# ABM-A

American Boiler Manufacturers Association 8221 Old Courthouse Rd, Suite 202, Vienna, Virginia 22182 703

-356

-7172 •fax 703

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


### Subject: ABMA Response 

### to DOE Request for Comment on the Publication "Preliminary Technical Support Document for Commercial Packaged Boiler Standards" - Docket No. EERE-2013-BT-STD-0030. (RIN 1904-ADOl) January 15, 2015 The following comments are submitted on behalfofthe American BoilerManufacturers Association (ABMA) by its Director ofTechnical Affairs, Geoffrey M Halley. As the oldest continuous national manufacturing trade association inAmerica, the American Boiler Manufacturers Association is composed ofover 100 small business manufacturer and supplier members in 24 states across America involved in the design and fabrication of> 400,000 Btu/hr. (heat input) commercial, institutional, industrial, heat recovery, and electricity-generating boilers and combustion equipment. ABMA was founded in 1888 by boiler manufacturers ofthe day to beginto craft legal and regulatory infrastructures that would ensure material integrity and commitmentto safety inthe design and fabrication ofboilers. Today, ABMA strongly abides bythose founding principles and its commitmentto safety is ongoing and over-ruling ofany contemplated code, standard orregulatory scheme. You will see these theme reflected inthe comments below. Comments onthe Technical Support Document follow:

1. The tentative decision notto set anupper limit on input capacity for CPBs is causing significant concern among the boiler manufacturer's represented by ABMA. As stated on many occasions, inboth verbal and written correspondence with DOE, this imposes a prohibitively high financial burden on companies manufacturing large institutional sized space heating boilers. These boilers can approach 80,000,000 Btu/hr input capacity, withtesting costs approaching $1,000,000.00 for the test rig, fuel cost and test boiler. This contrasts withthe $3,000.00 to $5,000.00 for the smaller boilers(< 400,000 Btu/hr input) thathas beenreferenced during recent DOE/Industry meetings. The DOE efficiency certification and testing concept is obviously based upon 

### existing methods developed for residential, and small commercial size boilers using an extension ofresidential technology. Unfortunately, there significant contrast between small boilers built in relatively large quantities to a standard specification and large boilers custom engineered and manufactured to specifications for a particular installation. Thesetwo sectors ofthe space heating boiler industry are completely different interms ofthe product and the mannerinwhich business is conducted. While the current DOE certification and testing conceptmay be well



### 1

... representing the best of the boiler industry!suited for residential and small commercial package boilers, it is most certainly illconceived when it is applied to the space heating boilers manufactured by the membership ofABMA, for large commercial and institutional boiler installations. In addition, most ABMA manufacturers have been offering efficiency guarantees since the late 1970's onthe large space heating commercial and institutional package boilers, and have been capable ofmeeting the current efficiency requirements since 1970. In this respect, the large CPB sector ofthe boiler industry (ABMA Membership) has been effectively self-regulating. Onthe basis ofthe above, we would respectfully recommend the DOE test and efficiency certification requirements be capped at 2,500,000 Btu/hr. input. This would still capture the high unit count ofthe small boilers for certification, which seems to be working quite well from all accounts, and leave only a relatively small unit count ofthe large boilers to be self-regulated. 2. We believe DOE would best served to not engage inthe standby, off-cycles orthe energy consumed in different operational modes. There are too many variables related to system design, set-up and operation for a one-size fits-all rule. Boiler manufacturers have no control over the manner in which a boiler is used, once it is installed in a system. In addition, ourprevious safety related comments provided on the framework document still apply. 3. It is apparent that the calculations involving Life Cycle Cost and Boiler Lifetime are skewed toward condensing boilers. The typical lifetime for a condensing boiler is shown as 10

- 15 years (with average of 12.5 years) in Table 8-F 2.1 but the boiler lifetime is standardized at 24.8 years, irrespective ofwhether it is a standard efficiency (non-condensing) boiler, or a higher efficiency (condensing boiler). 

### Itis difficult to understand why this was done. Withthat being said, any calculations using the proposed boiler lifetime as an input is highly suspect unless the life cycle cost ofa condensing boiler installation, over a 24.8 year lifetime includes the cost of 2 condensing boilers (areplacement after 12.5 years) rather than one. 4. We are concerned that the so-called large boilers are represented inthe engineering calculations withboiler input of3,000,000 Btu/hr. We realize there may be insufficient data available for larger size boilers to provide DOE withthe necessary degree ofconfidence in its calculations but the size referenced above is one ofthe smallest size manufactured by ABMA member companies and does not accurately represent large boiler market. It is ourbeliefthat the DOE requirements should be capped at 2,500,000 Btu/hr. 5. The apparent unwillingness ofDOE to allow the use ofASME PTC 4 as an alternate to BTS 2000 as a recognized test procedure for larger (ABMA) boilers, is a definite issue. One ofthe potential results ofthis position is that existing test data cannot be used in the generation ofAEDM's. This imposes undue hardship on the manufacturers ofthe largest space heating boilers. In this context, it should be noted

2

### that many ofthese boilers are low pressure versions ofindustrial boilers, manufactured by these same companies, but built to Section IV ofthe ASME Code rather than the high pressure (Section I) ASME Code. ASME PTC 4 is the only test procedure used for high pressure boilers, but can equally be used for low pressure boilers. We therefore request that DOE allow the use ofASME PTC 4 for these large boilers
. This again shows the need for a cap on capacity. As an additional comment, we believe that unless the boiler sizing closely foll0ws, the seasonal load profile, and the control system is capable ofselecting the correct boiler for the prevailing load, then the efficiency savings will not be maximized. We would also like to repeat our comment from the framework document, that we believe that proper maintenance ofthe entire system is the most important part ofenergy efficient operation. Respectfully submitted,

Geoffrey M Halley, P.E. Director ofTechnical Affairs American Boiler Manufacturers Association 

### Direct Telephone: 1-636-394-3483 Direct E-mail: ghalleysji @aol.com

3