1 | Energy Efficiency and Renewable Energy eere.energy.gov 

### July 28, 2015 James Raba
Department of Energy Building Technologies Office
EERE

- 2014

- BT

- TP

- 0055 SprayValves2014TP0055@ee.doe.gov 

### Test Procedure: Notice of Proposed Rulemaking for Commercial Prerinse Spray Valves2 

## Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time

– Say your name for the record

– there will be a complete transcript of this meeting

– Be concise

– share the ‘air

- time ’

– Keep the focus here

– cell phones on silent; limit sidebar conversations

– Webinar participants turn phone on mute; “raise your hand” to be recognized to speak



### • Housekeeping Items

• Agenda Review

• Opening Remarks3 

## Agenda

1) 9 :00 AM Introductions
2) 9:05 AM Opening Statements 3) 9:15 AM Regulatory History & Scope
4) 9:30 AM Definitions & Industry Standards Referenced
5) 10:00 AM Proposed Additions
6) 10:25 AM Small Business Impacts
7) 10:35 AM Closing Remarks for test procedure
8) 10:45 AM Break/Transition to ECS4 

## Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Additions

5 Small Business Impacts

6 Closing Remarks

7 Break5 

## Listening Via the Webcast

• DOE is broadcasting this meeting live over the Internet

• DOE is providing the webcast to accommodate stakeholders that are unable to attend the public meeting in person

• The web broadcast allows interested parties to listen in and view the slides

• All interested parties are encouraged to submit written comments after the public meeting6 

## Purpose of the Public Meeting

• Present DOE’s proposed test procedure for commercial prerinse spray valves (CPSVs)

• Invite comment on the notice of proposed rulemaking (NOPR) document

• Discuss next steps in the rulemaking

• Invite participants to provide summary comments or statements and raise additional issues for discussion7 

## Opening Remarks

Meeting participants are invited to provide opening remarks or statements at this time8 

## Issues for Discussion

Issue Box
DOE welcomes comments, data, and information concerning its proposed test procedure for commercial prerinse spray valves. Issues are numbered to correspond to issues presented in DOE’s published NOPR. Whether invited by an issue box or not, comments are welcome on any part of DOE’s analysis. 

### DOE welcomes comments, data, and information concerning its proposed test procedure for commercial prerinse spray valves. Whether invited by an issue box or not, comments are welcome on any part of DOE’s analysis.9 

## How to Submit Written Comments

In all correspondence, please refer to these commercial prerinse spray valve rulemakings by:

Postal : Courier Ms. Brenda Edwards Ms . Brenda Edwards U.S. Department of Energy U.S . Department of Energy Building Technologies Program, Building Technologies Program, Suite 600 Mailstop EE

- 5B 950 L’Enfant Plaza, SW 1000 Independence Avenue, SW Washington, DC 20024 Washington, DC 20585

- 0121 Tel: 202 586

- 2945

Title CPSV Test Procedure
Docket Number: EERE

- 2014

- BT

- TP

- 0055 Regulation Identification Number (RIN): 1904

- AD41

Email: SprayValves2014TP0 055@ee.doe.gov

Comments Due: September 8, 2015, 11:59 PM ET10 

## Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Additions

5 Small Business Impacts

6 Closing Remarks

7 Break11 

## Regulatory History & Authority

• Energy Policy and Conservation Act of 1975 (EPCA) Pub.L

. 94

- 163

– The Act set forth a variety of provisions designed to improve the energy efficiency of various products and equipment

– Part B of Title III provides for the “Energy Conservation Program for Consumer Products Other than Automobiles” (42 U.S.C. 6291

- 6309)



### • Energy Policy Act of 2005 ( EPAct) Pub.L. 109

- 58

– Amended EPCA to include commercial prerinse spray valves

– EPAct defined CPSVs (42 U.S.C. 6291(33)), established a test procedure (42 U.S.C. 6293(b)(14)), and determined energy efficiency standards for flow rate (42 U.S.C. 6295 ( dd ))12 

## Regulatory History & Authority

• History of the Test Procedure

– DOE incorporated by reference in 2006 ASTM Standard F2324

- 03 under 10 CFR 431.263. 71 FR 71340,71374 (Dec. 8, 2006)

– DOE updated the test procedure for CPSVs in 2013 by incorporating by reference ASTM Standard F2324

- 03 (2009) under 10 CFR 431.263. 78 FR 62970, 62980 (Oct. 23, 2013)13 

## Steps in the Test Procedure Rulemaking

• DOE initiated a test procedure to support the CPSV energy conservation standard

– TP NOPR published in the Federal Register on June 23, 2015 (80 FR 35874)

– TP NOPR Public Meeting today, July 28, 2015

• Comments on TP NOPR from interested parties

– Transcript records oral comments from today’s public meeting

– Written comments (comment period closes September 8, 2015 )

• DOE reviews and considers all comments

• Final Rule publication

– Final Rule is expected to be issued by the end of the year NOPR Final Rule14 

## Proposed Changes in this NOPR

In this NOPR, DOE proposes the followings changes:

1. Modify the current definition of the term “commercial prerinse spray valve,” and add a definition for the term “ spray force” 2. Incorporate by reference relevant portions ASTM Standard F2324

- 13 3. Add a test method for measuring spray force
4. Add a requirement for measuring flow rate and spray force for each spray pattern in commercial prerinse spray valves with multiple spray patterns 5. Modify rounding requirement for flow rate and add a requirement for spray force 6. Modify current CPSV sampling requirements15 

## Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Additions

5 Small Business Impacts

6 Closing Remarks

7 Break16 

## Definition of Commercial Prerinse Spray Valve

• DOE’s current definition: Commercial prerinse spray valve means a handheld device designed and marketed for use with commercial dishwashing and ware washing equipment that sprays water on dishes, flatware, and other food service items for the purpose of removing food residue before cleaning the items. (42 U.S.C. 6291 (33)(A))

• DOE proposes the following definition of commercial prerinse spray valve:

Commercial prerinse spray valve means a handheld device suitable for use with commercial dishwashing and ware washing equipment for the purpose of removing food residue before cleaning the items.



### Issue 1a. Commercial Prerinse Spray Valve Definition

DOE requests comment on the proposed revised definition of commercial prerinse spray valve.17 

## Proposed Definition of Spray Force

• DOE proposes to define the term “spray force” to distinguish between product classes (see CPSV energy conservation standard NOPR for more details)

• Spray force is used in ASTM Standard F2324

- 13 and defined as “the amount of force exerted onto the spray disc”

• DOE proposes the following definition of spray force:

Spray force means the amount of force exerted onto the spray disc, measured in ounce

- force (ozf).

Issue 1c. Spray Force Definition
DOE requests comment on its proposed definition of spray force.18 

## Method of Test

• The current DOE test procedure incorporates by reference ASTM Standard F2324

- 03 (2009) under 10 CFR 431.263. 78 FR 62970, 62980 (Oct. 23, 2013 )

• DOE proposes to update the method to the most recent industry method by incorporating by reference ASTM Standard F2324

– 13, which replaces the cleanability test with a spray force test

– Where the cleanability test evaluated cleaning time of a standard dinner plate, the current ASTM Standard F2324

– 13 prescribes spray force, measured in ounce

- force (ozf )19 

## Industry Standards Incorporated by Reference Comparison

Metric Current DOE Test Procedure Proposed DOE Test Procedure

Water Pressure Two different requirements to measure flow r ate at water pressure of 60 ± 1 psi and 60 ± 2 psi CPSV flow rate only measured at a water pressure of 60 ± 2 psi

Flow Rate of

Flex Tubing 7 gpm 3.5 gpm

Water Temperature for Testing 120 ± 4 o F 60 ± 10 o F

Length of Water Pipe to be Insulated Any insulation to have a thermal resistance (R) of 4 oF x ft 2 x h/Btu for the entire length of the water pipe, from the mixture valve to the inlet of the flex tubing No requirement 

### • The following table identifies other differences between ASTM Standard F2324

– 03 (2009 ) and ASTM Standard F2324

– 1320 

## Industry Standard Incorporated by Reference Sections

• DOE proposes to incorporate by reference only these sections of ASTM Standard F2324

– 13:

Section(s) Description
6.1

– 6.9 Apparatus

9.1

– 9.5.3.2 Preparation of apparatus for flow rate and spray force tests
10.1

– 10.2.5 Flow rate test method
10.3.1

– 10.3.8 Spray force test method
11.3.1 Flow rate calculation

General Replace the plural “nozzles” with “nozzle”, and exclude references to the “Annex”21 

## Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Additions

5 Small Business Impacts

6 Closing Remarks

7 Break22 

## Proposed Additional Test Method

– Spray Force

• DOE discussed in the September 2014 Framework public meeting for the CPSV energy conservation standard the addition of spray force to separate product classes

• DOE proposes to incorporate by reference sections 6.2 and 6.4

– 6.9 (Apparatus), 9.1

– 9.5.3.2 (Preparation of apparatus for the spray force test), and 10.3.1

– 10.3.8 (Spray force test method) of the ASTM Standard F2324

- 13 for the measurement of spray force

Issue 2. Spray Force DOE seeks comment on the proposed addition of the spray force test method.23 

### Proposed Additional Test Method

– CPSVs with Multiple Spray P atterns

• DOE has identified several commercial prerinse spray valves on the market with multiple spray patterns

– The valves contain an average of three spray patterns

– Each spray pattern could have a different spray force and flow rate



### • Therefore , DOE proposes that for a valve with multiple spray patterns, the flow rate and spray force for each spray pattern be tested

Issue 3. Spray Patterns DOE requests comment on testing all spray patterns for commercial prerinse spray valves with multiple spray patterns.24 

## Proposed Rounding Requirements

• DOE proposes changing the rounding requirements for flow rate to two decimal places

– EPA’s WaterSense program currently requires rounding flow rate to two decimal places (1.28 gpm)



### • DOE proposes to follow the spray force rounding requirements in section 11.4.2 of ASTM Standard F2324

- 13

– round to one decimal place Issue 4. Rounding Requirements DOE seeks comment on changing the flow rate measurement rounding requirements from one decimal place to two decimal places.

DOE seeks comment on rounding requirements for spray force rounded to one decimal.25 

## Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Modifications & Additions

5 Small Business Impacts

6 Closing Remarks

7 Break26 

## Review Under the Regulatory Flexibility Act

• DOE has used the Small Business Administration definition of small entities:

– Commercial prerinse spray valve manufacturers are included in NAICS 332919, “Other metal valve and pipe fitting manufacturing”

– The SBA standard for small entities in this industry description is < 500 employees



### • DOE found that eight out of eleven manufacturers of commercial prerinse spray valves qualify as small businesses27 

## Testing Burden Comparison

• Projected compliance requirements of the proposed rule for CPSVs , relative to current DOE test procedure :

Current Test Procedure Proposed Test Procedure Difference Testing at least two units per basic model Testing a t least two units per basic model None

Does not require spray force test Requires spray force test Negligible change in test time since DOE believes manufacturers already test for spray force
No requirement to test all spray patterns for CPSVs with multiple spray patterns Requires CPSVs with multiple spray patterns be tested for flow rate and spray force for each pattern + approximately 1 hour28 

## Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Modifications & Additions

5 Small Business Impacts

6 Closing Remarks

7 Break29 

## Request for Closing Remarks

At this time DOE welcomes any closing remarks from interested parties30 

## Reminder: How to Submit Comments

• Public Meeting

– Oral comments will be captured in the transcript and become part of the public record.



### • Written comments

– NOPR comment period open until September 8, 2015. Reference docket #: EERE

– 2014

– BT

– TP

– 0055 and/or RIN #: 1904

– AD41

Email: SprayValves2014TP0055@ee.doe.gov

Mail: Mrs. Brenda Edwards U.S. Department of Energy Building Technologies Office 1000 Independence Avenue SW., Mailstop EE

- 5B Washington, DC 20585

- 0121

Courier: Mrs. Brenda Edwards U.S. Department of Energy Building Technologies Office 950 L'Enfant Plaza, Suite 600 Washington, DC 20024 Telephone: 202 586

- 294531 

## Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Modifications & Additions

5 Small Business Impacts

6 Closing Remarks

7 Break