ABMA 

American Boiler Manufacturers Association 

8221 Old Courthouse Rd, Suite 202, Vienna, Virginia 22182 

703-356-7172 • fax 703-356-4543 • homepage: http://www.abma.com 

SUBJECT: Response to DOE Request for Comment on the Publication "Energy Conservation Standards 

Rulemaking Framework Document for Commercial Packaged Boilers" -- Docket No. EERE-2013-BT-STD0030-RtN: 1904-ADOl 

The following comments are submitted on behalf of the American Boiler Manufacturers 

Association (ABMA) by its Director of Technical Affairs, Geoffrey M. Halley. 

As the oldest national manufacturing trade association in America, the American Boiler 

Manufacturers Association is composed of over 100 small-business manufacturer and supplier 

members in 24 states across America involved in the design and fabrication of >400,000 Btuh 

(heat input) commercial, institutional, industrial, heat recovery, and electricity-generating boilers 

and combustion equipment. ABMA was founded in 1888 by boiler manufacturers of day to 

begin to craft legal and regulatory infrastructures that would insure of materials integrity and 

commitment to safety in design and fabrication of all boilers. ABMA today strongly abides by 

those founding principles and seeks to ensure that a commitment to safety is an ongoing and 

over-riding consideration of any contemplated code, standard or regulatory scheme. You will 

see this concern reflected in these comments. 

Comments on the Framework Document: 

Item 2-1 

As this rule primarily deals with Space Heating Boilers, the question has arisen as to whether 

Low Pressure Steam Boilers used purely in an Industrial Process are included in this rule. 

In our opinion, it is not necessary to include electric commercial packaged boilers in this 

rulemaking. 

The main concern with standby mode and off mode energy conservation standards is one of 

safety and which takes priority. Safety or Energy Conservation. 

Some standards require 100% shutoff of the stack on a down cycle. This has the potential to 

increase the likelihood of a combustion explosion should gas valves start leaking. This could be 

particularly severe on natural draft fired boilers, in which the open sides will allow the gas to 

October 17,2013 

Item 2-2 

Item 2-3 

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representing the best of the boiler industry! 
enter the space around the boiler, whereas with an open stack the gas would normally vent to 

atmosphere. Consideration should be given to an 80 to 90% shutoff instead. 

For forced draft fired boilers the use of 100% shutoff at the combustion air intake damper will 

provide a safer approach than a stack damper. 

Item 2.4 

ABMA has had concern for some time regarding the BTS-2000 Test Procedure and its 

applicability to boilers produced by our membership. The fact that the BTS-2000 Test Procedure 

appears to be founded in the residential/small commercial boiler marketplace of the mid 1900's 

is in all probability the reason for the 2 psig test pressure on steam boilers. Similarly the fact that 

existing so-called independent test facilities are limited to small boilers is attributable to this area 

of the market. This is, however, where the high unit count is. 

In our opinion the BTS-2000 Test Procedure allows an efficiency comparison between different 

manufacturer's boilers of equivalent size, however it does not provide the end user with a 

realistic efficiency that can be expected in a field installation. This is due to the fact that the 2 

psig test pressure specified for steam boilers and the water temperatures for hot water boilers will 

yield a higher efficiency on test than can be expected in the field. 

ABMA member concerns are: 

• The cost of testing their (larger) boilers is going to be considerably more expensive than 

the cost of testing the small commercial packaged boilers. The largest boilers built by 

some of our members could approach $1 million to test, given the specialized nature of 

the test rig. This contrasts with the $2000 to $3500 cost referenced for small boilers 

currently being tested under the existing DOE program. 

• The 0-2 psig test pressure required by BTS-2000 is unrealistic for larger steam boilers, as 

it causes high steam velocity at the steam/water interface and the steam outlet nozzle, and 

hence excessive water entrainment and carryover (poor steam quality). 

• The water inlet, or return, temperatures required by BTS-2000 would find certain parts of 

the boiler pressure vessel structure operating in the realm of High Strain Fatigue, hence 

shortening the life of the boiler. The longer the boiler the bigger the problem. 

• As all boilers manufactured by the ABMA membership are Built to Order for a specific 

job, coordination of production schedules, DOE or Independent Laboratory test schedules 

and jobsite installation schedules would become extremely difficult, and impossible in 

the event of short lead times. 

• All boilers built by ABMA member companies have pressure vessel/heat exchangers 

designed and assembled to the ASME Boiler & Pressure Vessel Code in accordance with 

a documented Quality Assurance System approved by the ASME, the National Board of 

Boiler and Pressure Vessel Inspectors and inspected at specified hold points by an 

independent Authorized Inspection Agency. Combustion equipment, safety controls, etc. 

are subjected to compliance examination and testing by an Independent Testing Agency, 

such as UL, at the completion of the product development phase. Test units are selected 

to be representative of the entire product line and include a combustion efficiency test. 

The Independent Testing Agency then develops a Build, or Assembly, Manual for the 

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product line, which must be followed if the product is to bear the testing agency mark or 

label. Periodic in-plant inspections of the manufacturing process are performed by 

Testing Agency Inspectors to ensure compliance with the Assembly Manual. Given the 

high degree of control in the manufacturing process, it is the position of ABMA that 

repeat testing of products that are unchanged is not justified. 

• The high degree of product control on these larger boilers continues into the field, where 

the product is typically sold to a Mechanical Contractor, rather than a Distributer, the 

installation being performed by that same contractor, rather than a plumber which can be 

the case with small units. The completed installation is then inspected by a National 

Board of Boiler Inspectors (NBBI) commissioned inspector for Codes Compliance. The 

boiler is then commissioned by Manufacturer's Authorized Startup Technician. Follow 

up inspections, by an NBBI commissioned boiler inspector, are performed on an annual 

or bi-aimual basis depending on State Boiler Laws, in order verify structural integrity, 

proper functioning of controls and cleanliness of heat transfer surfaces (for continued 

efficient operation). This may not be true in the case of small boilers, depending upon 

State Law. 

Having said this, the only test facilities capable of handling the large boilers exist in the 

manufacturers plants. Similarly, the real expertise in setting up, and testing, these large boilers 

lies with the manufacturers, not the independent testing labs. 

On the basis of the above, ABMA believes that the efficiency requirements for large boilers 

being uncapped, is problematic. A possible cap, based upon existing product line splits, could be 

2.5 million Btu/hr. input. Note also that test capability for hot water boilers does not exist in all 

manufacturers facilities, due to heat sink requirements for the hot water generated. 

Item 3-1 

ABMA has always believed that ASME PTC-4.1 is a more appropriate test standard for boilers 

produced by our membership, as explained in 2.4 above. 

Item 3-2 

ABMA has the following comments regarding the current DOE BTS-2000 Test Procedure: 

• The test pressures and temperatures specified should be more realistic in terms of normal 

system operating conditions. Suggested steam pressure would be 10 to 12 psig. Suggested 

water inlet or return temperature would be 140" F, or manufacturers recommended 

minimum. 

• References to instrumentation containing Mercury should be deleted, given that it is 

considered a bad actor in Today's World. 

• The instrumentation listing seems dated by current standards. Examples are the use of 

scales and Orsat apparatus. The graduations/accuracy defined for the CO instrument 

seems out of line with the current requirement of 400 ppm. Similarly it seems that the use 

of CO2 rather than O2 as the basis of exhaust gas analysis is out of line with current 

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practice. CO2 analyzers demand the use of span gas for calibration, whereas O2 analyzers 

only need an air sample for calibration. 

• If it can be shown, to DOE's satisfaction, that the combustion efficiency read directly 

from a good quality, properly calibrated combustion analyzer, is no different to the 

combustion efficiency produced from the somewhat laborious calculations outlined in 

BTS-2000, would this be accepted as an alternate to the calculation method? It would 

simplify testing considerably. 

• We have heard several comments to the effect that it is difficult to obtain consistently 

reliable thermal efficiencies of steam boilers, due to variations or shifts in the calibration 

of water flowmeters. This may not be the entire culprit as we have seen the cyclic on-off 

effect of water feeders affect water flow readings. When feedwater is injected into the 

two phase mixture of steam bubbles and water in a batch process, the steam bubbles 

collapse for a period of time causing the boiler pressure to drop, which in turn causes the 

moisture content of the steam generated to increase as steam space velocities increase, 

and the feedwater to overfeed. This cycle keeps repeating. It is generally accepted that a 

modulating feedwater controller is a better choice than an on-off water feeder, however it 

is not perfect. On this basis, we believe that the heat-loss method of determining steam 

boiler thermal efficiency, with the radiation losses calculated from boiler jacket surface 

temperatures, is going to yield more consistent results. 

• The BTS-2000 requirement, when testing steam boilers, to return the water level at the 

end of the test to its original level plus or minus inch could introduce variability in test 

results of varying magnitude depending upon the surface area of the steam to water 

interface. This again points to the heat loss method of calculating efficiency being likely 

to produce more accurate and consistent results. 

Item 3-3 

See comments under 2-4 above, concerning comparative efficiency, versus operating efficiency. 

Item 3-4 

Clearly the existing BTS-2000 Test Procedure is unsuitable for testing larger boilers, therefore 

there appears to be three possibilities to resolve this problem: 

• Update the existing BTS 2000 Procedure by adding more realistic test conditions for 

large boilers. 

• Allow the use of ASME PTC-4 (or 4.1) heat loss method for testing large boilers. 

• Produce a new test procedure which could be based on a simplified version of ASME 

PTC-4 Heat Loss Method. 

Figures 8.1,8.2 and 8.4 

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The wholesaler is not a part of the distribution chain for large boilers. 

As a closing comment we believe that proper maintenance of the entire system is the most 

important part of continuing energy efficient operation, and we enclose Attachment A as a 

thoughtful commentary on this topic. 

To elucidate the foregoing comments and to provide the perspective of a small-business 

manufacturer of the types of boilers addressed by the Framework Document, ABMA is 

submitting along with these comments by Mr. Halley, comments provided by Mr. Jack 

Coe, President, Rite Engineering & Manufacturing Corporation, 5832 Garfield Avenue, 

Commerce, California 90040,562/862-2135, iackc@riteboiier.com. DOE should feel free to 

contact Messrs. Halley and Coe for further information and clarity of our comments. 

Respectfully submitted, 

Q&offrey M. HaUey, PE 

Geoffrey M. Halley, PE 

Director, Technical Affairs 

American Boiler Manufacturers Association 

Direct Telephone: 1-636-394-3483 

Direct Email: ghalleysji@aol.com 

10.17.13 

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Rand y Rawso n 

Sent 

To: 

Cc: 

Subject: 

From: Jack Coe <jackc@riteboiler.com> 

Monday, September 16, 2013 10:37 PM 

'Geoffrey Halley' 

Randy Rawson; 'Peggy Light' 

FW: DOE Energy Conservation Standards Rulemaking Framework Document for 

Commercial Package Boilers 

Follow Up Flag: 

Flag Status: 

Follow up 

Flagged 

Hi Geoff, 

After reading the 74 page DOE paper that seeks input to set minimum energy efficiency levels in commercial boilers 

into law, I find that while it may seem well intentioned, it is based on several flaws and omissions and should be 

overhauled. To begin with, there are many factors far beyond a boilers "brand new, out of the box" efficiency that will 

determine how much energy it will consume for the service it was intended - including service calls, repairs and 

frequency of boiler replacement. Energy is energy, whether it's natural gas, gasoline, diesel or electrical. The DOE paper 

touches on this point, but its main focus seems to be the impending adoption of ASHRAE 90.1 into law. The ASHRAE 

90.1 table would just so happen to eliminate a number of boiler lines from the market including the atmospheric boilers 

that 1 make if it were adopted into law. The DOE should understand that the ASHRAE 90.1 standards didn't come out of 

a vacuum. Many manufacturers would benefit from the elimination of low cost boilers, and through their trade 

organizations they have managed to help establish these "standards". There is no question that energy is a big concern 

in this country and if the DOE can do things that sensibly save energy, more power to them. But boilers are not like 

cars. They don't guarantee roughly the same 'mileage' year after year. The problem with DOE using the ASHRAE 90.1 

model is that it has one huge fundamental flaw: it ignores efficiency over time. 

Boilers do not operate in a vacuum. Boilers don't operate in laboratory conditions where water quality is monitored 

24/7. What is the reason most boilers are replaced? It's because they scale up with mud and lime. And this doesn't 

happen overnight. It can take years - years of diminishing efficiency until the heat exchanger surfaces eventually 

overheat and fail. ASHRAE would have you believe that boilers with a higher baseline efficiency will still use less energy 

than boilers with a lower baseline efficiency if they had equal amounts of scale inside, and therefore the higher 

efficiency boiler is still justified. But is that really true? 

Take refrigerators. Refrigerator "A" is an irresistible 2014 gold star state of the art energy efficient appliance that 

comes with a big fat rebate. Refrigerator "B" is a standard run of the mill fridge that's been around for years and comes 

in avocado green. Operate them side by side in a clean room environment and "A" will use less energy than "B". That's 

the ASHRAE approach and pat on the lab coats all around. Now put these same refrigerators into the average American 

kitchen where pet hair, lint and dust are pulled into the coils every time the fan and compressor come on. Unless the 

coils are routinely cleaned, the efficiency of both refrigerators will start to drop. Now let's suppose the coils of 

refrigerator "A" are for one reason or another next to impossible to access and the coils in "B" are easy to get to and 

clean. If that's the case, then lowly refrigerator "B" is actually likely to be more efficient and use less energy than 

refrigerator "A". 

How does this relate to boilers? Heat exchanger surfaces in boilers get fouled just like refrigerator coils. The only 

difference is the fouling medium but the effect is the same: More energy required to do the same amount of work 

because less heat transfer is taking place. You would think that all boilers - with an average lifespan of 30 years by 

DOE's estimate - would have heating surfaces that would, could and should be easily accessed for cleaning. But look at 

three of the most popular designs in service today - fire-tube, cast iron and bent tube boilers - and you will see this is 

not the case. They are like refrigerator "A" - beautifully efficient to start with, woefully unequipped to maintain it when 

the honeymoon's over. Access to the waterside heating surfaces in these boilers is so limited that they are next to 

impossible to clean. The companies that make them know this which is why they'd like ASHRAE and the DOE to focus on 

brand new efficiency, and not something truly meaningful like maintainable efficiency. A boilers ability - or inability - to 

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clean its heat exchanger cannot and must not be left out of any serious discussion involving commercial boiler 

efficiency. 

There are several other factors that affect efficiency too. Water mass is one. The more water in the boiler, the more 

fuel required to heat it. A high mass boiler running 24/7 is one thing. A high mass steam boiler for an intermittent 

operation would be a poor choice because it would take more fuel to burn the extra water until it boiled. And yet 

consumers could be forced into buying the high mass boiler if the DOE proposal goes through. 

Electrical energy is another. What many so-called high efficiency boilers do today is rob Peter to pay 

Paul. Condensing boilers are a good example. Everyone knows they require more pump horsepower than a 

conventional boiler like mine. What fewer people know is they also require higher fan energy in the air handler to 

overcome the air pressure drop across the hot water coils that require more fins per inch than standard coils. Saving 

fuel by using more electricity does not save energy - the bill just comes in a different envelope. 

Draft, boiler cycling, air-fuel ratios, are just some of the other variables that will change a boilers short term and 

long term efficiency. And the higher the efficiency, usually the more critical the problem if something goes wrong. We 

have Representatives who will not sell power burner fired equipment in certain areas of the country because the 

maintenance people in those areas cannot work on them. You cannot leave out the human factor when it comes to 

efficiency either. Finding top notch boiler techs in the big cities is challenging enough. They almost don't exist out in the 

country. 

Suffice it to say that testing and certifying commercial boilers to the Hydronics Institute BTS 2000 test protocol will 

cost some manufacturers a small fortune. On top of that, verifying thermal efficiency requires a calculation of 4 test 

points such that a ]4% error at each point could throw the efficiency calculation off by 2% or more. A more sensible 

approach would be this: Require manufacturers to update their current efficiency information. Require a sticker on the 

boiler and a note in the owner's manual that basically gives a point of contact to the DOE (or some other agency) to the 

effect that the consumer can register a complaint if he or she feels the efficiency is not what was represented by the 

manufacturer. This would tend to make boiler manufacturers more honest with their ratings and the DOE would have 

the data at hand to question those who don't. 

With over 35 years in the boiler industry and ten or so years as president of Rite, I can guarantee you that boiler 

efficiency is one of the most important considerations people make when choosing a boiler and has been for a long 

time. This is why manufacturers such as Rite are constantly working to improve our product and promoting energy 

saving equipment such as automatic stack dampers on our atmospheric boilers. If I don't offer products that provide 

good overall value - including overall efficiency for the life of my product - then people will stop buying my boilers. They 

haven't, which tells me we are still doing something right after 60 years in business. 

It is bad enough that lobbyists and trade associations like LEEDS have managed to get utilities and other public 

agencies to subsidize condensing boilers. This has misled many consulting engineers and owners into believing huge 

savings were coming their way when in fact they didn't. Most condensing boilers don't condense, aren't waterside 

accessible, and have a considerably shorter service life than most conventional boilers. Different boilers have their 

advantages and disadvantages depending on the application. Through experience, research and word of mouth, most 

people will find their way to the right boiler. Government involvement like this will only drive boiler prices up and not 

accomplish its goal. If the DOE'S true objective is to save energy in the commercial boiler market, it might start by asking 

ASME CSD-1 to adapt European tested valve proving gas trains in lieu of pre and post purge cycles, and to discourage 

normally open gas valves. That would save a lot of natural gas and the impact on boiler manufacturers and consumers 

alike would be negligible. 

Well those are my thoughts on the subject, expressed a little hazily at 7:30 PM. I'm going home now! 

Best Regards, 

Jack Coe 

President 

Rite ENGINEERING & MANUFACTURING CORPORATION 

5832 Garfield Ave, Commerce California 90040 

Phone (562) 862-2135 • Fax (562) 861-9821 • www.riteboiler.com 

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