[Federal Register Volume 81, Number 108 (Monday, June 6, 2016)]
[Notices]
[Pages 36288-36295]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-13252]
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DEPARTMENT OF ENERGY
Office of Energy Efficiency and Renewable Energy
[Case No. WH-004]
Notice of Petition for Waiver of Raypak Inc. From the Department
of Energy Commercial Water Heater Test Procedure
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of petition for waiver and request for public comments.
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SUMMARY: This notice announces receipt of and publishes a petition for
waiver from Raypak Inc. (Raypak) seeking an exemption from specified
provisions applicable to standby loss of the U.S. Department of Energy
(DOE) test procedure for commercial water heating equipment. The waiver
request pertains to Raypak's specified models of commercial
instantaneous water heaters containing 10 gallons or more of water. In
its petition, Raypak contends that its specified water heater models
that employ tube-type heat exchangers and are designed to be flow
activated cannot be accurately tested using the currently applicable
DOE test procedure. Consequently, Raypak seeks to use an alternate test
procedure to address certain issues involved in testing the specific
basic models identified in its petition. DOE solicits comments, data,
and information concerning Raypak's petition and its suggested
alternate test procedure.
DATES: DOE will accept comments, data, and information with respect to
the Raypak Petition until July 6, 2016.
ADDRESSES: You may submit comments, identified by case number WH-004,
by any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting comments.
Email: [email protected]. Include the case
number [Case No. WH-004] in the subject line of the message. Submit
electronic comments in WordPerfect, Microsoft Word, PDF, or ASCII file
format, and avoid the use of special characters or any form of
encryption.
Postal Mail: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Office, Mailstop EE-5B, Petition for
Waiver Case No. WH-004, 1000 Independence Avenue SW., Washington, DC
20585-0121. Telephone: (202) 586-2945. If possible, please submit all
items on a compact disc (CD), in which case it is not necessary to
include printed copies.
[[Page 36289]]
Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department
of Energy, Building Technologies Office, 950 L'Enfant Plaza SW., Suite
600, Washington, DC 20024. If possible, please submit all items on a
CD, in which case it is not necessary to include printed copies.
Docket: The docket, which includes Federal Register notices,
comments, and other supporting documents/materials, is available for
review at www.regulations.gov. All documents in the docket are listed
in the www.regulations.gov index. However, some documents listed in the
index, such as those containing information that is exempt from public
disclosure, may not be publicly available.
For further information on how to submit a comment, or review other
public comments and the docket, contact Ms. Brenda Edwards at (202)
586-2945 or by email: [email protected].
FOR FURTHER INFORMATION CONTACT:
Mr. Bryan Berringer, U.S. Department of Energy, Building Technologies
Office, Mail Stop EE-5B, 1000 Independence Avenue SW., Washington, DC
20585-0121. Telephone: (202) 586-0371. Email:
[email protected].
Mr. Eric Stas, U.S. Department of Energy, Office of the General
Counsel, GC-33, 1000 Independence Avenue SW., Washington, DC 20585-
0121. Telephone: (202) 586-9507. Email: [email protected].
For information on how to submit or review public comments, contact
Ms. Brenda Edwards, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Office, Mailstop
EE-5B, 1000 Independence Avenue SW., Washington, DC 20585-0121.
Telephone: (202) 586-2945. Email: [email protected].
SUPPLEMENTARY INFORMATION:
I. Background and Authority
Title III, Part C \1\ of the Energy Policy and Conservation Act of
1975 (EPCA), Pub. L. 94-163 (42 U.S.C. 6311-6317, as codified), added
by Pub. L. 95-619, established the Energy Conservation Program for
Certain Industrial Equipment, which includes commercial water heaters,
the focus of this notice.\2\ Part C specifically includes definitions
(42 U.S.C. 6311), energy conservation standards (42 U.S.C 6313), test
procedures (42 U.S.C. 6314), labeling provisions (42 U.S.C. 6315), and
the authority to require information and reports from manufacturers.
(42 U.S.C. 6316) With respect to test procedures, Part C authorizes the
Secretary of Energy (the Secretary) to prescribe test procedures that
are reasonably designed to produce results that measure energy
efficiency, energy use, and estimated annual operating costs during a
representative average-use cycle, and that are not unduly burdensome to
conduct. (42 U.S.C. 6314(a)(2)) EPCA also directs DOE to consider
amending the existing test procedure for each type of equipment listed
each time the industry test procedure is amended for such equipment.
(42 U.S.C. 6314(a)(4)) The test procedure for commercial water heaters
is contained in the Code of Federal Regulations (CFR) at 10 CFR part
431, subpart G.
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\1\ For editorial reasons, upon codification in the U.S. Code,
Part C was re-designated Part A-1.
\2\ All references to EPCA in this document refer to the statute
as amended through the Energy Efficiency Improvement Act of 2015
(EEIA 2015), Pub. L. 114-11 (April 30, 2015).
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DOE's regulations set forth at 10 CFR 431.401 contain provisions
that permit a person to seek a waiver from the test procedure
requirements for covered equipment if at least one of the following
conditions is met: (1) The basic model contains one or more design
characteristics that prevent testing according to the prescribed test
procedures; or (2) the prescribed test procedures may evaluate the
basic model in a manner so unrepresentative of its true energy
consumption as to provide materially inaccurate comparative data. 10
CFR 431.401(a)(1). A petitioner must include in its petition any
alternate test procedures known to the petitioner to evaluate the basic
model in a manner representative of its energy consumption. 10 CFR
431.401(b)(1)(iii). DOE may grant a waiver subject to conditions,
including adherence to alternate test procedures. 10 CFR 431.401(f)(2).
As soon as practicable after the granting of any waiver, DOE will
publish in the Federal Register a notice of proposed rulemaking to
amend its regulations so as to eliminate any need for the continuation
of such waiver. As soon thereafter as practicable, DOE will publish in
the Federal Register a final rule. 10 CFR 431.401(l).
II. Petition for Waiver of Test Procedure
On May 5, 2015, Raypak filed a petition for waiver from the DOE
test procedure at 10 CFR 431.106 to measure standby loss of commercial
water heating equipment. This petition addresses Raypak's specified
models of commercial instantaneous water heaters containing 10 gallons
or more of water. The current DOE efficiency test procedure for
commercial water heaters incorporates by reference the relevant
industry test standard for measuring thermal efficiency and standby
loss, as specified in American National Standards Institute (ANSI) ANSI
Z21.10.3-2011, Gas-Fired Water Heaters, Volume III, Storage Water
Heaters, With Input Ratings Above 75,000 Btu Per Hour, Circulating and
Instantaneous. In its petition, Raypak contends that its identified
basic models rely on flow of water through the heater to activate the
burner, but because the current DOE test procedure does not take into
account such units, it does not provide a proper representation of the
standby loss of these models. The current standby loss test procedure
is designed to test tank-type water heaters which are thermostatically
operated. The models for which Raypak is seeking this test procedure
waiver employ tube-type heat exchangers and are designed to be flow
activated. To address the apparent shortcomings of ANSI Z21.10.3-2011,
Raypak has submitted to DOE an alternate test procedure for measuring
the standby loss of tube-type instantaneous water heaters, as addressed
in sections E.1 and E.3 of ANSI Z21.10.3-2012, Gas-Fired Water Heaters,
Volume III, Storage Water Heaters, With Input Ratings Above 75,000 Btu
Per Hour, Circulating and Instantaneous. Raypak believes this
alternative provides a representative measure of the standby loss of
these models.
III. Alternate Test Procedure
EPCA requires that manufacturers use DOE test procedures when
making representations about the energy consumption and energy
consumption costs of products and equipment covered by the statute. (42
U.S.C. 6293(c); 6314(d)) Consistent representations about the energy
efficiency of covered products and equipment are important for
consumers evaluating products when making purchasing decisions and for
manufacturers to demonstrate compliance with applicable DOE energy
conservation standards. Pursuant to its regulations applicable to
waivers and interim waivers from applicable test procedures at 10 CFR
431.401, DOE will consider setting an alternate test procedure for
Raypak in a subsequent Decision and Order.
Raypak has submitted to DOE an alternate test procedure for
measuring the standby loss of tube-type instantaneous water heaters as
addressed in ANSI Z21.10.3-2012 sections E.1 and E.3. Specifically,
Raypak has submitted the following alternate test procedure to
accurately represent the standby loss of its
[[Page 36290]]
commercial instantaneous water heaters containing 10 gallons or more of
water:
Z21.10.3-2012 Exhibit E Efficiency Test Procedures
E.1 Method of Test for Measuring Thermal Efficiency
A water heater for installation on combustible floors shall be
placed on \3/4\ in (1.9 cm) plywood platform supported by three 2 x 4
runners. If the water heater is for installation on noncombustible
floors, suitable noncombustible material shall be placed on the
platform. When the use of the platform for a large water heater is not
practical, the water heater may be placed on any suitable flooring. A
wall mounted water heater shall be mounted to a simulated wall section.
Placement in the test room shall be in an area protected from
drafts.
Inlet and outlet piping shall be immediately turned vertically
downward from the connections on a tank-type water heater so as to form
heat traps. Any factory supplied heat traps shall be installed per the
installation instructions. Thermocouples for measuring inlet and outlet
water temperatures shall be installed before the inlet heat trap piping
and after the outlet heat trap piping.
Water-tube water heaters shall be installed as shown in Figure 3,
Arrangement for Testing Water-tube Type Instantaneous and Circulating
Water Heaters.
a. Piping Insulation
Insulate the water piping, including heat traps, for a length of 4
ft (1.22 m) from the connection at the appliance with material having a
thermal resistance (R) value of not less than 4 [F[middot]ft
[middot]hr/Btu (0.7 K[middot]m/W)]. Care should be taken so the
insulation does not contact any appliance surface except at the
location where the pipe connections penetrate the appliance jacket.
b. Temperature and Pressure Relief Valve Insulation
If the manufacturer has not provided a temperature and pressure
relief valve, one shall be installed and insulated as specified above.
c. Vent Requirements
1. Appliance Equipped With Draft Hoods
All tests shall be conducted with the natural draft established by
the following vent pipe arrangements:
A vertically discharging vent connection shall have attached to and
vertically above it, 5 ft (1.52 m) of vent pipe the same size as the
outlet. If the vent does not discharge vertically, a suitable elbow
shall be installed first.
2. Direct Vent Appliances and Mechanically Vented
The appliance shall be installed with the venting arrangement
specified in the manufacturer's instructions. The water heater shall be
installed with the manufacturer's specified minimum venting length
venting arrangement.
d. Water Supply
During conduct of this test, the temperature of the supply water
shall be maintained at 70 2[emsp14][deg]F (21
1 [deg]C). The pressure of the water supply shall be maintained between
40 psi (275.8 kPa) and the maximum pressure specified by the
manufacturer for the appliance under test. The accuracy of the pressure
measuring devices shall be 1.0 psi (6.9 kPa). For a water-
tube water heater, the inlet water temperature shall be maintained at
the supply water temperature or as specified by the manufacturer (see
2.1.8).
A tank-type water heater shall be isolated by use of a shutoff
valve in the supply line with an expansion tank installed in the supply
line downstream of the shutoff valve. There shall be no shutoff means
between the expansion tank and the appliance inlet.
e. Gas Supply
The gas rate shall be adjusted as specified in 2.3.3. The outlet
pressure of the gas appliance pressure regulator shall be within 10 percent of that recommended by the manufacturer. The higher
heating value of the gas burned shall be obtained.
f. Installation of Temperature Sensing Means
For tank-type water heaters, six (6) temperature sensing means
shall be installed inside the storage tank on the vertical center of
each of 6 nonoverlapping sections of approximately equal volume from
the top to the bottom of the tank. Each temperature sensing means is to
be located as far as possible from any heat source or other
irregularity, anodic protective device, or water tank or flue wall. The
anodic protective device may be removed in order to install the
temperature sensing means and all testing may be carried out with the
device removed.
If the temperature sensing means cannot be installed as specified
above, placement of the temperature sensing means shall be made at the
discretion of the testing agency so comparable water temperature
measurements may be obtained.
A temperature sensing means, shielded against direct radiation and
positioned at the vertical midpoint of the water heater at a
perpendicular distance of approximately 24 in (610 mm) from the surface
of the jacket, shall be installed in the test room.
g. Setting Tank Thermostat
Before starting testing of a tank-type water heater, the setting of
the thermostat shall first be obtained by starting with the water in
the system at 70 2[emsp14][deg]F (21 1
[deg]C) and noting the maximum mean temperature of the water after the
thermostat reduces the gas supply to a minimum. The temperature shall
be 140 5[emsp14][deg]F (60 3 [deg]C).
h. Energy Consumption
Instrumentation shall be installed which determines, within 1 percent:
1. The quantity and rate of gas consumed.
2. The quantity of electricity consumed by factory supplied water
heater components, and of the test loop recirculating pump, if used.
i. Room Ambient Temperature
The ambient air temperature of the test room shall be maintained at
75 10[emsp14][deg]F (24 5.5 [deg]C), as
measured by the test room temperature sensing means described in ``-f''
above.
The ambient air temperatures shall be measured at 15 minute
intervals during conduct of this test. The room temperature shall not
vary more than 7.0[emsp14][deg]F ( 4 [deg]C)
from the average during the test, temperature readings being taken by
means of a recording thermometer at 15 minute intervals and averaged at
the end of the test.
j. Efficiency Measurement
The outlet water temperature shall be adjusted by varying the rate
of flow until temperature is constant at 70
2[emsp14][deg]F (21 1 [deg]C) above the supply
temperature. After the outlet temperature has become constant, as
indicated by no variation in excess of 2[emsp14][deg]F (1 [deg]C) over
a 3 minute period, the outlet water shall be diverted from the waste
line to a weighing container. A scale with an error no greater than 1
percent of the total draw shall be used. Water shall be allowed to flow
into the weighing container for exactly 30 minutes. The gas consumption
and electrical power consumption of factory supplied heater components
and of the test loop-recirculating pump, if used, shall be measured for
the 30 minute period. At this time, the outlet water shall be diverted
back into the waste
[[Page 36291]]
line, the meter readings noted, and the weight of heater water
recorded. Throughout the period of test, supply and outlet water
temperatures shall be recorded every minute. The temperature, pressure
and heating value of the gas metered and barometric pressure shall be
obtained.
A water meter with an error no greater than 1 percent of the total
draw may be used instead of the scale and weighing container.
Thermal efficiency, Et, shall be computed by use of the following
formula:
Et = (KW ([thetas]2-[thetas]1)/[(CF x
Q x H) + Ec]) x 100
Where:
K = 1.004 Btu per pound mass degree F (4184 J/kg [deg]C), nominal
specific heat of water at 105 [deg]F;
W = total weight of water heated, lbs. (kg);
[thetas]1 = average temperature of supply water, [deg]F
([deg]C);
[thetas]2 = average temperature of outlet water, [deg]F
([deg]C);
Q = total gas consumed as metered, cu. ft. (m\3\);
Cs = correction applied to the heating value H, when it
is metered at temperature and/or pressure conditions other than the
standard conditions. At which the heating value of gas is specified
[normally 30 inches mercury column (101.3 kPa) and 60 [deg]F (15.5
[deg]C)];
H = total heating value of gas, Btu per cu. ft. (MJ/m3);
and
Ec = electrical consumption of the water heater and, when
used, the test setup recirculating pump, specified in Btu (kJ).
Standby Loss for tank type water heaters shall be determined using
Appendix E.2
Standby Loss for tube type water heaters that contain 10 or more
gallons within the water heater, as determined under 5.27, shall be
determined using Appendix E.3
E.3 Method of Test For Measuring Standby Loss for Tube Type
Instantaneous Water Heaters With 10 or Greater Gallons of Storage
The appliance shall be installed as specified in G.1, Method of
Test for Measuring Thermal Efficiency. This test may be conducted
immediately following the thermal efficiency test. In this case, start
the test after the main burner(s) has shut down and, if applicable, the
water pump has shut down. Otherwise, the water heater shall be put into
operation under the same test conditions specified in G.1, and the
outlet water temperature shall be adjusted by varying the rate of flow
until temperature is constant at 70 2[emsp14][deg]F (21
1 [deg]C) above the supply temperature. After the outlet
temperatures becomes constant, as indicated by no variation in excess
of 2[emsp14][deg]F (1 [deg]C) over a 3 minute period, shut down the
main burner(s) and, if applicable, wait for the water pump to shut
down, and then start the test.
At the start of the test, record the time, ambient temperature,
outlet water temperature, supply water temperature, and begin measuring
the fuel and electric consumption.
During the first hour, outlet water temperature, supply water
temperature and the ambient air temperature shall be measured at the
end of each 5 minute interval. For the remainder of the test, these
measurements shall be made at the end of every 15 minute interval. The
duration of this test shall be 24 hours. If the main burner is firing
at 24 hours, continue the test until the main burner and the water
pump, if applicable, have shut down.
Immediately after the conclusion of the test, record the total fuel
flow and electrical energy consumption, the final ambient air
temperature, and the final outlet water temperature.
Calculate the average of the ambient air temperatures and the
supply water temperatures taken at the end of each time interval,
including the initial and final values.
The average hourly standby loss, S, rounded to the nearest Btu per
hour, shall be determined by the formula:
S = [(Cs(Qs)(H) + Ec)/t]-[([Delta]T4)/([Delta]T3)(t)Et]
Where:
Cs = correction applied to the heating value of a gas H, when it is
metered at temperature and/or pressure conditions other than the
standard conditions for which the value of H is based;
H = higher heating value of gas, Btu per cu. ft. (MJ/m3);
Qs = total fuel flow as metered, cu. ft. (m3);
[Delta]T3 = difference between the outlet temperature and the
average value of the ambient air temperature, [deg]F ([deg]C);
[Delta]T4 = difference between the average supply water temperature
and the outlet temperature, [deg]F ([deg]C);
t = duration of test, hrs.;
Ec = electrical energy consumption expressed in Btu (kJ); and
Et = thermal efficiency as determined under G1, Method of Test for
Measuring Thermal Efficiency
If the main burner(s) does not cycle on during this test, the
hourly average standby loss calculation simplifies to:
S = {(K(Va)([Delta]T4)/Et) + Ec{time} /t
For water heaters that will not initiate or cause actions that will
initiate burner operation, the following simplified procedure may be
used to measure the hourly standby loss.
This test may be conducted immediately following the thermal
efficiency test. In this case, start the test after the main burner(s)
has shut down and, if applicable, the water pump has shut down.
Otherwise provide the electrical connection as specified in G.1, Method
of Test for Measuring Thermal Efficiency, and start the test.
At the start of the test, record the time and begin measuring the
electric consumption for one hour. Record the duration of the test and
the total electrical consumption during the test.
The average hourly standby loss, S, rounded to the nearest Btu per
hour, shall be determined by the formula:
S = [(([Delta]T5 k Va/Et)/24) +Ec]
Where:
[Delta]T5 = 70 [deg]F (38.9 [deg]C), difference between
the supply and outlet water temperatures;
k= 8.25 Btu/gallon [deg]F (4147.6331 J/l [deg]C), the nominal
specific heat of water;
Va = water contained in the water heater expressed in gallons (L),
as determined under 5.27;
Ec = electrical energy consumption expressed in Btu (kJ); and
Et = thermal efficiency as determined under G1, Method of Test for
Measuring Thermal Efficiency.
The following basic models are included in Raypak's petition:
XTherm Model WH7-1005*
XTherm Model WH7-1505*
XTherm Model WH7-2005*
XTherm Model WH7-2505*
XTherm Model WH7-3005*
XTherm Model WH7-3505*
XTherm Model WH7-4005*
MVB Model WH7-2503*
MVB Model WH7-3003*
MVB Model WH7-3503*
MVB Model WH7-4003*
IV. Summary and Request for Comments
Through this notice, DOE announces receipt of and is publishing
Raypak's petition for waiver from the DOE test procedure for commercial
water heaters for its above-referenced commercial instantaneous water
heater models, which contain 10 gallons or more of water. The petition
contains no confidential information. The petition includes a suggested
alternate test procedure to determine the thermal efficiency and
standby loss of Raypak's specified basic models of commercial
instantaneous water heaters containing 10 gallons or more of water. DOE
is considering including this alternate test procedure in its
subsequent Decision and Order.
DOE solicits comments from interested parties on all aspects of the
petition, including the suggested alternate test procedure and
calculation methodology. Pursuant to 10 CFR 431.401(d), any person
submitting written comments to DOE must also
[[Page 36292]]
send a copy of such comments to the petitioner. The contact information
for the petitioner is: Mr. Robert Glass, Sr. Staff Engineer, Raypak
Inc., 2151 Eastman Avenue, Oxnard, CA 93030. All submissions received
must include the agency name and case number for this proceeding.
Submit electronic comments in WordPerfect, Microsoft Word, Portable
Document Format (PDF), or text (American Standard Code for Information
Interchange (ASCII)) file format and avoid the use of special
characters or any form of encryption. Wherever possible, include the
electronic signature of the author. DOE does not accept telefacsimiles
(faxes).
Pursuant to 10 CFR 1004.11, any person submitting information that
he or she believes to be confidential and exempt by law from public
disclosure should submit two copies: one copy of the document marked
``confidential'' with all of the information believed to be
confidential included, and one copy of the document marked ``non-
confidential'' with all of the information believed to be confidential
deleted. DOE will make its own determination about the confidential
status of the information and treat it according to its determination.
Issued in Washington, DC, on May 31, 2016.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy Efficiency, Energy Efficiency and
Renewable Energy.
Raypak, A Rheem Company
May 5, 2015
U.S. Department of Energy, Building Technologies Program, MS EE-2J,
Test Procedure Waiver, 1000 Independence Avenue, SW., Washington, DC
20585-0121.
Re: Waiver for Test Procedure for Commercial Water Heating Equipment
To Whom It May Concern: Pursuant to the provisions of 10 CFR
431.401, Raypak Inc. is hereby applying for a waiver of the standby
loss test procedure of 10 CFR .431.106 for the following basic model(s)
of commercial instantaneous water heaters containing 10 gallons or more
of water:
------------------------------------------------------------------------
Water capacity
Model (gal.)
------------------------------------------------------------------------
XTherm Model WH7-1005*.................................. 11.8
XTherm Model WH7-1505*.................................. 12.4
XTherm Model WH7-2005*.................................. 15.6
XTherm Model WH7-2505*.................................. 25.0
XTherm Model WH7-3005*.................................. 26.0
XTherm Model WH7-3505*.................................. 26.9
XTherm Model WH7-4005*.................................. 33.8
MVB Model WH7-2503*..................................... 10.9
MVB Model WH7-3003*..................................... 11.6
MVB Model WH7-3503*..................................... 12.2
MVB Model WH7-4003*..................................... 12.8
------------------------------------------------------------------------
The current Department of Energy efficiency test procedure for
commercial water heaters references the relevant test procedures for
measuring thermal efficiency and standby loss specified in the
standard, ANSI Z21.10.3-2011. The identified basic models rely on flow
of water through the heater to activate the burner. As will be
explained below, the current test procedure does not provide a proper
representation of the standby loss of these models.
The current standby loss test procedure is included as Attachment
A. This procedure is designed to test tank-type water heaters which are
thermostatically operated. The basic steps of the procedure are to heat
the water within the water heater, turn off the burner or element and
then measure all the energy consumption that occurs while the water
heater is ``standing by'' for approximately 24 hours with no water
being withdrawn from it. The key measurement of the test procedure is
the energy consumed by the burner or heating element when the
thermostat senses that the water in the tank has cooled down to the
point where it needs to be reheated. The current test does not address
water heaters that have no means to activate the burner or heating
element if no heated water is being drawn from the unit, i.e. the
standby condition.
The models for which Raypak Inc. is seeking this test procedure
waiver employ tube type heat exchangers and are designed to be flow
activated. That is, the burner does not come on until water flow
through the unit is sensed. Under the current standby loss test
procedure, the burner on these models will not fire at any time during
the test and the resulting standby loss measurement would be nearly
zero. That measurement is not representative of the standby loss
characteristics of these models. Raypak Inc. believes that the current
test procedure evaluates the standby loss of the identified basic
models in a manner so unrepresentative of the true energy consumption
as to provide materially inaccurate comparative data.
The manufacturers of other basic models marketed in the United
States known to Raypak Inc. to incorporate similar design
characteristics is included as Attachment B.
An alternative procedure for measuring the standby loss of tube
type instantaneous water heater is included as Attachment C. Raypak
Inc. believes this alternative provides a representative measure of the
standby loss of these models. Raypak Inc. requests that DOE grant it a
waiver to use this alternative procedure in lieu of the standby loss
procedure specified in the current DOE efficiency test procedures for
commercial water heaters.
Respectfully submitted,
Robert Glass
Sr. Staff Engineer
Raypak Inc.
2151 Eastman Avenue,
Oxnard, CA 93030
(805) 278-5300
FAX (800) 872-9725
www.raypak.com
Attachments--Attachment A--Current Standby Loss Test Procedure
Attachment B--Other Affected Manufacturers
Attachment C--Proposed Alternative Procedure for Measuring the Standby
Loss of Tube Type Instantaneous Water Heaters Containing More than 10
Gallons
C: Karen Meyers--Rheem Manufacturing Co.
Russell Pate--Rheem Manufacturing Co.
Attachment A: Current Standby Loss Test Procedure
E.2 Method of test for measuring standby loss
The appliance shall be installed as specified in E.1, Method of
test for measuring thermal efficiency. The gas to the main burner(s)
shall be turned on and the appliance put into operation. After the
first cutout, allow the water heater to remain in the standby mode
until the next cutout. At this time record the time, ambient
temperature and begin measuring the fuel and electric consumption.
Record the maximum mean tank temperature that occurs after cutout.
At the end of the first 15 minute interval and at the end of each
subsequent 15 minute interval, the mean tank temperature and the
ambient air temperature shall be recorded. The duration of this test
shall be until the first cutout that occurs after 24 hours or 48 hours,
whichever comes first.
Immediately after the conclusion of the test, record the total fuel
flow and electrical energy consumption, the final ambient air
temperature, and the time duration of the standby loss test (t) in
hours rounded to the nearest one hundredth of an hour and the maximum
[[Page 36293]]
mean tank temperature that occurs after cutout. Calculate the average
of the recorded values of the mean tank temperatures and of the ambient
air temperatures taken at the end of each time interval, including the
initial and final values.
Determine the difference ([Delta]T3) between these two
averages by subtracting the latter from the former, and the differences
([Delta]T4) between the final and initial mean tank
temperatures by subtracting the latter from the former.
The ratio of the average hourly energy consumption to the heat
content of the stored water above room temperatures, in percent,
rounded to the nearest one hundredth shall be determined by the
formula:
[GRAPHIC] [TIFF OMITTED] TN06JN16.001
Where
Cs = correction applied to the heating value of a gas H, when it
metered at temperature and/or pressure conditions other than the
standard conditions for which the value of H is based;
K = 8.25 Btu per gallon [deg]F (4147.6331 J/I [deg]C), the nominal
specific heat of water;
Va = tank capacity expressed in gallons (L), as determined under
5.26, Capacities of storage vessels;
H = higher heating value of gas, Btu per cu. Ft. (MJ/m\3\);
Qs = total fuel flow as metered, cu. Ft. (m\3\);
[Delta]T3 = difference between the average value of the mean tank
temperature and the average value of the ambient air temperature,
[deg]F ([deg]C);
[Delta]T4 = difference between the final and initial mean tank
temperature, [deg]F ([deg]C);
t = duration of test, hrs.;
Ec = electrical energy consumption expressed in Btu (kJ); and
Et = thermal efficiency as determined under E.1, Method of test for
measuring thermal efficiency.
Attachment B:
Manufacturers of Commercial Tube Type Water Heaters containing 10
gallons or more
A.O. Smith Corporation, 11270 W Park Place, P.O. Box 245008,
Milwaukee, WI 53224-3623
HTP, Inc., 120 Braley Rd., P.O. Box 429, East Freetown, MA 02717-
1125
Laars Heating Systems Company, 20 Industrial Way, Rochester, NH
03867-4296
Lochinvar LLC, 300 Maddox Simpson Pkwy., Lebanon, TN 37090-5366
Thermal Solutions Products, LLC, a Subsidiary of Burnham Holdings,
P.O. BOX 3244, Lancaster, PA 17604-3244
Attachment C
AHRI Recommended Standby Loss Test Procedure For Commercial Tube-Type
Instantaneous Water Heaters And Hot Water Supply Boilers That Contain
At Least 10 Gallons Of Water
Z21.10.3-2012
Exhibit E Efficiency Test Procedures
E.1 Method Of Test For Measuring Thermal Efficiency
A water heater for installation on combustible floors shall be
placed on \3/4\ in (1.9 cm) plywood platform supported by three 2 x
4 runners. If the water heater is for installation on noncombustible
floors, suitable noncombustible material shall be placed on the
platform. When the use of the platform for a large water heater is
not practical, the water heater may be placed on any suitable
flooring. A wall mounted water heater shall be mounted to a
simulated wall section.
Placement in the test room shall be in an area protected from
drafts.
Inlet and outlet piping shall be immediately turned vertically
downward from the connections on a tank-type water heater so as to
form heat traps. Any factory supplied heat traps shall be installed
per the installation instructions. Thermocouples for measuring inlet
and outlet water temperatures shall be installed before the inlet
heat trap piping and after the outlet heat trap piping.
Water-tube water heaters shall be installed as shown in Figure
3, Arrangement for Testing Water-tube Type Instantaneous and
Circulating Water Heaters.
a. Piping Insulation
Insulate the water piping, including heat traps, for a length of
4 ft (1.22 m) from the connection at the appliance with material
having a thermal resistance (R) value of not less than 4
[F[middot]ft [middot]hr/Btu (0.7 K[middot]m/W)]. Care should be
taken so the insulation does not contact any appliance surface
except at the location where the pipe connections penetrate the
appliance jacket.
b. Temperature and Pressure Relief Valve Insulation
If the manufacturer has not provided a temperature and pressure
relief valve, one shall be installed and insulated as specified
above.
c. Vent Requirements
1. Appliance Equipped With Draft Hoods
All tests shall be conducted with the natural draft established
by the following vent pipe arrangements:
A vertically discharging vent connection shall have attached to
and vertically above it, 5 ft (1.52 m) of vent pipe the same size as
the outlet. If the vent does not discharge vertically, a suitable
elbow shall be installed first.
2. Direct Vent Appliances and Mechanically Vented
The appliance shall be installed with the venting arrangement
specified in the manufacturer's instructions. The water heater shall
be installed with the manufacturer's specified minimum venting
length venting arrangement.
d. Water Supply
During conduct of this test, the temperature of the supply water
shall be maintained at 70 2 [deg]F (21 1
[deg]C). The pressure of the water supply shall be maintained
between 40 psi (275.8 kPa) and the maximum pressure specified by the
manufacturer for the appliance under test. The accuracy of the
pressure measuring devices shall be 1.0 psi (6.9 kPa).
For a water-tube water heater, the inlet water temperature shall be
maintained at the supply water temperature or as specified by the
manufacturer (see 2.1.8).
A tank-type water heater shall be isolated by use of a shutoff
valve in the supply line with an expansion tank installed in the
supply line downstream of the shutoff valve. There shall be no
shutoff means between the expansion tank and the appliance inlet.
e. Gas Supply
The gas rate shall be adjusted as specified in 2.3.3. The outlet
pressure of the gas appliance pressure regulator shall be within
10 percent of that recommended by the manufacturer. The
higher heating value of the gas burned shall be obtained.
f. Installation of Temperature Sensing Means
For tank-type water heaters, six (6) temperature sensing means
shall be installed inside the storage tank on the vertical center of
each of 6 nonoverlapping sections of approximately equal volume from
the top to the bottom of the tank. Each temperature sensing means is
to be located as far as possible from any heat source or other
irregularity, anodic protective device, or water tank or flue wall.
The anodic protective device may be removed in order to install the
temperature sensing means and all testing may be carried out with
the device removed.
If the temperature sensing means cannot be installed as
specified above, placement of the temperature sensing means shall be
made at the discretion of the testing agency so comparable water
temperature measurements may be obtained.
A temperature sensing means, shielded against direct radiation
and positioned at the vertical midpoint of the water heater at a
perpendicular distance of approximately 24 in (610 mm) from the
surface of the jacket, shall be installed in the test room.
[[Page 36294]]
g. Setting Tank Thermostat
Before starting testing of a tank-type water heater, the setting
of the thermostat shall first be obtained by starting with the water
in the system at 70 2 [deg]F (21 1 [deg]C)
and noting the maximum mean temperature of the water after the
thermostat reduces the gas supply to a minimum. The temperature
shall be 140 5 [deg]F (60 3 [deg]C).
h. Energy Consumption
Instrumentation shall be installed which determines, within
1 percent:
1. The quantity and rate of gas consumed.
2. The quantity of electricity consumed by factory supplied
water heater components, and of the test loop recirculating pump, if
used.
i. Room Ambient Temperature
The ambient air temperature of the test room shall be maintained
at 75 10 [deg]F (24 5.5 [deg]C), as
measured by the test room temperature sensing means described in ``-
f'' above.
The ambient air temperatures shall be measured at 15 minute
intervals during conduct of this test. The room temperature shall
not vary more than 7.0 [deg]F ( 4[deg]C)
from the average during the test, temperature readings being taken
by means of a recording thermometer at 15 minute intervals and
averaged at the end of the test.
j. Efficiency Measurement
The outlet water temperature shall be adjusted by varying the
rate of flow until temperature is constant at 70 2
[deg]F (21 1 [deg]C) above the supply temperature.
After the outlet temperature has become constant, as indicated by no
variation in excess of 2 [deg]F (1 [deg]C) over a 3 minute period,
the outlet water shall be diverted from the waste line to a weighing
container. A scale with an error no greater than 1 percent of the
total draw shall be used. Water shall be allowed to flow into the
weighing container for exactly 30 minutes. The gas consumption and
electrical power consumption of factory supplied heater components
and of the test loop-recirculating pump, if used, shall be measured
for the 30 minute period. At this time, the outlet water shall be
diverted back into the waste line, the meter readings noted, and the
weight of heater water recorded. Throughout the period of test,
supply and outlet water temperatures shall be recorded every minute.
The temperature, pressure and heating value of the gas metered and
barometric pressure shall be obtained.
A water meter with an error no greater than 1 percent of the
total draw may be used instead of the scale and weighing container.
Thermal efficiency, Et, shall be computed by use of
the following formula:
Et = (KW ([thgr]2 - [thgr]1)/[(CF x
Q x H) + Ec]) x 100
where
K = 1.004 Btu per pound mass degree F (4184 J/kg [deg]C), nominal
specific heat of water at 105 [deg]F;
W = total weight of water heated, lbs. (kg);
[thgr]1 = average temperature of supply water, [deg]F
([deg]C);
[thgr]2 = average temperature of outlet water, [deg]F
([deg]C);
Q = total gas consumed as metered, cu. ft. (m\3\);
Cs = correction applied to the heating value H, when it
is metered at temperature and/or pressure conditions other than the
standard conditions. At which the heating value of gas is specified
[normally 30 inches mercury column (101.3 kPa) and 60 [deg]F (15.5
[deg]C)];
H = total heating value of gas, Btu per cu. ft. (MJ/m3);
and
Ec = electrical consumption of the water heater and, when
used, the test setup recirculating pump, specified in Btu (kJ).
Standby Loss for tank type water heaters shall be determined using
Appendix E.2
Standby Loss for tube type water heaters that contain 10 or more
gallons within the water heater, as determined under 5.27, shall be
determined using Appendix E.3
E.3 Method Of Test For Measuring Standby Loss For Tube Type
Instantaneous Water Heaters With 10 or Greater Gallons of Storage
The appliance shall be installed as specified in G.1, Method of
Test for Measuring Thermal Efficiency. This test may be conducted
immediately following the thermal efficiency test. In this case, start
the test after the main burner(s) has shut down and, if applicable, the
water pump has shut down. Otherwise, the water heater shall be put into
operation under the same test conditions specified in G.1, and the
outlet water temperature shall be adjusted by varying the rate of flow
until temperature is constant at 70 2 [deg]F (21 1 [deg]C) above the supply temperature. After the outlet
temperatures becomes constant, as indicated by no variation in excess
of 2 [deg]F (1 [deg]C) over a 3 minute period, shut down the main
burner(s) and, if applicable, wait for the water pump to shut down, and
then start the test.
At the start of the test, record the time, ambient temperature,
outlet water temperature, supply water temperature, and begin measuring
the fuel and electric consumption.
During the first hour, outlet water temperature, supply water
temperature and the ambient air temperature shall be measured at the
end of each 5 minute interval. For the remainder of the test, these
measurements shall be made at the end of every 15 minute interval. The
duration of this test shall be 24 hours. If the main burner is firing
at 24 hours, continue the test until the main burner and the water
pump, if applicable, have shut down.
Immediately after the conclusion of the test, record the total fuel
flow and electrical energy consumption, the final ambient air
temperature, and the final outlet water temperature.
Calculate the average of the ambient air temperatures and the
supply water temperatures taken at the end of each time interval,
including the initial and final values.
The average hourly standby loss, S, rounded to the nearest Btu per
hour, shall be determined by the formula:
S = [(Cs(Qs)(H) + Ec)/t] - [([Delta]T4)/([Delta]T3)(t)Et ]
where
Cs = correction applied to the heating value of a gas H, when it is
metered at temperature and/or pressure conditions other than the
standard conditions for which the value of H is based;
H = higher heating value of gas, Btu per cu. ft. (MJ/m3);
Qs = total fuel flow as metered, cu. ft. (m3);
[Delta]T3 = difference between the outlet temperature and the
average value of the ambient air temperature, [deg]F ([deg]C);
[Delta]T4 = difference between the average supply water temperature
and the outlet temperature, [deg]F ([deg]C);
t = duration of test, hrs.;
Ec = electrical energy consumption expressed in Btu (kJ); and
Et = thermal efficiency as determined under G1, Method of Test for
Measuring Thermal Efficiency
If the main burner(s) does not cycle on during this test, the
hourly average standby loss calculation simplifies to:
S = {(K(Va)([Delta]T4)/Et) + Ec {time} /t
For water heaters that will not initiate or cause actions that will
initiate burner operation, the following simplified procedure may be
used to measure the hourly standby loss.
This test may be conducted immediately following the thermal
efficiency test. In this case, start the test after the main burner(s)
has shut down and, if applicable, the water pump has shut down.
Otherwise provide the electrical connection as specified in G.1, Method
of Test for Measuring Thermal Efficiency, and start the test.
At the start of the test, record the time and begin measuring the
electric consumption for one hour. Record the duration of the test and
the total electrical consumption during the test.
The average hourly standby loss, S, rounded to the nearest Btu per
hour, shall be determined by the formula:
S = [(([Delta]T5 k Va / Et)/24) +Ec]
Where:
[Delta]T5 = 70[emsp14][deg]F (38.9 [deg]C), difference
between the supply and outlet water temperatures;
k= 8.25 Btu/gallon [deg]F (4147.6331 J/l [deg]C), the nominal
specific heat of water;
Va = water contained in the water heater expressed in gallons (L),
as determined under 5.27;
Ec = electrical energy consumption expressed in Btu (kJ); and
Et = thermal efficiency as determined under G1, Method of Test for
Measuring
[[Page 36295]]
Thermal Efficiency.
[FR Doc. 2016-13252 Filed 6-3-16; 8:45 am]
BILLING CODE 6450-01-P