DOE 11/15/96 1

CP

 EE-RM-94-403 COMMENT 55G

I 

• b ,. 

DOE 

Clothes Washer Standards 

Rulelnaking 

11/15/96 1 
: Summary of DOE Draft Reports

- Design Options

- Engineering Analysis

. Future Analyses

DOE 11/15/96 2

 EE-RM-94-403 COMMENT 55G

DOE 

> cs 

.:. SUInInary of DOE Draft Reports 

- Design Options 

- Engineering Analysis 

.:. Future Analyses 

11/15/96 2 
)ign Option Xeor

o Product classes segregated by size

(compact and standard)

: Reports are limited to standard capacity

-lack of data for compacts

-compacts represent small market share

DOE 11/15/96 3

 EE-RM-94-403 COMMENT 55G

DOE 

°gn Option Report 

.:. Product classes segregated by size 

(colTIpact and standard) 

.:. Reports are lilllited to standard capacity 

-la.ck of data for cOlllpacts 

-cOlllpacts represent slllalllllarket share 

11/15/96 3 
gkn COptions onsi eIeL

: To consider a design option it must be

technically feasible (e.g. at a minimum a

working prototype with public data)

: 20 design options were investigated (report page 3)

-DOE proposed design options in the

November 1994, ANOPR

-DOE received feedback from industry

-design options were added

-terminology changes were made

DOE 11/15/96 4

 EE-RM-94-403 COMMENT 55G

· n Options Considered 

.:. To consider a design option it must be 

technically feasible (e.g. at a minimum a 

vvorking prototype with public data) . 

• :. 20 design options were investigated (report page 3) 

-DOE proposed design options in the 

Novell1ber 1994, ANOPR 

-DOE received feedback from industry 

-design options were added 

-terminology changes were l11ade 

DOE 11/15/96 4 
ning of Design Option

- The Department considers the following factors to

determine if a design option should be eliminated

from consideration:

-Practicability to manufacture, install and service

-Adverse impacts on product utility or availability

-Adverse impacts to health or safety

: 8 of the 20 design options were tentatively

eliminated

- Currently, DOE intends to consider 12 design

options (report page 15)

DOE 11/15/96 5

 EE-RM-94-403 COMMENT 55G

;' ening of Design Options 

.:. The Department considers the following factors to 

deterllline if a design option should be elilllinated 

from. consideration: 

-Practicability to lllanufacture, install and service 

-Adverse illlpacts on product utility or availability 

-Adverse illlpacts to health or safety 

.:. 8 of the 20 design options were tentatively 

elilllinated 

.:. Currently, DOE intends to consider 12 design· 

options (report page 15) 

DOE 11/15/96 5 
i 'fineering Ana ysis

. Based on AHAM aggregated data

(uncertainty/variability analysis has not been

conducted yet)

:Based on proposed Appendix J1 test procedure

(April 1996, NOPR) with revision to discount

Remaining Moisture Content (RMC) (improved

extraction used only 75 % of time by consumers)

- Developed in terms of a Modified Energy Factor

(MEF)

DOE 11/15/96 6

 EE-RM-94-403 COMMENT 55G

"neering Analysis 

.' 

.:. Based on AHAM aggregated data. 

(uncertainty/variability analysis has not been 

conducted yet) 

.:. Based on proposed Appendix Jl. test procedure 

(April 1996, NOPR) with revision to discount 

Relllaining Moisture Content (RMC) (illlproved 

extraction used only 75 % of tillle by consulllers) 

.:. Developed in terlllS of a Modified Energy Factor 

(MEF) 

DOE 11/15/96 6 
..::!.ii i!:i .:...:...:~:!:!~ iiii.~..iiiiiiisi-i'i^i<r":i-i: :1 s ^ I::..

ineering AnalIysis Resuits

Energy use Hot water

Mech anical

Dryer

Water use Per cycle

Water Consumption Factor (WCF)

Annual results Energy and water consumption

Operating Expense

Efficiency Modified Energy Factor (MEF)

Percentage improvement

DOE 11/15/96 7

 EE-RM-94-403 COMMENT 55G

ineering Analysis Results 

Energy use Hot water 

Mechanical 

Dryer 

Water use Per cycle 

Water Consumption Factor (WCF) 

Annual results Energy and water consumption 

Operating Expense 

Efficiency Modified Energy Facto~ (MEF) 

Percentage improvement 

DOE 11/15/96 7 
.:: D::: ii ii;.

.. t S.eps.. for Engineering

+ Receive stakeholder inputs to identify and

resolve remaining issues

+ Prepare revised engineering analysis,

schedule dependent upon extent of issues

identified today

+ Provide revised analysis to stakeholders for

comment prior to Supplemental ANOPR

being published

DOE 11/15/96 8

 EE-RM-94-403 COMMENT 55G

t Steps for Engineering 

alysis 

.:. Receive stakeholder inputs to identify and 

resolve relllaining issues 

.:. Prepare revised engineering analysis, 

schedule dependent upon extent of issues 

identified today 

.:. Provide revised analysis to stakeholders for 

COlll111ent prior to Supplelllental ANOPR 

being published 

11/15/96 8 
nsumer and National Impact

. Energy and water saving forecasting

+ Report discussing possible approaches and

sources of data will be made available in

January 1997

+ Workshop tentatively scheduled for

February 26, 1997

: Draft analysis expected with Supplemental

ANOPR, April 1997

DOE 11/15/96 9

 EE-RM-94-403 COMMENT 55G

DOE 

re Analyses - . 

umer and National Impact 

.:. Energy and water saving forecasting 

.:. Report discussing possible approaches and 

sources of data will be made available in 

January 1997 

.:. Workshop tentatively scheduled for 

February 26, 1997 

.:. Draft analysis expected with Supplemental 

ANOPR, April 1997 

11/15/96 9 
'tianufacturer Impact

: DOE is currently undergoing intensive effort to

improve analytical methodology

:Manufacturer impact workshop tentatively

scheduled for February 5, 1997

: Analysis for clothes washers will need to

consider impact of proprietary designs known to

DOE

DOE 11/15/96 10

 EE-RM-94-403 COMMENT 55G

re Analyses - ufacturer Impact 

.:. DOE is currently undergoing intensive effort to 

illlprove analyticallllethodology 

.:. Manufacturer iIllpact workshop tentatively 

scheduled for February 5,1997 

.:. Analysis for clothes washers will need to 

consider illlpact of proprietary designs known to 

DOE 

DOE 11/15/96 10 
+ Analyses to address impact on electric and

gas utilities will be conducted

+ Analysis to project emission reductions and

water savings for various candidate standard

levels will be conducted

DOE 11/15/96 11

 EE-RM-94-403 COMMENT 55G

DOE 

:",.:.:.:.:.:.,.:.",."'. IP..,." .., ........-, II . -til 

~~""Jlty ana ~nvlronmental 

,"H JITalyses 

.:. Analyses to address illlpact on electric and 

gas utilities will be conducted 

... :. Analysis to project elllission reductions and 

\Vater savings for various candidate standard 

levels \ViII be conducted . 

11/15/96 11 
... t on Competition

. Department of Justice (DOJ) makes a

determination regarding any lessening of

competition

- impact on consumers in terms of cost,

quality, and innovation of products in the

market

: DOJ analysis previously based on NOPR

- DOE plans to involve DOJ early in the

manufacturing impact analysis process

DOE 11/15/96 12

 EE-RM-94-403 COMMENT 55G · '-

ct on Competition 

.:. Departlllent of Justice (DOJ) lllakes a 

deterInination regarding any lessening of 

cOlllpetition 

~ illlpact on conSUl11ers in terl11S of cost, 

quality, and innovation of products in the 

lllarket 

.:. DO] analysis previously based on NOPR 

- DOE plans to involve DO] early in the 

lllanufacturing illlpact analysis process 

DOE 11/15/96 
Revieewers

· Richard Topping, Arthur D. Little Inc.

** James Gordon, Independent Consultant

.: John Tomlinson, Oak Ridge National

Laboratory

DOE 11/15/96 13

 EE-RM-94-403 COMMENT 55G

RevieIvers 

.:. Richard Topping, Arthur D. Little Inc . 

. :. James Gordon, Independent Consultant 

.:. John Tomlinson, Oak Ridge National 

Laboratory 

DOE 11/15/96 13 
n Options

*: 20 options analyzed

:* 8 options tentatively eliminated

DOE 11/15/96 14

 EE-RM-94-403 COMMENT 55G

.:. 20 options analyzed 

.:. 8 options tentatively eliminated 

DOE 11/15/96 14 
sig In Options E limnated

Design Option Reason for Tentative Elimination

Improved Water Extraction for Technical Feasibility - No known prototype

RMC's of 35%

Improved Water Extraction for Technical Feasibility - No known prototype

RMC's of 30%

Suds Saving Negative impact to utility; No energy savings

Reduced Thermal Mass Technical Feasibility - No known method to reduce

thermal mass below baseline (plastic tub).

Electric Disassociation of Water Technical Feasibility - No known prototypes for

residential use

Ultrasonic Washing Technical Feasibility - No known prototype

Bubble Action No known energy savings

Ozonated Laundering Technical Feasibility - No known prototypes for

residential use

DOE 11/15/96 15

 EE-RM-94-403 COMMENT 55G

sign Options Eliminated 

Design Option Reason for Tentative Elimination 

Improved Water Extraction for Technical Feasibility - No known prototype 

RMC's of 35% 

Impro ved Water Extraction for Technical Feasibility - No known prototype 

RMC's of 30% 

Suds Sa ving Negative impact to utility; No energy savings 

Reduced Thermal Mass Technical Feasibility - No known method to red uce 

thermal mass below baseline (plastic tub). 

Electric Disassociation of Water Technical Feasibility - No known prototypes for 

residential use 

Ultrasonic Washing Technical Feasibility - No known prototype 

Bubble Action No known energy savings 

o zonated Laundering Technical Feasibility - No known prototypes for 

residential use 

DOE 11/15/96 15 
"a a i

esz, C^Options Consiaered in

':~4~,~iBvBIIW ZU uj m : infry rli inrin I Ynt Ancl9ysi0 in ( jSIS

o Improved fill control : Horizontal axis with

. Tighter tub tolerance recirculation

o Thermostatically : Automatic fill control

controlled mixing valves * Increased motor efficiency

(TCMV) + Direct drive motor

o Improved water Improved water ,: Advanced controls/sensor extraction for RMC of 50% (l ld (soil load sensor)

: Improved water . 4 * Improved water ./.: Added insulation extraction for RMC of 40%

· Horizontal axis design

DOE 11/15/96 16

 EE-RM-94-403 COMMENT 55G

~pesign Options Considered in 

I\( iminary Engineering Analysis 

.:. Improved fill control 

.:. Tighter tub tolerance 

.:. Thermostatically 

.:. Horizontal axis with 

recircula tion 

.:. Automatic fill control 

controlled mixing valves 

(TCMV) 

.:. Increased motor efficiency 

.:. Direct drive motor 

-:. Improved water .:. Advanced controls/ sensor 

extraction for RMC of 50% (soil load sensor) 

.:. Improved water .:. Added insulation 

extraction for RMC of 40% 

.:. Horizontal axis design 

DOE 11/15/96 16 
n Options or Consideration

-: Are there any other design options DOE

should consider?

DOE 11/15/96 17

 EE-RM-94-403 COMMENT 55G

· 'gn Options for Consideration 

.:. Are there any other design options DOE 

should consider? 

DOE 11/15/96 17 
te for Establishing Pro uct

. Classes established based on

- different kind of energy

- capacity or performance-related feature that

justifies a higher or lower standard

- In considering whether a performance

related feature justifies establishment of a

higher or lower standard, consumer utility is

considered

42 USC 6295 (q)

DOE 11/15/96 18

 EE-RM-94-403 COMMENT 55G

,,"teria for Establishing Product >~ft:. ,:::;:::::: 

.:. Classes established based on 

- different kind of energy 

- capacity or perform.ance-related feature that 

justifies a higher or lower standard 

.:. In considering whether a perform.ance 

related feature justifies establishlllent of a 

higher or lower standard, consum.er utility is 

considered 

42 USC 6295 (q) 

DOE 11/15/96 18 
..........,1... -INA d-It

Fr for Engineering Analy s

: Peer reviewers expressed significant

concerns regarding validity and uncertainty

of data

- Alternative methods for improving data

:DOE requests inputs from stakeholders on

how to resolve issues

19 DOE 11/15/96

 EE-RM-94-403 COMMENT 55G

for Engineering Analysis 

.:. Peer reviewers expressed significant 

concerns regarding validity and uncertainty 

of data 

.:. Alternative methods for illlproving data 

.:. DOE requests inputs from. stakeholders on 

ho"W to resolve issues 

DOE 11/15/96 . 19