COMMERCIAL PACKAGED BOILER ENERGY CONSERVATION STANDARD RULEMAKING

Docket Number EERE

- 2013

- BT

- STD

- 0030
RIN 1904

- AD01

Item 14

- 1 Two subgroups to consider are those that primarily manufacturer their heat exchangers here in the states and those that primarily import the heat engines from outside the US. The impacts upon each could be quite different. Other subgroups are water

- tube and fire

- tube products or perhaps the materials the boilers are constructed of would provide your subgroups

- steel, stain less steel, cast iron, copper etc.
Item 14

- 3 DOE 2012

- all boiler manufacturers have recently gone through certifications of products to BTS

- 2000 for implementation January 1 st , 2014. Any change in testing standard, which was just completed would require retesting, re

- certification, and further costs associated with more testing.
Item13.1 None anticipated
Item11

- 2 You should contact BRG Building Solutions, Larry Longo at 973 347

- 5300. They provide the industry breakdown and history that you are looking for.
Item 10

- 6 The mater ial the boiler is constructed from , past performance of material, along with a products warranty should be used in determining equipment lifetimes. Steam should be separated from water and condensing boilers should be separated fro m non - condensing boilers. Some boilers last 30

- 50 years with maintenance, some other s will struggle achieving 10 years.
Item 10

- 2 Low

- minimum to 84% Mid

- 85

- 88% High

- 89

- 93 %
Max

- 94% plus The above efficiencies are based on current test criteria which may or may never be achieved in an actual heating system. This rating can be extremely misleading as an ultra efficient boiler may actually achieve low to mid efficiency status in it’s real world application. Max and high efficiency condensing boile rs achieve similar efficiency to mid efficiency non

- condensing boilers in non

- condensing applications requiring water temperatures above 130 degrees.
Item 10

- 4 High efficiency boilers are very limited in being “repairable” , and any issue with a heat exch anger and it has to pulled and sent back to manufacturer for possible repair or more likely heads tothe scrap yard. Steel, cast iron, and copper heat exchangers can be repaired in the field and boost expected lifetime of products.
Item 10

- 5 Any rule chan ging regarding use of chimneys will add costs
Item 9

- 5 No, all boilers are not designed the same. Some will perform better or worse than others at higher or lower water temperatures
Item 5

- 4 pumps with ECM motors
Item 5

- 1 Contact BRG group as p reviousl y mentioned.
Item 2

- 4 

### Would prefer testing be limited to 2,500,000 BTU’s under DOE test procedure. The bodies conducting the tests at their own labs cannot go much higher than this number. Outfitting current labs with dissipation systems above this mark is a huge burden. If this number is not adopted a single unit from a boiler series should suffice to certify the line and is not required to be re

- tested every year. This certification would be in effect until a change is made to the boiler series that would change the performance. Also b ased on current burner technology and range of achievable CO2’ s, the performance of a boiler will not change from one manufacturer to another when adjusted for same CO2 levels. Based o n this it is unnecessary to retest with each burner manufacturer.

On behalf of Burnham Holdings, Jim Schnorr and Chris Drew welcome the opportunity to meet personally and be interviewed. There are only a few manufacturers that provide boilers in the entire range you beseek input. We make all types of boilers, condensing and non

- condensing, steel, stainless steel, cast iron, and copper.