DOE F 1325.8

(12-84)

United States Government

memorandum

Department of Energy

DATE: November 7, 1988

REPLY TO

EH-25

ATTN OF:

Approval of the Environmental Assessment (EA) and Notice of

SUBJECT:. Proposed Rulemaking (NOPR) for Energy Conservation Standards for

Refrigerators, Refrigerator-Freezers, Small Gas Furnaces and

Television Sets (ACCRTS Item No. CE-516)

TO:

John R. Berg

Acting Assistant Secretary

Conservation and Renewable Energy

This is in response to the memorandum of October 28, 1988, from the

Supervisory Engineer, Building Equipment Division, requesting

approval of the subject EA and NOPR. Revised drafts of these

documents were submitted on November 3, 1988.

The Office of Environment, Safety and Health has reviewed these

documents in accordance with our responsibilities under Department

of Energy Order 5440.1C regarding compliance with the National

Environmental Policy Act. The EA adequately addresses the

environmental effects associated with the proposal to prescribe

energy conservation standards for certain major household

appliances, and administer an energy program.

Based upon my staff's review and analyses and their recommendations,

and after consultation with the Office of General Counsel, I have

determined that the EA is adequate for publication subject to

incorporation of the changes indicated on the attached copy of the

EA. The proposal does not constitute a major federal action

significantly affecting the quality of the human environment.

Therefore, an environmental impact statement is not required. This

determination is explained in the attached finding of no significant

impact. In addition, the attached environmental discussion prepared

for inclusion in the NOPR is adequate and is hereby approved.

This EA has been designated as DOE/EA-0372. Please provide the

Office of NEPA Project Assistance with a record of your distribution

of the EA and five copies of the published EA.

Ernest C. (^Tayn d, ITI

-Assistant Secretary

Environment, Safety and Health

Attachments

CE-RM-87-102 COMMENT 05 DOE F 1325.8 

(12-84) 

United States Government Department of Energy 

memorandum 

DATE: November 7, 1988 

REPLY TO EH-25 

ATTN OF: 

-Approval of the Environmental Assessment (EA) and Notice of 

SUBJECT:. Proposed Rulemaking (NOPR) for Energy Conservation Standards for 

Refrigerators, Refrigerator-Freezers, Small Gas Furnaces and 

Television Sets (ACCRTS Item No. CE-516) 

TO: 

John R. Berg 

Acting Assistant Secretary 

Conservation and Renewable Energy 

This is in response to the memorandum of October 28, 1988, from the 

Supervisory Engineer, Building Equipment Division, requesting 

approval of the subject EA and NOPR. Revised drafts of these 

documents were submitted on November 3, 1988. 

The Office of Environment, Safety and Health has reviewed these 

documents in accordance with our responsibilities under Department 

of Energy Order 5440.lC regarding compliance with the National 

Environmental Policy Act. The EA adequately addresses the 

environmental effects associated with the proposal to prescribe 

energy conservation standards for certain major household 

appliances, and administer an energy program. 

Based upon my staff's review and analyses and their recommendations, 

and after consultation with the Office of General Counsel, I have 

determined that the EA is adequate for publication subject to 

incorporation of the changes indicated on the attached copy of the 

EA. The proposal does not constitute a major federal action 

significantly affecting the quality of the human environment. 

Therefore, an environmental impact statement is not required. This 

determination is explained in the attached finding of no significant 

impact. In addition, the attached environmental discussion prepared 

for inclusion in the NOPR is adequate and is hereby approved. 

This EA has been designated as DOE/EA-0372. Please provide the 

Office of NEPA Project Assistance with a record of your distribution 

of the EA and five copies of the published EA. 

Attachments 

Ernest C. 

Assistant Secretary 

Environment, Safety and Health 
DOE/EA-0372

ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY

CONSERVATION STANDARDS FOR TWO TYPES OF

CONSUMER PRODUCTS; REFRIGERATORS,

REFRIGERATOR-FREEZERS, AND FREEZERS;

SMALL GAS FURNACES; AND A PROPOSED

"NO STANDARD" STANDARD FOR TELEVISION SETS

1 INTRODUCTION AND SUMMARY

This environmental assessment (EA) evaluates the environmental impacts

resulting from new or amended energy-efficiency standards for refrigerators,

refrigerator-freezers, freezers, small gas furnaces, and television sets as mandated

by the National Appliance Energy Conservation Act of 1987 (NAECA, 1987). A

complete description of the Engineering and Economic Analysis of the proposed

standards may be found elsewhere in the Technical Support Document (TSD).

Four of the 14 scenarios for product design changes described in the Engineering

Analysis of the TSD are chosen for environmental assessment based on their relative importance as design measures. Values for energy savings that result from

product design changes are also taken from the TSD.

The two main environmental concerns addressed are emissions from fossil

fuel-fired electricity generation and the chlorofluorocarbons used in the production of rigid insulation foam. Each of the 12 design options for refrigerators and

freezers result in decreased electricity use and, therefore, reduced power plant

emissions. Design changes that call for additional rigid foam insulation per appliance are of interest because they affect chlorofluorocarbon consumption. There is

strong evidence that chlorofluorocarbons migrate to the stratosphere, break down,

and catalyze the destruction of stratospheric ozone.

The four scenarios analyzed are product design levels 3, 7, and 8 for refrigerators and freezers and a 78% annual fuel use efficiency (AFUE) requirement for

small gas furnaces. Emission savings from the Level 3 scenario for television set

efficiencies are also presented, although these results are not discussed in detail.

1

CE-RM-87-102 COMMENT 05

DOE/EA-0372 

ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY 

CONSERVATION STANDARDS FOR TWO TYPES OF 

CONSUMER PRODUCTS; REFRIGERATORS, 

REFRIGERATOR-FREEZERS, AND FREEZERS; 

SMALL GAS FURNACES; AND A PROPOSED 

"NO STANDARD" STANDARD FOR TELEVISION SETS 

1 INTRODUCTION AND SUMMARY 

This environmental assessment (EA) evaluates the environmental impacts 

resulting from new or amended energy-efficiency standards for refrigerators, 

refrigerator-freezers, freezers, small gas furnaces, and television sets as mandated 

by the National Appliance Energy Conservation Act of 1987 (NAECA, 1987). A 

complete description of the Engineering and Economic Analysis of the proposed 

standards may be found elsewhere in the Technical Support Document (TSD). 

Four of the 14 scenarios for product design changes described in the Engineering 

Analysis of the TSD are chosen for environmental assessment based on their relative importance as design measures. Values for energy savings that result from 

product design changes are also taken from the TSD. 

The two main environmental concerns addressed are emissions from fossil 

fuel-fired electricity generation and the chlorofluorocarbons used in the production of rigid insulation foam. Each of the 12 design options for refrigerators and 

freezers result in decreased electricity use and, therefore, reduced power plant 

emissions. Design changes that call for additional rigid foam insulation per appliance are of interest because they affect chlorofluorocarbon consumption. There is 

strong evidence that chlorofluorocarbons migrate to the stratosphere, break down, 

and catalyze the destruction of stratospheric ozone. 

The four scenarios analyzed are product design levels 3, 7, and 8 for refrigerators and freezers and a 78% annual fuel use efficiency (AFUE) requirement for 

small gas furnaces. Emission savings from the Level 3 scenario for television set 

efficiencies are also presented, although these results are not discussed in detail. 

1 
In the Level 3 scenario, all refrigerator and freezer doors would be changed to

include rigid foam insulation one and a half inches thick. In the Level 7 scenario,

all refrigerator and freezer doors would be changed to include rigid foam insulation two inches thick. In the Level 8 scenario, the insulating value of the foam

itself in the walls and doors of appliances would be improved from a conductivity

factor, K, of 0.125 (Btu-inch)/(hr-ft2- °F) to a K value of 0.1. Levels 7 and 8

refrigerators and freezers also include 5.3 EER compressors and more efficient

fans. The design changes to small gas furnaces associated with an efficiency

improvement to 78% are installing an intermittent ignition device and a fan for

induced draft combustion. The 12 design changes for refrigerators and freezers

and the three increased efficiency designs for small gas furnaces are described in

greater detail in the TSD.

Levels 1 and 2 designs for refrigerators and freezers are not analyzed because

they do not call for changes in the quantity or nature of rigid foam insulation

used per unit; energy savings attributed to Levels 1 and 2 are achieved through

the use of 4.5 and 5.0 EER compressors, respectively. Power plant emissions

would be abated as a result of Levels 1 and 2, but in smaller amounts than for

Levels 3-12, which result in greater energy savings. Levels 4, 5, and 6 are not

analyzed because they do not use more CFCs than the Level 3 scenario and the

reduction in emissions are between the those for the Level 3 and the Level 7

scenarios. Levels 9 through 11 are not analyzed because they are not addressed in

the TSD and therefore values for estimated energy savings and numbers of appliances sold are not available for estimating environmental impacts. Level 12 is

excluded because it is a lower priority design measure than the levels analyzed.

The proposed efficiency standards will decrease air pollution by decreasing

future energy demand. The greatest decreases in air pollution will be in sulfur

oxides (listed in equivalent weight of sulfur dioxide, or SO0). For the Level 8

scenario in the year 2010, the estimated SO2 reduction will be 202,000 tons. This

reduction represents 1.2% of the U.S. SO2 emissions expected to be emitted by

power plants in that year if no appliance standards are established (Placet, 1986).

Although the quantity of raw materials used per appliance will remain relatively constant, increased energy efficiency is expected to slightly increase the

number of appliances sold, resulting in small increases in raw materials used.

This demand increase is estimated by the Consumer Impact Analysis in the TSD.

The main effect of increased appliance production is the SO9 emitted in steel production. The increase is small, however, in comparison to the SO9 decreases from

CE-RM-87-102 COMMENT 05

In the Level 3 scenario, all refrigerator and freezer doors would be changed to 

include rigid foam insulation one and a half inches thiclc In the Level 7 scenario, 

all refrigerator and freezer door~ w~uld be changed to include rigid foam insulation two inches thick. In the Level 8 scenario, the insulating value of the foam 

itself in the walls and doors of appliances would be improved from a conductivity 

factor, K, of 0.125 (Btu-inch)/(hr-ft2

- OF) to a K value of 0.1. Levels 7 and 8 

refrigerators and freezers also include 5.3 EER compressors and more efficient 

fans. The design changes to small gas furnaces associated with an efficiency 

improvement to 78% are installing an intermittent ignition device and a fan for 

induced draft combustion. The 12 design changes for refrigerators and freezers 

and the three increased efficiency designs for small gas furnaces are described in 

greater detail in the TSD. 

Levels 1 and 2 designs for refrigerators and freezers are not analyzed because 

they do not call for changes in the quantity or nature of rigid foam insulation 

used per unit; energy savings attributed to Levels 1 and 2 are achieved through 

the use of 4.5 and 5.0 EER compressors, respectively. Power plant emissions 

would be abated as a result of Levels 1 and 2, but in smaller amounts than for 

Levels 3-12, which result in greater energy savings. Levels 4, 5, and 6 are not 

analyzed because they do not use more CFCs than the Level 3 scenario and the 

reduction in emissions are between the those for the Level 3 and the Level 7 

scenarios. Levels 9 through 11 are not analyzed because they are not addressed in 

the TSD and therefore values for estimated energy savings and numbers of appliances sold are not available for estimating environmental impacts. Level 12 IS 

excluded because it is a lower priority design measure than the levels analyzed. 

The proposed efficiency standards will decrease air pollution by decreasing 

future energy demand. The greatest decreases in air pollution will be in sulfur 

oxides (listed in equivalent weight of sulfur dioxide, or S02)' For the Level 8 

scenario in the year 2010, the estimated S02 reduction will be 202,000 tons. This 

reduction represents 1.2% of the U.S. S02 emissions expected to be emitted by 

power plants in that year if no appliance standards are established (Placet, HJ86). 

Although the quantity of raw materials used per appliance will remain relatively constant, increased energy efficiency is expected to slightly increase the 

number of appliances sold, resulting in small increases in raw materials used. 

This demand increase is estimated by the Consumer Impact Analysis in the TSD. 

The main effect of increased appliance production is the S02 emitted in steel production. The increase is small, however, in comparison to the S02 decreases from 

2 
fuel burning avoided at power plants. The contribution from steel production is

included in the estimates for net SO2 decreases resulting from design changes in

refrigerators and freezers.

The Level 8 decrease in nitrogen dioxide (NO2) emissions for the year 2010 is

estimated at 134,000 tons. This decrease in NO2 emissions represents 1.3% of the

total NO2 emissions expected to be emitted by power plants in that year without

new appliance standards. Emissions savings projected from Level 7 design

changes are nearly as great as the Level 8 savings because the only applicable

difference between the two scenarios is a slightly larger number of appliances sold

in the Level 8 scenario. Emissions savings from Level 3 design changes amount to

about half those from the Level 8 design changes.

Cumulative SO2 emissions reductions from increased efficiency of small gas

furnaces is only about 3% of the reductions from Level 8 refrigerator and freezer

design changes, or about 110,000 tons cumulative between 1993 and 2015. For

Level 3 television set standards, the reduction of SO2 and NO.9 emissions amounts

to 10% of that from the Level 8 standards for refrigerators and freezers.

Another consequence of standards will be reduction of carbon dioxide (CO2)

emissions. CO2 from fossil fuel burning is considered an environmental hazard

because elevated CO2 concentrations in the atmosphere are believed to trap heat

from the sun that has been absorbed by the Earth and reradiated. This "greenhouse effect" is expected to gradually raise the mean global temperature. The

Level 8 scenario is estimated to reduce worldwide CO2 emissions, for each of the

years 2010 through 2015, by an amount equivalent to 0.2% of the 1985 base

figure for anthropogenic CO2 emissions, which is 5.84 x 109 tons of carbon per

year (Harte, 1985).

An additional effect of some design change scenarios is the increased consumption of chlorofluorocarbons (CFCs). The chlorofluorocarbon R-11 is contained in

the rigid foam insulation used in the walls and doors of appliances. Use of R-11

would increase if manufacturers increased the thickness of appliance insulation.

Another CFC, R-12, is the heat exchange fluid used in refrigerators and freezers.

The use of R-12 would increase if more refrigerators and freezers were produced

in response to an increased demand for the more efficient appliances. During the

year 2010, Level 8 increases in CFC consumption attributed to standards are

estimated at 1.0% of the 1985 total U.S. R-11 and R-12 consumption (Hammitt,

1986).

3

CE-RM-87-102 COMMENT 05

fuel burning avoided at power plants. The contribution from steel production is 

included in the estimatesJoJ; net S02 decreases resulting from design changes in 

refrigerators and freezers. 

The Level 8 decrease in nitrogen dioxide (N02) emissions for the year 2010 is 

estimated at 134,000 tons. This decrease in N02 emissions represents 1.3% of the 

total N02 emissions expected to be emitted by power plants in that year without 

new appliance standards. Emissions savings projected from Level 7 design 

changes are nearly as great as the Level 8 savings because the only applicable 

difference between the two scenarios is a slightly larger number of appliances sold 

in the Level 8 scenario. Emissions savings from Level 3 design changes amount to 

about half those from the Level 8 design changes. 

Cumulative S02 emissions reductions from increased efficiency of small gas 

furnaces is only about 3% of the reductions from Level 8 refrigerator and freezer 

design changes, or about 110,000 tons cumulative between 1993 and 2015. For 

Level 3 television set standards, the reduction of S02 and N02 emissions amounts 

to 10% of that from the Level 8 standards for refrigerators and freezers. 

Another consequence of standards will be reduction of carbon dioxide (C02

) 

emissions. CO2 from fossil fuel burning is considered an environmental hazard 

because elevated CO2 concentrations in the atmosphere are believed to trap heat 

from the sun that has been absorbed by the Earth and reradiated. This "greenhouse effect" is expected to gradually raise the mean global temperature. The 

Level 8 scenario is estimated to reduce worldwide CO2 emissions, for each of the 

years 2010 through 2015, by an amount equivalent to 0.2% of the 1985 base 

figure for anthropogenic CO2 emissions, which is 5.84 X 109 tons of carbon per 

year (Harte, 1985). 

An additional effect of some design change scenarios is the increased consumption of chlorofluorocarbons (CFCs). The chlorofluorocarbon R-ll is contained in 

the rigid foam insulation used in the walls and doors of appliances. Use of R-ll 

would increase if manufacturers increased the thickness of appliance insulation. 

Another CFC, R-12, is the heat exchange fluid used in refrigerators and freezers. 

The use of R-12 would increase if more refrigerators and freezers were produced 

in response to an increased demand for the more efficient appliances. During the 

year 2010, Level 8 increases in CFC consumption attributed to standards are 

estimated at 1.0% of the H)85 total U.S. R-ll and R-12 consumption (Hammitt, 

1986). 

3 
Other environmental effects related to a standards-induced decrease in electricity generation are relatively insignificant compared to the decreases in SO2, NO2,

and CO2.

An in-depth analysis of particulate emissions is not included in this assessment because they are insignificant compared to sulfur and nitrogen oxide emissions. Current electricity generating methods are far cleaner than those of the

past. In 1984, power plants contributed only 7% of U.S. total particulate emissions as compared to contributions of 83% and 34% to total SO2 and NO2 emissions, respectively (EPA, 1986).

More efficient small gas furnaces will decrease the amount of gas or oil burned

within some homes, thereby decreasing combustion effects on indoor air quality.

Indoor air problems are usually due to a combination of factors, including a tight

house envelope, cigarette smoke, ventilation methods, water use habits, and radon

diffusion from soil. In comparison to the above factors, incremental changes in

combustion gases used have a small effect on indoor air quality.

2 METHODS OF ESTIMATING ENVIRONMENTAL IMPACTS

The greatest impacts of the proposed standards are the result of generating

less electricity . Power plants' main environmental effects on air and water result

from emissions of sulfur oxides (SOX), nitrogen oxides (NOX), and carbon dioxide

(CO2). The symbols SO2 and NO2 represent all emissions of SOX and NOX

expressed in the equivalent weights of SO2 and NO2, respectively. Carbon dioxide

emissions are commonly expressed in tons of carbon.

The efficiencies of refrigerators and freezers can be improved by using foam

insulation in their doors. If this design option is chosen by the industry in

response to standards, chlorofluorocarbon consumption will increase . CFC use is

estimated on the basis of refrigerator and freezer dimensions and the amount of

additional CFC required to increase the volume of rigid insulation foam. None of

the design options proposed requires the use of additional R-12 (a CFC used as a

refrigerant) per appliance . A secondary effect, the change in shipments resulting

from standards, is also considered.

4

CE-RM-87-102 COMMENT 05

Other environmental effects related to a standards-induced decrease in electricity generation are relatively insign~?cant compared to the decreases in S02' N02, 

and CO2, " " 

An in-depth analysis of particulate emissions is not included in this assessment because they are insignificant compared to sulfur and nitrogen oxide emissions. Current electricity generating methods are far cleaner than those of the 

past. In 1984, power plants contributed only 7% of U.S. total particulate emissions as compared to contributions of 83% and 34% to total S02 and N02 emissions, respectively (EPA, 1986). 

More efficient small gas furnaces will decrease the amount of gas or oil burned 

within some homes, thereby decreasing combustion effects on indoor air quality. 

Indoor air problems are usually due to a combination of factors, including a tight 

house envelope, cigarette smoke, ventilation methods, water use habits, and radon 

diffusion from soil. in comparison to the above factors, incremental changes in 

combustion gases used have a small effect on indoor air quality. 

2 METHODS OF ESTIMATING ENVIRONMENTAL IMPACTS 

The greatest impacts of the proposed standards are the result of generating 

less electricity. Power plants' main environmental effects on air and water result 

from emissions of sulfur oxides (SOJ, nitrogen oxides (NOJ, and carbon dioxide 

(C02), The symbols S02 and NO,) represent all emissions of SO and NO _ x x 

expressed in the equivalent weights of S02 and N02, respectively. Carbon dioxide 

emissions are commonly expressed in tons of carbon. 

The efficiencies of refrigerators and freezers can be improved by using foam 

insulation in their doors. If this design option is chosen by the industry in 

response to standards, chlorofluorocarbon consumption will increase. CFC use is 

estimated on the basis of refrigerator and freezer dimensions and the amount of 

additional CFC required to increase the volume of rigid insulation foam. None of 

the design options proposed requires the use of additional R-12 (a CFC used as a 

refrigerant) per appliance. A secondary effect, the change in shipments resulting 

from standards, is also considered. 

4 
2.1 Sulfur and Nitrogen Oxide Emissions

For each of the scenarios analyzed for their environmental impacts (Level 3,

Level 7, and Level 8 in refrigerators and freezers, 78% AFUE small gas furnaces,

and Level 3 efficiencies for televisions), emissions abated from fossil fuel-burning

power plants are considered.

In analyzing the impacts of Level 3, 7, and 8 design changes to refrigerators

and freezers, increased sulfur emissions to come from increased steel production

are also considered. As mentioneu earlier in this report, these increases in steel

production result from slight increases in the number of appliances sold, equated

to an increase in the number of appliances manufactured. No changes in the

amount of steel used per refrigerator or freezer are expected.

Analysis of the impacts resulting from 78% AFUE small gas furnaces includes

the consideration of SO2 from in-home combustion of gas and oil.

Figures for energy saved by reduced electric generation are taken from the

TSD. Primary energy saved from electric generation is allocated among the

categories of coal on the one hand, and as plus oil on the other, in the ratios of

0.53 and 0.47, respectively, as estimated in supporting material for the Electric

Utility Analysis, also in the TSD. This disaggregation into coal and oil-plus-gas is

depicted in Figure 1. In order to capture the effects of cleaner-burning power

plants in future years, emission rates for power plant fuel burning are calculated

from projected emissions data and the projected quantities of the corresponding

fuels used, as described in Placet, et al. (1986). Gas and oil are combined

because, from an electric utility perspective, they are interchangeable. Linear

interpolation and extrapolation are used to derive emissions rates for years not

covered in the report.

Sulfur dioxide emissions from steel production are estimated assuming 100

pounds of steel per refrigerator or freezer (Mooz, 1982). An S02 emissions rate

for steel production is calculated from the "National Air Pollutant Emission Estimates, 1940-1985," (EPA, 1986), along with its supporting materials, and a value

for 1985 national steel production from the U.S. Department of Commerce (U.S.

Department of Commerce, 1986)*. SO2 emissions from steel production are multiplied by the tons of steel to be used in manufacturing the additional appliances in

the Level 3, 7, and 8 scenarios.

* Uncertainty arises because EPA had to make assumptions about the furnace types used to produce steel and about the sulfur content of the coal burned to generate the electricity for steel production.

5

CE-RM-87-102 COMMENT 05

2.1 Sulfur and Nitrogen Oxide Emissions 

For each of the scenarios analyzed for their environmental impacts (Level 3, "l- • ~ 

Level 7, and Level 8 in refrigerators and freezers, 78% AFUE small gas furnaces, 

and Level 3 efficiencies for televisions), emissions abated from fossil fuel-burning 

power plants are considered. 

In analyzing the impacts of Level 3, 7, and 8 design changes to refrigerators 

and freezers, increased sulfur emissions to come from increased steel production 

are also considered. As mentioneu earlier in this report, these increases in steel 

production result from slight increases in the number of appliances sold, equated 

to an increase in the number of appliances manufactured. No changes in the 

amount of steel used per refrigerator or freezer are expected. 

Analysis of the impacts resulting from 78% AFUE small gas furnaces includes 

the consideration of S02 from in-home combustion of gas and oil. 

Figures for energy saved by reduced electric generation are taken from the 

TSD. Primary energy saved from electric generation is allocated among the 

categories of coal on the one hand, and gas plus oil on the other, in the ratios of 

0.53 and 0.47, respectively, as estimated in supporting material for the Electric 

Utility Analysis, also in the TSD. This disaggregation into coal and oil-plus-gas is 

depicted in Figure 1. In order to capture the effects of cleaner-burning power 

plants in future years, emission rates for power plant fuel burning are calculated 

from projected emissions data and the projected quantities of the corresponding 

fuels used, as described in Placet, et al. (1986). Gas and oil are combined 

because, from an electric utility perspective, they are interchangeable. Linear 

interpolation and extrapolation are used to derive emissions rates for years not 

covered in the report. 

Sulfur dioxide emissions from steel production are estimated assuming 100 

pounds of steel per refrigerator or freezer (Mooz, 1982). An S02 emissions rate 

for steel production is calculated from the "National Air Pollutant Emission Estimates, 1940-1985," (EPA, 1986), along with its supporting materials, and a value 

for 1985 national steel production from the U.S. Department of Commerce (U.S. 

Department of Commerce, 1986)*. S02 emissions from steel production are multiplied by the tons of steel to be used in manufacturing the additional appliances in 

the Level 3, 7, and 8 scenarios. 

* Uncertainty arises because EPA had to make assumptions about the furnace types used to produce steel and about the sulfur content of the coal burned to generate the electricity for steel production. 

5 
Electricity Savings due to Standards on Refrigerator-Freezers

Level 3 Standards Level 8 Standards

0.7

0.6 -

0.5-

(U

D

C7

0.4-)

0.1-I

0.7-7

0.0 -^--,-

1990

Total

Electricity Savings

1995

Oil and Gas

0.0-

2000 2005 2010 2015 1990 1995 2000 2005 2010 2015

Year Year

CE-RM-87-102 COMMENT 05

-CJ) 

"0 

ro 

:J 

a 

-

:J 

+-' 

r::o 

c 

0 

"-

"0 

ro 

:::l 

a 

Electricity Savings due to Standards on Refrigerator-Freezers 

Level 3 Standards 

0.7,...---------------, 

0.6 

0.5 

Total 

Electricity Savings 

0.4 

0.3 

0.2 

0.1 

o.o~~~~~++~~~~~~~~~ 

1990 1995 2000 2005 2010 2015 

Year 

-CJ) 

"0 

ro 

:::l 

a 

-

:::l 

+-' 

r::o 

c 

0 

"-

"0 

ro 

::J 

a 

Level 8 Standards 

0.7,----------------...., 

0.6 

Total 

Electricity Savings 

0.5 

0.4 

0.3 

0.2 

0.1 

0.0 --t-T-f'~:r-f~~r-r~~~~~~~~ 

1990 1995 2000 2005 2010 2015 

Year 
The values for SO2 savings from in-home gas and oil combustion are produced by multiplying in-home fuel savings for gas and oil by corresponding emission rates for furnace operation, taken from Surprenant, et al. (1979).

Methods and data sources for calculating changes in NO2 emissions are identical to those for SO2 emissions with the exception of emissions from steel production. Unlike in the scenario for SO2, no significant NO9 emissions are expected

from increased steel production.

2.2 Carbon Dioxide Emissions

Values for CO2 abated are the sum of the CO2 savings from coal-, gas-, and

oil-fired power plants and, for the 78% AFUE small gas furnace scenario only,

CO2 emissions from in-home combustion of gas and oil. The energy saved from

electricity generation is apportioned between coal and gas or oil as in the calculation of SO2 and NO2. In addition, gas and oil are disaggregated into relative

shares of 0.70 and 0.30, respectively. These shares are the averages of the relative

quantities of these fuels to be used for electrical generation in the years 1990

through 1995, as estimated by the North American Electric Reliability Council

(NERC, 1985). The energy values of the fuels saved are translated into tons of

carbon using carbon/Btu values from the Carbon Dioxide Review, (Clark, 1982).

The data for a more accurate method of estimated relative gas and oil shares concerning order of dispatch in the various NERC regions are not available. This

disaggregation into fuel shares should therefore be taken only as a rough

representation of power plant fuel choices on the margin.

2.3 Chlorofluorocarbon Consumption

Design change level 3 involves adding foam to the doors of refrigeratorfreezers and freezers to a thickness of 1.5 inches. This would require additional

foam in the doors of some models and the use of foam to replace fiberglass in others. The Level 7 design change specifies increasing the thickness of the foam used

in the appliance doors to 2.0 inches. Design change level 8 includes the 2.0 inch

thick insulation in appliance doors called for by Level 7 and also specifies an

increase in the insulating value of the foam itself. Because they called for adding

foam insulation to the doors of refrigerators and freezers, all three design change

scenarios for these appliances involve a change in the amount of CFCs used per

7

CE-RM-87-102 COMMENT 05

The values for S02 savings from in-home gas- and oil combustion are produced by multiplying in-home fuel savings for gas and oil by corresponding emission rates for furnace ope~ati~n, taken from Surprenant, et al. (1979). 

Methods and data sources for calculating changes in N02 emissions are identical to those for S02 emissions with the exception of emissions from steel production. Unlike in the scenario for S02' no significant N02 emissions are expected 

from increased steel production. 

2.2 Carbon Dioxide Emissions 

Values for CO2 abated are the sum of the CO2 savings from coal-, gas-, and 

oil-fired power plants and, for the 78% AFUE small gas furnace scenario only, 

CO2 emissions from in-home combustion of gas and oil. The energy saved from 

electricity generation is apportioned between coal and gas or oil as in the calculation of 802 and N02. In addition, gas and oil are disaggregated into relative 

shares of 0.70 and 0.30, respectively. These shares are the averages of the relative 

quantities of these fuels to be used for electrical generation in the years 1990 

through 1995, as estimated by the North American Electric Reliability Council 

(NERC, 1985). The energy values of the fuels saved are translated into tons of 

carbon using carbon/Btu values from the Carbon Dioxide Review, (Clark, 1982). 

The data for a more accurate method of estimated relative gas and oil shares concerning order of dispatch in the various NERC regions are not available. This 

disaggregation into fuel shares should therefore be taken only as a rough 

representation of power plant fuel choices on the margin. 

2.3 Chlorofluorocarbon Consumption 

Design change level 3 involves adding foam to the doors of refrigeratorfreezers and freezers to a thickness of 1.5 inches. This would require additional 

foam in the doors of some models and the use of foam to replace fiberglass in others. The Level 7 design change specifies increasing the thickness of the foam used 

in the appliance doors to 2.0 inches. Design change level 8 includes the 2.0 inch 

thick insulation in appliance doors called for by Level 7 and also specifies an 

increase in the insulating value of the foam itself. Because they called for adding 

foam insulation to the doors of refrigerators and freezers, all three design change 

scenarios for these appliances involve a change in the amount of CFCs used per 

7 
appliance. The 78% AFUE small gas furnace scenario does not involve CFC production or consumption.

Average refrigerator and freezer dimensions are used to estimate the dimensions of foamed areas, which in turn are used to estimate changes in CFC use.

These estimated dimensions of foamed areas remain constant in all three scenarios

while the thickness of door insulation varies; the only exception is an increase in

the foamed area for refrigerator-freezers and freezers that have no door foam in

the base case scenario.

The volume of foam is estimated for each of ten product classes. The ten

classes fit into six groups of height, width, and depth. For example, group D

includes all side-by-side refrigerator-freezers. Appendix A specifies the classes

included in each group and lists the estimated dimensions of foamed areas for

groups A through F.

The estimates of foamed areas for appliance groups C, D, and E are based on

appliance dimensions as outlined in the Engineering Analysis in the TSD.

In order to estimate foamed areas for appliances in groups A, B, and F, average adjusted volumes for the specified models are first obtained from the Association of Home Appliance Manufacturers. These average adjusted volumes are used

to identify the most appropriately sized models for which exterior dimensions are

listed by the California Energy Commission, (CEC, 1987). Appliance dimensions

from the CEC report are then used to estimate dimensions of foamed areas.

When interior appliance dimensions are used to estimated the size of foamed

areas, 1.0 inch is added where appropriate in order to account for extra foam used

around corners. When exterior appliance dimensions are used to estimate the size

of foamed areas, 1.0 inch is subtracted where appropriate to account for the overlap of foamed areas around corners. It is assumed that the bottom edge of insulated areas begins 6.5 inches above floor level for each of the refrigerator-freezer

and freezer models except freezers. The bottom edge of insulated areas for chest

freezers is estimated to begin 2 inches above floor level.

Volumes of foam are converted into pounds of the CFC R-11 using a factor of

1.5 pounds of foam per cubic foot (Hammitt, 1986) and 0.2 pounds of R-11 per

pound of foam. The ratio of 0.2 pounds of R-11 per pound of foam is derived

from the current annual quantity of R-11 used by manufacturers of refrigerators

and freezers (14,835,000 pounds--AIIAM, 1987) along with the number of these

appliances manufactured (7,145,000 appliances--AI-IAM, 1987) and their average

8

CE-RM-87-102 COMMENT 05

appliance. The 78% AFUE small gas furnace scenario does not involve CFC production or consumption. 

Average refrigerator and freezer dimensions are used to estimate the dimensions of foamed areas, which in turn are used to estimate changes in CFC use. 

These estimated dimensions of foamed areas remain constant in all three scenarios 

while the thickness of door insulation varies; the only exception is an increase in 

the foamed area for refrigerator-freezers and freezers that have no door foam in 

the base case scenario. 

The volume of foam is estimated for each of ten product classes. The ten 

classes fit into six groups of height, width, and depth. For example, group D 

includes all side-by-side refrigerator-freezers. Appendix A specifies the classes 

included in each group and lists the estimated dimensions of foamed areas for 

groups A through F. 

The estimates of foamed areas for appliance groups C, D, and E are based on 

appliance dimensions as outlined in the Engineering Analysis in the TSD. 

In order to estimate foamed areas for appliances in groups A, B, and F, average adjusted volumes for the specified models are first obtained from the Association of Home Appliance Manufacturers. These average adjusted volumes are used 

to identify the most appropriately sized models for which exterior dimensions are 

listed by the California Energy Commission, (CEC, 1987). Appliance dimensions 

from the CEC report are then used to estimate dimensions of foamed areas. 

When interior appliance dimensions are used to estimated the size of foamed 

areas, 1.0 inch is added where appropriate in order to account for extra foam used 

around corners. When exterior appliance dimensions are used to estimate the size 

of foamed areas, 1.0 inch is subtracted where appropriate to account for the overlap of foamed areas around corners. It is assumed that the bottom edge of insulated areas begins 6.5 inches above floor level for each of the refrigerator-freezer 

and freezer models except freezers. The bottom edge of insulated areas for chest 

freezers is estimated to begin 2 inches above floor level. 

Volumes of foam are converted into pounds of the CFC R-ll using a factor of 

1.5 pounds of foam per cubic foot (Hammitt, 1986) and 0.2 pounds of R-ll per 

pound of foam. The ratio of 0.2 pounds of R-ll per pound of foam is derived 

from the current annual quantity of R-ll used by manufacturers of refrigerators 

and freezers (14,835,000 pounds--AH.A}.;I, 1987) along with the number of these 

appliances manufactured (7,145,000 appliances--AfLW, 1987) and their average 

8 
volumes of foam calculated as outlined above and weighted by shipment (Roman,

1987 and AHAM, 1986)

The total change in CFCs is the sum of CFCs from increased foam use per

appliance and increased CFCs from the production of a greater number of appliances. The former contribution to increased CFC use is the product of per unit

R-11 increases and the base case number of appliances shipped. The latter contribution to increased CFC use includes per unit R-11 in the foam insulation and

R-12 refrigerant in the additional appliances shipped. Values for the amounts of

the R- 12 used in refrigerators and freezers are 210 grams and 280 grams, respectively (Hammitt, 1986). Where R-12 values are included in totals, they are listed

in terms of their ozone damage potential (0.79) relative to R-11 (Mooz, 1982).

3 REFRIGERATORS AND FREEZERS

3.1 Level Three Design Changes

The Level 3 design changes are the addition of rigid insulating foam to the

doors of refrigerators and freezers to a thickness of one and a half inches.

3.1.1 Sulfur and Nitrogen Oxide Emissions

Changes in the amounts of SO 2 and NO2 emitted result mainly from greater

refrigerator and freezer efficiency and resulting decreases in the amount of electricity generated by fossil fuel-burning plants. SO 2 emissions are also affected by

increased steel production because of slightly increased demand for the more

efficient appliances. No additional steel is expected to be used per appliance.

Sulfur dioxide emissions would be decreased by a cumulative total of

1,540,000 tons between 1993 and 2015 in the Level 3 scenario. Figures for changes

in SO2 emissions are listed in Table 1. In the year 2000, decreases in sulfur dioxide will represent roughly 0.3% of the SO2 emissions estimated to come from

power plants in that year. In the year 2010, decreases in SO2 emissions will

represent about 0.6% of the SO2 emissions estimated to come from power plants

in that year if standards are not established.

9

CE-RM-87-102 COMMENT 05

volumes of foam calculated as outlined above and weighted by shipment (Roman, 

1987 and AHANI, 1986) 

The total change in CFCs is the sum of CFCs from increased foam use per 

appliance and increased CFCs from the production of a greater number of appliances. The former contribution to increased CFC use is the product of per unit 

R-ll increases and the base case number of appliances shipped. The latter contribution to increased CFC use includes per unit R-ll in the foam insulation and 

R-12 refrigerant in the additional appliances shipped. Values for the amounts of 

the R-12 used in refrigerators and freezers are 210 grams and 280 grams, respectively (Hammitt, 1986). Where R-12 values are included in totals, they are listed 

in terms of their ozone damage potential (0. 79) relative to R-ll (Mooz, 1 982). 

3 REFRIGERATORS AND FREEZERS 

3.1 Level Three Design Changes 

The Level 3 design changes are the addition of rigid insulating foam to the 

doors of refrigerators and freezers to a thickness of one and a half inches. 

3.1.1 Sulfur and Nitrogen Oxide Emissions 

Changes in the amounts of S02 and N02 emitted result mainly from greater 

refrigerator and freezer efficiency and resulting decreases in the amount of electricity generated by fossil fuel-burning plants. S02 emissions are also affected by 

increased steel production because of slightly increased demand for the more 

efficient appliances. No additional steel is expected to be used per appliance. 

Sulfur dioxide emissions would be decreased by a cumulative total of 

1,540,000 tons between 1993 and 2015 in the Level 3 scenario. Figures for changes 

in S02 emissions are listed in Table 1. In the year 2000, decreases in sulfur dioxide will represent roughly 0.3% of the S02 emissions estimated to come from 

power plants in that year. In the year 2010, decreases in S02 emissions will 

represent about 0.6% of the 802 emissions estimated to come from power plants 

in that year if standards are not established. 

9 
There is evidence that decreases in sulfur emissions are followed by proportional decreases in acid deposition (Oppenheimer, 1983). Quantifying and qualifying the resulting abatement of environmental damage is considerably more

difficult. An attempt is made in the section titled "Valuing Decreases in Acid

Precipitation".

Level 3 design changes to refrigerators would result in an estimated decrease

in NO2 emissions of 996,000 tons between 1993 and 2015. Changes in NO2 emissions are also listed in Table 1. NO2 decreases would represent 0.4% and 0.6% of

the NO2 emissions estimated to come from power plants in the years 2000 and

2010 , respectively.

3.1.2 Carbon Dioxide Emissions

The cumulative reduction in CO2 emissions from Level 3 design changes is 88

million tons of carbon. For the year 2000, the estimated CO2 reduction is 2.6

million tons of carbon. In 2010, the estimated CO., reduction is 5.8 million tons

of carbon, or about 0.1% of estimated 1985 worldwide anthropogenic CO2 emissions. In other words, by 2010, Level 3 design changes will decrease annual global

CO2 emissions by one one-thousandth of current levels.

3.1.3 Chlorofluorocarbon Consumption

The chlorofluorocarbon with the greatest ozone destruction potential, R-11, is

used as a blowing agent in producing polyurethane foam, the insulation used in

the walls of refrigerators and freezers. Most of the Level 3 increases in CFC use

can be attributed to the R-11 used as more insulation is blown into the doors of

refrigerators and freezers. Similar to the estimation of SO2 emissions, estimations

of CFC use include the effects of increased demand for efficient appliances. In the

case of CFCs, this includes the manufacturing of additional appliances including

R-11 in their foam walls and R-12 as a heat exchange fluid. R-12 is estimated to

be 0.79 times as damaging to the ozone as R-11 (Mooz, 1982).

Level 3 design changes would result in an average CFC-11 consumption of

2.71 pounds per refrigerator-freezer and 1.95 pounds per freezer, increases of 0.28

pounds and 0.12 pounds of CFC-11, respectively. Adding in additional R-12 used

in the Level 3 scenario and summing use between 1993 and 2015 yields a total

increase of 66 million pounds of CFC-11 equivalent. In the year 2010, the

estimated increase of 3.1 million pounds represents 0.7% of the 1985 U.S.

10

CE-RM-87-102 COMMENT 05

There is evidence that decreases in sulfur emissions are followed by proportional decreases in acid deposition (Oppenheimer, 1983). Quantifying and qualifying the resulting abatement ~f e"'nvironmental damage is considerably more 

difficult. An attempt is made in the section titled "Valuing Decreases in Acid 

Precipitation" . 

Level 3 design changes to refrigerators would result in an estimated decrease 

in N02 emissions of 996,000 tons between 1993 and 2015. Changes in N02 emissions are also listed in Table 1. N02 decreases would represent 0.4% and 0.6% of 

the N02 emissions estimated to come from power plants in the years 2000 and 

2010, respectively. 

3.1.2 Carbon Dioxide Emissions 

The cumulative reduction in CO2 emissions from Level 3 design changes is 88 

million tons of carbon. For the year 2000, the estimated CO2 reduction is 2.6 

million tons of carbon. In 2010, the estimated CO2 reduction is 5.8 million tons 

of carbon, or about 0.1% of estimated 1985 worldwide anthropogenic CO2 emissions. In other words, by 2010, Level 3 design changes will decrease annual global 

CO2 emissions by one one-thousandth of current levels. 

3.1.3 Chlorofluorocarbon Consumption 

The chlorofluorocarbon with the greatest ozone destruction potential, R-ll, is 

used as a blowing agent in producing polyurethane foam, the insulation used in 

the walls of refrigerators and freezers. Most of the Level 3 increases in CFC use 

can be attributed to the R-ll used as more insulation is blown into the doors of 

refrigerators and freezers. Similar to the estimation of S02 emissions, estimations 

of CFC use include the effects of increased demand for efficient appliances. In the 

case of CFCs, this includes the manufacturing of additional appliances including 

R-ll in their foam walls and R-12 as a heat exchange fluid. R-12 is estimated to 

be 0.79 times as damaging to the ozone as R-ll (Mooz, 1982). 

Level 3 design changes would result in an average CFC-ll consumption of 

2.71 pounds per refrigerator-freezer and 1.95 pounds per freezer, increases of 0.28 

pounds and 0.12 pounds of CFC-ll, respectively. Adding in additional R-12 used 

in the Level 3 scenario and summing use between 1993 and 2015 yields a total 

increase, of 66 million pounds of CFC-ll equivalent. In the year 2010, the 

estimated increase of 3.1 million pounds represents 0.7% of the 1985 U.S. 

10 
emissions of R-11 and R-12.

3.2 Level Seven Design Changes

The Level 7 design changes are the addition of rigid insulating foam to the

doors of refrigerators and freezers to thickness of two inches.

3.2.1 Sulfur and Nitrogen Oxide Emissions

Sulfur dioxide emissions would be decreased by a cumulative total of

2,910,000 tons between 1993 and 2015. Figures for changes in S02 emissions are

listed in Table 3. In the year 2000, decreases in sulfur dioxide will represent

roughly 0.6% of the SO2 emissions estimated to come from power plants in that

year if no efficiency standards are established. In the year 2010, decreases in SO2

emissions will represent about 1.1% of the SO2 emissions estimated to come from

power plants in that year.

Level 7 design changes to refrigerators and freezers would result in an

estimated decrease in NO2 emissions of 1,880,000 tons between 1993 and 2015 (see

Table 3.). NO2 decreases would represent 0.7% and 1.2% of the NO2 emissions

estimated to come from power plants in the years 2000 and 2010, respectively.

3.2.2 Carbon Dioxide Emissions

The cumulative reduction in CO2 emissions from Level 7 design changes is

166 million tons of carbon. For the year 2000, the estimated CO2 reduction is 4.9

million tons of carbon. In 2010, the estimated CO2 reduction is 11 million tons of

carbon, or about 0.2% of estimated 1985 worldwide anthropogenic CO2 emissions

expected if no appliance efficiency standards are established.

3.2.3 Chlorofluorocarbon Consumption

The production of refrigerator-freezers would require 2.84 pounds of R-11 for

wall and door insulation in the Level 7 scenario, an increase of 0.41 pounds over

the base case scenario. Freezers would require the use of 2.06 pounds of R-11 for

rigid insulation, an increase of 0.24 pounds per unit. Level 7 increase in the

chlorofluorocarbons R-11 and R-12, listed in equivalent amounts of R-11, sums to

102 million pounds of R-11 equivalent for the years 1993 and 2015. In the year

11

CE-RM-87-102 COMMENT 05

emissions of R-11 and R-12. 

3.2 Level Seven Design Changes 

The Level 7 design changes are the addition of rigid insulating foam to the 

doors of refrigerators and freezers to thickness of two inches. 

3.2.1 Sulfur and Nitrogen Oxide Emissions 

Sulfur dioxide emissions would be decreased by a cumulative total of 

2,910,000 tons between 1993 and 2015. Figures for changes in S02 emissions are 

listed in Table 3. In the year 2000, decreases in sulfur dioxide will represent 

roughly 0.6% of the S02 emissions estimated to come from power plants in th?-t 

year if no efficiency standards are established. In the year 2010, decreases in S02 

emissions will represent about 1.1% of the S02 emissions estimated to come from 

power plants in that year. 

Level 7 design changes to refrigerators and freezers would result in an 

estimated decrease in N02 emissions of 1,880,000 tons between 1993 and 2015 (see 

Table 3.). N02 decreases would represent 0.7% and 1.2% of the N02 emissions 

estimated to come from power plants in the years 2000 and 2010, respectively. 

3.2.2 Carbon Dioxide Emissions 

The cumulative reduction in CO2 emissions from Level 7 design changes is 

166 million tons of carbon. For the year 2000, the estimated CO2 reduction is 4.9 

million tons of carbon. In 2010, the estimated CO2 reduction is 11 million tons of 

carbon, or about 0.2% of estimated 1985 worldwide anthropogenic CO2 emissions 

expected if no appliance efficiency standards are established. 

3.2.3 Chlorofluorocarbon Consumption 

The production of refrigerator-freezers would require 2.84 pounds of R-ll for 

wall and door insulation in the Level 7 scenario, an increase of 0.41 pounds over 

the base case scenario. Freezers would require the use of 2.06 pounds of R-ll for 

rigid insulation, an increase of 0.24 pounds per unit. Level 7 increase in the 

chlorofluorocarbons R-ll and R-12, listed in equivalent amounts of R-ll, sums to 

102 million pounds of R-11 equivalent for the years 1993 and 2015. In the year 

11 
2010, the estimated increase of 4.8 million pounds represents 1.0% of the 1985

U.S. emissions of R-11 and R-12.

3.3 Level Eight Design Changes

The Level 8 design change includes the Level 7 increase in foam insulation to

two inches in appliances doors as well as increasing the insulating quality of the

foam itself. The current insulation conductivity factor for the foam used in appliance walls and doors is K = 0.125 (Btu-inch)/(hr-ft2- °F). Level 8 design changes

would require a change in the K factor from 0.125 to 0.10. Level 8 refrigerators

and freezers also include 5.3 EER compressors and more efficient fans. Better

insulation for refrigerators and freezers would result in decreased electricity consumption and a corresponding decrease in the burning of fossil fuels.

The effects of Level 8 design changes include the two contributions. SO2

changes will result from decreased fossil fuel burning in power plants as well as an

from increased steel production. Increased steel production is a result of greater

demand for the more efficient appliances.

3.3.1 Sulfur and Nitrogen Oxide Emissions

Net SO2 emissions abated between 1993 and 2015 sum to 3.2 million tons.

During the year 2000, 113,000 tons of SO2 will be abated, representing roughly

0.6% of the S02 emissions estimated to come from power plants in that year. By

the year 2010, SO2 emissions abated will be about 1.2% of the estimated annual

SO2 emissions from power plants if no new appliance efficiency standards are

established.

Avoided NO2 emissions resulting from Level 8 design changes are estimated as

those emissions saved from decreases in fossil fuel burning in electric power

plants. No significant NO9 contribution is expected from the increases in steel

production associated with increases in product demand. The cumulative NO9

emissions avoided for the 23-year period studied are 2.1 million tons. Annual

quantities of NO2 avoided are 66,000 tons (0.7% of estimated power plant emissions) and 134,000 tons (1.3%) for the years 2000 and 2010, respectively.

12

CE-RM-87-102 COMMENT 05

2010, the estimated increase of 4.8 million pounds represents 1.0% of the 1985 

U.S. emissions of R-11 and R-12: " , ~ 

3.3 Level Eight Design Changes 

The Level 8 design change includes the Level 7 increase in foam insulation to 

two inches in appliances doors as well as increasing the insulating quality of the 

foam itself. The current insulation conductivity factor for the foam used in appliance walls and doors is K = 0.125 (Btu-inch)/(hr-ft2

- OF). Level 8 design changes 

would require a change in the K factor from 0.125 to 0.10. Level 8 refrigerators 

and freezers also include 5.3 EER compressors and more efficient fans. Better 

insulation for refrigerators and freezers would result in decreased electricity consumption and a corresponding decrease in the burning of fossil fuels. 

The effects of Level 8 design changes include the two contributions. S02 

changes will result from decreased fossil fuel burning in power plants as well as an 

from increased steel production. Increased steel production is a result of greater 

demand for the more efficient appliances. 

3.3.1 Sulfur and Nitrogen Oxide Emissions 

Net S02 emissions abated between 1993 and 2015 sum to 3.2 million tons. 

During the year 2000, 113,000 tons of S02 will be abated, representing roughly 

0.6% of the S02 emissions estimated to come from power plants in that year. By 

the year 2010, S02 emissions abated will be about 1.2% of the estimated annual 

S02 emissions from power plants if no new appliance efficiency standards are 

established. 

Avoided N02 emissions resulting from Level 8 design changes are estimated as 

those emissions saved from decreases in fossil fuel burning in electric power 

plants. No significant N02 contribution is expected from the increases in steel 

production associated with increases in product demand. The cumulative N02 

emissions avoided for the 23-year period studied are 2.1 million tons. Annual 

quantities of N02 avoided are 66,000 tons (0.7% of estimated power plant emissions) and 134,000 tons (1.3%) for the years 2000 and 2010, respectively. 

12 
3.3.2 Carbon Dioxide Emissions

Level 8 changes in CO2 emissions add up to 185 million tons of carbon for the

years 1993 through 2015. CO2 savings are listed in Table 6. The quantity of

CO2 saved increases each year through the period studied, reaching 14.3 million

tons of carbon in the year 2015. These savings represent 0.2% of estimated 1985

worldwide CO9 emissions.

3.3.3 Chlorofluorocarbon Consumption

A change from a K factor from 0.125 to 0.10 involves changing the amount of

CO, and water used, and does not affect the amount of R-11 used. In other

words, the amount of R-11 used per appliance does not change from the Level 7

to the Level 8 scenario. The only difference between values for increased CFC

consumption between these two scenarios results from the difference in the

number of appliances sold. Values for CFC increases in the Level 8 scenario are

listed in Table 6.

4 SMALL GAS FURNACES

The effects considered in determining the environmental impacts of more

efficient small gas furnaces are a decrease in electricity generated at fossil fuelburning power plants and decreases in gas and oil burned in homes. Small

decreases in electricity consumption will occur as some households shift from electric heating to small gas furnaces.

Although slight increases in shipments of small gas furnaces are expected,

increases in the materials used in producing these furnaces will be offset by

decreases in the the materials used in producing the larger furnaces and the electric heating devices that the small gas furnaces will replace.

A change in furnace efficiency to 78% does not affect the emissions from gas

or oil burned in these furnaces. Although changes in emissions rates may occur

along with condensation of some of the vapor in the flue gases, this condensation

does not occur until efficiencies in the range of 82-84% are reached (DeWerth,

1988).

13

CE-RM-87-102 COMMENT 05

3.3.2 Carbon Dioxide Emissions 

Level 8 changes in CO,2 eJ-nissions add up to 185 million tons of carbon for the 

years 1993 through 2015. CO2 savings are listed in Table 6. The quantity of 

CO2 saved increases each year through the period studied, reaching 14.3 million 

tons of carbon in the year 2015. These savings represent 0.2% of estimated 1985 

worldwide CO2 emissions. 

3.3.3 Chlorofluorocarbon Consumption 

A change from a K factor from 0.125 to 0.10 involves changing the amount of 

CO2 and water used, and does not affect the amount of R-ll used. In other 

words, the amount of R-ll used per appliance does not change from the Level 7 

to the Level 8 scenario. The only difference between values for increased CFC 

consumption between these two scenarios results from the difference in the 

number of appliances sold. Values for CFC increases in the Level 8 scenario are 

listed in Table 6. 

4 SMALL GAS FURNACES 

The effects considered in determining the environmental impacts of more 

efficient small gas furnaces are a decrease in electricity generated at fossil fuelburning power plants and decreases in gas and oil burned in homes. Small 

decreases in electricity consumption will occur as some households shift from electric heating to small gas furnaces. 

Although slight increases in shipments of small gas furnaces are expected, 

increases in the materials used in producing these furnaces will be offset by 

decreases in the the materials used in producing the larger furnaces and the electric heating devices that the small gas furnaces will replace. 

A change in furnace efficiency to 78% does not affect the emissions from gas 

or oil burned in these furnaces. Although changes in emissions rates may occur 

along with condensation of some of the vapor in the flue gases, this condensation 

does not occur until efficiencies in the range of 82-84% are reached (De\Verth, 

1988). 

13 
4.0.1 Sulfur and Nitrogen Oxide Emissions

The decrease in SO2 emission resulting from the 78% AFUE standard

amounts to 110,000 tons between 1993 and 2015, as shown in Table 7. Annual

decreases in SO2 emissions amount to 2.4% and 4.2% of the emissions estimated

to come from residential fuel combustion during the years 2000 and 2010, respectively if no new efficiency standards are adopted.

NO2 emissions avoided between 1993 and 2010 amount to 80,000 tons. Annual

percent decreases for the years 2000 and 2010 are 0.6% and 1.3% of U.S. NO2

emissions from residential fuel combustion, respectively assuming no new appliance standards are established.

4.0.2 Carbon Dioxide Emissions

Decreases in CO2 emissions resulting from increased small gas furnace

efficiencies add up to 8.5 tons of carbon through the year 2015. The greatest

annual savings, achieved in the later years of the period studied, are about one

ten-thousandth of 1985 global CO2 emissions.

5 TELEVISION SETS

The television efficiency Level 3 scenario, which offers the greatest energy savings for televisions, decreases electricity use by about 0.73 quadrillion Btus for the

years 1992 through 2015. These electricity savings translate into cumulative savings of 309,000 tons of SO2 and 193,000 tons of NO2. These reductions are each

about 10% of the corresponding reductions from Level 8 refrigerator-freezer and

freezer efficiencies.

However, the proposed no standard for televisions results in no impact on the

environment since it will not change the status quo. DOE is unaware of any state

or local energy conservation standard concerning television sets that would be

preempted by the "no standard" standard. The only state standard of which

DOE is aware is the New York State standard that bans the "instant on" feature

of tube type televisions. However, since tube type television sets are no longer

manufactured, such standards currently have no effect.

14

CE-RM-87-102 COMMENT 05

4.0.1 Sulfur and Nitrogen Oxide Emissions 

The decrease in S02 emissioIlil resulting from the 78% AFUE standard 

amounts to 110,000 tons between 1993 and 2015, as shown in Table 7. Annual 

decreases in S02 emissions amount to 2.4% and 4.2% of the emissions estimated 

to come from residential fuel combustion during the years 2000 and 2010, respectively if no new efficiency standards are adopted. 

N02 emissions avoided between 1993 and 2010 amount to 80,000 tons. Annual 

percent decreases for the years 2000 and 2010 are 0.6% and 1.3% of U.S. N02 

emissions from residential fuel combustion, respectively assuming no new appliance standards are established. 

4.0.2 Carbon Dioxide Emissions 

Decreases in CO2 emissions resulting from increased small gas furnace 

efficiencies add up to 8.5 tons of carbon through the year 2015. The greatest 

annual savings, achieved in the later years of the period studied, are about one 

ten-thousandth of 1985 global CO2 emissions. 

5 TELEVISION SETS 

The television efficiency Level 3 scenario, which offers the greatest energy savings for televisions, decreases electricity use by about 0.73 quadrillion Btus for the 

years 1992 through 2015. These electricity savings translate into cumulative savings of 309,000 tons of S02 and 193,000 tons of N02. These reductions are each 

about 10% of the corresponding reductions from Level 8 refrigerator-freezer and 

freezer efficiencies. 

However, the proposed no standard for televisions results in no impact on the 

environment since it will not change the status quo. DOE is unaware of any state 

or local energy conservation standard concerning television sets that would be 

preempted by the "no standard" standard. The only state standard of which 

DOE is aware is the New York State standard that bans the "instant on" feature 

of tube type televisions. However, since tube type television sets are no longer 

manufactured, such standards currently have no effect. 

14 
6 EVALUATION OF ENVIRONMENTAL IMPACTS

6.1 Valuing Decreases in Acid Precipitation

Sulfur dioxide is the major contributor to acid precipitation in the U.S. After

a series of reactions with atmospheric gases and water, SO2 forms sulfuric acid.

More than half of the domestic S02 emitted as a result of human activities comes

from coal burned in power plants. The next greatest contributor to acid precipitation is nitrogen dioxide. One-third of the domestic NO2 emitted from human

activities comes from electricity generating facilities (Placet, 1986).

Attaching values to incremental changes in acid precipitation is difficult. The

effects of acid deposition on a given lake or forest depend on a variety of factors,

including distance from pollutant source, buffering capacity, surrounding topography, rate of snow melt, soil or sediment type, etc. Acid precipitation can have

negligible effects in buffered natural systems-those containing substances that

take up or react with acids-until the buffering capacity is used up. Continued

acid precipitation brings water and forest ecosystems closer to their buffering

capacity limits, which can greatly affect living systems. Allowing a body of water

to return to its natural state of alkalinity (buffering capacity) may require tens to

thousands of years. In attempting to quantify the effects of acid precipitation, it

is therefore important to consider cumulative effects that may not currently be

obvious.

Some effects on humans resulting from adding acid to ecosystems are:

decreases in fishing productivity, forest productivity, farming productivity,

recreational opportunities, and the degradation of susceptible buildings and

monuments.

6.2 Perspectives on Changes in Carbon Dioxide Emissions

Atmospheric CO0 is relatively transparent to incoming solar energy (shortwave radiation) but impedes outgoing solar energy, which is in the form of heat

(long -wave radiation). The net result of elevated COQ, concentrations is a trapping of heat near the Earth's surface. This trapping of heat, referred to as the

"greenhouse effect", raises the mean global temperature. Because of human

activity, the CO9 concentrations in the atmosphere have increased from 290 parts

per million (ppm) before the industrial era to about 335 ppm in 1979. Expected

15

CE-RM-87-102 COMMENT 05

6 EVALUATION OF ENVIRONMENTAL IMPACTS 

6.1 Valuing Decreases in Acid Precipitation 

Sulfur dioxide is the major contributor to acid precipitation in the U.S. After 

a series of reactions with atmospheric gases and water, S02 forms sulfuric acid. 

More than half of the domestic S02 emitted as a result of human activities comes 

from coal burned in power plants. The next greatest contributor to acid precipitation is nitrogen dioxide. One-third of the domestic N02 emitted from human 

activities comes from electricity generating facilities (Placet, 1986). 

Attaching values to incremental changes in acid precipitation is difficult. The 

effects of acid deposition on a given lake or forest depend on a variety of factors, 

including distance from pollutant source, buffering capacity, surrounding topography, rate of snow melt, soil or sediment type, etc. Acid precipitation can have 

negligible effects in buffered natural systems-those containing substances that 

take up or react with acids-until the buffering capacity is used up. Continued 

acid precipitation brings water and forest ecosystems closer to their buffering 

capacity limits, which can greatly affect living systems. Allowing a body of water 

to return to its natural state of alkalinity (buffering capacity) may require tens to 

thousands of years. In attempting to quantify the effects of acid precipitation, it 

is therefore important to consider cumulative effects that may not currently be 

obvious. 

Some effects on humans resulting from adding acid to ecosystems are: 

decreases in fishing productivity, forest productivity, farming productivity, 

recreational opportunities, and the degradation of susceptible buildings and 

monuments. 

6.2 Perspectives on Changes in Carbon Dioxide Emissions 

Atmospheric CO2 is relatively transparent to incoming solar energy (shortwave radiation) but impedes outgoing solar energy, which is in the form of heat 

(long-wave radiation). The net result of elevated CO2 concentrations is a trapping of heat near the Earth's surface. This trapping of heat, referred to as the 

"greenhouse effect", raises the mean global temperature. Because of human 

?,ctivity, the CO2 concentrations in the atmosphere have increased from 290 parts 

per million (ppm) before the industrial era to about 335 ppm in 1979. Expected 

15 
results of a global temperature change are : perturbed air and ocean currents, perturbed precipitation patterns, changes in the gaseous equilibrium between the

atmosphere and the biosphere, and^the melting of some of the ice now covering

polar lands and oceans followed by a rise in sea level (Council on Environmental

Quality, 1981).

A doubling of the pre-industrial levels of CO,, is projected to occur in the late

part of the next century. The process of controlling CO2 concentrations is dependent on two time determinants: lead times involved in changing current trends in

fossil fuel use and lag times in environmental systems. If the goal were to keep

CO2 concentrations from exceeding 500 ppm, even a growth rate in fossil fuel use

of 1.5% per year (compared to a growth rate of 2.3% in 1980) could not continue

much beyond the end of this century (Clark, 1982).

6.3 Perspectives on Changes in Chlorofluorocarbon Consumption

Chlorofluorocarbon use could upset the atmospheric equilibrium of ozone, a

compound that partially screens ultraviolet radiation entering the Earth's atmosphere. Increases in W radiation translate into increased risks of skin cancer in

humans, varied adverse effects on marine and terrestrial organisms and ecosystems, and a greater threat of altering global climatic patterns by contributing to

the greenhouse effect.

16

CE-RM-87-102 COMMENT 05

results of a global temperature change are: perturbed air and ocean currents, perturbed precipitation patterns, changes in the gaseous equilibrium between the .,~ ~ 

atmosphere and the biosphere, and the melting of some of the ice now covering 

polar lands and oceans followed by a rise in sea level (Council on Environmental 

Quality, 1QS1). 

A doubling of the pre-industrial levels of CO2 is projected to occur in the late 

part of the next century. The process of controlling CO2 concentrations is dependent on two time determinants: lead times involved in changing current trends in 

fossil fuel use and lag times in environmental systems. If the goal were to keep 

CO2 concentrations from exceeding 500 ppm, even a growth rate in fossil fuel use 

of 1.5% per year (compared to a growth rate of 2.3% in lQSO) could not continue 

much beyond the end of this century (Clark, 1QS2). 

6.3 Perspectives on Changes in Chlorofluorocarbon Consumption 

Chlorofluorocarbon use could upset the atmospheric equilibrium of ozone, a 

compound that partially screens ultraviolet radiation entering the Earth's atmosphere. Increases in UV radiation translate into increased risks of skin cancer in 

humans, varied adverse effects on marine and terrestrial organisms and ecosystems, and a greater threat of altering global climatic patterns by contributing to 

the greenhouse effect. 

16 
7 REFERENCES

NAECA 1987. National Appliance Energy Conservation Act, Public Law 100-12

U.S. Department of Energy. 1988. "Technical Support Document for the

Analysis of Efficiency Standards on Small Gas Furnaces, Television Sets, Refrigerators, Refrigerator-Freezers, and Freezers".

Placet M., D.G. Streets, E.R. Williams. 1986. "Environmental Trends Associated

with the Fifth National Energy Policy Plan," Argonne National Lab.

Harte, John. 1985. Consider a Spherical Cow, William Kaufmann, Inc., Los Altos

CA. p. 258.

Hammitt James K, Kathleen A. Wolf, Frank Camm, William E. Mooz, Timothy

H. Quinn, Anil Bamezai. 1986. "Product Uses and Market Trends for Potential

Ozone-Depleting Substances, 1985-2000," Rand, Santa Monica CA, R-3386-EPA.

U.S. Environmental Protection Agency. 1986. "National Air Pollutant Emission

Estimates, 1940-1984," EPA-450/4-85-014.

Oppenheimer, M. 1983. "The Relationship of Sulfur Emissions to Sulfate in Precipitation," Atmospheric Environment, Vol. 17.

Mooz W. E., S.H. Dole, D.L. Jaquette, W.H. Krase, P.F. Morrison, S.L. Salem,

R.G. Salter, K.A. Wolf. 1982. "Technical Options for Reducing

Chlorofluorocarbon Emissions," Rand Corporation, Santa Monica CA R-2879-

EPA.

DeWerth, Douglas. 1988. Personal communications on January 12 between Mr.

DeWerth (American Gas Association Laboratories) and Mr. Tim Springer

(Lawrence Berkeley Laboratory).

U.S. Council on Environmental Quality. 1981. "Fossil Fuels and the Effect of

Increasing Concentrations of Carbon Dioxide," Global Energy Futures and the

Carbon Dioxide Problem, Government Printing Office.

Clark, William C. 1982. Carbon Dioxide Review, Oxford University Press, New

York NY. pp. 357, 338.

U.S. Department of Commerce, Bureau of Economic Analysis. 1986. Survey of

Current Business, Vol. 66, No 7. p S-25. (July).

Surprenant N.F., R.R. Hall, K.T. McGregor, A.F. Werner. 1979. "Emissions

Assessment of Conventional Stationary Combustion Systems, Vol. 1, Gas & OilFired Residential Heating Sources," EPA 600 /7-79-029.

17

CE-RM-87-102 COMMENT 05

7 REFERENCES 

NAECA 1987. National A,pptiance Energy Conservation Act, Public Law 100-12 

U.S. Department of Energy. 1988. "Technical Support Document for the 

Analysis of Efficiency Standards on Small Gas Furnaces, Television Sets, Refrigerators, Refrigerator-Freezers, and Freezers". 

Placet M., D.G. Streets, E.R. vVilliams. 1986. "Environmental Trends Associated 

with the Fifth National Energy Policy Plan," Argonne National Lab. 

Harte, John. 1985. Consider a Spherical Cow, William Kaufmann, Inc., Los Altos 

CA. p. 258. 

Hammitt James K, Kathleen A. Wolf, Frank Camm, William E. Mooz, Timothy 

H. Quinn, Anil Bamezai. 1986. "Product Uses and Market Trends for Potential 

Ozone-Depleting Substances, 1985-2000," Rand, Santa Monica CA, R-3386-EP A. 

U.S. Environmental Protection Agency. 1986. "National Air Pollutant Emission 

Estimates, 1940-1984," EPA-450/4-85-014. 

Oppenheimer, M. 1983. "The Relationship of Sulfur Emissions to Sulfate in Precipitation," Atmospheric Environment, Vol. 17. 

Mooz W. E., S.H. Dole, D.L. Jaquette, W.H. Krase, P .F. Morrison, S.L. Salem, 

R.G. Salter, K.A. vVolf. 1982. "Technical Options for Reducing 

Chlorofluorocarbon Emissions," Rand Corporation, Santa Monica CA R-2879-

EPA. 

DevVerth, Douglas. 1988. Personal communications on January 12 between Mr. 

DeWerth (American Gas Association Laboratories) and Mr. Tim Springer 

(Lawrence Berkeley Laboratory). 

U.S. Council on Environmental Quality. 1981. "Fossil Fuels and the Effect of 

Increasing Concentrations of Carbon Dioxide," Global Energy FubLres and the 

Carbon Dioxide Problem, Government Printing Office. 

Clark, William C. 1982. Carbon Dioxide Review, Oxford University Press, New 

York NY. pp. 357, 338. 

U.S. Department of Commerce, Bureau of Economic Analysis. 1986. Survey of 

Current Business, Vol. 66, No 7. p S-25. (July). 

Surprenant N.F., R.R. Hall, K.T. McGregor, A.F. vVerner. 1979. "Emissions 

Assessment of Conventional Stationary Combustion Systems, Vol. 1, Gas & OilFired Residential Heating Sources," EPA 600/7-79-029. 

17 
Association of Home Appliance Manufacturers. 1987. "Appliance Energy

Efficiency Realities ... With a New Wrinkle," presented by John T. Weizeorick at

the ACEEE National Conference `oi Appliance Efficiency, Arlington VA.

Roman, Paul. 1987. Personal communications on October 15 between Mr. Roman

(Association of Homes Appliance Manufacturers) and Dr. James E. McMahon

(Lawrence Berkeley Laboratory) regarding projections for market shares of refrigerator and freezer models.

California Energy Commission. 1987. "Directory of Certified Refrigerators and

Refrigerator-freezers."

Association of Home Appliance Manufacturers. 1986. "Trends and Forecasts, Factory Unit Shipments (Domestic & Export) of Major Appliances," Chicago IL.

North American Electric Reliability Council, 1985. "1985 Electric Power Supply

and Demand--For 1984 to 1994".

18

CE-RM-87-102 COMMENT 05

Association of Home Appliance Manufacturers. 1987. "Appliance Energy 

Efficiency Realities ... With a New Wrinkle," presented by John T. Weizeorick at 

the ACEEE National Conferenc~'on" Appliance Efficiency, Arlington VA. 

Roman, Paul. 1987. Personal communications on October 15 between Mr. Roman 

(Association of Homes Appliance Manufacturers) and Dr. James E. McMahon 

(Lawrence Berkeley Laboratory) regarding projections for market shares of refrigerator and freezer models. 

California Energy Commission. 1987. "Directory of Certified Refrigerators and 

Refrigerator-freezers." 

Association of Home Appliance Manufacturers. 1986. "Trends and Forecasts, Factory Unit Shipments (Domestic & Export) of Major Appliances," Chicago 1L. 

North American Electric Reliability Council, 1985. "1985 Electric Power Supply 

and Demand--For 1984 to 1994". 

18 
Table 1. Refrigerators and Freezers - Level Three

Changes in Sulfur and Nitrogen Dioxide Emissions

so 2

Year

1995

2000

2005

2010

2015

NO2

Year

Abated

From

Coal

Generation

(tons)

Abated

From

Gas & Oil

Generation

(tons)

From

Increased

Steel

Production

(tons)

Net

Change

(tons)

Percent of

Annual

U.S. SO2

Power Plant

Emissions

-18,700 -2,900 +19 -21,600 -0.13

-46,200 -7,800 +18 -54,000 -0.30

-64,500 -13,700 +16 -78,100 -0.45

-78,200 -17,800 +20 -96,000 -0.56

-78,200 -20,000 +29 -100,000 -0.62

Cumulative SO2 reduction, 1993-2015 = 1,540,000 tons.

Abated

From

Abated

From

From

Increased

Net

Change

Percent of

Annual

Coal Gas & Oil Steel U.S. NO9

Generation

(tons)

Generation

(tons)

Production

(tons) (tons)

Power Plant

Emissions

1995 -8,500 -3,400 - -11,800 -0.14

2000 -22,100 -9,100 - -31,200 -0.35

2005 -34,400 -15,000 - -49,400 -0.51

2010 -46,200 -17,800 - -64,000 -0.62

2015 -51,900 -21,500 - -73,400 -0.69

Cumulative NO9 reduction, 1993-2015 = 996,000 tons.

19

CE-RM-87-102 COMMENT 05

8°2 

Year 

1995 

2000 

2005 

2010 

2015 

N02 

Year 

1005 

2000 

2005 

2010 

2015 

Table 1. Refrigerators and Freezers - Level Three 

Changes in Sulfur and Nitrogen Dioxide Emissions 

" ~ :..r 

Abated Abated From Net Percent of 

From From Increased Change Annual 

Coal Gas & Oil Steel U.S. S02 

Generation Generation Production Power Plant 

(tons) (tons) (tons) (tons) Emissions 

-18,700 -2,900 +19 -21,600 -0.13 

-46,200 -7,800 +18 -54,000 -0.30 

-64,500 -13,700 +16 -78,100 -0.45 

-78,200 -17,800 +20 -96,000 -0.56 

-78,200 -20,000 +29 -100,000 -0.62 

Cumulative 802 reduction, 1993-2015 = 1,540,000 tons. 

Abated Abated From Net Percent of 

From From Increased Change Annual 

Coal Gas & Oil Steel U.S. N02 

Generation Generation Production Power Plant 

(tons) (tons) (tons) (tons) Emissions 

-8,500 -3,400 -11,800 -0.14 

-22,100 -0,100 -31,200 -0.35 

-34,400 -15,000 -40,400 -0.51 

-46,200 -17,800 -64,000 -0.62 

-51,000 -21,500 -73,400 -0.60 

Cumulative NOz reduction, H)93-2015 = 996,000 tons. 

19 
Table 2. Refrigerators and Freezers - Level Three

Changes in Carbon Dioxide and Chlorofluorocarbon Emissions

CO2

Thousands of Tons of Carbon

Abated Abated Abated Net

From From From Change Percent of

Coal Gas Oil 1985 World

Year Generation Generation Generation Emissions

1995 -617 -219 -120 -957 -0.02

2000 -1,670 -593 -326 -2,590 -0.04

2005 -2,740 -972 -534 -4,240 -0.07

2010 -3,770 -1,340 -735 -5,840 -0.10

2015 -4,390 -1,560 -855 -6,800 -0.12

Cumulative CO2 reduction, 1993-2015 = 88 million tons of carbon.

CFC

All CFC values expressed in pounds of R-11 equivalent.

Increase Increase Net Percent of

From From Change U.S. 1985

Design Increased R-11

Year Changes Shipments & R-12*

1995 +2,400,000 +275,000 +2,670,000 +0.58

2000 +2,400,000 +254,000 +2,650,000 +0.57

2005 +2,520,000 +227,000 +2,740,000 +0.59

2010 +2,800,000 +289,000 +3,090,000 +0.67

2015 +2,980,000 +407,000 +3,390,000 40.73

Cumulative CFC increase, 1993-2015 = 66 million pounds of R-11 equivalent.

* Sum of estimated U.S. use of R-11 and R-12 (Hammitt, 198G).

20

CE-RM-87-102 COMMENT 05

CO2 

Year 

1995 

2000 

2005 

2010 

2015 

CFC 

Year 

1995 

2000 

2005 

2010 

2015 

Table 2. Refrigerators and Freezers - Level Three 

Changes in Carbon DiQ{Ciq.e and Chlorofluorocarbon Emissions 

Abated 

From 

Coal 

Generation 

-617 

-1,670 

-2,740 

-3,770 

-4,390 

Thousands of Tons of Carbon 

Abated Abated Net 

From From Change 

Gas Oil 

Generation Generation 

-219 -120 -957 

-593 -326 -2,590 

-972 -534 -4,240 

-1,340 -735 -5,840 

-1,560 -855 -6,800 

Percent of 

1985 World 

Emissions 

-0.02 

-0.04 

-0.07 

-0.10 

-0.12 

Cumulative CO2 reduction, 1993-2015 = 88 million tons of carbon. 

All CFC values expressed in pounds of R-ll equivalent. 

Increase Increase Net Percent of 

From From Change U.S. 1985 

Design Increased R-ll 

Changes Shipments & R-12* 

+2,400,000 +275,000 +2,670,000 +0.58 

+2,400,000 +254,000 +2,650,000 +0.57 

+2,520,000 +227,000 +2,740,000 +0.59 

+2,800,000 +289,000 +3,090,000 +0.67 

+2,980,000 +407,000 +3,390,000 +0.73 

Cumulative CFC increase, 1993-2015 = 66 million pounds of R-ll equivalent. 

* Sum of estimated U.S. use of R-ll and R-12 (Hammitt, 1986). 

20 
Table 3. Refrigerators and Freezers - Level Seven

Changes in Sulfur and Nitrogen Dioxide Emissions

SO2

Year

1995

2000

2005

2010

2015

NO2

Year

1995

2000

2005

2010

2015

Abated

From

Coal

Generation

(tons)

Abated

From

Gas Si Oil

Generation

(tons)

From

Increased

Steel

Production

(tons)

Net

Change

(tons)

Percent of

Annual

U.S. S02

Power Plant

Emissions

-35,400 -5,500 +33 -40,800 -0.24

-87,400 -14,800 +32 -102,000 -0.57

-122,000 -25,800 +28 -148,000 -0.84

-148,000 -33,700 +35 -181,000 -1.06

-151,000 -37,800 +50 -188,000 -1.17

Cumulative SO2 reduction, 1993-2015 = 2,910,000 tons.

Abated

From

Coal

Generation

(tons)

Abated From

From Increased

Gas & Oil Steel

Generation Production

(tons) (tons)

Net

Change

tons)

Percent of

Annual

U.S. NO2

Power Plant

Emissions

- 16,000 - 6,400 - -22,300 -0.27

-41,800 -17,200 - - 59,000 -0.66

-64,900 -28,400 - -73,300 -0.97

-87,200 -33,700 - - 120,000 -1.18

-98,200 -40,700 - -139 , 000 -1.30

Cumulative NO2 reduction, 1993-2015 = 1,880,000 tons.

21

CE-RM-87-102 COMMENT 05

Table 3. Refrigerators and Freezers - Level Seven 

Changes in 8)!lfur and Nitrogen Dioxide Emissions 'j ~ 

8°2 

Abated Abated From Net Percent of 

From From Increased Change Annual 

Coal Gas & Oil Steel U.S. S02 

Generation Generation Production Power Plant 

Year (tons) (tons) (tons) (tons) Emissions 

1995 -35,400 -5,500 +33 -40,800 -0.24 

2000 -87,400 -14,800 +32 -102,000 -0.57 

2005 -122,000 -25,800 +28 -148,000 -0.84 

2010 -148,000 -33,700 +35 -181,000 -1.06 

2015 -151,000 -37,800 +50 -188,000 -1.17 

Cumulative S02 reduction, 1993-2015 = 2,91O,000 tons. 

N02 

Abated Abated From Net Percent of 

From From Increased Change Annual 

Coal Gas & Oil Steel U.S. N02 

Generation Generation Production Power Plant 

Year (tons) (tons) (tons) (tons) Emissions 

1995 -16,000 -6,400 -22,300 -0.27 

2000 -41,800 -17,200 -59,000 -0.66 

2005 -64,900 -28,400 -73,300 -0.97 

2010 -87,200 -33,700 -120,000 -1.18 

2015 -98,200 -40,700 -139,000 -1.30 

Cumulative N02 reduction, 1993-2015 = 1,880,000 tons. 

21 
Table 4. Refrigerators and Freezers - Level Seven

Changes in Carbon Dioxide and Chlorofluorocarbon Emissions 11 1

CO2

Thousands of Tons of Carbon

Abated Abated Abated Net

From From From Change Percent of

Coal Gas Oil 1985 World

Year Generation Generation Generation Emissions

1995 -1,170 -414 -228 -1,810 -0.03

2000 -3,170 -1,120 -617 -4,900 -0.08

2005 -5,180 -1,840 -1,010 -8,020 -0.14

2010 -7,120 -2,530 -1,390 -11,000 -0.19

2015 -8,300 -2,940 -1,620 -12,900 -0.22

Cumulative CO2 reduction, 1993-2015 = 166 million tons of carbon.

CFC

All CFC values expressed in pounds of R-11 equivalent.

Increase Increase Net Percent of

From From Change U.S.1985

Design Increased R-11

Year Changes Shipments & R-12*

1995 +3,650,000 +496,000 +4,150,000 +0.90

2000 +3,660,000 +460,000 +4,120,000 +0.89

2005 +3,830,000 +412,000 +4,240,000 +0.92

2010 +4,260,000 +524,000 +4,780,000 +1.03

2015 +4,530,000 +742,000 +5,280,000 +1.14

Cumulative CFC increase, 1993-2015 = 102 million pounds of R-11 equivalent.

* Sum of estimated U.S. use of R-11 and R-12 (Hammitt, 1986).

CE-RM-87-102 COMMENT 05

CO2 

Year 

1995 

2000 

2005 

2010 

2015 

CFC 

Year 

1995 

2000 

2005 

2010 

2015 

Table 4. Refrigerators and Freezers - Level Seven 

Changes in Carbon Dioxid_e and Chlorofluorocarbon Emissions : ~ '\; 

Abated 

From 

Coal 

Generation 

-1,170 

-3,170 

-5,180 

-7,120 

-8,300 

Thousands of Tons of Car bon 

Abated Abated Net 

From From Change 

Gas Oil 

Generation Generation 

-414 -228 -1,810 

-1,120 -617 -4,900 

-1,840 -1,010 -8,020 

-2,530 -1,390 -11,000 

-2,940 -1,620 -12,900 

Percent of 

1985 World 

Emissions 

-0.03 

-0.08 

-0.14 

-0.19 

-0.22 

Cumulative CO2 reduction, 1993-2015 = 166 million tons of carbon. 

All CFC values expressed in pounds of R-ll equivalent. 

Increase Increase Net Percent of 

From From Change U.S. 1985 

Design Increased R-ll 

Changes Shipments & R-12* 

+3,650,000 +496,000 +4,150,000 +0.90 

+3,660,000 +460,000 +4,120,000 +0.89 

+3,830,000 +±12,000 +4,240,000 +0.92 

+4,260,000 +524,000 +4,780,000 +1.03 

+4,530,000 +742,000 +5,280,000 +1.14 

Cumulative CFC increase, 1993-2015 = 102 million pounds of R-ll equivalent. 

* Sum of estimated U.S. use of R-ll and R-12 (Hammitt, 1986). 

22 
Table 5. Refrigerators and Freezers - Level Eight

Changes in Sulfur and Nitrogen Dioxide Emissions

so 2

Year

1995

2000

2005

2010

2015

NO2

Year

Abated Abated From Net

From From Increased Change

Coal Gas & Oil Steel

Generation Generation Production

(tons) (tons) (tons) (tons)

Percent of

Annual

U.S. SO2

Power Plant

Emissions

-39,300 -6,100 +36 -45,400 -0.26

-97,200 -16,400 +34 -113,000 -0.63

-135,000 -28,700 +30 -164,000 -0.94

-164,000 -37,400 +38 -202,000 -1.18

-167,000 -42,000 +54 -209,000 -1.30

Cumulative SO2 reduction, 1993-2015 = 3,240,000 tons.

Abated Abated From Net Percent of

From From Increased Change Annual

Coal Gas & Oil Steel U.S. NO2

Generation Generation Production Power Plant

(tons) (tons) (tons) (tons) Emissions

1995 -17,800 -7,100 - -24,800 -0.30

2000 -46,400 -19,200 - -65,600 -0.73

2005 -72,200 -31,500 - -104,000 -1.08

2010 -96,900 -37,400 - -134,000 -1.31

2015 -109,000 -45,200 - -154,000 -1.45

Cumulative NO9 reduction, 1993-2015 = 2,000,000 tons.

23

CE-RM-87-102 COMMENT 05

Table 5. Refrigerators and Freezers - Level Eight 

Changes in SJJ-Ifur and Nitrogen Dioxide Emissions ';.. ~ 

5°2 

Abated Abated From Net Percent of 

From From Increased Change Annual 

Coal Gas & Oil Steel U.S. S02 

Generation Generation Production Power Plant 

Year (tons) (tons) (tons) (tons) Emissions 

1995 -39,300 -6,100 +36 -45,400 -0.26 

2000 -97,200 -16,400 +34 -113,000 -0.63 

2005 -135,000 -28,700 +30 -164,000 -0.94 

2010 -164,000 -37,400 +38 -202,000 -1.18 

2015 -167,000 -42,000 +54 -209,000 -1.30 

Cumulative S02 reduction, 1993-2015 = 3,240,000 tons. 

N02 

Abated Abated From Net Percent of 

From From Increased Change Annual 

Coal Gas & Oil Steel U.S. N02 

Generation Generation Production Power Plant 

Year (tons) (tons) (tons) (tons) Emissions 

1995 -17,800 -7,100 -2-1:,800 -0.30 

2000 -46,400 -19,200 -65,600 -0.73 

2005 -72,200 -31,500 -10-1:,000 -1.08 

2010 -96,900 -37,400 -13-1:,000 -1.31 

2015 -109,000 -45,200 -15-1:,000 -1.45 

Cumulative N02 reduction, 1993-2015 = 2,090,000 tons. 

23 
Table 6. Refrigerators and Freezers - Level Eight

Changes in Carbon Dioxide and Chlorofluorocarbon Emissions

C ot

Thousands of Tons of Carbon

Abated Abated Abated Net

From From From Change Percent of

Coal Gas Oil 1985 World

Year Generation Generation Generation Emissions

1995 -1,300 -460 -253 -2,010 -0.03

2000 -3,520 -1,230 -686 -5,450 -0.09

2005 -5,750 -2,040 -1,120 -8,920 -0.15

2010 -7,920 -2,810 -1,540 -12,300 -0.21

2015 -9,230 -3,270 -1,800 -14,300 -0.24

Cumulative CO. reduction, 1993-2015 = 185 million tons of carbon.

CFC

All CFC values expressed in pounds of R-11 equivalent.

Increase Increase Net Percent of

From From Change U.S. 1985

Design Increased R-11

Year Changes Shipments & R-12*

1995 +3,650,000 +528,000 +4,180,000 +0.90

2000 +3,660,000 +490,000 +4,150,000 +0.90

2005 +3,830,000 +440,000 +4,270,000 +0.92

2010 +4,260,000 +561,000 +4,820,000 +1.04

2015 +4,530,000 +796,000 +5,330,000 +1.15

Cumulative CFC increase, 1993-2015 = 103 million pounds of R-11 equivalent.

* Sum of estimated U.S. use of R-11 and R-12 (Hammitt, 1986).

24

CE-RM-87-102 COMMENT 05

CO2 

Year 

1995 

2000 

2005 

2010 

2015 

CFC 

Year 

1995 

2000 

2005 

2010 

2015 

Table 6. Refrigerators and Freezers - Level Eight 

Changes in Carbon Dioxide and Chlorofluorocarbon Emissions 

Abated 

From 

Coal 

Generation 

-1,300 

-3,520 

-5,750 

-7,920 

-9,230 

~.,f 

Thousands of Tons of Carbon 

Abated Abated Net 

From From Change 

Gas Oil 

Generation Generation 

-460 -253 -2,010 

-1,230 -686 -5,450 

-2,040 -1,120 -8,920 

-2,810 -1,540 -12,300 

-3,270 -1,800 -14,300 

Percent of 

1985 vVorld 

Emissions 

-0.03 

-O.Og 

-0.15 

-0.21 

-0.24 

Cumulative CO2 reduction, 1993-2015 = 185 million tons of carbon. 

All CFC values expressed in pounds of R-ll equivalent. 

Increase Increase Net Percent of 

From From Change U.S. 1985 

Design Increased R-ll 

Changes Shipments & R-12* 

+3,650,000 +528,000 +4,180,000 +0.90 

+3,660,000 +490,000 +4,150,000 +0.90 

+3,830,000 +440,000 +4,270,000 +0.92 

+4,260,000 +561,000 +4,820,000 +1.04 

+4,530,000 +796,000 +5,330,000 +1.15 

Cumulative CFC increase, 1993-2015 = 103 million pounds of R-ll equivalent. 

* Sum of estimated U.S. use of R-ll and R-12 (Hammitt, Hl86). 

2-1 
Table 7. 78% Efficient Small Gas Furnaces

Changes in Sulfur and Nitrogen Dioxide Emissions .11 -Z

so2

Year

1995

2000

2005

2010

2015

Abated

From

Coal

Generation

(tons)

Abated

From

Gas & Oil

Generation

(tons)

Abated

From

In-home

Combustion

(tons)

Net

Change

U.S. SO2

Residential

(tons)

Percent of

Annual

Emissions

-1,200 -200 -11 -1,500 -0.9

-3,300 -600 -22 -3,900 -2.4

-4,800 -1,000 -34 -5,800 -3.6

-5,500 -1,300 -46 -6,800 -4.2

-5,300 -1,300 -3 -6,600 -4.1

Cumulative SO2 reduction, 1993-2015 = 110,000 tons.

NO2

ear

Abated

From

Coal

Generation

(tons)

Abated

From

Gas & Oil

Generation

(tons)

Abated

From

In-home

Combustion

(tons)

Net

Change

U.S. NO2

Residential

(tons)

Percent of

Annual

Emissions

1995 -600 -200 -92 -900 -0.2

2000 -1,600 -600 -217 -2,400 -0.6

2005 -2,600 -1,100 -409 -4,100 -1.0

2010 -3,200 -1,300 -648 -5,100 -1.3

2015 -3,500 -1,400 -894 -5,800 -1.5

Cumulative NO2 reduction, 1993-2015 = 80,000 tons.

25

CE-RM-87-102 COMMENT 05

Table 7. 78% Efficient Small Gas Furnaces 

Changes in Sulfur and Nitrogen Dioxide Emissions ; ... - ~ 

8°2 

Abated Abated Abated Net Percent of 

From From From Change Annual 

Coal Gas & Oil In-home U.S. S02 

Generation Generation Combustion Residential 

Year (tons) (tons) (tons) (tons) Emissions 

1995 -1,200 -200 -11 -1,500 -0.9 

2000 -3,300 -600 -22 -3,900 -2.4 

2005 -4,800 -1,000 -34 -5,800 -3.6 

2010 -5,500 -1,300 -46 -5,800 -4.2 

2015 -5,300 -1,300 -3 -6,600 -4.1 

Cumulative S02 reduction, 1993-2015 = 110,000 tons. 

N02 

Abated Abated Abated Net Percent of 

From From From Change Annual 

Coal Gas & Oil In-home U.S. N02 

Generation Generation Combustion Residential 

Year (tons) (tons) (tons) (tons) Emissions 

1995 -500 -200 -92 -900 -0.2 

2000 -1,500 -500 -217 -2,400 -0.5 

2005 -2,600 -1,100 -409 -4,100 -1.0 

2010 -3,200 -1,300 -648 -5,100 -1.3 

2015 -3,500 -1,400 -894 -5,800 -1.5 

Cumulative N02 reduction, 1993-2015 = 80,000 tons. 

25 
Table 8. 78% AFUE Small Gas Furnaces

Changes in Carbon Dioxide Emissions

CO2

Thousands of Tons of Carbon

ear

Abated

From

Coal

Generation

Abated

From

Gas

Generation

Abated

From

Oil

Generation

Net

Change Percent of

1985 World

Emissions

1995 -41 -35 -10 -87 -0.001

2000 -119 -92 -27 -238 -0.004

2005 -203 -166 -46 -415 -0.007

2010 -265 -244 -60 -569 -0.010

2015 -292 -317 -71 -680 -0.012

Cumulative CO2 reduction, 1993-2015 = 8.5 million tons of carbon.

26

CE-RM-87-102 COMMENT 05

CO2 

Year 

1995 

2000 

2005 

2010 

2015 

Table 8. 78% AFUE Small Gas Furnaces 

Changes i:o. C~rbon Dioxide Emissions ., ~ 

Thousands of Tons of Carbon 

Abated Abated Abated Net 

From From From Change 

Coal Gas Oil 

Generation Generation Generation 

-41 -35 -10 -87 

-119 -92 -27 -238 

-203 -166 -46 -415 

-265 -244 -60 -569 

-292 -317 -71 -680 

Percent of 

1985 World 

Emissions 

-0.001 

-0.004 

-0.007 

-0.010 

-0.012 

Cumulative CO2 reduction, 1993-2015 = 8.5 million tons of carbon. 

26 
Appendix A. Estimated Dimensions of Foamed Areas

in Refrigerator-Freezers and Freezers

Foamed Dimension Product Class*

Area

A B C D E F

Measurement in inches

Refrigerator height 39.5 36 38 60.5 - -

Door width 24 28 28 20 - -

Freezer height 11 19 16 60.5 16 28

Door width 24 28 28 12 28 36

Refrigerator height 38 35 40 58.5 - -

Cabinet width 22 26 30 20 - -

depth 26 23 24 24 - -

Freezer height 12 19 18 58.5 55 32

Cabinet width 22 26 30 12 26 24

depth 26 23 24 24 21 26

* Product Class

A: Manual Defrost

B: Partially Automatic Defrost

C: Top Mounted Freezer, Automatic Defrost

Top Mounted Freezer, Automatic Defrost, Through-the-Door Ice

Bottom Mounted Freezer, Automatic Defrost

D: Side-by-Side Refrigerator-Freezers

Side-by-Side Refrigerator-Freezers, Through-the-Door Ice

E: Upright Freezer, Manual Defrost

Upright Freezer, Automatic Defrost

F: Chest Freezer

27

CE-RM-87-102 COMMENT 05

Foamed 

Area 

Refrigerator 

Door 

Freezer 

Door 

Refrigerator 

Cabinet 

Freezer 

Cabinet 

A: 

B: 

C: 

Appendix A. Estimated Dimensions of Foamed Areas 

in Refrlgerator-Freezers and Freezers 

Dimension Product Class* 

A B C D 

Measurement in inches 

height 39.5 36 38 60.5 

width 24 28 28 20 

height 11 19 16 60.5 

width 24 28 28 12 

height 38 35 40 58.5 

width 22 26 30 20 

depth 26 23 24 24 

height 12 19 18 58.5 

width 22 26 30 12 

depth 26 23 2~ 2~ 

* Product Class 

Manual Defrost 

Partially Automatic Defrost 

Top Mounted Freezer, Automatic Defrost 

E F 

- -

- -

16 28 

28 36 

- -

- -

- -

55 32 

26 24 

21 26 

Top Mounted Freezer, Automatic Defrost, Through-the-Door Ice 

Bottom Mounted Freezer, Automatic Defrost 

D: Side- by-Side Refrigerator-Freezers 

Side-by-Side Refrigerator-Freezers, Through-the-Door Ice 

E: Upright Freezer, Manual Defrost 

Upright Freezer, Automatic Defrost 

F: Chest Freezer 

27 
DEPARTMENT OF ENERGY

Office of Conservation and Renewable Energy

10 CFR Part 430

Energy Conservation Program for Consumer Products

AGENCY: Department of Energy.

ACTION: Finding of No Significant Impact (FONSI) on Proposed

Rulemaking for Energy Conservation Standards for 3 Types of Consumer

Products.

SUMMARY: The Energy Policy and Conservation Act (EPCA), as amended by

the National Energy Conservation Policy Act (NECPA) and the National

Appliance Energy Conservation Act (NAECA), prescribes energy

conservation standards for certain major household appliances, and

requires the Department of Energy (DOE) to administer an energy

conservation program for these products. As a general matter, these

Federal standards preempt State and local standards and any other

State and local requirements with respect to energy efficiency or

energy use of these products. Among other things, NAECA requires DOE

to consider amending the energy conservation standards for

refrigerators, refrigerator-freezers, and freezers; to establish

standards for small gas furnaces; and to consider establishing energy

conservation standards for television sets.

In accordance with NAECA, the Department has reviewed possible

standards for refrigerators, refrigerator-freezers and freezers, small

gas furnaces and television sets as discussed in today's notice of

proposed rulemaking.

1

CE-RM-87-102 COMMENT 05

DEPARTMENT OF ENERGY 

Office of Conservation and Renewable Energy 

10 CFR Part 430 

Energy Conservation Program for Consumer Products 

AGENCY: Department of Energy. 

ACTION: Finding of No Significant Impact (FONSI) on Proposed 

Rulemaking for Energy Conservation Standards for 3 Types of Consumer 

Products. 

SUMMARY: The Energy Policy and Conservation Act (EPCA), as amended by 

the National Energy Conservation Policy Act (NECPA) and the National 

Appliance Energy Conservation Act (NAECA), prescribes energy 

conservation standards for certain major household appliances, and 

requires the Department of Energy (DOE) to administer an energy 

conservation program for these products. As a general matter, these 

Federal standards preempt State and local standards and any other 

state and local requirements with respect to energy efficiency or 

energy use of these products. Among other things, NAECA requires DOE 

to consider amending the energy conservation standards for 

refrigerators, refrigerator-freezers, and freezers; to establish 

standards for small gas furnaces; and to consider establishing energy 

conservation standards for television sets. 

In accordance with NAECA, the Department has reviewed possible 

standards for refrigerators, refrigerator-freezers and freezers, small 

gas furnaces and television sets as discussed in today's notice of 

proposed rulemaking. 

1 
For refrigerators , refrigerator- freezers and freezers, the

Department is proposing a range of standards that includes not

increasing the stringency of the standard level. DOE is soliciting

comments and information from the public to be considered in

promulgating the final rule. As discussed in the proposed rule, the

final rule will specify a specific level for refrigerators,

refrigerator- freezers and freezers.

For small gas furnaces , the Department is proposing to determine

that standards would result in a significant conservation of energy

and be economically justified . Therefore, the Department is today

proposing to amend 10 CFR Part 430 to add standards for this product.

Finally, for television sets, the Department is proposing to

determine that an energy conservation standard would result in a

significant conservation of energy but would not be economically

justified . Therefore , the Department is proposing to amend Part 430

to include a determination of no standard for television sets.

Based on an Environmental Assessment (EA), DOE has determined

that none of the proposed standards , including the "no standard" for

television sets , are a major federal action significantly affecting

the quality of the human environment within the meaning of the

National Environmental Policy Act ( NEPA). Therefore an Environmental

Impact Statement will not be prepared. The EA is part of the

Technical Support Document for the proposed standards and is available

on request at the following address.

Public availability : Hearings and Dockets Branch, Office of

Conservation and Renewable Energy, U.S. Department of Energy , Docket

2

CE-RM-87-102 COMMENT 05

For refrigerators, refrigerator-freezers and freezers, the 

Department is proposing a range of standards that includes not 

increasing the stringency of the standard level. DOE is soliciting 

comments and information from the public to be considered in 

promulgating the final rule. As discussed in the proposed rule, the 

final rule will specify a specific level for refrigerators, 

refrigerator-freezers and freezers. 

For small gas furnaces, the Department is proposing to determine 

that standards would result in a significant conservation of energy 

and be economically justified. Therefore, the Department is today 

proposing to amend 10 CFR Part 430 to add standards for this product. 

Finally, for television sets, the Department is proposing to 

determine that an energy conservation standard would result in a 

significant conservation of energy but would not be economically 

justified. Therefore, the Department is proposing to amend Part 430 

to include a determination of no standard for television sets. 

Based on an Environmental Assessment (EA) , DOE has determined 

that none of the proposed standards, including the "no standard" for 

television sets, are a major federal action significantly affecting 

the quality of the human environment within the meaning of the 

National Environmental Policy Act (NEPA). Therefore an Environmental 

Impact Statement will not be prepared. The EA is part of the 

Technical Support Document for the proposed standards and is available 

on request at the following addre~s. 

Public availability: Hearings and Dockets Branch, Office of 

Conservation and Renewable Energy, U.S. Department of Energy, Docket 

2 
Number CE-RM-87-102, 1000 Independence Avenue, S.W., Room 6B-025,

Washington, DC 20585 ( 202) 586-9320.

FOR FURTHER INFORMATION CONTACT:

Michael J. McCabe

U.S. Department of Energy

Office of Conservation and Renewable Energy

Forrestal Building, Mail Station CE-132

1000 Independence Avenue, S.W.

Washington, D.C. 20585

(202) 586-9127

Donald E. Henninger

U.S. Department of Energy

Office of NEPA Project Assistance

Forrestal Building, Mail Station EH-25

1000 Independence Avenue, S.W.

Washington , DC 20585

(202) 586-4600

Martha S. Crosland

U.S. Department of Energy

Office of General Counsel

Forrestal Building, Mail Station GC-11

1000 Independence Avenue, S.W.

Washington, D.C. 20585

(202) 586-6947

SUPPLEMENTARY INFORMATION: DOE prepared an Environmental Assessment

(EA) on the proposed standards pursuant to the National Environmental

Policy Act of 1969, as amended, Pub. L. 91-190, 40 U.S.C. 4221 et seq,

and the implementing regulations of the Council on Environmental

Quality [40 CFR Parts 1500-1808]. The EA addresses the possible

incremental environmental effects attributable to the application of

the proposed standards to the design of refrigerators,

refrigerator- freezers , and freezers; and small gas furnaces. The EA

also looked at the impact of energy conservation standards for

television sets. As discussed in the General Findings, the "no

standard" standard for televisions will not change the status quo and

therefore will not result in any environmental impact. The effect of

3

CE-RM-87-102 COMMENT 05

Number CE-RM-87-102, 1000 Independence Avenue, S.W., Room 6B-025, 

Washington, DC 20585 (202) 586-9320. 

FOR FURTHER INFORMATION CONTACT: 

Michael J. McCabe 

U.S. Department of Energy 

Office of Conservation and Renewable Energy 

Forrestal Building, Mail station CE-132 

1000 Independence Avenue, S.W. 

Washington, D.C. 20585 

(202) 586-9127 

Donald E. Henninger 

U.s. Department of Energy 

Office of NEPA Project Assistance 

Forrestal Building, Mail Station EH-25 

1000 Independence Avenue, S.W. 

Washington, DC 20585 

(202) 586-4600 

Martha S. Crosland 

U.s. Department of Energy 

Office of General Counsel 

Forrestal Building, Mail station GC-11 

1000 Independence Avenue, S.W. 

Washington, D.C. 20585 

(202) 586-6947 

SUPPLEMENTARY INFORMATION: DOE prepared an Environmental Assessment 

(EA) on the proposed standards pursuant to the National Environmental 

Policy Act of 1969, as amended, Pub. L. 91-190, 40 U.S.C. 4221 et seq, 

and the implementing regulations of the Council on Environmental 

Quality [40 CFR Parts 1500-1808]. The EA addresses the possible 

incremental environmental effects attributable to the application of 

the proposed standards to the design of refrigerators, 

refrigerator-freezers, and freezers; and small gas furnaces. The EA 

also looked at the impact of energy conservation standards for 

television sets. As discussed in the General Findings, the "no 

standard" standard for televisions will not change the status quo and 

therefore will not result in any environmental impact. The effect of 

3 
the proposed standards range from no change to a slight improvement in

the outdoor environment as discussed in the General Findings below.

Approach Used in The Analysis.

This assessment evaluates the environmental impacts resulting

from the proposed setting of new or amended energy-efficiency

standards for refrigerators , refrigerator- freezers , freezers, and

small gas furnaces and the proposed setting of no standards for

television sets in accordance with the NAECA . A complete description

of the Engineering and Economic Analysis of the proposed standards may

be found in the Technical Support Document (TSD).

The two main environmental concerns addressed are emissions from

fossil fuel fired electricity generation and the chlorofluorocarbons

used in the production of rigid insulation foam.

Four of the fourteen scenarios for product design changes

described in the Engineering Analysis of the TSD were chosen for study

based on their relative importance as design measures. Values for

energy savings that result from product design changes are also taken

from the TSD.

An in-depth analysis of particulate emissions is not included in

this assessment because particulate emissions are relatively small

compared to sulfur and nitrogen oxide emissions. Current electricity

generating methods are far cleaner than those of the past. In 1984,

power plants contributed only 7 percent of U.S. total particulate

emissions as compared to contributions of 83 percent and 34 percent to

total SO2 and NO2 emissions , respectively ( EPA, 1986).

4

CE-RM-87-102 COMMENT 05

the proposed standards range from no change to a slight improvement in 

the outdoor environment as discussed in the General Findings below. 

Approach Used in The Analysis. 

This assessment evaluates the environmental impacts resulting 

from the proposed setting of new or amended energy-efficiency 

standards for refrigerators, refrigerator-freezers, freezers, and 

small gas furnaces and the proposed setting of no standards for 

television sets in accordance with the NAECA. A complete description 

of the Engineering and Economic Analysis of the proposed standards may 

be found in the Technical Support Document (TSD). 

The two main environmental concerns addressed are emissions from 

fossil fuel fired electricity generation and the chlorofluorocarbons 

used in the production of rigid insulation foam. 

Four of the fourteen scenarios for product design changes 

described in the Engineering Analysis of the TSD were chosen for study 

based on their relative importance as design measures. Values for 

energy savings that result from product design changes are also taken 

from the TSD. 

An in-depth analysis of particulate emissions is not included in 

this assessment because particulate emissions are relatively small 

compared to sulfur and nitrogen oxide emissions. Current electricity 

generating methods are far cleaner than those of the past. In 1984, 

power plants contributed only 7 percent of U.S. total particulate 

emissions as compared to contributions of 83 percent and 34 percent to 

total S02 and N02 emissions, respectively (EPA, 1986). 

4 
General Findings.

1. Refrigerators , Refrigerator-Freezers and Freezers.

The proposed standards for refrigerators , refrigerator- freezers,

and freezers range from retaining the federally mandated standards

contained in NAECA, up to three more stringent standards. The

greatest impacts of the proposed standards , other than the minimum

NAECA standards, are the result of generating less electricity. Power

plants ' main environmental effects on air and water result from

emissions of sulfur oxides ( SOX), nitrogen oxides (NOx), and carbon

dioxide (CO2). All SO x and NOX emissions are expressed in the

equivalent weights of SO2 and NO2, respectively. Carbon dioxide

emissions are commonly expressed as tons of carbon. Additionally,

there would be some shifting of CFC use . General findings are

summarized below:

A. Sulfur Dioxide.

The greatest decrease in air pollution will occur for sulfur

dioxide. The possible reductions range from no change up to 151,000

tons or 0.9 percent of the U.S. SO2 emissions expected to be emitted

by power plants by the year 2010 for the most stringent standard

proposed.

B. Nitrogen Dioxide.

The possible reductions in NO2 range from no change up to

j/ The upper levels are interpolated from data in Table 5 . 8 of the

Technical Support Document for energy savings and Tables 1,2,5, and 6

of the Environmental Assessment for pollutant reductions. The

interpolation is made between standard level 1 (engineering level 3)

and standard level 4 (engineering level 8).

5

CE-RM-87-102 COMMENT 05

General Findings. 

1. Refrigerators, Refrigerator~Freezers and Freezers. 

The proposed standards for refrigerators, refrigerator-freezers, 

and freezers range from retaining the federally mandated standards 

contained in NAECA, up to three more stringent standards. The 

greatest impacts of the proposed standards, ~ther than the minimum 

NAECA standards, are the result of generating less electricity. Power 

plants' main environmental effects on air and water result from 

emissions of sulfur oxides (SOx), nitrogen oxides (NOx )' and carbon 

dioxide (C02 ). All SOx and NO

x 

emissions are expressed in the 

equivalent weights of S02 and N02 , respectively. Carbon dioxide 

emissions are commonly expressed as tons of carbon. Additionally, 

there would be some shifting of CFC use. General findings are 

summarized below: 

A. Sulfur Dioxide. 

The greatest decrease in air pollution will occur for sulfur 

dioxide. The possible reductions range from no change up to 151,000 

tons or 0.9 percent of the u.S. S02 emissions expected to be emitted 

by power plants by the year 2010 for the most stringent standard 

proposed. 1/ 

B. Nitrogen Dioxide. 

The possible reductions in N02 range from no change up to 

1/ The upper levels are interpolated from data in Table 5.8 of the 

Technical Support Document for energy savings and Tables 1,2,5, and 6 

of the Environmental Assessment for pollutant reductions. The 

interpolation is made between standard level 1 (engineering level 3) 

and standard level 4 (engineering level 8). 

5 
100,000 tons or 1.0 percent of the total NO2 emissions expected to be

emitted by power plants by the year 2010 for the most stringent

standard proposed.2/

C. Carbon Dioxide.

The possible reductions in CO2 range from no change up to the

equivalent of 9,180,000 tons or 0.2 percent of the worldwide CO2

emissions for the year 2010 for the most stringent standard

proposed.V

D. Chlorofluorocarbons.

An additional effect of some design change scenarios is an

increased consumption of CFC ' s. CFC-11 is contained in the rigid foam

insulation used in the appliances and CFC-12 is the heat exchange

fluid used in refrigerators and freezers . The possible increased use

ranges from no change to one percent of the 1985 total United States

CFC-11 and CFC-12 consumption for the most stringent standards

proposed . However, since CFC production has been limited, any extra

consumption would have to come from other uses and would not result in

a net increase in CFC production.

None of the environmental impacts from the savings of SO2, NO2,

or CO2 from the range of proposed standards are considered to be

significant.

21 ibid.

2/ ibid.

6

CE-RM-87-102 COMMENT 05

100,000 tons or 1.0 percent of the total N02 emissions expected to be 

emitted by power plants by the year 2010 for the most stringent 

standard proposed.2J 

C. Carbon Dioxide. 

The possible reductions in CO2 range from no change up to the 

equivalent of 9,180,000 tons or 0.2 percent of the worldwide CO2 

emissions for the year 2010 for the most stringent standard 

proposed.'J..I 

D. Chlorofluorocarbons. 

An additional effect of some design change scenarios is an 

increased consumption of CFC's. CFC-11 is contained in the rigid foam 

insulation used in the appliances and CFC-12 is the heat exchange 

fluid used in refrigerators and freezers. The possible increased use 

ranges from no change to one percent of the 1985 total united states 

CFC-11 and CFC-12 consumption for the most stringent standards 

proposed. However, since CFC production has been limited, any extra 

consumption would have to come from other uses and would not result in 

a net increase in CFC production. 

None of the environmental impacts from the savings of S02' N02' 

or CO2 from the range of proposed standards are considered to be 

significant. 

2J ibid. 

'J..I ibid. 

6 
2. Small Gas Furnaces.

The greatest impact of the proposed standard for small gas

furnaces is a decrease in electricity consumption as some households

shift from electric heating to small gas furnaces and decreases in gas

and oil burned in homes . General findings are summarized below:

A. Sulfur Dioxide.

The reduction in SO2 would be 6800 tons or 4.2 percent of the

emissions estimated to come from residential fuel combustion during

2010.

B. Nitrogen Dioxide

The reduction in NO2 would be 5100 tons or 1.3 percent of the

emissions estimated to come from residential fuel combustion during

2010.

C. Carbon Dioxide

The reduction in CO2 would be equivalent to 569,000 tons of

carbon or . 01 percent of the worldwide CO2 emissions for the year

2010.

None of the environmental impacts from the savings of SO2, NO2,

or CO2 from the proposed standard are considered to be significant.

3. Television Sets.

The proposed " no standard" standard for television sets results

in no impact on the environment since it will not change the status

quo. DOE is unaware of any State or local energy conservation

standards concerning television sets that would be preempted by the

"no standard" standard . The only state standard for television sets

7

CE-RM-87-102 COMMENT 05

2. Small Gas Furnaces. 

The greatest impact of the proposed standard for small gas 

furnaces is a decrease in electricity consumption as some households 

shift from electric heating to small gas furnaces and decreases in gas 

and oil burned in homes. General findings are summarized below: 

A. Sulfur Dioxide. 

The reduction in S02 would be 6800 tons or 4.2 percent of the 

emissions estimated to come from residential fuel combustion during 

2010. 

B. Nitrogen Dioxide 

The reduction in N02 would be 5100 tons or 1.3 percent of the 

emissions estimated to come from residential fuel combustion during 

2010. 

C. Carbon Dioxide 

The reduction in CO2 would be equivalent to 569,000 tons of 

carbon or .01 percent of the worldwide CO2 emissions for the year 

2010. 

None of the environmental impacts from the savings of S02' N02' 

or CO2 from the proposed standard are considered to be significant. 

3. Television Sets. 

The proposed "no standard" standard for television sets results 

in no impact on the environment since it will not change the status 

quo. DOE is unaware of any state "or local energy conservation 

standrrds concerning television sets that would be preempted by the 

"no standard" standard. The only state standard for television sets 

7 
of which DOE is aware is the New York State standard that bans the

"instant-on " feature of tube type televisions . However, since tube

type television sets are no longer manufactured , such standards

currently have no effect.

Determination.

Based upon the EA, DOE has determined that the proposed interim

standards do not constitute a major federal action significantly

affecting the quality of the human environment , within the meaning of

NEPA. Therefore , an Environmental Impact Statement is not required.

Issued in Washington, D.C. November 7 , 1988.

6-

Ernest C. Bay d II

Assistant Se etary

Environment , Safety and Health

8

CE-RM-87-102 COMMENT 05

of which DOE is aware is the New York State standard that bans the 

"instant-on" feature of tube type televisions. However, since tube 

type television sets are no longer manufactured, such standards 

currently have no effect. 

Determination. 

Based upon the EA, DOE has determined that the proposed interim 

standards do not constitute a major federal action significantly 

affecting the quality of the human environment, within the meaning of 

NEPA. Therefore, an Environmental Impact Statement is not required. 

Issued in Washington, D.C. 

8 

NQvember 7, 1988. 

Ernest C. Bay 

Assistant Se 

Environment, Health 
a. Environmental Review

DOE prepared an Environmental Assessment (EA) on the proposed

standards pursuant to the National Environmental Policy Act of 1969,

as amended , Pub. L. 91-190, 40 U.S.C. 4221 et sect., and the

implementing regulations of the Council on Environmental Quality (40

CFR Parts 1500 through 1808 ). The EA addresses the possible

incremental environmental effects attributable to the application of

the proposed standards to the design of three types of covered

products: refrigerators, refricierator -freezers, and freezers; small

gas furnaces ; and television sets.

A Findinq of No Significant Impact (FONSI) is published in

today' s Federal Register . The FONSI concludes that the proposed

standards would result in no significant environmental impacts and

that an environmental impact statement is not required.

The EA is part of the Technical Support Document and is

available at the DOE Freedom of Information Reading Room at the

address provided at the beginning of this notice.

CE-RM-87-102 COMMENT 05

a. Environmental Review 

DOE prepared an Environmental Assessment (EA) on the proposed 

stannards pursuant to the National Environmental Policy Act of 1969, 

as amended, Pub. L. 9l-l90, 40 U.S.C. 4221 et seq., and the 

implementing requlations of the Council on Environmental Quality (40 

CFR Parts 1500 through 1808). The EA addresses the possible 

incremental environmental effects attributable to the application of 

the proposed standards to the design of three types of covered 

proructs: refriaerators, refriqerator-freezers, and freezers; small 

aas furnaces; and television sets. 

A Finding of No Significant Impact (FONSI) is published in 

todav's Fereral Register. The FONSI concludes that the proposed 

stanrarcs would result in no siqnificant environmental impacts and 

that an environmental impact statement is not required. 

The EA is part of the Technical Support Document and is 

availa~le at the DOE Freedom of Information Reading Room at the 

address provided at the beginning of this notice. 

Ii.:!U