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 UNITED STATES DEPARTMENT OF ENERGY 

 ENERGY EFFICIENCY & RENEWABLE ENERGY 

 + + + + + 

 TEST PROCEDURE NOPR FOR 

 DIRECT HEATING EQUIPMENT AND POOL HEATERS 

 + + + + + 

 PUBLIC MEETING 

 + + + + + 

 WEDNESDAY 

 DECEMBER 4, 2013 

 + + + + + 

 The Public Meeting convened in 

Room 8E-089, Forrestal Building, 1000 

Independence Avenue, S.W., Washington, D.C., 

at 9:00 a.m., Doug Brookman, Facilitator, 

presiding. 
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PRESENT: 

DOUG BROOKMAN, Facilitator 

KEN BELDING, Empire Comfort Systems 

RYAN CARROLL, Hearth, Patio & Barbecue 

 Association 

ROSALYN COCHRANE, Natural Resources Canada 

RUTH ANN DAVIS, Williams Furnace Company 

VICTOR FRANCO, Lawrence Berkeley National 

 Laboratory 

BYRON HORAK, Intertek 

ALEX LEKOV, Lawrence Berkeley National 

 Laboratory 

JOHN O'HARE, Hayward Industries 

FRANK STANONIK, Air Conditioning, Heating and 

 Refrigeration Institute 

DYLAN SULLIVAN, Natural Resources Defense 

 Council 

JOHN MICHAEL TALBOTT, P.E. 

VANCE WILLIS, Hayward Industries 

ALSO PRESENT: 

ARI ALTMAN, Office of General Counsel, DOE 

ASHLEY ARMSTRONG, DOE 

ADAM DARLINGTON, Navigant Consulting 

JUSTIN ELSZASZ, Navigant Consulting 

WILLIAM HEALY, National Institute of 

 Standards and Technology 
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 TABLE OF CONTENTS 

 Page 

Welcoming Remarks and Introductions 

 Doug Brookman and 

 Ashley Armstrong................ 4 

Regulatory History 

 Ashley Armstrong................ 9 

Rulemaking Overview 

 Ashley Armstrong................ 10 

Description of Issues Addressed in 

this NOPR 

 William Healy.................. 10 

Closing Remarks 

 Doug Brookman................... 34 
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1 P-R-O-C-E-E-D-I-N-G-S 

2 (9:03 a.m.) 

3 MR. BROOKMAN: Good morning, 

4 everyone. Welcome. This is the test 

5 procedure and NOPR for direct heating 

6 equipment and pool heaters. Today is 

7 December 4, 2013 here in the Forrestal 

8 Building. My name is Doug Brookman from 

9 Public Solutions. Glad to see you all here 

10 this morning. 

11 We are going to start with 

12 welcoming remarks from Ashley Armstrong. 

13 MS. ARMSTRONG: Hi, everyone. My 

14 name is Ashley Armstrong at DOE. I oversee 

15 the test procedures here coming out of the 

16 Department. 

17 I want to just welcome everyone. 

18 Thanks for coming. As you can see, we have a 

19 pretty short presentation, just to give you an 

20 overview of the proposed rule for test 

21 procedures. The important part of this is 

22 that we welcome your feedback and any 
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1 questions you have. So, we encourage you to 

2 participate as much as possible. 

3 And other than that, I will turn 

4 it over to Doug. 

5 MR. BROOKMAN: Thank you. We 

6 start with introductions, typically. You can 

7 get used to turning these microphones both on 

8 and off. If you are not using them, please 

9 turn them off. And I will start here to my 

10 immediate left. Your name and organizational 

11 affiliation. 

12 MR. WILLIS: Vance Willis, 

13 Hayward Industries. 

14 MR. BELDING: Is this on? 

15 MR. BROOKMAN: Now it is, yes. 

16 MR. BELDING: Ken Belding, Empire 

17 Comfort Systems. 

18 MR. CARROLL: Ryan Carroll with 

19 the Hearth, Patio and Barbeque Association. 

20 MR. SULLIVAN: Dylan Sullivan 

21 with the Natural Resources Defense Council. 

22 MS. COCHRANE: Rosalyn Cochrane, 
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1 Natural Resources Canada. 

2 MR. HORAK: Byron Horak from 

3 Intertek. 

4 MR. ALTMAN: Ari Altman with 

5 DOE's Office of the General Counsel. 

6 MS. ARMSTRONG: Ashley Armstrong, 

7 DOE. 

8 MR. BROOKMAN: Please stand. 

9 Yes, you. Just say it. 

10 MR. ELSZASZ: Justin Elszasz, 

11 Navigant Consulting. 

12 MR. DARLINGTON: Adam Darlington, 

13 Navigant Consulting. 

14 MR. LEKOV: Alex Lekov, Lawrence 

15 Berkeley National Laboratory. 

16 MR. HEALY: Bill Healy, National 

17 Institutes of Standards and Technology. 

18 MR. BROOKMAN: You are just in 

19 time, Frank. Introduce yourself. 

20 MR. STANONIK: Frank Stanonik, 

21 AHRI. 

22 MR. FRANCO: Victor Franco, 
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1 Lawrence Berkeley National Lab. 

2 MR. TALBOTT: John Talbott, 

3 consultant. 

4 MR. O'HARE: John O'Hare with 

5 Hayward Industries. 

6 MR. BROOKMAN: Thanks to all of 

7 you for being here. As Ashley said, it is a 

8 rather short presentation content packet this 

9 morning. We are just going to go through the 

10 packet page by page. And you will note in the 

11 packet there are these comment boxes that 

12 specifically call out the Department's 

13 request that you speak to the issue in that 

14 box. 

15 I would ask for your 

16 consideration. If you would, please speak 

17 one at a time. Please say your name for the 

18 record each time you speak. There will be a 

19 complete transcript of this meeting available 

20 to you on the website. Please keep the focus 

21 here. Turn your cell phones on silent mode. 

22 Limit the sidebar conversations. You have 
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1 already gotten used to turning these 

2 microphones on and off. That's good. If you 

3 could be concise, share the air time. I will 

4 be queuing individuals by name as best I can. 

5 I wish to encourage follow-on comment 

6 frequently. It is useful for the Department 

7 as they are considering the detailed comment 

8 that comes in this conversation, the back and 

9 forth between individuals sometimes is very 

10 helpful. 

11 So, I think that that is about all 

12 I need to say. Do we have individuals joining 

13 us via the web, Jack? Ten individuals joining 

14 us via the web. 

15 Welcome to all those joining via 

16 the web. The Department of Energy is trying 

17 very hard to make these meetings accessible. 

18 And if you would please keep your telephone on 

19 mute. And if you raise your hand and the 

20 software is working, which sometimes it does, 

21 typically it does, then we ought to be able to 

22 hear your comment and your question here in the 
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1 room, if you raise your hand and our webmaster 

2 over there can insert you in the conversation. 

3 So, let's proceed. Ashley 

4 Armstrong. 

5 MS. ARMSTRONG: So, just to start 

6 off, as Doug mentioned, we have highlighted 

7 throughout the presentation a couple specific 

8 requests for comment that we are seeking your 

9 opinions on. Obviously, we welcome comment 

10 throughout. So, feel free to chime in, if you 

11 would like to speak to something different. 

12 The only other thing I want to 

13 highlight on this slide is that the deadline 

14 for submitting written comments is January 

15 7th, just after the holidays. 

16 So, I am going to do a couple brief 

17 -- a very brief overview of the history. So, 

18 as you know, this meeting is in regards to 

19 direct heating equipment and pool heaters. 

20 And this just talks about EPCA a little bit of 

21 our legal authority, which EPCA established 

22 the consumer product provisions and directs 
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1 DOE to revise the test procedures. The Energy 

2 Independence and Security Act of 2007 requires 

3 us to review them and incorporate the standby 

4 and off mode provisions. We have dealt with 

5 the standby and off mode provisions already, 

6 the existing test procedures are found in 

7 Appendix O for DHE and Appendix P for Pool 

8 Heaters. And today, we are doing a revision 

9 to the active mode for those procedures. 

10 This is just the steps in the 

11 rulemaking process. What happens is we have 

12 issued a Notice of Proposed Rulemaking. It 

13 goes out for a 75-day comment period. As I 

14 noted, that ends in early January. The next 

15 step would be DOE would take all the comments 

16 we receive, including those made today, into 

17 consideration and that will inform our 

18 decisions for the final rule, which we expect 

19 to issue sometime early in 2014. 

20 And I am going to pass it to Bill 

21 to give some descriptions of our exact 

22 proposals in the NOPR. 
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1 MR. HEALY: Thank you, Ashley. 

2 We are going to split this up. We are going 

3 to first deal with direct heating equipment. 

4 So we will go through all the proposed updates 

5 for direct heating equipment and then we will 

6 follow along with pool heaters. 

7 So, the first topic that we are 

8 going to discuss is direct heating equipment. 

9 There is four key things that we want to 

10 discuss that DOE is proposing to update in the 

11 direct heating equipment test procedure. We 

12 will discuss each one of these in a little bit 

13 more detail. 

14 First of all, we are going to add 

15 provisions for testing vented home heating 

16 equipment using condensing technologies. 

17 There are a number of references that were 

18 found that appeared to be outdated. So DOE is 

19 proposing to update all of those industry 

20 standards to more recent ones. 

21 There is a proposed change for 

22 floor furnaces to reduce the test burden by 
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1 allowing a default value for jacket loss in 

2 lieu of testing. And then finally, there are 

3 some clarifications and corrections that are 

4 proposed that appeared to be in existence in 

5 the current test procedure that DOE is 

6 proposing to clarify. 

7 So the first thing I wanted to 

8 discuss are the provisions for condensing 

9 technologies. DOE received quite a few 

10 comments to the RFI that a method was going to 

11 be needed that deals with DHE that utilizes 

12 condensing technologies because right now it 

13 is not present in the test procedure. 

14 So, what DOE is proposing to do is 

15 to use provisions similar to those that are 

16 used in their furnace and boiler test 

17 procedure. It would incorporate the method 

18 basically that is in ASHRAE 103-2007, which is 

19 the method of test for furnaces and boilers. 

20 And these would be stand-alone amendments in 

21 the DHE test procedure. 

22 So, to summarize this, a separate 
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1 test would be conducted for those units that 

2 utilize condensing technology. The 

3 condensate would be collected and measured. 

4 For those units that may not be 

5 designed to collect it, the condensate, DOE 

6 would require that those units be designed to 

7 actually have some way to collect it for the 

8 test method. 

9 Using that condensate, the latent 

10 heat loss term that is used in calculating the 

11 AFUE would be modified to incorporate the fact 

12 that there is condensate. So the latent heat 

13 term in the equation for AFUE or the efficiency 

14 would be modified to give some efficiency 

15 increase because of the use of condensate 

16 technology. And these provisions would apply 

17 to all types of DHE. 

18 Question? 

19 MR. BROOKMAN: Please say your 

20 name. 

21 MR. HORAK: Byron Horak from 

22 Intertek. 
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1 We are questioning the need that 

2 spells out a separate test for the collection 

3 of condensate. 

4 MR. BROOKMAN: Is your microphone 

5 on, Byron? 

6 MR. HORAK: Excuse me? 

7 MR. BROOKMAN: Is your microphone 

8 on? 

9 MR. HORAK: Yes, the green light 

10 is on. 

11 MR. BROOKMAN: Thank you. Sorry. 

12 Go ahead. 

13 MR. HORAK: On the cooling side of 

14 the business, condensate is collected all the 

15 time and it is collected during the efficiency 

16 test, the performance test. And the guys back 

17 in the lab said there is absolutely no reason 

18 why condensate on these products couldn't be 

19 collected at the exact same time that the 

20 efficiency test is being run, rather than 

21 having a separate test which extends testing 

22 time for everyone. 
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1 MR. HEALY: I'm not -- 

2 MS. ARMSTRONG: I am not 

3 following either. 

4 MR. HEALY: Yes. 

5 MR. BROOKMAN: Go ahead, Frank. 

6 MR. STANONIK: Frank Stanonik 

7 with AHRI. 

8 I guess I have got a similar 

9 question. The 3.8.1 specifically says begin 

10 a steady state condensate collection 

11 immediately after the steady state testing. 

12 But during the steady state testing, aren't 

13 you developing some condensate that should be 

14 collected? 

15 MS. ARMSTRONG: So your, I guess, 

16 suggestion is that we collect the condensate 

17 during the steady state AFUE test, rather than 

18 separately. 

19 MR. HORAK: Absolutely. 

20 MS. ARMSTRONG: Okay. 

21 MR. BROOKMAN: Concurrently, as 

22 it were. Okay. 
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1 MR. HORAK: Concurrent, yes. 

2 That's all. 

3 MR. BROOKMAN: Okay, excellent. 

4 Frank Stanonik. 

5 MR. STANONIK: Frank Stanonik, 

6 AHRI. Just a follow-up question. Since the 

7 initial proposal is this way, are you 

8 perceiving there is some difference there? 

9 MR. HEALY: We are trying to be 

10 very consistent with the furnace and boilers 

11 approach. So, that was really one of the 

12 approaches that we ended up taking, just to be 

13 very consistent with what is currently done on 

14 furnaces and boilers. 

15 MR. STANONIK: Oh, okay. Well 

16 furnace and boiler test procedure is changing, 

17 too. Right? Okay. 

18 MR. BROOKMAN: Additional 

19 questions here? Ken. 

20 MR. BELDING: Ken Belding of 

21 Empire Comfort Systems. 

22 MR. BROOKMAN: Microphone. 
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1 MR. BELDING: Ken Belding with 

2 Empire Comfort Systems. 

3 We have, for your consideration, 

4 some possible corrections on the equation for 

5 MS off in 4.3.3. We feel that it is possibly 

6 incorrect and that the 100 there should be a 

7 CT*. Also in MF off, same Section, 4.3.3, we 

8 feel that the 100 there should also be a CT*. 

9 The next item is: DS is undefined 

10 for systems 9 through 12 but is included in the 

11 AFUE calculation in section 4.1.17. And this 

12 was a source of difference between the Empire 

13 and Intertek results in the past. 

14 We now assume that DS is zero. 

15 And this is found in AFUE calculation for 

16 vented home heating equipment without stack 

17 dampers and optional method 3.3. And we feel 

18 that Table 1 system number 10 DS should be 

19 zero. 

20 Next item is for a power burner 

21 direct vent condensing heater. A DF, as in 

22 Frank, value is used unless the optional 
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1 tracer gas test is conducted. Like some gas 

2 furnaces and boilers, Empire's new condensing 

3 zone heater has no measurable off-cycle flow. 

4 This made conducting a tracer gas test 

5 difficult. So, the direct vent heaters 

6 should have the same option as described in 

7 ASHRAE 103 Section 9.10 for condensing 

8 furnaces and boilers. For units with no 

9 off-period flue losses, a DF value of 0.05 can 

10 be used, rather than running the tracer gas 

11 test. 

12 The language from ASHRAE 103 

13 Section 9.10 needs to be included in the 

14 revised Appendix O. 

15 Then lastly on condensing is we 

16 have a question on multiple control options 

17 ship from the manufacturer, specifically on 

18 condensing units, and should the efficiency be 

19 tested in which mode is the question. 

20 Again, specifically for a unit 

21 that has a manual mode and a thermostat step 

22 modulating mode ship from the manufacturer on 
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1 the same unit. We have a unit we are shipping 

2 that has both modes and we need clarification 

3 on what to test. 

4 MS. ARMSTRONG: Okay. 

5 MR. BELDING: Thank you. 

6 MR. BROOKMAN: Okay, thank you 

7 for those specific comments. Since you have 

8 got them all written out there, if you could 

9 just type them up and send them in. 

10 MR. BELDING: Yes, we will do 

11 that. 

12 MR. BROOKMAN: Okay. To the 

13 Department, that would be helpful. 

14 Can you answer his question now or 

15 did you need to think about it for a while? 

16 MR. HEALY: No. 

17 MS. ARMSTRONG: I don't think we 

18 are going to answer it now. 

19 MR. BROOKMAN: Okay, thanks for 

20 that. I am going to return to Bill. 

21 MR. HEALY: The next topic we want 

22 to discuss and there will be more time for 
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1 question on DHE after a couple of slides here, 

2 DOE is proposing to update the referenced 

3 industry test standards. There are a number 

4 of industry standards that are referenced that 

5 are no longer current. So, DOE is proposing 

6 to adopt six current industry standards to in 

7 some cases they are going to update the exact 

8 same standard with a more recent version. In 

9 one case there were separate references that 

10 have been brought together under a single 

11 umbrella. And it covers those other three 

12 standards. 

13 And then the incorporation of 

14 Standard 103 is proposed in lieu of three older 

15 standards. 

16 DOE did check these and believes 

17 that this is -- you know there is no 

18 inconsistencies and no changes in doing so. 

19 Finally, the last two -- 

20 MR. BROOKMAN: Frank Stanonik. 

21 MR. STANONIK: Frank Stanonik, 

22 AHRI. 
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1 I think in a number of cases we 

2 would prefer that you, for gas-fired equipment 

3 use, still reference gas-fired safety 

4 standards. And I think it may be just a 

5 question of looking at different sections of 

6 those standards as opposed to where -- I would 

7 say one might normally find how to set up the 

8 unit for tests in the case of floor furnaces 

9 and room heaters. It may be at different 

10 sections such as the wall, floor, and in the 

11 case of room heaters, ceiling temperature test 

12 or something. 

13 But we will submit some comments 

14 to either indicate where you could reference 

15 the current standard to specify a setup as 

16 necessary for room heaters and floor furnaces 

17 or perhaps just add the text. It just seems 

18 a little -- and I realize it is there already 

19 but it just seems odd to reference a oil-fired 

20 standard for how to set up a gas-fired unit for 

21 test. 

22 MR. BROOKMAN: Got you. Ken? 
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1 MR. BELDING: Ken Belding. To 

2 just piggyback Frank a little bit here, one of 

3 our comments was that specifically on room 

4 heaters, floor furnaces, there is really no 

5 information in the Z2186 2008 Standard about 

6 specifically where to take that exhaust -- 

7 flue exhaust temperature. It talks about 

8 where to place thermocouples on that to 

9 physically take the temperature but not how 

10 far away from the exit. I suppose you might 

11 know that we use the minimum wall thickness as 

12 defined, which is about five inches, round 

13 numbers. But obviously, the farther you get 

14 away from that exit, the greater the 

15 efficiency will be represented. So, there is 

16 no real clarification for that. That is kind 

17 of what we were looking for on that test. 

18 MR. BROOKMAN: Okay, thank you. 

19 MR. BELDING: Thank you. 

20 MR. BROOKMAN: Other comments 

21 here? Byron. 

22 MR. HORAK: Byron from Intertek. 
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1 Referencing the safety standards 

2 for the installation of these products adds an 

3 extra burden which is unnecessary for 

4 performance testing. The safety standards 

5 require you to set up various walls and floors 

6 and paint it all flat black and mount these 

7 products in these walls and floors. And that 

8 is very much needed for safety testing but for 

9 performance testing, it has absolutely no 

10 effect and is just an added extra burden to 

11 anyone testing these products and really isn't 

12 required for performance testing. 

13 MS. ARMSTRONG: Well, I am going 

14 to turn that around to the manufacturers to see 

15 what they think about removing or the option 

16 of removing the false floors and the walls. 

17 I mean that is how they are installed. 

18 So, are you onboard with -- for 

19 performance testing, would your suggestion be 

20 to remove all that as a requirement for their 

21 as-tested setup? 

22 MR. BROOKMAN: Frank. 
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1 MR. STANONIK: Frank Stanonik 

2 with AHRI. 

3 I think, Ashley, that is why I said 

4 one of our options, and we need to discuss it, 

5 obviously, internally more but we also are 

6 considering just actually recommending some 

7 actual text to address, as I say, the setup as 

8 needed. As Byron was saying, the full 

9 structure for a wall, floor, and ceiling test 

10 really isn't needed for an efficiency test 

11 procedure. But again, flipping it around, 

12 you take a floor furnace, the five we test, 

13 whatever, but you take it out of the box, you 

14 have got to set it up somehow and we agree. 

15 And so I think what we are planning to look at 

16 is okay, what is in those standards today and 

17 again, if needed, we will just give you some 

18 text to say -- 

19 MS. ARMSTRONG: Right. And what 

20 is in the standards today is to build the false 

21 walls, floors, et cetera, et cetera. 

22 MR. STANONIK: Right. 
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1 MS. ARMSTRONG: So, that is what 

2 should be done now. That is not to say that 

3 should be propagated if everyone feels that it 

4 doesn't impact the measures of efficiency and 

5 it can be changed or there is a better way to 

6 do it to reduce burden but that is what is there 

7 now. 

8 MR. STANONIK: Right. 

9 MR. BROOKMAN: Ken, do you have a 

10 comment on this? 

11 MR. BELDING: Ken Belding. 

12 I think that I will wait with 

13 Frank. I mean I think we know it is not a big 

14 controversial topic. We have to set up the 

15 walls anyway to do the safety testing, 

16 efficiency testing. We do it at basically the 

17 same time. 

18 But I probably need to consult 

19 with Frank about what the industry probably 

20 wants to do as a whole. 

21 MR. BROOKMAN: Okay, good. Thank 

22 you. Okay. 
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1 MR. HEALY: So the next topic is 

2 related to jacket loss. For the furnaces and 

3 boilers test procedure there is an option to, 

4 instead of doing a jacket loss test procedure 

5 to assign a default value of one percent. DOE 

6 is proposing in this NOPR to leave that as an 

7 option for direct heating for floor furnaces. 

8 So, instead of doing the testing for jacket 

9 loss, it can be assigned a value of one 

10 percent. 

11 And finally, clarifications and 

12 corrections. There were a number of places 

13 that were identified in the existing test 

14 procedure that were, for example, missing 

15 equations. So the first bullet point there, 

16 the Section 4.2.4, there was a missing 

17 equation. So, DOE is proposing to include an 

18 equation there for that. 

19 The tracer gas procedures in 

20 Section 3.3 are modified to clarify how it is 

21 supposed to be employed for units with thermal 

22 stack damper. 
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1 And there were some typographical 

2 errors that were identified in Section 4.3.6 

3 that are proposed to be corrected as well. 

4 MR. BROOKMAN: Frank Stanonik. 

5 MR. STANONIK: Frank Stanonik, 

6 AHRI. 

7 Speaking of typographical errors, 

8 and maybe it has already -- I am sure it has 

9 been identified. But in the Federal Register 

10 notice, that point 3 is floating out there on 

11 those equations for L . 

 C,SS

12 MR. HEALY: It should be in the 

13 denominator. 

14 MR. STANONIK: Yes. 

15 MR. HEALY: Okay. 

16 MR. STANONIK: Well, no. It is 

17 1053.3 but the point three isn't up like at the 

18 end of the calculation. 

19 MR. HEALY: Okay. 

20 MS. ARMSTRONG: I have it. 

21 MR. BROOKMAN: Okay. Additional 

22 comments here? 
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1 Here you see four issue boxes and 

2 some of which -- 

3 MS. ARMSTRONG: We have gone 

4 through most of them. 

5 MR. BOOKMAN: -- may have been 

6 addressed. Maybe just take a peek there. 

7 Look at them and see if there is any -- if they 

8 cause you to want to make any additional 

9 comments at this time. 

10 MR. STANONIK: Frank Stanonik, 

11 AHRI. 

12 One of the -- just maybe a 

13 confirmation, so the proposed testing for 

14 condensing vented heater, that test is just 

15 running full fire? 

16 MR. HEALY: No. It is in some of 

17 the detail. So, can John speak to that one? 

18 MR. TALBOTT: John Talbott. 

19 MR. BROOKMAN: John, use the 

20 microphone, please. 

21 MR. TALBOTT: Okay. When it gets 

22 to high fire and low fire and modulating 
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1 control, you have to do the condensate 

2 collection at both rates, just like it is in 

3 103. 

4 MR. STANONIK: Okay. All right. 

5 So, if that is the case, if you look at the 

6 equation under 4.1.6.2 for it looks like L 

 C,SS

7 (L sub css), the very last term in the 

8 numerator is T minus 45, where 45, I believe 

 F,SS

9 is the design temperature, outdoor 

10 temperature. 

11 MR. TALBOTT: Design temperature, 

12 that is correct. 

13 MR. STANONIK: Yes, 45 is the 

14 average outdoor temperature. 

15 MR. TALBOTT: Yes. 

16 MR. STANONIK: But in the case if 

17 this was a furnace boiler test procedure and 

18 you had a modulating equipment, doesn't that 

19 number reflect that your outdoor temperature 

20 at full fire might be different than your 

21 outdoor temperature at a lower firing rate? 

22 MR. TALBOTT: Right. 
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1 MR. STANONIK: So, it is a 

2 variable, right? 

3 MR. TALBOTT: Right, but in the 

4 furnace test procedure in 103, it is 

5 separately, the modulating controls in there 

6 are separately conducted condensate 

7 collection procedures. And then in these 

8 procedures, they get weighted by the R factor 

9 of the percent of heating load that is 

10 addressed in the high mode and percent 

11 addressed in the low load. And you average 

12 them together and that will be your average 

13 condensate collection. 

14 So, I mean there is probably some 

15 small affect there that could be addressed but 

16 it wasn't addressed in 103 as an effect. But 

17 it is just following 103 as best it can, until 

18 there is some exception that needs to be made. 

19 MR. BROOKMAN: Additional 

20 comments on items 1 through 4? And let me 

21 remind those of you on the web, if you wish to 

22 make comments, we have ought to be able to hear 
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1 you in the room. 

2 Okay. 

3 MR. HEALY: So, this concludes 

4 the discussion on direct heating equipment. 

5 Next, we will talk about the 

6 summary of proposed updates for pool heaters. 

7 There are two key ones. The first one is 

8 proposed expansion to cover electric pool 

9 heaters. Currently, they are not covered in 

10 the test procedure. And this would include 

11 both electric heat pump pool heaters and 

12 electric resistance heaters. 

13 And then we just were, DOE is 

14 proposing to clarify that the procedures are 

15 applicable to oil-fired pool heaters. There 

16 is no changes on that. But just to clarify 

17 that they are covered. 

18 So first of all with electric pool 

19 heaters, there is a proposal, as I mentioned, 

20 to expand that test procedure to cover these 

21 electric pool heaters. DOE is proposing to 

22 adopt amendments from ASHRAE Standard 1160, 
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1 "Performance Rating of Heat Pump Pool Heaters" 

2 as well as -- I'm sorry AHRI 1160, as well as 

3 ASHRAE Standard 146, "Method of Testing and 

4 Rating Pool Heaters." 

5 The proposed amendments for 

6 electric resistance type of pool heaters would 

7 be specifically from ASHRAE Standard 146. 

8 There would be additional calculations for 

9 integrated thermal efficiency expressed in 

10 terms of percent for all pool heaters. And 

11 this is consistent with the current test 

12 procedure that includes standby power. 

13 And then there is a method to 

14 determine the COP for heat pump pool heaters 

15 and then convert that to a thermal efficiency 

16 as well. 

17 So, we would seek comment from you 

18 whether the proposal for these electric units 

19 is appropriate and sufficient. And then any 

20 impact on small businesses. 

21 MR. BROOKMAN: Any comments here? 

22 No comments here. Okay. 
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1 Let me say hello. You have just 

2 made it into the room. We are going through 

3 the content in this packet very rapidly here. 

4 And I want to specifically invite you to ask 

5 questions, make comments, get caught up in any 

6 way that is going to make you comfortable, 

7 since you are one of the manufacturers. So, 

8 just weigh in however suits you best. 

9 Okay, we are moving on. We are 

10 done, in fact. 

11 Frank Stanonik. 

12 MR. STANONIK: I notice that you 

13 have a -- Frank Stanonik, AHRI -- I notice you 

14 have a section reserved for hybrid pool 

15 heaters. What are you envisioning as a hybrid 

16 pool heater? 

17 MR. HEALY: We are not aware of 

18 any on the market right now but something like 

19 a heat pump pool heater with a gas burner. 

20 MR. STANONIK: Okay. 

21 MR. BROOKMAN: I want to -- go 

22 ahead Frank. 
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1 MR. STANONIK: Just in certain 

2 other product classes, hybrid is being used to 

3 describe a heat pump. Okay, maybe it needs a 

4 different name. 

5 MR. HEALY: Okay. 

6 MS. ARMSTRONG: Feel free to 

7 suggest one. 

8 MR. STANONIK: Okay. 

9 MR. BROOKMAN: So I think we are 

10 now finished with the content. 

11 MS. ARMSTRONG: We are. 

12 MR. BROOKMAN: And I invite 

13 anybody that wishes to make closing remarks. 

14 Any additional issues that, in particular 

15 since you joined us, if there is anything you 

16 wish to say to add to the record at this point. 

17 Additional issues that haven't been covered 

18 sufficiently, closing remarks? Frank. 

19 MR. STANONIK: Frank Stanonik, 

20 AHRI. 

21 Really more follow-on questions 

22 and two separate ones. So, if the test 
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1 procedure is planned to be finalized in early 

2 2014, there is certainly a strong suggestion 

3 that as far as heat pump pool heaters then the 

4 next step would be establishment of efficiency 

5 requirements for heat pump pool heaters. So, 

6 the question is does DOE have a schedule -- a 

7 rulemaking on the schedule for that? 

8 And then the second question, 

9 different subject, is it is also very clear in 

10 this NOPR that DOE is going to develop test 

11 procedures for vented, I will call them fire 

12 place heaters in a separate rulemaking. What 

13 is the schedule for that rulemaking? 

14 MR. BROOKMAN: Ashley Armstrong. 

15 MS. ARMSTRONG: Loaded questions, 

16 Frank, so early in the morning. 

17 I will do the easier one first. 

18 Pool heaters. So, I think at this point DOE 

19 is required to review its standards rules 

20 every so many years. So that is six years. 

21 Correct? So, we finished the previous rule in 

22 2010. So, we would have to review it in that 
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1 time frame. At that time, during that review, 

2 we would investigate whether efficiency 

3 standards meet the criteria or we would make 

4 a decision at that point about whether we 

5 should do efficiency standards for heat pump 

6 pool heaters. 

7 Just because there is a test 

8 procedure, doesn't mean we have to. So, that 

9 is the answer for that one. 

10 I don't know the answer to the 

11 other one, as far as vented home heating 

12 equipment and the schedule for a separate 

13 rule. But I don't have a definitive time 

14 table for that one, other than it will be 

15 separate and there will be separate notices on 

16 that one, coming for it. 

17 MR. STANONIK: Frank Stanonik, 

18 AHRI. 

19 This is certainly, at the moment, 

20 a theoretical question. But if the comments 

21 to this NOPR did include some suggestions on 

22 how to test a fireplace heater, I am assuming 
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1 DOE would be receptive to that? 

2 MS. ARMSTRONG: Absolutely. 

3 MR. BROOKMAN: Byron. 

4 MR. HORAK: Byron Horak, 

5 Intertek. 

6 Were we going to discuss oil-fired 

7 pool heaters under this meeting or is that a 

8 separate topic? 

9 MS. ARMSTRONG: It is under this 

10 one. You know, preliminarily, we made a 

11 determination the existing test procedures 

12 for gas-fired is applicable to oil-fired as 

13 written and we just clarified that. 

14 To the extent that you have 

15 comments about that, we welcome them. 

16 MR. HORAK: Okay, good. 

17 MR. BROOKMAN: Additional 

18 comments, as we move towards closure here? 

19 Okay, well, I see nothing 

20 additional. I thank you all for coming this 

21 morning. Very productive. Very crisp 

22 little meeting. Back to Ashley for review of 
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1 the send-in materials. 

2 MS. ARMSTRONG: So, I just want to 

3 thank everyone for coming. I know this was a 

4 short meeting. As you go through the proposed 

5 rule, if you have any more questions, 

6 obviously, we welcome your comments, 

7 clarifications, edits. You know, at any 

8 point in time, this is just a quick summary 

9 about how to submit comments and when the close 

10 of the comment period is, which is January 7th, 

11 just to remind you once again. 

12 And thank you for participating. 

13 MR. BROOKMAN: Thank you. Safe 

14 travels. 

15 (Whereupon, at 9:36 a.m., the 

16 foregoing meeting was concluded.) 

17

18

19

20

21

22
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gas 18:1,1,4,10

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6:15,16 7:1

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ought 8:21 30:22

outdated 11:18

outdoor 29:9,14,19

29:21

oversee 4:14

overview 3:7 4:20

9:17

P

P 10:7

P-R-O-C-E-E-D-...

4:1

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packet 7:8,10,11

33:3

page 3:2 7:10,10

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particular 34:14

pass 10:20

Patio 2:3 5:19

peek 28:6

perceiving 16:8

percent 26:5,10

30:9,10 32:10

performance 14:16

23:4,9,12,19 32:1

period 10:13 38:10

phones 7:21

physically 22:9

piggyback 22:2

place 22:8 35:12

places 26:12

planned 35:1

planning 24:15

please 5:8 6:8 7:16

7:17,20 8:18

13:19 28:20

point 26:15 27:10

27:17 34:16 35:18

36:4 38:8

pool 1:4 4:6 9:19

10:7 11:6 31:6,8

31:11,15,18,21

32:1,4,6,10,14

33:14,16,19 35:3

35:5,18 36:6 37:7

possible 5:2 17:4

possibly 17:5

power 17:20 32:12

prefer 21:2

preliminarily 37:10

present 2:1,11

12:13

presentation 4:19

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previous 35:21

probably 25:18,19

30:14

procedure 1:4 4:5

11:11 12:5,13,17

12:21 16:16 24:11

26:3,4,14 29:17

30:4 31:10,20

32:12 35:1 36:8

procedures 4:15,21

10:1,6,9 26:19

30:7,8 31:14

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process 10:11

product 9:22 34:2

productive 37:21

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proposal 16:7

31:19 32:18

proposals 10:22

proposed 4:20

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28:13 31:6,8 32:5

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Q

question 8:22 13:18

15:9 16:6 18:16

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33:5 34:21 35:15

38:5

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quick 38:8

quite 12:9

R

R 30:8

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24:6

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reduce 11:22 25:6

reference 21:3,14

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referenced 20:2,4

references 11:17

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Referencing 23:1

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Refrigeration 2:8

regards 9:18

Register 27:9

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remarks 3:3,10

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remind 30:21 38:11

remove 23:20

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requirements 35:5

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review 10:3 35:19

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revision 10:8

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right 12:12 16:17

24:19,22 25:8

29:4,22 30:2,3

33:18

room 1:11 9:1 21:9
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Neal R. Gross and Co., Inc.

Page 43

21:11,16 22:3

31:1 33:2

Rosalyn 2:4 5:22

round 22:12

rule 4:20 10:18

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running 18:10

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short 4:19 7:8 38:4

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sidebar 7:22

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software 8:20

Solutions 4:9

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Speaking 27:7

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specifically 7:12

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28:18,18,21 29:11

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thank 5:5 11:1

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22:18,19 25:21

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thanks 4:18 7:6

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theoretical 36:20

thermal 26:21 32:9

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thermocouples

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thickness 22:11

thing 9:12 12:7

things 11:9

think 8:11 19:15,17

21:1,4 23:15 24:3

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Neal R. Gross and Co., Inc.

Page 44

V

value 12:1 17:22

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Victor 2:5 6:22 W

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weigh 33:8

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welcome 4:4,17,22

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welcoming 3:3 4:12

William 2:14 3:9

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years 35:20,20 Z

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2010 35:22

2013 1:9 4:7

2014 10:19 35:2 3 3 27:10

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4 1:9 3:4 4:7 30:20

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4.1.6.2 29:6

4.2.4 26:16

4.3.3 17:5,7

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567

75-day 10:13

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8E-089 1:11 9 9 3:6 17:10

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9:00 1:12

9:03 4:2

9:36 38:15
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

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

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

45

Test Procedures for Direct

Heating Equipment and Pool Heaters

US DOE

12-04-13

Washington, DC