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 UNITED STATES DEPARTMENT OF ENERGY 

 + + + + + 

 APPLIANCE STANDARDS AND RULEMAKING 

 FEDERAL ADVISORY COMMITTEE 

 + + + + + 

 DISCUSSION OF VERIFICATION PROGRAMS FOR 

 COMMERCIAL PACKAGED BOILERS 

 + + + + + 

 WEDNESDAY 

 AUGUST 14, 2013 

 + + + + + 

 The Committee met in Conference 

Room 6075, 950 L'Enfant Plaza, at 9:00 a.m., 

Neil Eisner, Facilitator. 

PRESENT: 

NEIL EISNER, Facilitator 

LAURA BARHYDT, DOE General Counsel 

JOHN CYMBALSKY, DOE 

JEREMIAH FREEMAN, New West Technologies 

EMILY MARCHETTI, Energetics 

PRESENT VIA WEBINAR: 
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KARIM AMRANE, AHRI 

TIMOTHY BALLO, Earthjustice 

LAURA DEGITZ, Navigant Consulting 

PAUL DOPPEL, Mitsubishi 

SCOTT DURFEE, Nidec Motor Corporation 

GEOFFREY HALLEY, ABMA 

TRAVIS HARDIN, UL 

RANDY HASEMAN, UL 

DIANE JAKOBS, Rheem 

TOM JOHNSON, Daikin McQuay 

JEFF KLEISS, Lochinvar 

MICHAEL KOJAK, UL 

JONATHAN LEMMOND, AHRI 

ARIS MARANTAN, Navigant Consulting 

KAREN MEYERS, Rheem 

FRANK MYERS, PVI Industries 

NEIL ROLPH, Lochinvar 

PHILLIP STEPHENS, HTP 

JOHN SUTPHEN, Cleaver-Brooks 
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1 P-R-O-C-E-E-D-I-N-G-S 

2 (9:06 a.m.) 

3 MS. BARHYDT: Hello, everyone. 

4 This is Laura Barhydt with the U.S. 

5 Department of Energy. 

6 Thank you for participating today 

7 in the commercial HVAC negotiated rulemaking 

8 working group. Today we are going to talk 

9 some about boilers and some of the unique 

10 concerns that boiler manufacturers have. 

11 And I believe we have about 12 

12 people on the line. We are going to try 

13 unmuting you, so that everybody can speak 

14 freely. But if we end up having problems 

15 with a lot of background noise, we will have 

16 to mute everyone and you will have to raise 

17 your hand electronically to get your line 

18 unmuted. 

19 I do want to ask everyone to 

20 state their name before they speak. Our 

21 court reporters in this group have been 

22 phenomenal at recognizing voices, but -- you 
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1 can't see this right now, but we do actually 

2 have somebody different. So you need to make 

3 sure you identify yourself before you speak. 

4 So I'm not exactly sure who all 

5 is on the line, but -- can you just read off 

6 the list? 

7 MS. MARCHETTI: Yes. We have 

8 Diane Jakobs, Frank Myers, Jeff Kleiss, John 

9 Sutphen, Jonathan Lemmond, Karen Meyers, 

10 Laura Degitz, Michael Kojak, Phillip 

11 Stephens, Randy Haseman, Travis Hardin. So 

12 13 folks. 

13 MS. BARHYDT: Thirteen. Okay. 

14 So one of the concerns we have 

15 heard is that some of the larger boilers have 

16 issues with the current DOE test procedure, 

17 and we have talked about their ability to 

18 apply for a test procedure waiver. Are any 

19 of the manufacturers who feel like they have 

20 a problem with the current DOE test procedure 

21 on the line? 

22 MR. SUTPHEN: Yeah. This is John 
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1 Sutphen with Cleaver-Brooks. 

2 MS. BARHYDT: Hello. So one of 

3 the things that we wanted to talk about today 

4 is DOE's current regulatory framework, and 

5 how a test procedure waiver fits into that 

6 framework, and how this rulemaking fits into 

7 that framework. 

8 So under DOE regulations, a 

9 manufacturer has to test each basic model 

10 using the DOE test procedure, and that 

11 testing is the basis of the representations 

12 and a certification of compliance. At the 

13 beginning of this working group, we 

14 negotiated a proposal for alternative 

15 efficiency determination methods. 

16 And as part of that, that 

17 actually reduces test burden by allowing 

18 manufacturers to do a reduced amount of 

19 testing and to use simulation methods to 

20 estimate the efficiency of different basic 

21 models that have not been tested. 

22 But the waiver is only -- DOE can 
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1 only issue a waiver in certain circumstances, 

2 and that is where there is a design feature 

3 that is not accounted for by the test 

4 procedure. And I believe -- I ought to open 

5 up my reg book, but the language is something 

6 along the lines of "if the test procedure 

7 does not accurately reflect the performance 

8 of the product." 

9 And then the other circumstance 

10 where we can grant a waiver is if the test 

11 procedure just literally will not work for -- 

12 on the product due to some, again, design 

13 feature that makes it impossible to conduct 

14 the test in accordance with the DOE test 

15 procedure. 

16 DOE cannot grant a test procedure 

17 waiver to reduce test burden. That is just 

18 not part of the legal framework for the 

19 Department to grant a test procedure waiver. 

20 The mechanism in our regs to reduce test 

21 burden is the alternative efficiency 

22 determination method, the AEDM. 
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1 So to use an AEDM you have to 

2 have some testing that is done in accordance 

3 with either the DOE test procedure or a test 

4 procedure waiver granted by the Department. 

5 And, again, the test procedure waiver can 

6 only be granted where there is some design 

7 issue with the product that makes it either 

8 impossible to use the test procedure or that 

9 makes the test procedure generate a result 

10 that is not representative of the actual 

11 efficiency of the product. 

12 Does that all make sense? 

13 MR. EISNER: Laura, let me ask a 

14 question. 

15 MS. BARHYDT: Yes. 

16 MR. EISNER: This is Neil Eisner. 

17 The waiver is in the regulations or in the 

18 statute, I presume. 

19 MS. BARHYDT: Yes. 

20 MR. EISNER: Is it possible to 

21 grant an exemption which under case law is 

22 available for unique situations not 
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1 considered during the rulemaking? 

2 MS. BARHYDT: So it depends on 

3 what you mean by "exemption"? So -- 

4 MR. EISNER: Okay. Exemption 

5 would be somewhat like a waiver. You could 

6 say, "We will not apply the rule to you" or 

7 "we will apply the rule to you with these 

8 specific conditions." 

9 MS. BARHYDT: So the only 

10 exemption, if you want to use that word, that 

11 we have is the ability to come up with a 

12 different test procedure. There is no 

13 ability for us to waive testing altogether, 

14 and there is no ability for us to waive it -- 

15 so I think what you're asking about is, if we 

16 didn't consider something in the rulemaking, 

17 is that a grounds to issue a waiver? 

18 And the Department's view is 

19 that, if it's something we didn't consider in 

20 the rulemaking, then the test procedure is 

21 either not going to work or it's going to 

22 generate a result that is not representative. 
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1 MR. EISNER: So the bottom line 

2 for the boilers would be, is there another 

3 way to test, not in the rule, that will show 

4 the legitimate or the -- represent the actual 

5 efficiency of the system? Does anybody 

6 online have suggestions in that regard? Do 

7 you have alternative ways you would test for 

8 efficiency? 

9 MR. SUTPHEN: This is John at 

10 Cleaver-Brooks. In our waiver submittal, we 

11 requested to use the PTC 4 method for 

12 efficiency determination. We feel that the 

13 BTS-2000 test doesn't adequately portray 

14 testing of low pressure steam boilers. 

15 And we also, in our waiver, 

16 requested that we test for both the hot water 

17 and the low pressure steam using high 

18 pressure steam test, and then doing a stack19 over-steam method to calculate the low 

20 pressure steam and the hot water efficiency 

21 numbers. 

22 It is done very -- using 
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1 conservative methods for calculation. And I 

2 believe we showed some examples in our 

3 request for waiver on how that would be done. 

4 MS. BARHYDT: Okay. So it sounds 

5 like you have submitted information, and I 

6 just wanted to make sure that the role of the 

7 waiver within our framework is clear. My 

8 understanding is that your segment of the 

9 industry has not been as active in a lot of 

10 the rulemakings, and so -- at least my 

11 perception is that you don't have the long 

12 history with the Department that some of the 

13 other manufacturers have. 

14 So I just want to make sure that 

15 how our regulatory framework works makes 

16 sense, because -- 

17 MR. SUTPHEN: Okay. 

18 MS. BARHYDT: -- in part because 

19 some of the issues we are going to talk about 

20 today in verification, I want to make sure 

21 that how that fits into the other regulations 

22 is clear. Some of the emails we received 
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1 talked about certification testing, and I 

2 wanted to make sure that it's clear what the 

3 distinction is between certification testing 

4 and verification testing. 

5 So certification testing is that 

6 initial testing prior to distribution in 

7 commerce that is used to determine the 

8 compliance of the model. And that testing 

9 can either be testing of each basic model or 

10 it can be testing to establish an AEDM. 

11 That's the front end testing. 

12 The back end testing is the 

13 verification testing, and that is testing 

14 done on a long-term basis to check that the 

15 efficiency of the products is what 

16 manufacturers have certified. And some of 

17 the concerns that we heard previously from 

18 Jeff and Peter were that once there is a 

19 design there is no reason to think anything 

20 would change. 

21 And the Department's experience 

22 has been that a lot of times over time 
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1 manufacturing processes may change, suppliers 

2 may change. And I don't know how much this 

3 is applicable to your products, and so that's 

4 something I would like to hear more about. 

5 That in other products that we 

6 have seen there is often a change over time 

7 that may or may not be expected by the 

8 manufacturer, and so there is a real value to 

9 verification testing. And what we had heard 

10 previously from Jeff and Peter is that they 

11 didn't see the value. 

12 And so I would be interested in 

13 hearing more about how your manufacturing 

14 process works, how the design -- when the 

15 design is made relative to when products are 

16 built, whether or not a particular model is 

17 built over a long period of time, or whether 

18 it's literally just a one-time deal, that 

19 kind of thing. 

20 MR. SUTPHEN: This is John 

21 Sutphen, Cleaver-Brooks. All of our hot 

22 water and low pressure steam boilers are 
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1 built to ASME Section 4 Code, so we have to 

2 follow a very strict guideline for how we 

3 build our pressure vessel. And the mode of 

4 calculating efficiency is just, you know, you 

5 heat the water and then you calculate how 

6 much water you heated or how much steam you 

7 make. It's purely based on the heat transfer 

8 area and the actual design of your boiler. 

9 We don't use any electrical 

10 consumption in these calculations. The BTS11 2000 doesn't use any electrical components. 

12 There's no motors in the calculation, so 

13 there is no supplier that would change, you 

14 know, the efficiency of their product that we 

15 would use to have any effect on our 

16 efficiency numbers. 

17 So once the boiler is designed 

18 and tested, that design -- forever, unless we 

19 do a major design change, but then there 

20 would be almost a different product, you 

21 know. 

22 So a boiler that was built in 
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1 1950 will be exactly the same as the boiler 

2 that was built today, just because it has to 

3 be for that certain -- 

4 MR. HALLEY: This is Geoff Halley 

5 with ABMA. Can everybody hear me? 

6 MS. BARHYDT: Yes. 

7 MR. HALLEY: Okay. I'd like to 

8 add a couple of things. He's right, the 

9 basic design of the heat exchanger, which is 

10 the big thing, you know, flint unleashes a 

11 flint unleashes -- but the basic design of a 

12 heat exchanger can last for years and years. 

13 And, for example, a company I worked for at 

14 one time, we designed a new line of boilers 

15 around 1969, and it has already met these 

16 minimum standards. In fact, it exceeded them 

17 at that point in time. 

18 And it has prevailed without 

19 change to the heat exchanger design right 

20 through until the company was purchased and 

21 shutdown. But so there is a long more 

22 longevity I think. They are bigger boilers, 
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1 they take longer to develop, and they -- you 

2 know, there is a lot more money involved in 

3 testing them. So the product cycle, if you 

4 like, is a lot slower. 

5 The other thing I'd like to point 

6 out -- I did see a copy of the DOE comments 

7 on Cleaver-Brooks' request for waiver, and it 

8 seemed to me that one of the big problems 

9 with this two psi versus 10 psi pressure to 

10 perform the test start is that the AHRI who 

11 developed that test procedure got a steam 

12 separator that was only good up to two psi. 

13 But there are other methods of 

14 measuring the steam quality which go a lot 

15 higher than that. In fact, we did a lot of 

16 work in New York City with the Housing 

17 Authority back in the -- around 2000, and we 

18 ran all of the tests at 10 psi, and we used a 

19 piece of equipment called a throttling and 

20 separating calorimeter made by Ellison. It's 

21 not a cheap piece of equipment, but they can 

22 be rented. 
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1 And, you know, that would ease 

2 some of the problem, although there is 

3 nothing wrong with what John is talking about 

4 in doing it at higher pressure and then 

5 correcting back to, you know, whatever 

6 pressure DOE wants. 

7 Does that clear anything up or 

8 not? 

9 MS. BARHYDT: Well, it helps. I 

10 don't know if it clears it up entirely. 

11 MS. JAKOBS: This is Diane 

12 Jakobs. And my experience is with the 

13 residential furnaces, but I would agree with 

14 the first person that the variation that we 

15 do have is mostly associated with electrical 

16 components with the fans and the motors. 

17 And I'm also on the AHRI 

18 certification for furnaces committee, and we 

19 just don't have -- don't have the number -- 

20 don't have failures, really, for the most 

21 part, unless someone is doing something 

22 really, really bad. And I used to think 
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1 furnaces were just better, but I'm smarter 

2 now I guess. 

3 And I think that the variation is 

4 in the motors and related to air 

5 conditioning. And that what he was saying is 

6 right, if you have the same input rate for 

7 the gas that pretty much what you put in is 

8 related to the area of the heat exchanger, 

9 and that doesn't vary like windings do on 

10 motors. 

11 MR. HALLEY: Right. 

12 MS. JAKOBS: Okay. Yeah. I 

13 don't know if you have pumps, but -- 

14 MR. HALLEY: Well, they're 

15 external to the boiler. Typically, they're 

16 part of the system rather than the boiler. 

17 MS. JAKOBS: Right. So if you 

18 define the flow rate, and don't just kind of 

19 take what you get out of the motor, I would 

20 see that it would be really repeatable and it 

21 wouldn't vary like a device that has electric 

22 motors. 
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1 MR. HALLEY: Right. 

2 MS. JAKOBS: Okay. 

3 MR. EISNER: I'm not sure that 

4 John was finished earlier. 

5 MS. JAKOBS: Sorry. 

6 MR. SUTPHEN: This is John 

7 Sutphen, Cleaver-Brooks. I was pretty much 

8 finished, and I think what I was going to say 

9 Geoffrey covered it. But I think, you know, 

10 the boilers need to just focus on the 

11 pressure vessel, and the pressure vessel 

12 doesn't change. 

13 So it's our feeling that all of 

14 this extra testing is needless because 

15 nothing -- you are not going to catch anyone 

16 in the industry that builds a fire tube 

17 boiler cheating -- or something changing very 

18 much because it is what it is. A pressure 

19 vessel is a pressure vessel. And then -- 

20 MS. JAKOBS: Just to add to that, 

21 because you have to build to this ASME 

22 standard, which is a very stringent standard 
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1 on how you build that pressure vessel, it is 

2 almost impossible for the efficiency of the 

3 unit to change, because the construction of 

4 that pressure vessel is pretty strict. 

5 So I think that's what everyone 

6 is trying to say is you're not going to 

7 necessarily have the variation in efficiency 

8 because that ASME construction, standard of 

9 that pressure vessel, is, you know, 

10 monitored, and, you know, it's a pretty 

11 strict standard that you have to follow. 

12 MR. EISNER: This is Neil Eisner. 

13 Does 100 percent of the industry meet the 

14 ASME standard? 

15 MR. HALLEY: Yes. Unless you 

16 come from out of the country, in which case 

17 they have got to be still vetted and 

18 authorized by the State Chief Inspector as 

19 acceptable. 

20 MR. STEPHENS: Phillip Stephens, 

21 HTP. I think a question I had was, 

22 currently, do the DOE regs require ASME 
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1 construction for commercial boilers? Because 

2 a lot of times the market does definitely 

3 require it above a certain size. But when 

4 you get down to the smaller BTU products, I 

5 think it's a relatively recent event to 

6 require ASME within the past five years or 

7 so. 

8 MR. HALLEY: You are probably 

9 right about that. Certainly, from the 

10 National Board point of view, which is the 

11 enforcement arm of ASME, if you like, they 

12 really don't get involved in the residential 

13 size boilers enough. I think in fact, if 

14 anything, on the -- it's about 400,000 BTUs 

15 an hour input I think they don't get involved 

16 in. There are just too many of them for the 

17 -- you know, the workload basically. 

18 But beyond that, which is the -- 

19 you know, the ABMA side, if you'd like, not 

20 only is ASME involved in the National Board 

21 of Boiler Inspectors, they typically -- in 

22 fact, to my knowledge, I know everything that 
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1 went out of the company I worked for had a UL 

2 label on it, and it was inspected by the UL 

3 inspector, and they sampled a spectrum -- 

4 well, they inspected sampling of the entire 

5 line. 

6 Typically, the line was split 

7 into thirds. You looked at a sample from the 

8 bottom third, the middle third, and the top 

9 third, and they typically did a combustion 

10 efficiency as part of the program. And 

11 beyond that, once they were satisfied that 

12 you had got a boiler that was safe from the 

13 controls point of view, then they published 

14 or they gave what they call -- it was like a 

15 build stamp. 

16 It was actually a book that told 

17 you what had to be on the particular boiler 

18 in terms of the build standard. So not only 

19 is ASME involved, UL is involved, National 

20 Board is involved. So you've got three sets 

21 of checks basically. 

22 MS. BARHYDT: So what is the size 
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1 division between the ones that are subject to 

2 ASME and the ones where it has been a more 

3 recent development that the market has 

4 demanded ASME? 

5 MR. HALLEY: Right. The ASME has 

6 been around for a long time. In fact, ABMA 

7 was the forerunner to ASME and has been in 

8 business for 125 years this year. And their 

9 initial thing was boiler safety. There's a 

10 lot of boiler explosions back, you know, in 

11 the sort of -- I guess you'd say the 1800s, 

12 late 1800s. 

13 And so they formed, initially 

14 ABMA and then followed -- ASME followed, to 

15 set up standards and to design safer boilers, 

16 basically. And so to my knowledge, certainly 

17 I joined the boiler industry in 1968, and 

18 ASME was a big thing then and so was UL. 

19 MS. BARHYDT: So Phillip was 

20 saying that it's a more recent development 

21 for his products. And so what I'm wondering 

22 is, what is the BTU input that makes that 
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1 line between the products you're talking 

2 about with ABMA and the products that Phillip 

3 is talking about? 

4 MR. HALLEY: Do you want to 

5 answer that one, John, or do you want me to 

6 take a crack at it? 

7 MR. SUTPHEN: This is John at 

8 Cleaver-Brooks. I don't know where that line 

9 is, because all of our products are above 

10 that line. We have never -- 

11 MR. HALLEY: Well, I've -- 

12 MR. SUTPHEN: -- ASME section for 

13 a vessel. 

14 MR. EISNER: Are there any -- 

15 MR. HALLEY: Sorry. 

16 MR. EISNER: Are there any 

17 boilers sold in the United States that are 

18 not covered by ASME standards? I mean, 

19 you're saying, John, that yours are all 

20 covered. Do we know of any that wouldn't be 

21 covered? 

22 MS. JAKOBS: I know there's a 
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1 number like 300,000 for water heaters, but I 

2 don't know about boilers. I know everything 

3 above two and a half million -- or 2.5 

4 million BTUs has to have the ASME 

5 certification. But I think it goes further 

6 than that. Maybe, John or Geoff, you can -- 

7 MR. HALLEY: I know from sort of 

8 experience with, you know, product lines and 

9 that sort of thing I would say that I don't 

10 think there is any manufacturer that really 

11 sells much below what, say, 50, 60 

12 horsepower, which is an output number which 

13 -- oh, dear, my brain is not working too 

14 well. 

15 MR. KLEISS: The only non-ASME -- 

16 and this is Jeff Kleiss -- the only non-ASME 

17 boiler that I'm aware of is made by Kemco 

18 Systems. And it may be that it's more 

19 appropriately termed as a water heater. 

20 MR. HALLEY: Yeah. 

21 MR. KLEISS: But it has no 

22 pressure vessel, so it doesn't -- 
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1 MR. HALLEY: Okay. Right. 

2 MR. KLEISS: Now, there are some 

3 appliances that are truly water heaters or 

4 pool heaters that are sometimes sold as 

5 boilers, but they are not boilers and, you 

6 know, we believe that's a lapse of the boiler 

7 inspectors to allow the use of those in 

8 hydronic heating systems. 

9 MS. BARHYDT: Okay. So I'm 

10 guessing from that description, Jeff, that it 

11 would not meet the DOE definition of a 

12 commercial packaged boiler. 

13 MR. KLEISS: Correct. 

14 MS. JAKOBS: Correct. 

15 MR. STEPHENS: Phillip Stephens, 

16 HTP. I think what happens in the field is 

17 it's really up to the local inspectors and 

18 the local jurisdiction as to whether they 

19 want to enforce ASME. There are certain 

20 places in the country that simply don't 

21 enforce the ASME, and there are certain 

22 places in the country that I think all of us 
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1 know that you don't dare send any type of 

2 boiler without an ASME snap on the pressure 

3 vessel. 

4 MR. EISNER: Let me see if I -- 

5 MR. MYERS: This is Frank Myers 

6 -- 

7 MR. EISNER: Let me see if I 

8 understand -- 

9 MR. MYERS: This is Frank Myers 

10 with -- 

11 MR. EISNER: Go ahead, Frank. 

12 MR. MYERS: Go ahead. This is 

13 Frank Myers with PVI. I chair the ANSI 

14 Z21.13 Boiler Safety Standard Committee, and 

15 also participate in the Underwriters 

16 Laboratories review process for standards. 

17 And in order to get -- the two prevalent 

18 standards for boilers are either UL 795 or 

19 ANSI Z21.13. 

20 And in both of -- not that every 

21 boiler is certified to those, but if boilers 

22 are certified to either of those two 
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1 standards, they must be under ASME control. 

2 You cannot list to Z21.13, which includes 

3 residential boilers as well as commercial, 

4 unless you have an ASME stamp, and, likewise, 

5 for UL 795 for boilers, which requires an 

6 ASME stamp. 

7 MR. STEPHENS: Frank, when did 

8 that change take effect with the Z21.13 

9 standard? 

10 MR. MYERS: That has been in -- 

11 MR. STEPHENS: Is that the one I 

12 was -- 

13 MR. MYERS: This is Frank Myers, 

14 PVI. It actually has been well beyond my 

15 history, which is 30 years, with Z21.13. 

16 There was a clarification to make sure there 

17 was no slippage because some laboratories 

18 using that standard had begun allowing a 

19 water heater, which did not have to be ASME 

20 approved, to be listed under the boiler 

21 standard. 

22 So there was some leakage through 
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1 error, and the Standards Committee made 

2 revisions about four or five years ago to 

3 clarify that that was not acceptable, that 

4 you had to have the ASME stamp before you 

5 could get the safety approval. So it was a 

6 clarification as opposed to a change in the 

7 standard. 

8 MR. EISNER: I think what I'm 

9 hearing now is that, in accordance with the 

10 way DOE regulates in the area, all boilers 

11 would be covered by the ASME standard. They 

12 may call it a boiler, but under DOE 

13 regulations that would not count. Is that 

14 fair? 

15 MR. STEPHENS: Phillip Stephens, 

16 HTP. That is why I was asking the question 

17 about the wording of the DOE regulation. 

18 MS. BARHYDT: Rephrase your 

19 question, Phillip. I'll try and jump in. 

20 MR. STEPHENS: Does the text of 

21 the regulation require ASME construction of a 

22 boiler? 
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1 MS. BARHYDT: So unless it's in 

2 one of these documents as incorporated by 

3 reference, it is not in the text of the DOE 

4 regulation. 

5 MR. MYERS: This is Frank Myers. 

6 That is correct. It is not a part of the 

7 DOE regulation. If we were going to add some 

8 requirements for testing that were unique to 

9 this, it would have to be a part of the new 

10 rulemaking saying, "This is what applies to 

11 boilers that have the ASME stamp." 

12 MR. EISNER: Laura, could that be 

13 done as part of the grant of a waiver? 

14 MS. BARHYDT: Well, so, and folks 

15 on the phone correct me if I'm wrong, but I 

16 think what you all are arguing is that 

17 because of the high standards of this ASME 

18 Section 4 Code that there is not a need for 

19 verification testing because there is already 

20 such a high level of quality control, checks 

21 on production, that DOE should feel confident 

22 that one unit is going to be the same as the 
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1 next unit, which is different than the actual 

2 test procedure for measuring the efficiency 

3 of the product. 

4 MS. JAKOBS: Yeah. I think the 

5 big variable -- this is Diane Jakobs. I 

6 think the big variable is the area of the 

7 heat exchanger, the surface area, and the 

8 ASME standards are such that that's not -- 

9 does not vary. There is a check for another 

10 reason, for safety, but that's an area that 

11 won't vary from unit to unit. So there is no 

12 need to verify that for efficiency because 

13 the variations aren't allowed. 

14 MR. EISNER: Laura, are we -- 

15 MR. STEPHENS: What about the 

16 combustion efficiency? 

17 MS. JAKOBS: It got -- we were 

18 talking on top of each other. 

19 MR. STEPHENS: Oh, sorry. 

20 Phillip Stephens. What about the combustion 

21 efficiency? 

22 MR. HALLEY: The combustion 
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1 efficiency -- the manufacturer I work for, it 

2 didn't change from, say, 1970 on. They had 

3 good burners at that time, and, you know, a 

4 boiler that was designed to ASME, so it 

5 didn't change for all intents and purposes. 

6 Now, you know, there are some 

7 more modern developments, obviously, and 

8 surface area is still a big thing. But if 

9 you get into some more exotic tubing and that 

10 sort of thing, then you've got a different 

11 basic boiler. But once that has been 

12 developed and certified, then the same set of 

13 conditions apply. 

14 MR. KLEISS: Jeff Kleiss, 

15 Lochinvar. I would disagree with the point 

16 that there is so much consistency, or that 

17 boilers don't change, and, therefore, there 

18 is not a need for verification testing. 

19 My thoughts or points in the 

20 significance of the ASME and the rigor of the 

21 testing that's involved in certification of 

22 the boilers is more to say that boiler 
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1 designs do not rapidly change, nor do we 

2 create small modifications to heat exchangers 

3 once they are designed because it does -- as 

4 was said before, it makes more sense to call 

5 it a whole new model at that point. 

6 However, in cast boilers, you can 

7 have patterns that have tinware, or machining 

8 tolerances can cause sections to be separated 

9 more or less from each other, that opens or 

10 closes the flueways and changes the 

11 efficiency. 

12 You can have other machining 

13 tolerances or baffles that maybe are bent 

14 slightly differently or positioned slightly 

15 differently. Any number of various things 

16 can change within a manufacturing process 

17 that could affect the efficiency of just 

18 about any design boiler. 

19 And to say that because the 

20 design hasn't changed that there is not a 

21 need for verification I believe is 

22 inaccurate. 
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1 MS. BARHYDT: And, Jeff, just to 

2 be clear, you're making that statement across 

3 the full range of sizes of boilers, not just 

4 for the smaller ones? 

5 MR. KLEISS: Yeah. I think that 

6 it would be -- yeah, I think that's a little 

7 bit too sweeping. There may be some 

8 exceptions to that, but I'm concerned that 

9 anybody would say that their process does not 

10 have variability. 

11 MR. HALLEY: What are you talking 

12 about when you talk about machining 

13 tolerances? I mean, it sounds as though you 

14 get into very precise tolerances of 

15 thousandths of an inch or something like 

16 that, whereas those sort of tolerances don't 

17 exist on the big stuff, you know, that you're 

18 not working to thousandths of an inch. 

19 And I think with the sort of 

20 smaller sizes minor changes are going to have 

21 a bigger effect than they are on the big 

22 sizes. They are going to have little or no 
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1 effect at all on the big sizes. 

2 MR. MYERS: This is Frank Myers, 

3 PVI. I tend to agree with Jeff, but I would 

4 add that -- 

5 MR. HALLEY: Which Geoff? 

6 MS. BARHYDT: I was going to say, 

7 there's two Jeffs. 

8 (Laughter.) 

9 MR. MYERS: Jeff Kleiss with 

10 Lochinvar, who is concerned that there is -- 

11 there can be variation. I know when we were 

12 talking earlier, when there was discussion 

13 about not changing and there was mention of 

14 not having to conduct any verification test 

15 because of that, I was thinking at that time 

16 that I didn't necessarily agree with no test, 

17 but I could certainly agree with some reduced 

18 level of test because of these other control 

19 factors. 

20 And it may be when you get into 

21 the very large equipment that the kinds of 

22 tolerances that Jeff Kleiss was talking about 
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1 on a percentage basis may not have the same 

2 impact as they do on a smaller piece of 

3 equipment. 

4 So if there was an even further 

5 reduction of review, let's call it a review 

6 -- a periodic review of the AEDM as opposed 

7 to the equipment, and that serves as their 

8 verification, perhaps we could do something 

9 like that. 

10 But I do want to bring up one 

11 other point. There was a mention of not 

12 checking electrical consumption with BTS13 2000. That's not completely accurate. If 

14 the unit has a blower or other electrical 

15 components that are a part of the appliance, 

16 then they are checked. 

17 So if you -- and as you get to 

18 larger pieces of equipment, perhaps, again, 

19 that's a smaller percentage of the total. 

20 But there is electrical parasitic loss that 

21 if it's on the product -- now, not all 

22 products have those kinds of big electrical 
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1 consumers, but many of the newer products do 

2 have blower systems as opposed to 

3 atmospherically generated, either power-type 

4 burners, gun-type burners, and that consumes 

5 a level of power that should be factored into 

6 the overall efficiency. 

7 MR. SUTPHEN: This is John 

8 Sutphen, Cleaver-Brooks. I disagree on that 

9 last statement. There is not factored in -- 

10 there is no power consumption measurement 

11 during the BTS-2000 test, and nowhere does it 

12 say that you need to do a power consumption 

13 measurement during a BTS-2000 test. 

14 Also, I also disagree with Jeff 

15 Kleiss' statement that there is a lot of 

16 variability. He might be speaking on behalf 

17 of the cast iron market, and maybe the 

18 smaller -- very small residential commercial 

19 stuff. But as far as our industry, with the 

20 traditional fire tube and water tube boilers, 

21 this is not the case. 

22 We stamp a heating surface area 
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1 on every boiler. It's on the ASME form. It 

2 is pretty tightly monitored, so that the 

3 variability in these -- these levels that the 

4 DOE set for commercial heating boilers are -- 

5 for us they are very low. All of our 

6 products can meet it easily. 

7 I think you set them so low for 

8 these smaller boilers, you know, that might 

9 have smaller heating surface areas than what 

10 we have been used to for a hundred years. So 

11 I think, a) we're being what we consider 

12 wrongly grouped in with these small 

13 commercial products by not having a limit on 

14 boiler size as to where you break this -- you 

15 know, the size range. And we are being, you 

16 know, penalized for having a product that 

17 handily meets any regulation for all of this 

18 needless testing. 

19 MR. EISNER: Let me suggest that 

20 I think we are going in the right direction. 

21 We are starting to get into a situation 

22 where we are talking about exceptions within 
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1 the exceptions. Why don't we try to put 

2 something on the screen -- I assume you all 

3 have access to the screen -- so we can start 

4 narrowing down where the differences are, and 

5 maybe have somebody online start off with a 

6 description of what the ASME requires and why 

7 meeting ASME lessens the need for the kind of 

8 testing we are doing for the other equipment. 

9 And then start adding on some of these other 

10 conditions or factors that should be part of 

11 the decisionmaking process. 

12 Does somebody want to start off 

13 and just -- and we can start putting it up on 

14 the screen and describe what we were talking 

15 about in the very beginning, and then we can 

16 start talking about how we are going to 

17 define a boiler or whether we already have a 

18 definition for it. 

19 John, did you want to start off 

20 with a description about meeting the ASME 

21 standards and what that means? 

22 MR. SUTPHEN: This is John 
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1 Sutphen, Cleaver-Brooks. ASME Section 4, 

2 pressure vessel standard, is design3 constrained on how everyone needs to build 

4 their pressure vessel using these design 

5 standards and constraints, as far as how you 

6 -- every part of your pressure vessel is 

7 regulated and dictated by this standard. 

8 MR. EISNER: John, give us a 

9 second. 

10 MR. SUTPHEN: And every time you 

11 build -- 

12 MR. EISNER: John? John, give us 

13 a second here. We're trying to keep up with 

14 you, and there's some technical problem. 

15 (Pause.) 

16 Can you guys see it as it's being 

17 typed? So you know whether Laura is keeping 

18 up with you. 

19 MS. JAKOBS: It is American 

20 Society of Mechanical Engineers. So it's 

21 ASME. 

22 MR. EISNER: E at the end. 
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1 MS. JAKOBS: Yeah. So the very 

2 first part should be -- have an E and not an 

3 I. 

4 MS. BARHYDT: I'm trying, Diane. 

5 Hold on. 

6 MS. JAKOBS: Oh, okay. I'm 

7 sorry. Thank you. 

8 MS. BARHYDT: Okay. So that's 

9 all I've got so far. Go ahead, John. 

10 MR. SUTPHEN: The ASME monitors 

11 the heating surface area for all boiler 

12 products, and you have stamped that on the 

13 boiler. Every time you make that boiler, it 

14 has the exact same heating surface area. 

15 MR. EISNER: Slow down. 

16 MR. SUTPHEN: And that doesn't 

17 change. 

18 MR. EISNER: Anything Laura has 

19 missed so far? What else would you add? 

20 MR. HALLEY: A lot of the heating 

21 surface area is, obviously, the basis of 

22 efficiency. If you've got less for a given 
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1 input or output design, the heating surface 

2 area, if you've got less than this certain 

3 magic number, if you like, of so many square 

4 feet per -- say boiler horsepower is one unit 

5 they use, number of square feet of heating 

6 surface per boiler horsepower. 

7 If that goes down, then you would 

8 expect your efficiency to go down also. But 

9 if it goes up, if you've got more than this 

10 magic number, then you are going to get a 

11 higher efficiency. 

12 MS. JAKOBS: This is Diane. But 

13 I think because of the way the test procedure 

14 is written, you have the -- you measure the 

15 amount of BTUs per hour that go in. 

16 MR. HALLEY: Right. 

17 MS. JAKOBS: And that can vary 

18 for different fuels, but we make adjustments. 

19 And then you measure the BTUs that come out 

20 in the water and how you measure -- how you 

21 measure that is very -- is consistent. 

22 So the biggest variable I think 
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1 is the area. So someone correct me if I'm 

2 wrong, because I'm kind of extrapolating from 

3 things I'm more familiar with. 

4 MR. HALLEY: I'm not sure that I 

5 got all of what you said, Diane. Could you 

6 go through it again? 

7 MS. JAKOBS: Well, I think we're 

8 looking for where is the variability. So, 

9 and we're talking about variability between 

10 -- you make the first unit and you make a 

11 second unit, and that's what verification is 

12 about -- 

13 MR. HALLEY: Right. 

14 MS. JAKOBS: -- if you're making 

15 the same thing a number of times after it was 

16 designed. We're looking for where the design 

17 -- the production process can introduce 

18 variability. 

19 MR. HALLEY: I don't see where it 

20 can. 

21 MS. JAKOBS: Right. So if the 

22 area is the same, you measure -- 
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1 MR. HALLEY: If the area is the 

2 same, then you would expect the same 

3 efficiency. 

4 MS. JAKOBS: Yes. 

5 MR. SUTPHEN: This is John 

6 Sutphen, Cleaver-Brooks. And that's for a 

7 specific model. Let's say Model A has 100 

8 square feet. Model A will always have 100 

9 square feet. If you change that 100 square 

10 feet to 150 square feet, it's now Model B. 

11 It's not Model A. 

12 If you build a Model A, it's 

13 always 100 square feet, or whatever square 

14 feet you want to use. So it's always the 

15 same. So whatever that square footage is, it 

16 never changes for that model. 

17 MS. JAKOBS: This is Diane. I 

18 think we get into trouble when you talk about 

19 the same, because nothing is ever the same. 

20 But can it vary one percent or a half percent 

21 for the surface area? 

22 MR. HALLEY: Obviously, that is 
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1 going to change a little bit with size. For 

2 example, the smaller end of a product line, a 

3 minor variation in, say, tube length is going 

4 to be a bigger percentage than the same 

5 variation on a larger boiler. It's going to 

6 be minimal anyway, you know, I would say less 

7 than one percent. 

8 MR. EISNER: We've been using -- 

9 MR. HALLEY: A lot less than one 

10 percent. 

11 MR. EISNER: We've used the -- 

12 MR. HALLEY: Don't know where the 

13 -- 

14 MR. EISNER: We've used the 

15 comparison 100, 150 would be a different 

16 boiler. What about 110 or 101? Would that 

17 be a different -- 

18 MR. HALLEY: Well, they go in 

19 increments typically. They -- if you look at 

20 a catalogue of a manufacturer, you will see 

21 increments of, say, 100. The next increment 

22 could be 125, and then 150, and they are each 
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1 different boilers. They are different 

2 lengths. 

3 MS. BARHYDT: So does ASME 

4 specify how much variability is permitted? 

5 MR. HALLEY: In dimensions, it 

6 gives you a nominal number. Well, the 

7 designer, the manufacturer, has a nominal 

8 number in the tolerances, are very close. 

9 You know, John may be able to expand on that. 

10 He's more current than I am on the 

11 manufacturing side. 

12 MR. EISNER: But I think the 

13 problem that Laura is getting at is a 

14 regulation can't use words like "typically." 

15 It has to know what the standard is. Would 

16 somebody say, "I have enough room in my 

17 facility for you to make the boiler 105 

18 square feet, because I've got more room and 

19 that would be better for me"? And will 

20 somebody make a boiler for that person in 

21 that size? How can -- 

22 MR. SUTPHEN: That would be a 
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1 different model. This is John Sutphen, 

2 Cleaver-Brooks. 

3 MR. EISNER: Okay. So that's the 

4 question. At what point does it become a 

5 different model, one percent, five percent? 

6 MS. JAKOBS: Maybe we should look 

7 -- this is Diane. Maybe we should look at 

8 the ASME Code and see what the tolerances 

9 actually are. 

10 MR. KLEISS: I don't believe 

11 there are tolerances in Section 4. 

12 MR. HALLEY: Manufacturer sets 

13 the tolerances. 

14 MR. STEPHENS: Phillip Stephens, 

15 HTP. I think maybe we need to look at it 

16 from a little bit different perspective, kind 

17 of a "forest for the trees" situation with 

18 the ASME. We know that there's a definite 

19 break point, although we don't know where it 

20 is, for the large boilers that are very low 

21 volume, custom built, built to order types of 

22 products. 
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1 Maybe we need to set the break 

2 point there instead of looking at the ASME 

3 section. Just a strawman for a thought. 

4 MS. BARHYDT: So where would you 

5 put that line, Phillip? 

6 MR. STEPHENS: Well, I think 

7 Karen mentioned two and a half million 

8 earlier. So I'd throw that out as a first 

9 guess. 

10 MS. BARHYDT: That's BTU -- 

11 MR. STEPHENS: Nothing more than 

12 -- 

13 MS. BARHYDT: -- input or output? 

14 MR. STEPHENS: Input. I think 

15 Frank Myers may have mentioned that in a 

16 previous conversation also. 

17 The other common breakpoint is 

18 the 12-1/2 million BTUs, but I'm pretty sure 

19 -- 

20 MR. HALLEY: That's a control 

21 standard, that's CSD 1 control standard, 

22 which is also an ASME standard. 
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1 MS. MEYERS: Hey, Laura, this is 

2 Karen Meyers. I have to get off the phone, 

3 so if there are any votes taken, Diane has 

4 the proxy for Rheem. 

5 MS. BARHYDT: There be no votes 

6 today. We are just gathering information 

7 today. 

8 MS. MEYERS: Great. Good luck. 

9 MR. KLEISS: This is Jeff Kleiss. 

10 There is one other thing that I think may be 

11 a misconception that is affecting our 

12 discussion. And correct me if I'm wrong, but 

13 we are not talking about just determining 

14 yes, no, minimum compliance with the 

15 standard; but, rather, what we're talking 

16 about is accurate and consistent 

17 representation of the actual performance of 

18 the appliance. 

19 MS. BARHYDT: That's correct. 

20 MR. KLEISS: Okay. 

21 MR. EISNER: So how do we, again, 

22 determine where the break point is and 
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1 whether -- 

2 MR. HALLEY: Well, I'll -- the 

3 two and a half million input sounds fine to 

4 me. I don't know what John thinks, but it's 

5 fine with me. 

6 MR. SUTPHEN: It sounds fine to 

7 me. 

8 MS. BARHYDT: Okay. 

9 MR. EISNER: What does this mean 

10 in terms of the 100 versus the 150 square 

11 feet? 

12 MS. BARHYDT: That I'm not sure. 

13 MR. EISNER: Can somebody explain 

14 that? 

15 MR. STEPHENS: Phillip Stephens, 

16 HTP. It would be across dose boards where -- 

17 my comments before about the requirements of 

18 ASME, they were well below the two and a half 

19 million. Typically, if anything -- from my 

20 experience, if anything is a million BTUs or 

21 over, they are going to want ASME on it. So 

22 I know the break point is somewhere below 
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1 that, but I'm not sure where. 

2 MR. HARDIN: This is Travis 

3 Hardin. Can anybody hear me? 

4 (Several answers in the 

5 affirmative.) 

6 Okay. UL 795, the break point 

7 starts at 400,000. And the other thing I 

8 wanted to ask is, in commercial industrial 

9 boilers, would Section 1 of ASME be required 

10 or be used in lieu of Section 4? 

11 MR. HALLEY: Section 1 is high 

12 pressure code. I don't think that's covered. 

13 This is a heating boiler code, which is 

14 Section 4. 

15 MS. BARHYDT: Did that make sense 

16 to everyone? 

17 MR. KLEISS: Well, Travis brings 

18 up a good point. I mean, a Section 1 boiler 

19 is still a boiler. It still has an 

20 efficiency rating and should be covered. 

21 MR. MYERS: Yeah. This is Frank 

22 Myers, PVI. We have actually gotten -- 
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1 received cut and build custom boilers where 

2 the customer wanted it certified to Section 

3 1, but they intended to operate it at lower 

4 pressures. 

5 So it was designed to be able to 

6 handle the higher pressures, but their 

7 operation was at lower pressure. And we felt 

8 that that unit had to comply with the current 

9 DOE requirements. 

10 MR. HALLEY: Yeah. Doesn't DOE 

11 sort of specify that the requirements tie 

12 into heating boilers rather than, say, 

13 process boilers or industrial boilers? 

14 MR. MYERS: In this particular 

15 case, it was being used as a heating boiler. 

16 There was a customer who wanted to have what 

17 he felt was -- that customer felt was the 

18 greater certainty of performance afforded by 

19 the tighter constraints of Section 1. 

20 MR. SUTPHEN: This is John 

21 Sutphen, Cleaver-Brooks. A Section 1 boiler 

22 is not a heating boiler. It's a process 
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1 steam boiler. So if the customer wants a 

2 Section 1 boiler, it's not a heating boiler. 

3 If they want to use it for heating, that's 

4 their prerogative. It's just tighter design 

5 constraints. I don't think we should really 

6 need to discuss Section 1 boilers in this 

7 heating boiler discussion. 

8 MS. BARHYDT: Well, I was going 

9 to try and pull up the definitions for 

10 everyone, but -- 

11 MR. HALLEY: I think the DOE 

12 definition of a boiler is the same as the 

13 Section 4 definition of a boiler, ASME 

14 Section 4 I think, if I remember right. 

15 MS. BARHYDT: Okay. So I'm going 

16 to put them up on the screen. Okay. So give 

17 me one second, and I'll get them all up here. 

18 (Pause.) 

19 Okay. So that's commercial 

20 packaged boiler. Let's see, packaged boiler 

21 -- 

22 MR. STEPHENS: Laura, can we also 
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1 get the definition of the hot water supply 

2 boiler -- 

3 MS. BARHYDT: Okay. 

4 MR. STEPHENS: -- referenced in 

5 Item 2? Thank you. 

6 (Pause.) 

7 MR. KLEISS: Hey, Laura? 

8 MS. BARHYDT: Yes. 

9 MR. KLEISS: I just sent through 

10 the question and answer thing what you're 

11 typing. You can cut and paste. 

12 MS. BARHYDT: Thank you. 

13 MR. KLEISS: If it helps. 

14 MS. BARHYDT: Oh, darn. It went 

15 to the other computer. The trick is getting 

16 it to this computer. 

17 (Pause.) 

18 Does anyone know offhand where 

19 the definition of hot water supply boiler is? 

20 It's somewhere in the part, but it's not in 

21 this one. 

22 MR. EISNER: Did everybody hear 
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1 Laura's question? 

2 MR. KLEISS: Yeah. I'm looking. 

3 MS. BARHYDT: Okay. 

4 MR. BALLO: Hey, Laura, this is 

5 Tim Ballo. 

6 MS. BARHYDT: Yes. 

7 MR. BALLO: The definition of hot 

8 water supply boiler is in 10 CFR 431.102. 

9 MR. KLEISS: That's right. It's 

10 under water heaters. 

11 (Pause.) 

12 MS. BARHYDT: Okay. Any other 

13 definitions that would be useful? 

14 MR. KLEISS: I think it's 

15 worthwhile to point out that Table 1 in 

16 431.87 does divide the efficiency metrics at 

17 2.5 million BTUs per hour. So there is a 

18 pre-existing DOE dividing line that -- 

19 MS. BARHYDT: Oh, yes. 

20 MR. KLEISS: -- coincides with 

21 what we've been talking about. 

22 MS. BARHYDT: There's no way to 
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1 get it all on one screen. 

2 (Pause.) 

3 Okay. So all of this was to 

4 address a question as to what DOE's coverage 

5 was. So does this help with that issue? 

6 (No response.) 

7 Silence. 

8 MS. JAKOBS: This is Diane. 

9 Maybe the point is that the verification 

10 process should be different for these 

11 categories. 

12 MR. STEPHENS: Yes. This is 

13 Phillip. That was my intent for the 

14 strawman. 

15 MR. EISNER: Others agree with 

16 that or disagree with that? 

17 (No response.) 

18 All right. So assuming the lack 

19 of any statement means that generally there 

20 is agreement. What would the requirements be 

21 for each of these categories? 

22 MR. MYERS: This is Frank Myers, 
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1 PVI. I have some concern with a two and a 

2 half million break point in terms -- if the 

3 answer for above two and a half million is no 

4 verification, a significant part of the 

5 market right now for commercial boilers is in 

6 the -- in buildings that need four, six, 

7 eight million BTUs. 

8 And I'm sorry, I'm getting some 

9 feedback, it's difficult to carry on a 

10 thought here. 

11 But with boilers that are less 

12 than two and a half million, those are 

13 frequently provided, if that's what a 

14 manufacturer has, they will provide multiples 

15 of those boilers. Another manufacturer could 

16 have a single product or fewer numbers of 

17 let's say three million or four million BTU 

18 boilers that serves the exact same purpose, 

19 consumes the exact same amount of energy, 

20 plus or minus what the efficiency is, so they 

21 are serving the same market and one would be 

22 verified with some level of testing. 
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1 And I would not have a problem 

2 with a lower level of testing for products 

3 above two and a half million. But if we're 

4 looking at a break point with no verification 

5 testing unless there is a new model which 

6 would follow its certification requirements, 

7 I would be very uncomfortable about that. 

8 So it boils down to me, no 

9 testing versus a lower level of testing. 

10 MR. EISNER: Comments or 

11 questions? 

12 MR. STEPHENS: Phillip Stephens, 

13 HTP. I would agree with that statement. I 

14 think a good point to make is, the definition 

15 of packaged boiler, where it would be the 

16 total assembly of all of the smaller units. 

17 MR. EISNER: Does anybody 

18 disagree with this? 

19 MR. SUTPHEN: This is John 

20 Sutphen, Cleaver-Brooks. I disagree. 

21 MR. EISNER: And how would you 

22 respond to the specific points that were 
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1 made? 

2 MS. BARHYDT: So apparently, 

3 Geoff Halley, your phone was the one that was 

4 causing the feedback, so we have muted you. 

5 If you need to speak, raise your hand on the 

6 webinar, so that we can unmute you. 

7 MR. HALLEY: Yeah. I think I am 

8 unmuted now, aren't I? 

9 MS. BARHYDT: Yep. We can hear 

10 you now. 

11 MR. HALLEY: Okay. Yeah. I am 

12 not sure that I followed Frank completely 

13 with his sort of eight million. You know, 

14 when you design a building, obviously, with a 

15 boiler room which is a required sort of 

16 design input, if you like, for the boilers of 

17 eight million, it is usually more than -- 

18 typically more than one boiler. 

19 Otherwise, you know, the 

20 possibility of a breakdown will leave the 

21 building without heat if you've only got one 

22 boiler, is sort of the typical way of doing 
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1 things is to put in more than one. So if 

2 you've got eight million, you could put two 

3 boilers in. 

4 I'm not sure that I can agree 

5 with everything that was said there. I still 

6 think that the -- you know, that we've got a 

7 definite split between the two entities 

8 controlling boilers, if you like, or where 

9 the membership of boiler manufacturers is. 

10 And they are different worlds, 

11 and, you know, I've worked in both segments 

12 to a degree, more to the larger end. But I 

13 do some sort of expert witness work in the 

14 smaller end. So I've got a feel for what 

15 goes on there, and they are entirely 

16 different. 

17 MR. EISNER: Geoff, do you have a 

18 problem with the concept of some testing? In 

19 other words, do you prefer no testing above 

20 two and a half? Does it depend on what -- 

21 MR. HALLEY: I think the industry 

22 that I'm involved in is less prone to some of 
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1 the concerns that are being expressed by the 

2 -- you know, the smaller end of the 

3 marketplace. You know, there's a lot more 

4 money involved in developing the product, and 

5 it's got more longevity. 

6 So, ideally, I think you could 

7 rely on the manufacturer. But, you know, 

8 there's so much distrust these days that, you 

9 know, some minimal amount of testing I think 

10 -- I don't think you need verification 

11 testing. You know, you've obviously got to 

12 do a certification-type test at some point. 

13 But, beyond that, I don't think it's 

14 necessary. 

15 MS. BARHYDT: Okay. So 

16 certification testing is the testing that is 

17 already required by DOE regulations, and it 

18 is not something that we have -- that is 

19 within the scope of this working group. The 

20 certification testing was I guess an issue 

21 only to the extent that we were dealing with 

22 AEDMs and the ability to -- 
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1 MR. HALLEY: Right. 

2 MS. BARHYDT: -- simulate. So 

3 the certification testing -- 

4 MR. HALLEY: Right. 

5 MS. BARHYDT: -- requirements are 

6 what they are, and the issue is whether or 

7 not -- 

8 MR. HALLEY: Right. 

9 MS. BARHYDT: -- there should be 

10 verification testing. 

11 MR. HALLEY: Right. 

12 MR. EISNER: And, Frank, when you 

13 talk about some verification testing, what 

14 were you talking about? What are you 

15 thinking it would be? 

16 MR. MYERS: This is Frank Myers, 

17 PVI. Neil, if you are asking, what kind of 

18 volume do I think, I have always been a 

19 proponent of at least one test per year. No 

20 matter what your circumstance, if you only 

21 make one model, I still feel it's appropriate 

22 to have one test per year. So I wouldn't 
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1 even be uncomfortable as long as the 

2 Department was involved in making the 

3 decision as to what unit is tested. 

4 Obviously, when you get into the 

5 larger sizes, they would have to work with 

6 the manufacturer as a part of their 

7 production process to test something that is 

8 actually being built. But I actually have 

9 situations right now where we have some high 

10 efficiency products that currently only go up 

11 to two million. We have them safety 

12 certified to two and a half million. 

13 And at the time we certified it, 

14 that gave us quite a range of sales. And if 

15 you needed four million BTUs, you would put 

16 in two. If you needed six million BTUs, 

17 you'd put in three. And today what we're 

18 seeing is our direct competitors are taking 

19 their condensing designs to slightly larger 

20 sizes, something above two and a half 

21 million, so that they can sell fewer of the 

22 products to meet the building demand. 
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1 Sometimes it is fewer as in one 

2 larger boiler, and the building owner is 

3 willing to take that risk, and then sometimes 

4 there are multiples, like if they had six 

5 million BTU load they could put in two of the 

6 higher efficiency three million BTU products, 

7 but they would have to put in three of our 

8 products. 

9 So we are direct competitors in 

10 the same market, and I -- again, I wouldn't 

11 have a problem if they have less testing. 

12 But I would be uncomfortable, just knowing my 

13 competitors and what the possibilities are, 

14 for them to not have the exact number that 

15 they claim. I would like to see at least 

16 some level of testing. 

17 MR. EISNER: And what's the 

18 reaction to -- among the others on the phone 

19 to the idea of one per year chosen by DOE? 

20 MS. BARHYDT: Of something you 

21 are -- 

22 MR. SUTPHEN: This is John 
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1 Sutphen, Cleaver-Brooks. Our stance is zero 

2 testing. 

3 MS. JAKOBS: This is Diane 

4 Jakobs, and what you're proposing, what 

5 Frank's proposing I think, is instead of the 

6 way we think about it with residential that 

7 you're verifying each product design, I think 

8 you're talking about verifying the 

9 manufacturer's ability for repeatability of 

10 their design. 

11 So you're not going to look at -- 

12 I mean, it's just kind of more of a random 

13 sample. And I think that that is -- I think 

14 that's reasonable. I think it's hard to say 

15 you know the repeatability of your design if 

16 you're not testing it. 

17 So unless manufacturers had test 

18 data to support that their design doesn't 

19 vary, I don't think you can really say that 

20 it doesn't. So I think the idea of one test 

21 a year to verify just the manufacturer in 

22 general is reasonable. 
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1 MR. STEPHENS: Phillip Stephens. 

2 I would agree with that, but I would want to 

3 consider moving that limit higher from two 

4 and a half million to possibly five million. 

5 MR. EISNER: Any reaction to that 

6 or to the original point that we were talking 

7 about? 

8 MR. SUTPHEN: I just don't see -- 

9 if I can -- this is John Sutphen, Cleaver10 Brooks. If I remember correctly, for 

11 verification testing, I think there is up to 

12 five percent. 

13 MS. BARHYDT: No, no, no. So at 

14 the last meeting we were talking about how 

15 much testing, but there has been no decision 

16 about how much. And in particular, the 

17 discussions so far have focused on built to 

18 stock units, not custom built units, or built 

19 to order. 

20 MR. SUTPHEN: Okay. Because we 

21 don't have any build to stock units that -- 

22 MS. BARHYDT: Right. 
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1 MR. SUTPHEN: -- that we're 

2 really concerned about. 

3 MS. BARHYDT: So we are -- to the 

4 extent that -- so so far we have not 

5 discussed how much testing would be required 

6 for built to order products. We haven't 

7 discussed that at all. So there is no 

8 presumption of a certain amount. It's a 

9 question of -- 

10 MR. SUTPHEN: I'm talking about 

11 -- 

12 MS. BARHYDT: -- should there be 

13 some or none? 

14 MR. SUTPHEN: I guess it's -- I 

15 was talking about percentage of being off of 

16 your -- what you're saying your efficiency is 

17 -- 

18 MS. BARHYDT: Okay. 

19 MR. SUTPHEN: -- for verification 

20 testing. 

21 MR. HALLEY: The variability of 

22 tests is -- 
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1 MR. SUTPHEN: Yes. If it's five 

2 or 10 percent, I mean, that's pretty -- when 

3 you're talking about, oh, you can't have any 

4 variability, yet we're saying you can be up 

5 to 10 percent off, that just -- I mean, 

6 you're talking about variability that might 

7 have a half percent -- in our boiler 

8 industry, and every one in our -- from our 

9 side of the industry, it's -- I think you've 

10 got the one side is going about -- they want 

11 the DOE to list their efficiencies, and it's 

12 going to be the most accurate efficiency they 

13 have ever listed. 

14 And anyone that can't, you know, 

15 list its accurate efficiency can -- you know, 

16 they're going to use it in their sales 

17 literature and everything like that. Where 

18 the DOE just wants the minimum efficiency 

19 requirement, we would like to list that, yes, 

20 we comply, or no, we don't comply, and save 

21 all of the accuracy efficiency tests for the 

22 third party agencies like AHRI or UL or CSA 
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1 or anyone that wants to do that. But -- 

2 MR. KLEISS: John, this is Jeff 

3 Kleiss. This is not just about compliance 

4 with the minimum efficiency. This is about 

5 verification of the claimed ratings. 

6 MR. HALLEY: Well, what is the 

7 claimed ratings are we will meet the DOE 

8 minimum efficiency standards, and that's all, 

9 not a specific number? 

10 MS. BARHYDT: Well, so DOE does 

11 require you to provide a number. You are 

12 allowed to conservatively rate at the 

13 standard, so you would -- it sounds like what 

14 you would want to be doing is to rate it at 

15 whatever the standard is for that particular 

16 model. 

17 MR. HALLEY: Right. 

18 MR. EISNER: But you'd still have 

19 to do verification testing. 

20 MS. BARHYDT: And so if you rated 

21 it at the standard, then the verification 

22 would be verifying that it meets the 
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1 standard. 

2 MR. HALLEY: Okay. 

3 MR. EISNER: So in light of these 

4 clarifications, again, let me ask about 

5 concerns with one test, one verification 

6 test, on a product chosen by DOE. And let's 

7 also focus -- 

8 MR. SUTPHEN: This is John 

9 Sutphen. 

10 MR. EISNER: Go ahead, John. 

11 MR. SUTPHEN: There is also the 

12 point where there's sizes of product that are 

13 covered that we cannot physically test, and 

14 no one that you can pay can physically test 

15 them without buying brand-new equipment and 

16 spending over a million dollars to do it. 

17 So it's just not possible because 

18 you're talking about up to two million, two 

19 and a half, you know, maybe up to five 

20 million, where, you know, we can have 50 or 

21 60 million BTU input boilers on a common 

22 basis. So I don't know how you -- how we're 
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1 going to settle the question that -- or 

2 verify that on a yearly basis. 

3 MR. HALLEY: It's a lot easier 

4 for the smaller end of the marketplace to do 

5 this repeat testing, because it's relatively 

6 inexpensive from not only installing it in a 

7 test facility but also, you know, the fuel 

8 bill and that sort of thing and the time to 

9 test, whereas when you get into the larger 

10 stuff it is a lot of money to test. So it's 

11 not necessarily a fair comparison I don't 

12 think. 

13 MS. BARHYDT: So if we let you 

14 test it in your facility, does that change 

15 anything? 

16 MR. HALLEY: Still a lot of money 

17 for fuel and installing it in the test 

18 facility. 

19 MR. SUTPHEN: This is John 

20 Sutphen. We don't have the facility to test 

21 the larger products at the requirements of 

22 the BTS-2000. 
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1 MS. BARHYDT: Okay. So are those 

2 the same products that you are seeking a test 

3 procedure waiver for? Or are those different 

4 -- 

5 MR. SUTPHEN: Correct. 

6 MS. BARHYDT: -- products? 

7 MR. SUTPHEN: This is John 

8 Sutphen. It's the same product that we're 

9 seeking a waiver for. And we don't know of a 

10 single test facility in the United States 

11 that can test our products to the BTS-2000. 

12 MS. BARHYDT: Okay. So assuming 

13 that we did get a test procedure waiver for 

14 you, then at that point it would be testing 

15 to whatever that test procedure waiver 

16 specified. So presumably whatever you are 

17 requesting is something that you can test to 

18 in-house, is that correct? 

19 PARTICIPANT: Laura, would you 

20 say that again, please? 

21 MS. BARHYDT: Yes. So what I was 

22 asking is, for the products for which they 
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1 are requesting a waiver, if we were to grant 

2 that waiver, presumably what they are 

3 requesting as their alternate test method is 

4 something that they can actually perform in5 house. And I was wondering if that -- 

6 MR. SUTPHEN: This is John 

7 Sutphen. Based on our waiver, saying that we 

8 want to test the steam boiler, we would be 

9 able to do that in-house. 

10 MR. STEPHENS: Phillip Stephens, 

11 HTP. With the discussion we had at the last 

12 ASRAC meeting, the followup question I'd have 

13 to ask is if you would be able to obtain 

14 17025, because my concern is that very large 

15 products, it's going to be very difficult for 

16 manufacturers to obtain 17025, and very small 

17 businesses are going to be in the same 

18 situation. 

19 MR. HALLEY: I would say that 

20 it's going to be impossible for the 

21 manufacturers to get 17025 approval. You 

22 know, the facilities, they are just not 
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1 compatible with that sort of an approval. 

2 MS. BARHYDT: Is there something 

3 else that the Department could look to to 

4 verify the ability of the lab to meet the 

5 same sort of criteria without that 

6 accreditation? 

7 MR. STEPHENS: Phillip Stephens, 

8 HTP. The approach that most manufacturers 

9 take is they go through all of the 

10 requirements of 17025, but it's the act of 

11 obtaining the actual certification is where 

12 most of us draw the line. So calibration 

13 records, yes, those are typically something 

14 that we could provide a list of the people 

15 that complete the testing. 

16 Yes, we could provide, along with 

17 a copy of their resume or their experience 

18 and training history, we can provide that 

19 information, yes. The third party with DOE 

20 is a point of discussion also. 

21 MR. KLEISS: But what is it that 

22 is not doable that you -- the reason that you 
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1 cannot get 17025? 

2 MR. HALLEY: I just think that 

3 17025 is looking for a lot of things that 

4 don't exist in a manufacturing facility. A 

5 lot of this testing is done at the end of the 

6 production line in a fire test area, and 

7 that's just not compatible with the -- you 

8 know, 17025. 

9 As I've said before, the basic 

10 requirements of an accurate test are a test 

11 procedure that's agreed on, capable people, 

12 and, you know, they are not going to be 

13 allowed to test boilers of this size unless 

14 they are capable and competent people, well 

15 qualified, and extra instrumentation that has 

16 been properly calibrated and traceable and 

17 necessary for some standard, and, you know, 

18 the ability to reduce the test data to 

19 meaningful numbers in the end, meaningful 

20 efficiencies. 

21 And beyond that, you know, we 

22 have tested in the past on a railroad car the 
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1 side of the plant powerhouse because we got 

2 the fuel supplies, the electrical supplies, 

3 from the plant powerhouse out onto the 

4 railroad car. And we tested basically on the 

5 flight car, and the whole town could hear the 

6 thing firing. It made that much noise. That 

7 was, you know, 25, 30 million BTU input. So 

8 you can get adequate test data without a 

9 fancy facility is what I'm trying to say. 

10 MR. HARDIN: This is Travis. For 

11 the smaller boilers -- and when I say 

12 "smaller," I'm saying like, you know, less 

13 than 12-1/2 million, if you are currently 

14 getting those safety tested in your facility, 

15 that could serve a purpose for meeting, you 

16 know, currently ISO 17025 requirements, such 

17 as when we use the UL static test program, 

18 you know, we are following the rules in 

19 general of 17025. 

20 But I do agree with you, Geoff, 

21 when you get up into the large boilers, 

22 really anything above 12-1/2 million, it is 
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1 incredibly difficult to -- 

2 MR. HALLEY: Right. 

3 MR. HARDIN: -- hot water boiler, 

4 if not impossible. And then, a steam boiler 

5 is a little easier to test, but, yeah, with 

6 the fuel and all of the requirements for 

7 water and -- 

8 MR. HALLEY: Yeah. Well, let me 

9 ask you -- okay. Travis, let me ask you, is 

10 there anything that you see where the current 

11 UL testing of these boilers could be easily 

12 added to or adapted to meet some of the 

13 requirements of what DOE is looking for, up 

14 to 12-1/2 million? 

15 MR. HARDIN: Well, the standards 

16 in question, you know, that we currently use 

17 for the listing and certification, you know, 

18 of the test equipment essentially is going to 

19 be constrained. But, you know, efficiency is 

20 not a safety test, so -- 

21 MR. HALLEY: Right. 

22 MR. HARDIN: -- you know, I think 
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1 it could be done in conjunction. But at the 

2 same time, you know, depending on what is 

3 decided, I don't know if it would be added to 

4 the standard. 

5 MR. HALLEY: Well, you've got -- 

6 if you're going to do that, you've got to be 

7 able to run for a longer period of time than, 

8 you know, we possibly run on a standard UL 

9 safety test, and that, you know, a sort of 

10 operating pressure that is compatible with 

11 the boiler, which is not necessarily always 

12 done on a UL safety test. 

13 MR. HARDIN: Right. And the 

14 other thing about safety is, you know, we 

15 choose a representative sample. We don't 

16 necessarily -- 

17 MR. HALLEY: Right. 

18 MR. HARDIN: -- test the whole 

19 product line. 

20 MR. HALLEY: Right. Yeah. 

21 MS. BARHYDT: So, Geoff, you've 

22 said several times that the firing area at 
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1 the end of the line is not conducive to 

2 17025. Can you just explain to me a little 

3 bit more about what it is about that area 

4 that makes it -- 

5 MR. HALLEY: Well -- 

6 MS. BARHYDT: Because I have no 

7 mental model of what you're describing. 

8 MR. HALLEY: You probably ought 

9 to go into a boiler plant and look. It's not 

10 a particularly clean environment for a start 

11 in -- you know, it's a heavy manufacturing 

12 environment, a lot of overhead cranes in many 

13 cases, where, you know, boilers are moving 

14 around in the air, so you've got to watch out 

15 for things. 

16 The fire test area is -- it 

17 doesn't typically have a proper place to 

18 vent, control the steam pressure and vent it. 

19 They normally do a fire test just to check 

20 the safety controls and rough-in the 

21 combustion. That's done in the field by, you 

22 know, a certified startup technician. 
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1 But they just want to make sure 

2 all of the safety controls work before it 

3 leaves the plant, they do have a supply of 

4 water, and they do have a supply of fuel, 

5 which is -- 

6 MS. BARHYDT: Okay. 

7 MR. HALLEY: -- meets the rated 

8 capacity of the boiler. 

9 MS. BARHYDT: But that's -- 

10 MR. HALLEY: It's got some 

11 elements missing. 

12 MS. BARHYDT: But that sounds to 

13 me like it's not a place where they could 

14 actually conduct the test at all, then, as 

15 opposed to it not being able to meet 17025. 

16 MR. HALLEY: It's going to be 

17 very difficult to test, to make a reasonable 

18 test to capacity and pressure. In fact, it's 

19 going to be -- obviously, I don't know what 

20 every manufacturer who belongs to ABMA has in 

21 the way of capabilities. I do know -- I 

22 conducted a survey recently, and I do know 
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1 that most of them have the fuel supply to get 

2 to most of the capacities they produce, not 

3 necessarily all of them. 

4 But, you know, they've got enough 

5 to be able to test and say, "Okay. This 

6 boiler is safe, and it's not going to be a 

7 significant problem when it gets into the 

8 field to be started up properly by an 

9 approved technician." 

10 MR. KLEISS: This is Jeff Kleiss. 

11 Let's talk about some of the specifics of 

12 what you need in order to do the efficiency 

13 test. For these products we're talking about 

14 combustion efficiency test, so you have to 

15 have a calibrated combustion analyzer. 

16 MR. HALLEY: Right. 

17 MR. KLEISS: You need to be able 

18 to measure the water temperature, you need to 

19 measure the fuel flow rate -- 

20 MR. HALLEY: Right. 

21 MR. KLEISS: -- a barometer. 

22 What else? Let's walk through this. And 
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1 what is it that is preventing us from saying 

2 that we should do a 17025? And also, with 

3 respect to that, there are some advantages 

4 maybe for these small, you know, production 

5 line -- small volume production line, large 

6 product units, as far as part of 17025 is the 

7 process of controlling the products, knowing 

8 that, you know, what you're testing, keeping 

9 track of it and recordkeeping, and actually 

10 there are some advantages to low volume as 

11 far as writing a procedure and making sure 

12 that you're keeping your records properly. 

13 So -- 

14 MR. HALLEY: John, do you want to 

15 respond to that? You are more -- you are 

16 closer to that these days than I am. 

17 MR. SUTPHEN: This is John 

18 Sutphen, Cleaver-Brooks. 

19 MR. HALLEY: Sorry. I think I 

20 lost connection for a while, but carry on, 

21 John. 

22 MR. SUTPHEN: When we do testing, 
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1 we are using calibrated equipment that 

2 complies with the 17025, but we are not -- we 

3 are at a certified lab with 17025 or 17065, 

4 or whatever we were talking about last 

5 meeting. And I think it -- you're putting a 

6 lot of extra expense. 

7 It all depends how you write it. 

8 Do you want us to comply with it, or be 

9 certified for it? Once we figure out the 

10 distinction between those, I think we can 

11 have a better answer for you. 

12 MS. BARHYDT: Well, let's take -- 

13 MR. SUTPHEN: I don't think 

14 anyone really has an issue complying with 

15 this, but getting certified to it I think is 

16 -- you know, people are not going to like 

17 that too much. 

18 MR. KOJAK: This is Mike Kojak 

19 with UL. Laura, this is the same kind of 

20 thing we were talking about in the last 

21 meeting, the way UL has a witness test data 

22 program, where, you know, a representative of 
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1 the ISO 17025 lab goes to the client's 

2 facility and witnesses the test, and, you 

3 know, makes sure that the instrumentation is 

4 calibrated properly or, you know, they can 

5 even bring some ISO 17025 accredited, 

6 calibrated instruments from, you know, our 

7 location to the client's location to install 

8 in the setup process. 

9 So when the test is being done, 

10 it's witnessed by an ISO 17025 person, and it 

11 also is made sure that it -- the calibration 

12 of the equipment is done properly or they can 

13 supply their own equipment when they come 

14 there. 

15 MS. BARHYDT: So going back to -- 

16 MR. KOJAK: So what I'm trying to 

17 say is, if Cleaver-Brooks has, you know, the 

18 utilities and the piping and, you know, the 

19 infrastructure to run those types of tests, 

20 but they just don't meet the level of ISO 

21 17025 as the definition because, you know, 

22 they can't technically become ISO 17025, the 
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1 way we were talking about establishing the 

2 other programs was that they would have to be 

3 -- there would be an oversight of -- you 

4 know, it would -- the two choices would be 

5 that testing would have to be done at a 

6 17025-accredited third party lab or be 

7 witnessed by a third party lab, the testing. 

8 So if the manufacturer, like 

9 Cleaver-Brooks, has the facilities, if they 

10 are just being oversighted by a 17025 third 

11 party lab, that would be the same type of 

12 thing that we are talking about with CRE and 

13 commercial HVAC. 

14 MS. BARHYDT: Right. 

15 MR. KLEISS: That is exactly the 

16 kind of certification that we have here at 

17 Lochinvar. 

18 MS. BARHYDT: So, Geoff Halley, 

19 what I thought I heard you say was that you 

20 didn't think that some of the manufacturers 

21 have the infrastructure to do the test, at 

22 least certainly not to the level of meeting 
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1 the requirements of 17025, whether that 

2 certification is actually obtained or not. 

3 But I think what I heard John 

4 Sutphen say is that he thinks that the 

5 manufacturers do have the infrastructure and 

6 the capability of meeting the requirements. 

7 It is a question of the expense of actually 

8 getting the certification. So if both of you 

9 all could speak to whether I have correctly 

10 characterized your statements or -- 

11 MR. SUTPHEN: This is John 

12 Sutphen, Cleaver-Brooks. I was speaking more 

13 on our behalf instead of the industry's. I'm 

14 sure there are a lot of our competitors and 

15 boiler manufacturers that can, but I'm not 

16 aware that all of them can. And Geoffrey 

17 might have a better understanding on that. 

18 MR. HALLEY: Yeah. That's more 

19 or less what I was going to say, that 

20 Cleaver-Brooks -- you've got to realize that 

21 Cleaver-Brooks is the biggest boiler 

22 manufacturer in this part of the industry, 
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1 and they have a lot of the right things, so 

2 it comes down to expense. 

3 But with the small manufacturers, 

4 you know, they are -- they just don't have 

5 the facility that Cleaver-Brooks or the 

6 companies I used to work for have. And it's 

7 really going to push people, be pushing them 

8 hard. They are going to be hard-pressed to 

9 do a lot of the things that DOE requires or 

10 wants. 

11 MS. BARHYDT: And, John -- 

12 MR. MYERS: This is Frank Myers. 

13 

14 MS. BARHYDT: John, is -- 

15 MR. MYERS: This is Frank Myers. 

16 Go ahead. 

17 MS. BARHYDT: So, John, for your 

18 company, it sounded like your biggest concern 

19 was whether or not the actual 17025 

20 accreditation was required, but would you be 

21 more comfortable with it if we just said that 

22 the general requirements of 17025 had to be 
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1 met but not the actual certification 

2 obtained? 

3 MR. SUTPHEN: We would have to 

4 read the document to make a comment, but I 

5 guess we would lean towards that being true. 

6 But until we actually understand exactly 

7 what 17025 is, we can't really comment on it. 

8 MS. BARHYDT: Okay. 

9 MR. MYERS: This is Frank Myers 

10 with PVI. Two points. One, with reference 

11 to 17025, we have heard several times -- and 

12 it seems to me that any one of the three 

13 would be reasonable in this case -- that the 

14 lab doesn't have to have 17025 for two of 

15 those techniques. One is to have the lab -- 

16 an independent 17025 lab come to their 

17 facility and run the test using their own 

18 instruments. 

19 If the manufacturer has properly 

20 calibrated instruments, then the 17025 third 

21 party lab could come in and witness test 

22 using their instruments if they were 
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1 satisfactory. Or the third would be if the 

2 manufacturer has 17025 through a third party 

3 lab. 

4 So the first two of those don't 

5 require the manufacturer to have 17025, or 

6 even to have the instruments necessary. They 

7 just have to have the infrastructure to be 

8 able to provide the energy needed to run the 

9 test. 

10 The second point is there are 

11 unique issues being able to test products 

12 over the 12-1/2 million. And where I'm an 

13 advocate of one test per year in any event, I 

14 could probably get comfortable with that not 

15 being the case over 12-1/2 million. 

16 MR. EISNER: Would you say that 

17 again, that last part? 

18 MR. MYERS: Yes. I would be 

19 willing to talk about having three levels 

20 instead of two. We were trying to break it 

21 into under and over. But to have up to two 

22 and a half million, we do whatever we say we 
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1 have to do, which has not been locked in yet, 

2 but we decide what we do for less than two 

3 and a half million, two and a half and less. 

4 Over two and a half million up to 12-1/2 

5 million have one per year. And then none per 

6 year over 12-1/2 million because of their 

7 unique circumstance. This is the 

8 verification side. 

9 MR. HALLEY: I'd like to follow10 on from what Frank has just said, and the -- 

11 looking at the sort of sales volume based on 

12 size, the 12-1/2 million BTU would capture 

13 the vast majority of the large boilers. I 

14 don't know whether John wants to add to that 

15 or not. But from what I recall, the vast 

16 majority of the larger boilers would be 

17 caught under the 12-1/2 million size limit. 

18 MR. EISNER: And did you say 

19 you'd be okay with that, with what Frank 

20 proposed for two and a half -- 

21 MR. HALLEY: I think -- you know, 

22 I'd have to check with the membership of 
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1 ABMA, but I would think they would be -- you 

2 know, off the cuff, I think they would be 

3 reasonably comfortable with that. 

4 MR. EISNER: And, John, what -- 

5 MR. KLEISS: This is Jeff Kleiss. 

6 MR. EISNER: Yes? 

7 MR. KLEISS: And one of the 

8 things that we brought up in discussions this 

9 past week was the idea of having a selection, 

10 not being required to test it immediately, 

11 but not being allowed to sell a certain model 

12 until it was tested. And maybe for some of 

13 the extremely large units you could say even 

14 for the size range of not selling a unit 

15 beyond such and so size until one unit is 

16 tested, given some period of time, so that 

17 there is at least still some oversight, even 

18 for the very large products. 

19 MS. BARHYDT: Okay. So -- 

20 MR. KLEISS: So when they produce 

21 something for sale, because nobody is going 

22 to want to -- it's just not practical to 
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1 produce these for testing, but to say, you 

2 know, you've got -- for a unit over the 12.5 

3 million to say, you know, you don't -- you 

4 don't sell this unit until it's tested. 

5 So somebody places an order for 

6 one, you build it, and then while you've got 

7 it there you test it before you ship it out, 

8 say maybe on a -- whether it's once every two 

9 years, once every five years. 

10 MR. MYERS: Jeff, this is Frank 

11 Myers, PVI again. When we get into stuff 12-

12 1/2 million and over, you can almost make the 

13 case that what the manufacturer is building 

14 is not a complete boiler. And let me 

15 describe why I mean that, and that is it's 

16 almost to the point it can't operate without 

17 wrapping a building around it. 

18 You have to have this tremendous 

19 supply of energy and tremendous heat takeoff, 

20 heat consumption. And until you have it 

21 installed in a building, it's almost not in a 

22 position to test, especially if you're 
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1 talking about not just 12-1/2 million, but 30 

2 million, 60 million. 

3 They get to a point to where it's 

4 just not practical. And I think 12-1/2 

5 embodies that spirit. That's the reason a 

6 lot of test standards and a lot of control 

7 requirements all either stop or change 

8 dramatically at 12-1/2 million. 

9 MR. KLEISS: Okay. Good point. 

10 I accept that. 

11 MS. BARHYDT: So we are running 

12 out of time. I wanted to go back to one 

13 issue that someone raised earlier. And if 

14 anyone has a copy of BTS-2000 in front of 

15 them, there was some question as to whether 

16 or not the test procedure accounted for any 

17 other energy, particularly electrical energy, 

18 consumed by the boiler. And somebody 

19 suggested that it did. 

20 MR. KLEISS: I did open up a copy 

21 and look through it -- this is Jeff -- and I 

22 could not see where it was requiring 
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1 electrical power consumption for a combustion 

2 efficiency test. 

3 MS. BARHYDT: Okay. I couldn't 

4 either. I just wanted to doublecheck. 

5 MR. MYERS: This is Frank Myers, 

6 and I agree with that. I was in error. Our 

7 company does that, but that is because we 

8 have a common practice between our water 

9 heaters and boilers. But I, too, pulled out 

10 BTS-2000, and the gentleman from Cleaver11 Brooks is correct. There is no electrical 

12 requirement. 

13 MS. BARHYDT: Jeff Kleiss, one 

14 more quick question for you. So were you 

15 withdrawing your alternative proposal to 

16 verification test very large, only prior to 

17 sale? 

18 MR. KLEISS: Yes. 

19 MS. BARHYDT: Okay. 

20 MR. EISNER: And, John Sutphen, 

21 what was your reaction to the two and a half 

22 to 12-1/2 and above 12-1/2 proposal? 
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1 MR. SUTPHEN: I still believe 

2 there is going to be companies that are 

3 unable to test, you know, an eight million, 

4 10 million size boiler, even over four 

5 million. It's going to be very difficult for 

6 some companies to even perform these tests on 

7 a product that size. 

8 MR. HALLEY: Yeah, I'll go along 

9 with that. I know of one company, maybe two, 

10 that would have a tough time doing that. 

11 MS. JAKOBS: This is Diane. And 

12 so do you think that those companies would 

13 make a two and a half million BTU boiler? So 

14 I was thinking maybe the -- similar to what 

15 we were doing with the HVAC where the 

16 verification testing would be limited to part 

17 of the product line, so that you would use -- 

18 you would test a smaller boiler to verify 

19 that the manufacturer's processes were such 

20 that there was sufficient repeatability in 

21 their processes. 

22 MR. HALLEY: Yeah. I'd have to 
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1 check. I'm not familiar with, you know, the 

2 entire capacity range of the manufacturers' 

3 product lines that I just sort of mentioned 

4 where they'd have trouble. But I know they 

5 don't go to 12-1/2 million. They are less 

6 than 12-1/2 million. 

7 MR. MYERS: This is Frank Myers 

8 with PVI. I have a question for Travis with 

9 UL. Can Underwriters test at their facility 

10 a 12-1/2 million BTU water boiler at 80 

11 percent efficiency? 

12 MR. HARDIN: No. I mean, I agree 

13 with pretty much everybody on the call that 

14 anything over 12 million is incredibly 

15 impractical. And actually, you know, really 

16 anything over five million is just about as 

17 impractical from the standpoint of having 

18 enough facilities around the country to be 

19 able to do this. That's just my -- 

20 MR. SUTPHEN: This is John 

21 Sutphen with Cleaver-Brooks. I think the 12-

22 1/2 should be lowered to four million, four 
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1 or five million. That's the maximum capacity 

2 of most third party labs in a lot of boiler 

3 manufacturers. I don't think -- if you only 

4 have a third party lab that does this for a 

5 living being able to test it, I don't see why 

6 you should make that for anyone. 

7 MR. EISNER: Well, I thought we 

8 should -- 

9 MR. SUTPHEN: Through the current 

10 certification standard. 

11 MR. EISNER: I thought what you 

12 were saying was some might not be able to 

13 test between two and a half and 12-1/2. I 

14 implied from that -- inferred from that that 

15 others could. So if it can be done, why 

16 can't some do it when others can't? Is it 

17 simply because they're small and -- 

18 MR. KLEISS: Jeff Kleiss. 

19 MR. EISNER: Go ahead, Jeff. 

20 MR. KLEISS: Jeff Kleiss with 

21 Lochinvar. We currently do make a five 

22 million BTU per hour water boiler. And we do 
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1 test it in an ISO 17025 lab. 

2 MR. EISNER: So my question is, 

3 why can't DOE require that all of them be 

4 tested? What is the problem that some of the 

5 companies have? It's too expensive? Is that 

6 the only objection? 

7 MR. HALLEY: That's one of the 

8 reasons. But the problem with hot water 

9 boilers, certainly the ABMA part of the 

10 industry, I can tell you that the company I 

11 worked for had probably at the time the most 

12 advanced product development lab in the 

13 country. And we can test to about eight 

14 million on a hot water boiler because that 

15 was governed by the size of the heat sink. 

16 We had the ability to remove the heat that 

17 was generated by the boiler. So, you know, 

18 just as -- that lab does not exist anymore. 

19 MR. MYERS: This is Frank Myers 

20 with PVI. Neil, what you run into with labs 

21 -- if third party labs are available to send 

22 it to, and can test that size equipment, then 
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1 we could -- you could continue to say, okay, 

2 your eight million BTU piece of equipment has 

3 to be tested. If you don't want to do it, 

4 send it to a third party. 

5 But when there's no third party 

6 to send it to, then things start becoming 

7 major problems, like there is inadequate 

8 water supply in your area to be able to take 

9 such a tremendous amount of water to run a 

10 water boiler test that there is inadequate 

11 supply of water available, that there is 

12 inadequate gas supply to test those sizes. 

13 So it can get to a point where a 

14 company simply cannot, even though it's a 

15 federal requirement and they have no 

16 alternative to send it to a third party lab, 

17 if there's no third party lab to be able to 

18 run the test. 

19 MR. EISNER: So what you're 

20 saying is you're agreeing that the 12-1/2 

21 should be lowered to the maximum that an 

22 independent lab could handle? Can I -- 
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1 MR. MYERS: Five million BTUs? 

2 MR. EISNER: So you're saying it 

3 should be -- 12-1/2 should be lowered. 

4 MR. MYERS: If we're going to be 

5 -- once I heard that one of the largest labs, 

6 Underwriters, doesn't have the capacity to be 

7 able to test that large, can go to eight 

8 million BTUs, I think the five million BTU 

9 requirement becomes more reasonable. And 

10 five, just because that's a common break 

11 point in the industry -- 

12 MR. EISNER: So let me ask 

13 whether others would agree that we should 

14 have the same breakup, but it should be two 

15 and a half and under, or under two and a 

16 half, two and a half to five, and five and 

17 above. And five and above would -- 

18 MR. STEPHENS: Phillip Stephens, 

19 HTP. 

20 MR. EISNER: Go ahead, Phil. 

21 MR. STEPHENS: I'm concerned 

22 because I know for a fact there are several 
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1 labs that work on bottled gas with a closed 

2 loop cooling system that work up to five 

3 million on their own, and that's because of a 

4 local facilities issue. So I know those 

5 types of things can be overcome. 

6 I think if we reduce it below 

7 that level, below 12-1/2 million, we are not 

8 going to achieve what the Department wants us 

9 to and be equitable across all of the 

10 different manufacturers. 

11 MR. EISNER: Other thoughts? 

12 MS. JAKOBS: So what I'm hearing 

13 is you want a level playing field between 

14 manufacturers who make smaller equipment that 

15 can serve the same building with multiples as 

16 a large equipment manufacturer who might only 

17 have two boilers. The rules should be the 

18 same because they're competing against each 

19 other. 

20 MR. HALLEY: Well, yeah, the 

21 problem is the cost of testing the larger 

22 equipment is much more than the test of -- 
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1 the cost of testing the smaller equipment. 

2 You know, you've got that sort of cost 

3 differential. 

4 MS. JAKOBS: Right. 

5 MS. BARHYDT: So we're out of 

6 time today, but I think we have a few 

7 proposals for people to think about, possibly 

8 go back, talk to other manufacturers about, 

9 and certainly we will be talking here. So 

10 does anyone have any final thoughts or 

11 comments that they want to share before we 

12 shut it down today? 

13 MR. MYERS: This is Frank Myers. 

14 Are you going to post that on the site so 

15 that we can all have access to what you've 

16 jotted up on the screen? 

17 MS. BARHYDT: Yes. 

18 MR. MYERS: Okay. Thank you. 

19 MR. STEPHENS: And the other 

20 sheet you made also with all of the 

21 definitions? 

22 MS. BARHYDT: We will put it up, 
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1 too. 

2 MR. STEPHENS: Wonderful. 

3 MR. EISNER: Does anybody have 

4 any final thoughts about labs and whether we 

5 need to do more checking on the lab front to 

6 see what they do? Or do you all think we've 

7 heard the maximum capacities here? 

8 MR. KLEISS: As manufacturers, we 

9 have I think a pretty good grasp of that, 

10 because most of us have run into that 

11 ceiling. 

12 MR. EISNER: Okay. So there's a 

13 general agreement it should be five million 

14 in terms of what the labs can do. 

15 MR. KLEISS: Five million sounds 

16 like a reasonable ceiling. 

17 MR. SUTPHEN: Cleaver-Brooks 

18 agrees. 

19 MR. HALLEY: Yeah. I'll agree 

20 with five million, but I think you -- so long 

21 as it's an independent lab. I think if 

22 you're going to try and switch into a 
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1 competing manufacturer's lab, then you've got 

2 a real problem with, you know, competitive 

3 situations and that sort of thing. 

4 MR. STEPHENS: Phillip Stephens, 

5 HTP. Didn't Travis just mention that UL can 

6 do up to 12 million? 

7 MR. MYERS: No. 

8 MR. HALLEY: No. 

9 MR. MYERS: He said eight 

10 million, around eight million. 

11 MS. BARHYDT: Travis, one more 

12 time with nobody talking over you. 

13 MR. HARDIN: We cannot do up to 

14 12-1/2 million. I actually said it was more 

15 prevalent around five million. So I would 

16 agree with the five million threshold for 

17 having the capacity. And I don't know the 

18 capacity of our competitors, but I will 

19 assume it would be somewhere along those 

20 lines. 

21 MR. EISNER: Okay. Any other 

22 last thoughts? 
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1 (No response.) 

2 Well, thank you all for joining 

3 us this morning. I think there has been some 

4 good discussion. Don't know how close we are 

5 to some kind of resolution, but, as Laura 

6 said, give some thought to it, so when we 

7 meet again nobody says they have to go back 

8 and get more information. 

9 MR. KLEISS: Will we have another 

10 conference call like this? 

11 MR. EISNER: Do you think it 

12 would be helpful? 

13 MR. KLEISS: Yes. 

14 MS. BARHYDT: Okay. I will see 

15 what we can do about another Doodle poll. 

16 MR. KLEISS: Other guys, do you 

17 agree? 

18 PARTICIPANT: Yes. 

19 MS. BARHYDT: I heard at least 

20 one yes. 

21 MR. HALLEY: Make it two. 

22 PARTICIPANT: Here's another yes. 
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1 MS. BARHYDT: Okay, okay. We'll 

2 get that -- 

3 PARTICIPANT: Make it three, as 

4 long as it's next week. 

5 MS. BARHYDT: What was that? 

6 PARTICIPANT: Can it be next week 

7 when Peter Molvie is available? 

8 MS. BARHYDT: Okay. We will do 

9 our best. 

10 MR. EISNER: Thank you, all. 

11 (Whereupon, at 11:09 a.m., the proceedings in 

12 the foregoing matter were 

13 concluded.) 

14

15

16

17

18

19

20

21

22
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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

119

Discussion of Verification Programs

for Commercial Packaged Boilers

US DOE

08-14-13

Washington, DC