others disagreed with how that method w ould be applied to different sy stem configurations. The Joint Utilities and NEEA both r ecommended that all remo te condensing systems be tested using the “walk-in unit cooler match to parallel rack system” test met hod and noted that the matched system approach only be used for self-contai ned 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 co ndensing systems would create confusion and additional testing burden because there are many different te st methods and categories for different locations and types of condensing units. (Joint Utilities, No. 0059.1 at pp. 2 and 5) Other interested parties ques tioned the methodology for rating unit coolers connected to multiplex condensing systems. American Panel stat ed that the exemption of multiplex equipment would give that equipment an unfair advantage ov er single piece equipment. (American Panel, No. 0057.1 at p. 3) Master-Bilt stated that the mu ltiplex 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 conn ected 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 condensi ng 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 remo te condensing units represent a substantial79 opportunity for energy savings in a regulation fo r walk-in components because the configuration of a dedicated remote condensin g unit is widespread in several market segments such as restaurants. Manufacturers can optimize the de dicated remote condens ing 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 walk-in refrigera tion equipment accounts for these units.

To address Master-Bilt’s reque st for clarification, for sy stems 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 b ecause 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 multip lex 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 teste d, the condensing unit and compressor part of a multiplex condensing system is not exclusively pa rt of a walk-in unit. Therefore, DOE is not covering them in this test procedure. DOE not es that unit coolers connected to the multiplex condensing systems would still be c onsidered part of the walk-in a nd would need to be tested.80 The procedure considers the different perform ance of multiplex condensing systems and indoor condensing systems as recommended by NRDC . For multiplex condensing systems, the calculation of energy use includes a nominal effici ency that accounts for that type of system’s ability to reject heat. The rating conditions fo r 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 dete rmine the overall system performance for each application and recommended that performance da ta 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 application-specifi c and may not be useful for determining the performance of the system in conditions outside th e rating conditions. To provide this flexibility, as suggested by NRDC, the AHRI 1250 test proce dure contains provisions for conducting testing with application ratings to obtain the performan ce 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 produc t’s compliance with a pa rticular standard.

3. Alternative Efficiency Determination Method

For some covered equipment, DOE has allo wed manufacturers to use their own methods, whether a calculation or computer simulation, to rate their equipment af ter they substantiate those calculation or simulation met hods with test data. The purpose of this provision is to reduce81 the burden of testing customized, low-volume e quipment. DOE has allowed rating methods in the form of alternate rating methods (ARMs) 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 wate r heating (HVAC and WH) equipment -- is a rating method derived from a mathematical model th at represents the mech anical and electrical characteristics of the equipment and is based on engineering or statistical analysis, computer simulation or modeling, or other analytical eval uations of performance data. An AEDM must be substantiated by test data befo re it can be used to rate equi pment. (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 rule making, DOE introduced the concept of an AEDM at the Framework public meeting (Febru ary 4, 2009) and requested comment on whether it could be applied to walk-ins. At the Fram ework 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 inte rested 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 Corning82 stated that a single AEDM should be accepted to keep comparisons consistent (instead of different AEDMs from different manufacturers), a nd Craig said that requiring manufacturers to follow the same model (that is, not allowing manufacturers to use their own AEDMs) would provide consistent informati on 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 provi sions 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 th e envelope into its major components, the refrigeration system is considered as a single component. Cons istent with this appro ach, 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 s ituations, 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 compri se a complete refrigeration system. 75 FR 55073 (Sept. 9, 2010). In proposing this approach, DOE al so recognized that there could still be some burdens due to system variations. To mitigate these burdens, DOE noted that it might consider83 allowing manufacturers of refrigeration to us e 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 becaus e 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 th at even if unit coolers and condensing units could be tested separately, testing e ach component with all the options available would substantially increase the need for testing and would di scourage 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 un its. Heatcraft stated th at 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 syst em 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 testin g 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 w ith respect to walk-in components, in terms of their physical characteristics and, consequent ly, their energy performan ce or efficiency. To84 address Craig’s concern that te sting 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 th e 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 as follows:

(A) In general.- The terms “walk-in cooler” and “walk-in freezer” mean an enclosed storage space refrigerated to temperatures, respectively, a bove, and at or below 32 degrees Fahrenheit that can be walked into, and has a total chille d storage area of less than 3,000 square feet. (B) Exclusion.- The terms “walk-in cooler” and “wal k-in freezer” do not include products designed and marketed exclusively for medi cal, scientific, or research purposes. (42 U.S.C. 6311(20))

During the public meeting for the Ja nuary 2010 NOPR, Hired Hand and several interested parties stated that DOE should clarif y the definition of walk-in coolers and walk-in freezers with respect to temperature limits. Multiple interested parties commented that DOE85 should set an upper temperature limit for walk -ins. After reviewing the comments from interested parties, DOE proposed in the Sept ember 2010 SNOPR to modify the definition of “refrigerated” within the definiti on 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, Master -Bilt, 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; Thermo-K ool, No. 0072.1 at p. 1; Master-Bilt, No. 0069.1 at p. 1; Bally, No. 0078.1 at p.1) The Joint U tilities also recommended that DOE develop definitions for walk-in coolers and freezers th at are similar to California Title 24, Buildings Efficiency Standards, which contain a definiti on for “refrigerated warehouse” that clarifies a temperature of 55 degrees or less. (Joint Utilitie s, No. 0059.1 at p. 6) NEEA suggested that walkin coolers and freezers are essentially buildin gs and should be modeled as such. (NEEA, No. 0061.1 at p. 5)

DOE notes that any regulation it develops mu st be consistent wit h, and fall within the parameters of, the statutory provisions set by Co ngress. Working within the confines of the statutorily-prescribed definition of the walk-i n definition, DOE is clarifying what the term “refrigerated” means in the context of the walk-i n definition to help addr ess 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” as86 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, intere sted parties expresse d 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 de finition is unclear. (Cra ig Industries, Public Meeting Transcript, No. 0016 at p. 19; Hired Ha nd, 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 us age. Because a given walk-in sold by a company could be used in any of these types of applications, Craig I ndustries and Hired Hand were both concerned that a company could market its walk-in as medical e quipment and avoid having to meet any energy efficiency standards. Craig Industries and Hire d Hand requested that DOE work to improve the definition of exempted uses fo r walk-ins because the definiti on 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 promulga te – a manufacturer seeking to avail itself of87 the statutory exclusion would, cons istent with the statute, need to affirmatively demonstrate to DOE that its equipment is “designed and market ed exclusively for medical, scientific, or research purposes.” 42 U.S.C. 6311(20)(B). Furt her, 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 cons ider a number of factors, including, but not limited to, how a particular walk-in has been de signed, how it has been markete d, to whom the equipment has been distributed, and steps taken by manufacture rs. 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 c onservation standards. (Bally, No. 0078.1 at p.1) Under the component-level test pr ocedures established today, a c ubic 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 th e calculation methodology that DOE developed.

IV. Procedural Issues and Regulatory Review88 A. Review Under Executive Order 12866

The Office of Management and Budget has determined that test procedure rulemakings do not constitute “significant regulatory acti ons” under section 3(f) of Executive Order 12866, Regulatory Planning and Review, 58 FR 51735 (O ct. 4, 1993). Accordingly, this action was not subject to review under the Executive Order by th e 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 Rule making,” 67 FR 53461 (August 16, 2002), DOE published procedures and policie s 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 website: 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 proce dures and policies published on February 19, 2003.89 As discussed in detail below, DOE found that because these test procedures have not previously been required of manufacturers, a ll manufacturers, including small manufacturers, could experience a financial burden associated wi th new testing requirements. While examining this issue, DOE determined that it could not certif y 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 res ponse to the comments from interested parties, including the Small Business Administrati on (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 eco nomic impacts of the rule and responses thereto are provided in the analysis below.

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. 6190 FR 3286; see also 65 FR 30836, 30850 (May 15, 2000), as amended. 65 FR 53533, 53545 (September 5, 2000). The size standards are c odified at 13 CFR Part 121. The standards are listed by North American Industry Classification System (NAICS) code and industry description and are available at www.sba.gov/idc/groups/public/documen ts/sba_homepage/serv_sstd_tablepdf.pdf

.

In the January 2010 NOPR and September 2010 SNOPR, DOE classifi ed walk-in cooler and freezer equipment manufacturing under NAICS 333415, “Air-Conditioning and Warm Air Heating Equipment and Commerc ial and Industrial Refrigerati on Equipment Manufacturing,” which has a size standard of 750 employ ees. 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-i n 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 w ould not be considered small businesses) and a large number of small companies as categoriz ed by NAICS code 333415. Furthermore, more than half of small walk-in manuf acturers 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 ch aracterization 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 Panel91 characterized the majority of small walk-i n 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. (Ame rican Panel, No. 0057.1 at p. 3) Amer ican Panel stated that the cost of testing would be passed dow n to the product selling price, which would trickle down and seriously impact small business restaurant owne rs. (American Panel, No. 0057.1 at p. 4) Zero Zone agreed that small manufacturers would be imp acted by the regulations and stated that many will not be able to stay in business once they ar e burdened with the costs of certification. (Zero Zone, No. 0077.1 at p. 2)

In response to comments on the Ja nuary 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. Specifical ly, DOE is establishing test procedures for individual components of a walk-i n: panels, doors, and refrigera tion 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 positi oned to conduct these types of tests. See section III.A for further details on this approach.

As a result of this approach, DOE re-eva luated 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 und er the proposed approach, DOE estimates that there are 4 small manufacturers of refrigeration systems. Furthermore, DOE notes that entities it92 previously considered walk-in envelope manufactur ers 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 ma ke 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 characteriz ation of the walk-in industry as being composed mainly of small manufacturers. DOE believe s the new approach of regulating WICFs at the component level will reduce burden on sma ll manufacturers because the tes ting 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., manufact urers). The concurrent energy conservation standards rulemaking will address eff ects 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 th e test procedures on small manufacturers. DOE does not expect that small manufacturers wo uld have fewer basic models or component types than large manufacturers. Therefore, a sm all manufacturer could have the same total cost of testing as a large manufacturer, but this co st would be a higher percentage of a small manufacturer’s annual revenues. T hus, the differential impact associ ated with walk-in cooler and93 walk-in freezer test procedures on small businesse s 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 fre ezers within the appliance standards program, DOE is considering use of a component-based ap proach to walk-in standards, setting individual performance standards for each component. This approach would require the component manufacturers to test the components they manufactu re for walk-in applications, comply with the applicable performance standard for those co mponents, and certify to DOE that those components meet the standa rd. 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 rule making. Details on the performance standards rulemaking can be found on the DOE website 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 pe rformance 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 Manufact urer Testing Impacts94 In the September 2010 SNOPR, DOE proposed to require envelope manu facturers to test their equipment in accordance with several indus try test standards: ASTM C1363-05, “Standard Test Method for Thermal Performance of Build ing Materials and Enve lope 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) pr oducts—Specification;” and NF RC 100-2010[E0A1], “Procedure for Determining Fenestra tion Product U-factors.”

DOE spoke with industry experts to determin e the approximate cost of each test. Under the new component level approach to testing, en tire 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, thou gh 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 pa nels 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 c ould 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 confi gurations. However, for95 manufacturers who have fewer unique combinatio ns of frame type a nd 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 cal culate 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 usin g 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 modelin g 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 an ticipates 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 Impacts96 The test procedure for refrigeration systems will require manufacturers to perform testing in accordance with a single industry test st andard: AHRI 1250 (I-P)-2009, “2009 Standard for Performance Rating of Walk-In Coolers and Freeze rs.” DOE researched the cost of performing this test and, based on discussi ons with experts, estimates that a test using AHRI 1250 (I-P)-2009 would likely cost approximately $8,500. DOE estimate s that the total testing cost for a typical refrigeration manufacturer coul d be approximately $425,000, based on an estimate of 50 basic models, but that it could be higher for manufac turers 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 burden-reducing measures for refrigeration system manufacturers. The test procedure referenced in this final rule, AHRI 1250-2009, allows for rating the condensing un it and the unit cooler separately and then calculating their combined efficiency. This redu ces 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, manufacturer s 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 belie ves these provisions will reduce the burden of testing for refrigeration manufacturers because they will reduce the number of basic models a97 manufacturer must test. DOE may also consider allowing manufacturers to use validated alternative methods to rate thei r equipment. See section III.C.3 for further discussion of these methods.

DOE also considered a number of alternativ es to these test procedures, including test procedures that incorporate industry test standard s 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 131 65:2009-02 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 includi ng ASTM C1363-05 as part of the test procedure because heat conduction through st ructural members is a significant panel characteristic that is not addressed under AS TM 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.98 C. Review Under the Paperw ork Reduction Act of 1995

Manufacturers of walk-in cooler and walk-i n 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 walk-in freezer components, in cluding any amendments adopted for that test procedure. DOE has adopted regulations for th e certification and recordkeeping requirements for all covered consumer produc ts and commercial equipment, including walk-in cooler and walk-in freezer components. 76 FR 12442 (Mar ch 7, 2011). The collection-of-information requirement for the certification and recordke eping has been approved by OMB under control number 1910-1400. The public reporting burden for th e certification is estimated to average 20 hours per response, including the time for revi ewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.

Public comment is sought regarding: whethe r this proposed collection of information is necessary for the proper performance of the func tions of the agency, including whether the information shall have practical utility; the accu racy 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 co mments 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

.99 Notwithstanding any other provision of the la w, no person is required to respond to, nor shall any person be subject to a penalty for failu re 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 E nvironmental Policy Act of 1969

In this final rule, DOE establishes a new te st 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 Enviro nmental 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 th e amount, quality or distribution of energy usage, and, therefore, will not result in any environmenta l 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 impact s. 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 impleme nting policies or regulations that preempt State law or that have Federalism implicati ons. The Executive Order requires agencies to examine the constitutional and statutory aut hority supporting any action that would limit the policymaking discretion of the States and to carefully assess the necessity for such actions. The100 Executive Order also requires agencies to have an accountable process to ensure meaningful and timely input by State and local o fficials in the development of regulatory policies that have Federalism implications. On March 14, 2000, DOE pub lished 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 de termined that it will not have a substantial direct effect on the States, on th e relationship between the national government and the States, or on the distribution of power and responsibilities am ong the various levels of government. EPCA governs and prescribes Federal preemption of Stat e 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, a nd 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 Ju stice 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 ra ther than a general standard; and (4) promote simplification and burden reducti on. Section 3(b) of Executive Or der 12988 specifically requires that Executive agencies make every reasonable effo rt 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 sta ndard for affected conduct while promoting simplification and burden reduction; (4) specifies the retroactive effect, if any; (5) adequately101 defines key terms; and (6) addresses other im portant issues affectin g clarity and general draftsmanship under any guidelines issued by th e Attorney General. Section 3(c) of Executive Order 12988 requires Executive agencies to review regu lations in light of applicable standards in sections 3(a) and 3(b) to dete rmine 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 th e 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. Pub. L. No. 104-4, sec. 20 1 (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 re quires a Federal agency to publish a written statement that estimates the resulting costs, bene fits, and other effects on the national economy. (2 U.S.C. 1532(a), (b)) The UMRA also require s a Federal agency to develop an effective process to permit timely input by elected officer s 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 affe cted small governments before establishing any requirements that might significantly or uni quely 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 contains102 neither an intergovernmental ma ndate, nor a mandate that may re sult in the expenditure of $100 million or more in any year, so these requirements do not apply.

H. Review Under the Treasury and General Govern ment Appropriations Act, 1999

Section 654 of the Treasury and General Go vernment Appropriations Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Fami ly Policymaking Assessment for any rule that may affect family well-being. Today’s final ru le will not have any impact on the autonomy or integrity of the family as an institution. Accordi ngly, 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 agen cy pursuant to general guidelines issued by103 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 Ener gy Effects for any significant energy action. A “significant energy action” is defined as any actio n by an agency that promulgated or is expected to lead to promulgation of a final rule, and th at: (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 sign ificant 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 reasona ble alternatives to the action and their expected benefits on energy supply, distribution, and use.

Today’s regulatory action is not a signifi cant regulatory action under Executive Order 12866. Moreover, it would not have a significant a dverse effect on the supply, distribution, or use of energy, nor has it been designated as a si gnificant 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.104 L. Review Under Section 32 of the Fede ral Energy Administration Act of 1974

Under section 301 of the De partment 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 Adminis tration Authorization Act of 1977. (15 U.S.C. 788; FEAA) Section 32 essentiall y 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 additi on, 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 comme rcial or industry standards on competition.

The procedures addressed by this action inco rporate 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 thes e 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 provide s for public participati on, comment, and review.) DOE has consulted with both the Attorney Gene ral and the Chairman of the FTC about the impact on competition of using the methods contai ned in these standards and has received no comments objecting to their use.105 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).107 PART 431—ENERGY EFFICIENCY PROGRA M 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”, “Enve lope,” “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 move ment, 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 c oolers and walk-in freezers, a door includes the door panel, glass, fra ming materials, door plug, mullion, and any other elements that form the door or part of its connection to the wall.108 Envelope means— (1) The portion of a walk-in cooler or wa lk-in freezer that isolates the interior, refrigerated environment from the ambi ent, 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., elem ents 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 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 wher e 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.109 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. Re-designating paragraph (b) as paragraph (c); b. Adding at the end of the sentence in rede signated 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 incorpor ated by reference. * * * * * (b) AHRI . Air-Conditioning, Heating, and Refrigera tion Institute, 2111 Wilson Boulevard, Suite 500, Arlington, VA 22201, (703) 600-0366, or www.ahrinet.org

. (1) AHRI 1250 (I-P)-2009, (“AHRI 1250”), 2009 Standa rd for Performance Rating of Walk-In Coolers and Freezers, approved 2009, IBR approved for § 431.304. (2) [Reserved]. (c) * * * (1) * * * (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 431.110 (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 Ra ting Council, 6305 Ivy Lane, Ste. 140, Greenbelt, MD 20770, (301) 589-1776, or www.nfrc.org/. (1) NFRC 100-2010[E0A1], (“NFRC 100”), Procedur e for Determining Fe nestration Product Ufactors, approved June 2010, IBR approved for Appendix A to Subpart R of part 431. (2) [Reserved].

4. Section 431.304 is amended by re-designating paragraphs (b)(2), (b)(3), (b)(4), and (b)(5) as (b)(1), (b)(2), (b)(3), and (b)(4), resp ectively, and by adding new paragraphs (b)(5), (b)(6), (b)(7), (b)(8), and (b)(9) to read as follows. § 431.304 Uniform test method for the measur ement of energy consumption of walk-in coolers and walk-in freezers

. * * * * * (b) Testing and Calculations

. * * * * *111 (5) Determine the U-factor, conduction load, a nd energy use of walk-in cooler and walkin freezer display panels, floor panels, and non-fl oor panels by conducting the test procedure set forth in Appendix A, sections 4.1, 4.2, and 4.3, respectively. (6) Determine the energy use of walk-in cooler and walk-in freezer display doors and non-display doors by conducting the test procedur e set forth in Appendix A, sections 4.4 and 4.5, respectively. (7) Determine the Annual Walk-in Energy Fact or of walk-in cooler and walk-in freezer refrigeration systems by conducting the test pro cedure set forth in AHRI 1250 (incorporated by reference; see § 431.303). (8) Determine the annual energy consump tion 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 consum ption term in the equation for annual walkin energy factor in section 7 of AHRI 1250: Annual Energy Consumption = ෍ ܧሺݐ ௝ ሻ ௡ ௝ୀଵ where t j 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 c onditioned space, by performing the following calculation:112 Annual Energy Consumption ൌ ቆ 0.33 ൈ ܪܮܤ ሶ ൅ 0.67 ൈ ܮܮܤ ሶ Annual Walk-in Energy Factor ቇ ൈ 8760

where ܪܮܤ ሶ and ܮܮܤ ሶ for refrigerator and freezer system s are defined in sections 6.2.1 and 6.2.2, respectively, of AHRI 1250 and the annual walk-in en ergy 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 c onnected to a multiplex condensing system, by performing the following calculation:
Annual Energy Consumption ൌ ቆ 0.33 ൈ ܪܮܤ ሶ ൅ 0.67 ൈ ܮܮܤ ሶ Annual Walk-in Energy Factor ቇ ൈ 8760

where ܪܮܤ ሶ and ܮܮܤ ሶ for refrigerator and freezer syst ems 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—Unifor m Test Method for the Measurement of Energy Consumption of the Components of Envelopes of Walk-In Coolers and Walk-In
Freezers

1.0 Scope This appendix covers the test requirements used to measure th e energy consumption of the components that make up the envelope of a walk-in cooler or walk-in freezer.113 2.0 Definitions The definitions contained in § 431.302 ar e 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 cont act, 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 cont ains 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 pane l, 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 st ated otherwise, all conditions shown in Table A.1. For installations where two or mo re walk-in envelope components share any surface(s), the “external conditions” of the sh ared surface(s) must reflect the internal114 conditions of the adjacent walk-in. For exampl e, 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 Internal Temperatures (cooled space within the envelope) Value Cooler Dry Bulb Temperature 35 °F Freezer Dry Bulb Temperature -10 °F External Temperatures (space external to the envelope) Value Freezer and Cooler Dry Bulb Temperatures 75 °F Subfloor Temperatures Value Freezer and Cooler Dry Bulb Temperatures 55 °F

4.0 Calculation Instructions

4.1 Display Panels (a) Calculate the U-factor of the display pane l in accordance with section 5.3 of this appendix, Btu/ h-ft 2

- o F. (b) Calculate the display panel surface area, as defined in section 3.4 of this appendix, A dp , ft 2 , with standard geometric formul as or engineering software. (c) Calculate the temperature differential, Δ T dp , °F, for the display panel, as follows:

∆T ୢ୮ ൌ หT DB,ୣ୶୲,ୢ୮ െ T DB,୧୬୲,ୢ୮ ห (4-1)

Where:
T DB,ext,dp = dry-bulb air external temperature, °F , as prescribed in Table A.1; and115 T DB,int, dp = dry-bulb air temperature internal to the cool er or freezer, °F, as prescribed in Table
A.1.

(d) Calculate the conduction load through the display panel, Q cond-dp , Btu/h, as follows:

Q ୡ୭୬ୢ,ୢ୮ ൌ A ୢ୮ ൈ ∆T ୢ୮ ൈ U ୢ୮ (4-2)

Where:
A dp = surface area of the walk-in display panel, ft 2 ; Δ T dp = temperature differential between refrigerated and adjacent zones, °F; and
U dp = thermal transmittance, U-factor, of the displa y panel in accordance with section 5.3 of this appendix, Btu/ h-ft 2

- o 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, E dp , kWh/day, as follows:

E ୢ୮ ൌ Q ౙ౥౤ౚ,ౚ౦ EER ൈ ଶସ ୦ൈଵ ୩W ଵ ୢୟ୷ ൈଵ଴଴଴ W (4-3)

Where: Q cond, dp = the conduction load through the display panel, Btu/h; and116 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, A fp edge , ft 2 , with standard geometric formulas or engineering software as directed in se ction 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, A fp core , ft 2 , with standard geometric formulas or engineering software as directed in se ction 5.1 of this appendix. (c) Calculate the total area of the floor panel, A fp, ft 2 , as follows:

A ୤୮ ൌ A ୤୮ ୡ୭୰ୣ ൅ A ୤୮ ୣୢ୥ୣ (4-4)

Where:
A fp core = floor panel core area, ft 2 ; and
A fp edge = floor panel edge area, ft 2

.

(d) Calculate the temperature differential of the floor panel, ΔΤ fp , °F, as follows:

∆T ୤୮ ൌ หT ୣ୶୲,୤୮ െ T DB,୧୬୲,୤୮ ห (4-5)

Where:117 T ext, fp = subfloor temperature, °F, as prescribed in Table A.1; and
T DB,int, fp = dry-bulb air internal temperature, °F, as prescribed in Table A.1. If the panel spans both cooler and freezer temperatures, th e freezer temperature must be used.

(e) Calculate the floor foam degradation factor, DF fp , unitless, as follows:

DF ୤୮ ൌ R LTTR,౜౦ R బ,౜౦ (4-6)

Where:
R LTTR,fp = the long term thermal resistance R-value of the floor panel foam in accordance with section 5.2 of this appendix, h-ft 2

- o F/Btu; and
R o,fp = the R-value of foam determined in ac cordance with ASTM C518 (incorporated by reference; see section § 431.303) for purposes of compliance with the appropriate energy conservation standard, h-ft 2

- o F/Btu.

(f) Calculate the U-factor for panel core re gion modified by the long term thermal transmittance of foam, U LT,fp core , Btu/h-ft 2

- o F, as follows:

U LT,୤୮ ୡ୭୰ୣ ൌ U ౜౦ ౙ౥౨౛ DF ౜౦ (4-7)

Where:
U fp core = the U-factor in accordance with section 5.1 of this appendix, Btu/h-ft 2

- o F; and118 DF fp = floor foam degradation factor, unitless.

(g) Calculate the overall U-factor of the floor panel, U fp , Btu/h-ft 2

- o F, as follows:

U ୤୮ ൌ A ౜౦ ౛ౚౝ౛ ൈ U ౜౦ ౛ౚౝ౛ ାA ౜౦ ౙ౥౨౛ ൈU LT,౜౦ ౙ౥౨౛ A ౜౦ (4-8)

Where:
A fp edge = area of floor panel edge, ft 2 ;
U fp edge = U-factor for panel edge area in accordance with section 5.1 of this appendix, Btu/h-ft 2

-

o F;

A fp core = area of floor panel core, ft 2 ;
U LT,fp core = U-factor for panel core region modified by the long term thermal transmittance of foam, Btu/h-ft 2

- o F; and

A fp = total area of the floor panel, ft 2

.

(h) Calculate the conduction load through floor panels, Q cond-fp , Btu/h,

Q ୡ୭୬ୢି୤୮ ൌ ∆T ୤୮ ൈ A ୤୮ ൈ U ୤୮ (4-9)

Where:
Δ T fp = temperature differential across the floor panels, o F;
A fp = total area of the floor panel, ft 2 ; and119 U fp = overall U-factor of the floor panel, Btu/h-ft 2

- o 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, E fp , kWh/day, as follows:

E ୤୮ ൌ Q ౙ౥౤ౚష౜౦ EER ൈ ଶସ ୦ൈଵ ୩W ଵ ୢୟ୷ ൈଵ଴଴଴ W (4-10)

Where: Q cond-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 s ection 3.4, of the non-floor panel edge, as defined in section 3.3, A nf edge , ft 2 , with standard geometric formulas or engineering software as directed in se ction 5.1 of this appendix. (b) Calculate the surface area, as defined in s ection 3.4, of the non-floor panel core, as defined in section 3.2, A nf core, ft 2, with standard geometric form ulas or engineering software as directed in section 5.1 of this appendix. (c) Calculate total non-floor panel area, A nf , ft 2 :120 A nf = A nf edge + A nf core (4-11)

Where:
A nf edge = non-floor panel edge area, ft 2 ; and
A nf core = non-floor panel core area, ft 2

.

(d) Calculate temperature differential, Δ T nf , ° F:

∆T ୬୤, ൌ หT DB,ୣ୶୲,୬୤ െ T DB,୧୬୲,୬୤ ห (4-12)

Where:
T DB,ext, nf = dry-bulb air external temperature, ° F, as prescribed in Table A.1; and
T DB,int, nf = dry-bulb air internal temperature, ° F, as prescribed in Table A.1. If the non-floor panel spans both cooler and freezer temperatures, th en the freezer temperature must be used.

(e) Calculate the non-floor foam degradation factor, DF nf , unitless, as follows:

DF ୬୤ ൌ R LTTR,౤౜, R ౥,౤౜ (4-13)

Where:
R LTTR,nf = the R-value of the non-floor panel foam in accordance with section 5.2 of this appendix, h- ft 2

- o F /Btu; and121 R o,nf = the R-value of foam determined in ac cordance with ASTM C518 (incorporated by reference; see section § 431.303) for purposes of compliance with the appropriate energy conservation standard, h-ft 2

- o F/Btu.

(f) Calculate the U-factor, U LT,nf core , Btu/h-ft 2

- o F, as follows:

U LT,୬୤ ୡ୭୰ୣ ൌ U ౤౜ ౙ౥౨౛ DF ౤౜ (4-14)

Where:
U nf core = the U-factor, in accordance with section 5.1 of this appendix, of non -floor panel, Btu/hft 2

- o F; and
DF nf = the non-floor foam degradation factor, unitless.

(g) Calculate the overall U-factor of the non-floor panel, U nf , Btu/h-ft 2

- o F, as follows:

U ୬୤ ൌ A ౤౜ ౛ౚౝ౛ ൈ U ౤౜ ౛ౚౝ౛ ାA ౤౜ ౙ౥౨౛ ൈU LT,౤౜ ౙ౥౨౛ A ౤౜ (4-15)

Where:
A nf edge = area of non-floor panel edge, ft 2 ; U nf edge = U-factor for non-floor panel edge area in accordance with section 5.1 of this appendix, Btu/h-ft 2

- o F;
A nf core = area of non-floor panel core, ft 2 ;122 U LT,nf core = U-factor for non-floor panel core regi on modified by the long term thermal transmittance of foam, Btu/h-ft 2

- o F; and
A nf = total area of the non- floor panel, ft 2

.

(h) Calculate the conduction load through non-floor panels, Q cond-nf , Btu/h,

Q ୡ୭୬ୢି୬୤ ൌ ∆T ୬୤ ൈ A ୬୤ ൈ U ୬୤ (4-16)

Where:
Δ T nf = temperature differential across the non-floor panels, o F;
A nf = total area of the non-floor panel, ft 2 ; and
U nf = overall U-factor of the non-floor panel, Btu/h-ft 2

- o 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, E nf , kWh/day, as follows:

E ୬୤ ൌ Q ౙ౥౤ౚష౤౜ EER ൈ ଶସ ୦ൈଵ ୩W ଵ ୢୟ୷ ൈଵ଴଴଴ W (4-17)

Where: Q cond-nf = the conduction load through the non-floor panel, Btu/h; and123 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 acco rdance with section 5.3 of this appendix, Btu/h-ft 2

- o F (b) Calculate the surface area, as defined in section 3.4 of this appendix, of the display door, A dd , ft 2 , with standard geometric formul as or engineering software. (c) Calculate the temperature differential, Δ T dd , °F, for the display door as follows:

∆T ୢୢ ൌ หT DB,ୣ୶୲,ୢୢ െ T DB,୧୬୲,ୢୢ ห (4-18)

Where:
T DB,ext, dd = dry-bulb air temperature external to the di splay door, °F, as prescribed in Table A.1; and
T DB,int, dd = dry-bulb air temperature internal to the di splay door, °F, as prescribed in Table A.1.

(d) Calculate the conduction load through the display doors, Q cond-dd , Btu/h, as follows:

Q ୡ୭୬ୢ,ୢୢ ൌ A ୢୢ ൈ ∆T ୢୢ ൈ U ୢୢ (4-19)

Where:124 ∆T ୢୢ = temperature differential between refrigerated and adjacent zones, °F;
A dd = surface area walk-in display doors, ft 2 ; and
U dd = thermal transmittance, U-factor of the door , in accordance with section 5.3 of this appendix, Btu/ h-ft 2

- o F.

4.4.2 Direct Energy Consumption of Elect rical Component(s) of Display Doors Electrical components associated with display doors could include, but are not limited to: heater wire (for anti-sweat or anti-freeze app lication); 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, PTO t (%) (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 incl uded): 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 au to-shut-off systems, PTO = 0 percent. With timers, control system or other demand-based control, PTO = 50 percent. (3) For all other electricity consuming devi ces: 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.125 (b) Calculate the power usage for each type of electricity consuming device, P dd-comp,u,t , kWh/day, as follows:

P

ୢୢିୡ୭୫୮,୳,୲ ൌ P ୰ୟ୲ୣୢ,୳,୲ ൈ ൫1 െ PTO ୳,୲ ൯ൈn ୳,୲ ൈ 24h/day (4-20)

Where: u = the index for each of type of electricity-cons uming device located on either (1) the interior facing side of the display door or within the in side portion of the display door, (2) the exterior facing side of the display door, or (3) any combin ation of (1) and (2). For purposes of this calculation, the interior index is re presented by u = int and the exte rior index is represented by u = ext. If the electrical co mponent is both on the interior and exte rior 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;
P rated,u,t = rated power of each component, of type t, kW;
PTO u,t = percent time off, for device of type t, %; and

n u,t = number of devices at the rated power of type t, unitless.

(c) Calculate the total electrical energy consum ption for interior and exterior power, P dd-tot,

int (kWh/day) and P dd-tot, ext (kWh/day), respectively, as follows:

P

ୢୢି୲୭୲,୧୬୲ ൌ ∑ P ୢୢିୡ୭୫୮,୧୬୲,୲ ୲ ଵ (4-21)126 P

ୢୢି୲୭୲,ୣ୶୲ ൌ ∑ P ୢୢିୡ୭୫୮,ୣ୶୲,୲ ୲ ଵ (4-22)

Where: t = index for each type of electricity consuming device with identical rated power;
P dd-comp,int, t = the energy usage for an electricity cons uming device sited on the interior facing side of or in the display door, of type t, kWh/day; and
P dd-comp,ext, t = the energy usage for an electricity consu ming device sited on the external facing side of the display door, of type t, kWh/day.

(d) Calculate the total electri cal energy consumption, P dd-tot , (kWh/day), as follows:

P

ୢୢି୲୭୲ ൌ P ୢୢି୲୭୲,୧୬୲ ൅ P ୢୢି୲୭୲,ୣ୶୲ (4-23)

Where:
P dd-tot,int = the total interior electrical energy usage for the display door, kWh/day; and
P dd-tot,ext = the total exterior electrical energy usage for the display door, kWh/day.

4.4.3 Total Indirect Electricity Consum ption 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, C dd-load , kWh/day, as follows:127 C ୢୢି୪୭ୟୢ ൌ P ୢୢି୲୭୲,୧୬୲ ൈ ଷ.ସଵଶ EER B୲୳ Wି୦ (4-24)

Where: EER = EER of walk-in cooler or walk-in freezer, Btu/W-h; and
P dd-tot,int = The total internal electrical energy cons umption 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 consum ption due to conduction thermal load, E dd, thermal , kWh/day, as follows:

E ୢୢ,୲୦ୣ୰୫ୟ୪ ൌ Q ౙ౥౤ౚ,ౚౚ EER ൈ ଶସ ୦ൈଵ ୩W ଵ ୢୟ୷ ൈଵ଴଴଴ W (4-25)

Where: Q cond, 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, E dd,tot , kWh/day,128 E ୢୢ,୲୭୲ ൌ E ୢୢ,୲୦ୣ୰୫ୟ୪ ൅ P ୢୢି୲୭୲ ൅ C ୢୢି୪୭ୟୢ (4-26)

Where:
E dd, thermal = the total daily energy consumption due to thermal load for the display door, kWh/day;
P dd-tot = the total electrical load, kWh/day; and
C dd-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 sec tion 3.4 of this appendix, of the non-display door, A nd , ft 2 , with standard geometric formulas or with engineering software. (b) Calculate the temperature diffe rential of the non-display door, Δ T nd , ° F, as follows:

∆T ୬ୢ ൌ หT DB,ୣ୶୲,୬ୢ െ T DB,୧୬୲,୬ୢ ห (4-27)

Where:
T DB,ext, nd = dry-bulb air external temperature, °F , as prescribed by Table A.1; and
T DB,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: Q cond-nd , Btu/h,129 Q ୡ୭୬ୢି୬ୢ ൌ ∆T ୬ୢ ൈ A ୬ୢ ൈ U ୬ୢ (4-28)

Where:
Δ T nd = temperature differential across the non-display door, o F;
U nd = thermal transmittance, U-factor of the door , in accordance with section 5.3 of this appendix, Btu/ h-ft 2

- o F; and
A nd = area of non-display door, ft 2

.

4.5.2 Direct Energy Consumpti on of Electrical Components of Non-Display Doors Electrical components asso ciated with a walk-in non-display door comprise any components that are on the non-display door and that directly consume elec trical 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, PTO t (%) (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 incl uded): 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):130 Without timers, control system or other au to-shut-off systems, PTO = 0 percent. With timers, control system or other demand-based control, PTO = 50 percent. (3) For all other electricity consuming devi ces: 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, P nd-comp,u,t , kWh/day, as follows:

P

୬ୢିୡ୭୫୮,୳,୲ ൌ P ୰ୟ୲ୣୢ,୳,୲ ൈ ൫1 െ PTO ୳,୲ ൯ൈn ୳,୲ ൈ 24h/day (4-29)

Where: u = the index for each of type of electricity-cons uming device located on either (1) the interior facing side of the display door or within the in side portion of the display door, (2) the exterior facing side of the display door, or (3) any combin ation of (1) and (2). For purposes of this calculation, the interior index is re presented by u = int and the exte rior index is represented by u = ext. If the electrical co mponent is both on the interior and exte rior 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;
P rated,u,t = rated power of each component, of type t, kW;
PTO u,t = percent time off, for device of type t, %; and

n u,t = number of devices at the rated power of type t, unitless.131 (c) Calculate the total electrical energy consum ption for interior and exterior power, P nd-tot,

int (kWh/day) and P nd-tot, ext (kWh/day), respectively, as follows:

P

୬ୢି୲୭୲,୧୬୲ ൌ ∑ P ୬ୢିୡ୭୫୮,୧୬୲,୲ ୲ ଵ (4-30)

P

୬ୢି୲୭୲,ୣ୶୲ ൌ ∑ P ୬ୢିୡ୭୫୮,ୣ୶୲,୲ ୲ ଵ (4-31)

Where: t = index for each type of electricity consuming device with identical rated power;
P nd-comp,int, t = the energy usage for an electricity cons uming device sited on the internal facing side or internal to the non-display door, of type t, kWh/day; and
P nd-comp,ext, t = the energy usage for an electricity consu ming 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 electri cal energy consumption, P nd-tot , kWh/day, as follows:

P

୬ୢି୲୭୲ ൌ P ୬ୢି୲୭୲,୧୬୲ ൅ P ୬ୢି୲୭୲,ୣ୶୲ (4-32)

Where:
P nd-tot,int = the total interior electrical energy usage for the non-display door, of type t, kWh/day; and
P nd-tot,ext = the total exterior electrical energy usage fo r the non-display door, of type t, kWh/day.132 4.5.3 Total Indirect Electricity Consum ption 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, C nd-load , kWh/day, as follows:

C ୬ୢି୪୭ୟୢ ൌ P ୬ୢି୲୭୲,୧୬୲ ൈ ଷ.ସଵଶ EER B୲୳ Wି୦ (4-33)

Where: EER = EER of walk-in cooler or freezer, Btu/W-h; and
P nd-tot,int = the total interior electrical energy c onsumption 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 c onsumption due to thermal load, E nd, thermal , kWh/day, as follows:133 E ୬ୢ,୲୦ୣ୰୫ୟ୪ ൌ Q ౙ౥౤ౚష౤ౚ EER ൈ ଶସ ୦ൈଵ ୩W ଵ ୢୟ୷ ൈଵ଴଴଴ W (4-34)

Where: Q cond-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, E nd,tot , kWh/day, as follows:

E ୬ୢ,୲୭୲ ൌ E ୬ୢ,୲୦ୣ୰୫ୟ୪ ൅ P ୬ୢି୲୭୲ ൅ C ୪୭ୟୢ (4-35)

Where:
E nd, thermal = the total daily energy consumption due to thermal load for the non-display door, kWh/day;
P nd-tot = the total electrical energy consumption, kWh/day; and
C nd-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 Geom etry Requirements134 (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 Pane l Edge Test Region would be 7 in. ± 0.5 in. wide.

2. If the panel does not contain framin g 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 pane l length = Y + X, panel height = Z +X where X=2W.135 Figure 1 ASTM C1363 Test Regions (Not e: diagram not drawn to scale)

(2) Testing Conditions (i) The air temperature on the “hot side”, as denoted in ASTM C1363, of the nonfloor panel should be mainta ined at 75 °F ± 1 °F.

1. Exception: When testing floor pane ls, 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.136 (iii) The air velocity must be maintain ed as natural convection conditions as described in ASTM C1363. The test mu st 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: U nf, edge
2. Panel Core Region U-factor: U nf, core (ii) Floor Panels

1. Floor Panel Edge Region U-factor: U fp, edge
2. Floor Panel Core Region U-factor: U fp, 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 bein g tested must be used as the sample for completing DIN EN 13165.137 (ii) A 500mm × 500mm square (× thickness of the panel) section cut from the geometric center of the panel that is bein g 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: R LTTR,nf (ii) Floor Panels

1. Long Term Thermal Resistance: R LTTR,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 co efficient on both interior and exterior surfaces of the door should be based on the co efficients 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)138 (ii) Mean outside radiant temperature must be the same as section 5.3(a)(3)(i), above. (4) Direct solar irradiance = 0 W/m 2 (Btu/h-ft 2 ). (b) Required Test Measurements (i) Display Doors and Display Panels

1. Thermal Transmittance: U dd (ii) Non-Display Door

1. Thermal Transmittance: U nd