1

UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

+ ++++

WATER HEATER TEST PROCEDURE WORKSHOP

WEDNESDAY

FEBRUARY 12, 1997

The workshop was held in Room 1E-245, 1000

Independence Avenue, S.W., Washington, D.C., at 9:00

a.m., Jim Raba, Facilitator, presiding.

PRESENT:

JIM RABA

MICHAEL MCCABE

BRYAN BERRINGER

ED LEVY

CARL HILLER

TIM BEGOSKE

OTTO VAGO

JOHN PAISLEY

BILL HARRIGILL

GEORGE M. KUSTERER

STEVE ROSENSTOCK

BRIAN DOUGHERTY

JAMES MILLS

WILBUR L. HAAG, JR.

STANLEY LIU

WILLIAM HUI

RICHARD MILLER

ALAN CAPE

JIM LUTZ

ANDY LOWENSTEIN

DON ABRAMS

JIM EARLEY

MIKE PISTOLE

JIM VAUGHN

QUENTIN LOONEY

DIANE MOOREFIELD

R. DEAN MORRISON

JACOB H. HALL

WILLIAM M. PRYOR

CARL ADAMS

ADAM DUCH

JOHN HOLT

KIRSTIE KUMMER

BERT KALISCH

HAROLD HEISS

TIMOTHY A. BERNADOWSKI, SR.

FRANK STANONICK

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
A-G-E-N-D-A

Agenda Item

Welcome by Facilitator Raba .......

Introductions ..............

First Hour Ratings for Storage-type Water

Heaters

Brian Dougherty .............

Carl Hiller . . . . . . . . . . . . . . .

Instantaneous Water Heaters ..........

Storge-type Water Heaters of Less Than

20 Gallons . . . . . . . . . . . . . . . . .

Daily Hot Water Use and Thermostat Settings

Heat Pump Water Heaters and the Four

Proposed Definitions ............

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202):

3

. 13

. 21

. 32

118

158

198

225

234-4433

2

Page

 EE-RM-94-230 COMMENT 49P
3

1 P-R-O-C-E-E-D-I-N-G-S

2 (9:00 a.m.)

3 FACILITATOR RABA: Good morning. Good to

4 see everybody here this morning. Welcome, welcome to

5 the Department of Energy Workshop on Water Heater Test

6 Procedures. I trust everybody is settled in and ready

7 for a good discussion, good dialogue today.

8 My name is Jim Raba, I will be your

9 Facilitator for the day. My role is to remain neutral

10 and to help you focus on the task at hand, to get the

11 job done. As a Facilitator, just so we are all clear.

12 I am not going express my ideas or evaluate yours.

13 Both rather help you discuss, bring out and contribute

14 your ideas.

15 I will be involved in the process, not the

16 substance. I will make suggestions how to proceed and

17 hopefully get the most out of our time and our

18 discussions today at the workshop. This is your

19 meeting. My being a good Facilitator is difficult, so

20 please help me out.

21 And if you think I am pushing too hard or

22 guiding in the wrong way, please correct me and let me

23 know. I won't be defensive, but will make the

24 adjustments as necessary. And with your help, I'm

25 sure we will have a great meeting today.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
4

1 So, welcome. I would like to turn the

2 meeting over to the Director of the Office of Codes

3 and Standards, Mr. Michael McCabe, for some opening

4 remarks.

5 MR. MCCABE: Good morning. I am going to

6 move up to the front. As Jim stated, I am Michael

7 McCabe. I'm the Director of the Office of Codes and

8 Standards here in the Department. I would like to

9 welcome you all here for this workshop.

10 We have here helping us staff from the

11 National Institute of Standards and Technology. As

.2 well as staff from the Federal Trade Commission, who

13 have been involved with test procedures and labeling

14 of water heaters for some years now.

15 We also have a number of interested

16 parties from a variety of organizations,

17 manufacturers, utilities, representatives from states

18 and others. The purpose of today's meeting is to deal

19 with the test procedures. We had proposed amendments

20 to the test procedures some time ago, and we have been

21 overwhelmed by the other smaller issues that we deal

22 with in the office for the last 18 months or so, and

23 that's standards.

24 So we are trying to now take, now that

25 we've had the process improvement effort on appliance

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
5

1 standards completed. Where we have established the

2 new procedures which we will be following for

3 appliance standards, we are refocusing our efforts in

4 a number of areas and want to resolve the test

5 procedure issues that have been raised on water

6 heaters. And to issue a final rule as quickly as

7 possible.

8 We will appreciate your candid input

9 today. We will consider that and that will drive us

10 in the direction which we will be going with in the

11 final rule on the test procedures. Once we complete

12 the test procedure rule making, we will proceed with

13 the standards rule making.

14 The standards for water heaters have been

15 identified as one of the priority products for

16 standards in our regulatory agenda. I know that for

17 some parties that there was some confusion as to what

18 happened. And that we had a workshop on

19 prioritization where we had identified water heater as

20 a medium priority product.

21 And that some parties were rather

22 surprised when they saw or heard that the

23 prioritization had been moved up to high. I would

24 like to comment on that briefly, in that when we had

25 conducted the workshop, the process called for

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
6

1 presenting what is a staff recommendation, based on

2 the information that was in front of us.

3 The rationale that we did us for some

4 products for high priority, was that there were near

5 completions as well as the magnitude of energy

6 savings. A number of organizations had commented on

7 water heaters and urged the Department to change the

8 priority for water heaters to, from the medium to

9 high.

10 In looking at the rationale, we considered

11 it and accepted that. I will urge all parties, based

12 on that experience, that to take that to heart for

13 future prioritization process is that if you see

14 something that the staff this year proposes to be a

15 high, medium or low priority and you agree with that,

16 don't be silent. Speak up and say that you agree with

1.7 it.

18 If you disagree with it, then do the same.

19 Our process will be that, as in the past, we will

20 present a staff recommendation based on some

21 information that we've developed in consultation with

22 state goals. We will present that, receive comment,

23 we will present all that information to the Assistant

24 Secretary prior to publishing the final priorities,

25 the priorities in the Federal Register.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
7

1 So that is, we would appreciate and

2 encourage all comments. And I, given the forum that

3 we will be conducting today's meeting, being rather

4 informal, I will at this point invite anybody with any

5 questions of me right now or later, to just make those

6 questions and I would be happy to entertain them.

7 MR. ROSENSTOCK: Are the latest priorities

3 that have been picked, are those pretty much are they,

9 would you say those are the set for the rest of the

10 remainder of the year in terms of high, medium and

11 low?

12 MR. MCCABE: Yes. Those that were

13 published in the regulatory agenda in November are the

14 priorities for this year. And we are in the process

15 now of assigning a team within the staff to work on

16 the process for the 1998 priorities. A housekeeping

17 rule that might aid the Recorder, is that if anybody

18 who is asking a question, particularly from the

19 audience. But anybody that is asking a question or

20 making a statement, if they would identify themselves

21 first.

22 MR. ROSENSTOCK: Sorry, Steve Rosenstock.

23 MR. MCCABE: At this time, I would like to

24 turn it over to Bryan Berringer. Bryan is the Program

25 Manager on staff responsible for water heaters,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
8

1 including water heater test procedures. And has been

2 quite invaluable in a number of areas, including

3 supporting the process improvement effort.

4 MR. BERRINGER: Thank you, Michael. I

5 would like to say that I am the Project Manager on

6 this. I really appreciate everybody coming out today.

7 I just have a few procedural things to go over, so if

8 you could bear with me a moment. As Michael stated,

9 there is a number of people that work on the program.

10 We Brian Dougherty and Stan Liu from NIST.

11 Bill Hui, Carl Adams and Ed Levy from the

12 General Counsel who have all been working on this rule

13 making. On behalf of the Department of Energy, I

14 would like to thank everyone for coming today. What

15 we are trying to do and accomplish today is go and get

16 feedback on comments we've received on the March, '95

17 proposed notice.

18 And also the comments we've heard from the

19 Hearing in July, '95, pertaining to test procedures.

20 And to seek any additional data, input or information

21 pertaining to these comments.

22 And I think we have a full discussion on

23 these issues from a number of people. We did an

24 analysis in a letter to many of the stake holders on

25 December 26, 1996. We also put out a Federal Register

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
9

1 Notice. And any of you attending today that signed

2 in, if you haven't done so, if you would, you will be

3 added to the mailing list for future mailings.

4 The comments received here today and

5 submitted during written comment period or any

6 comments as a result of today's workshop, will assist

7 us in finalizing the final rule of test procedures.

8 Right now we've got that planned for April of '97.

9 Any comments made may not allow that, but that's

10 something that we will have to determine today from

11 the discussion. And hopefully that will be helpful.

12 I will be the presiding Officer for the

13 workshop today. And Jim Raba will be facilitating the

14 workshop today and giving us guidance as far as

15 conducting the workshop and providing other pertinent

16 information. In approximately two weeks, we will have

17 a complete copy of the transcripts of this workshop

18 available for inspection or copying at the DOE Freedom

19 of Information Room. Which is located down the hall

20 in Room 1E-190.

21 Anybody wishing to purchasing transcripts,

22 can talk to the Court Reporter. To provide the

23 Department with as much pertinent information as

24 reasonably can be obtained, and to enable everybody to

25 express their views, we would like to follow the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
10

1 workshop in the following procedures.

2 Again, the focus of the workshop is to

3 listen to your views pertaining to the comments

4 received on the notice and at the hearing and to seek

5 additional information pertaining to those comments.

6 We are going to begin with introductions. We will go

7 around the room. Then we will go over the ground

8 rules and we will have a discussion of the agenda and

9 we will expand on it, if there are other test

10 procedure issues that warrant discussion.

11 We will take an hour break for lunch some

12 time around noon. We have the DOE cafeteria in the

13 West Building. We also have a snack bar and cafeteria

14 one floor below us. There is also some restaurants up

15 the street if you walk up L'Enfant Plaza, at the mall

16 there, there is an underground mall.

17 We will also ask, so we get everybody's

18 participation, that we wait to be recognized by the

19 Facilitator. Please remember to speak into the

20 microphones, state your name and your company name

21 before you speak, so the Court Reporter can record

22 that.

23 We ask that side conversations be either

24 done in the corner or outside the room, so we don't

25 interrupt the presenters or so we can have a good

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
11

1 discussion and we are not over running each other.

2 We may have to cut off some topics to

3 maintain schedule. When we do the agenda review, we

4 may see some adjustments in that. There will be time

5 at the end of the workshop for additional discussions.

6 We encourage that everybody participate as much as

7 possible so that we can get a full spectrum of

8 opinions on the topics.

9 We are scheduled to go until 4:00 today or

10 sooner if we complete discussion, however I don't

11 think we will have that problem. The topics which

12 have not been completely discussed by 4:00 can be

13 addressed in additional comments, and we will discuss

14 at the end when we might receive those additional

15 comments in the Department.

16 All comments and data submitted will be

17 considered before we publish the final rule for test

18 procedures. We ask that all written comments and

19 submissions will be available in the Freedom of

20 Information Room.

21 The phone number is (202) 586-6020.

22 Written comments should be addressed to the Department

23 of Energy as outlined in the Federal Register Notice

24 of today's workshop, which is in your package.

25 We ask that 10 copies of comments and data

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
12

1 be submitted. In addition, if you have any electronic

2 copies, if you could submit them in Word Perfect 6.1.

3 No fax comments will be accepted. Any comments that

4 people feel are confidential or exempt by public law

5 disclosure, should submit one complete copy and 10

6 copies which have the confidential information deleted

7 from them.

8 In accordance with procedures established

9 in 10 CFR 1004.11, the Department of Energy will make

10 a determination whether the information is exempt from

11 public disclosure. In keeping with regulations of

12 this building, there is no smoking allowed in this

13 room or in this building. Rest rooms are down to your

14 left and to your right. There are phones in the main

15 lobby on this floor.

16 Again, we appreciate the time and effort

17 that you have taken to come here in preparing for this

18 workshop. And we are pleased to receive your comments

19 and opinions. I would like to reiterate, the purpose

20 is to listen to your views pertaining to comments

21 received on the proposed rule and at the Hearing to

22 seek additional information.

23 I'd ask if you have not signed in yet, if

24 you would please do so at that table. And at this

25 time, I would like to turn it back over to Jim and we

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
13

1 will do introductions, go over the ground rules and

2 review the agenda. Thank you.

3 FACILITATOR RABA: Good morning again. I

4 would like to start with introductions. Please state

5 your name and organization that you represent. We

6 will start here at this end of the table and go around

7 and then for the rest of the room.

8 MR. BERRINGER: Again, Bryan Berringer,

9 Department of Energy.

10 MR. LEVY: Ed Levy, Office of General

11 Counsel, Department of Energy.

12 DR. HILLER: Carl Hiller, Electric Power

13 Research Institute.

14 MR. BEGOSKE: Tim Begoske, Effikal

15 International.

16 MR. STANONICK: Frank Stanonick, Gas

17 Appliance Manufacturers Association.

18 MR. VAGO: Otto Vago, State Industries.

19 MR. MCCABE: Michael McCabe, Department of

20 Energy.

21 MR. PAISLEY: John Paisley, GSW Water

22 Heating Company.

23 MR. HARRIGILL: Bill Harrigill, Rheem

24 Manufacturing.

25 MR. KUSTERER: George Kusterer, Bock Water

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
14

1 Heaters.

2 MR. ROSENSTOCK: Steve Rosenstock, Edison

3 Electric Institute.

4 MR. DOUGHERTY: Brian Dougherty, National

5 Institute of Standards and Technology.

6 MR. MILLS: James Mills, Federal Trade

7 Commission.

8 MR. HAAG: Wilbur Haag, A.O. Smith Water

9 Products Company.

10 MR. LUI: Stanley Lui, NIST.

11 MR. HUI: Bill Hui, Department of Energy.

12 FACILITATOR RABA: Thank you. In the

13 back, please, starting on this side over here.

14 MR. MILLER: Rick Miller, Rheem

15 Manufacturing.

1.6 MR. CAPE: Alan Cape, Rheem Manufacturing.

17 MR. LUTZ: Jim Lutz, LB National

18 Laboratories.

19 MR. LOWENSTEIN: Andy Lowenstein AIL

20 Research.

21 MR. ABRAMS: Don Abrams, Abrams and

22 Associates.

23 MR. EARLEY: Jim Earley, Georgia Power

24 Company.

25 MR. PISTOLE: Mike Pistole, Effikal

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
15

1 International.

2 MR. VAUGHN: Jim Vaughn, Vaughn

3 Manufacturing.

4 MR. LOONEY: Quentin Looney, Policy

5 Research Associates.

6 MS. MOOREFIELD: Diane Moorefield, Potomac

7 Electric Power Company.

8 MR. MORRISON: Dean Morrison, Rheem.

9 MR. HALL: Jack Hall, Rheem Manufacturing.

10 MR. PRYOR: Mike Pryor, State Industries.

11 MR. DUCH: Adam Duch, Group Thermo.

12 MR. HOLT: John Holt, National Rural

13 Electric Cooperative.

14 MR. ADAMS: Carl Adams, DOE.

15 MR. STEPHENS: Charlie Stephens, Oregon

16 Energy Office.

17 MR. BARBER: Ed Barber --

18 MR. PAUL: Darrell Paul.

19 MR. RANFONE: Jim Ranfone, The American

20 Gas Association.

21 MR. HEISS: Harold Heiss, American

22 Electric Power.

23 MR. BERNADOWSKI: Tim Bernadowski,

24 Virginia Power.

25 FACILITATOR RABA: Thank you. Can you all

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
16

1 see back there?. We are meeting today to help the

2 process along and get the most out of today. I would

3 like to go over a few ground rules with you. I would

4 like to listen to some that you'd like to put up on

5 the board too.

6 Can you all see this? All right. Again,

7 for the record, for speaking, so we can all get

8 familiar with each other, please state your name

9 clearly and your organization represented. Because we

10 have a large group today, we recommend that each

11 raises their hand before speaking. It will help out'

12 a lot.

13 Let one person speak at a time. I would

14 like to stay on the topic, focus on the topic. If

15 there is something that needs to be discussed, we can

16 put it in a parking lot. We can write it down,

17 capture it for now, post it on the wall and come back

18 to it later on. So stay of topic. If something comes

19 up, we will hold on to it and we will save it for

20 later.

21 I would like you all just to listen as

22 allies. Listen constructively, focus on the task and

23 give constructive remarks. So listen as allies and be

24 concise. Be concise. Please, we have a lot to cover

25 today and I would like to hear from everybody,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
17

1 everybody. And also to focus on the future. That is

2 to work up, we are going to go forward. We are going

3 to look at the future, what we can do together. So we

4 are going to look at that as a future orientation.

5 Now here's some simple guidelines, ground

6 rules. Can you all accept these? Are these okay with

7 you? Do you feel comfortable with these? Are these

8 okay? Do you have anything to add to this, this list,

9 anything you'd like to put up here too? Any personal

10 concerns or ground rules?

11 (No response.)

12 FACILITATOR RABA: Okay, it sounds good,

13 it sounds good. Well, next thing, let's go over the

14 agenda. The purpose of our meeting today is really to

15 gather feedback and information and share data so we

16 can all come to some conclusions or some ways to

17 gather facts on the topics. To help us all out and

18 understand each one and help us in the direction with

19 the standards and procedures and test procedures for

20 water heaters.

21 So to gather feedback and information.

22 And the outcome is to use this input for the test

23 procedures for water heaters, and ultimately a final

24 rule for those test procedures. Going step-by-step

25 through the agenda, we are going to look at the topics

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
18

1 of first hour ratings for storage-type water heaters.

2 Then instantaneous water heaters. Then

3 look at storage-type water heaters of less than 20

4 gallons, the daily hot water use and heat pump water

5 heaters and attending definitions. Now, these are the

6 items in the agenda that we have posted here. Are

7 there any other critical items you'd like to bring up.

8 Please.

9 DR. HILLER: I am going to recommend a

10 change in the order of the agenda --

11 FACILITATOR RABA: Okay.

12 DR. HILLER: -- for the group to decide

13 on. I am anticipating that the first hour rating

14 issue is probably going to be the most contentious

15 issue. And I think some of the other issues could be

16 dealt with more rapidly, and especially in some of the

17 temperature issues. I don't see temperature

18 specifically listed there, but --

19 FACILITATOR RABA: Yeah, that was on the

20 agenda, thank you.

21 DR. HILLER: If we get some of those

22 things cleared up, then the first hour rating

23 discussion will be easier, because we will have

24 already agreed on the temperatures that we are talking

25 about.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
19

1 FACILITATOR RABA: That sounds good. Does

2 anybody have any other comments on that?

3 (No response.)

4 FACILITATOR RABA: Would you like to

5 rearrange the agenda just a bit?

6 MR. STANONICK: No, I'd rather leave it

7 that way. As far as I'm concerned, the issue is let's

8 get the first hour rating procedure, that is the

9 issue. The rest of this is relatively less important

10 stuff than resolving this issue of how you are going

11 to do first hour ratings.

12 FACILITATOR RABA: Okay, we have an offer

13 to rearrange the agenda for priorities and we have

14 another offer to keep it the same. Any other comments

15 on that, any other feedback? Yes, please.

16 MR. KUSTERER: I agree with Frank. I

17 think that's the major priority. I also think let's

18 get the hard part over with first. It seems that the

19 easier stuff will be easier to get through. I think

20 we should stick to the agenda.

21 MR. VAGO: I also support that position.

22 FACILITATOR RABA: Others please?

23 MR. ROSENSTOCK: Steve Rosenstock, Edison

24 Electric Institute. I think in terms of building

25 consensus, I agree with Dr. Hiller's approach, that it

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
20

1 might be easier to take some small steps first, before

2 we get to the more contentious issues.

3 FACILITATOR RABA: How does the rest of

4 the group feel about that?

5 (No response.)

6 FACILITATOR RABA: A show of hands. All

7 those who would like to keep the agenda as it is?

8 Three, four, five, six, seven, eight, nine, ten, 11,

9 12, 13, 14, 15, 16, I see. Seventeen. And to reload

10 the agenda? Okay, it shows that there are more in

11 favor of keeping as is.

12 Be assured, please, we will have ample

13 time to discuss all topics thoroughly. I appreciate

14 the suggestion to change, but we are going to stay on

15 topic as we are now according to the group. Thank you

16 very much for that. Again, reminding you are ground

17 rules. Please state your name and organization before

1.8 speaking. It will help our Reporter and each of us to

19 identify each other and know who each other are.

20 We did have that temperature setting to be

21 put back up there again. That went with the daily hot

22 water usage, is that correct? And temperature setting

23 goes right here. Are there any other issues that

24 could be on the agenda, any other critical issues?

25 (No response.)

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
21

1 FACILITATOR RABA: Okay, so we will just

2 stick with this for now. If something comes up, we

3 can put in on a parking lot or add it to the agenda.

4 I did see some others come in at the last minute. Has

5 everybody registered at the table there, give your

6 business card in?

7 Okay, we will make time to discuss each of

8 the issues thoroughly. And, as I say, if there is

9 anything else that comes up we can go over them at

10 that time. The first substantive element that we have

11 in our agenda is the discussion of the first hour

12 rating. In deed, a difficult topic, so we would like

13 to hear from everybody on this topic.

14 First we would like to start Brian

15 Dougherty from the National Institute of Standards and

16 Technology, who will give a brief background on the

17 first hour rating, and then a presentation by Dr. Carl

18 Hiller with EPRI. Thank you very much, Brian.

19 MR. DOUGHERTY: Thanks Jim. As Jim

20 mentioned, my purpose is to give you some background

21 to get us started. And before I do that, I just want

22 to drop back and first look at the purpose and goal of

23 first hour rating. And part of that carries over a

24 definition.

25 I will give you a brief history because

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
22

1 this thing does have a history. It has been revised

2 over the years. And at that point, I am going to drop

3 back and then hopefully open it up to the floor and

4 actually maybe call on some people at that point, as

5 far as options on water heaters, on first hour

6 ratings.

7 Should it be maintained in its present

8 structure? Slightly modified? Should we abandoned it

9 and put in alternative sizing descriptors? And then

10 once we get to a decision on which way to go, we can

11 look at the methods in detail to figure out in nuts

12 and bolts how they need to be changed.

13 When this thing came into being, it was

14 looked at in the late '70's and finally was made

15 official in '79, the goal was to providing sizing

16 information and a means for comparing different units.

17 There was a discussion back then to try and figure out

18 what a 30 gallon gas compares to and what two element

19 electric or single element electric compares to.

20 Also a big discussion back in the late

21 '70's was there was a time when FTC labeling was

22 coming along and the FTC was looking at using storage

23 capacity as a means for making comparisons. And the

24 question was, was there another description that could

25 be used, and first hour rating was pushed head to be

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
23

1 that descriptor.

2 First hour rating is something that is a

3 single descriptor that's more than most features, it

4 doesn't have multiple parameters and it embodies a few

5 things. One is the storage capacity of the water

6 heater. The second thing is the recovery capability

7 of the water heater. And that actually comes in two

8 forms. One, your heat input, but also where you place

9 that heat input.

10 A definition as it appeared in the back of

11 the '95 Code to Rule Making. It is an estimate of the

12 maximum volume of hot water, and you have to define

13 what hot is, that can be supplied within an hour,

14 that's the magic time frame, that begins with the

15 water heater fully heated. The thermostats are cut

15 off, you've got a fully heated tank, now you start the

17 one hour period.

18 As to the history. Since '79, this thing

19 has been looked at several times as to how it can be

20 tweaked and changed to try to come to some kind of

21 test procedure that actually comes close to meeting

22 the definition. And there is a reason behind these

23 revisions and I will note a few here.

24 One was try to add temperature corrections

:25 to minimize the effect of mixing. If someone had more

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
24

1 mixing occurring, they could potentially get a higher

2 first hour rating. So there was an attempt to have a

3 correction to negate that mixing advantage.

4 And also something that's very real in the

5 lab is you have to deal with testology. You are

6 allowed to have your thermostat cut off between 130

7 and 140 at present. And you are allowed to have your

8 inlet temperature vary between 56 and 60 degrees

9 fahrenheit. And because of those tolerances, they

10 have an impact of the final result.

11 And so if you start out with your

12 thermostat at 130 and your inlet temperature at 160,

13 you will get different results potentially than if you

14 had it at 140 and at 56. So there was methods looked

15 at to how you could correct for that, in fact you have

16 all it in test homes.

17 Another factor was to avoid overstating

18 ratings. There was a question of whether or not you

19 should get credit for something you get during the

20 hour, that doesn't really produce hot water at one

21 hour, but at a time after one hour.

22 There was also, at one point, a

23 repeatability problem that was an issue that

24 unfortunately, based on the test made a decision of

25 whether or not to draw or not to draw and that had an

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
25

1 implication as far as changing significantly the

2 outcome of the first hour rating.

3 And most recently, is to avoid the

4 understating tests, or the both the overstating and

5 understating. Unfortunately the test method wasn't

6 consistent with the definition which was what can you

7 do in one hour?

8 Where is first hour rating referenced?

9 Well it is used by FTC, as I mentioned. It was

10 implemented in '79, with their method for guidelines

11 or labeling program. It actually appeared in a HUD

12 document as far as FHA minimum requirements for water

13 heaters. They give things like number of bathrooms,

14 number of bedrooms and what supposedly your first hour

15 draw should be.

16 And it has been offered as a guideline,

17 not a requirement within some of the building codes,

18 BOCA, it is discussed in ASHRAE, their handbook

19 section on applications, Chapter 45, I think it is

20 now. And the GAMA Directory tries to show a person

21 how you would use the descriptive for in fact sizing.

22 It goes through and gives you an example

23 in a table what would be a typical shower usage, what

24 would be a typical hand washing usage, and you are

25 supposed to consider your peak hour usage.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
26

1 And one of the questions that I have for

2 you and the manufacturers in particularly and I was

3 talking to Jim Lutz about this, is that the first hour

4 rating used by the manufacturers in any kind of sizing

5 guidelines? Would anyone care to comment on that? Is

6 that in fact a component used in providing some of the

7 information on how to size it, as provided by the

8 manufacturer? And do manufacturers use it as far as

9 in providing information on the water heaters too?

10 MR. STANONICK: I think the more

11 appropriate question may be is what the opinion is as

12 to what extent unfortunately sizing even occurs in

13 residential.

14 MR. DOUGHERTY: I've got that next.

15 (Laughter.)

16 MR. KUSTERER: I'd like to comment on

17 that. George Kusterer with Bock Water Heaters. We

18 offer that information in our Engineering Manual for

19 both residential and commercial application. So it is

20 available to the consumer, to the installer, to the

21 Engineer who specifies the equipment.

22 So that first hour recovery is used in

23 some cases for sizing and that is made available to

24 them.

25 MR. DOUGHERTY: And as Frank mentioned --

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
27

1 in the back?

2 MR. MILLER: I just wanted to make a

3 comment. Rick Miller, Rheem Manufacturing. As George

4 points out, first hour is used in our literature as

5 well to provide that information to the consumer.

6 When you consider that the majority of domestic water

7 heaters sold today is a replacement, homeowners are

8 just typically looking to replace what they've had.

9 Unless the water heater that's failed

10 isn't providing them enough hot water. In such case,

11 they might look at first hour rating to re-size their

12 water heater. But by and large, it is generally not

13 used.

14 MR. DOUGHERTY: Your comments are

15 consistent with an ASHRAE forum that was in San Diego

16 and I can't remember if that was '95.. They had it on

17 sizing information and Jim was the Moderator. And

18 they kind of touched on this point. To spite the

19 noted references, is first hour rating really being

20 used as a sizing descriptor is questionable.

21 In new construction, the purchasing

22 decision is more often is even made by the builder or

23 the homeowner. 'If the builder makes it, it is a use

24 rule of thumb. And the fact is, for a regular size

25 house if they put in a 250 electric and if it's gas

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
28

1 they'll put in a 40 gallon. They have a high water

2 use appliance, like a hot tub, they will size up. Or

3 if it is a premium house they will size up,

4 potentially.

5 Replace market, just like you said, the

6 purchasing decision here is more the plumber or the

7 homeowner. And again, the first hour rating is

8 probably not considered. It is usually often a panic

9 situation where you want to get hot water back in

10 service and you find out what you have and you call

11 and say, do you have this?

12 So you typically get the same size and

13 type of unit that is presently installed. The closest

14 match to what is in stock, what is on the truck, you

15 want hot water back. And you mentioned, potentially

16 if you are having a condition where your kids are

17 draining down the hot water, you may say, can we go a

18 little higher so I can get my shower and not be cold.

19 So with that all in and just go back to

20 the first one and just say at this point in time, to

21 state our opinions on first hour ratings and maybe

22 even before that I will defer to Carl, if he'd like

23 to, and speak on what he can provide us before the

24 meeting as far as sizing.

25 Any opinions anyone wants to speak up

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
29

before I pass it over to Carl? Frank.

MR. STANONICK: If I could, Frank

Stanonick again. I just want to mention that we kind

of use or try to use first hour rating in our

directory as a guide to consumers. And I think, just

so everybody understands what we do there, is we tell

them to try and estimate what's the most water they

are going to use in an hour, and then find the water

heater that has a comfortable first hour rating in the

certain range of that.

The main, well, the reason for that is

first of all, we want people that are truly going to

shop for water heaters, we want them to compare

comparable water heaters. It is not to their

advantage to, you know, at one point look at a 30

gallon and then at another point look at a 50 and

think that both of these are going to -- one of them

isn't going to fit the needs, or whatever.

But, the thing about that is that, all

right, we are looking at this and is you look at that

chart and if you estimate, for example, the numbers we

are using, two showers and just any other usage, you

very quickly get up in the 50's and 60's in terms of

an hour load, all right.

Any time, if you do that calculation and

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

 EE-RM-94-230 COMMENT 49P
30

1 just try and estimate, you know, just for yourself.

2 Okay, what might be my worst case usage? You start

3 approaching numbers that are comparable to the daily

4 average hot water usage that's in the test procedure.

5 Okay, my point is that we use a very conservative,

6 that's a very conservative method of rating.

7 Because in fact in a lot of situations,

8 people will be coming up with an estimate that is

9 close to what would be the total daily usage, at least

10 what appears to be accepted as a kind of okay number,

11 and yet this is supposed to in an hour. And we do

12 that on purpose. Again, the idea here is nobody has

13 even complained because I had too much hot water.

14 There have been plenty complaints when

15 people don't have enough hot water. And so my point

16 is that we've structured that and we've used that

17 number in a conservation fashion to, first of all,

13 make sure people look at the same units when they are

19 trying to decide, if that's what they are doing. And

20 the other part of that is again, it does tend, if

21 anything to --

22 MR. DOUGHERTY: Make them think.

23 MR. STANONICK: Well, make them think and

24 also make sure, you know, it goes to the end of making

25 sure they'll have enough hot water.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
31

1 MR. DOUGHERTY: Yes, please, hand over

2 there.

3 MR. KUSTERER: George Kusterer with Bock

4 Water Heaters. I have mixed emotions about the first

5 hour recovery rating since I think in some cases, and

6 I know some of my colleagues are here. We are using

7 water heaters more and more nowadays in a combined

8 appliance application, where we are using it for

9 heating as well.

10 And I think it is extremely important,

11 like I say, we provide the first hour recovery listing

12 as our colleagues do, so that the Contractors can see

13 exactly what their requirements are first hour and

14 again to the consumer to make a comparison on the

15 units they are going to select. Obviously this is

16 with gas and electric equipment.

17 So, and again we are in an age when we are

18 dealing with this type of equipment, gas and oil19 fired, you know, this is not a throw away item

20 anymore. This is an investment. Especially when we

21 are using it in a combined appliance. So, I think

22 that ought to be taken into consideration.

23 FACILITATOR RABA: You had a question?

24 MR. RANFONE: Jim Ranfone, American Gas

25 Association. In terms of the first hour rating and

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
32

1 our experiences, we've had in our publications made it

2 available the policies and procedures because we do

3 think sizing is important. And I maybe not the, you

4 know, the wherewithal to size a water heater, but it

5 is certainly than what is out there today in terms of

6 trying to go by gallonage alone.

7 We think that proper sizing is very

8 important. You mentioned that the building codes do

9 use those guidelines and I believe that anybody could

10 do that, so it is going to be enforced, even though it

11 is a guideline. And the reason for it to properly

12 size that water heater. Because we had the experience

13 where consumers would, because they were running out

14 of hot water, start turning up thermostats. And

15 that's the last thing that you want.

16 So we don't want to throw the baby out

17 with the bath water.

18 FACILITATOR RABA: Good analogy. Any

19 other questions or comments, please?

20 (No response.)

21 FACILITATOR RABA: Dr. Hiller, would you

22 like to make your presentation?

23 DR. HILLER: Basically, I held my piece

24 while everyone was speaking, because we are really in

25 a position now to know what is really going on and I

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
33

1 am going to bring some clients into this issue. EPRI,

2 for the last two and a half years, has had a very

3 detailed water heating field test going on, and we

4 collect a number of channels of information.

5 We collect water draw information on a 15

6 second basis, 365 days a year. Each test site, what

7 do we have, two gigabytes a year for each test site of

8 14 single family detached residences, one apartment

9 building and two coin laundries. Today I am just

10 going to show you the single family residence

11 information.

12 So we know, with extreme detail, how

13 people are really using hot water, these were our 14

14 test sites. So we know longer have to guess, okay.

15 And let me just share some of that with you and how it

16 reflects developing hot water rating systems.

17 First of all, can we all agree that this

18 hot water delivery rating scheme, whatever it is, the

19 purpose of that is to help us select the right water

20 heater for the job without a test for oversizing. Is

21 that the objective that we are after with this? It's

22 what I've always assumed that it was about.

23 MR. STANONICK: It's effective purpose,

24 not primary to me. To me it is the secondary purpose,

25 not the primary one.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
34

1 DR. HILLER: What is the primary one, you

2 think?

3 MR. STANONICK: I think, in my opinion,

4 the primary purpose was to come up with some way so

5 that you could lump together comparable models so that

6 our friends at FTC could develop labels that would

7 identify models that were similar in capability and

8 you would compare those.

9 DR. HILLER: So it was not an issue of

10 selecting one versus another based on that rating?

11. MR. STANONICK: Again, I think that is the

12 secondary purpose and slash benefit. But I would say

13 if we didn't, if the FTC Energy Guides weren't looming

14 on the horizon, I don't believe there would have been

15 a first hour rating in the test procedures. My

16 opinion.

17 DR. HILLER: Okay. I agree that's an

18 issue. Let me just say, by the way, I think we all

19 know that the plumbers figure it out, what works and

20 what doesn't, quite a while ago. Everything we do is

21 kind of secondary to what the plumbers know works. A

22 lot of what I am going to show you today, is going to

23 show you why the plumbers knew what to do.

24 They figured this out with out having all

25 this data. You put enough water heaters in and you

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
35

1 listen to enough complaints, you figure this out. Let

2 me just show you data from a few of our test sites.

3 I've got all 14 of them here. We've got the whole

4 package of 14, has been copied, if it hasn't been

5 distributed, if will in plots that I am about to show.

6 FACILITATOR RABA: The handouts will be

7 available at the break.

8 DR. HILLER: What we did, we took all of

9 our raw data for every site and in moving with our

10 average, remember we have a 15 second resolution on

11 our drawing. We did a 15 minute' moving window

12 analysis. We looked at, every minute, we looked at 15

13 minute segment and looked at the water consumption in

14 that 15 minute window. And we moved throughout the

15 day and figured out what was the maximum gallons in

16 the highest 15 minute period.

17 And then we did that for a 30 minute

18 window, and a 45 minute window, and an hour window,

19 and a two hour window, three hour window, four hour

20 window, five, six and so on. And if you do that, you

21 get numbers of occurrences of gallons in different

22 time limits. And what we, it took us a while to

23 figure this all out. And this really crystallized for

24 us in the last couple of weeks.

25 You haven't seen a lot of this presented

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
36

1 in the ASHRAE, but this finally all jelled for us.

2 What you can do with all that information, is you can

3 create plots of draws of a certain magnitude in a

4 certain time window, not exceeded more than. And what

5 we've got here on this lower line, this is for one

6 particular customer. This lower line is, they do not

7 exceed this number of gallons, this is cumulative

8 gallons from the start of the window, more than once

9 a day.

10 Here they do not exceed this number of

11 gallons more than once a week. And here, more than

12 once a month. So, what's this saying? This is saying

13 that this moving window averages, so this encompasses

14 all the hours in the day. This customer, and this is

15 typical, most of their consumptions happened down here

16 in the 30 to 45 minute time, that there are large

17 jumps of consumptions, and then they tail off.

13 And we all know that. We take showers in

19 the morning and then we go to work. That's how it

20 works. We do the laundry and then we stop. And then

21 maybe we do a little laundry further on. So what

22 we've got here, is true, actual, from the field data

23 of how people use hot water. And what they don't do.

24 And what this is telling us is that this

25 customer never uses more than this once a month,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
37

1 twelve times, this is a year's data. Yeah, this is a

2 true year's data here. So that meant they use water,

3 say at a one hour time frame, they used more than 37

4 gallons in a one hour time frame, less than once a

5 month.

6 So anything down here is less than once a

7 month occurrence. Anything above this line, is less

8 than once a week occurrence. Now we know from our

9 test data and watching how people use hot water, we

10 know what they consider a hot water run off to be.

11 And that delivery temperature happens to be between

12 105 and 110 degrees.

13 And we've done independent tests where you

14 can stick people's hands in the water and they tell

15 you whether it is hot enough or not.

16 That comes out with the same answer.

17 People's definition for human uses. One hundred five

18 to 110, anything less than that, they start thinking

19 it is not warm enough. Anything above that is warmer.

20 Let me show up some of the other plots and then I will

21 come back and make some points.

22 That customer, by the way, happened to be

23 a 28 gallon per day on a yearly average. A small use

24 customer. Mind you, in our test set, in our test

25 program, we tried to find large families. These are

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
38

1 all typically families of four. There were a couple

2 that were families of three. These are four or more

3 people. This guy is real conservative.

4 MR. STANONICK: Explain again what this

5 tells you? This says, for example --

6 DR. HILLER: This tells that they are

7 really using hot water. This says that at 15 minutes,

8 they almost never use more than 3 gallons, at an hour,

9 they almost never use more than 37 gallons,

10 cumulative, over that hour time period.

11 MR. STANONICK: All right, all right.

12 DR. HILLER: And in four hours, it is 48

13 gallons. This is a low use customer.

14 MR. STANONICK: Right. But it is saying

15 that there is at least one situation once a month

16 where in a 15 minute period they did use 30 gallons?

17 DR. HILLER: Right. This line is not

18 exceeded more than 12 times a year.

19 MR. STANONICK: Right, right, okay.

20 DR. HILLER: This line is not exceeded

21 more than 52 times. And then the daily, this line is

22 not exceeded more than 365 times.

23 MR. STANONICK: So the daily line says

24 that --

25 DR. HILLER: Your average consumption --

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
39

1 MR. STANONICK: At least once a day, let

2 me make sure, at least once a day they have a 15

3 minute draw that is roughly seven gallons?

4 DR. HILLER: Right.

5 MR. STANONICK: At least once a day they

6 have a half hour draw?

7 DR. HILLER: Cumulative.

8 MR. STANONICK: Okay, so it is

9 including --

10 DR. HILLER: Cumulative. It includes the

11 15 minutes. These are the, our edge of the envelope,

12 all right. These are not exceeded, these bins are not

13 exceeded more than once a week, once a month or once

14 a year. It took us a while to figure out how to plot

15 this, because real consumption, of course, is jumping

16 all over.

17 But it really helps to understand what the

18 outer edge of the envelope looks like for sizing

19 purposes.

20 MR. KUSTERER: George Kusterer from Bock.

21 I am a poor Pennsylvania farm boy. Do these people

22 bathe more than once a month?

23 (Laughter.)

24 MR. KUSTERER: I'm missing something here.

25 DR. HILLER: Well, let me show you a more

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
40

1 typical customer.

2 MR. KUSTERER: Well, you are saying, you

3 saying this is a typical family of four?

4 DR. HILLER: I'm saying, we tried to --

5 MR. KUSTERER: How many people lived at

6 this test site?

7 DR. HILLER: Four.

8 MR. KUSTERER: Okay, great water in that

9 place.

10 DR. HILLER: When you see consumptions

11 like this, you can almost bet that they have a health

12 club.

13 MR. KUSTERER: Or a health problem.

14 (Laughter.)

15 DR. HILLER: And it may have been cold

16 water, I mean, they wash in cold water, they don't do

17 very many hot water. They may have a young child.

18 This is low. Even my family of four isn't that low.

19 My family, I've got my house instrumented and I'm

20 around 40 or 45 gallons.

21 MR. KUSTERER: And Carl, you were

22 measuring flow coming out of the water heater, right?

23 DR. HILLER: Right.

24 MR. KUSTERER: Well, even if they had some

25 other kind of semi-exotic auxiliary means to get hot

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
41

1 water, it still would come through there you would

2 think.

3 DR. HILLER: Anything that this water

4 heating device was using. And these are the water

5 heating devices for the homes.

6 MR. DOUGHERTY: Brian Dougherty from NIST.

7 Carl, did try to doing any kind of normalization for

8 outlet temperature, inlet temperature?

9 DR. HILLER: We have not yet done the

10 temperature normalization, that's the next step in

11 this analysis. Right now this is all water at

12 whatever temperatures. And we do know what the

13 temperature was at each 15 second or minute average

14 interval. It really doesn't mean any, the temperature

15 reading really doesn't tell you anything unless the

16 draw is at least a minute long.

17 But we know what the temperatures were, I

18 can present that information parenthetically. By the

19 way, this test program, this is just the summary data

20 for the first eight months of that test. Was

21 distilled down from 17 volumes or so, just to give the

22 summaries. In the two and a half years that we now

23 have, the full data set if we were to print out, would

24 be at least 40 volumes or so.

25 Thank heaven for computers and gigabytes

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
42

1 and inexpensive storage.

2 MR. BEGOSKE: Tim Begoske, Effikal

3 International. Did they have low consumption water

4 heads on all their outlets?

5 DR. HILLER: That customer was an extreme

6 conservative. We had, we had it turn out that we had

7 two families like that in the test program. Even

8 though, you know, when we surveyed the particular

9 sites, we were looking for people who were going to

10 use a lot of hot water, we thought. Because we wanted

11 to test the envelope of what certain devices would do

12 when we played with the different heating rates,

13 etcetera.

14 Here is another customer and this is more

15 typical, they had 63.1 gallon per day average

16 consumption. Their slope is a little higher down at

17 the beginning. All the curves look like this. They

18 all kind of go up in the first hour or 45 minutes and

19 then they start to level off. And that's how people

20 really use hot water.

21 MR. DUCH: Adam Duch, Group Thermo. Did

22 you have any houses at all that have --

2:3 DR. HILLER: You betcha, we're getting

24 there.

25 FACILITATOR RABA: Your name again, sir?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
43

1 MR. DUCH: Adam Duch, Group Thermo.

2 FACILITATOR RABA: Thank you.

3 DR. HILLER: We are going to get into some

4 interesting ones here now.

5 FACILITATOR RABA: We have a microphone in

6 the back there too, if anybody would like to use that.

7 It is standing there by the pillar.

8 DR. HILLER: Now I am going to go to the

9 ones where it really starts to get interesting where

10 you've got some higher consumptions. This family,

11 this is eight months to the beginning of the year,

12 83.4 gallons per day, average consumption. And this

13 is how they use hot water.

14 I am setting these plots aside, because we

15 will come back to them and do some other stuff with

16 them in a minute. Here is people with a spa tub and

17 three teenage daughters with long hair. And they were

18 our champion. They were 124.3 gallons a day average

19 consumption.

20 And they emptied, they used that spa about

21 once a week. And that empties a 50 gallon water

22 heater just to fill that tub. It takes a whole tank

23 just to fill that tub.

24 And we will come back in a minute and I

25 will show you some things that are interesting about

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
44

1 this site. But again everybody, regardless if you

2 went from 28 gallons a day to 124 gallons, that was a

3 100 gallons a day difference. They all have the same

4 characteristic. They use a fair amount of hot water

5 in the first half hour or 45 minutes and then they

6 start to tail off. These people happen to use more,

7 you know they are still thought here as steeper than

8 the typical customer, because they use more hot water

9 throughout the day than the typical customer. Or a

10 little less clustered and a little more spread out,

11 because, and that is part of why they use so much more

12 hot water.

13 Now one more site of interest, I will set

14 these all aside and come back to them, here was 76.6

15 gallons per day. Let me just show you something

16 interesting. Here is the 83 gallons a day, and here

17 is, I am going to overlay that now with 76 gallons a

13 day. Look what happens in the beginning. In the

19 beginning, it is the lower consumer actually has

20 higher water use in the beginning time period.

21 It is hard to tell that unless I move them

22 around a little bit. But then it levels off. So this

23 higher line is from the 83 gallon a day person. This

24 lower line is from the 76 gallon a day person, but

25 their consumption in the early time frame is higher.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
45

1 So that consumer with the smaller water consumption,

2 actually needed a little bit bigger water heater than

3 the larger consumption. Just because of the way they

4 use their hot water.

5 Their water use was a little bit more

6 clustered when they used it. And that gives us some

7 interesting comparisons to do. And so that's real

8 data. That's how people really use hot water. That's

9 the outer edge of the envelope. By the way, we do

10 know, we collected customer satisfaction surveys on a

11 monthly basis from all these customers as we played

12 around with their water heaters and stuff like that.

13 MR. LIU: Stanley Liu, NIST. You remember

14 that there is a wide difference in the customer

15 setting are they are pretty close to the same?

16 DR. HILLER: The different customers, you

17 mean?

18 MR. LIU: Yes.

19 DR. HILLER: We have all that data. The

20 lowest customers are typically around 120, the highest

21 were about 135. Most of them kind of hovered around

22 127 to 132. This is what they set it at.

23 MR. LIU: Most times have customer setting

24 at 150 or 160.

25 DR. HILLER: The assertion that people set

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
46

1 their thermostats up that high is an invalid

2 assertion, with the possible exception of single

3 element tanks. And we will come back to that and I

4 will show you why, okay?

5 MR. KALISCH: Bert Kalisch, AGA. What

6 about the size of the tanks that were used. Were

7 there various sizes or all the same?

8 DR. HILLER: We are going to get there.

9 What I am about to go into now starts to do that. But

10 I wanted to show you that we have real data and we

11 know how people are really using hot water in the

12 field. And we know this is an interesting period of

13 time.

14 And when you think about your own life, we

15 are all the same way. People tend to cluster their

16 water usage. You take a shower, you do a little

17 laundry and then you don't do something for a while,

18 you don't do as much for a while. So your

19 consumptions tend to be more clustered on a cumulative

20 basis over a short time period.

2: And indeed, that's what drives the size of

22 your water use. And I am going to show you that.

23 MR. PAUL: Darrell Paul. Were all of

24 these water heaters electric units?

25 DR. HILLER: Yes.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 2344433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
47

1 MR. PAUL: Okay. I know when my wife was

2 living in an apartment and we had an electric water

3 heater, we changed our behavioral patterns. She would

4 take a shower first thing in the morning, I would go

5 down and make a pot of coffee and have breakfast and

6 I would take a shower after breakfast. Simply because

7 if we both took a shower at the same time, we might

8 run out of water.

9 Whereas now that we have a gas water

10 heater, we both take a shower consecutively. So

11 behavioral patterns will change depending on people's

12 experience with the water heater. So I guess what I

13 am getting at is, I'm not sure you can generalize your

14 results to the population as a whole, since it was

15 only focusing on electric water heaters.

16 DR. HILLER: I knew that issue would be

17 brought up at this meeting. You are right that within

18 a certain range people will adjust their use patterns,

19 if a relatively minor adjustment in the way they

20 behave will make any problems go away. If it was a

21 major problem, they won't do it. They will get a new

22 water heater. But if it is a minor problem, then they

23 do it.

24 We do have customers that have extreme

25 storage capacity. One of the customers, I didn't show

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) . . 234-4433 WASHINGTON, D.C. 20005-3701 (202) . 234-4433

 EE-RM-94-230 COMMENT 49P
48

1 it up here, one of these customers had a dual tank

2 system, 100 gallons of storage with a natural

3 convection. One tank actively heating, passively

4 heating the other tank by natural convection. They do

5 not change their patterns.

6 They never run out of hot water, they

7 almost zero ran out through the test, and their

8 patterns look just like these. So it is not nearly as

9 strong an issue as you might think it is. People are

10 not really, based on the consumption we see, are not

11 changing their patterns. Some of these people never

12 come close to running out of hot water. A few of them

13 do, most of them don't.

14 Hot water run outs are fairly rare

15 occurrences if your water heater system is sized

16 properly. And we are going to come into that sizing

17 issue in just a minute. How we can figure out with

18 this information what size water heater --

19 MR. PAUL: There were 14 units that you

20 tested?

2:L DR. HILLER: Fourteen different

22 residential units. And we would love to get more

23 data. And one of the things maybe we can get out of

24 this meeting is get some collaborative effort together

25 to get more of this data. We've been working on less

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
49

1 elaborate data acquisition systems that can still get

2 high resolution and the draw information and a lot of

3 the other channels that we are collecting. But we

4 don't need that to get the water information.

5 We would love to get more information like

6 this and collect more information about, you know, the

7 number of people and ages and appliances and do some

8 statistically valid stuff that can create some draw

9 patterns like that that are statistically

10 representative. I don't claim that our 14 sites are

11 statistically representative.

12 I do claim that due to their similarity

13 there are some general conclusions that can be drawn.

14 But you are right, people will change their use

15 patterns a lit2le bit. But it is not as big an issue

16 as you would think. Another comment here?

17 MR. ROSENSTOCK: No, I was just going to

18 say that -- Steve Rosenstock, Edison Electric

19 Institute -- part of the usage pattern and also

20 sometimes a function of, in terms of the people in the

21 residence and it is probably the same with both

22 electric as well as gas water heaters, that people

23 will just in case, well, we won't take showers at the

24 same time, we will do it one after each other just to

25 be on the safe side.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
50

1 It is really, you know, I don't know if

2 studies have been done on it, but there, I'm sure

3 there, like Dr. Hiller was saying, there are a lot of

4 people out there who just won't take the risk of

5 getting the cold blast in the morning.

6 DR. HILLER: And if you look at, for

7 example, that 28 gallon per day customer. They do

8 take showers at home. And they never come close.

9 They've got a 50 gallon water heater, and they never

10 come close to running out of hot water, the way they

11 shower. That is just their behavior. I mean, I have

12 some renters, I have a rental property and I had one

13 renter in there for a while.

14 I finally had to kick him out, because he

15 kept doing this. And he kept complaining about my

16 water heater, and it wasn't providing adequate hot

17 water and he kept cranking the thermostat up, to the

18 point where it popped the T & P valve all the time.

19 I had constant battles with the guy.

20 It was a gas water heater. And the guy

21 cranked the thing up until it blew the T & P valve

22 every day, which is a tremendous scald potential for

23 the other people in the house. So I kicked him out

24 when he wouldn't listen to me. And I watched his use

25 patterns, I was there. And he would get into the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
51

1 shower, he would drain the tank completely, get out of

2 the shower, wait ten minutes and get back in again.

3 And he had no clue that he was six sigma

4 out of the norm in the way that he used hot water.

5 That was life to him, that was the way it was. As far

6 as he was concerned, that was the way everybody took

7 showers. But he was way out there. And I kicked him

8 out because he turned the temperature up on my gas

9 water heater to dangerous levels.

10 MR. STANONICK: If he turned it up on your

11 electric water heater it would have been dangerous

12 levels too, right?

13 DR. HILLER: That wouldn't have made a

14 difference, gas or electric.

15 MR. STANONICK: Thank you.

16 DR. HILLER: It was his use pattern to

17 turn the temperature up, not the water heater type or

18 size.

19 MR. KUSTERER: George Kusterer with Bock.

20 Had you had the first hour recovery on that rental

21 property, as published by a lot of the manufacturers

22 and it was properly sized, you wouldn't have had that

23 problem.

24 (Laughter.)

25 DR. HILLER: The water heater was properly

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
52

1 sized. For that application it was, I could have

2 given him a tank three times the size, he would

3 have --

4 MR. VAGO: You don't want to buy that big

5 a water heater.

6 DR. HILLER: Well, I don't want to supply

7 a customer --

8 MR. KUSTERER: I think that there are

9 tremendous concerns and again I feel that depending on

10 the appliance, whether it be gas, electric or oil,

11 they are all different, obviously. The recoveries are

12 different and we all know that. And therefore if you

13 are living with something, such as electric, and then

14 go to gas or vice versa, or an alternate fossil fuel,

15 your lifestyle will change'because you must correct

16 that lifestyle in order for you to live.

17 DR. HILLER: Within limits.

18 MR. KUSTERER: Within limits, okay. So it

19 is extremely important that we realize that, and I

20 guess everybody does. Like I say, I apologize for

21 being a poor dumb farm boy, but this is not the norm.

22 This is strictly electric. It does not take into

23 consideration gas or oil. And, you know, I am

24 concerned that we are going in that direction.

25 DR. HILLER: I would love to see more

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
53

1 information like this from fossil burning water

2 heaters. I just don't have it. I am pretty willing

3 to bet, based on the customer base that we had and the

4 average consumptions that are represented there, that

5 the average gas customer is not going to look much

6 different than the average electric customer.

7 MR. KUSTERER: Well, I disagree.

8 DR. HILLER: Because we've got so many of

9 our customers that don't ever come close to running

10 out of hot water, even with an electric tank.

11 MR. KUSTERER: I disagree.

12 DR. HILLER: They didn't change their use

13 pattern, because they didn't come close to running out

14 of hot water in the first place. Now, we are not

15 going to resolve that issue until we get the data, so

16 we can agree to --

17 MR. KUSTERER: Okay, my point is in order

18 to have a fair playing field, how are we going to get

19 that data?

20 MR. DUCH: Adam Duch, Group Thermo. I

21 believe sir that if you are living on Long Island with

22 17 cents per kilowatt electric rate versus gas and you

23 use 15 minute showers like your friend there in the

24 house, you will change your living patterns, because

25 the cost is just astronomical.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
54

1 DR. HILLER: You'd probably get rid of

2 your electric water heater at 17 cents a kilowatts, is

3 what you would do. Now let me come back to the tank

4 issue now for a second and this will all start to come

5 together.

6 What we've done here is we have done some

7 very simple crude analysis. And you can do this more

8 refined, but for purposes of this presentation and

9 understanding these issues, we did it simply. Looking

10 at how much hot water, different types of water

11 heaters can deliver the function.

12 In this case, this lower line is a 50

13 gallon single element tank with a 4500 watt element.

14 The blue line is a 50 gallon dual tank with two 4500

15 watt elements. The green line is 50 gallon gas water

16 heater with 35,000 btu per hour firing rate, .76

17 percent input efficiency.

18 The red line is an 80 gallon dual element,

19 dual 4500 watts. And if you look, and this is kind of

20 an estimate of hot water delivery. What we assumed

21 here was the.first draw can give you 90 percent of

22 actual tank volume. And then there is some time lag

23 ; while you reheat the water once you've taken that

24 first draw and before you can get any water or use

25 potential out of it.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
55

1 In this case, we are using 110 as the

2 temperature we had to reach before we took more water,

3 and we've got different plots for 135 versus 110. And

4 there is a number of interesting characteristics that

5 come out, let me just point them out. You will note,

6 that regardless of how you plot this and what

7 temperature you use and whatever assumptions you want

8 to make, there is a region, and note these are all

9 roughly the same size.

10 We used 90 percent, we assumed that the

11 actual tank volume was 90 percent of nominal volume,

12 well it is not quite, it is 95 percent for possible

13 argument. But it is probably not enough to really

14 show up on the curve. And it will be assumed that 90

15 percent of that actual volume was usable before it

16 dropped in temperature.

17 Several characteristics. You see, first

18 of all, single element tanks take a long time to

19 recover because they've got to heat the whole tank.

20 You see, the dual element tanks don't take nearly as

21 long to recover, but they don't recover as much. All

22 right, they are only heating the upper 25 percent or

23 so.

24 You see that fossil water heaters, because

25 they have so much higher heating input rate, this is

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
56

1 like a 10KW input rate, so it would be like a 7600

2 watt input rate to the water, 3413 btu per kilowatt

3 hour. And this is 3413 instead of 35,000, that would

4 be a 10KW firing rate and at 76 percent efficient, you

5 would a 7600 watt input rate. So it is not quite

6 double the input rate of a 4500 watt element. But you

7 empty it, and you can only get so much hot water. And

8 then you've got to wait until that whole tank gets

9 heated up again, then you get another bunch. Then you

10 wait some more, get another bunch. Wait some more,

11 get another bunch.

12 There is a region of time where how you

13 plot this, where the same size water heater, dual

14: element tanks have a region of time where they can

15 provide a little bit more hot water sooner than the

16 much higher firing rate of fossil water heaters.

17 That doesn't happen by accident. The

18 water heater manufacturers figured that out a long

19 time ago. And they figured out therefore, to give

20 adequate performance of electric water heaters, they

21 figured out where to put their upper elements, and the

2:2 fact that they needed upper elements to do that.

23 So that was not an accident. That was

24 design feature that the water heater manufacturers

25 built into to their electric water heaters, by

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
57

1 figuring our where to put the elements and how big

2 they had to be. Okay. Let me just show you for a

3 second, if you had 135 degrees, it just takes a little

4 longer to reach the temperature before you take the

5 draw.

6 So this is assuming that you take the draw

7 only when it reaches 135. This one was assuming you

8 took the draw when it reached 110. By the way, this

9 plot would be the same plot, regardless of the initial

10 temperature for the first draw. You look, it would be

11 the same number of gallons whether it was 135 or 110.

12 This is just looking at how long it took to reheat to

13 a usable temperature.

14 Now let's do some overlay, this is where

15 it starts to get interesting. Let me overlay first a

16 28 gallon per day customer, they had a 50 gallon water

17 heater, and look what happens here. We see that their

18 consumptions are so low, that even a single element

19 tank, they have never run out of hot water. To be

20 honest it is above the once a month curve. They

21 didn't need a water heater that big.

22 How big a water heater did they need?

23 Well, I've got a 30 and 40 gallon down here, let's

24 see. Here's a 30 gallon, let's see if a 30 gallon

25 would work. All right, here's our 30 gallon,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
58

1 unfortunately we didn't do that one color. You can

2 see the single element tank, the 30 gallon, hits the

3 once per week line. We know pretty much you better

4 keep the customer's uses happy with once a week. You

5 better be able to meet that load.

6 And the fact that that line crosses over

7 here, means that a single element tank would not have

8 worked for them. Looking at what the dual element

9 tank does. It, and I realize now after seeing some of

10 these, we are going to go back and plot these giving

11 five and ten minutes as well as the shape of the curve

12 down here. But a 30 gallon is probably all they

13 needed. They didn't need a 50.

14 An interesting thing started to happen,

15 though. Look where these curves start to intersect

16 and that the tank can do versus what the customer

17 needed. The interesting point which drives the size

18 for that water heater that that customer would have

19 needed, is down in this time range. Fifteen, 30, 45

20 and that always is the case, and you are going to see

21 that in a minute.

22 Let me go now, here is a 63 gallon a day

23 customer and let me put the 50 gallon tank back on

24 here. In this case, we see the single element tank

25 crosses the once per week line. A single element 50

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
59

1 gallon tank would not have been adequate for that

2 customer. A dual element 50 gallon doesn't even come

3 anywhere close to the once a month line. Fifty gallon

4 was more than adequate for that customer and so was

5 the gas water heater.

6 They happened to have an 80 at that site.

7 That's what was there when we came and we didn't

8 change it. Their tank was way bigger than they need,

9 and therefore their operating costs were higher than

10 they should have been. The tank was oversized for

11 their consumption needs. You wouldn't have

12 anticipated when you built that house that you should

13 have put an 80 in. That just happened to be there

14 when we showed up and we didn't change it.

15 They could have gotten away, now let's put

16 the 40 gallon up and see if could have gotten away

17 with a 40 gallon. Interesting, this is a 40 gallon

18 tank. A 40 gallon dual element would have worked. A

19 40 gallon gas is getting kind of questionable. It is

20 getting close to the once a week line.

21 Notice where these, so the right size

22 electric water heater for this customer, an acceptable

23 size would have been 40 gallons, 30 is probably a

24 little bit too smaller. Now clearly, a 40 gallon gas

25 wouldn't have worked there, but a 40 gallon electric

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
60

1 would have. But again, the time frame that drives the

2 necessary size for that customer is way down here, it

3 is no where near one hour.

4 And it is always that way. Let's look at

5 some bigger use customers now. Let's go to customer

6 696. This is the 83 gallons a day customer. Let's

7 put the 50 gallon water heater back up there. They

8 happen to have a 50 gallon water heater there. A

9 single element tank wouldn't have worked. You can see

10 that a single element 80 gallon, which would have come

11 out more like here, probably would have worked.

12 So if they were going to have a single

13 element tank, it would have had to be an 80. A 50

14 wouldn't have worked, but an 80 probably would have.

15 A 50 gallon electric works just fine there and we know

16 that. That customer rarely runs out of hot water and

17 they are pretty small run outs when they do occur.

18 A 50 gallon gas, again, would have been

19 questionable there. Now that doesn't always happen.

20 These are, you know, it just happens to be the shape

21 that these particular customers use hot water. Now

22 let's go down to the one with the spa tub. That's the

23 one with the spa tub and the teenage daughters with

24 long hair.

25 A single element tank, not a chance. A

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
61

1 dual element, 50 gallon is questionable. It crosses

2 that once a month line a lot. In fact, they had a 50

3 gallon electric dual element when we started. And

4 right away, early into the test, we discerned that

5 that was inadequate for that level.

6 Similarly, a 50 gallon gas, if they had

7 had one, would have been inadequate for that level.

8 Clearly, it crosses the once per week line. A 50

9 gallon electric would have been a little bit better

10 than the 50 gallon gas under that customer. We took

11 it out and gave them an 80 gallon dual element and

12 then we stayed way above their operating range, and

13 they never run out.

14 Now what happens here? Once a week they

15 are using their spa tub, at least once a week. And

16 they are emptying, in a very short period of time,

17 that tank to fill the tub. That's what's going on.

18 And that's why even with a much higher firing rate of

19 a fossil fire water heater, they will run out of hot

20 water.

21 Because you are not providing a heating

22 rate anywhere near fast enough to heat water real

23 time, so you empty the tank. Here is an example of a

24 customer who needed a bigger tank and we gave them a

25 bigger one. It is the only one in the test program

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
62

1 where we did that. Now let's go on to the last

2 customer. This is the 76 gallon per day customer.

3 They too happened to have a 50 gallon

4 water heater. It works. You can see there was a

5 little bit of a range here, where we are still above

6 the once a week line, we are below the once a month

7 line. We don't know, and it is somewhat a function of

8 the customer, as to whether or not this is important

9 to them or not.

10 A lot of these having to do with machines,

11 and the customer never knows it. When they are down

12 in the range where they are going to get a few run

13 outs. Fifty 50 gallon gas here, and again for that

14 customer, and these are high use customer. The

15 average customers, none of the tanks came close to

16 running out of hot water. These are high use

17 customers, above the norm.

18 Fifty gallon gas would have been

19 questionable. Fifty gallon dual element electric

20 works, a single element wouldn't, 80 gallon would have

21 been overkill. Now, that brings us back to, and again

22 you can see, the point where we cross, what determines

23 the necessary size of the water heater to keep that

24 customer happy, is down here, 15 minutes, 30 minutes.

25 That's what plumbers learned a long time ago.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
63

1 If you took any one single factor for

2 determining the necessary size of the water heater

3 it's first draw. The reheat rate is clearly important

4 to the single element tank. It would have taken a lot

5 longer and it would have been unsatisfactory. The

6 dual element tank was satisfactory. So there is a

7 reheat issue. But lacking any other information, the

8 most dominant thing is the first draw.

9 It is not the only factor, but it is the

10 most common factor. Now, if we try and do this with

11 a single rating point, for the purposes of sizing and

12 picking out what water heater you would want to use,

13 how would we do that? So I'm trying to figure out, if

14 we went with a single rating point and number, right

15 now we call it first hour.

16 Clearly, first hour, even let's go back to

17 our high use customer, our 124 gallon per day

18 customer, where you just double the norm. Let's go

19 down to one hour. Gas water heater is way up in this

20 range, but that is irrelevant to the customer. What

2:L drove the size of that water heater happened down

22 here.

23 What they needed was driven by a much

24 shorter time frame. So clearly, if you are going to

25 come up with a number that tells you how to size a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
1 water heater for the application, one hour is not the

2 time frame. That's why you don't see any when I talk.

3 I don't say first hour rating, I say hot water

4 delivery rate.

5 It is very clear from this that even a

6 customer that this twice the national average or even

7 then some, and I will come back to that issue later

8 on, one hour is way too long. Irrelevant to the

9 customer, from a sizing standpoint. Now if, let's

10 pick some what ifs for what time frame that ought to

11 be. If we picked, and let's say that the green line

12 was right on 30 minutes there.

13 If we picked 29 minutes, okay, as a single

14 rating point, then the single element electric and gas

15 fossil water heater would have the same rating, okay.

16 The dual element electric would have a somewhat higher

17 rating. Okay. Neither one of those would have been

18 adequate for the level. If we now go to 31 minutes,

19 the gas water heater rating goes way up far from the

20 electric.

21 It still wouldn't have been adequate for

22 the low, but would have served way more than 32

2:3 minutes than the customer needed. Now let's go back

24 to the second one for a minute. Now, something very

25 interesting happens and it shows you the problem with

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
65

1 the single rating number. We are just, you know, we

2 just happened to discover that these things happened

3 as we did this. We didn't try and make this happen.

4 Again, this is our 50 gallon gas overlay

5 here. This is a case where a 50 gallon gas wouldn't

6 have worked. A 50 gallon electric did. It just.

7 happened to be the case with that customer. If we had

8 done a rating point at 31 minutes, the gas water

9 heater would have gotten a higher rating than the dual

10 element electric, but the gas water heater wouldn't

11 have worked and the electric would have.

12 So what do you do and what's that number

13 mean to you? It doesn't mean anything. Even if you

14 have the higher rating, the customer would, there is

15 a piece of missing information in the hot water

16 delivery rating. That in a vacuum, doesn't tell you

17 anything. What you have to know and what the plumbers

18 know, the plumbers kind of know that people use hot

19 water like this.

20 They've learned it by experience and they

21 know what size water heaters work for the application.

22 So any single value rating regardless needs the other

23 piece of information, needs better information on how

24 people use hot water, in order to size the system.

25 And we tend to forget that when we are looking for a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
66

1 hot water delivery rating.

2 Even if we did the plot based approach

3 like we are doing here, that by itself doesn't tell

4 you anything. It only means something when you have

5 the consumption data to go with it. Clearly, we need

6 better consumption information. I don't claim that

7 our 14 test sites are statistically valid sample

8 sites.

9 We need to get some for fossil water

10 heaters and various types oil, gas and propane. We

11 need to get more electrics. We need to get a lot more

12 information on customer, you know, demographics and

13 appliances in the home and etcetera. If we have

14 enough of that, if we got a statistically balanced

15 sample size, different regions of the country with

16 different set point temperatures and cold water ending

17 temperatures, etcetera, eventually we could do a

18 statistical analysis to come up with some

19 representative curves that we ought to design to.

20 And that could all be built into a sizing

21 program of some sort, you know, it doesn't have to be

22 graphically like this. But you can see the down side

23 of trying to use a single number. Because here is a

24 case where the single number, even if you didn't, what

25 does that mean? The amount of water that the gas

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
67

1 water heater can provide from here to here is

2 irrelevant to the customer. Because they never use

3 that much.

4 MR. DOUGHERTY: Brian Dougherty, NIST. I

5 think your method has merit and if we had more data,

6 what would you foresee it becoming an ASHRAE handbook,

7 becoming a guideline that's available through

8 different parties?

9 DR. HILLER: For one thing, there would be

10 a sizing computer program put together that hopefully

11 all the manufacturers and stuff would use. We're

12 probably, if you look at how water heaters are really

13 sized in this country today, it is probably overkill.

14 They are probably going to keep doing what they are

15 doing.

16 And the result of that is, often times you

17 get a water heater that is bigger than you need. You

18 pay a little higher operating cost because the higher

19 losses are.

20 MR. DOUGHERTY: From the test procedures

21 standpoint then, you would have that tool there

22 eventually that would be very valuable I agree. From

23 the DOE test procedures standpoint, what would you

24 advocate? No sizing descriptor? Some kind of sizing

25 descriptor combination that supplements this

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
68

1 information, like first draw volume, confer recovery?

2 Bring it back to the test procedure. What

3 would you like to see in the test procedure?

4 DR. HILLER: You've hit the nail on the

5 head. It is hard to figure out what you should do.

6 And clearly, having a single number regardless of how

7 you come up with it, really isn't very useful. And

8 clearly we can see what, if you really want to figure

9 out the right size water heater for an application,

10 you need two pieces of information. You need these

11 plots and you need the consumption lines.

12 Are we going to do that? I don't know.

13 But that's what you need. Any single number, if you

14 have it, regardless of whether you did it on a first

15 draw capability only or, you know, 15 minutes or an

16 hour or six hours or whatever, none of those.numbers

17 mean anything.

18 MR. STEPHENS: Charlie Stephens, from the

19 Oregon Energy Office. I would like to interject one

20 thing here before we go too much farther since we seem

21 to be wandering on to it. We don't have, in the

22 northwest, quite as detailed a data as that, but we

23 have got a lot of experience working with builders and

24 plumbers in water heater and shower head programs and

25 other utility based programs, both gas and electric.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
69

1 And mostly what we've discovered is, that

2 builders and plumbers are not sizing water heaters for

3 their customers. They are not sizing it because

4 there's more people in the family. They are sizing it

5 because the house either has a spa tub or it doesn't.

6 And we all know that in a period of time that is much

7 shorter than the lifetime of most of these water

8 heaters, the customers that are in that house now, on

9 average, aren't going to be there.

10 There is going to be a new set of

11 customers, who may use the spa tub not at all, even

12 though it is there. And for them, you know, the water

13 heater that was put there is oversized. So I don't

14 think you are going to find people really sizing to a

15 family, they are going to be sizing to the building

16 and what it has in it.

17 Whether it is four bedrooms or five

18 bedrooms and can hold a much larger family, even if

19 only two people live there now, like the one I live

20 in. Or, it is a condo that may only have one bedroom.

21 They are going to look at the spa, the existence or

22 non-existence of a spa, how many showers, the

23 potential of the building to hold a lot of people,

24 even if it doesn't. And that's how they are going to

25 size the water heater when one is put in.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
70

1 So I don't know how relevant it is in

2 every case to tell how any individual customer or

3 group of customers looks. It is what are the houses

4 and the buildings that people live in look like, and

5 how many people could live there one day. Because I

6 think that's how the plumbers and the builders are

7 going to do it.

8 DR. HILLER: There is a number of us here

9 in this room today that are on an ASHRAE subcommittee

10 to look at issues like that, what sizing criteria

11 ought to be, and you are right. And really what we

12 need to do, from a sizing perspective is to get a

13 statistically balanced sample size and come up with a,

14: just like we do on temperatures, a 95th percentile

15 design consideration of some sort. It is a 95th

16 percentile customer on a statistically average basis

17 given their appliance or whatever.

18 From a practical standpoint, the plumbers

19 are going to keep doing what they are doing. They

20 know that if they give a customer a 50 gallon dual

21: element electric, actually unfortunately some

22 plumbers don't know that and there are regions of the

23 country where they are putting in single element

24 tanks, and those customers are often unhappy.

25 Dual element customers are pretty happy.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
71

1 Single element customers, you can see that clearly on

2 this thing, single element tanks take so much longer

3 to recover. And I would like to see, you know, that

4 people know that. I struggle with that issue doing

5 what I do for a living, trying to keep customers

6 happy. Any you've got to educate them. You've either

7 got to put in a dual element tank or you've got to put

8 in a bigger single element tank.

9 There are areas of the country, Oklahoma

10 for example, where the common, I don't know how this

11 got started but it is the norm and it is really hard

12 to change it. In many parts of Oklahoma, in most of

13 Oklahoma, they put in single element tanks. They

14 don't want to stock dual element tanks. And you've

15 got a lot of unhappy customers out there because of

16 that. How do we educate them to do that?

1'7 MR. LIU: You can start a drill taking

18 into consideration the number of bathrooms in the

19 residence.

20 DR. HILLER: We know, we have all that

21 information.

2:2 MR. LIU: If you have only two, then the

2:3 time frame for the three daughters, with only two

24 bathrooms, they have to take more than half hour to

25 take their shower only one at a time.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
72

1 DR. HILLER: We have the number of

2 bathrooms. We have the number of bedrooms. We've got

3 all that information. We can look at it any way we

4 want. We've got the square footage of the house. We

5 have the age and the genders and all that stuff,

6 information on all the appliances.

7 MR. KUSTERER: George Kusterer from Bock

8 again. If the plumbers know how to size water

9 heaters, than why aren't they here telling us how they

10 do it and where do they get that information? I mean,

11 is it part of their license requirement? You are

12 relying so heavily on plumbers know how to do this.

13 DR. HILLER: And in some cases --

14 MR. KUSTERER: And I don't find that the

15 case. Being an educator and traveling all over North

16 America, I am finding this is not normal, this is not

17 the truth. They are very adequate in what they do

18 with regard to replacements. But as far as initial

19 sizing, they don't size by load.

20 DR. HILLER: They don't do it

21 scientifically, that's right. They do kind of what --

22 MR. KUSTERER: Well, if they, according to

23 your statement, that they have the wherewithal to all

24 this sizing, why aren't they here telling us how we

25 should do it?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
73

1 DR. HILLER: I probably overstated the

2 case that they really know how to do it, because they

3 really don't.

4 MR. KUSTERER: Thank you.

5 DR. HILLER: Let's say they are lucky in

6 that, you know, the standard 30's, 40's and 50's tend

7 to satisfy most customer and they kind of, their rules

8 of thumb, with the possible exception of single

9 element tanks, they are lucky that they tend to work.

10 Single elements tanks that they tend to

11 work the same way and they don't.

12 MR. STANONICK: Frank Stanonick with GAMA.

13 Again, just so everybody recognizes. You keep talking

14 about a 50 gallon gas water heater. Well, you are in

15 fact talking about the 50 gallon gas water heater you

16 assumed for this analysis. Which is in fact the

17 lowest input 50 gallon that probably is out there.

18 So if we went to the other end of that

19 extreme the graph would change for that one, it might

20 change some things.

21 DR. HILLER: Clearly, you'd like to do

22 this with real draw patterns like that from some test

23 results.

24 MR. STANONICK: My only point was, you

25 know, for the brevity of your presentation, saying 50

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
74

1 gallons in some cases wouldn't do it. In fact, if

2 that 50 gallon wouldn't do it, another one might. But

3 the other, to me, the other dilemma with this is if we

4 wanted to do this right, okay, you need to know the

5 pattern, all right.

6 In most, well certainly in a new home, you

7 don't know the pattern. It doesn't have any occupants

8 yet. And even in an existing home, the only thing

9 close to knowing the pattern will be some perception

10 of the people in the house as to what they think their

11 pattern is.

12 I guess where I am going with this, you

1:3 know, this is useful information and it certainly

14 would be a more precise way to size, but you don't

15 know one end of the equation. And you never will.

16 Unless you go in and, unless we had a, change the

17 whole system. And the plumber went into the house and

18 instrumented the people's houses for a week and then

19 said, oh there's a pattern, you need this water

20 heater.

21 I guess what I'm saying is I think we are

22 looking, we are trying to grab something that is too

23 elusive. And I guess I will go back to my statement

24 that I believe it would be a better approach to say,

25 okay, let's use first hour rating or some measure that

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
75

1 is going to allow you to identify the water heaters

2 that are comparable in capability and then how that

3 might get used as sizing, will be left up to everyone,

4 I guess. As long as it is not some real far out

5 thing.

6 DR. HILLER: Let me paraphrase what you

7 said the way I say that. Let's put back our 83.4

8 gallon a day customer here. And their plot is not too

9 much different from the 76 gallon a day customer.

10 None of the rest of the houses have spa tubs, but that

11 one house. When you really size a water heating

12 system, you can't just size to the minimum customer

13 -uses that would be in that home.

14 You've got to kind of size for some, like

15 I said 95th percentile customers or something. And

16 you've got to figure out what that 95th percentile

17 customer is. And maybe it is a customer like this.

18 If we had enough data in a statistically valid sample

19 size, we could figure that out. And then say, size to

20 this pattern, based on number of bedrooms for everyone

21 and do the correlation.

22 You are right, you don't size for anyone

23 customer. You've got to size for what is likely,

24 statistically likely to work. And if you have the

25 information on the appliances, you could probably do

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
76

1 that. Clearly, a spa tub makes a big difference.

2 Because when you use it, you empty the small tank

3 completely.

4 Coming up with any single rating to do

5 this, I mean, we could come up with a statistically

6 representative curve or set of curves based on

7 appliances. It is a lot of work, but it could be

8 done. Coming back to the rating issue then, talk some

9 practicalities if you try to do a single number rating

10 approach.

11 I pointed out the differences -- it is a

12 fact, regardless of how you do this tank delivery

13 capability measurement, that a lot of the gas water

14 heater, fossil fire water heaters have a big spike

15 right in the middle of the time of interest. And it

16 is 100 percent difference in delivery.

17 If you have a rating, and hopefully I've

13 convinced you that one hour has nothing to do with

19 this issue. Now the real region of interest is a much

20 shorter time frame. But even if you did use the one

21 hour, there is still a big spike to be dealt with,

22 right in the middle of the one hour time frame.

23 It makes a big difference whether it is,

24 you know, 59 minutes or 61 minutes. But here it is a

25 third, here it is a half, relative to the unit.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
77

1 That's a 100 percent change in the delivery rating by

2 just moving one minute. Another thing that happens

3 from a practical test standpoint, is the same thing

4 happens with a slight shift in temperature or

5 thermostat behavior at some time interval that you

6 pick.

7 Let's say that you pick 31 minutes here,

8 instead of 29 minutes, so you were at what you thought

9 was going to be the other side of the curve. Your

10 thermostat, thermostats, and most are manufacturered,

11 thermostats are not very repeatable. They are pretty

12 inexpensive devices, they are adequate for the task at

13 hand. But you can't rely on them to repeat within a

14 fairly wide range of repeatability and temperature.

15 At Potomac Electric we tested 14 identical

16 tanks at the ETL Testing Lab, ran them all on the DOE

17 four hour test cycle, over and over and over again,

18 day after day after day, and looked at the

19 repeatability of the thermostat internal temperature.

20 The dead bands were much more repeatable when turned

21 on, than the turn offs.

22 But we saw a plus or minus eight degree

23 variation in the turn on and turn off temperature.

24 They are not all that repeatable. And just because of

25 that effect alone, you could be up on the other side

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
78

1 of the curve if you don't pick your tank carefully.

2 And the fact that that big spike happens right at the

3 time of interest, even the dual element tanks were

4 spiked at the time of interest.

5 From a practical test standpoint, it could

6 happen by accident, or it could happen by design to

7 gain the system. If the manufacturer, when they see

8 if we specify the 31 or 29 minute period here, for

9 example, the manufacturers could figure out fairly

10 quickly how to tweak the thermostat behavior to put

11 them on the other side, to move that spike back a

12 little bit and get a 100 percent increase in their

13 rating as a result.

14 Is that of any significance to the

15 customer? They also can tweak your heating rates.

16 Getting a rating that's way up there, versus way down

17 here really isn't what is important to the customer.

18 That's my big concern. It makes a 100 percent

19 difference in the rating on the tank, but it makes all

20 that extra capacity is useless to the customer.

2:L So what is the meaning of having that 100

22 percent higher rating? It doesn't mean anything. It

23 doesn't do them any good. For example, when you have

24 a little bit higher heating rate, things would heat up

25 faster, that would move this spike to the left and be

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
79

1 able to, it would be more likely to be adequate.

2 But what was really important was just

3 that little piece of it. The rest of it wasn't

4 important to start with. So there is this game, the

5 practicality of the sensitivity in the test. And also

6 the game that can be played to get a better rating,

7 but then what does that rating mean to the customer?

8 How do you pick your water heater based on that? The

9 problem is, you can't.

10 MR. KUSTERER: George Kusterer from Bock

11 Water Heaters again. Can we cut to the chase and what

12 is important? I mean, what is important to you? What

13 is your recommendation? What figure should we be

14 using?

15 DR. HILLER: Okay, let me take it in

16 pieces, there are a whole bunch of pieces to that.

17 MR. KUSTERER: Well, before you take it in

18 pieces, I think we are do for a break.

19 FACILITATOR RABA: It sounds good. All in

20 favor, break. Back in 15 minutes please.

21 (Whereupon, the foregoing

22 matter went off the record at

23 10:38 a.m. and went back on the

24 record at 10:55 p.m.)

25 FACILITATOR RABA: This is a very

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
80

1 comprehensive presentation. I would like to move

2 forward and think how we could relate this to the test

3 procedure. I want to hear some other points of view

4 also. I note that the comment, one hour is too long.

5 Perhaps we can nail down maybe some ideas as to what

6 is the right time frame for the test procedure and

7 proceed to focus on the future.

8 So we would like to invite some other

9 views on that. One hour is too long, what could it

10 be? Any thoughts on that?

11 MR. STANONICK: Well, let me go the other

12 way. I mean, I clearly don't have the command of

13 these graphs that Carl has, but at least in some of

14 the cases the graph seems to indicate that the rate of

15 change, if you will, flattens out around one hour.

16 I mean some of these graphs do indicate,

17 and I am specifically looking at the once per day one.

18 It seems to indicate that an hour time period is a

19 significant period of concern, because the rate of

20 change kind of flattens out. Now granted, the

21. greatest rate of change is in the smaller period, but

22 that, you know, is just logical.

23 But looking at some of these graphs, it

24 looks to me that there would be some indication that

25 at least some of these uses you should look at how

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
81

1 much water they use in an hour. I guess my point is

2 that this to me does not clearly show that one hour is

3 the wrong time period.

4 And so the other thing is, and again this

5 is more historical, there is part of the genesis of

6 the first hour recovery rate or first hour rating was

7 the concept of a recovery rate. And history in water

8 heater industry was you based recovery rate on what

9 you could recover in an hour.

10 Again, it is a convenient measure. But

11 this data seems to indicate there is also some

12 validity to an hour time period.

13 -FACILITATOR RABA: So, is it too long,

14 maybe an hour is fine, go ahead please.

15 MR. DUCH: I believe I support the

16 gentleman from GAMA.

17 FACILITATOR RABA: Your name, sir?

18 MR. DUCH: Adam Duch, Group Thermo.

19 FACILITATOR RABA: Thank you.

20 MR. DUCH: Because I believe if you work

21 backwards from those graphs it looks to me as if, if

22 you take the one hour rating, one of the graphs

23 superimposed on the other, at the one hour, any water

24 heater works for the one hour going backwards, it will

25 work for ten minutes.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 2344433

 EE-RM-94-230 COMMENT 49P
82

1 DR. HILLER: No, absolutely incorrect,

2 totally wrong. This data tells you exactly the

3 opposite.

4 MR. DUCH: That's not the way I see it.

5 DR. HILLER: This data tells you that what

6 happens in one hour tells you nothing about what, how

7 to size your water heater.

8 FACILITATOR RABA: Other views, please.

9 MR. ROSENSTOCK: Hi, Steve Rosenstock,

10 Edison Electric Institute. What, especially with the

11 data that Dr. Hiller has shown, you know, maybe you

12 could have as a multiple rating period. Because it is

13 obvious if you look at the function of peak demand,

14 I'll say for the hot water usage. You know, depending

15 on whether you are looking at day versus week versus

16 month, you maybe have two rating periods.

17 And again, there is also the dead band

18 problem and the turn on, turn off problem. Maybe you

19 do 20 minutes, 40 minutes and an hour. Because there

20 could be a variety of customers out there who are

2: going to be, I!ll say, at various happiness levels.

22 I'll put it that way.

2:3 Such that, I'll say you kind of cover,

24 like with other issues you look at the band width and

25 for a 20 minute rating period, you know, certain all

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
83

the customers will be happy, or 99 percent of the

customers will be happy based on the water heater

installed, versus the 40 minutes there will be a 95

percent satisfaction based on the size of the water

heater and the usage pattern versus an hour.

But again, I think what Dr. Hiller has

shown is that again there is a critical time period,

especially much less than an hour that needs to be

looked at for, I'll say, customer satisfaction.

FACILITATOR RABA: Thank you. Other

views, please. Someone who hasn't spoken yet? Frank.

MR. STANONICK: Frank Stanonick, GAMA. I

just have a question for Carl because I want to

understand how to read this. I'm looking at the 68.9

gallon per day chart, okay. And --

DR. HILLER: What's the customer number?

MR. STANONICK: 695, would that be the

number?

MR. KUSTERER: Right.

MR. STANONICK: Anyway, I've just been

looking at the once a day line, okay. I'm reading

that to say that for this customer, once a day they

have a, let's call them a combination of draws, but in

an hour period, they draw approximately 20 gallons.

Is that the correct way to interpret that?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21L

22

2:3

24

25

 EE-RM-94-230 COMMENT 49P
84

1 DR. HILLER: They do that at least once a

2 day.

3 MR. STANONICK: At least once a day. Now

4 this also says that at least once a day in a 15 minute

5 period they draw 12 gallons.

6 DR. HILLER: At least once a day.

7 MR. STANONICK: Okay, but that 15 minute

8 period could also be part of my hour period, is that

9 what that's telling me?

10 DR. HILLER: It could be, not necessarily.

11 MR. STANONICK: Okay, yeah. Well, I just,

12 you know, I was listening to what the gentleman back

13 there said and he said, well, that's not really what

14 it said. So I am just trying to figure out, what does

15 it say.

16 Okay, so it says that once a day these

17 folks do draw a total of roughly 20 gallons in an

18 hour, all right. They may, at least once a day, in a

19 half hour draw probably about 18. But I guess --

20 DR. HILLER: -- smallest tank to be looked

21 at, which is a 30 gallon tank, on that data.

22 MR. STANONICK: Uh huh.

23 DR. HILLER: The daily average plot, this

24 would suggest, because you could overlay the 30 gallon

25 and that 30 gallon would be totally inadequate for

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
85

1 that customer. You don't look at the daily stuff for

2 sizing purposes. Because that means, that all these

3 water heaters would be running out of hot water.

4 MR. STANONICK: All right, but if I look

5 at monthly, if I look at the monthly, again the way I

6 understand this I think an hour has more validity now

7 than a half hour.

8 DR. HILLER: For what?

9 MR. STANONICK: For trying to estimate

10 what these folks need.

11 DR. HILLER: This would say, you know, if

12 you look at any of these time frames with a single

13 element tank, if you are just looking at the daily

14 stuff or even the weekly stuff, the daily stuff

15 clearly would suggest that any of these small tanks

16 would work with a single element, and that's not the

17 case.

18 You don't look at the daily stuff. That

19 may be on average what happens, but you don't size to

20 the average. You can't. We've got good data that

2: shows the statistical distribution of draw. I don't

22 know if I brought those plots with me or not.

2:3 FACILITATOR RABA: Relating to the test

24 procedure, and the different methods proposed in the

25 Federal Register Notice as to where to go with this

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
86

1 procedure of the first hour rating and the preferred

2 method that the questions are asking here. Can we

3 relate more of your views toward that end too, please.

4 DR. HILLER: This isn't for that customer,

5 but I am just throwing this up here. This is the

6 statistical distribution of draws for the Ranger

7 Residence. And I forget, Ranger is 60 some odd

8 gallons a day, if I remember, on average.

9 MR. KUSTERER: I can't hear.

10 DR. HILLER: I said, Ranger I think was 60

11 some odd gallons a day on average. But this is how

12 the statistical distribution of water draws in bins of

13 draw of a certain number of gallons over that draw.

14 We've got all that data.

15 FACILITATOR RABA: We have two comments.

16 One from EEI and one gentleman in the back. First

17 over here to the left please.

18 MR. ROSENSTOCK: Yes, Steve Rosenstock,

19 Edison Electric Institute. In terms of test

20 procedure, it does look at, and also there was another

21 comment in here about the actual draw per day is that

22 it seems that 64.3 gallons per day does seem to be on

23 the high side. That it seems like there is a lot of

24 statistical evidence that it is actually a lower, more

25 in the 50 to 60 gallon range, rather than 64 gallon

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
87

1 range. That's one comment. In terms of the test

2 procedure, that's one comment that I would have.

3 FACILITATOR RABA: Thank you. Gentleman

4 in the back?

5 MR. VAUGHN: Jim Vaughn, Vaughn

6 Manufacturing. I would direct my question partially

7 to Mike. It seems that in terms of the test

8 procedure, we have two separate categories here. Dr.

9 Hiller has made a nice presentation about facts and

10 figures related to the actual energy used by the

11 customer. Is that the purpose of the test procedure?

12 Or is the purpose of the test procedure to

13 pick a first hour rating that will fairly compare one

14 manufacturer's product with another manufacturer's

15 product? And if so, is there something about the one

16 hour period that unfairly compares those products.

17 Up until now, it has been my impression

18 that the purpose of a first hour rating was to form

19 categories so that we could fairly compare one product

20 with another product and put them in a manual in some

21 sort of an organized way. If that's not true, then I

22 need to hear from Mike.

23 MR. MCCABE: Michael McCabe. Jim, you are

24 correct as far as the intention of the first hour

25 rating as it was originally developed. As with all

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
88

1 the other products, as far as a measure of capacity,

2 was to be able to provide for a measure of comparison

3 from one product to another. And it has been posed,

4 been a rather difficult product given the different

5 energy sources and also the different technologies

6 that exist.

7 DR. HILLER: Let me toss a legal hot

8 potato here, because I think it is very germane to

9 this discussion. Many of you in this room are

10 probably aware of efforts in the last two years made

11 by the American Gas Association to try and get codes

12 and standards changed, including ASHRAE, Council of

13 American Building Officials, International Council of

14 Building Officials and Southern Building Code Congress

15 International, to get those codes and standards

16 changed based on first hour rating numbers that

17 require larger electric water heaters.

18 They used first hour rating numbers from

19 in the GAMA directory and came to the assertion that

20 electric water heaters had to have equivalent first

21 hour ratings to. gas water heaters to be adequate. And

22 they went to try to get the codes changed. And in

23 fact, they were successful with the Southern Building

24 Code Congress International, which therefore required

25 an increase in required size of electric water heaters

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
89

1 to sizes that were oversized compared to what the

2 customer really needed.

3 That's what first hour rating was used for

4 in the political sense. And therefore, regardless of

5 what the original intent was, that is how it has been

6 used in the field and this data clearly shows that it

7 is unnecessary to have an electric water heater have

8 the same rating, however you determine it, as a gas

9 water heater to adequately serve your customer.

10 But that is what has been useful, and what

11 do we do about that.

12 FACILITATOR RABA: Relating to the test

13 procedure? Go ahead, please.

14 MR. RANFONE: Jim Ranfone, American Gas

15 Association. I will respond to Carl. First hour

16 ratings became the law of the land. It is part of the

17 labeling program. That's how you rate water heaters.

18 That's how, when you give it a label. What we

19 presented model folks had nothing to do, nothing to do

20 with trying to require larger electric water heaters.

21. If you are having a problem with the rating scheme,

22 this is the place to take care of it.

23 Don't accuse us of saying we are trying to

24 mandate larger electric water heaters based on our

25 presentations or our proposals to model trade groups.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
90

1 We have used existing test procedures, and by the way,

2 while we are talking about, the same rating scheme

3 that you are not criticizing, is the rating scheme

4 that EDI commends in your own literature, which we've

5 already presented to the model groups when they try to

6 oppose it.

7 This is not the forum to take it up, but

8 if you want to continue talking about that, I will be

9 glad to do that. What you've presented so far, is

10 your data which really hasn't undergone any kind of

11 analysis but your own. You've made this presentation,

12 you don't know any other details of how this data was

13 presented and you are expecting us to buy into it as

14 we sit around this table today.

15 If you want to talk about first hour

16 rating and what your agenda is and what you are trying

17 to get and telling people that a 30 gallon water

18 heater in a home with four people is adequate. Try it

19 yourself. Because you are wrong and you know it.

20 FACILITATOR RABA: I would like to get

21 back to the test procedure also. Clearly, there is

22 some differences of thought here. I would like to get

23 some more views first. And maybe we should go back to

24 our Federal Register Notice to look at some of the

25 questions that we were interested on finding out your

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
91

1 views on too.

2 Should we reconsider the 1979 test method

3 for measuring the first hour rating? Should DOE

4 retain the current test method for measuring the first

5 hour rating? Should DOE adopt a 1995 proposed test

6 method for measuring the first hour rating? And then

7 should we adopt the ultimate test method proposed by

8 Dr. Hiller?

9 These are areas, again, bringing it back

10 to the test method and the one hour rating. Do you

11 have any comments? I wanted to get this back on track

12 for folks in the future, and what we can do work

13 together on this clearly controversial issue. But

14 let's try to surmount that and stick with the issue

15 please. Go ahead.

16 MR. STANONICK: Frank Stanonick with GAMA.

17 First of all, from our perspective, most assuredly DOE

18 should not retain the current 1990 or the current

19 procedures in the 1990 final rule. And primarily, we

20 have submitted comments before.

21 We think there is a fundamental error in

22 the calculation procedure, at the very least, that

23 results in situations, as an example, where you have

24 a 120 gallon electric water heater that comes out in

25 the first hour rating as 80. And to us that is

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
92

1 nonsensical, it defies logic, if you will.

2 And so we do, we also have a record with

3 comments, is basically supporting the concept of the

4 proposed test procedure that was in the 1995 proposed

5 revision. In the packet of material that has been

6 passed out, you will see we have a letter and I would,

7 first of all, we did some, we had some data generated

8 by ETL, who runs our certification program, and it

9 starts at the bottom of the first page there.

10 What we did is have them run the revised,

11 the proposed revised test in the 1995 proposed rule

12 compared to the ratings we published. We are still

13 publishing ratings based on the old 1979 test

14 procedures.

15 MR. DOUGHERTY: With a slight

16 modification.

17 MR. STANONICK: Yes, with a slight

18 modification. But we purposely and so advised both

19 FTC and DOE that we thought it would be too confusing

20 to consumers if we published numbers that came from

21. the 1990 rule. So we are comparing actually, we

22 compared this new proposed revised test procedure to

23 the numbers we are publishing.

24 The manufacturer's claimed rating based

25 on, as Brian mentioned, there is really a slight

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
93

1 modification from the '79 procedure. And what you can

2 see there is a number of tests we've run where that

3 delta is the difference between the revised procedure

4 and the current rating for each of the models we

5 tested.

6 And don't ask me why on 30 gallon gas the

7 average came out a little less. I can't explain that

8 one and I'll tell you from a manufacturer's

9 perspective, we don't care. You can see there the

10 sigma, that's the sigma of the sample model, so that

11 tells you what kind of spread you are looking at.

12 In general, the new test procedure does,

13 on average, give out a slightly higher number. The

14 same thing for electrics. You don't see any large

15 volume sizes there, basically because in some cases we

16 only had one data point and I don't think it is going

17 to make sense to give you a statistical average on one

18 data point.

19 In any event, based on what we saw there,

20 and that represents over 100 water heaters that were

21 tested, we think that this proposed revised test

22 procedure does at least give you reasonable results.

23 It does, it is a reasonable way to lump products of

24 equal ability together. On the issue of one hour, I

25 think there is clearly, you know, there is indications

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
94

1 that one hour isn't a perfect number. The fact is no

2 number is.

:3 It is better than many and certainly no

4 worse than any other number, but it certainly has some

5 historical basis. If we are talking about plumbers,

6 plumbers no recovery rate is an hour. They probably

7 confuse first hour rating with recovery rate, but if

8 anything, that causes oversizing which is again, maybe

9 not the Department of Energy's concern, but if you are

10 selling water heaters it is certainly a lesser sin

11 that undersizing.

12 I mean, if everybody undersized, there

13 would be a lot of energy saved, because you wouldn't

14 be having hot water. But the second part of this is

15 that, going back to this question of should we use the

16 '79 method? When the test procedures were first

17 proposed, there was for an interim period an optional

18 calculation, all right.

19 We would like to reintroduce the idea of

20 allowing manufacturers to use a conservative

2:1 calculation for the garden variety, what I am going to

22 call the standard design water heater, whether it is

23 gas or electric, first hour rating number is fairly

24 predictable, all right. And we think that DOE should

25 reconsider the idea to allow manufacturers to

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
95

1 calculate, rather than run a test.

2 And when, and at the manufacturers choice,

3 if he chooses to design in features that are going to

4 give a better than normal first hour rating, then he

5 can run the test and the test will in fact verify

5 whether those features work or not. But we came up

7 with some, our suggestions for calculations there.

8 They, I am not going to tell you that they are

9 absolutely the best calculations that fit the best.

10 It was kind of a semi, we just developed

11 this last week. So it probably could use some fine

12 tuning, to address the issue of recognizing, as Carl

13 mentioned, the single element electric is not, I mean,

14 there is a reason why you have a dual element

15 electric. And it is really to recover, to provide

16 some hot water, some portion of the hot water quicker.

17 So we separate out single and dual

18 elements there. And then just to further show you at

19 least what's behind our's here, we, the first term in

20 both of those calculations is a ratio of the volume,

21 restored volume, and we are using the rated volume.

22 And so for gas and oil we would say, okay, in the

23 first draw you are going to roughly pull out 80

24 percent of the rated volume.

25 DR. HILLER: When you say rated, do you

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
96

1 mean --

~~2 ~ MR. STANONICK: Rated volume, it is on the

rating plate. Yeah

4 .1DR. HILLER: Not the actual.

5 MR. STANONICK: Yeah, because I can read

6 the rated volume, I don't have to measure it. I mean,

7 we can use actual and the rates will just change. You

8 know, it is just numbers, it's math. And then for

9 electrics we use the .75. And then what we did is we

10 went back to ETL and said, okay, pull out some data

11 and show us the actual ratio of draw, the first draw,

12 versus the rated volume.

13 And so what you see down at the bottom of

14 Page 2 there is, and the data is attached. We looked

15 at ten units of each size and these were just picked

16 from tests we've been running. There is nothing

17 special about them. On the 40 gallon, typically, the

18 average was the ratio of the first draw for the rated

19 volume of 85 percent.

20 You can see there it gradually goes up as

2:1 you go up in size. Well, basically you can also

22 assume, you know, a bigger water heater has more

23 input, some there's some connection there. We did the

24 same thing for electrics and as you can see there, for

25 the smaller volume electrics, the average ratio was

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
97

1 78. And you went up to 50 gallon, 52 gallon, it goes

2 up to 85.

3 We only put that there to show you we are

4 purposely selecting conservative numbers.

5 Manufacturers are willing that if DOE would give them

6 the option to calculate, we would recognize, okay,

7 that's going to be a conservative calculation and thus

8 create an incentive that, in fact, if you are really

9 interested in promoting a high recovery or some other

10 product that has features that really do give

11 unusually high ability to provide hot water, then you

12 could run the test.

13 This thing is not so broke that it

14 requires a dramatic overhaul. And the fact is,

15 whatever DOE puts in here as a first hour rating, can

16 be used in some form or another. And I say that

17 because you people could use it as it's printed, they

18 could use it with some of their own adjustments, but

19 it could be used as a sizing type.

20 How you do that properly to me is not,

21 again, I've .said it before, is not the critical

22 question of the test procedures. You know, that will

23 occur outside the test procedures and it is going to

24 occur regardless of what number you pick. And I guess

25 I just want to say, let people figure it out for their

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
98

own purposes.

FACILITATOR RABA: Thank you. Another

comment.

MR. ROSENSTOCK: Well, just a couple of

clarification points on the GAMA equations.

FACILITATOR RABA: Your name, again.

MR. ROSENSTOCK: I'm sorry, Steve

Rosenstock, Edison Electric Institute. What the

variables P and E sub R, what are those?

MR. STANONICK: I'm sorry, I've been with

this too long. P is input and E sub R is recovery

efficiency. In the case of electrics, the recovery is

assumed to be 98, that's why you get .98P and then the

3412 is converting kilowatts to BTU's.

MR. ROSENSTOCK: Inputting gallons, input

in --

MR. STANONICK: No, energy. BTU's per

hour.

MR. ROSENSTOCK: Now with the electric

units, would the values down at the bottom, are those

'for both single and dual elements units?

MR. STANONICK: I am willing to bet these

are all dual element. Yeah, in fact they must be.

I'm not sure how single elements would test.

DR. HILLER: First draws are driven by

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21.

22

23

24

25

 EE-RM-94-230 COMMENT 49P
99

1 volume and relatively little to do with heating range.

2 MR. STANONICK: Right, but we usually, I

3 can't recall that we tested many single elements.

4 MR. DOUGHERTY: Actually, Brian Dougherty,

5 NIST. I would have hoped that some of the deltas up

6 above the page for the electric single element would

7 have went down rather than up. Two element I can

8 understand going up, but the single element I would

9 hope that they actually went down.

10 I was actually curious whether or not any

11 of those listed were single element in that example.

12 MR. STANONICK: Give me a second here.

13 There were very few electric units that went down.

14 And again, I've got to believe that, just in terms of

15 what we were looking at, you know, we select units to

16 randomly test for our certification program. So we

17 just ran this additional test on the units we

18 selected.

19 So there wasn't any, let's say, plan to

20 try and identify single from double. And again, I'm

2: not aware that we, I can try and find out, but I don't

2:2 think we really tested any single elements.

23 FACILITATOR RABA: Go ahead.

24 MR. ROSENSTOCK: The other question I had,

25 in terms of the first part of these formulas, .8 times

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
100

1 the volume, the rated volume, versus .75. Is there,

2 in terms of the electric, how is it determined that it

3 is .75 times the volume? Was it field tested?

4 MR. STANONICK: First of all, if you look

5 at --

6 MR. DOUGHERTY: Tolerances allowed on the

7 tanks.

8 MR. STANONICK: If you look at Attachment

9 One, which is the supporting data on our comparative

10 first hour rating test, you will see that we did rated

11 volume versus measured, okay. Electric water heater

12 by the UL Standard, its actual volume can be, has to

13 be within 90 percent of the rated volume.

14 MR. ROSENSTOCK: Right.

15 MR. STANONICK: Most of them are around

16 there. Okay, a gas water heater has to be within 95

17 percent of the rated volume. Most of them are around

18 there.

19 MR. DOUGHERTY: They can hit it.

20 MR. STANONICK: So what you are basically

21 seeing there is the difference that, again, we chose

22 the formulas compared to rated. What you are really

2:3 seeing is that, the fact that a gas water heater, in

24 terms of its actual volume, it is closer to the rating

25 than the electric.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
101

1 It is, that's just the way it works out.

2 And what we tried to show on the bottom there, is that

3 in both cases, we picked numbers that are

4 conservative, conservative ratios. But we believe

5 that these calculations should note that in terms of

6 actual volume versus the rated, there is a difference

7 between the electric and the gas. And we are just

8 picking that up.

9 DR. HILLER: Question for you, Frank.

10 MR. STANONICK: Yes.

11 DR. HILLER: Would it be --

12 FACILITATOR RABA: Say your name again.

13 DR. HILLER: Carl Hiller. Would it be

14 appropriate in a rating scheme like this to have a

15 statement that this rating should not be used for

16 sizing purposes?

17 MR. STANONICK: I guess, Carl, I'm not

18 sure if it would make any difference if that sentence

19 was there or not. In fact, I mean, if we went with

20 okay. Let's say just say that this was implemented,

21 in fact, we knew this was the formula, all right.

22 Well, someone who knew and had data could in fact take

23 that number and break it out into its component parts

24 and with some knowledge probably actually adjust it to

25 have more relevance to sizing in a particular effort.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
102

1 So, I guess I'd say maybe it shouldn't be

2 used, what's the word, not arbitrarily, but shouldn't

3 be used without some additional knowledge or

4 information or something.

5 DR. HILLER: This equation gives you a

6 single number?

7 MR. STANONICK: Right.

8 DR. HILLER: The question is, can that

9 number be used in any way to size a water heater?

10 MR. STANONICK: I think it could be. Is

11 it going to be the best sizing in all cases, probably

12 not. But again, it is a question of what is, you

13 know, is there an ideal method for size? I don't

14 think there is. The test procedures, I guess if the

15 test procedures said that it wouldn't be, not intended

16 to be used for sizing, I don't care.

17 I mean, I would say that in fact, that is,

18 I would say that is consistent with where we all

19 started from on the test procedures. But I don't know

20 that it is going to seriously curtail people from

21 trying to use. that.

22 FACILITATOR RABA: Other views, please.

23 MR. RANFONE: Jim Ranfone, AGA. If it

24 isn't in this calculated method or the current, or the

25 testing method, how do you tell people to size water

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
103

1 heaters? Are you going to use the method, well, the

2 plumbers know? One minute they know and the next

3 minute they don't know. You need some kind of

4 mechanism.

5 If there is no sizing mechanism, then how

6 can you tell people to size?

7 FACILITATOR RABA: Comment.

8 MR. ROSENSTOCK: Steve Rosenstock, Edison

9 Electric Institute. You are saying these values were

10 conservative and it was GAMA that decided on the first

11 unit .8 V versus .75.

12 MR. STANONICK: It is our recommendation.

13 MR. ROSENSTOCK: Okay, but someone could

14 recommend you make .9 for the electric and .8 for the

15 gas, if they wanted to.

16 MR. STANONICK: And then they've probably

17 deviated from the conservative, because clearly the .9

18 would be more than the test supports.

19 MR. ROSENSTOCK: Well, I would just, you

20 know, because it just seems that, you know, that first

21 number seems to be the main, you know, it is obviously

22 the main parameter there. And then since it is so

23 almost, you know, it is based, it is very subjective

24 around an objective --

25 MR. STANONICK: A 50 gallon gas water

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
104

1 heater typically holds between 47 and a half and 48

2 gallons. A 50 gallon electric water heater, typically

3 holds 45 gallons. That's the facts. And we are just

4 trying to reflect the physical reality. And if

5 anything, you know, we can probably, well, I was going

6 to say, we did ten data points for each volume size.

7 We can do more, but I don't think those ratios in the

8 real world are going to change much.

9 DR. HILLER: Can I interrupt here for a

10 second, Frank?

11 FACILITATOR RABA: Carl, are you speaking?

12 DR. HILLER: Yes, Carl Hiller. Your

13 proposal says you have a single element tank and a

14 number that is independent of basically any reading,

15 right? It is just a function of volume?

16 MR. STANONICK: Yeah. Okay, you picked

17 the 40 gallon?

18 DR. HILLER: Over a one hour time frame it

19 reheats.

20 MR. STANONICK: You are right.

21 DR. HILLER: A 50 gallon doesn't.

22 MR. STANONICK: A 30 gallon electric, a

23 single element, there is a good possibility it would

24 recover by the end of that hour. We admit that and

25 again, I came in saying that, you know, these are, can

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
105

1 use some refining. If, you know, I guess you could

2 say the single element formula only applies for

3 volumes, 32 gallons or higher or something.

4 And if it is a 30 gallon single element,

5 you could use that, the first formula. But the point

6 is, the point is, or are point is that the fact,

7 again, a garden variety standard design water heater,

8 this number is very predictable. And because it is,

9 and because of our opinion, all we are trying to do is

10 lump water heaters of equal capability together that

11 we think will be appropriate for manufacturers to have

12 an option to just use the calculation.

13 Especially when the new test is now an

14 hour test and yeah it can be run at the end of the 24

15 hour test or whatever and it is an hour time and a

16 little more perhaps. But your opinion is that you

17 don't need to do it, so why do it.

18 FACILITATOR RABA: Comments? In the back,

19 please.

20 MR. EARLEY: Jim Earley, Georgia Power, I

21 have a question for Frank. You said that your testing

22 that you are using right now is a modified version of

23 the '78, the earlier, the previous test for the first

24 hour rating?

25 MR. STANONICK: Right.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
106

1 MR. EARLEY: In that test that you are

2 doing, are you accounting for single and double

3 element electrics, or are you using the test where you

4 just put both of them together.

5 MR. STANONICK: To tell you the truth, I

6 would have to see what the test procedure says. I

7 don't recall that. One of the modifications

8 obviously, the original test procedure we were using

9 160 degree mean tank temperature. Today we use 135

10 and a different inlet water temperature.

11 So those are some of the modifications.

12 But I would have to see what the test procedure says

13 about how you address single elements. I don't

14 recall.

15 MR. EARLEY: '78 said that you use the

16 bottom element, and the '95 said the top.

17 DR. HILLER: Actually, '78 --

18 MR. DOUGHERTY: You want it from the time

19 that it turns on.

20 FACILITATOR RABA: State your name,

21 please.

22 MR. DOUGHERTY: Brain Dougherty, NIST.

23 You make a first draw, then you evaluate when that

24 thermostat cuts on, and then you find out the

25 difference between that time and the end of the hour.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
107

1 Then you make a calculation for how much water it

2 would have heated during that hour.

3 FACILITATOR RABA: Other views? In the

4 back, please go ahead.

5 MR. BERNADOWSKI: Tim Bernadowski from

6 Virginia Power.

7 FACILITATOR RABA: There's a microphone

8 there if you would like, if you feel comfortable with

9 that. If not --

10 MR. BERNADOWSKI: Can folks here me? I

11 don't feel comfortable getting next to electric

12 things.

13 (Laughter.)

14 MR. BERNADOWSKI: What I'm hearing is some

15 agreement. One being first hour rating is a lousy way

16 to size water heaters. Another thing that I am kind

17 of hearing here is that if the first hour rating was

18 originally put there to, in order to do things so that

19 there can be some similar comparability, particularly

20 for the labeling system, that almost sounds like the

21 tail wagging the dog. But it doesn't sound like you

22 really need the number.

23 It sounds to me like all you really need

24 to do is break them into certain classifications and

25 those classifications have a certain criteria and

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
108

1 that's how you group them as far as the labeling.

2 That sounds to me like what everybody is saying here,

3 for the purposes of DOE, that is the only reason that

4 first hour rating is here.

5 FACILITATOR RABA: Do we have more views

6 on the purpose of first hour rating? Good comments.

7 Dr. Hiller?

6 DR. HILLER: I think I pointed out and I

9 suspected not too much disagreement in the room that

10 any single point rating, regardless of what time frame

11 or what procedure you get it out of is going to have

12 shortcomings. All single point ratings have sin.

13 MR. STANONICK: For sizing purposes.

14 DR. HILLER: Well, that's one of the sins.

15 What it gets used for, right. Let me finish my

16 statement.

17 MR. STANONICK: Okay, okay.

18 DR. HILLER: I would argue, especially

19 based on our data, that if you are going to use a

20 single number, the number with the least amount of

21 sins would be first draw. That would be the number

22 with the least amount of sins. It doesn't adequately

23 distinguish between tanks with different heating rates

24 and single element and dual element. But in my view,

25 that has fewer problems associated with it than any

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
109

1 other method, if you are going to have a single point

2 rate.

3 Because clearly, most of your sizing is

4 driven by the first draw.

5 FACILITATOR RABA: We've got a tie here.

6 In the back first.

7 MR. STEPHENS: Charlie Stephens, Oregon

8 Energy Office again. I sort of have to agree with a

9 combination of the sentiments that are being presented

10 here. I really don't think water heaters are going to

11 get sized, in general, by the first hour rating. They

12 are going to get sized by their capacity, because

13 that's what most people understand.

14 However, there is probably some need to

15 differentiate between one 50 gallon and another 50

16 gallon, especially between a single element and a dual

17 element tank. I mean, somebody may want to be able to

18 compare those capabilities. So there probably is some

19 reason, along with the fact that there is a lot of

20 other institutions in this country that, at the moment

21 anyway, cite.the first hour rate as something that

22 they look at.

23 So I don't think you can just toss it out

24 without giving a lot of notice to people that it is

25 leaving. On the other hand, I think that Dr. Hiller's

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
110

1 data here has sort of shown me a few things, that I

2 don't know whether he intended them to show that or

3 not.

4 It looks like, in most of his data, what

5 really converges for comparing like tanks or tanks

6 that will meet the needs for most of the families out

7 there, is the one hour rating. Most of that stuff, if

8 you are going to pick number, the one hour rating in

9 my estimation isn't so bad. Dr. Hiller did provide

10 some insight as to how you can fudge around with the

11 half hour mark and plus or minus and really change

12 things.

13 Things kind of converge pretty well at the

14 one hour mark and as he pointed out, the only tank

15 that really failed to meet most families needs, was

16 the single element electric. Most of the rest of the

17 families in that study group, and our data by the way

18 in the northwest isn't as detailed, but it does

19 support his finding.

20 Assuming his finding is that most families

21 are served well by a 40 to 64 gallon tank, either

22 electric or gas and that the plumbers most of the time

23 do pretty well, given that they are sizing it for the

24 house rather than for the family that lives there.

25 So I think the first hour rating as it has

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
111

1 been recommended for upgrade is probably okay. I

2 agree with Frank Stanonick a lot. I agree with a lot

3 of what he said. I don't think it is a bad test. I

4 don't think it is going to get heavily used, except

5 for comparing similar tanks that people who are just

6 looking for minor performance differences between one

7 50 gallon and another 50 gallon tank. Which is okay.

8 I have heard plumbers say that they do use

9 that. Not to size the tank, but to compare things.

10 So let them use it. Plus there is the possibility

11 that there is some things that aren't quite normal.

12 That aren't exactly like the run of the mill tank that

13 Frank refers to.

14 These tanks need some way to at least be

15 comparably benchmarked against everything else that's

16 out there. So I think we really need to hone in on

17 the fact that the test is there if we kind of need it.

18 The modifications are not there. I don't object to a

19 calculational method, if it is conservative.

20 I think what he is showing here could save

21 some money for some manufacturers who do make a whole

22 host of run of the mill tanks. And again, if they

23 have a high performance tank, they can test it. I

24 don't see any problems with any of that. I recommend

25 we adopt the modified procedure, provided everybody

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
112

1 agrees.

2 FACILITATOR RABA: Adopt that what?

3 Please, what was your comment?

4 MR. STEPHENS: The modified procedure that

5 GAMA has suggested fairly accurately that reflects the

6 testing and the capability of the tanks that they get

7 in the first hour rating. I would endorse keeping the

8 first hour rating, Number one. And Number Two, some

9 of the modifications that were suggested most

10 recently, that have been tested by GAMA and shown to

11 leave the tanks fairly well equated when they are

12 equal are probably well adopted at this point. We can

13 talk, I'll have to, we will have to raise temperature

14 settings.

15 DR. HILLER: What do you mean be equated

16 and equal?

17 MR. STEPHENS: Well, I'm talking about

18 tanks that deliver approximately the same amount of

19 hot water as the first hour rating. If you take a

20 home with electric service and one with gas service,

21 the tank that the plumber would select for each.

22 The ones on your charts that will meet 95

23 percent of the families needs.

24 FACILITATOR RABA: We'll get back to you,

25 thank you.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
113

1 DR. HILLER: If you look at a one hour

2 time frame, here the greens are 50, the red is the 80,

3 let's say we just have, I don't know exactly where

4 that line is going to be. Let's say our rating really

5 was over here, so that the gas water heater was at a

6 higher rating than the 80 gallon electric.

7 If you are looking at first hour rating,

8 those would be the closest two. But in fact, you

9 didn't need either one of those and the rating that

10 the 50 gallon would have gotten was certainly low. So

11 you would be comparing an 80 gallon electric to a 50

12 gallon gas, when in fact a 50 gallon electric is the

13 one you should have compared, when it should have been

14 used for the application. Not the 80, the 80 was

15 oversized.

16 MR. STEPHENS: For whom?

17 DR. HILLER: For that customer.

18 MR. STEPHENS: Well, I've already

19 maintained that it won't be sized for the customer, it

20 will sized for the house that the customer lives in.

21 DR. HILLER: My point is, you are going by

22 first hour ratings. And my point is a comparison of

23 first hour rating has nothing to do with that water

24 heater, how you pick it.

25 MR. STEPHENS: I think I said that

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
114

1 already.

2 FACILITATOR RABA: Other views, please.

3 Over here.

4 MR. KUSTERER: George Kusterer, again. I

5 mean, I kind of had mixed emotions. Around 10:30 I

6 kind of asked, what would your recommendation be. And

7 I still haven't heard an answer. I agree with the

8 gentleman from Oregon. We are dealing with first hour

9 recovery. It is not a bad number, it works.

10 A plumber is going to use it for sizing?

11 No, that's not the primary use of the first hour

12 recovery. First hour recovery is something that the

13 consumer can use. And basically, we owe it to the

14 consumer to provide that first hour recovery, so they

15 can make a direct comparison.

16 Whether they need a 30, a 50, an 80 or a

17 120, is totally irrelevant. We are not dealing with

18 a water heater that you are putting in a house for

19 four people. You are dealing with a water heater for

20 of structure, that may have an 80 gallon hot tub that

21 these people want to use every time they come home and

22 read the newspaper. Because it does become somewhat

23 stressful lately.

24 (Laughter.)

25 MR. KUSTERER: Now, are we sizing it

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
115

1 because there are four people in the house, or are we

2 sizing it because they need 80 gallons within an hour,

3 so they can reduce their stress. The problem is this,

4 although you did an excellent job and you should be

5 commended, is skewed strictly for electric. Not that

6 I have any problem with electric, but it does not show

7 the average for gas or other fossil fuels.

8 We owe to the general public a number, not

9 to be used in sizing, but should sometimes be taken

10 into consideration by the installer. And I am getting

11 away from the plumber. But we owe it to the general

12 public to give a first hour rating. How much they

13 expect from that water heater installed in the den of

14 inequity. In the twilight zone.

15 Because basically, nobody goes down there

16 except us dumb mechanics to fix them. But that's what

17 we owe. A 30 minute recovery, people are, but I need

18 80 gallons in an hour, I don't need 25.2 gallons in 30

19 minutes. It's a good number.

20 FACILITATOR RABA: I have a comment over

21 here and one in the back too.

22 MR. VAGO: Otto Vago, State Industries.

23 To this day, a high percentage of plumbers are sizing

24 the water heater by the old recovery rate method. If

25 you tell them that, well, use the first hour rating.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
116

1 He says, yeah, okay, what is the recovery rate on

2 that. In other words, they are not familiar with the

3 first hour rating term, even to this day.

4 After all these years, they go by the old

5 recovery rate method. And that's not only the

6 plumbers, but also some engineers that actually size

7 the water heater for the new construction.

8 FACILITATOR RABA: All right. And back

9 there, please.

10 MR. ABRAMS: Yes, Don Abrams, Abrams and

11 Associates. I am concerned that we are focusing in

12 too strongly on residential applications for

13 households of four. It seems to be where we are

14 focusing. I think we need to keep in mind that a

15 large number of new units, even though they are called

16 residential units, find application in commercial

17 buildings.

18 In fast food restaurants and office

19 buildings, where they behave very differently. These

20 structures are typically closed on weekends and their

21 water usage is much more compact during the day, for

22 a nine hour period, rather than an 18 hour period like

23 in a residence.

24 The other thing is there are a large

25 number of single occupant and dual occupant households

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
117

1 in the country. And the demographics trend I think is

2 showing that that is becoming more prevalent. Those

3 households, that kind of household would certainly be

4 more accurately represented by recovery duration

5 period.

6 One and two occupant households don't have

7 a concern typically about a longer time period. Their

8 hot water usage, particularly single occupant

9 households is very compactly centered into a shower or

10 a laundry load or a dishwasher operation cycle. So we

11 are getting further away from the commercial

12 applications, and the small occupant, small household

13 residential application.

14 Keep in mind, we are dealing with, I would

15 say at least major classes of users rather than just

16 residential four person households.

17 FACILITATOR RABA: A lot of good comments

18 this morning. I would like to get some closure and

19 move on. This is a very interesting topic for

20 everybody. We've gotten a lot of information that we

21 can certainly use from all sides. I appreciate your

22 comments and would like to at this time stick with the

23 agenda a little a closer.

24 Certainly this is a topic that we could go

25 on all day about. And well, if we don't really get a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
118

1 conclusion today, we have a direction we can go in.

2 We've heard a lot of good things today, and we will

3 take this into consideration as the public mulls over

4 all the facts, the data, and maybe read some more

5 later on in your written comments too.

6 So we would like to ask you if we could

7 either, well first of all, if you would like to table

8 this for now. We can come back later on and discuss

9 other topics in the agenda. Continue our discussion,

10 would you like to either move to instantaneous water

11 heaters, which would be the second topic, it could be

12 an instant discussion too.

13 Or, would you like to break earlier for

14 lunch and come back early after lunch. Move on or

15 take a break? Has everybody been heard on this matter

16 that wants to be heard on the proper sizing, for the

17 test procedure, the first hour rating? Does anybody

18 else have a desire to say something there? Please,

19 before we take this interlude.

20 (No response.)

21 FACILITATOR RABA: Well, would you like to

22 proceed then and go on to instantaneous water heaters

23 or take a break? Instantaneous? Press on, all right.

24 Remember, you said an instant discussion too. Looking

25 at the agenda, some questions to think about. What

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
119

1 currently exists in the marketplace today?

2 Should test procedures be developed for

3 oil-fired units? Should an alternate method be used

4 for first hour rating? Should an alternate method be

5 used for the energy factor for units with a lower

6 heating rating? I will open discussion on that. Any

7 comments or views, any statements perhaps?

8 Instantaneous water heaters.

9 MR. ROSENSTOCK: Just a quick orientation.

10 FACILITATOR RABA: Name again, please?

11 MR. ROSENSTOCK: Steve Rosenstock, Edison

12 Electric Institute. You asked about oil-fired units

13 for instantaneous. Are there any being built or

14 installed or you know, just out of curiosity, how, do

15 they have any market whatsoever, really?

16 FACILITATOR RABA: Good question.

17 MR. ROSENSTOCK: I personally don't know.

18 I would assume it is extremely small.

19 FACILITATOR RABA: Does anybody know? Any

20 data or facts, please.

21 MR.. STANONICK: Frank Stanonick with GAMA.

2:2 We are not aware of any oil-fired instantaneous,

23 residential oil-fired instantaneous water heaters on

24 the market.

25 MR. ROSENSTOCK: Or commercial?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
120

1 MR. STANONICK: I'm sure there might be

2 some commercial sizes, but not residential.

3 MR. KUSTERER: Not at this time.

4 FACILITATOR RABA: Others?

5 DR. HILLER: Is the issue specifically

6 should we add oil-fired? Or is the issue a general

7 issue about instantaneous water heaters and their

8 ratings?

9 MR. DOUGHERTY: The first question is

10 just, Brian Dougherty, NIST, are there any oil-fired?

11 If there are, do we need to cover them? If there are

12 not, we will just eliminate that section and move on

13 to the other general topics.

14 MR. MILLS: James Mills from the Federal

15 Trade Commission. We don't receive any data for oil16 fired instantaneous water heaters to add to the mix.

17 FACILITATOR RABA: Can we move on to the

18 next question then? Thank you very much. Should test

19 procedures be developed for single point of use type

20 electric instantaneous water heaters? These questions

21 are also in your Federal Register Notice.

22 MR. ROSENSTOCK: Did you say electric or

23 oil?

24 MR. KUSTERER: Electric.

25 FACILITATOR RABA: Well, we could still

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
121

1 stick with oil if you would like?

2 MR. ROSENSTOCK: No, I am just looking at

3 the agenda, sorry about that.

4 FACILITATOR RABA: Yeah, sure, that's

5 fine. The question, should test procedures be

6 developed for single point of use type electric

7 instantaneous water heaters?

8 MR. KUSTERER: You have a gentleman behind

9 you.

10 DR. HILLER: I have a general comment

11 about instantaneous water heaters and how to rate

12 them. Hopefully, there won't be too much dissent in

13 the room if I make the statement that instantaneous

14 water heaters basically cannot do the same job as

15 tank-type water heaters. Especially under the

16 tendency to have clustered, short-term high draws.

17 I mean you can make an instantaneous water

18 heater that will serve the same kind of loads that a

19 tank-type water heater is normally intended to serve,

20 but it would have a very high heat input rate if you

2:1 did that. And to my knowledge, the instantaneous

2:2 water heaters that are on the market, in the sizes

23 that would be covered by these rules, typically do not

24 have high enough heating rates to meet the kinds of

25 draws that would be demanded of them if they were

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
122

1 trying to serve whole house loads.

2 And therefore, if you try and give them a

3 rating that looks something like a rating that you

4 would give a tank-type water heater, you would do a

5 tremendous disservice to the general public, because

6 they won't be able to know the difference. For

7 example, if you did a one hour rating, and an issue

8 that's particularly, I come up against all the time.

9 If you look at what's available in

10 electric instantaneous water heaters, a typical nine

11 kilowatt input rate. The maximum flow rate that that

12 device can serve, is something on the order of one to

13 one and half gallons a minute depending on your

14 temperature rise assumptions. Maybe even less than

15 that.

16 That is not adequate for many household

17 uses, or uses in general. And yet, if you gave it a

18 one hour rating, you would get a 60 gallon rating, if

19 it could meet that draw at one gallon per minute. And

20 if you compared that to a tank-type water heater that

21 had a similar 60 gallon rating, if you didn't know any

22 better, you would know which one to pick.

23 But by giving them a rating, that looks

24 like it is the same, like a one hour rating, you might

25 have people out there picking instantaneous water

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
123

1 heaters thinking they are going to be the equivalent

2 to the tank-type water heaters, when in fact they are

3 not.

4 FACILITATOR RABA: Question or comment in

5 the back, please?

6 MR. DUCH: Adam Duch, Group Thermo. Is

7 your definition of instantaneous water heater direct

8 power or indirect?

9 DR. HILLER: Anything that does not have

10 a storage volume within the definition of DOE's one

11 gallon or two gallon or whatever it is.

12 MR. DUCH: There is a major difference

13 between direct fired and a heat exchanger type.

14 MR. STANONICK: They're not covered by

15 this test procedure right now. These are all direct

16 fired types.

17 MR. DUCH: So you are talking about direct

18 fired instantaneous.

19 MR. MCCABE: Correct.

20 DR. HILLER: The argument really applies

21 regardless of as long as you don't have any storage

22 volume to rely on, you look at the power ratings that

23 are under the standard, there aren't very many high

24 rated units.

25 MR. DUCH: No, if you look at the indirect

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
124

1 fired, what you have said is not true. Because there

2 is one on the market recently introduced in the United

3 States that does as good a job if not better, in the

4 first hour. It is instantaneous as a storage type

5 unit.

6 DR. HILLER: What's the maximum gallon per

7 minute that that can serve?

8 MR. DUCH: Up to 30 or 45 minutes.

9 DR. HILLER: So that is a very high heat

10 input.

11 MR. DUCH: But it uses different

12 technology and the first hour it is totally comparable

13 to the first hour of direct, of storage-type.

14 DR. HILLER: My whole point, what I am

15 leading up to, is if we have ratings for instantaneous

16 water heaters, I strongly argue that we do them on a

17 gallon per minute rating, rather than a gallon per

18 hour rating.

19 FACILITATOR RABA: Comment from NIST.

20 MR. DOUGHERTY: Brian Dougherty from NIST.

21 In fact, Carl, that was a comment that was

22 consistently received. And so now the question

23 becomes, if people do not object to abandoning first

24 hour rating for instantaneous, and converting to a

25 gallons per time valve, hour, minute value, then the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
125

1 issue becomes, what name do you give that descriptor

2 and then what temperature-wise do you do the rating.

3 The issue that I saw thus far is whether

4 or not to use a 77 temperature rise, which is more

5 consistent with storage, or use something that is a 50

6 degree temperature rise, which may be more consistent

7 with how they are applied. So I saw those as the two

8 key issues. I guess I would like to see if we can get

9 over the first hurdle, in that it would be okay with

10 people to abandon first hour rating for instantaneous

11 water heaters.

12 And once over that hurdle, the question

13 becomes, now do we go to the gallon per time rating

14 descriptor, give it a name and decide on the

15 temperature rise at which you evaluate that

16 descriptor.

17 FACILITATOR RABA: All right.

18 MR. EARLEY: Jim Earley of Georgia Power.

19 As a power company representative, we strongly

20 discourage people using instantaneous in replacing a

21 whole house storage-type water heater. I don't think

22 it is good for the customer, and every customer on our

23 line that puts in a water heater that comes on

24 instantaneously, it is going to drive us crazy.

25 And in regards to Brian question. The

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
126

1 first part of that is I think we need to definitely

2 have it in gallons per minute and you can call it

3 just a recovery rating, if you want. And show it as

4 gallons per minute. And I suggest that 50, because if

5 someone wants to convert that to different numbers,

6 you can divide it by 50 and manipulate the number.

7 Where if you use 77, then you've got to

8 sit down with a calculator.

9 FACILITATOR RABA: The 77 is noted in your

10 Federal Register Notice. Any other comments or views

11 on that? -Good point. In the back.

12 MR. STEPHENS: Charlie Stephens, Oregon

13 Energy Office again. From our perspective, we would

14 recommend using a gallons per minute rating and

15 perhaps rate it at two different temperatures to get

16 around some of the controversies.

17 In most of our applications, 50 degrees is

13 not sufficient to overcome the inlet water temperature

19 most of the year and deliver what most people would

20 consider truly hot water. On the other hand, 77

21 degrees tends to be more than is really needed to do

22 that job.

23 So, I would suggest trying to find a

24 couple of numbers, or if we are going to pick one

25 number, that it be related to something that the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
127

1 manufacturers already do or can agree on that they

2 will do in the future.

3 FACILITATOR RABA: Any thoughts, any

4 numbers? Over here.

5 DR. HILLER: It just so happens, if you

6 look at the minimum entering water temperatures, like

7 up in Alaska, for example. Thirty-two degrees is the

8 kind of minimum number you are going to see. Anything

9 below that, you are going to get slush. And you don't

10 really see that very often, but it is kind of a

11 minimum theoretical number you would see.

12 It just so happens, a 77 degree rise from

13 32, is what, 107, 108, something like that. Which is

14 in the minimum usable delivery temperature range. So

15 one could argue that a 50 degree rise might be kind of

16 representative of an average rise, and also makes the

17 math easier.

18 And a 77 degree rise, represents kind of

19 a worse case scenario and happens to coincide with the

20 tank-type. So if you have two ratings, that would

21 work out kind of conveniently.

22 FACILITATOR RABA: Other thoughts?

23 MR. STANONICK: Frank Stanonick with GAMA.

24 First of all, we've also been on record as supporting

25 the idea that for instantaneous you go to a gallon per

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 2344433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
128

1 minute. I just want to clarify, are we still talking

2 specifically about single point of use, or are we

3 mixing up point of --

4 MR. DOUGHERTY: Instantaneous, it is all

5 together.

6 MR. STANONICK: All right. Well, we

7 certainly, we've got an understanding, we certainly

8 think that you at least need to measure it at the 77

9 degree rise, because now you are including products

10 that at least, in some applications, will be presented

11 as equivalent to serving the same need that your

12 storage water heater would have served.

13 And so, I certainly would support that at

14 least it gets measured at 77.

15 FACILITATOR RABA: Other thoughts, please.

16 Do you all agree with that? Do you disagree with it?

17 In the back please.

18 MR. BERNADOWSKI: Tim Bernadowski,

19 Virginia Power. We support the gallon per minute

20 rating. We think that is much more appropriate for

21. that type of equipment. I think the temperature rise,

22 what you want to do is have some consistency across

23 the different pieces of water heating equipment.

24 And I think somewhere else in your agenda,

25 you have the discussion of, if you have storage

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
129

1 equipment, what temperature do you use? What's that

2 temperature? I think whatever temperature rise you

3 use for instantaneous should be consistent with

4 whatever temperature you decide is appropriate on the

5 storage.

6 FACILITATOR RABA: Thank you. Others,

7 please?

8 MR. ROSENSTOCK: Steve Rosenstock, Edison

9 Electric. Another factor to possibly, is the relative

10 use of the instantaneous water heaters in residential

11 versus commercial applications.) It is possibly

12 because also, in commercial application it might be

13 more likely if water temperature, especially in the

14 urban areas, inlets are going to be higher to being

15 with regardless.

16 And if most of the instantaneous water

17 heaters will be used in the commercial and industrial

18 applications, then obviously that is going to effect

19 what the actual temperature rise is going to be. I

20 would tend to actually go more towards a 50 degree

21 fahrenheit temperature rise.

22 MR. RANFONE: Jim Ranfone, AGA. Just a

23 clarification. You are only talking residential

24 applications, right, not commercial or industrial?

25 FACILITATOR RABA: Anybody want to

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
130

1 respond?

2 MR. BERRINGER: Bryan Berringer, it is

3 just residential.

4 MR. ROSENSTOCK: Oh, it is just

5 residential, okay.

6 MR. DOUGHERTY: One is covered by the

7 definition in the test procedure. So that gets back

8 to Don Abrams comment that although it may be intended

9 for residential, it may end up in a commercial

10 application.

11 FACILITATOR RABA: Instantaneous water

12 heaters, temperature rise, flow rate, other comments

13 or views on this particular issue?

14 DR. HILLER: Carl Hiller from EPRI. Let

15 me just summarize what I think I heard everybody say.

16 I think there is general agreement about a gallons per

17 minute rating. There is not disagreement with a 77

18 degree rise, but maybe having two ratings, 50 and 77

19 is a little more practical.

20 Seventy-seven has a benefit of being

21 comparable to the tank-type water heater test. And

22 representing a maximum rise condition in the field.

23 And 50 has the advantage of being kind of an average

24 rise condition and easy math. So if we had just two

25 numbers, it would kind of solve both concerns.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
131

1 FACILITATOR RABA: I like easy math. Go

2 ahead.

3 MR. STEPHENS: Charles Stephens, from

4 Oregon Energy Office. I have to ask a question. I am

5 not really familiar with what, with everything that's

6 out there. Are there equipment that can't meet a 77

7 degree rise at their minimum flow rate?

8 MR. DOUGHERTY: Good question. How low do

9 electric go?

10 DR. HILLER: Well, there is some minimum

11 flow rate that they will turn on. I think the way

12 most of them work is that there is a flow switch and

13 they activate on flow, regardless of flow rate. But

14 there is a thermostat to turn them off if the outlet

15 gets above a certain temperature. And it is that

16 turnoff temperature that would govern the minimum flow

17 rate.

18 MR. STEPHENS: Right, right, if it

19 overheats, it would shut off.

20 DR. HILLER: But that would be way above

21 the 77 degree rise.

22 MR. STEPHENS: I don't know --

23 DR. HILLER: That's like a 150 or 160

24 safety net.

25 MR. STEPHENS: Yeah, I was suggesting I

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202). 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
132

1 guess that if there is such a product, that you might

2 have to put a clause in the rating literature to say

3 77 degrees or whatever the maximum temperature is that

4 it can reach at its minimum flow rate. And that it

5 would have to specify what that is, what its maximum

6 temperature would be.

7 MR. KUSTERER: George Kusterer, with Bock

8 again. I have a little bit of a problem with that 50

9 degree rise. It, you know, under, I have well water

10 obviously, being a poor dumb farmer from Pennsylvania.

11 And my well water comes in at about 40 degrees,

12 because I am down 300 and some odd feet.

13 Now at a 50 degree rise, I am not going to

14 get a very hot shower. And I don't suspect a lot of

15 other people will either. I don't think that 50

16 degree rise is such a hot number. I like the 77.

17 FACILITATOR RABA: Anybody else from

18 Pennsylvania?

19 (Laughter.)

20 MR. STEPHENS: Charlie Stephens, again.

21 I realize that there are a lot of places in the

22 country where, you know, your average inlet

23 temperature is 45 to 50 degrees. We are at 54,

24 typically. But that's not the case in places like

25 Florida, Alabama, Mississippi, Texas. And there is a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
133

1 substantial portion of the country that live down

2 there.

3 And I am not averse to accommodating those

4 people, if it is an easy thing to do. And I think

5 this test is probably an easy thing to accomplish, to

6 get both numbers. I think we are going to see more of

7 this as we look at standards. This is just one

8 instance where not every place in the country is the

9 same and some people will make use of one number and

10 some people will make use of another.

11 But if it is cheap and easy to give them

12 both, why not?

13 FACILITATOR RABA: Anybody else.

14 MR. KUSTERER: Well, how do we know where

15 the product is going to be sold?

16 MR. STEPHENS: Your plumber will tell you.

17 (Laughter.)

18 FACILITATOR RABA: Go ahead.

19 MR. DUCH: Generally, you are going to

20 assume that the water in the northeast is 50 degrees

21 and a 50 degree rise will give you 100. That's

22 unacceptable, it is simple as that.

23 DR. HILLER: That's not the point. The

24 point is that it makes the math easy. We are not

25 implying that a 50 degree rise is generally

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
134

1 acceptable.

2 MR. DUCH: If we are doing something for

3 the consumer, and he doesn't get hot water because the

4 math is easier, it is not reality. Some of the

5 country is 60 and 50, something is very wrong. We

6 should get another government funded reading program

7 in that school.

8 (Laughter.)

9 MR. VAGO: Otto Vago, State Industries.

10 We do support the gallon per minute for 77 degree

11 rise, only. The second comment is what the gentleman

12 proposed that the, whatever the temperature

13 differential going to be at a minimum flow rate, that

14 would confuse the issue I think considerably.

15 I believe, if I understood the gentleman

16 saying that from the minimum flow rate, whatever that

17 temperature differential will be, I think that would

18 be very confusing.

19 MR. STANONICK: If they could do 77.

20 MR. VAGO: If they could do 77 in the

21 first place. Thank you.

22 MR. RANFONE: Jim Ranfone, AGA. I guess

2:3 I had a question for FTC. Once this does get in

24 place, this coverage is extended, what would be your

25 options in terms of requiring labeling on this

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
135

1 product? Is it a covered product that would require

2 labeling?

3 MR. MILLS: This is the electric?

4 MR. RANFONE: The electric instantaneous.

5 MR. MILLS: It would --

6 FACILITATOR RABA: James Mills, FTC.

7 MR. MILLS: James Mills, FTC. If it were

8 a product that was covered by the Department of

9 Energy's test procedure, it would be a new product and

10 we would examine it on the public record with input

11 from the public, whether it should be labeled. And if

12 so, how it should be and what kind of a descriptor we

13 want to use to describe the energy use and how to size

14: it. Whether first hour rating or gallons per minute

15 would be appropriate.

16 Similarly, if we were, the DOE test

17 procedure is modified so that the rating becomes

18 gallons per minute for these products, we would have

19 to look at our rule in a rule making to determine

20 whether we should change that for labeling purposes

21 and for purposes of our ranges of comparability.

22 MR. RANFONE: Okay, but this issue about

23 the temperature, Jim Ranfone, AGA, whether it is 50 or

24 77 is going to have modifications on where you are

25 using this product. And that's the point I want to

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
136

1 get to.

2 MR. MILLS: Our labels are really driven

3 by the DOE test procedures, so that would be settled

4 in this proceeding. And we would move on from there.

5 FACILITATOR RABA: Steve.

6 MR. ROSENSTOCK: Steve Rosenstock, EEI.

7 My mother is from Scranton, Pennsylvania, I hope

8 that's okay with you.

9 MR. KUSTERER: No, that's fine, they just

10 have high water pressure over there, that's all.

11 MR. ROSENSTOCK: Okay, that's why she

12 moved out.

13 (Laughter.)

14 MR. ROSENSTOCK: In terms of the

15 temperature rise, I think it is very important to have

16 that 50 degrees, because like the gentleman from

17 Oregon said, there are a lot of places like Miami and

18 Texas where the inlet temperature can be higher than

19 40 degrees for a good portion of the year, if not all

20 of the year.

21 And especially, if you are looking at the

22 energy usage patterns, to be base something, it is

23 better if you want a range, do a low range, because

24 again that is going to be real conditions if people

25 are doing energy studies or analysis in those

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 2344433

 EE-RM-94-230 COMMENT 49P
137

1 conditions, where people only need a 50 degree rise.

2 I mean, do a simulation or saving

3 calculation, if they are not needing the 77 degree

4 delta. Is you know, it will overestimate all the

5 energy usage and all the other annual costs, etcetera,

6 associated with that product.

7 MR. KUSTERER: George Kusterer again. Are

8 we assuming that because Florida is south and it is

9 relatively hot down there at times, that their water

10 temperature is 60 or 70 degrees inlet from the street?

11 DR. HILLER: We have lots of data on that.

12 MR. STEPHENS: We have lots of data on

13 that, we don't have to assume.

14 MR. HEISS: Harold Heiss, American

15 Electric Power. I am a hydrogeologist. And the mean

16 average ground water temperatures reflect the mean

17 annual air temperatures. You'll find water

18 temperatures up in the Dakotas from the 40's to down

19 in Miami and Brownsville, Texas to be 75 to 80

20 degrees.

21 So the, it does change and it has been

22 mapped and it does exist. And Miami's, I believe, is

23 about is about 72 degrees.

24 MR. DUCH: What's the average?

25 MR. KUSTERER: Well, what do they need

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
138

1 water heaters for?

2 MR. HEISS: The average for the states.

3 (Laughter.)

4 FACILITATOR RABA: Hold on, I can't here,

5 one at a time. Go ahead.

6 MR. DUCH: What is the average for the,

7 what is the 50th percentile?

8 MR. HEISS: I would imagine the 50th

9 percentile would be somewhere in the mid 50's.

10 MR. DUCH: The mid 50's plus 50, makes it

11 105. Which is the minimum acceptable.

12 FACILITATOR RABA: Interesting point,

13 thank you very much. Any comments, sir.

14 MR. PAUL: No, I was just going to say the

15 same thing he just said.

16 FACILITATOR RABA: Just trying to

17 reinforce the comment.

18 MR. HEISS: Yeah, I am remembering Miami

19 temperatures as being closer to 78 or 79. That's a

20 function of the depth of ground water.

21 MR. STANONICK: Frank Stanonick with GAMA.

22 There is an assumption that we've all bought into

23 here, whether we recognize it or not. And we are all

24 talking about that we just want to get this water to

25 110. And that these electric instantaneous water

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
139

1 heaters are only going to be used in cases where you

2 are supplying hot water for people, as opposed to hot

3 water for the house.

4 Well, the hot water for the house, needs

5 water for the clothes washer, it needs water for the

6 dishwasher, and other uses where the people never

7 touch the water, if you will. And if you use an

8 instantaneous water heater to supply my dish washer.

9 Let's say I had an old dish washer that didn't have

10 its own preheater or something.

11 And for whatever reason I wanted to have

12 a water heater supplied directly to the dish washer,

13 they are not going to be interested in 110 water.

14 They are going to want 140 degree water or there

15 abouts. In fact, that would be a pretty reasonable

16 application perhaps. And in that case, 50 degree rise

17 and the water is 70 or 80, I don't care, it ain't

16 gonna do it.

19 And so I think as long we, well, first of

20 all we are talking about all types of electric

21 instantaneous and I think everyone should recognize,

22 up to this point, we were just talking about those

23 applications where somebody is in the water. In the

24 shower, bathtub, hand washing or whatever.

25 But you can't ignore the other

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
140

1 applications where in fact you are delivering water to

2 a machine and in fact the desire may be to have hotter

3 water for that machine. And when you get to those

4 situations, a 50 degree rise has, I don't think it has

5 any value.

6 FACILITATOR RABA: Charlie.

7 MR. STEPHENS: I hate to keep standing up.

8 Charlie Stephens, Oregon. I don't want to go into

9 this. I live perfectly well, and without any

10 amenities suffering, with a 50 or 55 degree

11 temperature rise, from a system exactly like the one

12 we are talking about for a couple of years in

13 Colorado.

14 And Colorado is kind of, you know, between

15 Florida and North Dakota. So, you know, it wasn't the

16 coldest and it wasn't the warmest, but I did very well

17 on that, and I didn't suffer for having had it. But

18 I think that we are all losing sight of the fact here

19 that we are trying to provide people information.

20 And the fact is, that if I see a number of

21 flow rate at 50 degree temperature rise and I see a

22 flow rate at 77, I am going to be able, I am an

23 engineer, I mean I see these things this way. I am

24 going to be able to try to figure out what my maximum

25 flow rate requirements are.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
141

1 And these things are set for temperature

2 anyway. And you know, if the flow exceeds what it is

3 rated for at that temperature, well the water is going

4 to cool off. Everybody recognizes that..

5 But let's not presume to be deciding what

6 is adequate for consumers. I think most consumers

7 will, they'll hear it out, or if it is inadequate,

8 they will fix the situation. Hopefully, some

9 intelligent people will expect these things.

10 I think what we are trying to do here is

11 provide information for the people who are going to

12 make the decision. And I think a two point scale that

13 shows people what the range of operating conditions

14 that this thing could actually provide, provided they

15 are installed right, is all we really need here.

16 I don't think it matters whether it is

17 adequate for this group of consumers or that group.

18 They will be sold, hopefully, where they are adequate.

19 FACILITATOR RABA: The gentleman with A.O.

20 Smith.

21 MR. HAAG: Wilbur Haag, with A.O. Smith.

22 I would be in favor of a single GPM 77 degree

23 temperature rise, based on comparable ratings. I can

24 envision the manufacturers of these devices having a

25 whole host of GPM's, 20, 40, 60, 80 and 100 degrees

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
142

1 rise in their literature. Such will suffice. I don't

2 see any reason to complicate it with two. I think 77

3 degrees would be adequate.

4 MR. MILLS: James Mills, FTC. If we were

5 to label these products it would be simpler for

6 consumers to have a single number for comparative

7 purposes.

8 FACILITATOR RABA: George, then Steve.

9 MR. KUSTERER: One final comment. I would

10 like to go on record in supporting Wilbur Haag from A.

11 O. Smith with his recommendation with a single digit

12 number, using the gallon flow rate.

13 FACILITATOR RABA: Thank you. Steve.

14 MR. ROSENSTOCK: In terms of the labeling

15 issue, I just know on many, most appliances, water

16 heaters, air conditioners, furnaces, that the yellow

17 label, the FTC label that everyone sees there is

18 always a variety of information of them.

19 For example, with water heaters they show

20 various rates of electricity from I'll say four cents

21 per kilowatt hour, up to 14 cents per kilowatt hour.

22 MR. STANONICK: Not on the water heater

23 label.

24 MR. KUSTERER: That's the dish washer

25 label.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
143

1 MR. MILLS: James Mills, FTC. Before you

2 go any further, we've changed or labels. They don't

3 have those cost grids on them any more, that you are

4 addressing.

5 MR. ROSENSTOCK: They don't?

6 MR. MILLS: Because we've found that they

7 were a little too confusing for people.

8 FACILITATOR RABA: Thank you. Stan.

9 MR. LIU: The energy factor is also

10 determined on 175 degree temperature. So if you go 50

1L degree rise, then you have to run another test to

12 recertify and the manufacturer might consider that an

13 added burden.

14 FACILITATOR RABA: Other thoughts and

15 views about the instantaneous questions?

16 (No response.)

17 FACILITATOR RABA: Well, indeed we

18 gathered a lot of information so far this morning on

19 both our first hour rating and instantaneous water

20 heaters. Keep some of these in mind, we will come

21 back after lunch and if we'd like to pick some this

22 up, we can table it and go to it later on.

23 I would like to invite a lunch break at

24 this time. If there is nobody else that wants to talk

25 at this time, we can do that. I would recommend that,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
144

well, what would you like to do, just take one hour?

Please come back at 1:00. We will pick up with our

next topic on the storage-type water heaters less than

20 gallons. If you haven't already registered, please

do so.

(Whereupon, the foregoing matter

went off the record at 12:13

p.m. for a lunch recess.)

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

1

2

3

4

5

6

7

8

9

10

11.

12

13

14

15

16

17

18

19

20

21

22

23

24

25

(

 EE-RM-94-230 COMMENT 49P
145

1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

2 (1:10 p.m.)

3 FACILITATOR RABA: Thank you very much for

4 a very lively discussion this morning. Some good

5 information has been gathered certainly. And we look

6 forward to -- the easy stuff we've covered; right?

7 We'll get to the hard stuff this afternoon.

8 However, we would commend to your

9 attention a statement of Control Energy corporation --

10 it was in your packet of information -- regarding

11 gas-fired water heaters.

12 For the record, we just would like you to

13 take a look at that and review those comments as well.

14 They are part of the record. You'll review these as

15 we go along. If there are any comments on these, we

16 can hold them for later on or we can discuss them now

17 if you'd like.

18 Also, a reminder that we have in your

19 packets a summary of those issues on Page 8 of the DOE

20 water heater workshop summary of issues and comments

2:L prepared by Bryan dated February 12th, today, just to

22 keep us on track with some of these issues, some good

23 summaries there.

24 George?

25 MR. KUSTERER: Before we go on, -- and I

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
146

1 don't want to really belabor this -- we seem to have

2 skipped over an issue regarding: Should DOE adopt the

3 alternate test method proposed by Carl Hiller?

4 This is George from Bock Water Heaters.

5 It would be my recommendation that because

6 the information provided by Carl Hiller with regard to

7 test procedures dated today is somewhat not

8 conclusive, it would be Bock's recommendation that DOE

9 not accept Carl Hiller's proposed test procedure as it

10 is written.

11 FACILITATOR RABA: Is there another view

12 on that, please?

13 (No response.)

14 FACILITATOR RABA: Okay. We'll note that.

15 Certainly we'd like to gather more data as well.

16 Perhaps if other manufacturers and organizations have

17 additional data to gather so we can evaluate, it would

18 be very helpful, too. And I appreciate your comments.

19 One more thing, please. Thank you. I

20 note, too, as a housekeeping matter that it's kind of

21 hard, even for me, to hear in the back, not because

2:2 your voices aren't loud enough, but we've got the

23 soundproof on the wall back there. So we would invite

24 you to either speak up a little bit louder with your

25 name or we provide at no extra charge this microphone

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
147

1 in full view of everybody. Behind the pillar, you

2 couldn't be seen. Now you can be seen and heard both.

3 So whatever is comfortable, please.

4 Go ahead.

5 MR. DUCH: Further on the point that --

6 FACILITATOR RABA: Your name again, sir?

7 MR. DUCH: Adam Duch, Group Thermo.

8 FACILITATOR RABA: Thank you.

9 MR. DUCH: Just further on the point that

10 was mentioned by Bock's working person, the tests,

11 should they be done on the basis of another dozen test

12 families or water heaters are selected on the basis of

13 what is in the house?

14 FACILITATOR RABA: Is that a question for

15 the group?

16 MR. DUCH: Yes because in my view I

17 suppose they did them for all of them. The water

18 heater is selected, what demand is in the house, not

19 how many people are in the house now because the house

20 may be sold in five years and the water use may go up

21 tremendously. So the water heaters are based and put

22 in, what is in the house. That's realistic.

2:3 FACILITATOR RABA: Can anybody respond,

24 please? Can you give any opinions or what are your

25 views on that? Go ahead. Your name again, sir?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
148

1 MR. LOWENSTEIN: Yes. Andy Lowenstein,

2 AIL Research.

3 The issue of whether people are installing

4 water heaters based on a specific family or whether

5 they're sizing it for the house is a little bit of a

6 red herring issue.

7 I think the data that were shown this

8 morning by Carl, though he was using specific

9 families, could have been generalized to a generic

10 family that represented your 95th percentile house

11 family that was likely to move into any particular

12 house.

13 I think what the procedure that was shown

14 this morning tried to focus on was more the ambiguity

15 in the current way of doing things; that is, the

16 possibility that you may have a water heater if it has

17 a high one-hour rating, even higher than an

18 alternative water heater it's being compared to. Yet,

19 it may reach its limit at early water draws or under

20 a particular set of circumstances.

21 Certainly the methodology presented this

22 morning was in no sense meant to be definitive or was

23 meant to be a proposed rating procedure that should be

24 followed. I think it was more intended to show that

25 there are problems in the current way of doing it and

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
149

1 that the one-hour rating in some sense is a

2 disservice, can actually mislead people into putting

3 the wrong water heater into the house. And in that

4 sense, maybe no information is better than providing

5 the one-hour rating in particular.

6 And I would ask the question of the people

7 who are sort of supporting the one-hour rating: Why

8 the one-hour? I think it's a question that certainly

9 has been raised over the years when this topic gets

10 discussed. What is magical about the one-hour rating?

11 Again, I think this morning's presentation

12 by Carl points out that you can come to completely

13 different conclusions by playing with that number.

14 And, again, the one-hour rating, again, in some sense

15 provides maybe misleading information or a false sense

16 of security, "I have this number that I can hold onto.

17 Now let's start making comparisons" when that number

18 really isn't anchored into anything in reality,

19 anything significant.

20 FACILITATOR RABA: Does anybody have any

21 facts in the background of that or -- go ahead.

22 MR. DUCH: It was mentioned before in the

23 test data presented by Dr. Hiller this morning. And

24 that was supported by the gentleman from Argonne. If

25 you look at the demand for one month at one hour, any

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
150

1 water heater heating that demand would be good for the

2 house. Water heaters meeting lower demands may not

3 satisfy that one-month, one-hour demand. That's one

4 hour, shown by the data.

5 MR. LOWENSTEIN: Can I address that?

6 FACILITATOR RABA: Go ahead, please.

7 MR. LOWENSTEIN: Yes. Andy Lowenstein

8 again, AIL Research.

9 I think if you really look at the data

10 that was presented this morning, you come to the exact

11 opposite conclusion, which is that there are very

12 definite cases where the one-hour rating was much more

13 than adequate for the house.

14 But if you start looking down in the

15 30-minute time period, that same water heater that had

16 a more than adequate one-hour rating would lead to an

17 unacceptable number of run-outs for that particular

18 home, the exact opposite conclusion than what the

19 person behind me said.

20 MR. DUCH: I guess statistically you can

21 look at a set of numbers and get ten different

22 conclusions.

23 FACILITATOR RABA: Hold on. Thank you.

24 Charlie?

25 MR. STEPHENS: Charlie Stephens.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
151

1 I don't recall those data where I think

2 you all agreed that the gas water heater had some

3 instances at the earlier time frame, the 30-45-minute

4 period, that appeared to be what I think we also all

5 agreed that a 45,000-BP-per-hour water heater is

6 probably more typical of what's out there than what

7 was in that test and in the data that Carl showed.

8 I came to the conclusion that most of the

9 time a 50-gallon gas water heater or a 52-gallon

10 electric water heater was more than adequate to serve

11 the family most of the time and that they might have

12 been oversized to some extent. But I don't see there

13 being a big penalty from that.

14 And I don't have any evidence that the

15 description of water heaters for houses right now led

16 into misapplication based on what we know today.

17 MR. KUSTERER: George Kusterer, Bock.

18 And, again, the report that we saw this

19 morning gave us a lot of time frames and gave us a lot

20 of gallons, but nowhere did I see temperatures. And

21 I think this would have a tremendous impact on that

22 study as well as the gas unit that was used.

23 Is it typical? I doubt if it was typical.

24 And I'm seriously concerned with the report that an

25 electric heater. Although they are very good and they

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
152

1 are an extremely important item to the consumer, I

2 just -- and I don't doubt their research, but I just

3 can't believe that an electric water heater is far

4 superior to an alternate fuel.

5 So, therefore, I stand and state publicly

6 for the record that we at Bock oppose DOE accepting

7 this proposal.

8 FACILITATOR RABA: Other thoughts, please,

9 and views?

10 DR. HILLER: Can I respond to that?

11 FACILITATOR RABA: Yes, of course. Go

12 ahead.

13 DR. HILLER: Carl Hiller from EPRI.

14 I apologize if you came away with the

15 impression that I was trying to show that 50-gallon

16 electric was better than 50-gallon gas. That was not

17 my intent.

18 The primary thing I was trying to achieve

19 was showing that a first-hour rating number is -- the

20 one-hour time frame is way beyond the time frame of

21 interest for whether or not it's adequate to serve the

22 load.

23 The gentleman back in the back here from

24 Argonne just said that he thinks the data shows that

25 50-gallon gas and 50-gallon dual and electric are

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
153

1 pretty comparable. That's probably generally a true

2 statement, but if you look at the first-hour ratings

3 that those two tanks have, they're vastly different.

4 Therein lies the problem with the

5 single-number rating out anywhere near one hour.

6 They're both adequate to serve the load, but one has

7 a much higher rating than the other. So what does the

8 rating mean?

9 MR. KUSTERER: Again I ask my question

10 which I asked earlier this morning: What do you

11 propose?

12 DR. HILLER: My'proposal if you're going

13 to have a single rating number is first draw.

14 MR. KUSTERER: It won't work.

15 DR. HILLER: That is the least of all

16. evils.

17 MR. KUSTERER: It won't work.

18 FACILITATOR RABA: We probably need some

19 more data on this, too. Certainly it's a very

20 interesting subject. And there may be more

21 examination needed, too. So I would invite anyone

22 with some thoughts, even after today's workshop, to

23 get back to the Department with those, maybe written

24 comments.

25 Data is most helpful. We would appreciate

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
154

1 receiving those, too. I sense we may not come to a

2 conclusion on this today but indeed would certainly

3 entertain other views as we go along.

4 There was a hand in the back there.

5 MR. MILLER: Rick Miller, Rheem

6 Manufacturing.

7 Speaking as a marketing person, which

8 probably to most people here is the scum of the earth,

9 the idea of a real world environment, that being

10 plumbers, installers, people we sell our products to,

11 with regards to a first-hour rating, from my

12 experience, it's a number that is published by us and

13 the other manufacturers. But I think in the real

14 world, that being a consumer, it's a number that is

15 very seldom used.

16 If you think that there are 90 million or

17 so odd water heaters installed today, every one of

18 them started as a new construction; that is, some

19 plumber deciding, "What water heater am I going to put

20 in this home?"

2:1 And when he looks at that, he's looking at

22 the size of the home and what does it cost and what is

23 it going to do. And if it's a 1,500-square-foot home,

24 he's probably going to put in this size water heater.

25 If it's a 2,000-square-foot home, he may put in a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
155

1 little bit larger water heater. And if it's a

2 3,000-square-foot home with a whirlpool tub, he's

3 going to put in a larger water heater.

4 When that water heater fails, that

5 consumer is going to decide, "What do I replace it

6 with?" In 99 percent of the cases, they're going to

7 replace it with the exact same water heater if it has

8 adequately served their needs.

9 But when Family A buys this home new, then

10 sells it, and Family B moves into it, those water

11 consumption patterns may change dramatically. And

12 that's when the homeowner will say, "Well, this

13 40-gallon water heater isn't enough. I'm going to buy

14 a 50-gallon" only because they relate to capacity, not

15 to first-hour in my opinion.

16 FACILITATOR RABA: Thank you. Thank you.

17 Comment, please?

18 MR. RANFONE: You started talking about a

19 schedule of written comments. Based on the discussion

20 today, are you expecting comments by a certain date or

2: -

22 MR. BERRINGER: We can open this

2:3 discussion at the end of the day. Are 30 days

24 adequate to give comments? We'll determine it as one

25 of the closing items.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
156

1 MR. RANFONE: Again, Jim Ranfone, AGA.

2 To another issue, back to the first-hour

3 rating, its value or if it's not valuable, I ask the

4 question again. I don't. think we can just say

5 gallonage is the way to go on this thing.

6 It's been the practice in the past, but if

7 first-hour is a valid way -- Carl did some

8 stimulation. And he used a gas. I don't know what

9 assumptions you made in the gas. I wouldn't consider

10 them valid from what I've heard said so far, but it's

11 not a gas/electric battle here.

12 What I'd like to see is an effort to

13 explain the size of water heaters properly so that you

14 don't have the complaints of callbacks of not enough

15 water heated.

16 FACILITATOR RABA: Tough question.

17 Go ahead.

1:3 MR. RANFONE: If that's the purpose of the

19 first-hour rating was a scheme in order to categorize

20 water heaters, why isn't that to be made when it was

21 first published in 1979?

22 FACILITATOR RABA: Steve?

23 MR. ROSENSTOCK: I was just going to say

24 in terms of market data that DOE's -- I don't know

25 when the next RECS is going to be published or going

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
157

1 to be sent out to people, the residential energy

2 consumption survey.

3 One area -- you know, obviously it asks

4 about what type of water heater, what type of fuel do

5 you have, do you have water, what type of water

6 heater, what type of fuel.

7 In some of those surveys, it might be of

8 benefit to DOE to ask, "Did you increase the size?

9 Did you decrease the size?"; some of the I'll just say

10 more consumer-type data, just to see what were the

11 main factors.

12 It might be of interest for all parties to

13 see in an unbiased survey, "What did people choose or

14 how did they choose it? And did they really care

15 about what the fuel source was? And how did they

16 figure out what size to buy? If they changed the

17 size, what were the main factors?"; things like that.

18 FACILITATOR RABA: Sure.

19 MR. ROSENSTOCK: So just as another

20 focusing on the future, another --

21 FACILITATOR RABA: On the future, sure.

22 Thank you.

23 Again, I commend to you the questions that

24 we have asked about this subject. What is the purpose

25 of the first-hour rating? What are the different

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
158

1 methods for determining it, the test procedures? We'd

2 like to get that input from you. And what is the

3 preferred method? Again, we need some constructive

4 direction-pointing comments, which would be very

5 helpful to us.

6 As an aside, I note that the workshop

7 procedure that we're going through here today is part

8 of the new process for the rulemakings on test

9 procedures. We hope to continue this forum, workshop

10 format, in the future to air these views out and to

11 get both sides and to hear everybody's points of view

12 as much as possible to engage in dialogue so that you

13 know that we're trying to be responsive to everybody

14 and everybody's concerns and needs but also entertain

15 data to come back to us, factual data, things like

16 that. We appreciate your time and efforts with that.

17 Any further discussion? We should move

18 on. We can table the first-hour rating now, if you

19 would. Any further discussion on this at this time,

20 please?

21 (No response.)

22 FACILITATOR RABA: Thank you.

23 Let's go on, please, to our next agenda

24 item, storage-type water heaters with storage

25 capacities of less than 20 gallons. Your agenda asks

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
159

1 some questions. Should test procedures be developed?

2 And if so, what type of test? What should the draw

3 rate and daily volume be? Should there be a lower

4 size limit? And should test procedures be developed

5 for storage-type less than ten gallons?

6 Would anybody care to open with any

7 background or views on that? Charlie?

8 MR. STEPHENS: Charlie Stephens.

9 I'd like to open this with a question.

10 Can somebody, one of the manufacturers here, tell us

11 what fraction of the storage water heater market these

12 20 gallons and less represent?

13 MR. MILLER: Rick Miller with Rheem.

14 It's a small percentage of our business.

15 MR. STEPHENS: Ten? Three? Two? Seven?

16 MR. STANONICK: Closer to ten, closer to

17 ten.

18 MR. STEPHENS: Ten percent?

19 MR. STANONICK: Ten is probably a little

20 high but not much.

21 MR. STEPHENS: Okay.

22 MR. STANONICK: Let's say between six to

23 nine percent.

24 DR. HILLER: How many of those are gas?

25 MR. STANONICK: None.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
160

1 DR. HILLER: It's all electric?

2 MR. STANONICK: It's all electric. The

3 data we have is all electric.

4 DR. HILLER: So 10 percent of the electric

5 water-heating market is 20 gallons or less?

6 FACILITATOR RABA: Brian?

7 MR. DOUGHERTY: Just curious. I had some

8

9 FACILITATOR RABA: Brian Dougherty from

10 NIST.

11 MR. DOUGHERTY: Thank you, Jim.

12 A 19-gallon gas, just underneath the

13 threshold?

14 MR. STANONICK: That product has pretty

15 much disappeared.

16 MR. DOUGHERTY: Okay.

17 MR. STANONICK: Earlier on, it was 20

18 gallons. Some people did 19. That approach has gone

19 by the wayside.

20 FACILITATOR RABA: Steve?

21 MR. ROSENSTOCK: Steve Rosenstock, EEI.

22 I guess another question would be usage

23 pattern. Is it residential for a particular appliance

24 or device, such as a whirlpool or something, or is it

25 a more general use? Is it multi-use or single-use?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
161

1 That's another critical factor on this discussion for

2 this particular unit.

3 FACILITATOR RABA: Certainly.

4 Brian?

5 MR. DOUGHERTY: Brian Dougherty, NIST.

6 What happened here is simply that NAECA

7 included language, NAECA in regards to the standards

8 rulemaking back in '87. It was suggested that water

9 heaters less than 20 gallons should be covered. And

10 that's where this comes from.

11 The question is homeowners came in with

12 the question that as a percent of market, don't worry

13 about it. Even though NAECA says you should cover

14 them, just maintain the existing approach that this is

15 at a lower value.

16 So the question now becomes: Should we

17 take it to zero, should we leave it at 20, or should

18 we come up with some other value in between? And once

19 we come to that bottom value, then go on with the rest

20 of the issues. That's kind of leading into the last

21 bullet items under this discussion.

22 FACILITATOR RABA: Frank, then Charlie.

23 MR. STANONICK: Frank Stanonick, GAMA.

24 To answer the last question, DOE has

25 already to some extent identified a floor, if you

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) , _ _, 234-4433 ..

 EE-RM-94-230 COMMENT 49P
162

1 will. Gas instantaneous water heater has in its

2 definition a less than two gallons, two gallons.

3 Basically two gallons is the cutoff point.

4 So I think that does at least suggest one

5 possibility, which would be that you could take less

6 than 20 down to 2 gallons. And those can be

7 considered in this class of what I'll call

8 point-of-view storage water heaters. I'm not sure

9 what else to call it.

10 The thing is, first of all, to our

11 knowledge, they're all electric. Clearly, clearly

12 there's a lot of those that end up in an installation

13 that you wouldn't consider residential, but the fact

14 is the law says what it says. And so they've been

15 lumped in with this test procedure, if you will.

16 We're supportive of having some method of

17 evaluating those products for efficiency. The more

18 we've looked into it, certainly a simulated use kind

19 of test, at least the one in the test procedures,

20 doesn't come close to having any relevance.

21 And even some other kind of test that

22 might have an energy factor, at this point in time, we

23 haven't been able to figure a procedure that would

24 give you what I'm going to call a reasonable number.

25 Those products to the extent it was ever

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
163

1 -- well, to the extent it was enforced is a separate

2 question, but those products hadn't been addressed for

3 a long time in ASHRAE Standard 90.

4 Those of you who go back that far, there

5 was standby loss for electric residentials that was

6 four watts per square foot of tank surface area. And

7 then you had a total of 43 watts, whichever was

8 greater. So there was, in fact, a minimum/maximum

9 standby loss if you followed that.

10 That really applied to those small-volume

11 products, where the concept of a watts per square foot

12 lost sense. And so what we have suggested is that's

13 how those products were addressed in ASHRAE Standard

14 90.

15 And to make the step of getting them in

16 the test procedures we think at this time what DOE

17 should do because it can be done quicker and we

18 believe perhaps with less and muss is that kind of an

19 approach, to say, "Okay. For the less than 20, we're

20 not going to pretend that they compare to a

21 residential storage water heater. They're a different

22 product. And they are all electric. They're all

23 immersed elements. The recovery efficiency is a

24 known." And the only issue is really their standby

25 loss. So it could be addressed by strictly a maximum

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
164

1 standby loss requirement.

2 FACILITATOR RABA: Charlie?

3 MR. STEPHENS: We second.

4 FACILITATOR RABA: Are there opposing

5 points of view? Carl?

6 DR. HILLER: I'm basically supporting most

7 of what Frank just said. Let me state it a little bit

8 different way. There are really kind of two issues.

9 One is: Should 20 gallons or smaller have a standard?

10 What do we get by having a standard, how much impact

11 on national energy consumption or whatever we're going

12 to do by having the standard?

13 The second issue is: If we decide to have

14 a standard, what should that standard be? The last

15 proposal in 1995 was to have a similar draw schedule

16 to the larger tanks but with smaller volumes.

17 And just so everybody understands the same

18 playing field here, the science is very clear on that

19 issue that if you take tanks smaller than 20 gallons,

20 especially smaller than 10 gallons, and try and apply

21 the 6 equal draws, the 64.3 gallons, you run out of

22 hot water. And once you run out of hot water, the

23 test is invalid. It's meaningless. So you have no

24 choice but to change the gallons consumption.

25 As soon as you change the gallons

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 

. . 234-4433

 EE-RM-94-230 COMMENT 49P
165

1 consumption, you change the ratio of standby loss to

2 actual useful heat provided. And that changes the

3 efficiency. So it is if you change the gallons

4 consumed, it is not possible, physically not possible,

5 to meet the same energy factor equations. Those are

6 scientific facts.

7 So you've got to do something. If you're

8 going to have any kind of energy efficiency rating for

9 the smaller tanks, it has to be different than the

10 larger tanks. Then what is it? is the next question.

11 FACILITATOR RABA: Good question. What

12 would that be? Does anybody have any views on that,

13 thoughts, on what kind of procedure that would be?

14 MR. VAGO: What kind of procedure?

15 FACILITATOR RABA: Well, what procedure,

16 yes, if it's to be different, the same, different.

17 MR. STANONICK: Okay. My proposal would

18 be you would just run a standby loss test over

19 obviously some length of time, but you end up with an

20 hourly standby loss number.

21 DR. HILLER: In absolute watts or

2:2 something like that.

23 MR. STANONICK: Right.

24 FACILITATOR RABA: I heard a "Hear, hear"

25 in the back.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
166

1 MR. DOUGHERTY: Jim, just one thing.

2 FACILITATOR RABA: Go ahead, Brian.

3 MR. DOUGHERTY: Brian Dougherty, NIST.

4 I like the loss test, too. The only thing

5 I want to bring into it is if you limit the

6 storage-type water heater to 64.3 gallons and below 20

7 you go to a standby loss test, would you use a

8 different draw profile on instantaneous water heaters

9 that have a lower input -- we actually skipped over

10 that one from the morning -- or do you continue to

11 have instantaneous water heaters that have the low

12 input at 64.3 gallons, too?

13 It's a side issue I thought at one point

14 may have merit to test those at lesser daily uses if

15 that was a docket for the storage-type. But if you go

16 to a standby loss test for storage-type, then do you

17 stay with 64.3 because you can't --

18 DR. HILLER: Let me address the issue of

19 energy factor rating for an instantaneous water heater

20 and discuss some of the issues. If you look at

2:L fossil-fired instantaneous water heaters, especially

22 ones that have a high enough heating rate to start to

23 look like they behave like tank-type water heaters,

24 those heat exchangers are very large. And they

25 represent a fairly significant thermal mass, both of

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
167

1 the material and of the water left inside of it during

2 the off cycle.

3 If you apply a 6-draw per day, you get

4 tremendously different lost energy out of that system

5 than if you do what really happens in the field, which

6 is more like 20 or 30 or 50 draws a day because the

7 percentage of energy lost out of that thermal mass of

8 the water and the heat exchanger in the off cycle

9 becomes a much higher percentage as you have more on

10 and off cycles.

11 So applying six equal draws doesn't really

12 accurately represent how those systems perform in the

13 field. And the losses are much higher under a real

14 draw scenario.

15 FACILITATOR RABA: Go ahead.

16 MR. STANONICK: In talking about

17 instantaneous water heaters, I've got to distinguish

18 between the ones that are point of use and the -- if

19 we're talking about units that --

20 MR. DOUGHERTY: The ones that compete

21 against maybe these 20 or less --

22 MR. STANONICK: -- suggest it's going to

23 satisfy the entire house load, I think they should run

24 the same procedures.

25 MR. DOUGHERTY: Brian Dougherty, NIST.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
168

1 I guess I had the question of the ones

2 that supposedly would be compared to the

3 20-gallon-or-less storage water heater. So if you had

4 a tank gallon storage water heater and you had an

5 instantaneous water heater that supposedly gave you

6 comfortable performance, one may have an energy factor

7 based on 64.3 gallons. Another one may have a standby

8 loss value.

9 MR. STANONICK: Well, but I think this

10 other one that you just had there, I don't think it

11 would have an energy factor either.

12 FACILITATOR RABA: Excuse me. I'm getting

13 lost here. Are we talking about 20-gallon-or-less

14 capacity or 10-gallon-or-less capacity or

15 instantaneous or storage or all of the combinations?

16 MR. DOUGHERTY: Brian Dougherty, NIST.

17 I apologize for muddying the waters, but

18 we skipped over the last item on the instantaneous

19 water heaters, and we broke for lunch. It had to do

20 with: Do you use an energy factoring method for these

21 lower heating rate units?

22 The thought that I had coming in here was

23 that, well, I guess you do, but the question is:

24 Would you apply a lesser daily draw profile on them

25 because when you test at 64.3 gallons, they just don't

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
169

1 keep up in the test? And you have this huge

2 correction to get them back to 135.

3 MR. STANONICK: Frank Stanonick.

4 For the instantaneous water heaters that

5 I thought we were talking about in this discussion,

6 which was primarily the electric, my suggestion would

7 be you don't run an energy factor test on those.

8 MR. DOUGHERTY: Period, period.

9 MR. STANONICK: I mean, I tend to think

10 those are going to -- they're more so toward the

11 point-of-use kind of application, although I guess

12 some people try and suggest you can use it in the

13 whole house. Maybe you have to give some thought to

14 how you address that.

15 Understand that doesn't say, at least the

16 way I look at things, you're not going to give some

17 information about consumption, again because if I have

18 a gallon per minute, whether it's 50 or 75, and if I'm

19 assuming a 98 percent efficiency with its heating, I

20 can figure out pretty easily what its electrical

21 consummation would be per gallon if that's kind of my

22 measure of merit. And maybe that's what you do.

23 I guess my point is that I don't see the

24 energy factor applying, but I still accept or still

25 believe you need it at the end point to give, in

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
170

1 addition to some measure of capability, some measure

2 of consumption.

3 FACILITATOR RABA: Thank you. Thanks for

4 bringing us back, Brian. I appreciate that.

5 Carl?

6 DR. HILLER: Question for Frank. On

7 fossil-fired instantaneous water heaters, -- and there

8 are some of those that are applied in larger

9 applications -- do you think the 6-draw scenario

10 accurately represents what the 64.3 gallons -- do you

11 think that accurately represents the kind of losses

12 that those systems are really having to feel?

13 MR. STANONICK: I guess I'd say it's close

14 enough. And I'm trying to remember. Don't even come

15 close to quoting me on this. But I have this memory

16 that at some point there was some work done on varying

17 draw schedules applied to instantaneous water heaters

13 to see what kind of energy factor you got out of

19 there. And I might be confusing some work here, but

20 if I can find that, I certainly will bring it out

21 again. I think it's close enough.

22 One of the issues raised here actually to

23 me is a bigger question. There's some comment

24 suggesting that apparently because they can, that the

25 .test procedures should recognize that the pilot can be

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
171

1 turned off when the water heater is not being used.

2 And so since you can do that, they're

3 saying the test procedure should recognize that.

4 Obviously that will change the energy factor a lot

5 because the pilot on instantaneous is a loss. When

6 you're not heating water, it's not doing much of

7 anything.

8 And there's a suggestion here that if it's

9 a manually operated pilot, people will go turn it off

10 and not use any hot water. If you've had some

11 experience with the European heaters, where you had to

12 throw coins in to get the hot water, that may be what

13 the people in the United States would be willing to

14 do. But that would be a huge change in their pattern

15 of hot water usage that before they went to bed,

16 they'd go down and shut off their pilot on their water

17 heater. Then they'd fight in the morning to see who

13 was going to get out of bed first to go turn the pilot

19 back on.

20 MR. KUSTERER: It would be cheaper to go

21 to a car wash.

22 (Laughter.)

23 MR. KUSTERER: Throw in a buck and a half.

24 You get all the water you want. Soap, rinsed, the

25 whole thing.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
172

1 FACILITATOR RABA: With brushes or

2 without?

3 MR. KUSTERER: With.

4 FACILITATOR RABA: If you find the data,

5 that would be very good. If you can't, well --

6 MR. STANONICK: I may be mixing up two

7 reports, but the question has been looked at, I think.

8 FACILITATOR RABA: Sure. Okay.

9 In the back?

10 MR. STEPHENS: Yes. Charlie Stephens.

11 It almost sounds to me like storage water

12 heaters and their standby losses is the

13 differentiation between that type of device and what

14 might be almost an annual fuel utilization efficiency

15 for fossil fuel-fired instantaneous water heater that

16 has some of the same characteristics except it's key

17 to water use, instead of air temperature and whatever

18 losses the house has. It's only running on other than

19 pilot when there's demand.

20 And there are some heat-up, some warm-off,

21 and cool-down losses associated with it just like in

22 a furnace. And I'm not sure if there are any related

23 types of test issues that could be used, but it is

24 clear I think that this needs some kind of a separate

25 test procedure.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
173

1 I don't have any recommendations on what

2 that is.

3 FACILITATOR RABA: Thank you.

4 Carl?

5 DR. HILLER: There is some data. There

6 have been some field tests reported on instantaneous

7 fossil-fired water heaters in real field applications.

8 I'd be hard-pressed to quote the specific references

9 right now. We could probably dig them out.

10 My recollection of that -- and, again,

11 you've got to understand the use patterns and how they

12 would have compared to a tank-type water heater in the

13 same application, et cetera. And there were some that

14 flipped back and forth between a tank-type water

15 heater and instantaneous water heater. Frank may even

16 know where some of these data reports are.

17 My recollection is that the difference in

18 seasonal energy consumption was the instantaneous

19 water heater only had slightly less consumption than

20 the tank-type water heater on a single basis. That's

21 how large the cycling losses were.

22 MR. STANONICK: Well, Frank Stanonick from

23 GAMA.

24 The test procedure, the current test

25 procedures -- and right now they are only being

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
174

1 applied to fossil fuel, to gas-fired from 50,000 up to

2 200,000. Okay?

3 But that current test procedure does show

4 that with an instantaneous water heater with, let's

5 just say, a reasonable size pilot, which I'm going to

6 say is maybe 500 btu, maybe a little more than that --

7 in fact, it may be a little higher than that.

8 But the energy factor from that water

9 heater doesn't come out. It comes out better than

10 minimum gas storage water heaters, but, in fact, the

11 energy factor indicates it would be comparable or is

12 comparable in efficiency to a higher-end storage water

13 heater.

14 And so I guess that's why we're not as

15 concerned about the six. It's true if you put it

16 through more draws because of the heating and

17 cool-down cycles you're probably going to get a

18 different number, but let's say for the sake of some

19 commonality six draws seems to work all right for

20 instantaneous for other problems, but --

2:L DR. HILLER: We could test that pretty

22 easily in the lab, do it one long draw versus 6 equal

23 draws versus 100 equal draws. We could plot that

24 difference.

25 MR. STANONICK: Keep in mind you always --

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
175

1 this is such an elusive thing. I mean, as soon as you

2 lock down any draw, there are lots of typical draws,

3 but there is no one real average draw.

4 We're dealing with how people use' hot

5 water in their homes. And it's so different from one

6 to the next. You can only hope you've got a fairly

7 representative one and move from there because there

8 isn't any average draw.

9 FACILITATOR RABA: We're going to have to

10 move on soon. Thank you.

11 In the back, Charlie?

12 MR. STEPHENS: I have a question for these

13 people who seem to --

14 FACILITATOR RABA: Go ahead. Louder.

15 MR. STEPHENS: Charlie Stephens.

16 A question for Frank and Carl and whoever

17 else can answer the question. Would it be possible to

18 just have an efficiency factor related to whether it

19 has a pilot light or it doesn't, two groups, and a

20 burner efficiency when it's operating and some

21 lab-determined penalty for the amount of water that's

22 actually in the heat exchanger and left in the heat

23 exchanger after it's applied?

24 MR. STANONICK: Is it possible? Yes, but

25 at some risk here. I mean, just as one could build a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
176

1 storage water heater with an electronic ignition

2 system, one can build an instantaneous water heater

3 with an electronic ignition system. If a manufacturer

4 wants to get the benefit of doing away with that, it

5 can be done at a cost, at a cost.

6 But the concept that will let it have a

7 standing pilot but now base my test procedure on an

8 assumption that the homeowner is going to regularly

9 manipulate, they could do that with their storage

10 water heater. I mean, they could do that with their

11 storage water heater. I mean, they could turn it on

12 to the pilot position every night and probably save

13 some standby. It probably wouldn't be much.

14 We already have a huge difficulty dealing

15 with first-hour rating because of the human factor,

16 because of what people really do. To introduce in the

17 test procedure some perceived efficiency savings

18 because you're going to account that they may do

19 something else as far as manipulating the water

20 heater, I just don't -- that's a move in the wrong

21 direction, I believe.

22 MR. STEPHENS: No. I'm pushing you in the

23 other direction. I'm asking: Can you calculate the

24 burner efficiency? Is that easy enough to do?

25 MR. STANONICK: Well, the test procedure,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
177

1 yes. The test procedure does that.

2 MR. STEPHENS: Is it easy enough to

3 measure what the pilot light consumes?

4 MR. STANONICK: Yes.

5 MR. STEPHENS: Per hour?

6 MR. STANONICK: Yes.

7 MR. STEPHENS: Then what I'm suggesting is

8 that you go to a calculational method after you know

9 those things and forget about draws somehow because if

10 the differences that we're talking about are five,

11 six, seven, eight percent in efficiency, compared to

12 what you could get through calculationally, then I

13 think if all you're going to do is move it a half a

14 point, one way or the other, I'm not sure it matters

15 that we be that accurate if you can get pretty

16 accurate with a calculational procedure based on the

17 features that it has and how it operates, when it

18 operates.

19 And I'd like to steer away from the test

20 procedure stuff if we can.

21 FACILITATOR RABA: Go ahead, Brian. Give

22 you a break there. Thank you.

23 MR. DOUGHERTY: Brian Dougherty, NIST.

24 There was a workshop I believe in 1985 at

25 NIST. At that time there was an issue of how to rate

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) , , _234-4433

 EE-RM-94-230 COMMENT 49P
178

1 heat pump water heaters. At that time there was an

2 idea put forward that: Well, we'll just have a

3 different test procedure for heat pump water heaters.

4 And the outcome of that process in the late '80s was:

5 No. We want to have everyone tested the same.

6 So as you're introducing changes, -- we

7 have some other issues here -- past consensus has

8 been: No. Don't do that because there may be a

9 tipping that occurs because of different test methods

10 that may favor one versus the other where if you test

11 them all the same way or as closely as you can, at

12 that time the consensus was that would be the

13 preferred option.

14 MR. STEPHENS: I don't think you have the

15 same beast here.

16 FACILITATOR RABA: Two. Go ahead, Carl.

17 Then you, Frank. Thank you.

18 DR. HILLER: If I may, I'd like to offer

19 a recommendation. We probably can't 100 percent

20 answer this issue right now, but we can certainly

21 collect data. that would really narrow down the

22 decision-making process.

23 I'm going to recommend that NIST could

24 test kind of the smaller end of the fossil-fired water

25 heater range and the larger end of the fossil-fired

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
179

1 instantaneous water heater range under different

2 breakups in the draw scenario.

3 I think if you're going to have an energy

4 factor rating that's going to be used and be compared

5 to tank types, you've got to use 64.3 gallons, but you

6 can break that up in different draw scenarios, 6

7 draws, 100 draws, one long draw, and see what the

8 difference is in the efficiency that you get by those

9 different scenarios.

10 If it's only two percent, then who cares?

11 If it's 20 percent, then we've got to take a closer

12 look at it.

13 FACILITATOR RABA: Thank you.

14 Frank, did you want to comment, then?

15 MR. STANONICK: Only that the interest in

16 having the same test procedure is within the concept

17 of: Okay. Products in the market either do compete

18 against each other or are, in fact, presented as being

19 competitive products.

20 And so that's why we're not as concerned,

21 but we might go to a different test procedure for less

22 than 20 because they have their own market, if you

23 will. But products out there in the field, in the

24 market that do get presented as being equal ways to do

25 the same job, our contention should be tested to the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
180

extent possible for the same test procedure.

And that's why on the instantaneous,

again, as Carl pointed out, you saw some huge

difference. That may change the situation. But

basically we think they should be tested, as others

are tested in storage water heaters.

FACILITATOR RABA: Go ahead, Carl.

DR. HILLER: One issue that would remain

along with that, is in all likelihood, you can't meet

the same draw. And what do you do about that when you

run that test?

MR. STANONICK: And then there's at least

an attempt to address that, yes.

FACILITATOR RABA: Further views on this

subject?

(No response.)

FACILITATOR RABA: I think we should move

on, please. Can we come back to the less than 20

gallons storage type or less than 10 gallons? Where

did we leave that? Bring me back up to speed on

those, please.

MR. STANONICK: Could I ask a question?

FACILITATOR RABA: Go ahead.

MR. STANONICK: Why do you ask the

question? I mean, again, from GAMA's perspective,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

1

2

3

4

5

6

7

8

1

10

11

12

13

14:

15

16

17

18

1 193

20

21

2:2

23

24

25

 EE-RM-94-230 COMMENT 49P
181

1 less than 20 goes from 20 to 2. What's magic about

2 ten?

3 FACILITATOR RABA: Help me out, Brian.

4 MR. DOUGHERTY: Brian Dougherty, NIST.

5 That was where the magic dividing line

6 was. If you use the simulated use test, how much --

7 MR. STANONICK: Okay.

8 MR. DOUGHERTY: So it was just from

9 ASHRAE. That was the dividing point in ASHRAE.

10 MR. STANONICK: All right. Now I

11 understand.

12 MR. DOUGHERTY: That's why that number

13 shows up. That's the only reason. I think what it is

14 is that the summary was that 20 or less, the market is

15 electric water heaters only.

16 And because you have this pinned down

17 pretty well as far as recovery efficiency, the thing

18 that you're lacking is the loss. So, rather than try

19 and get an energy factor from a 24-hour simulated use

20 test, instead, go with a standby loss test. I guess

21 that was it.

22 Do you then convert that into energy

23 usage? Do you take it the next step?

24 MR. STANONICK: It seems to me that

25 somehow you have to, somehow. I'm not sure that

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
182

1 answers.

2 FACILITATOR RABA: Can somebody else

3 respond to the question, help Frank out? Go ahead,

4 Steve.

5 MR. ROSENSTOCK: Let me get a

6 clarification. Steve Rosenstock, Edison Electric

7 Institute.

8 You were trying to just correlate standby

9 losses to overall energy consumption?

10 MR. DOUGHERTY: That's what you'd have to

11 do, yes. That's not the question. You have to do

12 that. It's the next step.

13 MR. STANONICK: Not just standby.

14 ' MR. DOUGHERTY: Yes. You'd have to take

15 in the recovery efficiency, which is known for

16 electric. You have to do it by a calculation.

17 MR. ROSENSTOCK: Based on --

18 MR. DOUGHERTY: Has to do a draw test, a

19 24-hour simulated use. We have imposed draw and then

20

21 MR. ROSENSTOCK: So what you're saying is

22 figure out what the standby losses are and then do

23 this other test to do the overall?

24 MR. DOUGHERTY: Not another test, but a

25 calculation of --

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
183

MR. ROSENSTOCK: Just a calculation,

rather than another test?

MR. DOUGHERTY: Right.

MR. ROSENSTOCK: Okay. I wanted to

clarify what you were trying --

FACILITATOR RABA: Are there other areas

to clarify on that?

MR. ROSENSTOCK: You're not making a big

leap from a standby loss into an overall consumption,

in other words. Okay. All right.

DR. HILLER: Can I venture a

recommendation here --

FACILITATOR RABA: Sure.

DR. HILLER: -- at the risk of being shot

down on it?

We know that these smaller tanks are all

electric. We know kind of the input efficiency. I

would argue 98 percent, but that's in the change.

If we developed a standby loss from

measurement test and then a standard that said you had

to meet a minimum watts as a function of tank volume;

in other words, you go down from two to some minimum

threshold, you don't go below, it seems to me that

would both allow us to compare the standby loss of

different tanks.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20)

21

22

23

24

25

(202) 234-4433 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
184

1 It's down in the 20-gallon or less range

2 the consumptions are -- the use patterns are not

3 nearly so clear as in the larger tanks. So why even

4 bring the gallon consumption into the issue? Just

5 compare it on standby loss. And you can mandate

6 higher efficiencies by changing the required equation

7 that they have to meet.

8 We're going to have a different standard

9 down below 20 gallons no matter what. So why not do

10 it that way? It's simple that way.

11 MR. DOUGHERTY: Brian Dougherty, NIST.

12 Keep energy out of it. And, in fact,

13 based on the passage clearance, it may be a single

14 number for all of those tanks because of the great

15 impact of the fittings, as opposed to a jacket size or

16 volume. So it just may be a single number, as opposed

17 to one that actually slides, but it may slide slightly

18 based on volume.

19 DR. HILLER: We could test existing

20 products out there, see how they test on the standby

21 loss, look at what we think is, you know, is a crummy

22 tank, is a good tank, and kind of set it to meet some

23 reasonable number, rather than the crummy tank.

24 MR. RANFONE: Jim Ranfone, AGA.

25 I did learn something today, that there

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
185

1 are a hell of lot of these variants out there. I

2 didn't realize that that market was so big. They are

3 unregulated. I mean, you build a less than 20-gallon

4 electric water heater, you don't have to meet

5 anything.

6 Whether it's a standby loss requirement or

7 a variation.of the current procedure, something has to

8 be done. That's a hell of a hit that you have to face

9 out there when you've estimated 350,000 of these being

10 shipped every year and you've got regulated product,

11 like direct heating equipment, for example, well under

12 200,000 products a year.

13 So I would just suggest we get on with it.

14 FACILITATOR RABA: Any more thoughts about

15 the test procedure that Carl advanced, the idea of

16 that test procedure? Do you agree/disagree?

17 MR. STANONICK: I guess I had mentioned it

18 earlier, and I just want to make sure that we're still

19 thinking this. I think for this product, you still

20 need to make some estimate of consumption per gallon

21 of hot water delivered or something because that would

22 go into the mix.

23 I'm trying to envision somebody who's

24 trying to evaluate what this product can do and as

2!5 part of this scheme also give some sense of what, if

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
186

1 you will, it costs them to do that, whether you put an

2 energy or whatever.

3 And so it seems to me you have -- the real

4 requirement would be a standby, but in terms of trying

5 to estimate some consumption, there has to be some

6 measure of what's the consumption of providing a

7 gallon of hot water, however the hot water is going to

8 be defined.

9 DR. HILLER: Since that's electrics,

10 though, it's so easy to do.

11 MR. STANONICK: I know. I'm just saying

12 it has to be --

13 DR. HILLER: I don't think the test you

14 need is a standby.

15 MR. STANONICK: I know. It's an easy

16 thing, yes.

17 MR. MILLS: James Mills, FTC.

18 Just a reminder I think that I think the

19 Department is required by statute to come up with that

20 kind of a measurement and at least one other. And at

21 the FTC, these products do have to be labeled. And

22 right now what has to be on the label is energy

23 consumption. So I think you're on the right track.

24 FACILITATOR RABA: Good point. Thank you.

25 Jim?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
187

1 MR. LUTZ: Jim Lutz, LBNL.

2 Is there anybody, especially in the market

3 area, who might know how these things are installed

4 and what's a typical use? Recommending some -- how

5 are you going to pick a pattern or draw a pattern or

6 gallons per day or gallons per year to rate them at?

7 You need that. Otherwise, you can't get a consumption

8 figure.

9 MR. MILLER: Rick Miller with Rheem.

10 To answer your question, as I think Frank

11 pointed out earlier, most less than 20-gallon water

12 heaters are not installed in single-family homes.

13 Some are, remote baths, somebody has a bar sink, a lot

14 of applications where they could be used. By and

15 large, the majority of these products and sold and

16 installed in other than residential homes; this

17 building, for example, gas stations, office buildings,

18 doctors' buildings, et cetera, where they have small

19 requirements of hot water at various intervals.

20 MR. KUSTERER: Recreational vehicles.

21 MR. MILLER: RVs, different category,

22 different classification, by the way, in what we call

23 the point-of-use water heater that goes from 2 and a

24 half gallons up to 20. That's where we see a lot of

25 those installed.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
188

1 MR. LUTZ: Any idea what type of building

2 sees the majority of them?

3 MR. MILLER: No.

4 MR. LUTZ: Are you talking five gallons of

5 water a day? Twenty gallons of water a day?

6 MR. MILLER: That data we don't

7 necessarily get. That's developed by some engineer

8 who is spec-ing the application. He may say, "I'll

9 put in one 15-gallon point-of-use heater to service 5

10 laboratories on a floor of an office building" or it

11 may be one doctors' office that needs water in each of

12 his examination rooms. He may have three individual

13 two-and-a-half-gallon heaters or something along those

14 lines. So it really varies.

15 FACILITATOR RABA: Thank you.

16 Carl and then Steve.

17 DR. HILLER: Let me offer an observational

18 fact that for the tank-type water heaters now, we have

19 the six equal draws analysis with the exception of

20 off-peak water heaters which turn the active heating

21 elements off during much of the day.

22 It is the case that as long as you don't

23 run out of hot water during the draws from a total

24 energy consumption analysis standpoint, you consume

25 the standby losses constant.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
189

1 In other words, six draws versus one draw

2 makes like a one percent or a two percent difference

3 in the number. So the draw pattern except for

4 instantaneous fossil-fired water heaters, the heat

5 exchanger is unimportant, the gallons per day that

6 govern.

7 You could even do it on the big water

8 heaters. Take one draw. It wouldn't make any

9 difference. It has a minuscule effect on the

10 efficiency.

11 FACILITATOR RABA: Steve?

12 MR. ROSENSTOCK: Just based on what Mr.

13 Miller said from Rheem, it's obvious that these are --

14 it seems the majority of them in terms of test

15 procedure, that it's single function. You don't have

16 to worry about a wide range of end uses for this

17 product.

18 It's not going to be also for hand-washing

19 as well as dish-washing or laundry. It just seems

20 like it's one function, one end-use function, one

21 profile. And also it's probably a much narrower

22 temperature range in terms of what the outlet

23 temperature has to be.

24 That's just what it seems like. That is

25 the market for them: One function, pretty much one

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
190

1 temperature. You're not trying to meet a very wide

2 bandwidth of topic temperatures. I think a lot of

3 people can agree on that.

4 DR. HILLER: If we had the standby energy

5 loss number, we could give the user an equation to

6 plug in their gallons per day to determine.

7 FACILITATOR RABA: Can someone develop

8 that?

9 Charlie?

10 MR. STEPHENS: Charlie Stephens.

11 That still is relevant. They still have

12 to be labeled. And they still have an annual kilowatt

13 hour number on them. To the extent that the 64.3

14 gallons that we're using for the other water heaters

15 is based on something, it would be nice if we had

16 something we could base this on it as well, although

17 I, for one, don't know of any data that we could use

18 right now.

19 FACILITATOR RABA: It sounds like we need

20 more data.

21 Stan, go ahead.

22 MR. LIU: Actually 118 --

2:3 FACILITATOR RABA: Stanley Liu from NIST.

24 MR. LIU: Stan Liu, NIST.

25 Actually 118.1 or 2 specifies 24 gallons

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
191

1 for the tank, 20 gallons, and then 9 gallons per day

2 for below 10 gallons. That's a number there for

3 folks. If you had the number, draw gallons per day,

4 then you could come up with any. The point is that

5 number can be used for some other number and verified.

6 FACILITATOR RABA: It was 110.2, is it?

7 118.2?

8 MR. STEPHENS: Question, Stan: Does that

9 come close to being able to be put into some kind of

10 an equation, like 1.2 times the rated storage volume

11 or something as the daily draw?

12 MR. STANONICK: I think -- well, you can

13 answer him.

14 MR. LIU: That one just -- the committee's

15 decision, actually the'committee's decision.

16 MR. STANONICK: I think the point is that

17 for that product, you don't need to do the draw

18 schedules. There will need to be some agreement as

19 to: Okay. What are we going to assume is a daily use

20 for this size?

21 Those numbers are good starting points,

22 but once you've determined that, let's say it's nine

23 gallons a day. Okay? If we know the consumption per

24 gallon delivered, well, that's nine times that amount.

25 And then you can just back out the standby

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
192

1 period. And we have an hourly standby, which also

2 multiplied, the answer can be figured out as a daily

3 consumption and then yearly if you need it.

4 FACILITATOR RABA: Other thoughts to

5 advance this? Other thoughts? Does this cover the

6 20-gallon? How about the ten-gallon: same, same, or

7 something different? I see nods yes. Do I see nods

8 no? I see nodding off.

9 DR. HILLER: The arguments are the same

10 until you get down to the really small two gallons and

11 less. Those are such a specific application, the two

12 gallons and less, especially tank-type two gallons and

13 less, are definitely single point-of-use applications,

14 very limited use.

15 MR. STANONICK: My choice would be to'

16 categorize it as an instantaneous, whatever procedure

17 is for that one. But I'd say that one enters into

18 another category. Whether it's less than two or two,

19 I don't know, but, I mean --

20 DR. HILLER: It's an entirely different

21 beast.

22 MR. STANONICK: Yes.

23 DR. HILLER: It's meant for a cup of hot

24 water for coffee or something like that, not really

25 meant on a continuous draw basis. It can't be on 150

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
193

1 watts, 150 volts.

2 FACILITATOR RABA: Does that go to the

3 question of: Should there be a lower size limit, two

4 gallons?

5 DR. HILLER: Right. I'm arguing for a

6 lower size limit, two gallons or less.

7 FACILITATOR RABA: Thank you.

8 Charlie?

9 MR. STEPHENS: I would concur with that.

10 And I guess I have to question why we would bother

11 with an energy efficiency rating on something like

12 that.

13 FACILITATOR RABA: Steve?

14 MR. ROSENSTOCK: Steve Rosenstock, EEI.

15 Yes. I would concur with Dr. Hiller to go

16 from 2 to 20 gallons for this categorization. But

17 also the next thing would be, well, in actuality, like

18 the other person was saying, there are 2 different

19 gallons per day. Ten to 20 gallons is 24 gallons per

20 day. Ten and below, it's nine gallons per day.

21 So there is going to be a difference in

22 terms of labeling. That will make a difference

23 obviously in the annual energy consumption.

24 FACILITATOR RABA: Mr. Miller?

25 MR. MILLER: Rick Miller with Rheem.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
194

1 - I guess this will get off the subject a

2 little bit, but should these products even be rated?

3 I guess that's to the gentleman from Argonne's

4 question.

5 You can't apply the same test to a product

6 less than 20 gallons for the reasons that have already

7 been discussed. When you consider where these

8 products are installed and the wide range of

9 application of these, who is going to benefit from it?

10 Is the goal to provide some means of

11 measuring, as with higher capacity water heaters,

12 Product A versus Product B or what is the purpose I

13 guess is what I'm asking? Who is going to benefit by

14 measuring these products?

15 FACILITATOR RABA: Don?

16 MR. ABRAMS: Don Abrams from Abrams and

17 Associates.

18 I'd say a very direct benefit for

19 commercial applications, again not residential, if

20 you're specifying point of use, in a building like

21 this, there might be 500 of them.

22 The standby loss becomes a critical

23 concern in terms of the annual energy budget for a

24 building. So I'd say there's a big concern to both

25 the building operator and for DOE.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
195

1 MR. MILLER: That's a good plan. I would

2 agree with that. If you're going to measure them,

3 measure the standby loss. I think that's the only

4 thing you could really measure.

5 MR. ABRAMS: I understand. That's

6 something we've been talking about, including that.

7 FACILITATOR RABA: Charlie?

8 MR. STEPHENS: Yes. Charlie Stephens

9 again.

10 We had thought about that as well. And I

11 think I might be able to concur with that. If we just

12 are going to measure the standby loss and try to get

13 at the annual consumption that way, it might be better

14 to exempt them from normal labeling rules.

15 From what I've heard, these things aren't

16 going in -- they're not being chosen because of their

17 energy efficiency per se, though if you cover standby

18 loss, you'll get most of the losses that people are

19 concerned about. They're being purchased for point of

20 use pretty much, no matter who does it.

21 And if you insulate them well, cut down on

22 the standby losses sufficiently, you've pretty much

23 done all you can do to get the benefit out of any kind

24 of a rating for these things.

25 And perhaps the easier and better thing to

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
196

1 do would be indeed regulate them by putting them in a

2 separate class where only standby losses are

3 essentially specified, maximum standby losses, and

4 exempt them from the typical annual consumption

5 labeling because they aren't bought that way.

6 FACILITATOR RABA: Thank you.

7 Anybody else? Give Charlie a break there.

8 Thank you, Charlie.

9 Anybody else?

10 MR. ABRAMS: Yes. Don Abrams again.

11 I think that's a good point as long as

12 they remain all electric devices. As soon as you put

13 a combustion device in, then the energy diversion

14 pressure is out of proportion again.

15 FACILITATOR RABA: Okay.

16 Go ahead, Charlie. Back to you.

17 MR. STEPHENS: I think you're going to

18 find that most of the uses aren't going to happen that

19 way. You're not going to put a combustion device in

20 there. The cost of the flue and the exhaust and

21 everything tends to make that kind of an installation

22 nonviable for most --

23 MR. STANONICK: Just economically not

24 feasible.

25 MR. MORRISON: Putting one under your sink

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
197

1 is just --

2 FACILITATOR RABA: Identify yourself, sir.

3 Thank you.

4 MR. MORRISON: Dean Morrison, Rheem.

5 FACILITATOR RABA: Thank you.

6 MR. MORRISON: Putting a vented system

7 under your sink is just not a practical option in most

8 cases.

9 FACILITATOR RABA: Jim?

10 DR. HILLER: Yes. It's a combination

11 heater.

12 (Laughter.)

13 FACILITATOR RABA: Did we have that

14 discussion? This is an interesting topic, broken down

15 and reassembled. It's a good topic.

16 Could I invite you to move along on the

17 agenda, please?

18 MR. MILLS: One last thing.

19 FACILITATOR RABA: Go ahead. James Mills.

20 MR. MILLS: James Mills, FTC.

21 On that issue that Charlie Stephens

22 raised, just so it's on this rulemaking record, if you

23 wanted to have those products exempted from the

24 labeling requirements of the FTC's rule, that would be

25 something you could petition the FTC to consider in a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
198

1 rulemaking, perhaps along with some of the other

2 issues that might be appropriate for that kind of an

3 undertaking.

4 You might put them all in one package, and

5 we could deal with how to rate instantaneous water

6 heaters and whether to cover these small, very small

7 storage water heaters any more under the rule.

8 It could all be done in one rulemaking,

9 just so you would know what you need to do.

10 FACILITATOR RABA: It sounds efficient.

11 Thank you.

12 Moving right along, we're scheduled for a

13 2:30 break. If you'd like to make that, let's go on,

14 then, to continue. Discussion on daily hot water

15 usage and thermostat settings. There are some

16 questions in your agenda. And I also commend your

17 attention to the questions in the "Federal Register"

18 notice.

19 Does the daily uses assumed in current

20 test procedures of 64.3 gallons reflect realistic

21 daily hot water usage? And if not, what volume should

22 it be? And how would the energy factor be affected if

23 testing were conducted at a daily hot water use volume

24 other than 64.3 gallons? And then will the change

25 cause confusion in the marketplace?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
199

1 Again open it up to your discussion,

2 please. Carl?

3 DR. HILLER: Let me take the temperature

4 issue. I would argue that we should stick with 135.

5 I don't see any strong argument to go to 120, and for

6 good reason.

7 I mentioned earlier some of our tests

8 where we looked at the repeatability and variability

9 of how thermostats actually turn on and off. They

10 don't always turn on and off the same temperature. It

11 is also a function of the rate of draw out of the tank

12 and the temperature surrounding the tank as to how

13 they behave and how well the thermostat is insulated

14 from the outside environment.

15 When you consider it all and you look at

16 the dead bands, the typical on/off differential of a

17 core element for an electric tank is in the 5 to

18 15-degree range, 5 to 10 being most typical. The

19 upper thermostats are 20 to 30 typically, much larger

20 dead bands. And the reason for that is to prevent

21 wear-out of the upper thermostat due to repeated

22 on/off cycling during mixing during the reheat

23 process. Typical fossil-fired water heaters, at least

24 the ones that I've tested, seem to be in the, say, 15

25 to 25-degree dead band range.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
200

1 The net result of that dead band and that

2 variability is that if you set a water heater to turn

3 off at 120, you risk under a variety of scenarios

4 having inadequate temperature in the tank at the time

5 you use the water.

6 Believe me, in my house I set the water

7 heaters as low as I can. I have gas and electric

8 water heaters and the ability to switch back and forth

9 between them.

10 I cannot set my water heater down to 120

11 because in the summertime, the tank doesn't come on at

12 nighttime to make up standby loss. In the wintertime,

13 it does. And the water is hot when I've got to use it

14 in the morning. In the summertime, it loses less

15 heat, doesn't trigger the thermostat. And if I have

16 it set at 120, the tank is at 100 when I get up

17 because it hasn't triggered back up yet.

18 So, given all of those variability

19 factors, I would argue and indeed we see in our test

20 data how people have their water heater thermostat set

2:L when we got there. One thirty to 135 is very typical

22 of what we see in the field. And I would argue just

23 keep it there.

24 FACILITATOR RABA: Keep it there? Okay.

25 Again, a thank you to Carl for bringing my attention

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
201

1 again to the thermostat settings on your "Register"

2 notice for those questions.

3 Charlie, you're up first, then Steve.

4 MR. STEPHENS: I'll just endorse what Carl

5 said. The data that we have right now amounts to

6 several thousand water heat customers in the

7 Northwest. It pretty much confirms what Carl says.

8 The vast majority are clustered between

9 130 and 135, very few below 130 and a fair number

10 above 135. The mean tends to run right around 134 for

11 most of the customers. It's a little lower if you

12 look only at participants in energy efficiency

13 programs but not below 130.

14 So I would concur that 135 is a reasonable

15 number to use.

16 FACILITATOR RABA: Steve, you're up.

17 MR. ROSENSTOCK: Yes. Two quick ones,

18 just two issues at once. In terms of daily usage,

19 there does seem to be a lot of materials here that

20 would suggest that a proper statistical median usage

21 or mean -- I don't know whether you would prefer to

22 use a median or a mean -- would be somewhere in the 50

23 to 57-gallon, hot gallons, per day of hot water in

24 terms of how to use I'll say a midpoint for testing

25 purposes.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
202

1 There's data in here, and there's others.

2 I think the old LBNL report also talked about looking

3 at numbers like 58 gallons per day or 57 gallons per

4 day based on a variety of household factors.

5 In terms of thermostat settings, I know

6 that over the past several years there have been a lot

7 of utilities and a lot of publications that have

8 suggested that, again, people put their hot water

9 heaters at 120 degrees to prevent scalding and to save

10 energy, et cetera, et cetera.

11 One issue that -- I know there's a lot of

12 gas water heaters out there that don't have

13 temperature settings per se. They will say "warm"

14 versus "hot" and various factors in between. It's a

15 turn knob.

16 So, again, I don't know whether there's

17 been testing done because a lot of water heaters might

13 say, "Put it here for warm water that will meet your

19 needs." That's probably likely at the 130-degree

20 range. I'm not exactly sure. It all depends probably

21 on the main factor, what they call warm versus hot,

22 what the exact temperature setting is.

23 So, again, there could be arguments to say

24 that with all of the literature out there and with all

25 of the -- again, there is going to be quite a range

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
203

1 between where exactly are people setting their water

2 heaters in the market and where the low range on a gas

3 water heater or oil, whether that warm is 120 versus

4 130. Again, that's probably for lab testing or some

5 sort of testing, field testing, but especially for

6 electric, where the actual temperatures are on a

7 scale.

8 In many instances -- and again, depending

9 on how aggressive utilities have been -- many people

10 in the past, gosh, I would say, 20 years have been

11 being told, "Put it at 120 degrees."

12 So that would be my kind of -- I'll say

13 it's market-based. There are a lot of water heaters

14 out there, over 90 million. What have people done?

15 And maybe they've responded to price factors as well.

16- That could also be an issue.

17 FACILITATOR RABA: Jim, do you have a

18 comment?

19 MR. RANFONE: Jim Ranfone, AGA.

20 First, a question for Charlie. You said

21 that you have.a field survey, inspected a lot of water

22 heaters, and came to the conclusion that the average

23 setting was about 134. I assume they were all

24 electric water heaters or were there some gas?

25 MR. STEPHENS: No. There have been a lot

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 \ _, _ .

 EE-RM-94-230 COMMENT 49P
204

1 of gas involved.

2 MR. RANFONE: How did you determine that?

3 MR. STEPHENS: They weren't actually

4 settings. We were examining the actual water

5 temperature that came out of the tap from the exit

6 from the water system closest to the water heater.

7 MR. RANFONE: So you were getting 134

8 coming out of that typically?

9 MR. STEPHENS: One thirty-one for the one

10 batch, 134 for another, dependent on a little bit

11 where you were. And, again, you're at the water

12 heater per se. You're at the closest hot water outlet

13 to the water heater, which means you're going to have

14 a little bit of loss. We know that.

15 It didn't matter what you told these

16 people. Most of these people acknowledged that

17 somebody along the line had advised them to turn it

18 down to 120. They turned it back up. They weren't

19 happy with that. And I'm beginning to understand why

20 as we go along.

21 Basically thousands, thousands and

22 thousands, of customers have been surveyed that way.

23 And it's pretty consistent.

24 MR. RANFONE: But it's not the fact that

25 the water heater was set at 134?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) . . 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
205

1 MR. STEPHENS: No.

2 MR. RANFONE: You're saying that the

3 temperature of the water heater could be set higher

4 than 134?

5 MR. STEPHENS: Magically we don't know how

6 in every case the water heater came to be set where it

7 is. All we know is it was delivering water at the

8 closest tap to the water heater at 131 to 135 or '6

9 typically.

10 MR. RANFONE: Well, that leads me to the

11 second comment. And that's we are supporting a lower

12 thermostat setting in the test procedure. We did

13 provide testimony to that fact because we think that

14 hot water tap scalding is a problem.

15 There are a lot of effort, a lot of

16 programs to do that, to reduce the thermostat setting.

17 And we think that's really what's reflected in the

18 field. If you're finding that you've got water

19 heaters set much higher than that, I think you are at

20 risk of having some scalding problems.

21 Manufacturers have some pretty extensive

22 programs and labels, at least gas water heaters, like

23 properly setting thermostats and the dangers of

24 harmful tap scalding.

25 I think you've got to make decisions. Is

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
206

1 that what's happening in the field? Is that the way

2 the water heaters should be rated or are we telling

3 customers one thing and providing information another

4 way or testing another way?

5 FACILITATOR RABA: Saw a lot of hands go

6 up. Let me just sort this out. Steve first. And I

7 think we went to the back there and here.

8 MR. ROSENSTOCK: No. It was him.

9 FACILITATOR RABA: Okay. Sorry. Go

10 ahead.

11 MR. KUSTERER: George Kusterer, Bock Water

12 Heaters.

13 FACILITATOR RABA: George?

14 MR. KUSTERER: Oh, I'm sorry.

15 FACILITATOR RABA: Go ahead, please.

16 MR. DUCH: Adam Duch, Group Thermo.

17 FACILITATOR RABA: Thanks, George.

18 MR. DUCH: The interesting quote from

19 special concerns, American Society of Plumbing

20 Engineers, Legionnaires disease, the bacteria was

21 115-degree water. That's when it grows at the fastest

22 rate.

23 So if you keep your water heater around

24 120 and the lower level of the water heater

25 stratified, it will be the range of 115. Keep it at

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
207

1 120, and you're inviting a class action suit by the

2 ambulance-chasing lawyers.

3 MR. RANFONE: Keep it at 135, and you'll

4 get the other lawyers.

5 FACILITATOR RABA: Good point.

6 Let's see. Who was next? I think George

7 and over here and back here.

8 MR. KUSTERER: George Kusterer, Bock Water

9 Heaters.

10 FACILITATOR RABA: Thank you.

11 MR. KUSTERER: I'm seriously concerned

12 about the 135-degree water. And we are, in effect,

13 proposing the lowering to 120 degrees. I realize my

14 colleague had just mentioned Legionnaires disease,

15 which is a virus and sometimes misconstrued in our

16 industry.

17 Having been no such a dumb farmer from

18 Pennsylvania but a fire chief out of New York, I've

19 seen a number of scalding cases and have had to

20 testify as an expert witness before a number of courts

21 throughout North America with regard to scalding.

22 And if you pick up the newspaper, you

23 realize that you can go into Mcdonald's and win a

24 couple of a millon dollars. So what are we doing

25 sitting here?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
208

1 Scalding is a tremendous issue. And we as

2 a water heater manufacturer of fossil fuel equipment

3 and element support the use of 120-degree water. If

4 a requirement is needed to a greater water temperature

5 that an anti-scald valve or a mixing valve be

6 installed, either at the water heater or at the point

7 of use, 135 I think we're inviting big problems.

8 FACILITATOR RABA: Other views on that?

9 We had one here from Carl, then this gentleman here.

10 Go ahead.

11 DR. HILLER: I am as concerned as everyone

12 else is about the scalding issue. I'm also fairly

13 knowledgeable about the Legionnella issue. I have

14 managed a lot of research and development on both

15 issues. Let me throw some data points out for you.

16 First of all, in terms of measuring the

17 water temperature at the closest tap versus at the top

18 of the water heater, in our field test, we did both.

19 And if you draw the draw long enough to heat up the

20 pipe, you get maybe a two-degree tap from what's

21 actually coming out of the water heater. So it's not

22 a big difference.

23 In terms of setting your temperature low

24 enough when you do the practice of setting your

25 thermostat down to as low as possible that serves your

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
209

1 need, you run into the fact and pay attention. It's

2 a very important statement. You realize that what

3 you're setting is the time temperature, not the

4 turn-off temperature.

5 When you attempt to set your thermostat at

6 the lowest possible setting that will serve the job,

7 what you're really doing is setting the minimum

8 turn-on temperature. Below that, if it doesn't turn

9 on on time, you get water that's not hot enough out of

10 the tank.

11 That's exactly the scenario I run into in

12 my own gas water heater in the summertime. And I find

13 to get rid of that issue, my minimum temperature --

14 believe me, I've got young children. Pay very close

15 attention to this.

16 I have instrumentation on my house. I can

17 measure the temperature. The lowest I can set my

18 turn-off temperature to get adequately warm water in

19 the summertime, turn the water heater off at 128.

20 I was going for the lowest temperature

21 that could serve the load. That was governed by the

22 tank not coming on to make up standby loss in the

23 summertime at night. And, therefore, I was at my

24 minimum temperature before the thermostat was going to

25 kick on in the morning when I took a shower.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

{202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
210

1 With a 20-degree dead band, you set it at

2 120. You get 100-degree water in the entire tank.

3 And you don't have hot water. So you must turn the

4 thermostat up if your differential is 20 degrees or if

5 at least the way the tank behaves, it behaves as if it

6 were a differential of 20 degrees.

7 So while I understand all the arguments

8 about the lower temperature for stalling, et cetera,

9 the reality is 120 doesn't work in this in many

10 applications. There are cases where it does.

11 If you get enough standby loss out of the

12 tank at night, then you never run into that at the

13 minimum temperature level when you go to use the

14 water, but there are a number of people who do. And

15 I happen to be one of them.

16 So 120 just doesn't work for all

17 customers. One thirty maybe, but then what's the

18 difference between 130 and 135 from an energy

19 efficiency standpoint is not much.

20 MR. KUSTERER: No, but the rate of

21 stalling changes.

22 DR. HILLER: Yes.

23 FACILITATOR RABA: We had a comment here,

24 please.

25 MR. VAGO: Otto Vago, State Industries.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 2344433

 EE-RM-94-230 COMMENT 49P
211

1 For many, many years, the gas-fired water

2 heater thermostats have been set at the lowest point,

3 lowest possible point, as the water heater leaves the

4 manufacturing facilities. For many years, that's been

5 that, the lowest possible setting.

6 Basically I'm responding to the

7 gentleman's comment here that the thermostat may be

8 set at 120, 130 at some point in time.

9 FACILITATOR RABA: Okay. We've got one,

10 two, three. Go ahead, George.

11 MR. KUSTERER: One point that I forgot to

12 bring out was we have to look at local, state, and

13 regional codes which are being implemented by code

14 enforcement officials throughout the United States and

15 in Canada, where they are requiring a maximum of

16 120-degree water.

17 It exists right here in the State of

18 Maryland. The State of Maryland says you cannot

19 exceed 118.5. Now, that is a code requirement.

20 DR. HILLER: As shipped from the factory

21 or as installed?

22 MR. KUSTERER: As installed, not shipped

23 from the factory, because the code enforcement

24 official is not concerned about what comes out of the

25 factory. Our concern when they go to inspect the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
212

1 equipment installed by a license contractor is that

2 the water temperature does not exceed 118.5 degrees.

3 In fact, in the State of Maryland, in all

4 of their municipal buildings, including hospitals,

5 nursing homes, and prisons, the water is not to exceed

6 115 degrees.

7 Now, here we are saying it's okay to use

8 135 degrees, but the code enforcement officials are

9 saying, "We want 120 degrees."

10 DR. HILLER: So, actually, in the process

11 of inspecting each water heater installation, they

12 actually take a thermometer to the closest tap or

13 something and take a --

14 MR. KUSTERER: Yes, they do. They

15 absolutely do.

16 FACILITATOR RABA: Thank you.

17 Go ahead over here on the side. Tim, is

18 it?

19 MR. BERNARDOWSKI: Tim Bernardowski,

20 Virginia Power.

21 I'm not making a recommendation so much as

22 an observation. First, on the daily news issue, I

23 tried to do some research and head back and see where

24 that number, that 64 whatever, came up and how it was

25 originally developed. I'm not sure it wasn't

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
213

1 established sometime before the invention of paper.

2 We recognize that that number has been

3 around for a long time. We also recognize that there

4 have been a lot of demographic changes and changes in

5 the way folks live and things that they do, which

6 leads me to believe that that 64-gallon number is

7 probably high. That is, it probably should be

8 something lower. There is some pretty good data that

9 shows that it probably should be around 50 or down

10 there.

11 So if you want to, I guess one of the

12 things that's pushing me in all of this is that if

13 we're going to go through the bother of doing all the

14 testing and providing all of this data to the

15 customer, let's try to as much as we can kind of

16 simulate the way he uses the equipment. So if you're

17 going to try and go that route, then I think there's

18 a lot of argument for going to a lower daily use rate.

19 Similarly, if you look at the water

20 temperature set, I see a number of dichotomies there.

21 First off, I'm not sure -- there are so many versions

2:2 of the test procedure I'm not sure if I was looking at

23 the right one. The one I was looking at seemed to

24 indicate to me that the way the tank temperature is

25 tested is it's actually measured. You basically

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
214

1 fiddle with the thermostat until you get 135 in the

2 tank.

3 I don't know of any customer who does that

4 to set his tank temperature. What he does if he knows

5 where the thermostat is -- and my market research

6 people tell me that there's a large percentage of the

7 customers that have no clue where the thermostat

8 setting is. If he does, he does it based on what's

9 written on the thermostat. So it's not real clear to

10 me that from that standpoint the test really tests as

11 a customer uses the equipment.

12 I also tried to look at this 135/120

13 issue. I got on the internet and starting browsing

14 state energy office Web pages. I started finding,

15 trying to find, what state energy offices recommended

16 thermostats be set at. I quit at about 15 Web pages,

17 and I didn't find anything above 125.

18 So, 'again, if you test at 135 degrees,

19 there's this big dichotomy. By the way, I also found

20 on some of the DOE Web pages recommendations for 123

21 temperature settings.

22 So there's a dichotomy there. If you hold

23 it at the higher temperature, the 135, you are not

24 testing it the way you are telling people to use the

25 water heaters.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
215

1 I recognize there's a problem with the

2 dead bands. And I totally agree that that's probably

3 valid, but you've got to get rid of that dichotomy

4 somehow. It doesn't make sense to be testing at 135

5 and tell everybody to set them at 120.

6 FACILITATOR RABA: Thank you.

7 Frank?

8 MR. STANONICK: Let me first state our

9 position. The answer to that dichotomy is not ignored

10 but changes thinking because the test procedure --

11 people shouldn't believe or present the test procedure

12 as a prediction of what the efficiency is going to be

13 in the installation. It won't happen. It won't

14 happen. Carl only had 14 houses, and his range of

15 usage went from 28 a day to 123. And forget what

16 temperature you're dealing with.

17 We look at the daily hot water usage and

18 thermostat setting as two sides of the same coin.

19 It's clear if you raise the daily hot water usage,

20 your energy factor goes up. If you lower it, your

21 energy factor is going to go down. If you change the

22 thermostat setting and lower it, in general probably

23 your energy factor is going to go up. And that may be

24 a little more depending on where you pick it.

25 Right now we have, if you will, a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
216

1 measuring stick of how to compare water heater

2 efficiencies. We chose some numbers. You've got to

3 pick points to compare on the same basis, 77-degree

4 rise, 64.3 gallons per day.

5 If you move any of these numbers, you

6 literally just take the comparison and you move it

7 down and up the scale. You very likely don't change

8 a thing as to how Product A compares to Product B.

9 What you do do is make all the water

10 heater manufacturers test every single water heater

11 again, determine a new energy factor, spend a lot of

12 time and money, new energy guide labels.

13 And we did that once on electric water

14 heaters back in 1990 or whatever. And I don't think

15 the industry has recovered yet. There are still

16 people out there who haven't caught up in the fact

17 that there was a little quantum share in the scale of

18 energy factors for electric water heaters.

19 There is no benefit here. There is no

20 benefit. If Model A is more efficient than Model B

21 under the current test procedures and you take it into

22 any given home within the normal range of

23 reasonableness and wherever that usage is in that

24 home, Model A is still going to be the more efficient

25 product for that consumer.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
217

1 If you're interested in telling those

2 people, "Okay. This is based on 77-degree rise. Your

3 rise is only 50 degrees," that's a state ratio. It

4 holds pretty well. It's linear. And, again, that's

5 how you get to the fringes.

6 The same thing with water usage. If

7 they're not using 64.3, they're using 50 gallons, it's

8 just a mathematical ratio that holds pretty well. If

9 they're using 120 gallons, now you're getting towards

10 the fringe, but it's still pretty close to an estimate

11 of what their consumption is more than likely to be in

12 reality.

13 But this discussion that somehow this test

14 procedure should tell consumers what the consumption

15 of that water heater is going to be in their home,

16 that's another one you can't win. There may be a

17 consumer that would fit. The rest of them are not

18 going to. So why try?

19 FACILITATOR RABA: Carl and then Charlie.

20 DR. HILLER: We now have analysis tools

21 that can much. more accurately than the DOE test

22 procedure tell you what your energy consumption is

23 really going to be as a function of all the parameters

24 that are appropriate to you, your gallons per day,

25 your entering cold water temperature, your set point

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
218

1 temperature.

2 Those are available. By the way, here

3 they are: WATTSIMPL and WATTSIM. They are available

4 to --

5 MR. STANONICK: The price, too?

6 DR. HILLER: They're available to the

7 public. Anybody can get them.

8 It seems to me on this temperature issue,

9 we're mixing two desires. There is a desire to make

10 a recommendation on what people should set their

11 thermostats to versus on what basis we make

12 comparisons.

13 I think the recommendation of what they

14 should set their thermostats to probably ought to be

15 something like, "Set as low as possible to serve your

16 needs," whatever that happens to be for you. If

17 that's 110, so be it absent the Legionnella issue,

18 which is a separate issue.

19 I agree with Frank that if you look at a

20 basis of comparison, the energy efficiency is changed

21 a little bit between 120 and 135, a little less

22 between 130 and 135, but the trend of which one is

23 more efficient remains constant. And so I don't see

24 any compelling reason to change the number.

25 It's not going to change the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
219

1 recommendation of how they should set their

2 thermostat. That's as low as possible. And you can

3 tell them how much energy that is going to represent.

4 FACILITATOR RABA: In the back.

5 MR. STEPHENS: Yes. Charlie Stephens.

6 I've been second all of what's been said

7 before. That being said, I do know that we have

8 enough data to show if you were trying to represent

9 reality, given that baths and showers are some of the

10 largest uses in the household of hot water, especially

11 as some of the other uses get a little more efficient,

12 there is an inverse relationship between the

13 thermostat set point or the actual temperature of the

14 water in a water tank and the gallons of hot water

15 used per day.

16 I can go into why that is. We also know

17 why. For those of you who want to know that, I'll

18 explain it later. People really do know how hot their

19 shower is with a very narrow band. And they'll keep

20 it there, no matter what temperature of water you give

21 them to do it with.

22 The thing is I agree with Frank

23 wholeheartedly. This is never going to represent what

24 actual conditions are out there. We're already within

25 that band, and it's not going to get a whole lot

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
220

1 better if we start moving things very far. So I don't

2 see any compelling reason to change the way we're

3 doing things right now.

4 MR. HAAG: Wilbur Haag with A. O. Smith.

5 I support the GAMA position as outlined in

6 the February 10th letter that you all have a copy of,

7 which is no change is justified in the temperature

8 setting or the gallons per day.

9 FACILITATOR RABA: Thank you.

10 Steve?

11 MR. ROSENSTOCK: Steve Rosenstock, Edison

12 Electric Institute.

13 I would say I think it would be useful for

14 a lot of different purposes if -- again, as I said

15 before, lower temperature and lower daily usage. The

16 decision by DOE is to stick with the current number is

17 fine, but I would say that, again, a bandwidth

18 approach I think would be very useful such that this

19 is the average, X accounts per day, X temperature

20 setting, X LT in water; however, at the low end, 40 to

21 50 gallons per day, LT of 50 degrees, outlet

22 temperature of 115, just to show people a bandwidth

23 because, again -- and then on the higher range, if you

24 have two hot tubs or something, boom, you've got

25 however many gallons OT, et cetera.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON. D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
221

1 There is a wide bandwidth out there. And

2 I think it would be useful for many people just to

3 say, "Okay. If you have this unit using at these --

4 depending on your conditions, depending, again, on

5 what you're using, you're a single occupant, et

6 cetera, few uses, few gallons, versus a high user, it

7 can be useful for consultants of utilities and other

8 analyzers to say, "Okay. Here is the average based on

9 DOE tests. But also DOE says that if you're at the

10 low end of the scale, here is what you're going to be

11 actually using. If you're at the high end, here's

12 what you're going to be using."

13 FACILITATOR RABA: Carl?

14 DR. HILLER: First of all, let me say my

15 bladder has reached capacity. So hopefully we'll take

16 a break real soon.

17 So far I haven't said anything about

18 gallons per day. So let me say something. ASHRAE

19 90.2 subcommittee for residential energy efficiency

20 standards came up with a lot of data to try and figure

21 out what gallons per day number ought to be used. Our

22 TC 6.6 subcommittee is going to address that issue as

23 well.

24 There is a fair amount of data out there

25 for both gas and electric water heaters that suggests

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
222

1 that for whatever you want to define typical

2 residential customers, the actual gallons per day now

3 are somewhere between 40 and 55 gallons a day,

4 substantially below 64.3.

5 That's a separate issue in my mind as to

6 what number we use for comparison purposes for a

7 single-point rating. Like I said, the tools are

8 available to tell you what your energy consumption and

9 overall efficiency are going to be based on any

10 consumption level now.

11 I think what worries a lot of us is what

12 happened in the 1994 proposal to outlaw resistance

13 water heating where a lot of economic analysis was

14 done on a 64.3-gallon-a-day assumption and a 58-degree

15 entering water temperature assumption.

16 The DOE number is not intended for that

17 kind of analysis. It's meant purely to compare A

18 water heater to B. And that will tell you which one

19 is more efficient. It won't tell you which one is

20 more cost-effective.

21 So I don't see any strong reason -- if you

22 limit the use of that energy factor number to compare

23 which tank is more efficient, then there's no reason

24 to change from 50 to 64 or whatever.

25 But we've got to caution DOE in the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
223

1 process not to use that number nor the 58-degree

2 entering water temperature number to do

3 cost-effectiveness analysis on a national basis. You

4 cannot do that. The DOE procedure and numbers are not

5 appropriate for doing that.

6 FACILITATOR RABA: Thank you.

7 DR. HILLER: So there are two separate

8 issues there. One is compare Water Heater A to Water

9 Heater B. The other is how you do energy in

10 cost-effectiveness.

11 FACILITATOR RABA: Response to that? Tim?

12 MR. BERNARDOWSKI: Yes. Carl, I think you

13 missed part of the coin. I was thinking about the

14 discussion we had this morning on the first-hour

15 ratings, where: What is it meant to be used for? It

16 was meant to be used to group the water heaters

17 together, but it's also being used for size.

18 90.2 brought that whole issue up, not

19 because it's critical to the energy cost budget method

20 in 90.2, but because the number stays the same no

21 matter how you do it. But because people were using

22 the 64-gallon number to design, I think there are some

23 valid reasons.

24 I agree with Frank that you just move the

25 scale one way or the other. My concern is similar to

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
224

1 this first-hour rating, similar to the 64-gallon.

2 When I look at the temperature things, I get some

3 analysis from somebody, from a lab, real good analysis

4 on hot water heaters.

5 What should you base the set point

6 temperatures at? A hundred and thirty-five degrees.

7 Why did you do that? Because that's what the DOE test

8 procedure does. So now I've got to go back and try to

9 work with those numbers to make them something useful.

10 I see that a lot where folks are facing

11 different things that they're doing in some of the

12 numbers used in these test procedures. And that's why

13 I would like to see them push towards something that

14 is more realistic. That was my basis.

15 FACILITATOR RABA: Thank you.

16 I tell you what. Let's try to wrap this

17 up so we can take a break. Comment over here, please?

18 MR. BEGOSKE: Tim Begoske, Effikal

19 International.

20) We agree with GAMA's position on this.

2:L And I have some rental properties with anti-scald

22 devices on the showers, set at 110 degrees Fahrenheit.

23 I also set my water heaters at 120 degrees. And the

24 tenants in those locations turn that water heater up

25 because they do not have enough hot water to take care

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
225

1 of their needs. Those are new appliances that were

2 properly calibrated and set.

;~3 These are performance issues, not

a liability issues. We should promote anti-scald

5 devices for the homes so that we can control the water

6 temperatures or maybe at the outlet of the water

7 heater. We have to have higher temperatures in that

8 water heater to supply the needs of the users of the

9 appliances.

10 FACILITATOR RABA: Thank you. Good point.

11 Anything further?

12 (No response.)

13 FACILITATOR RABA: I'll invite a 15-minute

14 break at this time. Maybe we can come back to it, but

15 we should also think about pressing on to heat pump

16 water heaters and definitions. They are all good

17 comments. We certainly appreciate the time. See you

18 back at 3:00 o'clock.

19 (Whereupon, the foregoing matter went off

20 the record at 2:45 p.m. and went back on

21 the record at 3:02 p.m.)

22 FACILITATOR RABA: Let's go on with our

23 discussion on heat pump water heaters and the. four

24 proposed definitions. If there are other pressing

25 issues, we can come back. Put them on the table now

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
226

1 and come back in just a little bit, right now the item

2 of the definitions of heat pump water heaters, add-on

3 heat pump water heaters, integral heat pump water

4 heaters, solar water heaters, and heat pump water

5 heater storage tanks, a lot to look at there, the

6 questions being just summarizing the agenda there,

7 again bounces off the "Federal Register" notice

8 inquiry here.

9 Does the current test procedure allow the

10 resistance elements to activate? Should alternate

11 draw schedule be used? Will the energy factor be

12 Affected if there are alternate draw schedules? Are

13 any of the proposed definitions useful?

14 We'd like to open the floor for comments,

15 please. Carl?

16 DR. HILLER: Let me address the

17 definitions issue for a second here. I was probably

18 the primary person who brought that issue up to the

19 front in 1994.

20 The issue there is when DOE was proposing

21 the resistance water heat, it changed a bunch of

22 definitions to help facilitate that process. Right

23 now the requirements to test are a remote-type heat

24 pump must be tested on what, a 50-gallon or 52-gallon

25 tank. I think it's 50-gallon.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
227

1 MR. STANONICK: Yes, nominal 50-gallon.

2 DR. HILLER: Nominal 50-gallon tank. The

3 revised wording had to be retested on the 50-gallon

4 heat pump water heater storage tank. That in itself

5 wouldn't have been so bad, but then they created a

6 definition of heat pump water heater storage tank.

7 And that definition was heat pump water

8 heater storage tank is a tank that is intended solely

9 for the purpose for use on a heat pump water heater

10 and is not functional without the heat pump water

11 heater present.

12 The problem with that is there is no such

13 tank. And, therefore, you cannot test the heat pump

14 water heater. By the definitions they use, it was

1i impossible to use the test.

16 What do we do about that?

17 FACILITATOR RABA: What do we do about

18 that? Suggestions?

19 MR. STEPHENS: Question. Were you

20 speaking specifically about add-on, under the

21 definition of add-on, or --

22 DR. HILLER: I'm talking specifically

23 about the definitions that DOE had proposed. They

24 proposed for add-on heat pump water heaters that they

25 had to be -- they changed the wording. Instead of

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
228

1 just a 50-gallon tank, they had to be a 50-gallon heat

2 pump water heater tank. They created a new definition

3 of heat pump water heater tank to be one that could

4 not function without the heat pump water heater.

5 MR. STEPHENS: Yes. I read, I think, some

6 of your comments and some of the other literature that

7 was there. It seemed to me that you kind of had two

8 types. There was either an integral device that came

9 as a package unit or there was a device that could be

10 added to a tank, to a storage tank, one or the other.

11 And none of the definitions as they were

12 proposed made any sense to me either.

13 DR. HILLER: Let me propose a solution to

14 that. There's no reason to require that especially

15 remote heat pump-type water heaters be tested only on

16 heat pump water heater tanks. Just test them on the

17 50-gallon tank and be done with it.

18 They're designed to work on any tanks that

19 have the adequate control circuits to make it

20 function. And, indeed, you could use them on even a

21 gas water heater if the heat pump happened to come

22 with thermostats, like some of the earlier versions

23 did. You could have a totally different tank.

24 So there's nothing unimportant for the

25 purposes of defining the test procedures to require

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 I ,

 EE-RM-94-230 COMMENT 49P
229

1 that it be a, quote, "heat pump water heater tank" or

2 to have any special definition of what that tank is.

3 Take that out.

4 FACILITATOR RABA: Brian?

5 MR. DOUGHERTY: Brian Dougherty, NIST.

6 I agree with Carl. The definitions for

7 solar water heater and heat pump water heater storage

8 tank should be eliminated from the test procedure.

9 The comments were in favor of that, and they make

10 sense.

11 Unless someone has an opposing view, that

12 would be my recommendation.

13 FACILITATOR RABA: Someone to keep them

14 in? Frank?

15 MR. STANONICK: No. I'm more interested

16 in clarifying something.

17 FACILITATOR RABA: Sure. Go ahead.

18 MR. STANONICK: We've been using what we

19 refer to as a standard test tank. And for the test

20 procedure for add-on heat pump, I think you need that.

21 You need to define what it's going to be connected to

22 because you're trying to test. Again, it should be

23 tested all on the same basis, which would mean the

24 same tank.

25 Now, I agree that, all of a sudden,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
230

1 calling that a heat pump water heater storage tank

2 gives it some different connotation that I think was

3 never intended.

4 The idea is that when you run the test,

5 this thing is intended to be hooked up to a tank in

6 the field. So you need what I call standard tests.

7 And that should be part of the procedure. But I don't

6 think you need a separate definition for that.

9 DR. HILLER: Energy factor rating.

10 MR. STANONICK: Right, right. And then

11 the other thing as far as what's here as far as

12 integral heat pump water heater, I think it would be

13 better if you just called that a heat pump water

14 heater with tank.

15 I mean, I realize you're thinking of the

16 type of unit where the heat pump sits right on top of

17 the tank and the exchanger goes right down in the

18 middle, but as this is defined, you would preclude if

19 a manufacturer chose, for Lord knows what reason --

20 let's say he chose to sell as a package a heat pump

21 with a specific tank. I'm going to make one up here.

22 Let's say he had an add-on unit but he

23 wanted, for his purposes, that manufacturer wanted, to

24 sell it with an 80-gallon super deluxe insulated tank.

25 Okay? And that was his selection of how he was going

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
231

1 to go to market with that product.

2 That product should be tested that way.

3 But I think to do that, your definition should address

4 just heat pump water heater with tank, however that

5 tank comes with the unit, to distinguish the one that

6 is clearly sold and marketed to be hooked up to

7 whatever tank is out there. That one is going to get

8 tested with the standard testing because the real tank

9 is undefined.

10 But in the other circumstance, I think you

11 at least need to allow that possibility.

12 MR. STEPHENS: Frank, Charlie Stephens.

13 How many have you tested or how many

14 different ones have you tested?

15 MR. STANONICK: There's only two rated in

16 our directory. We're down to one. The DEC unit,

17 which would be the integral, and the CrispAir, that's

18 the add-on.

19 MR. STEPHENS: And the main difference

20 between those two is that one of them circulates water

2:L and the other one circulates refrigerant to the tank.

22 MR. STANONICK: Yes.

23 MR. STEPHENS: So one of them pretty much

24 is integral. It doesn't work without being able to

25 circulate the refrigerant to its tank. And the other

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
232

1 one is more of the add-on type that we have been

2 talking about.

3 - Do you foresee based on how you tested

4 those other configurations that might show up that

5 would complicate our definition?

6 MR. STANONICK: Not in --

7 MR. STEPHENS: Maybe Carl could answer,

8 too.

9 MR. STANONICK: Carl probably has a better

10 sense than I have. Not so much other configurations,

11 but I do foresee where there might be market

12 influences where a manufacturer might say, "I want to

13 sell this," quote, unquote, "add-on," like I say,

14 "with an 80-gallon superiorally insulated tank"

15 because, first of all, you'd probably get a better

16 first-hour rating. I may actually get a better energy

17 factor supplying the tank, as opposed to the 52-gallon

18 standard test tank.

19 There may be reasons why he would want to

20 do that. Granted, he's raised the cost of his

21 product, but those are market considerations.

22 DR. HILLER: Carl Hiller from EPRI.

23 Looking at the kinds of water heaters that

24 were out there, heat pump water heaters, the industry

25 has had exactly that kind of tank before they took it

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
233

1 off the market. They had what was really a

2 remote-type heat pump water heater with a water pump

3 in it, but they only sold it with a specific tank.

4 And it had special plumbing fittings on it to connect

5 a certain way.

6 You could have taken the heat pump water

7 heater and used it on anybody's tank, but they

8 wouldn't sell it that way. They only sold it with the

9 tank. And that was classified in the GAMA directory

10 as a with-tank as the end result, and that's the way

11 it ought to be.

12 MR. STEPHENS: Okay. So if it's marketed

13 that way, I can concur it should be tested that way.

14 FACILITATOR RABA: Carl Adams?

15 MR. ADAMS: Carl Adams, DOE.

16 I don't have the test procedure here in

17 front of me, but I thought I remembered that there was

18 a provision in there that you only used the specified

19 tank if there wasn't a tank provided with the heat

20 pump.

21 MR. STANONICK: That's probably correct.

22 I was just reacting to the definition that's here of

23 integral heat pump water heater that's been proposed

24 that says "an air to water heater heat pump integral

25 with an insulated storage tank." To me that has a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
234

1 specific meaning, as opposed to just a unit that gets

2 sold as a package.

3 MR. ADAMS: Right. But what I mean is an

4 add-on heat pump which is not that integral.

5 MR. STANONICK: Right, right.

6 MR. ADAMS: I thought that for the add-on,

7 that there was a provision in the test procedure that

8 you used in --

9 MR. STANONICK: In the proposed one?

10 MR. ADAMS: Well, I was thinking it was in

11 the existing one. I don't remember the proposed one.

12 MR. STANONICK: I don't remember either.

13 MR. ADAMS: -- that you only used the

14 specified tank if the heat pump, the add-on heat pump,

15 didn't come with its own tank.

16 DR. HILLER: I think the point that Frank

17 is trying to make is it's really with a tank or

18 without a tank. Integral has a specific meaning of

19 the two are not separable from each other. And that

20 really is unnecessary. It should be either sold with

2: a tank or not sold with a tank. Integral means

22 specifically physically integrated and not separable.

23 MR. STEPHENS: Carl, Charlie Stephens.

24 Isn't it true that CrispAir makes

25 recommendations for family size and size of storage

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
235

1 tank that can best be mated with it so that any one

2 specific tank that they recommend that --

3 DR. HILLER: As an add-on unit.

4 MR. STEPHENS: -- that that's an add-on

5 unit that doesn't come with a tank necessarily? It

6 simply makes recommendations on how to size the

7 storage tank?

8 DR. HILLER: I don't think there's a big

9 issue on these definitions. The old definitions were

10 adequate. The new definitions weren't. Go back to

11 the old definitions, and we make the problem go away.

12 FACILITATOR RABA: Does your silence mean

13 agreement with that?

14 DR. HILLER: There are a couple of other

15 important issues related to this stuff, though. One

16 that you didn't mention but I think is important to

17 bring up is how you plumb a remote-type heat pump

18 water heater to its tank.

19 The most recently proposed wording says

20 remote heat pump water heaters get hooked with, what,

21 eight-foot-long rubber hoses uninsulated, Frank? I

22 think it says something like that. I think --

23 MR. STANONICK: Something like that,, yes.

24 DR. HILLER: I think that's really

25 inappropriate. What I think the thing needs to say

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
236

1 is, "Install in accordance with the manufacturer's

2 recommendations" because you wouldn't want the heat

3 pump water heater manufacturers to provide all the

4 plumbing fittings because there's such a variety of

5 tank sizes. That would just drive the cost up.

6 Most of them don't provide the plumbing

7 fittings, but they do provide recommendations on, say,

8 "Don't hook up more than two feet away" or "Go this

9 way." They don't say anything about eight feet long

10 uninsulated hoses."

11 Uninsulated would be stupid, for one

12 thing. Nobody would say, "Use uninsulated fittings."

13 You've got to insulate these. They're basically part

14 of the tank. Those lines are part of the tank.

15 MR. STANONICK: Carl, I think actually

16 what it may say is that you do the eight-foot -- you

17 follow the manufacturer's instructions. And if he

18 doesn't provide any, you do the eight-foot. It may be

19 something on that order.

20 DR. HILLER: Well, see, that's the

21 problem. In 1994 the proposal didn't say that.

22 MR. STANONICK: Okay.

23 DR. HILLER: And so we need to have the

24 clause in there that says, "Install in accordance with

25 the manufacturer's recommended insulation

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
237

1 instructions." If they don't recommend it, then use

2 eight feet uninsulated rubber hoses. That will drive

3 them to make the recommendations is what it will do.

4 FACILITATOR RABA: Go ahead. Stan, do you

5 have a comment? Speak up, please.

6 MR. LIU: We evaluated your comments,

7 asking your written comments, during the open comment

6 period. We saw your recommendations. So essentially

9 it will be changed if nobody else has another opinion.

10 FACILITATOR RABA: Thank you very much.

11 You mentioned other issues. Do you have

12 some others to bring up along these same lines?

13 DR. HILLER: That brings us to the draw

14 pattern that should be used under the energy factor

15 test rate. I can show some viewgraphs on that

16 subject.

17 FACILITATOR RABA: Is this a new agenda

18 item?

19 DR. HILLER: Well, it's part of that

20 subject matter you brought up. One of the issues was

21 the drawn pattern energy factor.

22 FACILITATOR RABA: Okay.

23 DR. HILLER: And we've got some science

24 here. We can show what the arguments are.

25 FACILITATOR RABA: Is this a good time to

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
238

1 pick this up now? Let's take a look at this. Go

2 ahead.

3 DR. HILLER: Again, from our test data, it

4 turned out that all 16 of our tests -- we flipped back

5 and forth between resistance and heat pump water

6 heater usage. We used all the data on resistance

7 water heaters and heat pump water heaters.

8 And we used the smallest commercially

9 available heat pump water heater that has ever been

10 built and is ever likely to be built. The reason for

11 that is they don't make compressors much smaller than

12 that.

13 You don't need a heat pump water heater

14 even that big to serve the loads adequately, but you

15 can't make one any smaller because those compressors

16 don't exist.

17 And here is the percentage of annual

18 energy consumption, electric energy consumption, due

19 to the resistance elements versus total. Let me

20 explain this thing. This is not percentage of hot

21 water produced. This is the percentage of energy

22 consumption.

23 Here's that 124.3-gallon-a-day customer.

24 That's 697. Six ninety-eight was 83 gallons a day or

25 .76 gallons a day. Six nine-six was 83 gallons a day.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
239

1 The percentage, the maximum percentage, of total

2 energy consumption we ever saw was 27-28 percent.

3 Most were down less than that.

4 The percentage of water heating done by

5 the upper element is roughly half that because the

6 heat pump water heater has an efficiency that's twice

7 that of resistance elements. So the percentage of

8 energy consumption represented by the element is a

9 larger percentage than the percent water heating done.

10 What this is saying if you work out the

11 math, this is like 16 percent. And all the rest of

12 these are less than ten percent of a water heated on

13 an annual basis is done by that upper element or for

14 backup heat, to defrost, low ambient temperature

15 conditions, or whatever. It's all lumped in there

16 together.

17 If you try and modify the

18 64.3-gallon-a-day, 6-equal-draw test somehow by making

19 it one big draw and then a couple of little draws or

20 whatever such that the upper element would kick on,

21 what happens is once you kick the upper element on,

22 you cannot meet the 10 percent number, just by ever

23 kicking it on.

24 Another way of saying that is, in reality,

25 in the field, the upper elements only come on once

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
240

1 every four or five days, even with these small heat

2 pump units. They don't come on every day. And trying

3 to create a draw pattern that makes them come on

4 during the test, therefore, cannot possibly represent

5 the right percentage energy consumption for hot water

6 delivery, not possible to do that.

7 FACILITATOR RABA: Other comments or

8 questions? Frank?

9 MR. STANONICK: In a letter that we sent

10 in that's in your packets, the last page there, we, in

11 fact, tried to do that. We did have ETL get a heat

1:2 pump water heater and try some different draw

13 schedules.

14 One draw schedule we ran 21.4 gallons at

15 the beginning of each hour for the first 3 hours to

16 see if that might do it. It didn't do it. The

17 element didn't come on.

18 Then we did a schedule that in the first

19 hour we ran 21.4 gallons, the next hour 10.7, let it

20 sit for 2 hours, in the 5th hour went to 21.4, and

21 then the 6th hour went to 10.7, kind of a binodal kind

22 of a usage pattern. And, again, the upper element

23 never came on.

24 . We didn't go much past that because --

25 well, it seemed like the only other choice would have

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
241

1 been to say, "Okay. Let's dump 64 gallons in an hour

2 and see what happens." But that isn't particularly

3 realistic.

4 DR. HILLER: To make it come on, you're

5 driven to emptying the tank.

6 MR. STANONICK: Yes. So, in any event, we

7 haven't been able to identify a usage or draw schedule

8 that, in fact, would make the upper element come on.

9 Carl seems to have some information to explain why

10 that's so.

11 But, nonetheless, I guess we do have the

12 concern, as was shown there, that in terms of the

13 consumption of that product, somewhere on the order of

14 20 percent, give or take, of the consumption does

15 occur through the resistance element.

16 Test procedures today don't account for

17 that at all. And I think we --

18 DR. HILLER: It's more like ten percent.

19 For a 64.3-gallon-a-day average consumption level,

20 it's 10 percent or less. The big numbers were the big

21 consumers. They were way above 64.3. They were 70,

22 80, 120-gallon tanks.

23 MR. STANONICK: All right. But I guess

24 I'm also thinking at least some older field studies

25 that suggested it was in that area of 15-20 percent.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
242

1 In any event, our position still is that it's not

2 insignificant.

3 There is some significant portion of the

4 consumption of that product that occurs through the

S resistance element, not through the heat pump. And

6 this procedure -- there's no factoring that in right

7 now.

8 Obviously if we had some way to do that,

9 we would have included it in our letter, but we don't.

10 FACILITATOR RABA: Can anybody add to that

11 or lead us in direction to the group? Go ahead,

12 Charlie.

13 MR. STEPHENS: Frank, based on what you

14 and Carl have just told us, is there some way that you

15 could, given that we can't accurately reflect reality

16

17 MR. STANONICK: Right.

18 MR. STEPHENS: -- for every household in

19 America, is there a way that you could mathematically

20 calculate, basically measure the energy use of the

21 heat pump unit and then penalize at some fixed amount

22 for the fraction of the time?

23 MR. STANONICK: I'm sure you could, yes.

24 MR. STEPHENS: Assume that every heat pump

25 out there if they face the same draw schedules that

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
243

1 this ugly family put it through that they'd all have

2 a similar kind of energy performance? Mathematically

3 can we do that?

4 DR. HILLER: This is the very reason.

5 These kinds of issues are the very reason we created

6 this computer code. This computer code does a full

7 transient analysis second by second basis 355 days a

8 year.

9 There are all the appropriate parameters

10 any way you want to enter them, entering cold

11 temperature, entering load temperature, entering heat

12 pump water heater source temperature, varying draw

13 patterns from zero gallons a day to 200 gallons of

14 day, whatever you want to put into it. And it will

15 tell you what the energy total consumption is, how

16 much of it is due to heat pump versus upper element

17 versus lower element, et cetera.

18 You can't do that with an average single

19 number test procedure. You have to use a

20 sophisticated program to do that. That's why we

21 created the tool. It is not possible with a single

22 energy factor rating number to make any kind of a

23 procedure that will do that.

24 MR. STEPHENS: Do what, though?

25 FACILITATOR RABA: Excuse me. For the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
244

1 record, this is audio, not video. Could you please

2 state what the "this tool" is? Thank you.

3 DR. HILLER: WATTSIM computer program.

4 FACILITATOR RABA: WATTSIM computer

5 program?

6 Now, question back here.

7 MR. STEPHENS: I guess I'd still have to

8 go back to saying: What? I guess if I wanted to know

9 given a set of conditions that I understood well

10 enough exactly what the consumption would be, then I

11 would have to use that?

12 Again, reminding everybody that we're not

13 trying to figure out reality here, we're only trying

14 to get a consistent way to test one piece of equipment

15 against another one consistently.

16 We really I think do need to come up with

17 some kind of a test procedure-based way to rate these

18 products similarly to the way other products are rated

19 but recognizing that they have this funky feature.

20 DR. HILLER: Again, Carl Hiller from EPRI

21 speaking.

22 The problem with trying to do that is the

23 DOE test procedure is based on average consumption.

24 And under average consumption, whether you have a heat

25 pump or a water or whatever, the upper element does

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 2344433

 EE-RM-94-230 COMMENT 49P
245

1 not come on under that. It only comes on under the

2 extremes. So any procedure that is designed based on

3 averages cannot reflect the extremes.

4 FACILITATOR RABA: Frank, you had your

5 hand up?

6 MR. STANONICK: You're talking about the

7 daily situation. But the information does indicate

8 that on the average, whether it's monthly or annual,

9 on the average, the consumption of that heat pump

10 water heater, there is, again, I'm going to say, a

11 significant portion of the energy consumption that

12 goes through the resistance element, not the heat

13 pump.

14 Now, the fact that it isn't daily, I

15 recognize that, but it seems to me that -- I'll just

16 make up a number. Let's say if it were just a ten

17 percent adjustment factor in the annual consumption

18 number, that would still be more reflective of the

19 average use because the average use is not that all of

20 the consumption of that water heater goes through the

21 heat pump. That's not the case, and we know that.

22 Now, whether the number is 10, 15, or 20,

23 that's something that can be researched and somewhat

24 I'm sure debated. But we still believe there should

25 be some kind of mathematical adjustment there.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
246

1 DR. HILLER: Let me throw out another

2 thing here. Recognizing that the WATTSIM computer

3 code is a complex code that the average person is not

4 going to use, we've created what's called the

5 WATTSIMPL computer code.

6 What this does is it takes the DOE energy

7 factor test information and knowledge of the test

8 conditions and the energy factor rating results, and

9 that calculates the heat loss characteristic for a

10 given tank or a given energy factor rating.

11 Then, knowing that UA factor for the tank,

12 as it were, you can calculate the energy efficiency

13 under any other set of conditions, gallons per day,

14 changes in entering water temperature, changes in set

15 point temperature, et cetera.

16 The way we do heat pump water heaters, we

17 have performance maps. Both of these programs have a

18 performance map of the heat pump water heater that you

19 have to either create or get from the manufacturer.

20 And then in the simplified procedure, the

21 worst case scenario pretty much is that any

2:2 consumption above 75 percent of tank volume is done by

23 the resistance element. And below that is done by the

24 heat pump. That's the worst case scenario. This is

25 very simple. Anybody can pick this up.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
247

1 What we give them in terms of the energy

2 efficiency and energy consumption in the heat pump

3 water heater cases, we, therefore, give you a range.

4 One range is all the water heating that's done by the

5 heat pump. The other range is only 75 percent of tank

6 volume as done by the heat pump.

7 So if you have 200 gallons per day

8 consumption and you have a 10-gallon tank, 7.5 gallons

9 is done with a heat pump. And the rest is done with

10 a resistance element.

11 If you have a 100-gallon tank and 50

12 gallons of day consumption, then none is done with the

13 resistance element. So there is a range that you can

14 look at for energy consumption with these simple

15 models that is in the right range.

16 But, really, there's no predictor on what

17 any given customer will get because it's a function of

18 exactly how they use hot water. They could have the

19 same total gallons per day but have it spread out, as

20 opposed to clustered, have it spread out. They won't

21 trip on the upper element.

22 Even the smallest heat pump water heater

23 is capable of heating 300 gallons a day, way more than

24 you need. Whether or not you kick on the element is

25 a function of how clustered your water draws are.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
248

1 MR. STEPHENS: Yes. Charlie Stephens

2 again.

3 I guess we recognize all of that. All you

4 have to do is size the storage tank large enough And

5 you'll probably for any given group of people avoid

6 ever tripping the heating element.

7 However, I don't know that that's going to

8 be sized that way. And I guess my recommendation

9 would simply be for learned people -- and that might

10 involve NIST and any number of other -- Frank, you

11 know, you all get together and figure out what penalty

12 per se -- I don't like to use that word, but what

13 resistance element penalty might be appropriate to

14 apply to any given installation to recognize that in

15 some installations, you're going to trip the element

16 in a small percentage of the time.

17 And it just gets applied as equivalently

18 as we can to all the different types of heat pump

19 products that might be out there such that it will

20 penalize their energy factor a little. But, again,

21 given that you're starting almost two, more than two,

22 it's not going to be a terrible number, I wouldn't

23 think.

24 DR. HILLER: Carl Hiller speaking again.

25 Let me translate what you just said. If

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
249

1 we had more field test data like the stuff that I

2 showed earlier, we could do that. And I would love to

3 have that data.

4 You're right. If we had enough

5 statistically valid sampling for all ranges of the

6 country, we got warm air temperatures and warm water

7 temperatures and cold air, you could probably create

8 some statistics to the 95th percentile kind of stuff.

9 It's going to be different depending on

10 geographical locations. Southern climates almost

11 never hit down in the upper element, no matter what,

12 Alaska probably more so than Florida. So there's no

13 one number that is ever going to really represent a

14 national average.

15 MR. STEPHENS: Then I would recommend

16 making it small. Once again, we're not trying to

17 reflect reality here. We're just trying to compare

18 pieces of equipment fairly.

19' FACILITATOR RABA: What does the rest of

20 the group think about that? Tim?

21 MR.. BERNARDOWSKI: Tim Bernardowski,

22 Virginia Power.

23 I think there are some pros and cons to

24 what you're proposing. Putting myself in a position

25 of maybe somebody selling an add-on heat pump water

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
250

1 heater, I might say that if you do that from my add-on

2 heat pump water heater that comes with no tank

3 designation at all, that you're unfairly penalizing me

4 because the customer may put that on any type of a

5 unit and you have just no clue at all as to what the

6 number would be for the resistance part of that on

7 there.

8 So I'd say if you go that route, at least

9 for the add-on use, it wouldn't be appropriate to add

10 that penalty on to the add-on units.

11 MR. STEPHENS: Except you really are

12 leaving that in the hands of the person who installs

13 the system and the choice of tank they make for the

14 system. If they choose a bigger tank in order to

15 avoid that penalty, then the consumer is going to get

16 penalized the additional money for that storage tank

17 up front.

18 And I think if you balance that off

19 against some level of savings that might be expected

20 from that investment up front, it's not going to be so

21 radically different than if they got a smaller tank

22 and paid for some electricity for the resistance

23 element once in a while.

24 So I'm not sure the consumer is going to

25 be penalized by not getting the right signal.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
251

1 MR. BERNARDOWSKI: Well, if I look at it

2 from the consumer perspective, I'm buying the add-on

3 heat pump water heater as a separate item. I'm not

4 buying the tank.

5 If I'm concerned with that, then I should

6 look at what happens when I combine that add-on unit

7 with various types of tanks, maybe using programs or

8 whatever. I think it's a penalty that's inappropriate

9 because it's just there's nothing at all designated

10 about what that tank is.

11 You've got to use something for standards

12 for rating the energy on the heat pump water heater.

13 But I just think it would be an unfair penalty to an

14 add-on heat pump water heater because there's such a

15 large --

16 FACILITATOR RABA: Did you get up,

17 everybody, okay? Jim, could you share that with us?

13 MR. RANFONE: We agree with him, whatever

19 he said there.

20 FACILITATOR RABA: It's a good question.

21 Go ahead. Thank you for the comments, Tim.

22 Yes, go ahead.

23 MR. RANFONE: I had a technical question

24 on the test procedure.

25 FACILITATOR RABA: Okay.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
252

1 MR. RANFONE: I got my answers.

2 FACILITATOR RABA: Thank you very much.

3 Excuse me for interrupting you.

4 Does anybody else have any comments on

5 this? Jim?

6 MR. LUTZ: Jim Lutz, LBNL.

7 It seems like the number of sales of heat

8 pump water heaters is so small -- I hope that that

9 changes, and I'm sure some other people in the room

10 do, too. But for now and given how much more

11 efficient they are than just by their nature that it

12 seems like you shouldn't even -- the extra fuss and

13 bother of creating a separate test procedure for the

14 number that is sold doesn't seem to be worth it at

15 this point to me.

16 FACILITATOR RABA: Another view? I see a

17 head nodding back there. Any other comments on this?

18 MR. STANONICK: Again, so everybody is

19 clear on this, the only reason it's an issue for us

20 is, in fact, because the energy factor that came out

21 of the current test procedures became a basis for DOE

22 to come out with a rule that says every water heater

23 should be a heat pump water heater. And, in fact, now

24 you're talking about what we maintain is a huge

25 misrepresentation of what will happen in the field.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
253

1 And so Jim is absolutely right. These are

2 not a huge player in the market right now. But if

3 people are going to -- rightly or wrongly, if they are

4 going to assume that the test procedure does tell them

5 what the thing is going to do in the field and it

6 leads to incorrect conclusions in some people's

7 opinion, ours included, then actually we've got to fix

8 the procedure, then.

9 Because, again, even putting that aside,

10 if this thing is going to be compared to, again,

11 looking at the relative -- you know, this is our

12 measuring stick concept. If it is going to be

13 compared to an electric resistance storage water

14 heater and if the information is there that says,

15 "Well, this heat pump water heater, this isn't really

16 the full picture because it doesn't heat the -- not

17 all the consumption occurs through that machine," then

18 I think it needs to be fixed.

19 I don't believe its benefits for

20 efficiency need to be exaggerated. They already are

21 well-defined as superior to a electric resistance

22 water heater. But, that being the case, you don't

23 need to overemphasize or over-exaggerate what that

24 product is going to do. And right now I think we have

25 that circumstance.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 

. . 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
254

1 FACILITATOR RABA: Help me out. Jim first

2 and Steve, then back to Charlie.

3 MR. RANFONE: Jim Ranfone, AGA.

4 I would take the position that if you're

c; going to do this realistically and some adjustments

6 have to be made to the test procedure to account for

7 electric resistance operation, then do it because you

8 can't talk out of both sides of your mouth in terms

9 of, "Well, we're going to try to save energy," yet the

10 test procedure doesn't adequately reflect the electric

11 resistance usage.

12 And you can't promote the hell out of it

13 and say it's the best thing since sliced bread, on one

14 hand, and then when DOE comes along and does an

15 evaluation of minimum efficiency in this case, based

16 on the information that's provided by the marketeers,

17 then I would say maybe this is a small segment of the

18 market now.

19 But if you continue to promote it as. being

20 all-encompassing, it does provide all the hot water,

21 electric resistance isn't accounted for, it's going to

22 get a larger market. In those cases, where are you

23 going to be? So adequately reflect the best you can

24 the use of electric resistance to hot water.

25 I don't know how much impact that has on

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
255

1 the analysis of overall energy use for heat pump water

2 heaters. Is it really going to skew it that much to

3 save ten percent that it doesn't become as

4 cost-effective as DOE has presented it in your 1994

5 "Federal Register" notices? Does the ten percent

6 additional use or accounting for electric resistance

7 skew your analysis that much?

8 FACILITATOR RABA: Steve?

9 MR. ROSENSTOCK: One thing I want to say,

10 again, talking about test procedures, it seems that if

11 you wanted to draw out that resistance element like

12 Dr. Hiller was saying, you have to do such an extreme

13 test procedure that it has nowhere near any sense of

14 reality. It would have to be one draw at 50 or 60

15 gallons to bring out that upper element for a heat

16 pump water heater.

17 And if you have such a radical difference

18 in test procedures, then I don't think you're really

19 getting a clear and accurate picture because from what

20 I've been hearing, at least 90 percent of the time, it

21 seems, the resistance element is going to come on

22 anyway. And I think at a 90 percent confidence level,

23 that's pretty good.

24 FACILITATOR RABA: Charlie?

25 MR. STEPHENS: Yes. I guess I find myself

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
256

1 in a position of agreeing with just about everybody

2 who's said anything so far. It leads me to the

3 conclusion that we ought to be able to penalize these

4 things in a rational way that does more accurately

5 reflect their true performance.

6 We have about three dozen of these add-on

7 units in the field right now that are being

8 sub-metered. I don't know if our data so far is

9 broken out to where I can get an estimate of what

10 fraction of the consumption is on the resistance

11 elements.

12 We measured that, but I don't know if I

13 can collect it yet. It's being computer-collected.

14 But if we can, I'm sure we should be able to come to

15 some rational amount that is not going to penalize the

16 heat pump water heaters drastically. I can already

17 tell you that based on what our data is.

18 A lot of our data is on 50-gallon nominal

19 tanks out there. And so I know the customers are

20 pretty happy with it. We haven't had any problems

21 that would suggest there's a level service issue.

2:2 So everything seems to be normal. And,

23 yes, they work pretty well. And we've got some data.

24 I think we ought to be able to sit around the table

25 and come up with some mathematical way of representing

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
257

1 that for the time being given Jim's comment that, hey,

2 there aren't that many of them yet. The damage is

3 minor.

4 ' FACILITATOR RABA: First Carl. And then

5 I saw Steve. You're up, Tim, after that.

6 DR. HILLER: There's a fundamental issue

7 here. Right now we have an energy factor test

8 procedure that's kind of meant to represent average

9 conditions. Do we want to stick to a test procedure

10 that represents average conditions or not?

11 If you try and change the test procedure

12 to kick upper elements on, that is a deviation from

13 average conditions because under average conditions,

14 under the conditions of DOE's test procedure, for the

15 most part upper elements don't come on at the average.

16 So if you're going to change that procedure to deviate

17 from the average, I would argue you should change them

18 all and deviate.

19 If you look at the difference in cold

20 water temperature between Alaska and Phoenix, it's 100

21 percent difference in the energy consumption to

22 provide the same amount of hot water. Why not deviate

23 in that respect, too?

24 I say don't start deviating from average.

25 If you're going to have an average, stick to it for

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
258

1 everything. Don't make an exception for one product.

2 FACILITATOR RABA: Steve?

3 MR. ROSENSTOCK: Just a comment. You said

4 3-16 is your testing and you're collecting your data.

5 Do you have any preliminary information?

6 MR. STEPHENS: I'm not in charge of that

7 product. So I --

3 MR. ROSENSTOCK: How long is your data?

9 MR. STEPHENS: It's a two-year project.

10 And it started about seven months ago. So I don't

11 really know how soon we're going to be reducing the

1:2 data to some form that's readable by the outside

13 public.

14 I know these guys pretty well. I might

15 actually be able to coerce one number or one piece of

16 data out and try to help people make a decision.

17 FACILITATOR RABA: Tim, is that --

13 MR. BERNARDOWSKI: Tim Bernardowski,

19 Virginia Power.

20 I just wanted to point out in discussing

21 this, this is kind of peanuts compared to the

22 differences we get in the amount of resistance heat

23 depending upon your ambient air conditions on these

24 things, depending on where you place things, how much

25 of the year it sees too cold to actually do anything.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
259

1 It actually takes the lower element.

2 Yes. Just to keep this whole discussion

3 in perspective, this thing about the upper element is

4 peanuts compared to differences you can see in

5 resistance based on where you put the ambient air

6 conditions.

7 FACILITATOR RABA: Thank you.

8 Frank?

9 MR. STANONICK: I was just going to agree

10 with Carl. At this point we're not saying change the

11 average conditions of the test procedures. We tried

12 it. You can't. So don't even bother it. I mean,

13 we're not saying change the test procedure to try and

14 force the electric resistance element to come on.

15 What our position is, then, in the test

16 procedures when you get to the point of estimating

17 consumption, at that point you've got to we believe

18 roll in somehow some factor that says, "Okay. In

19 terms of the consumption of this product, there will

20 be some segment that goes through an electric

21 resistance element which doesn't give you two btu for

22 every one. It gives you roughly one for every one."

23 And, as I said there, whether it's 10

24 percent or 20 percent or whatever the number is, it is

25 some number. And I think it can be reasonably figured

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
260

1 out.

2 FACILITATOR RABA: Carl?

3 DR. HILLER: Carl Hiller, EPRI.

4 I would argue that if you start playing

5 that game, then you should open up the whole gamut and

6 put in the 100 percent variation to the water

7 temperature and all the other factors that are really

8 important.

9 My argument is that we've got the tools to

10 do the analysis right, but that's not the DOE test

11 procedure. If you want to know the right number, use

12 the tool. The tools will give you the right number.

13 FACILITATOR RABA: A comment back there?

14 You had your hand up?

15 MR. ABRAMS: Yes. When we were discussing

16 first-hour rating, we said very strictly that we were

17 not trying to create a figure for use in seismic

18 systems, we were just creating a figure for relative

19 comparisons.

20 Are we not getting into the same sort of

21 extrapolation here to try to go from a comparison

22 figure to actual end-use figures?

23 FACILITATOR RABA: Does someone want to

24 respond? Frank?

25 MR. STANONICK: The thing that seems

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
261

l different to me is with the other water heaters, this

2 value that we have determined based on average

3 conditions, if you will, tracks when you change

4 conditions in the field. All right?

5 If you have a different temperature rise,

6 again, it's fairly linear proportion. If you have

7 different uses, it's fairly linear proportion. But in

8 the case of the heat pump water heater, the test

9 procedure just doesn't capture today any consumption

10 that occurs through the, if you will, less efficient

1: means. And, yet, data from the field says that

12 happens.

13 That to me is a very different situation

14 versus the situation of, "Okay. How does the average

15 value we have selected for the test procedure compare

16 to the range in the field?" To me it's just a very

17 different circumstance.

18 FACILITATOR RABA: Go ahead.

19 MR. LOWENSTEIN: Andy Lowenstein, AIL

20 Research.

21 It seems like we're having a lot of

2:2 trouble just dealing with uncertainty. And I'm coming

23 at this from the field testing, laboratory point of

24 view. One thing I know from experience is that we

25 never try to make corrections to our data when the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
262

1 measurement error is greater than the quantity we're

2 trying to measure if we're trying to make the

3 adjustment.

4 That's what we're trying to do here to a

5 certain extent. We don't have any good handle on how,

6 what the magnitude of this correction factor is. And

7 is your statement saying, "Well, we'll find out what

8 a reasonable correction factor is?"

9 I think we all know judging by the

10 practical problems involved in collecting this type of

11 data that there's not going to be any type of a

1:2 consensus as to what a reasonable correction factor

13 is.

14 And until there are more of these units

15 out in the field that it really begins to make a

16 difference, why are we just setting out another area

17 of contention? And why are we in a sense trying to

18 make adjustments that are within our ability, within

19 our measurement error, within our ability to measure

20 the quantities that we're trying to address?

21 Generally what we do, we may know that

22 there is an error in our measurements, but if it's

23 within the ability of our instrumentation to measure

24 it, we leave the data the way it is.

25 FACILITATOR RABA: Thank you.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
263

1 Go ahead, Jim.

2 MR. RANFONE: Yes. Jim Ranfone, AGA.

3 Just another comment about trying to

4 normalize the test procedures is basically what the

5 discussion is about. You always have a precedent.

6 Whether you like test procedures, you agree with them,

7 you don't agree with them, they're the law of the

8 land. And they've been around for a number of years.

9 And there is a precedent for normalizing,

10 as we call it. In the test procedures, you make

11 adjustments for over-sizing, things like that, to try

12 to put some semblance of continuity of what energy use

13 is in the field.

14 Now, again, you may not agree with that,

15 but that's been a precedent. And I think this is

16 another case where in the heat pump water heater test

17 procedure, that ought to be felt there, a

18 normalization process.

19 MR. LOWENSTEIN: Well, I'm not arguing

20 against normalizing.

21 Andy Lowenstein again.

22 I'm not arguing against normalizing. All

23 I'm saying is that you have just as much chance of

24 overcompensating. When you don't know the magnitude

25 of the quantum you're testing for, you have just as

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
264

1 much chance as overcompensating than you are if you

2 left it where it was.

3 MR. RANFONE: Okay. Jim Ranfone.

4 I thought you were going the other way:

5 Don't do anything. So you're saying if you have the

6 data, then make the adjustment.

7 MR. LOWENSTEIN: If you have the data,

8 certainly use the data to make the adjustment.

9 FACILITATOR RABA: A couple more, and

10 we'll go on. Go ahead, Carl.

11 DR. HILLER: Carl Hiller again here.

12 If I understand correctly what Frank is

13 proposing, he's saying run this test under the kind of

14 average conditions that we're currently using and then

15

16 MR. STANONICK: Don't change the test.

17 Just run it the way it is.

18 DR. HILLER: -- and then multiply by .9 or

19 something like that, somehow, some measurement to get

20 that number. The problem with doing that is that .9

21 is not the average condition.

22 That number comes from a non-average

23 condition. And as soon as you open it up to doing

24 that, maybe the number is 1.2, not .9. Certainly that

25 isn't going to be 1.2 in Florida. It's not going to

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
265

1 be .9. It's going to be bigger in the warmer

2 climates. It's going to go above the average.

3 It's not a single corrections factor

4 involved here. The higher the entering air

5 temperature, the more efficient your heat pump is. So

6 we're testing this thing at 67.5, entering air

7 temperature, when the average air temperature in

8 Florida is 75. In Phoenix it's 82.

9 MR. STEPHENS: Well, the data I'm going to

10 give you is it's 67, all of them.

11 DR. HILLER: It turns out that the

12 correction factor that you would want to apply when

13 you start deviating from the averages, if you're

14 really going to start playing that game, you've got to

15 correct depending on where you are.

16 It's not a single number. I mean, the

17 average conditions are not 67.5 in Florida. The

18 number could be higher or lower. So don't play the

19 game.

20 FACILITATOR RABA: Go ahead, please.

21 MR. VAUGHN: Jim Vaughn, Vaughn

22 Manufacturing.

23 I think we're getting back to the. same

24 arrangement that we heard from the young man from DOE.

25 You know, the same thing Carl just said about the heat

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
266

1 pump water heater can be said about the whole test

2 procedure. You take any resistance water heater and

:3 take the standard test and move north or south or

4 change the ambient conditions or change the draw

5 schedule, and the thing is invalid.

6 I mean, what we're trying to get here is

7 a standard for testing and not a standard that's

3 supposed to work all over the United States. And I

9 think when you approach it, it ought to be approached

10 on a conservative basis, just like all the other tests

11 are approached.

12 FACILITATOR RABA: Thank you.

13 A couple more comments. We should finish

14 up soon. Go ahead, George.

15 MR. KUSTERER: George from Bock.

16 Basically we were here this morning when

17 we were dealing with 50 degrees and 77 degrees, same

18 issue. What have we learned from this morning?

19 Nothing.

20 I agree with Mr. Vaughn. I think that's

21 where we should go. Once we start playing with

22 numbers, that's what you want to do with the 50

23 degrees because you've got 90-degree groundwater in

24 Florida. I sure as heck don't have it in

25 Pennsylvania. But what we need is an average,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
267

1 something that's workable for everybody.

.2 I think the direction that we're going in

:3 is extremely valuable. However, there's no consensus

4 of opinion here. There is no direction. I think

5 that's where we should be, not what's best for -- I

6 mean, we've got a level playing field now. Everybody

7 wants to change numbers to suit themselves.

8 Well, I'll tell you what. I'll go home

9 tonight. And if a state trooper on 95 decides, "Hey,

10 I'm going to give tickets at 68 miles an hour,"

11 instead of 70,. well, that suits him good. It sure as

12 heck don't help me. And that's what we're doing.

13 FACILITATOR RABA: Other views on that,

14 please?

15 (No response.)

16 FACILITATOR RABA: Well, I would say that

17 we certainly accomplished a lot here today in the

18 sense that our purpose was to gather feedback and

19 information from all of you. You all had a chance to

20 speak on these different issues and gave us some

21 dialogue.

22 Before we say go further, we would like

23 to. Is there anything else on the agenda we should

24 cover or go beyond? Go ahead, Steve.

25 MR. ROSENSTOCK: I was just going to do an

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
268

1 extra comment. In terms of if people wanted to submit

2 other written comments about this issue or some other

:3 issues that were brought up today, do you have any

4 particular deadline for comments?

5 FACILITATOR RABA: The question is: Where

6 do we go from here? Bryan Berringer will address

7 that.

8 MR. ROSENSTOCK: Okay.

9 MR. BERRINGER: As far as comments, if

10 anybody would like to elaborate on comments,

11 statements made today, offer additional supporting

12 statements or information, we will consider that.

13 What we'd like to do is to request that

14 additional information, that the subject matter be

15 diluted to what was on the agenda today, what was

16 discussed today as far as topics. And don't go

17 outside that scope.

18 I would suggest if it's agreeable that we

19 would look at maybe having comments by the end of this

20 month, by February 28. And if people don't think

21 that's enough.time, please indicate it's unacceptable.

22 Is there any discussion on that?

23 MR. KUSTERER: Bryan, I think, you

24 suggested earlier in the program that 30 days would be

25 the schedule for written comments. I know that number

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
269

1 was thrown out.

2 MR. BERRINGER: Yes.

3 MR. KUSTERER: I'm not sure it was from

4 you.

5 MR. BERRINGER: No. It's up for

6 discussion. I mean, we want to try and keep a

7 schedule here. We've got to address a schedule to get

8 the test procedures done. We said we'd plan for

9 April. So we'd like to get it as soon as possible.

10 But if you feel 30 days are needed, then I think

11 that's something we can do.

12 Are there any other comments?

13 MR. STANONICK: Thirty days would be

14 better.

15 FACILITATOR RABA: Go ahead.

16 MR. VAUGHN: Jim Vaughn, Vaughn

17 Manufacturing.

18 I have just a suggestion. As my

19 impression of the meeting, this whole business of the

20 testing versus what uses of the numbers of the field

21 have come up,.there's no question in my mind that it's

22 a very valid observation.

23 I think that DOE has an opportunity here

24 to do us all a lot of good if they could consider

25 Frank's suggestion is that the standard water heater

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
270

1 tests would have to have some linear adjustments

2 depending on whether you live in the Dakotas or in

3 Florida or Texas.

4 Why can't DOE take on the job or give it

5 to one of these smart young fellows here and print

6 that linear adjustment and educate the state and local

7 code authorities and the state and local conservation

8 people so that they can make the adjustment for their

9 area and then emphasize that our test procedure was

10 conducted in this manner for consistency? We need no

11 better excuse than that. And tell them that in their

12 neighborhood, these numbers need adjusting according

13 to these factors. It would make sense.

14 FACILITATOR RABA: Thank you.

15 Further comments, please? Steve?

16 MR. ROSENSTOCK: Bryan, these comments

17 should be sent to you, addressed to you, or to whom?

18 MR. BERRINGER: As in the "Federal

19 Register" notice, it would be addressed to me or to

20 Sadie Beall, as it appears in the "Federal Register"

21 notice.

22 Based on the discussion, I was going to

23 say that we would allow 30 days for a comment period.

24 And that would be -- make it March 12th. I don't have

25 a calendar in front of me.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
271

1 Is that acceptable to everybody, March

2 12th?

3 MR. KUSTERER: That's a Wednesday?

4 MR. BERRINGER: Yes.

5 FACILITATOR RABA: Does anybody else have

6 something to add to our topics today? Go ahead,

7 George.

8 MR. KUSTERER: My final comment. I think

9 the moderator did an excellent job, and I commend him

10 for that.

11 FACILITATOR RABA: Well, I thank you all

12 for being very open to discuss, engage in dialogue,

13 stick to the issues on the agenda. You've made my job

14 a lot easier. And I appreciate your time certainly.

15 I see we have indeed fulfilled our purpose

16 to gather feedback from you. This has been your

17 meeting. And we've gathered a lot of information. We

18 expect more. Thank you very, very much.

19 I would commend to your attention this

20 meeting evaluation form if you'd like. Just fill this

21 out and leave it with Sandy on the way out. I would

22 appreciate that.

23 You know this is part of our new process,

24 our process of improvement, to afford more time to

25 discuss, to evaluate before a test procedure does come

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
272

1 out. And so I appreciate your participating in that

2 as we go forward, as we focus on the future with

3 topics such as water heaters and other, other

4 products.

5 Thank you all for coming today.

6 Anything further from our chairman?

7 MR. BERRINGER: No. I'd just like to

8 thank everybody for coming. It's a lively discussion.

9 I think you gave us a better direction on how we can

10 go.

11 Thank you.

12 FACILITATOR RABA: Entertain adjournment.

13 (Whereupon, the foregoing matter was

14 concluded at 3:56 p.m.)

15

16

17

18

19

20

21

22

23

24

25

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 200053701 (202) 234-4433

 EE-RM-94-230 COMMENT 49P
2

CERTIFICATE

This is to certify that the foregoing transcript in t

matter of: Water Heater Test Procedure Workshop

Before:

Date:

U.S. Dept. of Energy

February 12, 1997

Washington, DC

represents the full and complete proceedings of th

aforementioned matter, as reported and reduced 

typewriting.

A -ti3

g W j^

Place:

 EE-RM-94-230 COMMENT 49P