October 14 th

, 2013

Ms. Brenda Edwards

US Department of Energy

Building Technologies Office

Mailstop EE

‐ 2J

1000 Independence Avenue SW

Washington DC 20585

‐ 0121

Re:

Framework Document for Commercial Packaged Boilers

Docket No. EERE

‐ 2013

‐ BT

‐ STD

‐ 0030 and/or RIN 1904

‐ AD01

Dear Ms. Edwards,

Cleaver

‐ Brooks has the following comments on the s ubject Framework Document:

Item 2

‐ 4 DOE welcomes comment as to whether there are any size

‐ related issues with conducting

testing under the DOE test procedure which the agency should consider addressing in its test

procedure rulemaking. DOE is also interested in any comments regarding whether there is a capacity

limit beyond which amended ene rgy conservation standards would not be technologically feasible

and economically justified.

We believe that there needs to be some upper limit on the scope of the regulation for cost and

practicality reasons. Large commercial boilers are very expensive and take considerable time to

manufacturer. Larger projects can be over one million dollars and take several months to

manufactu re. Both of these issues make compliance with the existing procedures financially

burdensome and in larger cases totally impractical. Our preference, based on the structure of our

product offering would be to cap the requirements at 2.5 MMBtu/hr input

Item 3

‐ 2 DOE requests feedback on is sues or problems with the current test procedure that may

make it burdensome or infeasible for manufacturers to conduct testing on some or all models of

commercial packaged boilers. Specifically, DOE requests comment whether the operating pressures

required by BTS

‐ 2000 are not achievable for any commercial packaged boilers within the sc ope of

this rulemaking.

BTS

‐ 2000 specifies testing on steam operating at 0 to 2 psi. The boilers that we sell are not designed to

operate at this pressure. They are designed to operate near or at 10 psi. We cannot test our steam

boilers at such low operating pressures due to resultant excessive moisture car ryover. For hot water

boilers, BTS

‐ 2000 specifies testing with a supply temperature of 180 o F and a return temperature of 38

to 80 o F for non

‐ condensing boilers. For many of our products, we specify a minimum return

temperature of 140 o F to reduce damage due to thermally induced stresses. Neither the specified

steam nor hot water test conditions reflect what is typically found in actual application. In both cases

the specified test conditions overestimate the efficiency of the boiler compared to what an end user will

actually see in the field. Ou r suggestion is for steam testing to be performed at 10 psi and water testing

to be performed with a supply of 180 o F and return of 140 o F, or as a minimum allow those test

conditions as an alternative.With regard to the use of a thermocouple grid for stack temperature measurement, we acknowledge

that this method of measurement is more accurate than a single point measurement. However, if the

difference, if the single point measurement is done properly, results in less than 1⁄4% difference in

efficiency. Again, all our hist orical test data is based on using a single point stack temperature

measurement with an electronic combustion analyzer. While we do not object to using a thermocouple

grid for any future testing, we wish to avoid having to redo all our existing testing just to satisfy the

requirement for a grid tem perature measurement.

Item 3

‐ 4 DOE welcomes comment on alternative industry test methods for determining the

efficiency for commercial packaged boilers, particularly with regards to how an alternative standard

would improve or not improve upon the current test procedure based on BTS

‐ 2000, and on the

comparability of efficiency ratings determined using the alte rnative standards to those from a BTS

‐

2000 test.

All of the testing that we perform when we develop our designs is done in accordance with ASME

PTC

‐ 4.1

‐ 1964 (reaffirmed 1991) using the abbreviated test form and the heat loss method. This is

the most common standard used by larger packag ed boiler industry (above 2.5 MMBtu.hr input).

Nearly all of our historical efficiency data is based on this test standard. It would be a huge financial

burden to repeat all our existing development testing in order to comply with BTS

‐ 2000. PTC

‐ 4.1

heat loss method returns essentially the same ef ficiency values as BTS

‐ 2000 combustion efficiency if

the radiation losses are included. BTS

‐ 2000 combustion efficiency does not include radiation losses,

so PTC

‐ 4.1 is more accurate.

Sincerely,

Peter A. Molvie, PE