January 21,2013 Dr. David T. Danielson Assistant Secretary, Energy Efficiency 

### & Renewable Energy U

.S

. Department of Energy Mail Station EE-1 1000 Independence Avenue, SW Washington, DC 20585 David

.Danielson@ee

.doe

.gov
Via e-mail (David

.Danielson@ee.doe

.gov) and overnight mail
Re: Petition for Waiver and Application for Interim Waiver concerning the measurement of water and energy used in the water softening regeneration process of Dishwasher having an Integrated Water Softener Dear Assistant Secretary Danielson: BSH Home Appliance Corporation ("BSH") hereby submits this Petition for Waiver and Application for Interim Waiver pursuant to 10 CFR 430

.27, concerning the test procedure for measuring energy consumption of Dishwashers. BSH is the manufacturer of household appliances bearing the brand names of Bosch, Thermador, and Gaggenau. Its appliances include dishwashers, washing machines, clothes dryers , refrigerator-freezers, ovens, and microwave ovens, and are sold worldwide, including in the United States. BSH's United States operations are headquartered in Irvine, California

.
10 CFR 430.27(a)(1) provides that any interested person may submit a petition to waive for a particular basic model any requirement of Section 430.23 , or of any appendix to this subpart, upon grounds that the basic model contains one or more design characteristics which either prevent testing of the basic model according to the prescribed test procedures, or the prescribed test procedures may evaluate the basic model in a manner so unrepresentative of its true energy consumption characteristics , or water consumption characteristics as to provide materially inaccurate comparative data. Additionally, 10 CFR 430.27 (b)(2) allows any applicant of a Petition of Waiver to also request an Interim Waiver if it can be demonstrated the likely success of the Petition for Waiver, while addressing the economic hardship and/or competitive disadvantage that is likely to result absent a favorable determination on the Application for Interim Waiver.This request for Waiver is directed to Dishwashers containing a built-in or integrated water softener, specifically addressing the energy and water used in the regeneration process of the integrated water softener. This request is similar to several previously approved waivers (such as Waiver Case Number DW-005)

. Further, the water softening technology used in these models is identical to the models that were previously approved. Based on the reasoning indicated herein, BSH submits that the testing of Dishwashers equipped with a water softener under the current DOE test procedure may lead to information that could be considered misleading to consumers.
1

. Identification ofBasic Models

. The Dishwasher models manufactured by BSH which contain an integrated water softener and were not included in previous Waiver applications is as follows : Bosch brand: • Basic Model
- SHE43T5### • Basic Model
- SHX43T5### • Basic Model
- SHE33T5### Kenmore brand : • Basic Model
- S38KML4### • Basic Model
- S48KML2### • Basic Model
- S48KML3### • Basic Model
- S38KML5### • Basic Model
- S37KMK2### Gaggenau brand: • Basic Model- DF261761 • Basic Model
- DF260761 2. Background The design characteristic that is unique among the above listed models is an integrated water softener. The primary function of a water softener is to reduce the high mineral content of "hard" water. Hard water reduces the effectiveness of detergents leading to additional detergent usage
. Hard water also causes increased water spots on dishware, resulting in the need to use more rinse aid to counterbalance this effect. "Hard " water can reduce customer satisfaction with Dishwasher performance resulting in increased pre-rinsing and/or hand washing as well as increased detergent and rinse agent usage
. The water softening process requires water usage for both the regeneration process and to flush the system. For purposes of this Waiverrequest, the term "regeneration " will include the water and energy used in both the flushing and regeneration process of the water softener. The water used in the regeneration process is in addition to the water used in the dish washing process. The water used in the r egeneration process does not occur with each use of the Dishwasher. The frequency of the regeneration process is dependent upon an adjustable water softener setting that is controlled by th e end user, and based on the home water hardness. Regeneration frequency will vary greatly depending upon the customer setting of the water softener. Data from the U.S. Geological Survey shows considerable variation in the water hardness within the U

.S. and for many locations the use of a water softener is not necessary
. Water hardness varies throughout the U.S. with the mean hardness of 217 mg/liter or 12.6 grains/gallon (based on information provided by the U.S. Geological Survey located at http://water.usgs

.gov/owg/hardness
alkalinity

.html). 

### Calculations 

### Water Use • Based on the DOE Energy Test for Dishwashers , the BSH Dishwashers listed in this waiver with an internal water softener use an average of approximately 9 liters of water per dish cleaning cycle. • Based on an average U.S. water hardness of 12.6 grains/gallon, the internal BSH Dishwasher water softener system would be set on "3". • Based on a BSH Dishwasher internal water softening system setting of "3" and the dishwasher using 9 liters of water per run, the water regeneration process would occur every 6th cycle. • When using the Dishwasher 215 times per year (per DOE test procedure) , the regeneration process would occur 35.8 times (36). • The internal BSH water softening system uses approximately 5.0 per regeneration cycle. • Water usage calculation based on above data. o 36 x 5 = 180 liters per year (47.6 gallons) or .84 liters (.22 gallons) each time the dishwasher is used

. 

### Energy Used in 

### kWh • Formula W= V x T x K o V = Weighted Average Water Usage per DOE o T = Nominal water heater temperature rise of 39° C o K = Specific heat ofwater 0.00115 • Calculated Energy use - 180 x 39 x .00115 = 8

.0 kWh/yr

### Summary

• A Dishwasher built by BSH with an integrated water softener in a home with a 12.6 grain per gallon water hardness would be cycled through the water softening regeneration process approximately every 6 dish cleaning cycles

. When the water used in the water softener regeneration process is apportioned evenly over all dishwasher runs , the amount of energy and water usage per cycle is very low

. Based on the assumptions provided, BSH estimates the typical water used in the internal Dishwasher water softener regeneration process at .84 liters (.22 gallons) per use ; furthermore , using about 8.0 kWh per year to heat this water in the home hot water heater

. 3

. Requirements sought to be waived Dishwashers are subjected to test methods outlined in 10 CFR Part 430, Subpart B, App

. C, Section 4

.3, which specifies the method for the water energy calculation

. • BSH is requesting approval to estimate the water and energy used in the water softening process based on the design of the BSH Dishwasher and the calculations and assumptions outlined above.

4

. Grounds for Waiverand Int er im W aiver 10 CFR 430 .27 (a) (1) provides that a Petition to waive a requirement of 430.23 may be submitted upon grounds that the basic model contains one or more design characteristics which either prevent testing of the basic model according to the prescribed test procedures , or the prescribed test procedures may evaluate the basic model in a manner so unrepresentative of its true energy consumption characteristics as to provide materially inaccurate comparative data. If a water softener regeneration process was to occur while running an energy test, the water usage would be overstated. In this case, the water energy usage would be unrepresentative of the product providing inaccurate data resulting in a competitive disadvantage to BSH. Granting of an Interim Waiver in this case is justified since the prescribed test procedures would potentially evaluate the basic model in a manner so unrepresentative of its true energy consumption characteristics as to provide materially inaccurate comparative data. In addition, a similar Interim Waiver and Waiver have previously been granted to BSH.

### 5

. M anufacturer s ofSimilar Products andAffected Manufactur ers Web based research shows that at least two other manufacturers are currently selling dishwashers with an integrated water softener, Miele Inc. and Whirlpool Corporation (Waiver Granted). Manufacturers selling dishwashers in the United States include AGA Marvel , Arcelik A.S ., ASKO Appliances , Inc., Electrolux North America , Inc., Fagor America , Inc., Fisher & Paykel Appliances, GE Appliances and Lighting, Haier America , Indesit Company Sa, Teka USA, Inc., LG Electronics USA, Miele , Inc., Samsung Electronics Co. , Viking Range Corporation and Whirlpool Corporation. BSH will notify all companies listed above (as well as AHAM) , as req uired by the Department's rules, providing them with a copy of this Petition for Waiver and Interim Waiver. 6

. Conclusion BSH Home Appliances Corporation hereby requests approval of the Waiver petition and Interim Waiver. By granting said Waivers the Department of Energy will further ensure that water energy is measured in the same way by all Dishwasher Manufacturer's that have a integrated water softener. Further, BSH would request that these Waivers be in good standing until such time that the test procedure can be formally modified to account for integrated water softeners. BSH Home Appliances certifies that all manufacturers of domestic Dishwashers as listed above have been notified by letter. With Best Regards , Mike Edwards 

# A\
- fv\-- C2d-u**C!J~'--** U nior Engineer, Performance and Consumption BSH Home Appliances Corporation (FNbG) 100 Bosch Blvd., Building 102 New Bern, NC 28562-6924 mike.edwards@bshg .com Phone (252) 672 9161 Fax (949) 8096177