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 behalf of the American Boiler Manufacturers 

Association (ABMA) by its Director of Technical Affairs, Geoffrey M Halley. 

As the oldest continuous national manufacturing trade association in America, the 

American Boiler Manufacturers Association is composed of over 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 of the day to begin to craft legal and regulatory 

infrastructures that would ensure material integrity and commitment to safety in the 

design and fabrication of boilers. Today, ABMA strongly abides by those founding 

principles and its commitment to safety is ongoing and over-ruling of any contemplated 

code, standard or regulatory scheme. You will see these theme reflected in the comments 

below. 

Comments on the Technical Support Document follow: 

1. The tentative decision not to set an upper limit on input capacity for CPBs is causing 

significant concern among the boiler manufacturer's represented by ABMA. As 

stated on many occasions, in both 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, with testing costs approaching $1,000,000.00 for the test rig, 

fuel cost and test boiler. This contrasts with the $3,000.00 to $5,000.00 for the 

smaller boilers(< 400,000 Btu/hr input) that has been referenced 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 of residential 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. These two sectors of the space heating boiler industry are 

completely different in terms of the product and the manner in which business is 

conducted. While the current DOE certification and testing concept may be well 

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... 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 of ABMA, for large commercial and institutional boiler installations. 

In addition, most ABMA manufacturers have been offering efficiency guarantees 

since the late 1970's on the large space heating commercial and institutional package 

boilers, and have been capable of meeting the current efficiency requirements since 

1970. In this respect, the large CPB sector of the boiler industry (ABMA 

Membership) has been effectively self-regulating. 

On the basis of the 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 of the small boilers for certification, which 

seems to be working quite well from all accounts, and leave only a relatively small 

unit count of the large boilers to be self-regulated. 

2. We believe DOE would best served to not engage in the standby, off-cycles or the 

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, our previous 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 of whether it is a standard 

efficiency (non-condensing) boiler, or a higher efficiency (condensing boiler). It is 

difficult to understand why this was done. With that being said, any calculations 

using the proposed boiler lifetime as an input is highly suspect unless the life cycle 

cost of a condensing boiler installation, over a 24.8 year lifetime includes the cost of 

2 condensing boilers (a replacement after 12.5 years) rather than one. 

4. We are concerned that the so-called large boilers are represented in the engineering 

calculations with boiler input of 3,000,000 Btu/hr. We realize there may be 

insufficient data available for larger size boilers to provide DOE with the necessary 

degree of confidence in its calculations but the size referenced above is one of the 

smallest size manufactured by ABMA member companies and does not accurately 

represent large boiler market. It is our belief that the DOE requirements should be 

capped at 2,500,000 Btu/hr. 

5. The apparent unwillingness of DOE to allow the use of ASME PTC 4 as an alternate 

to BTS 2000 as a recognized test procedure for larger (ABMA) boilers, is a definite 

issue. One of the potential results of this position is that existing test data cannot be 

used in the generation of AEDM' s. This imposes undue hardship on the 

manufacturers of the largest space heating boilers. In this context, it should be noted 

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that many of these boilers are low pressure versions of industrial boilers, 

manufactured by these same companies, but built to Section IV of the 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 of ASME 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 of selecting 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 of the entire system is the most important part of energy 

efficient operation. 

Respectfully submitted, 

Geoffrey M Halley, P.E. 

Director of Technical Affairs 

American Boiler Manufacturers Association 

Direct Telephone: 1-636-394-3483 

Direct E-mail: ghalleysji@aol.com 

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