[Federal Register Volume 76, Number 73 (Friday, April 15, 2011)]
[Rules and Regulations]
[Pages 21580-21612]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2011-8690]
[[Page 21579]]
Vol. 76
Friday,
No. 73
April 15, 2011
Part III
Department of Energy
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10 CFR Part 431
Energy Conservation Program: Test Procedures for Walk-In Coolers and
Walk-In Freezers; Final Rule
Federal Register / Vol. 76, No. 73 / Friday, April 15, 2011 / Rules
and Regulations
[[Page 21580]]
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DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket No. EERE-2008-BT-TP-0014]
RIN 1904-AB85
Energy Conservation Program: Test Procedures for Walk-In Coolers
and Walk-In Freezers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Final rule.
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SUMMARY: On January 4, 2010, the U.S. Department of Energy (DOE) issued
a notice of proposed rulemaking (January 2010 NOPR) to establish new
test procedures for walk-in coolers and walk-in freezers (WICF or walk-
ins). On September 9, 2010, DOE issued a supplemental notice of
proposed rulemaking (September 2010 SNOPR) to propose changes to the
test procedures that it proposed in the NOPR. Those proposed
rulemakings serve as the basis for today's action. DOE is issuing a
final rule that establishes new test procedures for measuring the
energy efficiency of certain walk-in cooler and walk-in freezer
components including panels, doors, and refrigeration systems. These
test procedures will be mandatory for product testing to demonstrate
compliance with energy standards that DOE is establishing in a
separate, but concurrent rulemaking, and for representations starting
180 days after publication. This final rule incorporates by reference
industry test procedures that, along with calculations established in
the rule, can be used to measure the energy consumption or performance
characteristics of certain components of walk-in coolers and walk-in
freezers. Additionally, the final rule clarifies the definitions of
``Display door,'' ``Display panel,'' ``Door,'' ``Envelope,'' ``K-
factor,'' ``Panel,'' ``Refrigerated,'' ``Refrigeration system,'' ``U-
factor,'' ``Automatic door opener/closer,'' ``Core region,'' ``Edge
region,'' ``Surface area,'' ``Rating condition,'' and ``Percent time
off'' as applicable to walk-in coolers and walk-in freezers.
DATES: The effective date of this rule is May 16, 2011. The final rule
changes will be mandatory for product testing starting October 12,
2011.
The incorporation by reference of certain publications listed in
this rule was approved by the Director of the Federal Register on May
16, 2011.
ADDRESSES: The public may review copies of all materials related to
this rulemaking at the U.S. Department of Energy, Resource Room of the
Building Technologies Program, 950 L'Enfant Plaza, SW., Suite 600,
Washington, DC (202) 586-2945, between 9 a.m. and 4 p.m., Monday
through Friday, except Federal holidays. Please contact Ms. Brenda
Edwards at the above telephone number, or by e-mail at [email protected], for additional information regarding visiting the
Resource Room.
Docket: The docket is available for review at regulations.gov,
including Federal Register notices, framework documents, public meeting
attendee lists and transcripts, comments, and other supporting
documents/materials. All documents in the docket are listed in the
regulations.gov index. However, not all documents listed in the index
may be publicly available, such as information that is exempt from
public disclosure.
A link to the docket web page can be found at: http://www1.eere.energy.gov/buildings/appliance_standards/commercial/wicf.html. This web page will contain a link to the docket for this
notice on the regulations.gov site. The regulations.gov web page will
contain simple instructions on how to access all documents, including
public comments, in the docket.
FOR FURTHER INFORMATION CONTACT:
Mr. Charles Llenza, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Program, EE-2J,
1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone:
(202) 586-2192. E-mail: [email protected].
Mr. Michael Kido, U.S. Department of Energy, Office of the General
Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC 20585-
0121. Telephone: (202) 586-8145. E-mail: [email protected] or Ms.
Elizabeth Kohl, U.S. Department of Energy, Office of the General
Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC 20585-
0121. Telephone: (202) 586-7796. E-mail: [email protected].
SUPPLEMENTARY INFORMATION: This final rule incorporates by reference
into subpart R of Title 10, Code of Federal Regulations, part 431 (10
CFR part 431), the following industry standards:
(1) AHRI 1250 (I-P)-2009, ``2009 Standard for Performance Rating of
Walk-In Coolers and Freezers,'' approved 2009.
(2) ASTM C1363-05, ``Standard Test Method for Thermal Performance
of Building Materials and Envelope Assemblies by Means of a Hot Box
Apparatus,'' approved May 1, 2005.
(3) DIN EN 13164:2009-02, ``Thermal insulation products for
buildings--Factory made products of extruded polystyrene foam (XPS)--
Specification,'' approved February 2009.
(4) DIN EN 13165:2009-02, ``Thermal insulation products for
buildings--Factory made rigid polyurethane foam (PUR) products--
Specification,'' approved February 2009.
(5) NFRC 100-2010[E0A1], ``Procedure for Determining Fenestration
Product U-factors,'' approved 2010.
Copies of ASTM standards can be obtained from ASTM International,
100 Barr Harbor Drive, West Conshohocken, PA 19428-2959, (610) 832-
9585, or http://www.astm.org.
Copies of AHRI standards can be obtained from AHRI. Air-
Conditioning, Heating and Refrigeration Institute, 2111 Wilson
Boulevard, Suite 500, Arlington, VA 22201, (703) 600-0366, or http://www.ahrinet.org.
Copies of DIN EN standards can be obtained from CEN. European
Committee for Standardization (French: Norme or German: Norm), Avenue
Marnix 17, B-1000 Brussels, Belgium, Tel: + 32 2 550 08 11, Fax: + 32 2
550 08 19 or http://www.cen.eu.
Copies of NFRC standards can be obtained from NFRC. National
Fenestration Rating Council, 6305 Ivy Lane, Ste. 140, Greenbelt, MD
20770, (301) 589-1776, or http://www.nfrc.org.
You can also view copies of these standards at the U.S. Department
of Energy, Resource Room of the Building Technologies Program, 950
L'Enfant Plaza, SW., 6th Floor, Washington, DC 20024, (202) 586-2945,
between 9 a.m. and 4 p.m., Monday through Friday, except Federal
holidays.
Table of Contents
I. Authority and Background
II. Summary of the Final Rule
III. Discussion
A. Overall Approach: Component-Based Testing
1. Test Metrics
2. Responsibility for Testing and Compliance
3. Basic Model
B. Test Procedures for Envelope Components
1. Definition of Envelope
2. Heat Transfer Through Panels
3. Energy Use of Doors
4. Heat Transfer via Air Infiltration
5. Electrical Components
C. Test Procedures for Refrigeration Systems
1. Definition of Refrigeration System
2. Refrigeration Test Procedure: AHRI 1250 (I-P)-2009
3. Alternative Efficiency Determination Method
D. Other Issues--Definition of Walk-In Cooler or Freezer
[[Page 21581]]
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review Under the Regulatory Flexibility Act
1. Statement of the Need for, and Objectives of, the Rule
2. Summary of the Significant Issues Raised by the Public
Comments, DOE's Response to These Issues, and Any Changes Made in
the Proposed Rule as a Result of Such Comments
3. Description and Estimated Number of Small Entities Regulated
4. Description and Estimate of Compliance Requirements and
Description of Steps To Minimize the Economic Impact on Small
Entities
C. Review Under the Paperwork Reduction Act of 1995
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under Treasury and General Government Appropriations
Act, 2001
K. Review Under Executive Order 13211
L. Review Under Section 32 of the Federal Energy Administration
Act of 1974
M. Congressional Notification
N. Approval of the Office of the Secretary
I. Authority and Background
Title III of the Energy Policy and Conservation Act (42 U.S.C.
6291-6317; ``EPCA'' or, ``the Act'') sets forth a variety of provisions
designed to improve energy efficiency. (All references to EPCA refer to
the statute as amended through the Energy Independence and Security Act
of 2007 (EISA 2007), Public Law 110-140 (Dec. 19, 2007)). Part C of
Title III (42 U.S.C. 6311-6317), which was subsequently redesignated as
Part A-1 for editorial reasons, establishes an energy conservation
program for certain industrial equipment. This includes walk-in coolers
and walk-in freezers, the subject of today's notice. (42 U.S.C.
6311(1), (20), 6313(f), and 6314(a)(9))
Under EPCA, this program consists essentially of three parts: (1)
Testing, (2) labeling, and (3) Federal energy conservation standards.
The testing requirements consist of test procedures that manufacturers
of covered products or equipment must use (1) as the basis for
certifying compliance with the applicable energy conservation standards
adopted under EPCA, and (2) for making representations about the
efficiency of those products. Similarly, DOE must use these test
requirements to determine whether the products comply with any relevant
standards promulgated under EPCA.
Section 312 of the Energy Independence and Security Act of 2007
(``EISA 2007'') amended EPCA by adding certain equipment to this energy
conservation program, including walk-in coolers and walk-in freezers
(collectively ``walk-in equipment,'' ``walk-ins,'' or ``WICF.''). (42
U.S.C. 6311(1), (20), 6313(f), and 6314(a)(9)) As amended by EISA 2007,
EPCA requires DOE to establish new test procedures to measure the
energy use of walk-in coolers and walk-in freezers. (42 U.S.C.
6314(a)(9)(B)(i)) The new test procedures for WICF equipment are the
subject of this rulemaking. EPCA also directs DOE to publish
performance-based standards and promulgate labeling requirements (42
U.S.C. 6313(f)(4)(A) and 42 U.S.C. 6315(e), respectively). These
actions will be covered in separate rulemakings.
In the notice of proposed rulemaking published January 4, 2010
(January 2010 NOPR or, in context, NOPR), DOE proposed to establish
test procedures to measure the energy efficiency of walk-in coolers and
freezers. 75 FR 186. DOE identified several issues in its proposal
based on the public comments submitted in response to the January 2010
NOPR and further research. These issues included: (1) The proposed
definition of a walk-in cooler or freezer with regards to the upper
temperature limit; (2) the proposal to create test procedures for the
envelope and refrigeration system of a walk-in cooler or freezer; (3)
the proposal to group walk-in envelopes and refrigeration systems with
essentially identical construction methods, materials, and components
into a single basic model; and (4) the proposed calculation methodology
for determining the energy consumption of units within the same basic
model. 75 FR 186, (Jan. 4, 2010). On March 1, 2010, DOE held a public
meeting to receive comments, data, and information on the January 2010
NOPR. Through their comments, interested parties raised significant
issues and suggested changes to the proposed test procedures. DOE
determined that some of these comments warranted further consideration
and published a supplemental notice of proposed rulemaking on September
9, 2010 (September 2010 SNOPR or, in context, SNOPR). 75 FR 55068. DOE
received 22 written comments on the September 2010 SNOPR. This final
rule addresses comments from the January 2010 NOPR that were not
addressed in the September 2010 SNOPR and comments received on the
September 2010 SNOPR.
General Test Procedure Rulemaking Process
Under 42 U.S.C. 6314, EPCA sets forth the criteria and procedures
DOE must follow when prescribing or amending test procedures for
covered equipment. EPCA provides that test procedures ``shall be
reasonably designed to produce test results which reflect energy
efficiency, energy use and estimated annual operating costs of a type
of industrial equipment (or class thereof) during a representative
average use cycle as determined by the Secretary [of Energy], and shall
not be unduly burdensome to conduct.'' (42 U.S.C. 6314(a)(2))
Additionally, EPCA notes that if the procedure determines estimated
annual operating costs, the procedure ``shall provide that such costs
shall be calculated from measurements of energy use in a representative
average use cycle (as determined by the Secretary), and from
representative average-unit costs of the energy needed to operate such
equipment during such cycle.'' (42 U.S.C. 63114(a)(3)) Further, the
statute provides that DOE ``shall provide information to manufacturers
of covered equipment respecting representative average unit costs of
energy.'' Id.
With respect to today's rulemaking, the test procedure DOE is
prescribing today is a new test procedure. Today's rule establishes a
comprehensive testing regime to ensure minimum levels of performance by
applying the component-based approach detailed in EISA 2007. The
separate but concurrent energy conservation standards rulemaking for
walk-in coolers and walk-in freezers will be based on the performance
of walk-in coolers and walk-in freezers as measured by the test
procedure set forth in this final rule.
II. Summary of the Final Rule
Today's final rule establishes a new test procedure for measuring
the energy efficiency of walk-in cooler and walk-in freezer equipment.
The test procedure is essentially composed of tests for the principal
components that make up a walk-in: Panels, doors, and refrigeration.
Testing individual components of walk-in coolers and walk-in freezers
is simpler and less burdensome to manufacturers than testing an entire
walk-in. In this test procedure, DOE also provides a method for
calculating the energy use of an entire envelope, or the efficiency of
a refrigeration system, based on the results of the component tests.
The test procedure incorporates by reference the industry test
procedures ASTM C1363-05, ``Standard Test
[[Page 21582]]
Method for Thermal Performance of Building Materials and Envelope
Assemblies by Means of a Hot Box Apparatus,''DIN EN 13164:2009-02,
``Thermal insulation products for buildings--Factory made products of
extruded polystyrene foam (XPS)--Specification,'' DIN EN 13165:2009-02,
``Thermal insulation products for buildings--Factory made rigid
polyurethane foam (PUR) products--Specification,'' NFRC 100-2010[E0A1],
``Procedure for Determining Fenestration Product U-factors,'' and AHRI
1250 (I-P)-2009, ``2009 Standard for Performance Rating of Walk-In
Coolers and Freezers.''
Concurrently, DOE is undertaking an energy conservation standards
rulemaking to address the statutory requirement to establish
performance standards for walk-in equipment by 2012. (42 U.S.C.
6313(f)(4)(A)) DOE will use this test procedure in the concurrent
process of evaluating potential performance standards for the
equipment. After the compliance date of the performance standards, this
walk-in cooler and walk-in freezer test procedure, along with any
future statistical sampling plans that may be adopted, must be used by
manufacturers to determine compliance with the standards, and by DOE to
ascertain compliance with the standards in any enforcement action.
Moreover, once any final test procedure is effective, any
representation of the energy use of walk-in equipment or components
must reflect the results of testing that equipment using the test
procedure.
III. Discussion
In this section, DOE describes the overall approach it followed in
developing today's test procedure for walk-in cooler and freezer
equipment, including envelope components and refrigeration systems. The
following section also addresses issues raised by interested parties,
which consisted of the following entities:
Manufacturers: American Panel, Craig Industries,
CrownTonka, Heatcraft Refrigeration Products (Heatcraft), Hill Phoenix,
International Cold Storage (ICS), Kysor Panel Systems (Kysor Panel),
Manitowoc, Master-Bilt, Owens Corning, Nor-Lake, ThermalRite, Thermo-
Kool, and Zero Zone;
Material suppliers: Carpenter Company (Carpenter);
Trade associations: AHRI, Center for the Polyurethanes
Industry (CPI);
Utility companies: Pacific Gas & Electric Company (PG&E),
Southern California Edison (SCE), Sacramento Municipal Utility District
(SMUD), and San Diego Gas and Electric (SDG&E);
Advocacy groups: Appliance Standards Awareness Project
(ASAP), Alliance to Save Energy (ASE), American Council for an Energy-
Efficient Economy (ACEEE), Natural Resources Defense Council (NRDC),
Northeast Energy Efficiency Partnerships (NEEP), and Northwest Energy
Efficiency Alliance (NEEA);
Other parties: Oak Ridge National Laboratory (ORNL), and
the Small Business Administration (SBA).
A. Overall Approach: Component-Based Testing
In the framework document, DOE contemplated developing a single
test for an entire walk-in cooler or freezer. See http://www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/wicf_framework_doc.pdf. However, feedback from interested parties
indicated that a single test procedure for the entire WICF would not be
practical because many walk-ins are assembled on site with components
from different manufacturers, which would make on-site testing
infeasible. DOE then proposed in the January 2010 NOPR and September
2010 SNOPR to develop separate tests for the envelope and refrigeration
system of a walk-in, which in aggregate would represent the performance
of the entire walk-in (75 FR 186, 191 (Jan. 4, 2010) and 75 FR 55068,
55070 (Sept. 9, 2010)). DOE proposed to have one metric for the
refrigeration system, which would be an efficiency metric, and one
metric for the envelope, which would be an energy use metric. The
envelope metric would account for electrical use of envelope
components, as well as any energy used by the refrigeration system to
reject the heat contributed by conduction, infiltration, and other heat
sources. In this way, DOE intended to capture the energy impact of
components, such as panels, that do not themselves consume electricity.
DOE received comments on the September 2010 SNOPR from interested
parties stating that the walk-in cooler and walk-in freezer main
components could be further broken down into their own constituent
components: panels and doors of envelopes and unit coolers and
condensing units of refrigeration systems. Commenters explained that
all of these components could be produced by separate manufacturers and
then assembled into a complete walk-in. Because of this situation, it
would be difficult to determine who should test the walk-in envelope,
the refrigeration system, or both. It would also be difficult to
determine who would be best positioned to ensure the walk-in cooler or
freezer complied with an energy conservation standard. DOE acknowledges
these and similar concerns from the stakeholders.
Based on the information provided by commenters and DOE's own
research, DOE has determined that a component-based approach would
address the unique challenges posed in regulating the energy efficiency
performance of walk-in envelopes. As noted above, these challenges
include the fact that walk-in units are frequently assembled using
components made by multiple manufacturers, and walk-in installers may
not be equipped to test all the components that comprise a walk-in.
These factors indicate that a component-based approach would not only
help ensure compliance with whatever energy conservation standards that
DOE sets, but also reduce the overall testing burden on the
manufacturers, including small businesses who are involved in producing
walk-in units, either in full or in part.
Moreover, DOE notes that the adoption of such an approach is
consistent with the component-based approach that Congress took when it
enacted EISA 2007. Thus, DOE is adopting a component-level approach for
this rule and discusses the specific component metrics in greater
detail in section III.A.1.
1. Test Metrics
As stated previously, DOE initially proposed separate test
procedures for envelopes and refrigeration systems of walk-ins along
with different test metrics for each. The metric for the refrigeration
system would be an efficiency metric, and the metric for the envelope
would be an energy use metric that would account for the electrical use
of envelope components and the energy used by the refrigeration system
to reject the heat contributed by conduction, infiltration, and other
heat sources. To account for different sizes of envelopes, DOE further
proposed that the result of the envelope test procedure should be a
normalized energy use metric--the total energy use divided by the
external surface area of the envelope (energy use per square foot).
Several interested parties disagreed with the proposed metrics.
NEEA stated that regulating walk-in coolers and walk-in freezers on the
basis of annual energy use would not accurately estimate actual energy
use, and therefore such estimates would be misleading for almost all
installed systems. NEEA suggested using an overall U-value for the
entire envelope and a spreadsheet that calculates the overall U-factor
of a walk-in by weighted area. (NEEA, No. 0061.1 at
[[Page 21583]]
p. 1 and 9; NEEA, No. 0061.2 at p. 1) (In this and subsequent
citations, the document number refers to the number of the comment in
the Docket for the DOE rulemaking on test procedures for walk-in
coolers and freezers, Docket No. EERE-2008-BT-TP-0014; and the page
references refer to the place in the document where the statement
preceding appears.) NRDC also disagreed with the annual energy use
metric because of the number of assumptions that would be required and
the potential to confuse customers. (NRDC, No. 0064.1 at p. 7) NRDC
further stated that normalizing energy use to the surface area would be
unusual and may not be useful. (NRDC, No. 0064.1 at p. 2) NEEA
suggested that the envelope metric should be a U-factor (which is a
characterization of the heat loss performance). (NEEA, No. 0061.1 at p.
7) A comment submitted jointly by SCE, SDG&E, PG&E, and SMUD, hereafter
referred to as the Joint Utilities, suggested an area-based conductance
metric for the envelope that would consider both opaque and transparent
surfaces. (The Joint Utilities, No. 0059.1 at p. 2) NRDC also suggested
a metric for refrigeration systems that would encompass the total
equivalent warming impact and measure the heat loads from refrigeration
systems impacting a building's heating, ventilation, and air
conditioning (HVAC) system. (NRDC, No. 0064.1 at p. 8) A comment
submitted jointly by ACEEE, ASAP, ASE, NRDC, NEEP, and NEEA on the
September 2010 SNOPR (hereafter referred to as The Joint SNOPR comment)
stated that the energy conservation standard for envelopes should be
the overall heat gain (U-overall) with separate standards for walk-in
coolers and walk-in freezers. (Joint SNOPR Comment, No. 0074.1 at p. 2)
While other interested parties suggested specific metrics for walk-
in components, manufacturers also offered suggestions for overall walk-
in metrics. Craig Industries recommended combining the envelope and
refrigeration calculations to calculate the overall efficiency of the
complete walk-in system and labeling each walk-in with that efficiency
metric. (Craig, No. 0068.1 at p. 6) Zero Zone stated that the test
procedure should include performance testing to verify adequate
temperatures inside the walk-in. (Zero Zone, No. 0077.1 at p. 1)
In view of the component-level approach being adopted today, DOE is
not establishing an overall energy use metric for the envelope in this
test procedure. Instead, DOE is establishing separate metrics for the
individual components of the walk-in: the wall and ceiling panels
(hereafter referred to as non-floor panels); floor panels; the display
and non-display doors; and the refrigeration system. Regarding Zero
Zone's suggestion that the procedure verify that adequate internal
temperatures are used in evaluating a walk-in unit's efficiency, DOE
does not believe that such a requirement is necessary in light of the
component-based approach being adopted today.
The panel metric determined by the test procedure accounts for the
conductance and is in terms of U-factor (that is, the thermal
transmittance) measured in Btu/h-ft\2\-[deg]F, as NEEA, the Joint SNOPR
Comment, and the Joint Utilities recommended. The metric for display
and non-display doors accounts for the thermal transmittance through
the door and the electricity use of any electrical components
associated with the door, and is in terms of energy use, measured in
kWh/day. DOE believes that requiring separate metrics for specific
individual walk-in components does not constitute a substantive change
from what was proposed in the September 2010 SNOPR because this Final
Rule only requires tests that were proposed for components in the
September 2010 SNOPR. Also, the September 2010 SNOPR and this final
rule contain similar calculation methodologies.
2. Responsibility for Testing and Compliance
DOE proposed to adopt separate tests for the envelope and
refrigeration system of a walk-in and require the manufacturers of each
to test and certify the part they manufacture. 75 FR 186, 191 (Jan. 4,
2010) and 75 FR 55068, 55070 (Sept. 9, 2010). In response to this
proposed approach, DOE received multiple comments regarding who should
assume testing, certification, and compliance responsibilities. The
Joint SNOPR Comment recommended that DOE focus on factory-produced
products (i.e. kits) instead of walk-ins that are assembled on-site
from components from different manufacturers. (Joint SNOPR Comment, No.
0074.1 at p. 1) The Joint SNOPR Comment further suggested that panel,
refrigeration system, and door manufacturers each be responsible for
compliance and certification responsibilities for their own products.
(Joint SNOPR Comment, No. 0074.1 at pp. 2-3) Thermo-Kool agreed with
this approach and submitted a copy of a regulatory framework proposed
by NEEA, in which envelope, door, and refrigeration manufacturers would
be responsible for testing and complying with the standards for the
components they manufacture. (Thermo-Kool, No. 0072.1 at p. 1)
DOE received several other comments which it summarized in the
certification, compliance, and enforcement (CCE) final rule, published
on March 7, 2011. 76 FR 12422, 12444. In brief, some of those comments
agreed with the approach suggested by the Joint SNOPR Comment and
Thermo-Kool that individual component manufacturers should test,
certify, and ensure compliance of their respective components. Other
commenters recommended that the manufacturer, the assembler, or the
system designer of the overall walk-in should be responsible for the
compliance of the walk-in with the standards. 76 FR 12442-12446.
In the CCE final rule, DOE addressed these comments by defining the
manufacturer of a walk-in at 10 CFR 431.302. 76 FR 12504.
The definition extends the compliance responsibility to both the
component manufacturer and the assembler. In the CCE final rule, DOE
clarified that component manufacturers would be the entity responsible
for certifying compliance of the components they manufacture for walk-
in applications and ensuring compliance with the applicable Federal
standards of those components. Assemblers of the complete walk-in
system are required to use only components that are certified to meet
the applicable Federal standards. DOE also adopted a flexible
enforcement framework in which it will determine who is responsible for
noncompliance on a case-by-case basis. 76 FR 12444.
DOE notes that the provisions and clarifications in the CCE final
rule were made in the context of component manufacturers certifying
their components to the existing standards in EPCA, which prescribe
requirements on a component-level basis. DOE has decided to continue
this approach in developing test procedures and performance-based
standards for walk-in coolers and freezers. DOE believes that, within
the very limited context of walk in equipment, EPCA created a means for
DOE to set performance-based standards for certain walk-in component
manufacturers. In particular, because Congress set requirements for
specific components used in walk-in applications, it provided DOE with
the implicit authority to set performance-based standards at the
component level for these specific components. This unique ability
stems from the manner in which Congress set standards for walk-in
equipment by prescribing, among
[[Page 21584]]
other things, specific performance-based requirements for wall,
ceiling, door, and floor insulation panels used in walk-ins. See 42
U.S.C. 6313(f).
Because interested parties, including entities who produce these
components and are subject to today's requirements, have indicated to
DOE that the energy efficiency performance of WICF components would be
most readily and easily tested and certified by component
manufacturers, DOE intends to take this approach for WICF test
procedures and performance standards. DOE acknowledges the numerous
difficulties that commenters have noted with alternative proposed
approaches. By requiring individual component manufacturers to certify
that their components satisfy specified performance-based standards,
DOE can ease the overall burden on walk-in manufacturers relative to
the alternatives that were under consideration as part of the January
2010 NOPR and September 2010 SNOPR. Therefore, in this test procedure,
DOE is establishing tests for the components of a walk-in (i.e. panels,
doors, and refrigeration systems) and anticipates that component
manufacturers will test their equipment using the applicable procedure
and, in the future, will certify that they comply with the appropriate
standard. DOE emphasizes that until performance standards are
established, manufacturers are not required to use this test procedure
to certify equipment to DOE (although they must use this test procedure
in making representations as to the performance of their components).
However, because the prescriptive standards established by the 2007
amendments to EPCA are already in effect, manufacturers must
demonstrate compliance with them using the method specified in the CCE
final rule. 76 FR 12422.
3. Basic Model
DOE proposed a definition of basic model for both envelopes and
refrigeration systems. 75 FR 186, 188-189 (Jan. 4, 2010) and 75 FR
55068, 55071-55073 (Sept. 9, 2010). DOE received comments from
interested parties on the definition and summarized them in the CCE
final rule. 76 FR 12422. Consistent with its component-level approach
to certification, discussed in section III.A.2, and taking the comments
from interested parties into consideration, DOE decided to define a
basic model for each of the key components of a walk-in, rather than
defining a basic model for the entire walk-in. DOE emphasized that
although the term ``basic model'' is defined on the component level, it
is still implemented in the same manner as it is in the rest of DOE's
appliance standards program; that is, a basic model consists of
equipment that is essentially the same with respect to energy
consumption, efficiency, or other measure of performance. 76 FR 12444-
12446.
DOE provided, in relevant part, the definition of basic model in
the CCE final rule at 76 FR 12504 (providing definition of ``basic
model'' for walk-ins) (to be codified at 10 CFR 431.302).
DOE believes applying the basic model concept at the component
level will reduce the testing burden on manufacturers while ensuring
that their products meet any applicable standard, because it removes
the difficulty of testing and/or certifying different sized walk-ins
that would have different energy consumption levels. 76 FR 12445. The
CCE final rule provides that manufacturers may elect to group
individual models into basic models at their discretion to the extent
the models have essentially identical characteristics that affect
energy efficiency or energy consumption. Manufacturers may also rate
models conservatively--i.e. the tested performance of the model(s) must
be at least as good as the certified rating--after applying the
appropriate sampling plan. 76 FR 12429. The basic model concept is
applied slightly differently to panels, doors, and refrigeration
systems because of their different characteristics. These differences
are explained below.
a. Basic Model of Panels
Panels are construction components that are not doors and that are
used to construct the envelope of the walk-in. These components
comprise the elements separating the interior refrigerated environment
of the walk-in from the exterior environment. In this test procedure,
panels are classified as either floor panels, non-floor panels, or
display panels. A display panel is a panel that is entirely or
partially comprised of glass, a transparent material, or both and is
used for display purposes. Floor and non-floor panels are mostly
comprised of insulating material and are not primarily used for display
purposes. For all types of panels, the energy efficiency metric is the
U-factor, which is a measure of conductive, convective, and radiative
heat transfer and which takes into account composite panel
characteristics, which may include the insulation type, structural
members, any type of transparent material (e.g. glass), and panel
thickness. See section III.B.2 for details on how the U-factor is
determined. DOE considers a panel basic model to include panels which
do not have any differing features or characteristics that affect the
U-factor. 76 FR 12504.
DOE notes that manufacturers who make customized panels may
experience a higher certification burden than manufacturers of
standardized panels. For example, under today's procedure, a panel's U-
factor is a surface area-independent metric, which implies that
variation in panel width and height alone would not be expected to
affect the U-factor rating if all other characteristics were equal. In
those instances where no changes in energy efficiency would occur,
these panels could be grouped as a basic model. In contrast, smaller
floor and non-floor panels may have a higher proportion of framing
material to non-framing material, or other structural members, which
could affect the overall panel U-factor rating if the framing material
or framing geometry has different thermal conductivity performance than
the neighboring insulation. Therefore, for two or more floor or non-
floor panels that are equivalent in materials and other characteristics
but differ in their frame to insulation proportions such that they have
different U-factor ratings, the panels would be considered different
basic models and would need to be certified independently to DOE, if
the manufacturer chooses to claim different U-factor ratings. However,
DOE emphasizes that as explained in section III.3, manufacturers may
group models into basic models at their discretion as long as the
tested performance of the models is at least as good as the certified
rating.
DOE has also introduced additional provisions to reduce the testing
and certification burden on floor and non-floor panel manufacturers.
See section III.B.2.a for details.
As explained above, the energy efficiency metric for display panels
is the U-factor, as for floor and non-floor panels. However, unlike a
floor, ceiling, or wall panel, a display panel is essentially a window.
Therefore, in this test procedure, DOE is requiring the U-factor of
display panels to be tested using NFRC 100-2010[E0A1], ``Procedure for
Determining Fenestration Product U-factors,'' which DOE proposed in the
SNOPR for measuring the U-factor of doors and windows, including their
framing materials. 75 FR 55083. (Sept. 9, 2010) As with floor and non-
floor panels, the basic model concept allows manufacturers to group
display panels that are essentially identical in U-factor into one
basic model, which DOE anticipates will reduce the testing burden on
display
[[Page 21585]]
panel manufacturers. Also, NFRC 100-2010[E0A1] allows verified computer
models to simulate a display panel's energy consumption, another factor
that reduces the manufacturer's testing burden.
b. Basic Model of Doors
A door is an assembly installed in an opening on an interior or
exterior wall that is used to allow access or close off the opening and
that is movable in a sliding, pivoting, hinged, or revolving manner of
movement. For walk-in coolers and walk-in freezers, a door includes the
door panel, glass, framing materials, door plug, mullion, and any other
elements that form the door or part of its connection to the wall. This
test procedure defines two types of doors, display and non-display
doors. Display doors are doors designed for product movement, display,
or both, rather than the passage of persons, and non-display doors are
considered to be all other types of doors. For all doors, the energy
consumption metric that DOE is adopting in today's rule incorporates
the U-factor and any electrical components built into the door. (See
section I.A.1.a for details.) Calculating this metric requires the use
of NFRC 100-2010[E0A1], ``Procedure for Determining Fenestration
Product U-factors,'' which DOE proposed in the SNOPR for measuring the
U-factor of doors and windows, including their framing materials. 75 FR
55083. (Sept. 9, 2010) Applying the NFRC test yields an overall U-
factor for the tested door. Then, through calculations outlined in
Appendix A, the U-factor and the electrical energy consumption are
combined to create a rating for the door.
As with panels, doors with essentially identical energy consumption
levels may be grouped into a basic model and rated conservatively. 76
FR 12429 and 12504. The basic model concept can be used to reduce the
testing and certification burdens by allowing manufacturers to group
doors that are essentially identical in energy consumption but
cosmetically different. The NFRC procedure also permits either a
physical test or a verified computer model to be used when determining
the U-factor of the door. The latter of these options would be expected
to reduce testing burden because only a series of calculations would
need to be run by an NFRC-approved computer modeling program. DOE also
notes that the calculations for energy consumption of door components
are not based on testing, which reduces the general testing burden for
doors. Any results from physical tests, computer simulations, and
calculations must be retained as required by the CCE final rule. 76 FR
12494.
c. Basic Model of Refrigeration Systems
The refrigeration system consists primarily of a compressor,
condenser, unit cooler, valves, and piping. It is considered a
component under the component level approach (see section III.A) that
DOE is adopting in today's final rule. As with the panels and doors,
and consistent with the approach promulgated in the CCE final rule,
manufacturers may elect to group individual models into basic models at
their discretion to the extent the models have essentially identical
electrical, physical, and functional characteristics that affect energy
efficiency or energy consumption. Furthermore, manufacturers may rate
models conservatively, meaning the tested performance of the model(s)
must be at least as good as the certified rating, after applying the
appropriate sampling plan. 76 FR 12429. DOE believes these provisions
will reduce the burden of testing for refrigeration manufacturers,
including those who make customized equipment. DOE may also consider
methods which allow manufacturers to use an alternate method of
determining the energy use of the refrigeration system in a future
rulemaking. This concept is further discussed in section III.C.3.
B. Test Procedures for Envelope Components
The envelope consists of the insulated box in which items are
stored and refrigerated. In the NOPR and SNOPR, DOE proposed methods
for evaluating the performance characteristics of insulation, testing
thermal energy gains related to air infiltration, and determining
direct electricity use and heat gain due to internal electrical
components. The proposed procedure used these methods to determine the
energy use associated with the envelope by calculating the effect of
the envelope's characteristics and components on the energy consumption
of the walk-in as a whole. Those characteristics and components
included the energy consumption of electrical components present in the
envelope (such as lights) and variation in the energy consumption of
the refrigeration system due to heat loads introduced as a function of
envelope performance (such as conduction of heat through the walls of
the envelope). The impact on the refrigeration system energy
consumption was determined by calculating the energy consumption of a
theoretical or ``nominal'' refrigeration system when paired with the
tested envelope. 75 FR 186, 191 (Jan. 4, 2010) and 75 FR 55068, 55074
(Sept. 9, 2010).
As described in section III.A, DOE is no longer requiring
manufacturers to determine the energy consumption of the entire
envelope in this final rule. Rather, DOE is establishing metrics for
the principal components of the envelope (i.e. the panels and doors) as
described in section III.A.1. In doing so, DOE is requiring
manufacturers to use the same physical tests for the components that it
proposed in the NOPR and SNOPR, but is introducing revisions to the
calculations in Appendix A of the new procedure. These revisions will
enable manufacturers to calculate the required component metrics from
the results of those tests.
For panels, DOE is adopting separate approaches depending on
whether a given panel is a display or non-display panel. Display panels
are panels that are primarily made of transparent material and used for
display purposes. Display panels are considered equivalent to windows
because of their transparent characteristics and associated thermal
heat transfer properties, and therefore the U-factor will be measured
by NFRC 100-2010[E0A1], ``Procedure for Determining Fenestration
Product U-factors,'' which DOE proposed in the SNOPR for measuring the
U-factor of doors and windows, including their framing materials. 75 FR
55083. (Sept. 9, 2010) Non-display panels are floor and non-floor
panels. Since both floor and non-floor panels are typically made out of
a composite of insulation, framing, and facer material, both types of
panels will be tested using the same methodology. In today's rule, the
physical tests pertaining to the performance of non-display panels are
from ASTM C1363-05, ``Standard Test Method for Thermal Performance of
Building Materials and Envelope Assemblies by Means of a Hot Box
Apparatus'' and, for foams that experience aging, DIN EN 13164:2009-02,
``Thermal insulation products for buildings--Factory made products of
extruded polystyrene foam (XPS)--Specification'' or DIN EN 13165:2009-
02, ``Thermal insulation products for buildings--Factory made rigid
polyurethane foam (PUR) products--Specification,'' as applicable. These
tests were proposed in the SNOPR. 75 FR 55068, 55075-55076 and 55081
(Sept. 9, 2010). In this final rule, panel performance is denoted by
its overall U-factor, or thermal transmittance, which is determined by
the test procedures and calculation methodologies described in section
III.B.2.
[[Page 21586]]
DOE is requiring one test for door performance, NFRC 100-
2010[E0A1], ``Procedure for Determining Fenestration Product U-
factors,'' which was proposed in the SNOPR. 75 FR 55083 (Sept. 9,
2010). This test measures conduction through a door, whether it is a
display door or a non-display door. The total energy consumption of a
door is calculated as the effect of a door's thermal load on the
refrigeration system combined with the door's electrical energy use, as
described in section 4.5 and section 4.4 of Appendix A of this final
rule. The effect on the refrigeration system is determined by
calculating the energy consumption that a theoretical or ``nominal''
refrigeration system would use to reject the heat that was transmitted
through the door. The energy that would be used by the theoretical
refrigeration system to reject a given amount of heat is represented by
the energy efficiency ratio (EER) of the refrigeration system. The test
procedure uses the same nominal refrigeration system EER for all tested
doors to enable direct comparisons of the performance of walk-in doors
across a range of sizes, product classes, and features. The nominal EER
values for cooler and freezer refrigeration (i.e. 12.4 Btu/W-h and 6.3
Btu/W-h for coolers and freezers, respectively) are the same as those
proposed in the SNOPR for calculating the energy use of the envelope.
See 75 FR 55013 (Sept. 9, 2010).
1. Definition of Envelope
In the January 2010 NOPR, DOE proposed the following definition of
``envelope:''
Envelope means (1) a piece of equipment that is the portion of a
walk-in cooler or walk-in freezer that isolates the interior,
refrigerated environment from the ambient, external environment; and
(2) all energy-consuming components of the walk-in cooler or walk-in
freezer that are not part of its refrigeration system.
75 FR 186, 192 (Jan. 4, 2010).
The walk-in envelope was proposed to include, but not be limited
to, walls, floors, ceilings, seals, windows, doors, or any combination
thereof, composed of single or composite materials. DOE did not propose
any changes to this definition in the September 2010 SNOPR.
Master-Bilt, BASF, ThermalRite, ACEEE, and ICS submitted written
comments supporting the proposed definition for the walk-in envelope.
(Master-Bilt, No. 0027.1 at p. 1; BASF, No. 0021.1 at p. 3;
ThermalRite, No. 0049.1 at p. 1; ACEEE, No. 0052.1 at p. 2; ICS, No.
0045.1 at p. 1) However, Nor-Lake asked that the definition of envelope
exclude components of the envelope purchased separately by the end user
to enable the manufacturer of the envelope to avoid compliance
responsibility for the performance of those components. (Nor-Lake, No.
0023.1 at p. 2) ICS requested clarification on the preemption of energy
codes by building, electrical, and mechanical codes and stated that the
definition must allow for structural and electrical safety code
compliance over energy compliance when in conflict. (ICS, No. 0045.1 at
p. 1) A representative from Gonzaga Law argued that the definition
proposed by the DOE was too inclusive but did not propose an
alternative definition. (Gonzaga Law, No. 0018 at p. 1) At the public
meeting for the January 2010 NOPR, ICS suggested that DOE's standards
and definitions should align with NSF's (formerly known as the National
Sanitation Foundation) definition of envelope and requirements. (ICS,
Public Meeting Transcript, 0016 at p. 30) (In this and subsequent
citations, ``Public Meeting Transcript'' refers to the transcript of
the March 1, 2010, public meeting on the proposed test procedures for
walk-in coolers and freezers. ``No. 0016'' refers to the document
number of the transcript in the Docket for the DOE rulemaking on test
procedures for walk-in coolers and freezers, Docket No. EERE-2008-BT-
TP-0014; and the page number refers to the place in the transcript
where the statement preceding appears.)
DOE notes the comments and suggestions from Master-Bilt, BASF,
ThermalRite, ACEEE, ICS, and Gonzaga Law. However, because DOE is
taking a component-based approach, the proposed envelope definition is
no longer applicable for the purpose of this test procedure. As
suggested by ICS, when evaluating potential standards applicable to
walk-ins, DOE will also consider their related requirements that
manufacturers need to satisfy. In response to Nor-Lake's comment
regarding components not supplied by the envelope manufacturer, DOE
clarifies that each component manufacturer is responsible for testing
its component with the appropriate test procedure as discussed in
section III.A.2. The envelope component manufacturer is not responsible
for the end user's implementation of the component; rather, the
manufacturer would be responsible only for the component's compliance
as designed. Also, the envelope assembler is responsible for using
WICF-compliant components to assemble the total envelope.
2. Heat Transfer through Panels
a. U-Factor of Composite Panels Including Structural Members of Panels
EPCA specifies that ASTM C518-04, ``Standard Test Method for
Steady-State Thermal Transmission Properties by Means of the Heat Flow
Meter Apparatus,'' must be used to determine the K-factor of walk-in
insulation. The statute defines the R-value as equal to the value of 1/
K-factor multiplied by the thickness of the panel. (42 U.S.C. 6314
(a)(9)(A)(i)-(ii)) In response to the January 2010 NOPR, interested
parties commented that the heat conduction through structural members
must be considered because this factor could affect the conductance
through the composite walk-in insulation panel. Accordingly, DOE
proposed in the September 2010 SNOPR to use ASTM C1363-05, ``Standard
Test Method for Thermal Performance of Building Materials and Envelope
Assemblies by Means of a Hot Box Apparatus,'' to measure the overall U-
factor of fully assembled panels to help account for the impact that
structural members have on the overall U-factor. 75 FR 55074.
Several interested parties--NEEA, AHRI, Master-Bilt, Thermo-Kool,
Carpenter, and Bally--supported the use of ASTM C1363-05 to measure the
overall panel U-factor. (NEEA, No. 0061.1 at p. 2; AHRI, No. 0070.1 at
p. 2; Master-Bilt, No. 0069.1 at p. 1; Thermo-Kool, No. 0072.1 at p. 1;
Carpenter, No. 0070.1 at p.2; Bally, No. 0078.1 at p. 2))
Other interested parties, however, disagreed with DOE's proposal to
use ASTM C1363-05 to measure panel performance. At least some of these
concerns were premised on a mistaken belief that DOE's proposal would
result in the elimination of structural members embedded into panels.
For example, a comment submitted jointly by the manufacturers
CrownTonka, ThermalRite, and ICS (collectively referred to as the Joint
Manufacturers) recommended that structural members be excluded from the
stated R-value requirements for overall envelope thermal resistance.
The Joint Manufacturers explained that many walk-ins require the use of
structural members to comply with building codes and to help support
loads placed on the building from factors such as snow and wind. The
Joint Manufacturers stated that ASTM C518-04 should be used to measure
the K-factor of foam, as specified in EPCA. (42 U.S.C. 6314
(a)(9)(A)(i)-(ii)) (Joint Manufacturers, No. 0062.1 at p. 1)
While American Panel agreed with DOE's general approach that the R-
value
[[Page 21587]]
of structural members should be considered in determining the overall
U-factor and submit data to demonstrate the impact of structural
members on the overall U-factor, it stated that the composite panel
must meet the minimum R-value requirement. American Panel continued to
state that the R-value should be calculated by using a weighted
percentage of foam R-value and structural R-value based on the
percentage each material represents in the panel. (American Panel, No.
0057.1 at p. 1; American Panel, No. 0057.1 at p. 2; American Panel, No.
0057.3 at p. 1) It asserted that ASTM C1363-05 is not the appropriate
test method for measuring the insulating values of foam, and added,
along with Craig Industries and Carpenter, that ASTM C518-04 should be
used to measure heat conduction through panels. (American Panel, No.
0057.1 at p. 2; Craig, No. 0068.1 at p. 2; Carpenter, No. 0067.1 at p.
2) Craig Industries was concerned that using ASTM C1363-05 to calculate
the heat conduction through structural members may not take the
reduction of joints (that is, panel to panel interfacing members) into
consideration. Craig Industries recommended that the structural members
should be tested with a procedure to represent the real R-value, which
would replace the R-value of the insulation where it is replaced with
structural members. (Craig, No. 0057.13 at p. 2) Carpenter further
asserted that ASTM C518-04 is simpler and less costly to perform than
C1363-05. (Carpenter, No. 0067.1 at p. 2) Thermo-Kool, on the other
hand, disagreed with the approach of using R-value testing of different
components of the composite panel to determine heat loss. (Thermo-Kool,
No. 0072.1 at p. 1) Bally, who agreed with DOE's proposed approach,
requested clarification specifically regarding how the two tested areas
would be used to represent the performance of a panel. (Bally, No.
0078.1 at p. 2)
None of the interested parties offered any further explanation for
their views other than those already described.
In this final rule, the terms ``foam'' and ``insulation'' are used
synonymously, but a panel is the fully manufactured product that
contains, but is not limited to, the insulating material, metal skin,
framing material, other structural members, or any combination thereof.
To address the Joint Manufacturers' concerns about the potential
elimination of structural members, DOE emphasizes that the overall U-
factor testing required by today's final rule will not prevent
manufacturers from including structural members in panels because the
existing standards in EPCA only regulate the R-value of the foam and do
not restrict the overall panel U-factor or the R-value of the
structural components. The R-value of insulation, which is 1/K-factor
as determined by ASTM C518-04, will still have to comply with the
existing EPCA requirements for insulation. (42 U.S.C. 6314
(a)(9)(A)(i)-(ii)) However, the overall U-factor of the fully assembled
panel, including structural members, may be used to meet an energy
conservation standard for panels, which will be determined in a
parallel rulemaking. Including ASTM C1363-05 will provide a more
accurate means to represent the overall heat transfer performance of
panels. DOE believes this procedure will be beneficial because it will
capture the effects of structural members that incorporate insulation
or otherwise contribute to the efficiency of the walk-in.
Additionally, while DOE acknowledges the concerns raised by
American Panel, the Joint Manufacturers, Craig Industries, and
Carpenter, the final rule includes ASTM C1363-05 as part of the test
procedure in order to determine the overall U-factor of the panel. DOE
is including this protocol as part of the test procedure because heat
conduction through structural members is a significant panel
characteristic that is not addressed under the statutorily-prescribed
testing requirements (i.e. ASTM C518-04). While ASTM C518-04 could be
used to individually measure the R-value of structural members, or any
other material, as Craig Industries suggested, DOE believes that this
approach would be more costly because of the many materials that could
comprise a panel and the need to test each material separately under
that approach. Furthermore, DOE believes that panel geometry could make
calculations to combine the R-value of each material into an overall
panel R-value complicated and burdensome.
DOE also acknowledges Craig Industries' concern that ASTM C1363-05
does not account for the reduction of joints (that is, panel to panel
interfacing members). Since DOE is adopting an approach to ensure the
energy efficiency performance of particular components, an approach
suggested by numerous commenters, and is no longer considering the
effects of infiltration, panel joint issues are outside of this
approach.
DOE notes that American Panel supported the inclusion of structural
members in calculating the overall U-factor. Furthermore, DOE would
like to clarify the calculation methodology to address the comment from
Bally. Today's final rule adopts a weighted percentage of the panel
edge (which may contain structural members) and panel core region
(which may also include structural members) in order to calculate the
panel's total U-factor. DOE believes that using the weighted percentage
of edge U-factor and core U-factor to calculate the total U-factor will
help reduce the manufacturer's testing burden.
In applying this weighted percentage approach, today's final rule
provides that for floor or non-floor panels of the same thickness,
construction methods, and materials, manufacturers must test a pair of
4 ft. by 8 ft. ``test panels'' to obtain a core U-factor and an edge U-
factor. The manufacturer must then calculate the overall U-factor of
other floor or non-floor panels with the same panel thickness,
construction methods, and materials using the U-factor results for the
core and edge region ``test panels.'' For example, a manufacturer tests
a 4 ft. by 8 ft. test panel and finds the edge region and core region
U-factors. The same manufacturer also produces 6 ft. by 8 ft. panels
that have identical core and edge region thickness, construction
methods and materials. Therefore, the manufacturer may apply the core
and edge region factors to the 6 ft. by 8 ft. panel to calculate the
overall U-factor of the 6 ft. by 8 ft. panel instead of performing an
additional test. DOE notes that any calculations that support the
certified ratings must be retained along with the test data for the
``test panels'' for all basic models pursuant to the requirements for
the maintenance of records promulgated in the CCE final rule. 76 FR
12494. DOE expects that, based on the information it has collected,
including information made available by manufacturers on their Web
sites and submitted comments, most manufacturers use the same panel
thickness, materials, and construction methods for many of their
panels, which results in a minimal testing burden.
In regard to American Panel's comment that the composite panel must
meet the minimum R-value requirement, DOE clarifies that EPCA states
that only the insulation material (that is, the foam) must meet the
prescribed R-value. (42 U.S.C. 6313(f)(1)(C)) The test procedure is
prescribing ASTM C1363-05 as a method of measuring the overall U-factor
of the entire panel. For EPCA compliance, the R-value of the insulation
must be separately determined in accordance with ASTM C518-04 as
specified in EPCA. (42 U.S.C. 6313(f)(1)(C))
[[Page 21588]]
Finally, interested parties suggested changes to the test
methodology DOE proposed. NRDC stated that irregular or non-homogeneous
foam products should be tested for actual R-value where there is no
quality control to maintain the orientation of the foam in the finished
product. To clarify, DOE believes that when NRDC noted the concern
about the orientation of the foam, they were referring to bun-stock
foam products. Bun-stock products are manufactured in ``buns'' that may
have foam cell structure similar to the grains in wood. Like wood,
depending on how the buns are cut into boards, the orientation of the
cell ``grains'' may vary by finished board. NRDC continued to suggest
that if a foam product cannot be tested, then the stated R-value should
be a conservative number representing the lowest R-value for a tested
material. (NRDC, No. 0064.1 at p. 4) NRDC also suggested that DOE
review the impact of testing the final fabricated panel rather than
requiring manufacturers to specially construct units for testing,
because specially constructed units may not represent the typical
product. (NRDC, No. 0064.1 at p. 4) Master-Bilt suggested changing the
width and length of the panel to 8 x 4 ft. +/- 1 ft. to have more
tolerance and allow for the testing of standard width panels. (Master-
Bilt, No. 0069.1 at p. 2)
In response to NRDC's comment about irregular or non-homogeneous
foam products, DOE anticipates that the prescribed sampling procedures
for certification will accurately capture the foam's R-value. A
sampling plan is intended to ensure accurate and statistically
repeatable results are achieved when using the test procedure. DOE
notes NRDC's concern that specifically constructed units may not
represent an actual product. However, in order to reduce the testing
burden presented by ASTM C1365-05, DOE is maintaining the approach of
specifying two test regions of a pair of representative panels. At one
test region, the tester measures the U-factor of the perimeter that may
contain structural members and panel-to-panel interface area (the
``Panel Edge''), while at the other region the tester measures the U-
factor of the core area of the panel (the ``Panel Core'') which may
also contain structural members. The U-factor for each region is then
applied to panels of the same type (that is, same foam type, framing
material, and panel thickness) to obtain an overall U-factor that is
representative of actual products sold by the panel manufacturer. DOE
applies a calculation methodology to extrapolate the core and edge U-
factor to determine the U-factor of any panel produced by a
manufacturer.
In response to Master-Bilt's comment, DOE agrees that increasing
the tolerance of the 8 ft x 4 ft test panel to +/- 1 ft will provide
manufacturers with a greater range of standard sized panels. DOE
conducted a mathematical analysis to determine how changing the
tolerance would affect the U-factor as determined by ASTM C1363-05. DOE
found that increasing the size tolerance of the test panel results in
less than a 0.5 percent change to the U-factor as determined by ASTM
C1363-05. Therefore, DOE has amended the standard size of a test panel
for ASTM C1363-05 to be 8 ft x 4 ft +/- 1 ft.
b. Long-Term Thermal Resistance
In the January 2010 NOPR and September 2010 SNOPR, DOE cited
several studies that conclude that lateral gas diffusion, which causes
a reduction in R-value, occurs in impermeably faced foams. See 75 FR
192-194 and 75 FR 55075-55079. These types of foams are common to walk-
ins. The lateral gas diffusion occurs over time and affects the energy
efficiency performance of the foam as diffusion continues. To account
for this aging effect on a foam's insulation performance--and, by
extension, the energy consumption of a walk-in due to thermal losses
attributable to this reduced performance--DOE, consistent with its
proposed approach, is adopting a method to account for this phenomenon
in walk-in applications. Hill Phoenix added that different methods of
manufacturing panels should be taken into account when determining the
test procedure. (Hill Phoenix, No. 0063.1 at p. 2)
The most significant factor affecting the efficiency of a walk-in
panel is the insulating foam in a panel, and accurately capturing the
foam's R-value is critical to measuring the overall performance of the
panel. Panels can be in use for 10 to 20 or more years before they are
replaced. Performance metrics for a panel based on initial foam R-value
will tend to overestimate the amount of energy saved over this
equipment's lifetime. Research on panel aging has shown that a 5-year
aged R-value found by LTTR testing is representative of the panel's
insulation performance over its lifetime, and there are industry tests
for walk-in foam that estimate the aged R-value over time. Using these
industry-developed protocols will enable manufacturers to more
accurately capture the lifetime performance of a walk-in panel.
Incorporating a long term thermal resistance degradation factor
improves the reliability of test results for walk-in panels. While EPCA
contains standards for the R-value or insulating performance of the
foam, these standards do not specify when the insulating foam must be
tested. (42 U.S.C. 6313(f)(1)(C)) Variables that impact the time at
which panels are tested include shipping time, production time,
shipment of completed panels to test lab, and test facility
availability. Changing any one of these variables could result in
significantly different test results and measured R-values. This is in
contrast to most other types of equipment within the appliance
standards program, which would not exhibit significant differences in
performance based on the length of time between manufacture and
testing. Because of the unique aging profile of certain foam types, the
timing of a walk-in panel test would affect both manufacturers'
certification of the panel U-factors and any enforcement testing
undertaken by DOE. Therefore, using LTTR values to measure foam
performance eliminates the ``time'' variable that could affect whether
a panel is shown to comply with an overall performance standard that
DOE may set. The purpose of the LTTR testing is to accelerate foam
aging to the point where the R-value changes relatively slowly over
time and to then measure its performance, thus improving the
repeatability of the test because the timing of the test is no longer
critical.
In the January 2010 NOPR, DOE proposed to use ASTM C1303-08,
``Standard Test Method for Predicting Long-Term Thermal Resistance of
Closed-Cell Foam Insulation,'' to calculate the long-term thermal
resistance (LTTR) of walk-in foam insulation. 75 FR 186, 193-94 (Jan.
4, 2010). In the September 2010 SNOPR, DOE proposed to use the updated
version of ASTM C1303-08, which was ASTM C1303-10. 75 FR 55068, 55075
(Sept. 9, 2010). In that notice, DOE also offered an alternative
method, Annex C of either DIN EN 13164:2009-02, ``Thermal insulation
products for buildings-- Factory made products of extruded polystyrene
foam (XPS)--Specification'' or DIN EN 13165:2009-02, ``Thermal
insulation products for buildings--Factory made rigid polyurethane foam
(PUR) products--Specification,'' as applicable, to test for the LTTR.
This alternative was offered in response to concerns raised in response
to the NOPR. The SNOPR requested comments on both of these alternative
methods. 75 FR 55079 (Sept. 9, 2010).
[[Page 21589]]
In light of the comments that DOE received on all of these various
testing methods, which are addressed below, DOE has decided to adopt
DIN EN 13165:2009-02 or DIN EN 13164:2009-02, as applicable, as the
test procedure for determining LTTR. The LTTR value determined by DIN
EN 13165:2009-02 or DIN EN 13164:2009-02 will be used to determine a
degradation factor, which will be the LTTR R-value divided by the
initial R-value of the foam. The initial R-value will be determined in
accordance with ASTM C518-04 as specified in the EISA 2007 amendments
to EPCA and used to establish compliance with those statutorily-
prescribed requirements. (42 U.S.C. 6313(f)(1)(C)) The degradation
factor is applied to the U-factor of the panel found by ASTM C1365-05;
see section 4.2 and 4.3 in Appendix A.These protocols are preferable to
ASTM C1303-10 because they account for the effect of impermeable
facers, which ASTM C1303-10 does not.
In response to this approach, DOE received a number of comments.
Thermo-Kool noted the general need to consider LTTR. It also suggested
that the potential for thermal degradation is more likely to occur at
the panel joints than from actual polyurethane (i.e. foam) issues.
(Thermo-Kool, 0072.1 at p. 1) The Joint Manufacturers recommended that
structural members be considered in the long-term thermal resistance
performance of any panels with structural edges because they may lessen
or slow off-gassing over time. (The Joint Manufacturers, No. 0062.1 at
p. 1).
American Panel and Bally opposed DOE's inclusion of a test
procedure that measured LTTR. (American Panel, No. 0057.2 at p. 1;
Bally, No. 0078.1 at p. 2) American Panel explained that impermeable or
metal skins protect the polyurethane foam from aging and that little
change will occur in the long term R-value. In support of its claim
that impermeably faced metal skins protect foam from aging, American
Panel submitted the results of a study conducted by Carpenter. That
study found a 3.6 percent loss in insulating value of a panel after 9
years in a walk-in application. (American Panel, No. 0057.2 at p. 1)
American Panel also asserted that none of its customers complained
about R-value loss in the panels that American Panel sold to them.
(American Panel, No. 0057.1 at p. 2)
One interested party recommended that DOE collect test data before
prescribing a particular test method. Bally stated that more data from
actual walk-in panels with intact metal skins and sealed edges should
be collected before DOE includes a test procedure for long-term thermal
resistance. (Bally, No. 0078.1 at p. 2)
DOE acknowledges Thermo-Kool's assertion that most aging occurs at
the panel joints and Bally's suggestion that DOE collect more data to
support long term thermal aging. DOE notes, however, that polyurethane
itself has the potential to age significantly. DOE cited multiple
studies, in both the January 2010 NOPR and September 2010 SNOPR, that
conclude that aging occurs in most types of foams commonly used in
walk-in applications, including polyurethane. 75 FR 192-194 (Jan. 4,
2010) and 75 FR 55075-55079 (Sept. 9, 2010). In response to the Joint
Manufacturers' comment about accounting for the effect structural
members have on LTTR, DOE also notes that no known test procedures are
available that address edge sealing at this time but that this factor
could be considered in a future rulemaking.
DOE also considered the merits of the submissions in support of
American Panel's contention that impermeably faced foams do not undergo
significant aging. After evaluating this information, however, DOE
continues to believe that the inclusion of LTTR testing in the test
procedure is necessary to accurately measure the R-value of foam. DOE
notes that the samples in the Carpenter study cited by American Panel
were taken from the center of the panel. As DOE noted in the SNOPR,
another study (the Ottens study, ``Industrial Experiences with
CO2 Blown Polyurethane Foams in the Manufacture of Metal
Faced Sandwich Panels'') found that core samples do not represent the
overall aging of foam in panels because most aging occurs at the
panel's perimeter. 75 FR 55068, 55077 (Sept. 9, 2010) (citing Ottens et
al., ``Industrial Experiences with CO2 Blown Polyurethane
Foams in the Manufacture of Metal Faced Sandwich Panels,'' Polyurethane
World, 1997.) As a result, the data from this study indicate that the
Carpenter study's results do not necessarily provide an accurate
portrayal of the likely effects of panel aging.
Additionally, while American Panel asserted that the lack of
customer complaints about R-value loss in panels indicates that the
deterioration of LTTR values is insignificant, the lack of customer
complaints may be influenced by a variety of factors. For example, a
panel is normally only replaced when visibly damaged. However, a panel
may have reduced thermal performance without any accompanying visual
cues suggesting problems with the panel. Accordingly, DOE does not
believe that the statements and materials cited by American Panel
support the premise that LTTR of foam is negligible for walk-in panels.
Interested parties also made comments on the specific test methods
that DOE proposed. DOE received some comments from interested parties
in favor of using ASTM C1303-10 to determine the LTTR of foam
insulation. Owens Corning agreed that DOE should use the most current
version of whichever ASTM standards it planned to use. (Owens Corning,
No. 0058.1 at p. 1) Craig Industries agreed with the use of ATSM C1303-
10, but stated that DOE should evaluate if ASTM C1303-10 is appropriate
for all present and future foam insulation products. (Craig, No. 0068.1
at p. 4) NRDC supported testing insulated products to determine whether
the R-value degraded over time, and stated that the proposed ASTM
standard is acceptable and known in the industry. (NRDC, No. 0064.1 at
p. 4) NEEA stated that although some interested parties have concerns
about LTTR values derived from ASTM C1303-10, NEEA believed that
carefully specifying the physical characteristics of the tested panel
samples will address their concerns. (NEEA, No. 0061.1 at p. 2)
Some interested parties disapproved of ASTM C1303-10. American
Panel, Hill Phoenix, Thermo-Kool, and the Joint Manufacturers opposed
using ASTM C1303-10 as the test procedure to measure LTTR. (American
Panel, No. 0057.1 at p. 2; Hill Phoenix, No. 0063.1 at p. 2; Thermo-
Kool, 0072.1 at p. 1; the Joint Manufacturers, No. 0062.1 at p. 1)
American Panel asserted that any testing to determine R-value must
allow the foamed-in-place polyurethane to remain encapsulated by the
metal facers to resemble the real-world application. (American Panel,
No. 0057.1 at p. 2) Hill Phoenix and Thermo-Kool did not recommend the
use of ASTM C1303-10 because, as noted in section 1.3 of ASTM C1303-10,
the standard does not apply to impermeably faced foams; therefore,
applying the results from ASTM C1303-10 to impermeably faced foams
would be misleading. Hill Phoenix also suggested that ASTM C1303-10
would significantly overestimate foam aging of foamed-in-place
polyurethane panels. (Hill Phoenix, No. 0063.1 at p. 2) The Joint
Manufacturers opposed the use of ASTM C1303-10 for measuring long-term
R-value decline because it is not intended for use with faced panels
and unfairly penalizes foamed-in-place polyurethane that has minimal or
zero exposure of permeable surfaces (the Joint Manufacturers, No.
0062.1 at p. 1)
[[Page 21590]]
Owens Corning stated that the prescriptive and research methods of ASTM
C1303-10 are not comparable and will not generate comparable results.
It added that the Canadian test procedure CAN/ULC S770, which is based
on various versions of ASTM C1303, has a positive bias and may over-
predict foam aging, and submitted foam aging data and an article about
the CAN/ULC S770 test to support this comment. (Owens Corning, No.
0058.1 at p. 2; Owens Corning, No. 0058.1 at p. 1; Owens Corning, No.
0058.5 at p. 19; Owens Corning, No. 0058.2 at p. 2)
Carpenter and Master-Bilt also opposed the use of ASTM C1303-10 for
LTTR testing and suggested possible alternatives. Carpenter suggested
testing initial and aged K-factors per ASTM C518 at 20 [deg]F and 55
[deg]F for freezers and coolers, respectively. (Carpenter, No. 0067.1
at p. 3) Carpenter stated that ASTM C1303-10 would underestimate the
LTTR of impermeably faced panels and that LTTR tests should be
performed on samples with intact facers. (Carpenter, No. 0067.1 at p.
2) Similarly, Master-Bilt explained that panel edges are not 100
percent exposed, but are tight against one another and sealed with
caulk and vinyl gaskets. Collectively, the caulk and gaskets
significantly reduce gas migration, thus reducing the effects of aging.
Therefore, in its view, the testing of skinned panels with exposed
edges still considerably overstates the insulation degradation. Master-
Bilt suggested that a formula based on test data from actual walk-in
panels that have been installed could be used instead of ASTM C1303-10.
(Master-Bilt, No. 0068.1 at p. 2)
DOE agrees with the assessment that ASTM C1303-10 is not adequate
for testing impermeably faced foams. DOE believes that the concerns
about ASTM C1303-10 expressed by American Panel, Hill Phoenix, Thermo-
Kool, Master-Bilt, the Joint Manufacturers, Carpenter, and Owens
Corning are addressed by DIN EN 13165:2009-02 and DIN EN 13164:2009-02,
which account for impermeably faced foams, reduce the testing burden,
and are appropriate for different types of foam. DIN EN 13165:2009-02
and DIN EN 13164:2009-02 partially rely on a formula based on test
data, as suggested by Master-Bilt. DOE agrees with Owens Corning that
the prescriptive and research methods of ASTM C1303-10 are not
comparable, and notes that DIN EN 13165:2009-02 and DIN EN 13164:2009-
02 do not have this problem.
One interested party expressed concerns about two of the studies
DOE referenced in the September 2010 SNOPR. One study was the Ottens
study, in which an experiment was completed on polyurethane foamed-in-
place panels to assess their long-term insulating behavior. 75 FR
55068, 55077 (Sept. 9, 2010). (Ottens et al., ``Industrial Experiences
with CO2 Blown Polyurethane Foams in the Manufacture of
Metal Faced Sandwich Panels,'' Polyurethane World, 1997.) In the SNOPR,
DOE estimated that the test was likely representative of panels aged
for at least 5 years. 75 FR at 55077 (Sept. 9, 2010). ORNL challenged
this estimate and stated that the results from the Ottens study cannot
be correlated to a particular aging period. (ORNL, No. 0060.1 at p. 2)
The second study DOE referenced was a round robin test using CAN/
ULC-S770-03, a standard with the same test methodology as a previous
version of ASTM C1303. DOE referenced the test to address concerns
raised by various interested parties that the thin slicing method, CAN/
ULC-S770-03. Results from the round-robin study predicted that
polyurethane would perform at a lower level than extruded polystyrene
or even at a level as low as expanded polystyrene. 75 FR 55079 (Sept.
9, 2010). ORNL stated the testing used in the referenced study relied
on the original version of S770, which has been shown to over-predict
thermal resistance. ORNL added that the test was performed on foams
created with blowing agents that are no longer used, and the results
are not representative of current products. (ORNL, 0060.1 at p. 2)
Regarding ORNL's comment about the Ottens study, DOE agrees that
the method in the study cannot be accurately correlated to a particular
aging period. However, in DOE's view, the conclusions reached in those
studies illustrate that impermeably faced foams are subject to aging.
DOE agrees with ORNL's evaluation of the flaws in the round robin test
data but notes that the same test was used on each type of foam
evaluated, which permits a comparison of the results from each type of
tested foam. DOE used the results of the round robin test to
demonstrate that there were no performance differences between
polyurethane and polystyrene foams--not to predict the level of thermal
resistance over time.
Interested parties also commented on the specific testing
conditions for ASTM C1303-10. ORNL proposed that, if adopted, ASTM
C1303-10 should be modified to allow the user to take multiple 12 inch
x 12 inch specimens from the 48 inch x 96 inch panel, at least 12
inches away from the edge of the 48 inch x 96 inch source. (ORNL, No.
0060.1 at p. 2) ORNL suggested specifying the aging conditioning
temperatures for foam insulation. ORNL explained that while most
insulation foams must follow aging condition requirements, the
conditions used to age bun stock foam, which is used in producing foam
insulation, may be freely modified. This situation could lead to skewed
comparisons between products. (ORNL, No. 0060.1 at p. 2)
Manufacturers also offered views regarding these proposed testing
conditions. Craig Industries, Carpenter, and Owens Corning stated that
the procedures detailed in ASTM C1303-10 should be conducted at the
specified EPCA mean temperatures 55 [deg]F and 20 [deg]F for a cooler
and freezer, respectively. (Craig Industries, 0068.1 at p. 4;
Carpenter, No. 0067.1 at p. 3; Owens Corning, No. 0058.1 at p. 2)
Carpenter also suggested modifying DOE's proposal by adding a provision
for molding test panels using unprimed aluminum facers. (Carpenter, No.
0067.1 at p. 3) NRDC asserted that the proposed temperatures for
testing insulation needed to be substantiated. (NRDC, 0064.1 at p. 4)
Craig Industries asserted that the modifications to ASTM C1303-10
proposed by DOE in the September 2010 SNOPR test were acceptable, but
wanted DOE to ensure that the changes would also apply to expanded
polystyrene insulation. (Craig Industries, No. 0068.1 at p. 4) Bally
suggested that the initial panel size should be changed to 48 inches
3 inches and 96 inches 2 inches so that a
standard panel configuration could be used for the test panel. Bally
stated that manufacturers could incur significant costs from
manufacturing test panels. (Bally, No. 0078.1 at p. 2)
While DOE appreciates ORNL's and Bally's suggested improvements to
ASTM C1303-10, these recommendations are no longer relevant since DOE
has decided to adopt DIN EN 13165:2009-02 and DIN EN 13164:2009-02,
which collectively address some of the shortcomings of ASTM C1303-10.
For example, DIN EN 13165:2009-02 and DIN EN 13164:2009-02 provide for
inclusion of metal facers, while ASTM C1303-10 does not. In regard to
Bally's concern about the size of the test panel, a test panel is no
longer required to be a certain size as long as the panel is large
enough for the test sample to be cut from its geometric center, as
prescribed in Appendix A. Additionally, given the comments from Craig
Industries, Carpenter, Owens Corning, and NRDC about the temperature
conditions for testing, DOE has decided to adopt the EPCA mean
temperatures of 55 [deg]F and
[[Page 21591]]
20 [deg]F for a cooler and freezer, respectively for the DIN EN
13165:2009-09 and DIN EN 13164:2009-02 testing conditions. This means
that when a manufacturer tests a panel for LTTR, the manufacturer will
determine the initial and aged R-value as specified by DIN EN
13165:2009-09 and DIN EN 13164:2009-02 except the panel will be rated
at 55 [deg]F and 20 [deg]F for a cooler and freezer, respectively. By
deviating from the temperature condition specified in DIN EN
13165:2009-09 and DIN EN 13164:2009-02, the fixed increment values and
safety increment values will be slightly more conservative than the
values that would be expected if the LTTR test were performed at the
temperature condition specified in DIN EN 13165:2009-09 and DIN EN
13164:2009-02, when applied to freezer panels.
In response to Craig Industries' comment that whatever method is
adopted should be applicable to expanded polystyrene foam, DOE notes
that the foam aging procedures it proposed are only applicable to foams
that rely on low conductivity blowing agents that are intended to stay
within the foam for the life of the product. Because it is DOE's
understanding that expanded polystyrene foam is not blown with low
conductivity blowing agents that are intended to remain in the product
for its usable life and does not exhibit long term changes in thermal
resistance, these tests would not apply, nor would they be needed to
assess the long term thermal resistance of this type of foam.
One commenter did not agree with the proposed use of any of the
protocols. Thermo-Kool disagreed with both ASTM C1303-10 and DIN EN
13165:2009-02 and DIN EN 13164:2009-02 because none of these protocols,
in its view, is designated for testing composite panels faced with
metal skins. (Thermo-Kool, 0072.1 at p. 1) DOE agrees with Thermo-Kool
that ASTM C1303-10 was not designed to test panels with metal facers.
However, DIN EN 13165:2009-02 and DIN EN 13164:2009-02 were designed to
account for metal facers on foam. DIN EN 13165:2009-02 and DIN EN
13164:2009-02 allow all metal skins or facers to remain on the foam
during aging and testing. See, e.g., DIN EN 13165:2009-02, Annex C
(instructing in relevant part to ``select a product sample including
any product facing.'').
DOE notes that many of the interested parties that opposed using
ASTM C1303-10 to measure LTTR supported using DIN EN 13165:2009-02 and
DIN EN 13164:2009-02 instead. Carpenter agreed with using DIN EN
13165:2009-02 and DIN EN 13164:2009-02 as an alternative to ASTM C1303-
10. (Carpenter, No. 0067.1 at p. 2) Hill Phoenix and AHRI requested
more time to review the European test procedure, but Hill Phoenix's
initial assessment was that DIN EN 13165:2009-02 was a better option
than ASTM C1303-10. (Hill Phoenix, No. 0063.1 at p. 2; AHRI, No. 0070.1
at p. 2) Hill Phoenix added that DOE should adopt test procedures that
are appropriate for the insulation materials that could be found in
walk-in panels, which DOE interprets to mean that Hill Phoenix is
suggesting that DOE adopt both DIN EN 13165:2009-02 and DIN EN
13164:2009-02 if DOE uses these standards instead of ASTM C1303-10.
(Hill Phoenix, No. 0063.1 at p. 2) Master-Bilt also stated DIN EN
13165:2009-02 and DIN EN 13164:2009-02 seemed to better account for
long-term degradation of foam performance, though they acknowledged
they did not fully understand DIN EN 13165:2009-02 and DIN EN
13164:2009-02. (Master-Bilt, No. 0069.1 at p. 2)
Other stakeholders had reservations about DIN EN 13165:2009-02 and
DIN EN 13164:2009-02. Craig Industries stated that the alternatives to
ASTM C1303-10 may ignore the fact that different plastic foam product
insulations in the marketplace respond differently to heat. (Craig
Industries, No. 0068.1 at p. 4) It added that DOE should prevent
foamed-in-place walk-in manufacturers from picking the most efficient
part of the panel for testing. (Craig, No. 0068.1 at p. 4) Owens
Corning noted that DIN EN 13165:2009-02 and DIN EN 13164:2009-02
appeared to be material standards and not test methods, and Owens
Corning asked for clarification on what the test method would be.
(Owens Corning, 0058.1 at p. 1) NRDC suggested that DOE review the
proposed standards, ASTM C1303-10, DIN EN 13165:2009-02, and DIN EN
13164:2009-02, to determine which standard yields better results, and
what the related testing burden would be to adopt a foreign standard.
(NRDC, No. 0064.1 at p. 4)
DOE notes Carpenter's, Hill Phoenix's, AHRI's, and Master-Bilt's
approval of DIN EN 13165:2009-02 and DIN EN 13164:2009-02, and in light
of the criticisms that DOE has received about ASTM C1303-10 and the
support for DIN EN 13165:2009-02 and DIN EN 13164:2009-02, DOE has
decided to adopt DIN EN 13165:2009-02 and DIN EN 13164:2009-02 as the
test procedure for determining LTTR of polyurethane products and
extruded polystyrene products, respectively (polyisocyanurate products
are covered by the test for polyurethane products). Today's final rule
provides that the LTTR value determined by Annex C of DIN EN
13165:2009-02 or DIN EN 13164:2009-02 shall be used to determine a
degradation factor. The degradation factor will be the LTTR R-value
divided by the original R-value of the foam. The original R-value of
the foam will be tested with ASTM C518-04, as specified by the EISA
2007 amendments to EPCA, and can be used for compliance with the
relevant R-value requirement established by those amendments. (42
U.S.C. 6313(f)(1)(C)) The degradation factor is applied to the U-factor
of the panel found by ASTM C1365-05; see section 4.2 and 4.3 in
Appendix A.
In response to Owens Corning's comment that DIN EN 13165:2009-02
and DIN EN 13164:2009-02 appeared to be material standards and not test
methods, DOE notes that Annex C of both DIN EN 13165:2009-02 and DIN EN
13164:2009-02 provide the methodology for testing. DOE also notes Craig
Industries' concern about using heat to test for LTTR and NRDC's
recommendation that DOE compare the different standards that were
proposed; however, DOE believes DIN EN 13165:2009-02 and DIN EN
13164:2009-02 are more accurate and appropriate for assessing the long-
term performance of impermeably faced foams used in walk-in coolers and
freezers because they permit panels to be tested with their facers, and
accounts for impermeably faced foam. Also, to address Craig Industries'
concern about manufacturers not all choosing the same part of the
panel, DOE is requiring that this test sample should be taken from the
geometric center of the test specimen.
DOE is largely incorporating DIN EN 13165:2009-02 and DIN EN
13164:2009-02 except for the requirement that the thermal resistance
measurement is conducted at a mean temperature of 10 [deg]C. DOE has
decided to adopt the EPCA mean temperatures of 55 [deg]F and 20 [deg]F
for a cooler and freezer, respectively for the DIN EN 13165:2009-09 and
DIN EN 13164:2009-02 testing conditions. However, the manufacturer will
still have to follow any applicable aging conditions prescribed by DIN
EN 13165:2009-09 and DIN EN 13164:2009-02. By deviating from the
temperature condition specified in DIN EN 13165:2009-09 and DIN EN
13164:2009-02, the fixed increment values and safety increment values
will be slightly more conservative than the values that would be
expected if the
[[Page 21592]]
LTTR test were performed at the temperature condition specified in DIN
EN 13165:2009-09 and DIN EN 13164:2009-02, when applied to freezer
panels.
c. Moisture Absorption
In the January 2010 NOPR, DOE discussed the possibility of testing
the impact of moisture absorption on the R-value of different
insulation materials, evaluated various tests developed by ASTM, and
reviewed a research paper completed by the U.S. Army Corps of
Engineers' Cold Regions Research and Engineering Laboratory (CRREL),
which Owens Corning submitted to the docket. (Owens Corning, No. 0054.3
at p. 1) DOE initially concluded that testing the effect of moisture
absorption on the R-value of insulation foam would be complex, costly,
and time-consuming, and that there was no well-accepted testing method.
As a result, DOE proposed that the impact of water absorption on R-
value not be included in the test procedure. 75 FR 186, 194 (Jan. 4,
2010).
DOE received many comments from interested parties that supported
the inclusion of some means to account for the effect of water
infiltration. At the NOPR public meeting, and in several written
comments, Craig Industries urged DOE to test for and include the impact
of moisture absorption in foam. (Craig Industries, Public Meeting
Transcript, No. 0016 at p. 248; Craig Industries, No. 0035.1 at p. 3;
Craig Industries, No. 0068.1 at p. 5; Craig Industries, No. 0057.13 at
p. 5) ACEEE also stated that it was imperative to include the effect of
moisture absorption. (ACEE, No. 0052.1 at p. 2) Kysor maintained that
moisture did not affect the R-value of poured-in-place polyurethane,
but laminated panels would be severely affected by water because of the
water-based glue used to bond the insulation to the metal skins.
(Kysor, No. 0053.1 at p. 3)
Some interested parties suggested possible tests and studies that
could be used to measure the effect of water absorption. For example,
Craig Industries and Owens Corning referred to the CRREL study for
information about the performance of various materials with water.
(Craig Industries, No. 0054.1 at p. 2; Owens Corning, Public Meeting
Transcript, No. 0016 at p. 250) Nor-Lake suggested that an adequate
test for water absorption would be ASTM D2842-06, ``Standard Test
Method for Water Absorption of Rigid Cellular Plastics.'' (Nor-Lake,
No. 0047.1 at p. 3) Owens Corning suggested that ASTM E96, ``Standard
Test Methods for Water Vapor Transmission of Materials,'' could be used
to test water vapor permeability rates and determine the effect of
moisture absorption on foam. (Owens Corning, Public Meeting Transcript,
No. 0016 at p. 253; Owens Corning, No. 0048.1 at p. 1; Owens Corning,
No. 0032.1 at p. 3) Owens Corning also suggested that ASTM E96 could be
used to identify suitable materials for walk-in cooler and walk-in
freezer applications. (Owens Corning, No. 0048.1 at p. 1 and No. 0032.1
at p. 3)
Additionally, joint comments filed by SCE, SMUD, SDG&E, and SCG on
the January 2010 NOPR, hereafter referred to as the Joint Comment,
added that although ASTM E96 produces a conservatively low estimate of
moisture permeance at high vapor pressures, DOE should evaluate whether
using ASTM E96 is better than not accounting for the effect of moisture
on insulating foam. (Joint Comment, No. 0037.1 at p. 11) The Joint
Comment added that there may be difficulties in testing and
characterizing R-value deterioration in foams due to moisture
absorption, but DOE should still consider a requirement for testing
vapor permeability. (Joint Comment, No. 0037.1 at p. 1) Owens Corning
also stated that, since DOE raised the proposed relative humidity
assumption for the test condition from 45 percent to 75 percent in the
September 2010 SNOPR, DOE implicitly acknowledged the high humidity
conditions present in walk-in cooler and freezer environments, which,
in its view, supported the consideration of the impact of moisture on
the thermal performance of a walk-in over its lifetime. (Owens Corning,
No. 0058.1 at p. 2) ACEEE suggested that because a major threat to
moisture control for panels is the integrity of the exterior skin, a
minimally intrusive method to determine the impact of moisture
absorption would be to assess the vapor diffusion integrity of the
sealed panel. (ACEEE, No. 0052.1 at p. 2)
Other interested parties did not support including water absorption
in the test procedure. ThermalRite stated that moisture infiltration
was unlikely to occur in properly constructed panels, water
infiltration would most likely be the result of improper materials or
manufacturing, and that moisture infiltration should be considered
inconsequential and removed from proposed test procedures.
(ThermalRite, No. 0045.1 at p.1; ThermalRite, No. 0045.1 at p. 2;
ThermalRite, No. 0049.1 at p.2) ICS commented that water infiltration
is related to panel installation and that there were no data to support
that moisture infiltration is caused by the walk-in's manufacture or
design. (ICS, Public Meeting Transcript, No. 0016 at p. 253; ICS, No.
0045.1 at p. 1) ICS went on to state that, under actual and average
usage conditions, water absorption in foam is negligible and it
recommended that the impact of moisture absorption should be removed
from the proposed test procedure. (ICS, No. 0045.1 at p. 1; ICS, No.
0045.1 at p. 2) Hill Phoenix commented that moisture absorption was not
an issue and any moisture issues were generally reported by the walk-in
cooler or walk-in freezer user and were quickly repaired. (Hill
Phoenix, No. 0041.1 at p. 2) Carpenter agreed with DOE that the impact
of water absorption of foam would be difficult to study and quantify,
and added that polyurethane foam has an inherently low permeability,
which would minimize water absorption. (Carpenter, No. 0043.1 at p. 2)
TAFCO concurred that moisture infiltration into polyurethane foam is
not an issue, and that it would not cause the R-value to degrade
significantly over time. (TAFCO, No. 0040.1 at p. 2) TAFCO also stated
that they have installed panels in high-humidity environments and they
did not encounter any cases of water absorption by panels. It urged
that DOE not pursue this issue further. (TAFCO, No. 0040.1 at p. 2)
DOE understands that interested parties have concerns regarding the
potential impact of moisture absorption on the thermal performance of
insulating material over the lifetime of a walk-in cooler or freezer.
Prior to the publication of the January 2010 NOPR, DOE reviewed several
methods for testing vapor permeance and water absorption in foam
insulation materials. However, this review of various test methods
showed that there were disparities among the different methods, and
that there was no general agreement upon a single approach. 75 FR 186,
194 (Jan. 4, 2010). Moreover, while these tests are designed to measure
the performance of insulating foam by itself, they would not account
for the many unique construction methods and combinations of materials
employed by manufacturers of panels to minimize moisture infiltration.
At this time, test procedures for measuring the impact of water on
foam R-value are not yet recognized by a national organization such as
ASTM. DOE notes that because of the absence of any nationally
recognized testing standards, it would need to develop such a protocol.
To this end, one of DOE's national labs is in the process of developing
procedures to evaluate the impact of moisture on insulation R-values.
Accordingly, because of the potential ambiguities that are currently
[[Page 21593]]
present with respect to the means by which to assess the impact of
moisture absorption on the thermal performance of insulating material
over time, DOE is not incorporating a method to account for moisture
absorption at this time. DOE may, however, consider adopting such a
procedure in the future.
d. Display Panels
In the September 2010 SNOPR, DOE proposed that glass walls
(``display panels'') would be tested using NFRC 100-2001-E0A to measure
their thermal transmittance, or U-factor. 75 FR 55068, 55098 (Sept. 9,
2010). Display panels are typically found on beer caves and share many
characteristics with display doors. Notably, they are readily tested or
simulated using the procedure in NFRC 100-2001-E0A. DOE received no
comments regarding its proposed approach for display panels.
Consequently, DOE is including this test procedure (to be codified in
section 4.1 of Appendix A) to measure the thermal transmittance of
display panels or walls. Additionally, to improve clarity, DOE is
defining ``display panels'' as a panel that is entirely or partially
comprised of glass, a transparent material, or both and is used for
display purposes.
e. Open Areas of Walk-Ins
The test procedure DOE is establishing today contains tests for
components of walk-ins that separate the interior refrigerated
environment of the walk-in from the exterior. Zero Zone stated that the
test procedure should include a method to determine the energy use for
walk-ins that have open areas to display food. (Zero Zone, No. 0077.1
at p. 1) Because an open area does not, by definition, separate the
interior refrigerated environment of the walk-in from the exterior, an
open area is not a component of the walk-in that is covered under this
test procedure. Accordingly, DOE is not adopting Zero Zone's
suggestion.
3. Energy Use of Doors
a. U-Factor of Doors
In the September 2010 SNOPR, DOE proposed to rate the total thermal
transmittance (i.e. U-factor) of doors, including their framing
materials or complete door plug, using the test procedure NFRC 100-
2010[E0A1], ``Procedure for Determining Fenestration Product U-
factors.'' 75 FR 55068, 55083 (Sept. 9, 2010). DOE specified internal
and external rating conditions for the test procedure to closely match
conditions that would be experienced by the door when it is part of a
walk-in.
NEEA strongly supported DOE's use of NFRC 100-2010[E0A1] procedures
for testing the performance of walk-in cooler and freezer doors. (NEEA,
No. 0061.1 at p. 2) NRDC agreed with DOE's use of NFRC 100-2010[E0A1]
for rating doors with the proposed changes to the temperatures used for
the testing procedure. (NRDC, No. 0064.1 at p. 6)
DOE notes NEEA's and NRDC's support and has incorporated the use of
NFRC 100-2001-E0A1 in this final rule. DOE also notes that none of the
interested parties submitted comments that disagreed with using NFRC
100-2001-E0A1. The thermal transmittance result from NFRC 100-2001-E0A1
is then used to calculate the corresponding energy consumption of a
refrigeration system whose efficiency is given in sections 4.4 and 4.5
of Appendix A for display and non-display doors, respectively. This
energy metric is combined with the electricity consumption from
electrical door components to calculate the door's total energy
consumption.
b. Electrical Components of Doors
As described in section III.A.1, the test metric for doors includes
the energy consumed by electrical components associated with a walk-in
door. The electricity consumed by the door will be the sum of the rated
power associated with each electricity consuming device multiplied by
the assumed time the device will be operational. Percent time off (PTO)
assumptions are given in sections 4.4.2 and 4.5.2 of Appendix A for
display and non-display doors, respectively. PTO assumptions are
specified for some electrical components, such as anti-sweat heater
wire. For any electricity consuming devices for which a PTO is not
specified in Appendix A, today's final rule provides that if a
manufacturer can demonstrate that the device is controlled by a
preinstalled timer, control system or other auto-shut-off system, the
PTO is assumed to be 25 percent. For example, if a door has a
thermometer mounted on it that consumes electricity, but the
thermometer has a built in timer so that it shuts off at certain times,
then the manufacturer of the door can use the PTO value of 25 percent
when calculating the energy consumption of the thermometer.
The test procedure also provides a means for measuring the heat
generation of door electrical components that are located on the inside
surface of the door. This heat is added to the heat transmitted through
the door and the corresponding refrigeration energy use is calculated
using the method described in section III.B.3.c. The refrigeration
energy use is added to the electrical energy use to calculate the total
energy consumption of the door.
DOE received a comment challenging its assumptions about heat from
electrical devices. Zero Zone disagreed with the assumption that all
anti-condensate heat contributes to the walk-in heat load, and instead
suggested that 50 to 75 percent of the anti-condensate heat going into
the display case would be a more appropriate assumption. (Zero Zone,
No. 0077.1 at p. 2) After further analysis, DOE agrees with Zero Zone's
observation that not all anti-condensate heat necessarily contributes
to the walk-in heat load because the anti-condensate heat is applied to
the transparent surface of the display case. Because one side of the
transparent surface is in contact with the surrounding external
environment, a portion of the heat is transmitted from the display case
to the surrounding environment. Therefore, DOE has revised the
equations in sections 4.4.2and 4.5.2of Appendix A to capture only 75
percent of the power from anti-sweat heaters as an additional
compressor load.
c. Energy Efficiency Ratio
In the January 2010 NOPR, DOE proposed to require that
manufacturers measure the energy use of walk-in cooler and walk-in
freezer envelopes in kWh/day. However, most metrics used to describe
heat transfer losses are in units of British thermal units (Btu) per
unit time. In order to convert the thermal energy transmission
calculation (Btu/hr) into a measure of electrical energy consumed by
the refrigeration equipment, DOE proposed to use an energy efficiency
ratio based on a nominal efficiency of an assumed refrigeration system.
The EER values proposed for coolers and freezers were 12.4 Btu/W-h and
6.3 Btu/W-h respectively. The values were selected to provide a means
of comparison and were not intended to represent the actual efficiency
of the refrigeration system with which the envelope would ultimately be
paired. 75 FR 186, 197 (Jan. 4, 2010). Although the test procedure no
longer requires one to calculate the overall envelope energy, the
concept is still relevant for calculating door energy.
DOE received comments in response to the January 2010 NOPR
regarding the use of an EER value, the assumptions used to calculate
the EER value, and the proposed EER values for coolers and freezers.
BASF commented that the proposed EER assumptions were reasonable.
(BASF, No. 0021.1 at p. 4) Nor-Lake agreed with DOE's use of a
[[Page 21594]]
nominal EER value to convert the thermal energy transmission to
electrical energy consumption. (Nor-Lake, No. 0047.1 at p. 5) Master-
Bilt also agreed with the proposed use of a nominal EER but stated that
the proposed EER values are not achievable. (Master-Bilt, No. 0027.1 at
p. 2) Kason requested that the nominal EER values be reassessed to
represent real world values. (Kason, No. 0055.1 at p. 4) Nor-Lake
commented that the EER values on their refrigeration models did not
match DOE's proposed nominal values. (Nor-Lake, 0023.1 at p. 4)
DOE considered these comments and, in conjunction with the
supportive comments from Master-Bilt, Nor-Lake, and BASF, continues to
use an EER value to relate the thermal energy transmission to the
electrical energy consumed for doors. Despite the comments from Kason,
Master-Bilt, and Nor-Lake, DOE finds 12.4 Btu/W-h and 6.3 Btu/W-h to be
appropriate conversions for walk-in coolers and walk-in freezers,
respectively, because these EER values correspond to nominal EER values
contained in the refrigeration test procedure for unit coolers
connected to multiplex condensing systems (AHRI 1250 (I-P)-2009). DOE
is aware that the nominal values for this configuration may not
represent all walk-ins, but notes that these EER values are intended to
provide a means of comparison and not directly reflect a real walk-in
installation. In particular, these EER assumptions are not intended to
represent the expected efficiency of any particular refrigeration
system produced by a manufacturer and are provided as a method to
converting thermal energy to electrical energy consumed by a
refrigeration system.
4. Heat Transfer via Air Infiltration
In the January 2010 NOPR, DOE stated that, compared with other
energy consumption factors such as conduction losses through
insulation, air infiltration may be the largest contributing factor to
envelope thermal load. That notice identified two infiltration
pathways: steady state leakage and air losses due to door-opening
events. To address this issue, DOE proposed to include test procedures
to measure the steady state infiltration and infiltration from door
opening events and subsequently modified these test procedures in
response to comments to the September 2010 SNOPR. See 75 FR 196-197
(Jan. 4, 2010) and 75 FR 55084-55086 (Sept. 9, 2010). Interested
parties submitted comments pertaining to the topic of envelope
infiltration, including steady state infiltration, door opening
infiltration, calculations, and empirical methodologies for quantifying
the effects of infiltration.
a. Steady State Infiltration
In the January 2010 NOPR, DOE proposed that steady state
infiltration of fully assembled envelopes must be tested using the
method described in ASTM E741-06, ``Standard Test Method for
Determining Air Change in a Single Zone by Means of a Tracer Gas
Dilution.'' 75 FR 196 (Jan. 4, 2010).
Some interested parties stated that steady state infiltration
should not be included in the test procedure. Hill Phoenix maintained
that an insufficient amount of infiltration would occur in a properly
installed walk-in, essentially suggesting that DOE abandon the
inclusion of infiltration in the test. (Hill Phoenix, No. 0063.1 at p.
2) AHRI concurred, stating that a steady-state infiltration test is not
necessary due to the insignificant amount of infiltration present in a
walk-in * * * (AHRI, No. 0070.1 at p. 3) Master-Bilt agreed, suggesting
that testing steady-state infiltration is unnecessary because this
infiltration is insignificant compared with infiltration from door
openings. (Master-Bilt, No. 0069.1 at p. 2) NRDC suggested that DOE
confirm the assumption that the impact of infiltration and exfiltration
through the envelope is minimal compared to the infiltration through
the doors, and suggested that DOE should weigh each impact. (NRDC, No.
0064.1 at p. 6)
Other interested parties commented on the specific test methods DOE
proposed in the January 2010 NOPR for measuring steady-state
infiltration of walk-in envelopes. TAFCO stated that ASTM E741-06,
Standard Test Method for Determining Air Change in a Single Zone by
Means of a Tracer Gas Dilution, is an acceptable method for determining
steady state air infiltration. (TAFCO, No. 0040.1 at p. 3) ACEEE also
agreed with using ASTM E741-06. (ACEEE, 0052.1 at p. 3) NEEA commented
that either ASTM E741-06 or a standard blower test is a reasonable
method of calculating steady state infiltration, but noted that the
blower test would be faster and less costly to administer. Therefore,
NEEA recommended that DOE test ASTM E741-06 and the standard blower
door test before prescribing which methodology must be used. (NEEA, No.
0061.1 at p. 2) Kysor, on the other hand, stated that it is neither
necessary nor cost effective to assemble an entire walk-in to test for
air infiltration. Kysor stated that each component should be tested
separately and recommended that DOE use ASTM E1424-08, Standard Test
Method for Determining the Rate of Air Leakage Through Exterior
Windows, Curtain Walls, and Doors Under Specified Pressure and
Temperature Differences Across the Specimen, and ASTM E2357-05,
Standard Test Method for Determining Air Leakage of Air Barrier
Assemblies, because either can test any assembly that will become part
of a walk-in. (Kysor, No. 0053.1 at p. 3)
In the January 2010 NOPR, DOE proposed that ASTM E741-06 should be
used to measure infiltration; however, in the September SNOPR, DOE
determined that ASTM E741-06 could present an undue burden for
manufacturers with respect to the many door combinations that are
possible. Therefore, DOE proposed in its September 2010 SNOPR to also
consider measuring steady state infiltration through doors using NFRC
400-2010-E0A1, ``Procedure for Determining Fenestration Product Air
Leakage.'' 75 FR 55068, 55084 (Sept. 9, 2010).
Interested parties commented on NFRC 400-2010-E0A1 and suggested
alternatives. NRDC agreed with using NFRC 400-2010-E0A1 to determine
infiltration of individual envelope components, but also recommended
using a pressurization test to determine infiltration of fully
assembled envelopes, based on ASTM D6670, ``Standard Practice for Full-
Scale Chamber Determination of Volatile Organic Emissions from Indoor
Materials/Products.'' (NRDC, No. 2.3.008 at p. 6) AHRI recommended that
infiltration could be estimated for a family of doors by using a
scaling methodology based on a limited number of tests. AHRI cautioned
DOE against requiring the manufacturer to test every single door
because it would be burdensome. (AHRI, No. 2.3.015 at p.3) Some
interested parties commented on the prescribed testing conditions to be
implemented with NFRC 400-2010-E0A1. American Panel stated that the
proposed steady state infiltration test unit is not representative of
the average walk-in size and suggested a more representative size of 8
feet by 12 feet by 8 feet high. (American Panel, No. 2.3.001 at p. 3)
American Panel, NEEA, and Bally concurred with DOE's assumption of 75
percent relative humidity, which DOE proposed as a condition of
testing. (American Panel, No. 2.3.001 at p. 3; NEEA, No. 2.3.005 at p.
5; Bally, No. 0078.1 at p.2)
DOE notes the specific comments and suggestions from TAFCO, NEEA,
ACEEE, Kysor, NRDC, AHRI, and American Panel, but has decided not to
include steady state infiltration in the WICF test procedure at this
time. In response to NRDC's suggestion that DOE
[[Page 21595]]
weigh the impact of steady-state infiltration against other sources of
infiltration, DOE believes that the contribution of steady state
infiltration towards the aggregate energy consumption of a well-
constructed factory-built walk-in unit is most likely negligible
compared to other energy consumption pathways for current WICF designs.
Higher steady-state infiltration across the envelope for site-assembled
walk-in coolers and freezers appears to be generally caused by poor
installation and construction practices. As such, DOE is not
incorporating an overall infiltration measurement, which is a factor
that relies heavily on on-site assembly practices rather than the
performance of individual components. Given that today's final rule
includes a means to assess the performance of specific individual
components, the performance of these components will be captured under
the new procedure and should be sufficiently adequate prior to their
installation as part of a completed walk-in unit. Should this prove not
to be the case, DOE may re-examine the procedure and consider
modifications to address its potential shortcomings.
b. Door Opening Infiltration
In the January 2010 NOPR, DOE proposed to calculate air
infiltration associated with each door-opening event using established
analytical methods based on equations and computational values
published in the ASHRAE Refrigeration Handbook. DOE also made several
assumptions in the test procedure that could have a significant impact
on the predicted air exchange. The assumptions with the most impact
were the number of doorway passages (the number of door-opening cycles
for a given door), door open-close time, and the amount of time the
door is held or propped open. 75 FR 186, 196 (Jan. 4, 2010). In the
September 2010 SNOPR, DOE did not propose to change the basic
methodology, but modified some of the assumptions in order to
differentiate door types. 75 FR 55068, 55085 (Sept. 9, 2010).
Some interested parties supported the proposed method. Hired Hand
agreed with the methodology used for calculating the air infiltration
from door openings. (Hired Hand, Public Meeting Transcript, No. 0016 at
p. 309) Hired Hand emphasized that air infiltration may be the largest
contributing factor to envelope energy losses. (Hired Hand, Public
Meeting Transcript, No. 0016 at p. 28; Hired Hand, Public Meeting
Transcript, No. 0016 at p. 279; Hired Hand, Public Meeting Transcript,
No. 0016 at p. 285) American Panel suggested the use of ASHRAE values
for heat load as the best way to account for the effects of air
infiltration. (American Panel, No. 0042.1 at p. 2) ThermalRite, Nor-
Lake, and Master-Bilt agreed with American Panel's suggestion.
(ThermalRite, No. 0049.1 at p. 2; Nor-Lake, No. 0047.1 at p.4; Master-
Bilt, Public Meeting Transcript, No. 0016 at p. 311) Master-Bilt and
Zero Zone also agreed with DOE's assumptions regarding infiltration
attributed to door openings. (Master-Bilt, No. 0069.1 at p. 2; Zero
Zone, No. 0077.1 at p. 2)
Other interested parties questioned the applicability of the method
to walk-in cooler and freezer doors, or questioned DOE's assumptions in
calculating door opening infiltration. Schott Gemtron contended that
ASHRAE equations may be based on supermarket display cases, implying
that they may not be applicable to some walk-in doors. (Schott Gemtron,
Public Meeting Transcript, No. 0016 at p. 314) Hired Hand was concerned
that the proposed test procedures do not account for the effect of
fast-acting doors on air infiltration. (Hired Hand, Public Meeting
Transcript, No. 0016 at p. 286) SCE and Hired Hand both stated that the
parameters used to calculate air infiltration should clearly show the
benefit of fast-acting doors. (SCE, Public Meeting Transcript, No. 0016
at p. 320; Hired Hand, Public Meeting Transcript, No. 0016 at p. 320)
Hired Hand also recommended that the equations used to calculate air
infiltration should be based on the operational time the doors are
opened over an assumed 24-hour day. (Hired Hand, No. 0051.1 at p. 4)
Zero Zone stated that any air infiltration calculations should include
additional air infiltration if the evaporator is discharging air in the
direction of the display doors. (Zero Zone, No. 0077.1 at p. 1) Bally
stated that hybrid walk-ins, that is, walk-ins sited within another
walk-in, should be given beneficial consideration. Bally explained that
a walk-in freezer sited inside a walk-in cooler would experience less
infiltration because of the smaller temperature differential between
the interior and exterior of the freezer. (Bally, No. 0078.1 at p.2)
Interested parties also made specific comments on the effect of
infiltration reduction devices (IRDs). ACEEE and ThermalRite supported
the infiltration device effectiveness test methodology. (ACEEE, No.
0052.1 at p. 3; ThermalRite, No. 0049.1 at p. 2) TAFCO also stated that
ASTM E741-06 is an acceptable method for determining IRD effectiveness.
(TAFCO, No. 0040.1 at p. 3) NRDC stated that the proposed door opening
infiltration calculation from ASHRAE Fundamentals 2009 is acceptable
for conventional doors, but when doorways are protected by an air
curtain or other infiltration reduction device, calculations should
include the effect of such devices on energy use. (NRDC, No. 0064.1 at
p. 6)
Master-Bilt commented that air infiltration from door openings
cannot be modeled in a meaningful way and should be excluded from the
test methodology. (Master-Bilt, No. 0027.1 at p. 2) Hill Phoenix noted
that the panel manufacturer has no bearing on door opening frequency,
which accounts for the majority of the infiltration. (Hill Phoenix, No.
0063.1 at p. 2) NEEA suggested that DOE should not make assumptions
about the nature of the use of a particular walk-in. (NEEA, No. 0061.1
at p. 5) Instead, it recommended that DOE include a prescriptive
requirement for infiltration reduction devices. (NEEA, No. 0061.1 at p.
5)
DOE has decided not to include any test procedure for door opening
infiltration following its decision to have component-level test
procedures and standards. Door infiltration is primarily reduced by
incorporating a separate infiltration reduction device at the assembly
stage of the complete walk-in. Based on DOE's understanding of the door
manufacturing industry, a typical door manufacturer has very few direct
means for reducing the door infiltration on its own since IRDs are
generally designed and manufactured independently from doors and they
require proper field installation to achieve rated performance.
Consequently, at this time, DOE is not incorporating provisions that
would require measuring the effectiveness of the infiltration reduction
devices and door infiltration, as suggested by Master-Bilt, Hill
Phoenix, and NEEA. Likewise, reduction of door infiltration due to the
location of the walk-in is not captured, as suggested by Bally.
In response to NEEA's comment recommending a prescriptive standard,
DOE notes that EPCA has already established a prescriptive requirement
for infiltration reduction devices, and there may be limited if any
benefit to DOE adding additional prescriptive standards for
infiltration reduction devices. (42 U.S.C. 6313(f)(1)(B)) Nevertheless,
DOE will consider the need for these types of standards within the
context of its ongoing energy standards rulemaking.
5. Electrical Components
In the January 2010 NOPR, DOE proposed to calculate the energy
consumption of electrical devices using their nameplate rating and duty
cycle
[[Page 21596]]
assumptions about their daily operation. In addition, the heat loads
from electrical devices were factored into the envelope refrigeration
load calculations. DOE proposed to incorporate 100 percent of the
electrical energy consumed to operate the devices that are internally
located and to convert the electrical energy consumed to a thermal
load. The associated thermal load was then used to calculate the
additional refrigeration load using the nominal refrigeration EER
values described in section III.B.3.c. DOE also proposed a variety of
PTO values in the NOPR to account for reductions in energy use due to
component control and hours of usage. 75 FR 186, 198 (Jan. 4, 2010).
BASF supported including electricity consumption as part of the
energy calculation, and concurred with the duty cycle assumptions.
(BASF, No. 0021.1 at p. 5) Master-Bilt and Nor-Lake also agreed with
the electrical duty cycle equation proposed by DOE. (Master-Bilt, No.
0027.1 at p. 2; Nor-Lake, No. 0023.1 at p. 4) ACEEE supported the
methods and assumptions for PTO values and electrical loads and agreed
with the use of nameplate power ratings because it encouraged load
reduction. (ACEEE, No. 0052.1 at p. 3) ThermalRite noted that while it
did not fully understand how the proposed PTO values listed in the
January 2010 NOPR were developed, it believed that the proposed values
represented a fair method of comparison among manufacturers because the
same assumptions are made for all users. ThermalRite asked that DOE
ensure that the values include all device types. (ThermalRite, No.
0049.1 at p. 2) ORNL requested that DOE include the ground heater below
the floor insulation as part of the energy use calculation. (ORNL, No.
0028.1 at p. 2) Craig Industries requested that DOE accommodate high-
efficiency heater wires that apply heat on demand. (Craig Industries,
Public Meeting Transcript, No. 0016 at p. 325 and No. 0054.1 at p. 3)
Finally, Nor-Lake expressed the opinion that the proposed PTO values
for lights are low because in most applications the lights would be
shut off each night for 8 hours. (Nor-Lake, No. 0047.1 at p. 5)
DOE notes support from BASF, Master-Bilt, Nor-Lake, ACEEE, and
ThermalRite for its methodology and assumptions. DOE is also aware of
the concerns presented by ORNL, Craig Industries, and Nor-Lake.
However, since DOE will implement a component-based standard,
electrical components not part of a door are not included in the
component test or component metric. DOE notes that assemblers or
manufacturers of complete walk-ins must still use lighting that
complies with the efficacy standard prescribed in EPCA. (42 U.S.C.
6313(f)(1)(G)) DOE will continue to use the method proposed in the
January 2010 NOPR to calculate the energy consumption of lights,
sensors, and other miscellaneous electrical devices associated with
walk-in doors. Regarding Craig Industries' specific comment about door
heater wire, DOE's PTO assumptions take into account demand-based
control of components, which includes the loads from door heater wires.
PTO assumptions are given in sections 4.4.2 and 4.5.2 of Appendix A for
display and non-display doors, respectively. See section III.B.3.b for
further discussion of electrical components of doors.
C. Test Procedures for Refrigeration Systems
The refrigeration system is the equipment that performs the
mechanical work necessary to cool the interior space of a walk-in
cooler or freezer. As previously discussed, DOE considers the
refrigeration system an individual component of the walk-in cooler or
walk-in freezer. Therefore, in this test procedure, DOE establishes a
test of the performance of a refrigeration system itself, assuming
nominal envelope characteristics. In the concurrent standards
rulemaking, DOE intends to establish energy conservation standards for
the refrigeration system. See generally 75 FR 17080 (April 5, 2010).
The following sections address issues raised by interested parties on
the January 2010 NOPR and September 2010 SNOPR.
1. Definition of Refrigeration System
In the January 2010 NOPR, DOE proposed a definition of
refrigeration system that described three types of systems that would
be covered: (1) Single-package systems containing the condensing and
evaporator units; (2) split systems with the condensing unit and unit
cooler physically separated and connected via refrigerant piping; or
(3) unit coolers that receive refrigerant from a compressor rack system
shared with other refrigeration equipment. 75 FR at 200 (Jan. 4, 2010).
In the September 2010 SNOPR, DOE proposed minor revisions to that
definition to clarify some of these terms. That notice proposed the
following definitions:
Refrigeration system means the mechanism (including all controls
and other components integral to the system's operation) used to
create the refrigerated environment in the interior of a walk-in
cooler or freezer, consisting of (1) a packaged system where the
unit cooler and condensing unit are integrated into a single piece
of equipment, (2) a split system with separate unit cooler and
condensing unit sections, or (3) a unit cooler that is connected to
a multiplex condensing system.
75 FR 55068, 55093 (Sept. 9, 2010).
NRDC, Craig Industries, and Master-Bilt agreed with the revisions
proposed in the September 2010 SNOPR. (NRDC, No. 0064.1 at p. 7; Craig
Industries, No. 0068.1 at p. 5; Master-Bilt, No. 0069.1 at p. 3) Other
interested parties did not agree with the classification contained in
the definition or the types of systems covered. NEEA stated that the
three refrigeration types do not accurately represent the market, and
recommended that the equipment classification should instead match the
classifications contained in DOE's regulations for commercial
refrigeration equipment. (NEEA, No. 0061.1 at pp. 2 and 4) The Joint
Utilities also disagreed with the concept of defining systems as
``matched'' (``packaged'' or ``split'' systems as termed in the
proposed definition) or ``remote'' (a unit cooler connected to a
multiplex condensing system as in the proposed definition). (Joint
Utilities, No. 0059.1 at p. 2) Like NEEA, the Joint Utilities suggested
that DOE change its proposed definition by adopting the approach taken
with the commercial refrigeration equipment efficiency regulations:
``packaged'' systems should be termed ``self-contained condensing
units'' and all other condensing units should be considered ``remote
condensing units.'' The Joint SNOPR comment also agreed with this
approach, suggesting that DOE classify refrigeration systems as self-
contained (packaged systems) or unit coolers connected to remote
condensing units (both dedicated and multiplex). It also suggested that
for remote condensing systems, any applicable energy conservation
standards should only apply to the unit cooler. (Joint SNOPR Comment,
No. 0074.1 at p. 3)
DOE believes the three types of refrigeration systems described in
the definition accurately represent the range of refrigeration
equipment that is used in walk-in coolers and freezers. Although the
definition differs from the definition for commercial refrigeration
equipment, there are key differences between commercial refrigeration
equipment refrigeration systems and walk-in refrigeration systems that
make a new definition necessary. NEEA and the Joint Utilities refer to
two common types of commercial refrigeration equipment refrigeration
units. Some are ``self-contained'' (meaning the entire refrigeration
system is built into the case). Others are ``remote condensing''
(meaning the unit cooler is built into the
[[Page 21597]]
case, but the whole case is connected to a central system of
compressors and condensers (called a ``rack'' or ``multiplex condensing
system'') that is connected to most or all of the refrigeration units
in a building). The latter configuration is common in supermarkets. For
all remote condensing systems, the commercial refrigeration equipment
test procedure rulemaking assumed a certain efficiency of the multiplex
condensing system and the standards rulemaking did not regulate this
part of the equipment. 71 FR 71340 and 74 FR 1092.
However, ``remote condensing'' can also refer to a configuration in
which the unit cooler is connected to a dedicated (that is, only
serving that one unit) compressor and condenser that are located
somewhere away from the walk-in. This configuration is very rare for
commercial refrigeration equipment but comprises a large proportion of
walk-in refrigeration system applications. For this reason, DOE does
not agree with the suggestion of NEEA and the Joint Utilities that this
configuration should be classified as ``remote condensing'' and does
not agree that the compressor and condenser parts should not be covered
under the walk-in coolers and freezers rulemaking. Rather, DOE believes
that a dedicated condensing unit should be included in the rule, even
if it is remotely located, because it could be viewed as part of the
walk-in cooler as long as it is connected only to that cooler and not
to other refrigeration equipment. For systems where the walk-in is
connected to a multiplex condensing system that runs multiple pieces of
equipment, the compressor and condenser would not be covered because
they are not exclusively part of the walk-in.
In consideration of the above, DOE believes the commercial
refrigeration equipment definition cannot be applied to walk-ins,
because there is a certain type of walk-in refrigeration--namely, a
split system with a dedicated but remotely located condensing unit--
that is highly represented in walk-ins but rarely, if ever, represented
in commercial refrigeration equipment. Thus, while the Joint Comment
compares walk-in refrigeration systems to commercial refrigeration
equipment, DOE believes this is not a relevant comparison. A closer
comparison would be to residential central air conditioners--an example
of equipment that almost always has a dedicated, but remotely located,
condensing unit. In that instance, DOE's definition covers this type of
remote condensing unit. Furthermore, DOE notes that manufacturers can
optimize the dedicated, remote condensing unit with the unit cooler to
take advantage of certain conditions such as low ambient outdoor
temperatures. Therefore, DOE has retained the proposed definition's
coverage of dedicated remote condensing systems. To further clarify
this coverage, DOE has added the term ``dedicated'' to describe
packaged systems and split systems in the definition it is adopting
today.
2. Refrigeration Test Procedure: AHRI 1250 (I-P)-2009
DOE proposed to incorporate the industry standard AHRI 1250-2009,
``2009 Standard for Performance Rating of Walk-In Coolers and
Freezers,'' into the test procedure. (The January 2010 NOPR referred to
the preliminary version of this standard, AHRI 1250P-2009. The SNOPR
updated this reference to the final version.) 75 FR 186, 200-201 (Jan.
4, 2010) and 75 FR 55068, 55086 (Sept. 9, 2010). DOE proposed that
manufacturers use this standard to rate the refrigeration systems of
walk-in coolers and freezers.
AHRI 1250-2009 covers the testing of refrigeration systems for
walk-in coolers and freezers, which includes unit coolers and
condensing units that are sold together as a matched system, unit
coolers and condensing units that are sold separately, and unit coolers
connected to compressor racks. The procedure describes the method for
measuring the refrigeration capacity and the electrical energy
consumption for the condensing unit and the unit cooler, as well as the
off-cycle fan energy and the defrost subsystem under specified test
conditions. The standard test conditions specify the dry-bulb and wet-
bulb temperatures of the air surrounding the unit cooler and the
condensing unit. The standard test conditions are different for indoor
and outdoor locations for the condensing unit and for coolers and
freezers.
The AHRI procedure also specifies the calculations used to
ascertain the nominal box loads under typical low-load and high-load
conditions, expressed as a function of the ambient air temperature.
(The ``nominal box load'' refers to the refrigeration load imposed on
the system by the walk-in envelope.) During the test, the system must
operate under steady-state conditions. For systems in which the
condensing unit is located outdoors, the test procedure uses bin
temperature data and bin hour data to represent the impact of the
seasonal variation in outside ambient air temperature on energy use.
The test procedure provides a calculation methodology to compute an
annual walk-in efficiency factor (AWEF) for the refrigeration system
under a specified load profile. For unit coolers and condensing units
sold separately, the test procedure allows for testing the components
individually and then calculating the system AWEF from the component
test results.
Several interested parties agreed with DOE's proposed methodology.
AHRI urged DOE to allow a rating of walk-in refrigeration systems using
the calculation methodologies in the proposed protocols contained in
AHRI 1250. (AHRI, No. 0070.1 at p. 2) American Panel, Thermo-Kool,
Bally, and NRDC also supported DOE's proposal to allow the evaporator
and condensing unit to be tested separately according to the proposed
methodology. (American Panel, No. 0057.1 at p. 1; Thermo-Kool, No.
0072.1 at p. 1; Bally, No. 0078.1 at p. 3; NRDC, No. 0064.1 at p. 3)
Craig Industries supported a formula that would allow the efficiency of
the refrigeration system to be calculated from testing data provided by
each component supplier. (Craig, No. 0068.1 at p. 3) Heatcraft advised
that the refrigeration system procedure should allow for testing new
components. (Heatcraft, No. 0065.1 at p. 1) However, the Joint
Utilities disagreed with the assumption in AHRI 1250-2009 that unit
coolers and remote condensing units that are sold separately will be
matched and installed together, and stated that AHRI 1250-2009 does not
allow unit coolers to be compared with each other unless they have been
tested on the same condensing unit. (Joint Utilities, No. 0059.1 at p.
2) No parties opposed DOE's proposal to allow evaporator and condensing
unit to be tested separately.
DOE notes the support of AHRI, American Panel, and NRDC for the
proposed method and incorporates it into this final rule. In response
to Heatcraft's suggestion that the procedure should allow for testing
new components, DOE anticipates that the method will lead to
manufacturers testing unit coolers and condensing units when they are
manufactured separately, so that they can be used in new systems.
Regarding the issues raised by Craig Industries and the Joint
Utilities, DOE emphasizes that the proposed procedure contains a
calculation method by which the overall refrigeration performance can
be calculated using testing data from a condensing unit and unit
cooler, even if the two components are provided by different suppliers.
The test results for a unit cooler or condensing unit are independent
from whichever condensing unit or unit cooler is matched with the
tested component. In
[[Page 21598]]
contrast, the test results for each component are in the form of a
performance curve to facilitate calculation of matched performance,
which, as suggested by the Joint Utilities, does not lend itself to
meaningful comparisons between unit coolers without matching the
particular unit coolers with the same condensing unit. DOE acknowledges
this limitation but believes it is important to maintain the results in
terms of the performance curve to facilitate calculation of the
performance of the system as a whole, because the entire refrigeration
system is treated as a component under the approach adopted in today's
final rule. Given that the refrigeration system is treated as a single
component under the procedure, the procedure offers a simple method for
determining the energy efficiency profile of the walk-in refrigeration
system because it allows the unit cooler and condensing unit to be
tested separately.
Additionally, DOE notes that if unit coolers are tested and rated
as if they were to be combined with a multiplex condensing system, they
could be compared against each other. The test data for unit coolers in
a mix-match system include the data necessary for calculating the unit
cooler's performance when paired with a multiplex condensing system.
Thus, it would be relatively simple for manufacturers of unit coolers
to provide both the performance data for matching purposes and the
performance as connected to a multiplex condensing system. DOE may
consider requiring this information as part of any related labeling
requirements for WICF equipment.
While interested parties generally agreed with the adoption of AHRI
1250-2009, others disagreed with how that method would be applied to
different system configurations. The Joint Utilities and NEEA both
recommended that all remote condensing systems be tested using the
``walk-in unit cooler match to parallel rack system'' test method and
noted that the matched system approach only be used for self-contained
condensing units. (Joint Utilities, No. 0059.1 at p. 3; NEEA, No.
0061.1 at p. 4) The Joint Utilities further stated that the proposed
AHRI 1250-2009 test method for rating dedicated remote condensing
systems would create confusion and additional testing burden because
there are many different test methods and categories for different
locations and types of condensing units. (Joint Utilities, No. 0059.1
at pp. 2 and 5) Other interested parties questioned the methodology for
rating unit coolers connected to multiplex condensing systems. American
Panel stated that the exemption of multiplex equipment would give that
equipment an unfair advantage over single piece equipment. (American
Panel, No. 0057.1 at p. 3) Master-Bilt stated that the multiplex
exemption seemed to suggest that any condensing unit connected to more
than one unit cooler would not be covered. (Master-Bilt, No. 0069.1 at
p. 3) NRDC stated that the proposed equations for evaluating the energy
use of units with indoor condensing units and those connected to
multiplex condensing systems should account for differences in the
systems' ability to reject heat. (NRDC, No. 0064.1 at p. 7)
Addressing the comments from the Joint Utilities and NEEA, as
discussed in section III.C.1, DOE considers dedicated remote condensing
units as distinct from multiplex condensing systems in that dedicated
remote condensers are part of only one walk-in, while multiplex
condensing systems are connected to more than one walk-in or other unit
of refrigeration equipment. DOE believes that dedicated remote
condensing units represent a substantial opportunity for energy savings
in a regulation for walk-in components because the configuration of a
dedicated remote condensing unit is widespread in several market
segments such as restaurants. Manufacturers can optimize the dedicated
remote condensing unit with the unit cooler to take advantage of
certain conditions such as low ambient outdoor temperatures. The
approach suggested by the Joint Utilities and NEEA would exclude
dedicated remote condensing units from this regulation, but DOE views
these units as part of the walk-in cooler or freezer if the unit is
connected only to the walk-in and not to any other refrigeration
equipment. Therefore, the test procedure for walk-in refrigeration
equipment accounts for these units.
To address Master-Bilt's request for clarification, for systems
where the walk-in is connected to a central multiplex condensing system
that runs multiple pieces of equipment, the compressor and condenser
would not be covered because they are not exclusively part of the walk-
in. DOE realizes there are certain condensing units that are connected
to more than one unit cooler inside a single walk-in. These systems
would not be considered ``multiplex condensing systems'' because they
are connected to a single walk-in. However, if the condensing unit were
connected to more than one unit cooler inside more than one walk-in or
other piece of equipment, DOE would consider that a multiplex
condensing system because the system's performance could not be
attributed to one walk-in alone. While DOE understands American Panel's
concern that multiplex condensing systems could have an advantage
because those condensing units would not need to be tested, the
condensing unit and compressor part of a multiplex condensing system is
not exclusively part of a walk-in unit. Therefore, DOE is not covering
them in this test procedure. DOE notes that unit coolers connected to
the multiplex condensing systems would still be considered part of the
walk-in and would need to be tested. The procedure considers the
different performance of multiplex condensing systems and indoor
condensing systems as recommended by NRDC. For multiplex condensing
systems, the calculation of energy use includes a nominal efficiency
that accounts for that type of system's ability to reject heat. The
rating conditions for indoor condensing units provide an opportunity
for crediting energy savings that result from an increased ability to
reject heat.
Finally, one interested party proposed to expand the test procedure
to provide more information than DOE previously proposed. NRDC
suggested that testing data should be input into standardized
calculations that would determine the overall system performance for
each application and recommended that performance data should be able
to be interpolated or extrapolated for hot climates. (NRDC, No. 0064.1
at p. 3) DOE notes that standardized rating conditions are not
typically application-specific and may not be useful for determining
the performance of the system in conditions outside the rating
conditions. To provide this flexibility, as suggested by NRDC, the AHRI
1250 test procedure contains provisions for conducting testing with
application ratings to obtain the performance for a particular
application. However, DOE emphasizes that the standardized rating
conditions are useful for comparing systems with each other and must be
used for evaluating a product's compliance with a particular standard.
3. Alternative Efficiency Determination Method
For some covered equipment, DOE has allowed manufacturers to use
their own methods, whether a calculation or computer simulation, to
rate their equipment after they substantiate those calculation or
simulation methods with test data. The purpose of this provision is to
reduce the burden of testing customized, low-volume equipment. DOE has
allowed rating methods in the form of alternate rating methods (ARMs)
[[Page 21599]]
or alternative efficiency determination methods (AEDMs). An ARM, which
is allowed for rating residential central air conditioners and heat
pumps, must be a representation of the test data and calculations of a
mechanical vapor-compression refrigeration cycle. Manufacturers may use
an ARM after submitting documentation to DOE and receiving specific
approval from DOE to use that ARM to rate their equipment. (10 CFR
430.24(m)(4)-(6)) An AEDM, which is allowed for certain products and
commercial equipment--including electric motors, distribution
transformers, and commercial heating, ventilating, air-conditioning,
and water heating (HVAC and WH) equipment--is a rating method derived
from a mathematical model that represents the mechanical and electrical
characteristics of the equipment and is based on engineering or
statistical analysis, computer simulation or modeling, or other
analytical evaluations of performance data. An AEDM must be
substantiated by test data before it can be used to rate equipment. (10
CFR 431.17(a)(2)-(3); 10 CFR 431.197(a)(2); and 10 CFR 431.197(a)(2)-
(3))
For the walk-in coolers and freezers rulemaking, DOE introduced the
concept of an AEDM at the Framework public meeting (February 4, 2009)
and requested comment on whether it could be applied to walk-ins. At
the Framework public meeting, DOE asked how an AEDM could be
implemented for walk-ins, what a sufficient test sample size for
validating an AEDM would be, and how accurate (to what percentage) an
AEDM should be. DOE did not receive any feedback regarding these
questions. Several interested parties did, however, raise concerns in
written comments on the Framework and during the Framework public
meeting about the potential for inconsistency among manufacturers'
rating methods. For example, Owens Corning stated that a single AEDM
should be accepted to keep comparisons consistent (instead of different
AEDMs from different manufacturers), and Craig said that requiring
manufacturers to follow the same model (that is, not allowing
manufacturers to use their own AEDMs) would provide consistent
information to end users. (Owens Corning, No. EERE-2008-BT-STD-0015-
0034.1 at p. 2; Craig, No. EERE-2008-BT-STD-0015-0025.1 at p. 5) DOE
summarized and addressed these comments in the January NOPR. 75 FR 186,
190 (Jan. 4, 2010).As a result, DOE did not propose any specific
provisions regarding AEDMs or any other provisions that would allow
manufacturers to develop their own rating methods for walk-ins.
Instead, DOE proposed its own calculation methodology for manufacturers
to use in rating similar units of walk-in equipment. 75 FR 186, 191
(Jan. 4, 2010).
While the procedure divides the envelope into its major components,
the refrigeration system is considered as a single component.
Consistent with this approach, DOE is incorporating a single metric to
cover the performance of the refrigeration system. DOE noted in the
September 2010 SNOPR that the proposed refrigeration test procedure,
AHRI 1250 (I-P)-2009, ``2009 Standard for Performance Rating of Walk-In
Coolers and Freezers,'' allows manufacturers to test condensing units
and unit coolers separately in certain situations, and to calculate the
performance of the combined system. DOE anticipated that this approach
would reduce the overall testing burden by eliminating the need to test
the many possible unit cooler and condensing unit combinations that
could comprise a complete refrigeration system. 75 FR 55073 (Sept. 9,
2010). In proposing this approach, DOE also recognized that there could
still be some burdens due to system variations. To mitigate these
burdens, DOE noted that it might consider allowing manufacturers of
refrigeration to use AEDMs to rate their equipment. 75 FR 55089 (Sept.
9, 2010).
In comments on the September 2010 SNOPR, interested parties
commented on the burden of testing refrigeration systems because a
manufacturer's product line may have many different condensing units
and unit coolers, which may be similar, but not identical, and need to
be tested individually. Craig Industries stated that even if unit
coolers and condensing units could be tested separately, testing each
component with all the options available would substantially increase
the need for testing and would discourage manufacturers from improving
their equipment. (Craig Industries, No. 0068.1 at p. 3) AHRI requested
that DOE allow manufacturers to rate their equipment and demonstrate
compliance with the Federal standard through the use of an AEDM to
minimize testing burden. (AHRI, No. 0070.1 at p. 3) Manufacturers were
also concerned about how they would rate custom units. Heatcraft stated
that refrigeration system manufacturers would face an undue testing
burden and asserted that manufacturers would not be able to sell a
particular piece of equipment if it had been tested. (Heatcraft, No.
0065.1 at p. 2) DOE acknowledges that when a refrigeration system is
tested, it undergoes some modifications in order to accommodate the
apparatus for taking test measurements. As a result, these units can no
longer be sold as new equipment after testing and are typically
destroyed. This situation, in Heatcraft's view, would prevent them from
selling custom equipment if the inclusion of a custom piece requires a
separate test of the refrigeration system.
DOE recognizes the potential for variability with respect to walk-
in components, in terms of their physical characteristics and,
consequently, their energy performance or efficiency. To address
Craig's concern that testing all equipment variations would be
burdensome, and AHRI's request that DOE allow manufacturers to use
AEDMs, DOE will continue to consider the application of AEDMs or ARMs.
DOE recognizes the value of permitting the use of AEDMs and ARMs in
limited instances and may consider the adoption of such methods for
walk-in equipment, including the statistical basis and the sample size
required to validate them, in a future rulemaking.
D. Other Issues--Definition of Walk-In Cooler or Freezer
EPCA defines walk-in equipment at 42 U.S.C. 6311(20), codified at
10 CFR 431.302.
During the public meeting for the January 2010 NOPR, Hired Hand and
several interested parties stated that DOE should clarify the
definition of walk-in coolers and walk-in freezers with respect to
temperature limits. Multiple interested parties commented that DOE
should set an upper temperature limit for walk-ins. After reviewing the
comments from interested parties, DOE proposed in the September 2010
SNOPR to modify the definition of ``refrigerated'' within the
definition of walk-in cooler or freezer to mean at or below 55 [deg]F.
75 FR 55068, 55069 (Sept. 9, 2010).
The Joint Utilities, AHRI, American Panel, the Joint Manufacturers,
NEEA, Craig Industries, Thermo-Kool, Master-Bilt, and Bally agreed to
the proposed upper temperature limit of 55 [deg]F for walk-ins. (Joint
Utilities, No. 0059.1 at p. 6; AHRI, No. 0070.1 at p. 1; American
Panel, No. 0057.1 at p. 1; Joint Manufacturers, No. 0062.1 at p. 1,
NEEA, No. 0061.1 at p. 2; Craig Industries, No. 0068.1 at p. 1; Thermo-
Kool, No. 0072.1 at p. 1; Master-Bilt, No. 0069.1 at p. 1; Bally, No.
0078.1 at p. 1) The Joint Utilities also recommended that DOE develop
definitions for walk-in coolers and freezers that are similar to
California Title 24, Buildings Efficiency Standards, which contain a
[[Page 21600]]
definition for ``refrigerated warehouse'' that clarifies a temperature
of 55 degrees or less. (Joint Utilities, No. 0059.1 at p. 6) NEEA
suggested that walk-in coolers and freezers are essentially buildings
and should be modeled as such. (NEEA, No. 0061.1 at p. 5)
DOE notes that any regulation it develops must be consistent with,
and fall within the parameters of, the statutory provisions set by
Congress. Working within the confines of the statutorily-prescribed
definition of the walk-in definition, DOE is clarifying what the term
``refrigerated'' means in the context of the walk-in definition to help
address the concerns raised by commenters. In particular, DOE is
defining ``refrigerated'' for purposes of walk-ins to mean ``held at a
temperature at or below 55 degrees Fahrenheit using a refrigeration
system'' as suggested by commenters. Adopting this approach should
enable DOE to sufficiently account for the range of walk-in equipment
that exist.
In comments on the January 2010 NOPR, interested parties expressed
concern about the potential for abuse in light of the breadth of the
exclusion in the statute and requested that DOE clarify the scope of
this clause. At the public meeting for the January 2010 NOPR, Craig
Industries stated that the definition of ``medical, scientific, and
research walk-ins'' should be better defined, and Hired Hand agreed
that the definition is unclear. (Craig Industries, Public Meeting
Transcript, No. 0016 at p. 19; Hired Hand, Public Meeting Transcript,
No. 0016 at p. 26) These commenters were concerned because the current
statutory language does not account for the fact that, in practice,
walk-ins may be used interchangeably for either food storage or
medical, scientific, or research usage. Because a given walk-in sold by
a company could be used in any of these types of applications, Craig
Industries and Hired Hand were both concerned that a company could
market its walk-in as medical equipment and avoid having to meet any
energy efficiency standards. Craig Industries and Hired Hand requested
that DOE work to improve the definition of exempted uses for walk-ins
because the definition could create ambiguity and loopholes. (Craig
Industries, Public Meeting Transcript, No. 0016 at p. 4; Hired Hand,
No. 0051.1 at p. 2)
DOE is sensitive to the potential for abuse regarding walk-ins. To
ensure that such abuse does not occur and to help clarify the scope of
the exclusion created by Congress, DOE notes that for any walk-in--
including those components that are covered by today's test procedure
and any applicable standards that DOE may promulgate--a manufacturer
seeking to avail itself of the statutory exclusion would, consistent
with the statute, need to affirmatively demonstrate to DOE that its
equipment is ``designed and marketed exclusively for medical,
scientific, or research purposes.'' 42 U.S.C. 6311(20)(B). Further,
while DOE is currently unaware of any instances where this exclusion is
being abused, DOE will monitor the situation and take steps to prevent
these types of activities from occurring when it receives sufficient
information substantiating the existence of such activities. In
examining whether a given walk-in satisfies the statutory exclusion,
DOE may consider a number of factors, including, but not limited to,
how a particular walk-in has been designed, how it has been marketed,
to whom the equipment has been distributed, and steps taken by
manufacturers. Accordingly, while DOE appreciates the concerns raised
by Craig Industries and Hired Hand, DOE has decided that, at this time,
the exclusion set by Congress is sufficiently clear. DOE may revisit
this issue in the future if necessary.
One commenter requested clarification of the 3,000 square foot
provision. Bally suggested that DOE add a corroborating cubic foot
threshold, and stated that the large variability in panel heights could
impact the energy conservation standards. (Bally, No. 0078.1 at p. 1)
Under the component-level test procedures established today, a cubic
foot threshold for a walk-in is not necessary. Rather, a panel is
considered as an individual component and its dimensions, including its
height, are accounted for in the calculation methodology that DOE
developed.
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
The Office of Management and Budget has determined that test
procedure rulemakings do not constitute ``significant regulatory
actions'' under section 3(f) of Executive Order 12866, Regulatory
Planning and Review, 58 FR 51735 (Oct. 4, 1993). Accordingly, this
action was not subject to review under the Executive Order by the
Office of Information and Regulatory Affairs (OIRA) in the Office of
Management and Budget (OMB).
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (IFRA) for
any rule that by law must be proposed for public comment, unless the
agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by Executive Order 13272, ``Proper Consideration of Small
Entities in Agency Rulemaking,'' 67 FR 53461 (August 16, 2002), DOE
published procedures and policies on February 19, 2003, to ensure that
the potential impacts of its rules on small entities are properly
considered during the DOE rulemaking process. 68 FR 7990. DOE has made
its procedures and policies available on the Office of the General
Counsel's Web site: http://www.gc.doe.gov.
DOE reviewed the test procedures considered in today's final rule
under the provisions of the Regulatory Flexibility Act and the
procedures and policies published on February 19, 2003.
As discussed in detail below, DOE found that because these test
procedures have not previously been required of manufacturers, all
manufacturers, including small manufacturers, could experience a
financial burden associated with new testing requirements. While
examining this issue, DOE determined that it could not certify that
this rule would not have a significant effect on a substantial number
of small entities. Therefore, DOE prepared an Initial Regulatory
Flexibility Analysis (IRFA) for this rulemaking. 75 FR 55068, 55087.
The Final Regulatory Flexibility Analysis (FRFA) set forth below, which
describes potential impacts on small businesses associated with walk-in
cooler and freezer testing requirements, incorporates the IRFA and
changes made to the IRFA in response to the comments from interested
parties, including the Small Business Administration (SBA), on the
September 2010 SNOPR.
1. Statement of the Need for, and Objectives of, the Rule
A statement of the need for, and objectives of, the rule is stated
elsewhere in the preamble and not repeated here.
2. Summary of the Significant Issues Raised by the Public Comments,
DOE's Response to These Issues, and Any Changes Made in the Proposed
Rule as a Result of Such Comments
The comments received on the IRFA and the economic impacts of the
rule and responses thereto are provided in the analysis below.
[[Page 21601]]
3. Description and Estimated Number of Small Entities Regulated
DOE uses the SBA small business size standards published on January
31, 1996, as amended, to determine whether any small entities would be
required to comply with the rule. 61 FR 3286; see also 65 FR 30836,
30850 (May 15, 2000), as amended. 65 FR 53533, 53545 (September 5,
2000). The size standards are codified at 13 CFR Part 121. The
standards are listed by North American Industry Classification System
(NAICS) code and industry description and are available at http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf.
In the January 2010 NOPR and September 2010 SNOPR, DOE classified
walk-in cooler and freezer equipment manufacturing under NAICS 333415,
``Air-Conditioning and Warm Air Heating Equipment and Commercial and
Industrial Refrigeration Equipment Manufacturing,'' which has a size
standard of 750 employees. 75 FR 186, 204 (Jan. 4, 2010) and 75 FR
55068, 55087 (Sept. 9, 2010). After reviewing industry sources and
publicly available data, DOE identified at least 37 small manufacturers
of walk-in cooler and freezer envelopes and at least 5 small
manufacturers of walk-in cooler and freezer refrigeration systems that
met this criterion. DOE also noted that the walk-in industry can be
characterized by a few manufacturers that are subsidiaries of much
larger companies (that would not be considered small businesses) and a
large number of small companies as categorized by NAICS code 333415.
Furthermore, more than half of small walk-in manufacturers have 100 or
fewer employees. 75 FR at 55088 (Sept. 9, 2010).
Interested parties commented on the market characterization DOE
presented in the September 2010 SNOPR. SBA agreed with DOE's
characterization of the walk-in manufacturing industry. (SBA, No.
0066.1 at p. 2) American Panel stated that most walk-in companies are
small businesses and would be at a disadvantage compared to the large
conglomerates. American Panel characterized the majority of small walk-
in manufacturers as making between $10 and $25 million in sales while
large manufacturers represent $75 million in walk-in sales and $250
million in overall sales. (American Panel, No. 0057.1 at p. 3) American
Panel stated that the cost of testing would be passed down to the
product selling price, which would trickle down and seriously impact
small business restaurant owners. (American Panel, No. 0057.1 at p. 4)
Zero Zone agreed that small manufacturers would be impacted by the
regulations and stated that many will not be able to stay in business
once they are burdened with the costs of certification. (Zero Zone, No.
0077.1 at p. 2)
In response to comments on the January 2010 NOPR and September 2010
SNOPR regarding DOE's proposed standards for WICF, DOE is taking a
component-level approach in the WICF test procedure rulemaking.
Specifically, DOE is establishing test procedures for individual
components of a walk-in: Panels, doors, and refrigeration systems.
Manufacturers of these components will be required to test the
components they manufacture for walk-ins and certify that they meet any
applicable component performance standard. This approach will mitigate
the overall burdens posed by this regulation and ensure that those
burdens are borne on those manufacturers who are best suited and
positioned to conduct these types of tests. See section III.A for
further details on this approach.
As a result of this approach, DOE re-evaluated the number of small
manufacturers it identified in the September 2010 SNOPR for this final
rule. Because DOE is considering refrigeration systems as a single
component under the proposed approach, DOE estimates that there are 4
small manufacturers of refrigeration systems. Furthermore, DOE notes
that entities it previously considered walk-in envelope manufacturers
also manufacture the panels. As a result, DOE estimates that there are
37 small manufacturers of panels. For doors, DOE notes that some of the
panel manufacturers make doors and others buy doors from suppliers. DOE
researched manufacturers who solely manufacture the doors of WICF, and
estimates that there are four small manufacturers of walk-in doors who
do not also manufacture panels. DOE notes SBA's and American Panel's
characterization of the walk-in industry as being composed mainly of
small manufacturers. DOE believes the new approach of regulating WICFs
at the component level will reduce burden on small manufacturers
because the testing and compliance burden will be reduced due to an
enhanced ability to apply the basic model concept. See section
III.A.3.a for details. In response to American Panel's comment that the
cost of testing would affect small restaurant owners, DOE notes that
this analysis considers entities who are directly regulated by this
test procedure rulemaking (i.e., manufacturers). The concurrent energy
conservation standards rulemaking will address effects on walk-in
manufacturers' customers.
4. Description and Estimate of Compliance Requirements and Description
of Steps To Minimize the Economic Impact on Small Entities
DOE recognizes the particular burden of the test procedures on
small manufacturers. DOE does not expect that small manufacturers would
have fewer basic models or component types than large manufacturers.
Therefore, a small manufacturer could have the same total cost of
testing as a large manufacturer, but this cost would be a higher
percentage of a small manufacturer's annual revenues. Thus, the
differential impact associated with walk-in cooler and walk-in freezer
test procedures on small businesses may be significant even if the
overall testing burden is reduced as described elsewhere in the
preamble.
Due to the nature of walk-in coolers and freezers within the
appliance standards program, DOE is considering use of a component-
based approach to walk-in standards, setting individual performance
standards for each component. This approach would require the component
manufacturers to test the components they manufacture for walk-in
applications, comply with the applicable performance standard for those
components, and certify to DOE that those components meet the standard.
See section III.A for details on this approach. At this time there are
no performance standards in place for walk-in equipment, as those
standards are being developed in a concurrent rulemaking. Details on
the performance standards rulemaking can be found on the DOE Web site
at http://www1.eere.energy.gov/buildings/appliance_standards/commercial/wicf.html. However, manufacturers will be required to use
these test procedures to certify performance once any final standards
are issued and must use the test procedures outlined in this final rule
if they make representations as to the performance of their components.
To further address concerns about costs, DOE is anticipating
developing a sampling plan in a future rulemaking to determine how many
units of each walk-in component must be tested. In such a rulemaking,
DOE will consider the impacts to small businesses.
a. Panel and Door Manufacturer Testing Impacts
In the September 2010 SNOPR, DOE proposed to require envelope
manufacturers to test their equipment in accordance with several
industry test standards: ASTM C1363-05, ``Standard
[[Page 21602]]
Test Method for Thermal Performance of Building Materials and Envelope
Assemblies by Means of a Hot Box Apparatus;'' DIN EN 13164:2009-02,
``Thermal insulation products for buildings--Factory made products of
extruded polystyrene foam (XPS)--Specification;'' DIN EN 13165:2009-02,
``Thermal insulation products for buildings--Factory made rigid
polyurethane foam (PUR) products--Specification;'' and NFRC 100-
2010[E0A1], ``Procedure for Determining Fenestration Product U-
factors.''
DOE spoke with industry experts to determine the approximate cost
of each test. Under the new component level approach to testing, entire
walk-ins are not required to be tested or certified. Rather, component
manufacturers are required to test and certify their own components.
Therefore, DOE evaluated the cost of each test to the component
manufacturer. For foam used in panels, a test using DIN EN 13164:2009-
02 or DIN EN 13165:2009-02 costs approximately $5,000 for each type of
foam, though DOE has found that most manufacturers use only one type.
The test result would be used to calculate the LTTR for all the
manufacturer's panels that use that type of foam. For the panels
themselves, a test using ASTM C1363-05 costs approximately $5,000.
Manufacturers would need to test the core and edge U-factor of a pair
of 4 ft. by 8 ft. panels, for each foam type, frame type, and panel
thickness they manufacture. DOE estimated that manufacturers use either
one or two types of foam and may have up to nine different combinations
of frame type and panel thickness. Using this estimate, the total cost
of testing compliance with a panel standard could be up to an average
of $5,000-$10,000 for the foam panels and $45,000 to test the U-factors
of the different panel configurations. However, for manufacturers who
have fewer unique combinations of frame type and panel thickness, the
testing cost would be substantially less. DOE has incorporated other
burden reducing measures to reduce cost. Specifically, it incorporated
a method that allows manufacturers to test a reference panel that is 4
ft. by 8 ft. and then calculate the U-factor of other panels of
different dimensions from those test results as long as certain aspects
of the panels are the same. See section III.B.2 for details.
For doors, a test of door U-factor using NFRC 100 costs
approximately $5,000. DOE estimates that a typical door manufacturer
would have to certify up to 20 to 40 basic models of doors, which would
cost $100,000 to $200,000 if each door were to be physically tested.
However, NFRC 100 also permits computer modeling of a door's U-factor,
which could further reduce the testing cost. See section III.B.3 for
discussion of the NFRC testing requirements for doors.
The estimated costs only include the cost of one test on each basic
model, and do not include additional testing on the same basic model
that may be required as part of a sampling plan. As mentioned above,
DOE anticipates developing sampling plans in a future rulemaking to
determine how many tests need to be performed on the same type of
envelope component, to ensure the test results are repeatable and
statistically valid.
b. Refrigeration System Manufacturer Testing Impacts
The test procedure for refrigeration systems will require
manufacturers to perform testing in accordance with a single industry
test standard: AHRI 1250 (I-P)-2009, ``2009 Standard for Performance
Rating of Walk-In Coolers and Freezers.'' DOE researched the cost of
performing this test and, based on discussions with experts, estimates
that a test using AHRI 1250 (I-P)-2009 would likely cost approximately
$8,500. DOE estimates that the total testing cost for a typical
refrigeration manufacturer could be approximately $425,000, based on an
estimate of 50 basic models, but that it could be higher for
manufacturers of more customized equipment. For instance, a
manufacturer with 200 basic models would incur a testing cost of
approximately $1.7 million.
To address concerns of manufacturer impact, DOE is including
burden-reducing measures for refrigeration system manufacturers. The
test procedure referenced in this final rule, AHRI 1250-2009, allows
for rating the condensing unit and the unit cooler separately and then
calculating their combined efficiency. This reduces testing burden by
not requiring testing of every combination. Allowing such a calculation
to be used will significantly decrease the number of tests. See section
III.C.2 for details. DOE also notes that the CCE final rule, published
March 7, 2011, allows that in general, manufacturers may elect to group
individual models of equipment into basic models at their discretion to
the extent the models have essentially identical electrical, physical,
and functional characteristics that affect energy efficiency or energy
consumption. Furthermore, manufacturers may rate models conservatively,
meaning the tested performance of the model(s) must be at least as good
as the certified rating, after applying the appropriate sampling plan.
76 FR 12429. DOE believes these provisions will reduce the burden of
testing for refrigeration manufacturers because they will reduce the
number of basic models a manufacturer must test. DOE may also consider
allowing manufacturers to use validated alternative methods to rate
their equipment. See section III.C.3 for further discussion of these
methods.
DOE also considered a number of alternatives to these test
procedures, including test procedures that incorporate industry test
standards other than the referenced standards, DIN EN 13164:2009-02,
DIN EN 13165:2009-02, ASTM C1363-05, and AHRI 1250-2009, all previously
described in section III. (DOE also notes that NFRC 100, the test
method adopted for determining the U-factor of doors, was the least
burdensome test DOE identified.) Instead of requiring DIN EN
13164:2009-02 or DIN EN 13165:2009-02 for testing the long-term thermal
properties of insulation, DOE could require only ASTM C518-04,
``Standard Test Method for Steady-State Thermal Transmission Properties
by Means of the Heat Flow Meter Apparatus,'' which tests the thermal
properties of insulation at a certain point in time (that is, the point
of manufacture). This test could also be used in place of ASTM 1363-05.
A test conducted as per ASTM C518-04 would cost approximately $500 to
$1,000, as compared to $5,000 for a test conducted as per DIN EN
13164:2009-02 or DIN EN 13165:2009-02 and $5,000 for a test conducted
as per ASTM C1363-05. DOE is including ASTM C1363-05 as part of the
test procedure because heat conduction through structural members is a
significant panel characteristic that is not addressed under ASTM C518-
04. See section III.B.2.a for details. DOE is including DIN EN
13164:2009-02 and DIN EN 13165:2009-02 as part of the test procedure
because these methods account for the effect of aging on foam's
insulation performance, a phenomenon that is not captured under ASTM
C518-04. See section III.B.2.b for details.
C. Review Under the Paperwork Reduction Act of 1995
Manufacturers of walk-in cooler and walk-in freezer components must
certify to DOE that their equipment complies with any applicable energy
conservation standard. In certifying compliance, manufacturers must
test their equipment according to the DOE test procedure for walk-in
cooler and walk-in freezer components, including any amendments adopted
for that test procedure. DOE has adopted regulations
[[Page 21603]]
for the certification and recordkeeping requirements for all covered
consumer products and commercial equipment, including walk-in cooler
and walk-in freezer components. 76 FR 12442 (March 7, 2011). The
collection-of-information requirement for the certification and
recordkeeping has been approved by OMB under control number 1910-1400.
The public reporting burden for the certification is estimated to
average 20 hours per response, including the time for reviewing
instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the
collection of information.
Public comment is sought regarding: Whether this proposed
collection of information is necessary for the proper performance of
the functions of the agency, including whether the information shall
have practical utility; the accuracy of the burden estimate; ways to
enhance the quality, utility, and clarity of the information to be
collected; and ways to minimize the burden of the collection of
information, including through the use of automated collection
techniques or other forms of information technology. Send comments on
these or any other aspects of the collection of information to Charles
Llenza (see ADDRESSES) and by e-mail to [email protected].
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
D. Review Under the National Environmental Policy Act of 1969
In this final rule, DOE establishes a new test procedure for walk-
in coolers and walk-in freezers. DOE has determined that this rule
falls into a class of actions that are categorically excluded from
review under the National Environmental Policy Act of 1969 (42 U.S.C.
4321 et seq.) and DOE's implementing regulations at 10 CFR part 1021.
Specifically, this rule establishes a test procedure without affecting
the amount, quality or distribution of energy usage, and, therefore,
will not result in any environmental impacts. Thus, this rulemaking is
covered by Categorical Exclusion A5 under 10 CFR part 1021, subpart D,
which applies to any rulemaking that does not result in any
environmental impacts. Accordingly, neither an environmental assessment
nor an environmental impact statement is required.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism,'' 64 FR 43255 (August 4, 1999)
imposes certain requirements on agencies formulating and implementing
policies or regulations that preempt State law or that have Federalism
implications. The Executive Order requires agencies to examine the
constitutional and statutory authority supporting any action that would
limit the policymaking discretion of the States and to carefully assess
the necessity for such actions. The Executive Order also requires
agencies to have an accountable process to ensure meaningful and timely
input by State and local officials in the development of regulatory
policies that have Federalism implications. On March 14, 2000, DOE
published a statement of policy describing the intergovernmental
consultation process it will follow in the development of such
regulations. 65 FR 13735. DOE examined this final rule and determined
that it will not have a substantial direct effect on the States, on the
relationship between the national government and the States, or on the
distribution of power and responsibilities among the various levels of
government. EPCA governs and prescribes Federal preemption of State
regulations as to energy conservation for the products that are the
subject of today's final rule. States can petition DOE for exemption
from such preemption to the extent, and based on criteria, set forth in
EPCA. (42 U.S.C. 6297(d)) No further action is required by Executive
Order 13132.
F. Review Under Executive Order 12988
Regarding the review of existing regulations and the promulgation
of new regulations, section 3(a) of Executive Order 12988, ``Civil
Justice Reform,'' 61 FR 4729 (Feb. 7, 1996), imposes on Federal
agencies the general duty to adhere to the following requirements: (1)
Eliminate drafting errors and ambiguity; (2) write regulations to
minimize litigation; (3) provide a clear legal standard for affected
conduct rather than a general standard; and (4) promote simplification
and burden reduction. Section 3(b) of Executive Order 12988
specifically requires that Executive agencies make every reasonable
effort to ensure that the regulation: (1) Clearly specifies the
preemptive effect, if any; (2) clearly specifies any effect on existing
Federal law or regulation; (3) provides a clear legal standard for
affected conduct while promoting simplification and burden reduction;
(4) specifies the retroactive effect, if any; (5) adequately defines
key terms; and (6) addresses other important issues affecting clarity
and general draftsmanship under any guidelines issued by the Attorney
General. Section 3(c) of Executive Order 12988 requires Executive
agencies to review regulations in light of applicable standards in
sections 3(a) and 3(b) to determine whether they are met or it is
unreasonable to meet one or more of them. DOE has completed the
required review and determined that, to the extent permitted by law,
this final rule meets the relevant standards of Executive Order 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For a regulatory action resulting in a rule that may cause the
expenditure by State, local, and Tribal governments, in the aggregate,
or by the private sector of $100 million or more in any one year
(adjusted annually for inflation), section 202 of UMRA requires a
Federal agency to publish a written statement that estimates the
resulting costs, benefits, and other effects on the national economy.
(2 U.S.C. 1532(a), (b)) The UMRA also requires a Federal agency to
develop an effective process to permit timely input by elected officers
of State, local, and Tribal governments on a proposed ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements that might
significantly or uniquely affect small governments. On March 18, 1997,
DOE published a statement of policy on its process for
intergovernmental consultation under UMRA. 62 FR 12820; also available
at http://www.gc.doe.gov. DOE examined today's final rule according to
UMRA and its statement of policy and determined that the rule contains
neither an intergovernmental mandate, nor a mandate that may result in
the expenditure of $100 million or more in any year, so these
requirements do not apply.
H. Review Under theTreasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule
[[Page 21604]]
that may affect family well-being. Today's final rule will not have any
impact on the autonomy or integrity of the family as an institution.
Accordingly, DOE has concluded that it is not necessary to prepare a
Family Policymaking Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive Order 12630, ``Governmental
Actions and Interference with Constitutionally Protected Property
Rights'' 53 FR 8859 (March 18, 1988), that this regulation will not
result in any takings that might require compensation under the Fifth
Amendment to the U.S. Constitution.
J. Review Under Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516 note) provides for agencies to review most
disseminations of information to the public under guidelines
established by each agency pursuant to general guidelines issued by
OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22, 2002), and
DOE's guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has
reviewed today's final rule under the OMB and DOE guidelines and has
concluded that it is consistent with applicable policies in those
guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use,'' 66 FR 28355
(May 22, 2001), requires Federal agencies to prepare and submit to OMB,
a Statement of Energy Effects for any significant energy action. A
``significant energy action'' is defined as any action by an agency
that promulgated or is expected to lead to promulgation of a final
rule, and that: (1) Is a significant regulatory action under Executive
Order 12866, or any successor order; and (2) is likely to have a
significant adverse effect on the supply, distribution, or use of
energy; or (3) is designated by the Administrator of OIRA as a
significant energy action. For any significant energy action, the
agency must give a detailed statement of any adverse effects on energy
supply, distribution, or use if the regulation is implemented, and of
reasonable alternatives to the action and their expected benefits on
energy supply, distribution, and use.
Today's regulatory action is not a significant regulatory action
under Executive Order 12866. Moreover, it would not have a significant
adverse effect on the supply, distribution, or use of energy, nor has
it been designated as a significant energy action by the Administrator
of OIRA. Therefore, it is not a significant energy action, and,
accordingly, DOE has not prepared a Statement of Energy Effects.
L. Review Under Section 32 of the Federal Energy Administration Act of
1974
Under section 301 of the Department of Energy Organization Act
(Pub. L. 95-91; 42 U.S.C. 7101), DOE must comply with section 32 of the
Federal Energy Administration Act of 1974, as amended by the Federal
Energy Administration Authorization Act of 1977. (15 U.S.C. 788; FEAA)
Section 32 essentially provides in relevant part that, where a proposed
rule authorizes or requires use of commercial standards, the notice of
proposed rulemaking must inform the public of the use and background of
such standards. In addition, section 32(c) requires DOE to consult with
the Attorney General and the Chairman of the Federal Trade Commission
(FTC) concerning the impact of the commercial or industry standards on
competition.
The procedures addressed by this action incorporate the following
commercial standards: ASTM C1363-05, AHRI 1250 (I-P)-2009, DIN EN
13164:2009-02, DIN EN 13165:2009-02, and NFRC 100-2010[E0A1]. DOE has
evaluated these standards and is unable to conclude whether they fully
comply with the requirements of section 32(b) of the FEAA (i.e. whether
they were developed in a manner that fully provides for public
participation, comment, and review.) DOE has consulted with both the
Attorney General and the Chairman of the FTC about the impact on
competition of using the methods contained in these standards and has
received no comments objecting to their use.
M. Congressional Notification
As required by 5 U.S.C. 801, DOE will report to Congress on the
promulgation of today's rule before its effective date. The report will
state that it has been determined that the rule is not a ``major rule''
as defined by 5 U.S.C. 804(2).
N. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this final
rule.
List of Subjects in 10 CFR Part 431
Administrative practice and procedure, Confidential business
information, Energy conservation, Incorporation by reference, Reporting
and recordkeeping requirements.
Issued in Washington, DC, on March 30, 2011.
Kathleen Hogan,
Deputy Assistant Secretary for Energy Efficiency, Office of Technology
Development, Energy Efficiency and Renewable Energy.
PART 431--ENERGY EFFICIENCY PROGRAM FOR CERTAIN COMMERCIAL AND
INDUSTRIAL EQUIPMENT
0
1. The authority citation for part 431 continues to read as follows:
Authority: 42 U.S.C. 6291-6317.
0
2. Section 431.302 is amended by adding, in alphabetical order, new
definitions for ``Display door,'' ``Display panel,'' ``Door'',
``Envelope,'' ``K-factor,'' ``Panel,'' ``Refrigerated,''
``Refrigeration system,'' and ``U-factor'' to read as follows:
Sec. 431.302 Definitions concerning walk-in coolers and walk-in
freezers.
* * * * *
Display door means a door designed for product movement, display,
or both, rather than the passage of persons.
Display panel means a panel that is entirely or partially comprised
of glass, a transparent material, or both and is used for display
purposes.
Door means an assembly installed in an opening on an interior or
exterior wall that is used to allow access or close off the opening and
that is movable in a sliding, pivoting, hinged, or revolving manner of
movement. For walk-in coolers and walk-in freezers, a door includes the
door panel, glass, framing materials, door plug, mullion, and any other
elements that form the door or part of its connection to the wall.
Envelope means--
(1) The portion of a walk-in cooler or walk-in freezer that
isolates the interior, refrigerated environment from the ambient,
external environment; and
(2) All energy-consuming components of the walk-in cooler or walk-
in freezer that are not part of its refrigeration system.
K-factor means the thermal conductivity of a material.
* * * * *
Panel means a construction component that is not a door and is used
to construct the envelope of the walk-in, i.e., elements that separate
the interior refrigerated environment of the walk-in from the exterior.
Refrigerated means held at a temperature at or below 55 degrees
Fahrenheit using a refrigeration system.
Refrigeration system means the mechanism (including all controls
and other components integral to the
[[Page 21605]]
system's operation) used to create the refrigerated environment in the
interior of a walk-in cooler or freezer, consisting of:
(1) A packaged dedicated system where the unit cooler and
condensing unit are integrated into a single piece of equipment; or
(2) A split dedicated system with separate unit cooler and
condensing unit sections; or
(3) A unit cooler that is connected to a multiplex condensing
system.
U-factor means the heat transmission in a unit time through a unit
area of a specimen or product and its boundary air films, induced by a
unit temperature difference between the environments on each side.
* * * * *
0
3. Section 431.303 is amended by:
0
a. Redesignating paragraph (b) as paragraph (c);
0
b. Adding at the end of the sentence in redesignated paragraph (c)(1),
``and Appendix A to Subpart R of Part 431''.
0
c. Adding new paragraphs (b), (c)(2), (d), and (e) to read as follows.
Sec. 431.303 Materials incorporated by reference.
* * * * *
(b) AHRI. Air-Conditioning, Heating, and Refrigeration Institute,
2111 Wilson Boulevard, Suite 500, Arlington, VA 22201, (703) 600-0366,
or http://www.ahrinet.org.
(1) AHRI 1250 (I-P)-2009, (``AHRI 1250''), 2009 Standard for
Performance Rating of Walk-In Coolers and Freezers, approved 2009, IBR
approved for Sec. 431.304.
(2) [Reserved]
(c) * * *
(2) ASTM C1363-05, (``ASTM C1363''), Standard Test Method for
Thermal Performance of Building Materials and Envelope Assemblies by
Means of a Hot Box Apparatus, approved May 1, 2005, IBR approved for
Appendix A to Subpart R of part 431.
(d) CEN. European Committee for Standardization (French: Norme or
German: Norm), Avenue Marnix 17, B-1000 Brussels, Belgium, Tel: + 32 2
550 08 11, Fax: + 32 2 550 08 19 or http://www.cen.eu/.
(1) DIN EN 13164:2009-02, (``DIN EN 13164''), Thermal insulation
products for buildings--Factory made products of extruded polystyrene
foam (XPS)--Specification, approved February 2009, IBR approved for
Appendix A to Subpart R of part 431.
(2) DIN EN 13165:2009-02, (``DIN EN 13165''), Thermal insulation
products for buildings--Factory made rigid polyurethane foam (PUR)
products--Specification, approved February 2009, IBR approved for
Appendix A to Subpart R of part 431.
(e) NFRC. National Fenestration Rating Council, 6305 Ivy Lane, Ste.
140, Greenbelt, MD 20770, (301) 589-1776, or http://www.nfrc.org/.
(1) NFRC 100-2010[E0A1], (``NFRC 100''), Procedure for Determining
Fenestration Product U-factors, approved June 2010, IBR approved for
Appendix A to Subpart R of part 431.
(2) [Reserved]
0
4. Section 431.304 is amended by redesignating paragraphs (b)(2),
(b)(3), (b)(4), and (b)(5) as (b)(1), (b)(2), (b)(3), and (b)(4),
respectively, and by adding new paragraphs (b)(5), (b)(6), (b)(7), and
(b)(8) to read as follows.
Sec. 431.304 Uniform test method for the measurement of energy
consumption of walk-in coolers and walk-in freezers.
* * * * *
(b) * * *
(5) Determine the U-factor, conduction load, and energy use of
walk-in cooler and walk-in freezer display panels, floor panels, and
non-floor panels by conducting the test procedure set forth in Appendix
A to this subpart, sections 4.1, 4.2, and 4.3, respectively.
(6) Determine the energy use of walk-in cooler and walk-in freezer
display doors and non-display doors by conducting the test procedure
set forth in Appendix A to this subpart, sections 4.4 and 4.5,
respectively.
(7) Determine the Annual Walk-in Energy Factor of walk-in cooler
and walk-in freezer refrigeration systems by conducting the test
procedure set forth in AHRI 1250 (incorporated by reference; see Sec.
431.303).
(8) Determine the annual energy consumption of walk-in cooler and
walk-in freezer refrigeration systems:
(i) For systems consisting of a packaged dedicated system or a
split dedicated system, where the condensing unit is located outdoors,
by conducting the test procedure set forth in AHRI 1250 and recording
the annual energy consumption term in the equation for annual walk-in
energy factor in section 7 of AHRI 1250:
[GRAPHIC] [TIFF OMITTED] TR15AP11.024
where tj and n represent the outdoor temperature at each
bin j and the number of hours in each bin j, respectively, for the
temperature bins listed in Table D1 of AHRI 1250.
(ii) For systems consisting of a packaged dedicated system or a
split dedicated system where the condensing unit is located in a
conditioned space, by performing the following calculation:
[GRAPHIC] [TIFF OMITTED] TR15AP11.025
where BLH and BLL for refrigerator and freezer systems are defined
in sections 6.2.1 and 6.2.2, respectively, of AHRI 1250 and the
annual walk-in energy factor is calculated from the results of the
test procedures set forth in AHRI 1250.
(iii) For systems consisting of a single unit cooler or a set of
multiple unit coolers serving a single piece of equipment and connected
to a multiplex condensing system, by performing the following
calculation:
[[Page 21606]]
[GRAPHIC] [TIFF OMITTED] TR15AP11.026
where BLHand BLL for refrigerator and freezer systems are defined in
section 7.9.2.2 and 7.9.2.3, respectively, of AHRI 1250 and the
annual walk-in energy factor is calculated from the results of the
test procedures set forth in AHRI 1250.
0
5.Appendix A to subpart R of part 431 is added to read as follows:
Appendix A to Subpart R of Part 431--Uniform Test Method for the
Measurement of Energy Consumption of the Components of Envelopes of
Walk-In Coolers and Walk-In Freezers
1.0 Scope
This appendix covers the test requirements used to measure the
energy consumption of the components that make up the envelope of a
walk-in cooler or walk-in freezer.
2.0 Definitions
The definitions contained in Sec. 431.302 are applicable to
this appendix.
3.0 Additional Definitions
3.1 Automatic door opener/closer means a device or control
system that ``automatically'' opens and closes doors without direct
user contact, such as a motion sensor that senses when a forklift is
approaching the entrance to a door and opens it, and then closes the
door after the forklift has passed.
3.2 Core region means the part of the panel that is not the edge
region.
3.3 Edge region means a region of the panel that is wide enough
to encompass any framing members and edge effects. If the panel
contains framing members (e.g. a wood frame) then the width of the
edge region must be as wide as any framing member plus 2 in. 0.25 in. If the panel does not contain framing members then
the width of the edge region must be 4 in. 0.25 in. For
walk-in panels that utilize vacuum insulated panels (VIP) for
insulation, the width of the edge region must be the lesser of 4.5
in. 1 in. or the maximum width that does not cause the
VIP to be pierced by the cutting device when the edge region is cut.
3.4 Surface area means the area of the surface of the walk-in
component that would be external to the walk-in. For example, for
panel, the surface area would be the area of the side of the panel
that faces the outside of the walk-in. It would not include edges of
the panel that are not exposed to the outside of the walk-in.
3.5 Rating conditions means, unless explicitly stated otherwise,
all conditions shown in Table A.1. For installations where two or
more walk-in envelope components share any surface(s), the
``external conditions'' of the shared surface(s) must reflect the
internal conditions of the adjacent walk-in. For example, if a walk-
in component divides a walk-in freezer from a walk-in cooler, then
the internal conditions are the freezer rating conditions and the
external conditions are the cooler rating conditions.
3.6 Percent time off (PTO) means the percent of time that an
electrical device is assumed to be off.
Table A.1--Temperature Conditions
------------------------------------------------------------------------
Value
------------------------------------------------------------------------
Internal Temperatures (cooled space within
the envelope):
Cooler Dry Bulb Temperature.............. 35 [deg]F
Freezer Dry Bulb Temperature............. -10 [deg]F
External Temperatures (space external to
the envelope):
Freezer and Cooler Dry Bulb Temperatures. 75 [deg]F
Subfloor Temperatures:
Freezer and Cooler Dry Bulb Temperatures. 55 [deg]F
------------------------------------------------------------------------
4.0 Calculation Instructions
4.1 Display Panels
(a) Calculate the U-factor of the display panel in accordance
with section 5.3 of this appendix, Btu/h-ft\2\-[deg]F.
(b) Calculate the display panel surface area, as defined in
section 3.4 of this appendix, Adp, ft\2\, with standard
geometric formulas or engineering software.
(c) Calculate the temperature differential,
[Delta]Tdp, [deg]F, for the display panel, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.027
Where:
TDB,ext,dp = dry-bulb air external temperature, [deg]F,
as prescribed in Table A.1; and
TDB,int, dp = dry-bulb air temperature internal to the
cooler or freezer, [deg]F, as prescribed in Table A.1.
(d) Calculate the conduction load through the display panel,
Qcond-dp, Btu/h, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.028
Where:
Adp= surface area of the walk-in display panel,
ft2;
[Delta]Tdp= temperature differential between refrigerated
and adjacent zones, [deg]F; and
Udp = thermal transmittance, U-factor, of the display
panel in accordance with section 5.3 of this appendix, Btu/h-ft\2\-
[deg]F.
(e) Select Energy Efficiency Ratio (EER), as follows:
(1) For coolers, use EER = 12.4 Btu/W-h
(2) For freezers, use EER = 6.3 Btu/W-h
(f) Calculate the total daily energy consumption,
Edp, kWh/day, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.029
Where:
Qcond, dp = the conduction load through the display
panel, Btu/h; and
EER = EER of walk-in (cooler or freezer), Btu/W-h.
4.2 Floor Panels
(a) Calculate the surface area, as defined in section 3.4 of
this appendix, of the floor panel edge, as defined in section 3.3,
Afp edge, ft\2\, with standard geometric formulas or
engineering software as directed in section 5.1 of this appendix.
(b) Calculate the surface area, as defined in section 3.4 of
this appendix, of the floor panel core, as defined in section 3.2,
Afp core, ft\2\, with standard geometric formulas or
[[Page 21607]]
engineering software as directed in section 5.1 of this appendix.
(c) Calculate the total area of the floor panel, Afp,
ft\2\, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.030
Where:
Afp core = floor panel core area, ft\2\; and
Afp edge = floor panel edge area, ft\2\.
(d) Calculate the temperature differential of the floor panel,
[Delta][Tgr]fp, [deg]F, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.031
Where:
Text, fp = subfloor temperature, [deg]F, as prescribed in
Table A.1; and
TDB,int, fp = dry-bulb air internal temperature, [deg]F,
as prescribed in Table A.1. If the panel spans both cooler and
freezer temperatures, the freezer temperature must be used.
(e) Calculate the floor foam degradation factor,
DFfp, unitless, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.032
Where:
RLTTR,fp = the long term thermal resistance R-value of
the floor panel foam in accordance with section 5.2 of this
appendix, h-ft\2\-[deg]F/Btu; and
Ro,fp = the R-value of foam determined in accordance with
ASTM C518 (incorporated by reference; see section Sec. 431.303) for
purposes of compliance with the appropriate energy conservation
standard, h-ft\2\-[deg]F/Btu.
(f) Calculate the U-factor for panel core region modified by the
long term thermal transmittance of foam, ULT,fp core,
Btu/h-ft\2\-[deg]F, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.033
Where:
Ufp core = the U-factor in accordance with section 5.1 of
this appendix, Btu/h-ft\2\-[deg]F; and
DFfp = floor foam degradation factor, unitless.
(g) Calculate the overall U-factor of the floor panel,
Ufp, Btu/h-ft\2\-[deg]F, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.034
Where:
Afp edge = area of floor panel edge, ft\2\;
Ufp edge = U-factor for panel edge area in accordance
with section 5.1 of this appendix, Btu/h-ft\2\-[deg]F;
Afp core = area of floor panel core, ft\2\;
ULT,fp core = U-factor for panel core region modified by
the long term thermal transmittance of foam, Btu/h-ft\2\-[deg]F; and
Afp = total area of the floor panel, ft\2\.
(h) Calculate the conduction load through floor panels,
Qcond-fp, Btu/h,
[GRAPHIC] [TIFF OMITTED] TR15AP11.035
Where:
[Delta]Tfp = temperature differential across the floor
panels, [deg]F;
Afp = total area of the floor panel, ft\2\; and
Ufp = overall U-factor of the floor panel, Btu/h-ft\2\-
[deg]F.
(i) Select Energy Efficiency Ratio (EER), as follows:
(1) For coolers, use EER = 12.4 Btu/W-h
(2) For freezers, use EER = 6.3 Btu/W-h
(j) Calculate the total daily energy consumption,
Efp, kWh/day, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.036
Where:
Qcond-fp = the conduction load through the floor panel,
Btu/h; and
EER = EER of walk-in (cooler or freezer), Btu/W-h.
4.3 Non-Floor Panels
(a) Calculate the surface area, as defined in section 3.4, of
the non-floor panel edge, as defined in section 3.3,
Anf edge, ft\2\, with standard geometric formulas or
engineering software as directed in section 5.1 of this appendix.
(b) Calculate the surface area, as defined in section 3.4, of
the non-floor panel core, as defined in section 3.2,
Anf core, ft\2,\ with standard geometric formulas or
engineering software as directed in section 5.1 of this appendix.
(c) Calculate total non-floor panel area, Anf, ft\2\:
[GRAPHIC] [TIFF OMITTED] TR15AP11.037
Where:
Anf edge = non-floor paneledge area,ft\2\; and
Anf core = non-floor panel core area, ft\2\.
(d) Calculate temperature differential, [Delta]Tnf,
[deg]F:
[GRAPHIC] [TIFF OMITTED] TR15AP11.038
Where:
TDB,ext, nf = dry-bulb air external temperature, [deg]F,
as prescribed in Table A.1; and
TDB,int, nf = dry-bulb air internal temperature, [deg]F,
as prescribed in Table A.1. If the non-floor panel spans both cooler
and freezer temperatures, then the freezer temperature must be used.
(e) Calculate the non-floor foam degradation factor,
DFnf, unitless, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.039
Where:
RLTTR,nf = the R-value of the non-floor panel foam in
accordance with section 5.2 of this appendix, h-ft\2\-[deg]F/Btu;
and
[[Page 21608]]
Ro,nf = the R-value of foam determined in accordance with
ASTM C518 (incorporated by reference; see section Sec. 431.303) for
purposes of compliance with the appropriate energy conservation
standard, h-ft\2\-[deg]F/Btu.
(f) Calculate the U-factor, ULT,nf core, Btu/h-ft\2\-
[deg]F, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.040
Where:
Unf core = the U-factor, in accordance with section 5.1
of this appendix, of non-floor panel, Btu/h- ft\2\-[deg]F; and
DFnf = the non-floor foam degradation factor, unitless.
(g) Calculate the overall U-factor of the non-floor panel,
Unf, Btu/h-ft\2\-[deg]F, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.041
Where:
Anf edge = area of non-floor panel edge, ft\2\;
Unf edge = U-factor for non-floor panel edge area in
accordance with section 5.1 of this appendix, Btu/h-ft\2\-[deg]F;
Anf core = area of non-floor panel core, ft\2\;
ULT,nf core = U-factor for non-floor panel core region
modified by the long term thermal transmittance of foam, Btu/h-
ft\2\-[deg]F; and
Anf = total area of the non- floor panel, ft\2\.
(h) Calculate the conduction load through non-floor panels,
Qcond-nf, Btu/h,
[GRAPHIC] [TIFF OMITTED] TR15AP11.042
Where:
[Delta]Tnf = temperature differential across the non-
floor panels, [deg]F;
Anf = total area of the non-floor panel, ft\2\; and
Unf = overall U-factor of the non-floor panel, Btu/h-
ft\2\-[deg]F.
(i) Select Energy Efficiency Ratio (EER), as follows:
(1) For coolers, use EER = 12.4 Btu/W-h
(2) For freezers, use EER = 6.3 Btu/W-h
(j) Calculate the total daily energy consumption,
Enf, kWh/day, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.043
Where:
Qcond-nf = the conduction load through the non-floor
panel, Btu/h; and
EER = EER of walk-in (cooler or freezer), Btu/W-h.
4.4 Display Doors
4.4.1 Conduction Through Display Doors
(a) Calculate the U-factor of the door in accordance with
section 5.3 of this appendix, Btu/h-ft\2\-[deg]F
(b) Calculate the surface area, as defined in section 3.4 of
this appendix, of the display door, Add, ft\2\, with
standard geometric formulas or engineering software.
(c) Calculate the temperature differential,
[Delta]Tdd, [deg]F, for the display door as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.044
Where:
TDB,ext, dd = dry-bulb air temperature external to the
display door, [deg]F, as prescribed in Table A.1; and
TDB,int, dd = dry-bulb air temperature internal to the
display door, [deg]F, as prescribed in Table A.1.
(d) Calculate the conduction load through the display doors,
Qcond-dd, Btu/h, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.045
Where:
[Delta]Tdd = temperature differential between
refrigerated and adjacent zones, [deg]F;
Add = surface area walk-in display doors, ft\2\; and
Udd = thermal transmittance, U-factor of the door, in
accordance with section 5.3 of this appendix, Btu/h-ft\2\-[deg]F.
4.4.2 Direct Energy Consumption of Electrical Component(s) of Display
Doors
Electrical components associated with display doors could
include, but are not limited to: Heater wire (for anti-sweat or
anti-freeze application); lights (including display door lighting
systems); control system units; and sensors.
(a) Select the required value for percent time off (PTO) for
each type of electricity consuming device, PTOt (%)
(1) For lights without timers, control system or other demand-
based control, PTO = 25 percent. For lighting with timers, control
system or other demand-based control, PTO = 50 percent.
(2) For anti-sweat heaters on coolers (if included): Without
timers, control system or other demand-based control, PTO = 0
percent. With timers, control system or other demand-based control,
PTO = 75 percent. For anti-sweat heaters on freezers (if included):
Without timers, control system or other auto-shut-off systems, PTO =
0 percent. With timers, control system or other demand-based
control, PTO = 50 percent.
(3) For all other electricity consuming devices: Without timers,
control system, or other auto-shut-off systems, PTO = 0 percent. If
it can be demonstrated that the device is controlled by a
preinstalled timer, control system or other auto-shut-off system,
PTO = 25 percent.
(b) Calculate the power usage for each type of electricity
consuming device, Pdd-comp,u,t, kWh/day, as follows:
[[Page 21609]]
[GRAPHIC] [TIFF OMITTED] TR15AP11.046
Where:
u = the index for each of type of electricity-consuming device
located on either (1) the interior facing side of the display door
or within the inside portion of the display door, (2) the exterior
facing side of the display door, or (3) any combination of (1) and
(2). For purposes of this calculation, the interior index is
represented by u = int and the exterior index is represented by u =
ext. If the electrical component is both on the interior and
exterior side of the display door then u = int. For anti-sweat
heaters sited anywhere in the display door, 75 percent of the total
power is be attributed to u = int and 25 percent of the total power
is attributed to u = ext;
t = index for each type of electricity consuming device with
identical rated power;
Prated,u,t = rated power of each component, of type t,
kW;
PTOu,t = percent time off, for device of type t, %; and
nu,t = number of devices at the rated power of type t,
unitless.
(c) Calculate the total electrical energy consumption for
interior and exterior power, Pdd-tot, int (kWh/day) and
Pdd-tot, ext (kWh/day), respectively, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.047
[GRAPHIC] [TIFF OMITTED] TR15AP11.048
Where:
t = index for each type of electricity consuming device with
identical rated power;
Pdd-comp,int, t = the energy usage for an electricity
consuming device sited on the interior facing side of or in the
display door, of type t, kWh/day; and
Pdd-comp,ext, t = the energy usage for an electricity
consuming device sited on the external facing side of the display
door, of type t, kWh/day.
(d) Calculate the total electrical energy consumption,
Pdd-tot, (kWh/day), as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.049
Where:
Pdd-tot,int = the total interior electrical energy usage
for the display door, kWh/day; and
Pdd-tot,ext = the total exterior electrical energy usage
for the display door, kWh/day.
4.4.3 Total Indirect Electricity Consumption Due to Electrical Devices
(a) Select Energy Efficiency Ratio (EER), as follows:
(1) For coolers, use EER = 12.4 Btu/Wh
(2) For freezers, use EER = 6.3 Btu/Wh
(b) Calculate the additional refrigeration energy consumption
due to thermal output from electrical components sited inside the
display door, Cdd-load, kWh/day, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.050
Where:
EER = EER of walk-in cooler or walk-in freezer, Btu/W-h; and
Pdd-tot,int = The total internal electrical energy
consumption due for the display door, kWh/day.
4.4.4 Total Display Door Energy Consumption
(a) Select Energy Efficiency Ratio (EER), as follows:
(1) For coolers, use EER = 12.4 Btu/W-h
(2) For freezers, use EER = 6.3 Btu/W-h
(b) Calculate the total daily energy consumption due to
conduction thermal load, Edd, thermal, kWh/day, as
follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.051
Where:
Qcond, dd = the conduction load through the display door,
Btu/h; and
EER = EER of walk-in (cooler or freezer), Btu/W-h.
(c) Calculate the total energy, Edd,tot, kWh/day,
[GRAPHIC] [TIFF OMITTED] TR15AP11.052
[[Page 21610]]
Where:
Edd, thermal = the total daily energy consumption due to
thermal load for the display door, kWh/day;
Pdd-tot = the total electrical load, kWh/day; and
Cdd-load = additional refrigeration load due to thermal
output from electrical components contained within the display door,
kWh/day.
4.5 Non-Display Doors
4.5.1 Conduction Through Non-Display Doors
(a) Calculate the surface area, as defined in section 3.4 of
this appendix, of the non-display door, And, ft\2\, with
standard geometric formulas or with engineering software.
(b) Calculate the temperature differential of the non-display
door, [Delta]Tnd,[deg]F, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.053
Where:
TDB,ext, nd = dry-bulb air external temperature, [deg]F,
as prescribed by Table A.1; and
TDB,int, nd = dry-bulb air internal temperature, [deg]F,
as prescribed by Table A.1. If the component spans both cooler and
freezer spaces, the freezer temperature must be used.
(c) Calculate the conduction load through the non-display door:
Qcond-nd, Btu/h,
[GRAPHIC] [TIFF OMITTED] TR15AP11.054
Where:
[Delta]Tnd = temperature differential across the non-
display door, [deg]F;
Und = thermal transmittance, U-factor of the door, in
accordance with section 5.3 of this appendix, Btu/h-ft\2\-[deg]F;
and
And = area of non-display door, ft\2\.
4.5.2 Direct Energy Consumption of Electrical Components of Non-Display
Doors
Electrical components associated with a walk-in non-display door
comprise any components that are on the non-display door and that
directly consume electrical energy. This includes, but is not
limited to, heater wire (for anti-sweat or anti-freeze application),
control system units, and sensors.
(a) Select the required value for percent time off for each type
of electricity consuming device, PTOt (%)
(1) For lighting without timers, control system or other demand-
based control, PTO = 25 percent. For lighting with timers, control
system or other demand-based control, PTO = 50 percent.
(2) For anti-sweat heaters on coolers (if included): Without
timers, control system or other demand-based control, PTO = 0
percent. With timers, control system or other demand-based control,
PTO = 75 percent. For anti-sweat heaters on freezers (if included):
Without timers, control system or other auto-shut-off systems, PTO =
0 percent. With timers, control system or other demand-based
control, PTO = 50 percent.
(3) For all other electricity consuming devices: Without timers,
control system, or other auto-shut-off systems, PTO = 0 percent. If
it can be demonstrated that the device is controlled by a
preinstalled timer, control system or other auto-shut-off system,
PTO = 25 percent.
(b) Calculate the power usage for each type of electricity
consuming device, Pnd-comp,u,t, kWh/day, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.055
Where:
u = the index for each type of electricity-consuming device located
on either (1) the interior facing side of the display door or within
the inside portion of the display door, (2) the exterior facing side
of the display door, or (3) any combination of (1) and (2). For
purposes of this calculation, the interior index is represented by u
= int and the exterior index is represented by u = ext. If the
electrical component is both on the interior and exterior side of
the display door then u = int. For anti-sweat heaters sited anywhere
in the display door, 75 percent of the total power is attributed to
u = int and 25 percent of the total power is attributed to u = ext;
t = index for each type of electricity consuming device with
identical rated power;
Prated,u,t = rated power of each component, of type t,
kW;
PTOu,t = percent time off, for device of type t, %; and
nu,t = number of devices at the rated power of type t,
unitless.
(c) Calculate the total electrical energy consumption for
interior and exterior power, Pnd-tot, int (kWh/day) and
Pnd-tot, ext (kWh/day), respectively, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.056
[GRAPHIC] [TIFF OMITTED] TR15AP11.057
Where:
t = index for each type of electricity consuming device with
identical rated power;
Pnd-comp,int, t = the energy usage for an electricity
consuming device sited on the internal facing side or internal to
the
[[Page 21611]]
non-display door, of type t, kWh/day; and
Pnd-comp,ext, t = the energy usage for an electricity
consuming device sited on the external facing side of the non-
display door, of type t, kWh/day. For anti-sweat heaters,
(d) Calculate the total electrical energy consumption,
Pnd-tot, kWh/day, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.058
Where:
Pnd-tot,int = the total interior electrical energy usage
for the non-display door, of type t, kWh/day; and
Pnd-tot,ext = the total exterior electrical energy usage
for the non-display door, of type t, kWh/day.
4.5.3 Total Indirect Electricity Consumption Due to Electrical Devices
(a) Select Energy Efficiency Ratio (EER), as follows:
(1) For coolers, use EER = 12.4 Btu/Wh
(2) For freezers, use EER = 6.3 Btu/Wh
(b) Calculate the additional refrigeration energy consumption
due to thermal output from electrical components associated with the
non-display door, Cnd-load, kWh/day, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.059
Where:
EER = EER of walk-in cooler or freezer, Btu/W-h; and
Pnd-tot,int = the total interior electrical energy
consumption for the non-display door, kWh/day.
4.5.4 Total Non-Display Door Energy Consumption
(a) Select Energy Efficiency Ratio (EER), as follows:
(1) For coolers, use EER = 12.4 Btu/W-h
(2) For freezers, use EER = 6.3 Btu/W-h
(b) Calculate the total daily energy consumption due to thermal
load, End, thermal, kWh/day, as follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.060
Where:
Qcond-nd = the conduction load through the non-display
door, Btu/hr; and
EER = EER of walk-in (cooler or freezer), Btu/W-h.
(c) Calculate the total energy, End,tot, kWh/day, as
follows:
[GRAPHIC] [TIFF OMITTED] TR15AP11.061
Where:
End, thermal = the total daily energy consumption due to
thermal load for the non-display door, kWh/day;
Pnd-tot = the total electrical energy consumption, kWh/
day; and
Cnd-load = additional refrigeration load due to thermal
output from electrical components contained on the inside face of
the non-display door, kWh/day.
5.0 Test Methods and Measurements
5.1 Measuring Floor and Non-Floor Panel U-Factors
Follow the test procedure in ASTM C1363, (incorporated by
reference; see Sec. 431.303), exactly, with these exceptions:
(1) Test Sample Geometry Requirements
(i) Two (2) panels, 8 ft. 1 ft. long and 4 ft.
1 ft. wide must be used.
(ii) The panel edges must be joined using the manufacturer's
panel interface joining system (e.g., camlocks, standard gasketing,
etc.).
(iii) The Panel Edge Test Region, see figure 1, must be cut
using the following dimensions:
1. If the panel contains framing members (e.g. a wood frame),
then the width of edge (W) must be as wide as any framing member
plus 2 in. 0.25 in. For example, if the face of the
panel contains 1.5 in. thick framing members around the edge of the
panel, then width of edge (W) = 3.5 in. 0.25 in and the
Panel Edge Test Region would be 7 in. 0.5 in. wide.
2. If the panel does not contain framing members, then the width
of edge (W) must be 4 in. 0.25 in.
3. Walk-in panels that utilize vacuum insulated panels (VIP) for
insulation, width of edge (W) = the lesser of 4.5 in. 1
in. or the maximum width that does not cause the VIP to be pierced
by the cutting device when the edge region is cut.
(iv) Panel Core Test Region of length Y and height Z, see Figure
1, must also be cut from one of the two panels such that panel
length = Y + X, panel height = Z + X where X = 2W.
[[Page 21612]]
[GRAPHIC] [TIFF OMITTED] TR15AP11.062
(2) Testing Conditions
(i) The air temperature on the ``hot side'', as denoted in ASTM
C1363, of the non-floor panel should be maintained at 75 [deg]F
1 [deg]F.
1. Exception: When testing floor panels, the air temperature
should be maintained at 55 [deg]F 1 [deg]F.
(ii) The temperature on the ``cold side'', as denoted in ASTM
C1363, of the panel should be maintained at 35 [deg]F 1
[deg]F for the panels used for walk-in coolers and -10 [deg]F 1 [deg]F for panels used for walk-in freezers.
(iii) The air velocity must be maintained as natural convection
conditions as described in ASTM C1363. The test must be completed
using the masked method and with surround panel in place as
described in ASTM C1363.
(3) Required Test Measurements
(i) Non-floor Panels
1. Panel Edge Region U-factor: Unf, edge
2. Panel Core Region U-factor: Unf, core
(ii) Floor Panels
1. Floor Panel Edge Region U-factor: Ufp, edge
2. Floor Panel Core Region U-factor: Ufp, core
5.2 Measuring Long Term Thermal Resistance (LTTR) of Insulating
Foam
Follow the test procedure in Annex C of DIN EN 13164 or Annex C
of DIN EN 13165 (as applicable), (incorporated by reference; see
Sec. 431.303), exactly, with these exceptions:
(1) Temperatures During Thermal Resistance Measurement
(i) For freezers: 35 [deg]F 1 [deg]F must be used
(ii) For coolers: 55 [deg]F 1 must be used
(2) Sample Panel Preparation
(i) A 800mm x 800mm square (x thickness of the panel) section
cut from the geometric center of the panel that is being tested must
be used as the sample for completing DIN EN 13165.
(ii) A 500mm x 500mm square (x thickness of the panel) section
cut from the geometric center of the panel that is being tested must
be used as the sample for completing DIN EN 13164.
(3) Required Test Measurements
(i) Non-floor Panels
1. Long Term Thermal Resistance: RLTTR,nf
(ii) Floor Panels
1. Long Term Thermal Resistance: RLTTR,fp
5.3 U-factor of Doors and Display Panels
(a) Follow the procedure in NFRC 100, (incorporated by
reference; see Sec. 431.303), exactly, with these exceptions:
(1) The average convective heat transfer coefficient on both
interior and exterior surfaces of the door should be based on the
coefficients described in section 4.3 of NFRC 100.
(2) Internal conditions:
(i) Air temperature of 35 [deg]F (1.7 [deg]C) for cooler doors
and -10 [deg]F (-23.3 [deg]C) for freezer doors
(ii) Mean inside radiant temperature must be the same as shown
in section 5.3(a)(2)(i), above.
(3) External conditions
(i) Air temperature of 75 [deg]F (23.9 [deg]C)
(ii) Mean outside radiant temperature must be the same as
section 5.3(a)(3)(i), above.
(4) Direct solar irradiance = 0 W/m\2\ (Btu/h-ft\2\).
(b) Required Test Measurements
(i) Display Doors and Display Panels
1. Thermal Transmittance: Udd
(ii) Non-Display Door
1. Thermal Transmittance: Und
[FR Doc. 2011-8690 Filed 4-14-11; 8:45 am]
BILLING CODE 6450-01-P