U.S. Department of Energy Public Meeting on Plumbing Products

Washington, DC 

### February 28, 1996 Introductory Remarks Good afternoon. I'm Bill Hui, Program Manager for Plumbing Products in the Office of Codes and Standards. On behalf of the Department of Energy. Thank you for taking time to participate in this public meeting concerning the Department's program to conserve water by improving the efficiency of water use of certain plumbing products. We will begin with introductions around the room. Please state your name and the company or organization you represent. If you have not already done so, please fill out the information requested on the sign

-in sheet. Purpose of Meeting The purpose of today' s meeting is to discuss issues raised by the Plumbing Manufacturers Institute concerning proposed statistical sampling plans for plumbing fixtures, mathematical rounding procedures, and incorporation of the 1994 ASME/ANSI Standard A112.18.1M for "Plumbing Fixture Fittings." The Energy Policy Act of 1992 requires faucets. showerheads, water closets, and urinals to'meet certain standards of water use efficiency as of January 1, 1994 when tested in accordance with procedures prescribed in the statute. The Department of Energy is drafting a proposed rule to incorporate the statutory plumbing requirements into the Code of Federal Regulations. Statements submitted before March 31 on the issues discussed today will be considered before the Department publishes a Notice of Proposed, Rulemaking on Plumbing Products. As the presiding official, I will set the guidelines for conducting the meeting and provide other pertinent information. In order to obtain as much relevant information as reasonable and to enable interested persons to express their views, the public meeting will be conducted conference style. A verbatim transcript of the public meeting will be taken. Format of Meeting The meeting format will be as follows. I will state each agenda item to be discussed, and then invite statements on that item. Following that, there will be opportunities for informal discussion. Participants who wish to speak should first be recognized. Please state your name first and the organization you represent. Representatives from the Department of Energy and the National Institute of Standards and Technology may also wish to speak or ask follow-up questions. Where someone is in agreement, I will appreciate an indication of that agreement; and in the interest of time, comments need not be repeated. I will summarize the main points after discussion of an agenda item. If time permits and after all agenda items have been covered, participants may raise other topics regarding the water use efficiency of plumbing products. Again. please remember to state your name first and the organization you represent.

1Please keep side conversations to a minimum to avoid interrupting a presenter

. If a lengthy private discussion is needed, please move outside the room. It may be necessary to cut off discussion on some topics to maintain the schedule. I encourage all persons present to participate so the Department may get a full spectrum of opinions on the agenda items. Today' s meeting is scheduled to end by 5 : 00 p.m . ( or sooner). Items not covered by 5:00 p.m. may be addressed in written statements submitted before March 31, 1996. In keeping with the regulations of these building facilities, there is no smoking allowed in this room. Transcript and Submissions In approximately two weeks, the written transcript of this meeting will be available for inspection at the Department of Energy's Freedom of Information Reading Room located in Room IE-190. Anyone who wishes to purchase a copy of the transcript may make arrangements with the court reporter. All written statements will be available for public inspection in the Department of Energy Freedom of Information Reading Room, telephone number (202) 586-6020. Written statements should be addressed to the Department of Energy as noted in the letter of invitation to today's meeting. Ten copies of each statement are requested. In addition, the Department will appreciate an electronic copy of each statement submitted. The Department is currently using WordPerfect 5.1 and WordPerfect 6.1. Comments submitted by telefax will not be accepted. Any person submitting information that he or she believes to be confidential and exempt by law from public disclosure should submit one complete copy and eight copies from which information claimed to be confidential has been deleted. In accordance with the procedures established at 10 CFR 1004.11, the Department of Energy shall make its own determination as to whether the information shall be exempt from public disclosure. Summary We appreciate the time and effort you have taken to participate in today's public meeting. Again, the purpose of today's meeting is to discuss issues raised by the Plumbing Manufacturers Institute concerning proposed statistical sampling plans for plumbing fixtures, mathematical rounding procedures. and incorporation of the 1994 ASME/ANSI Standard A112.18.1M for "Plumbing Fixture Fittings." I will begin by summarizing the first agenda item, statistical sampling plan, and then I will invite statements on that item. Statistical Sampling Plan The Department understands the relationship of statistical confidence levels to variations in vitreous china plumbing products resulting from the manufacturing process.The Department proposes the following statistical sampling plan for water closets and urinals. For each basic model of water closet or urinal, a sample of sufficient size shall be tested to ensure that any represented value of water consumption shall be no less than the higher of (A) the mean value of the sample or (B) the upper 90 percent confidence limit of the true mean value divided by 1.1. The Department understands the Plumbing Manufacturers Institute will support this proposal. According to the December 13, 1995, letter from Mr. Rick Church, Managing Director of the Plumbing Manufacturers Institute, "If DOE were to publish in the upcoming rule that the 'D factor' for fixtures would be Ll, industry could support it." The Department believes that such a statistical sampling plan for plumbing fixtures will allow manufacturers to test a minimum number of units without undue burden, and at the same time provide meaningful statistical assurance to consumers that such products comply with the Energy Policy Act of 1992. Is there public support for this statistical sampling plan for plumbing fixtures? Mathematical Rounding Procedures The second issue on today's agenda concerns mathematical rounding procedures. Section 123(j) of the Energy Policy Act of 1992 specifies. the standards for maximum water use for faucets, showerheads, water closets, and urinals in terms of tenths of gallons, or in the case of metering faucets hundredths of gallons. It is the Department's view that simple mathematical rounding procedures should be used to convert water use test data for plumbing products into reporting data. For example, five and above round up; less than five round down. Is there public support for these mathematical rounding procedures?

ASME/ANSI Standards The third issue on today' s agenda concerns the adoption of the ASME/ANSI Al12. 18.1M-1994 test procedure for "Plumbing Fixture Fittings," which requires faucets to not exceed 2. 2 gallons per minute flow rate when measured at 60 pounds per square inch pressure. According to the November 20, 1995, letter from Mr. Rick Church, Managing Director of the Plumbing Manufacturers Institute, "because of the issue of marketplace confusion, the industry feels it is very important that the federal, law and the ANSI standards are brought to conformity." The Department agrees with this point of view and intends to incorporate by reference the flow -capacity test procedures contained in ASME/ANSI A112.18.IM-1994. However, the Department is concerned that the requirement of 2.2 gpm at 60 psi could be considered more stringent than the 1989 requirement of 2.5 gpm at 80 psi, and may adversely affect the manufacturers of variable orifice devices installed in faucets. Manufacturers test data provided by the Plumbing Manufacturers Institute indicate the existence of variable flow controlled faucets that comply at 2.5 gpm at 80 psi, but not 2.2 gpm at 60 psi. In order to adopt the flow rate of 2.2 gpm at 60 psi for faucets, the Department requests statements for the public record that:

3for fired orifice f low control devices, the efficiency of water use at 2.2 gpm at 60 psi is equivalent to 2.5 gpm at 80 psi; and .for variable orifice flow control devices, such devices meet the efficiency of water use requirement of 2.2 gpm at 60 psi in ASME/ANSI A 112.18. 1 M-1994. Does the public wish to provide such statements? Adjournment Thank you for participating in today's public meeting. The Department looks forward to your support throughout the rulemaking process. Ladies and gentlemen, we are adjourned.