[Federal Register Volume 84, Number 195 (Tuesday, October 8, 2019)]
[Notices]
[Pages 53710-53716]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-21935]
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DEPARTMENT OF ENERGY
[Case Number 2019-006; EERE-2019-BT-WAV-0020]
Energy Conservation Program: Petition for Waiver of Bradford
White Corporation From the Department of Energy Consumer Water Heaters
Test Procedure and Grant of Interim Waiver
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of petition for waiver and grant of an interim waiver,
and request for comments.
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SUMMARY: This document announces receipt of and publishes a petition
for waiver from Bradford White Corporation (``BWC''), which seeks a
waiver for a specified consumer water heater basic model from the U.S.
Department of Energy (``DOE'') test procedure used for determining the
efficiency of consumer water heaters. BWC asserts that for that
identified basic model, application of the calculation specified in the
DOE test procedure to determine recovery efficiency yields an
``artificially high'' value that in turn results in a lower overall
uniform energy factor value. Consequently, BWC seeks to use an
alternate test procedure to address issues involved in testing the
basic model identified in its petition. More specifically, BWC has
requested that DOE waive the equation for calculating recovery
efficiency of the consumer gas-fired storage water heater basic model
for which the first occurrence of the main burner cutting out (``cut-
out'') occurs during a draw. Instead, BWC requests that the recovery
efficiency for this water heater be calculated using a revised recovery
efficiency equation that accounts for the first cut-out occurring
during a draw. For the reasons discussed in this document, DOE grants
BWC an interim waiver from the DOE's consumer water heater test
procedure for the basic model listed in the interim waiver, subject to
use of the alternate test procedure as set forth in the Interim Waiver
Order. DOE solicits comments, data, and information concerning BWC's
petition, its suggested alternate test procedure, and the alternate
test procedure in the Interim Waiver Order so as to inform its final
decision on BWC's waiver request.
DATES: Written comments and information will be accepted on or before
November 7, 2019.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at http://www.regulations.gov.
Alternatively, interested persons may submit comments, identified by
case number ``2019-006'' and Docket number ``EERE-2019-BT-WAV-0020,''
by any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting comments.
Email: [email protected]. Include Case No.
2019-006 in the subject line of the message.
Postal Mail: Appliance and Equipment Standards Program,
U.S. Department of Energy, Office of Energy Efficiency and Renewable
Energy, Building Technologies Office, Mailstop EE-5B, Petition for
Waiver Case No. 2019-006, 1000 Independence Avenue SW, Washington, DC
20585-0121. If possible, please submit all items on a compact disc
(``CD''), in which case it is not necessary to include printed copies.
Hand Delivery/Courier: Appliance and Equipment Standards
Program, U.S. Department of Energy, Building Technologies Office, 950
L'Enfant Plaza SW, 6th Floor, Washington, DC 20024. Telephone: (202)
287-1445. If possible, please submit all items on a ``CD'', in which
case it is not necessary to include printed copies.
No telefacsimilies (faxes) will be accepted. For detailed
instructions on submitting comments and additional information on this
process, see section V of this document.
Docket: The docket, which includes Federal Register notices,
comments, and other supporting documents/materials, is available for
review at http://www.regulations.gov. All documents in the docket are
listed in the http://www.regulations.gov index. However, some documents
listed in the index, such as those containing information that is
exempt from public disclosure, may not be publicly available.
The docket web page can be found at https://www.regulations.gov/docket?D=EERE-2019-BT-WAV-0020. The docket web page contains
instruction on how to access all documents, including public comments,
in the docket. See section V for information on how to submit comments
through http://www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Ms. Lucy deButts, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Office, Mailstop
EE-5B, 1000 Independence Avenue SW, Washington, DC 20585-0121.
Telephone: (202) 287-1604. Email: [email protected].
[[Page 53711]]
Mr. Eric Stas, U.S. Department of Energy, Office of the General
Counsel, Mail Stop GC-33, Forrestal Building, 1000 Independence Avenue
SW, Washington, DC 20585-0103. Telephone: (202) 586-5827. Email:
[email protected].
SUPPLEMENTARY INFORMATION:
I. Background and Authority
The Energy Policy and Conservation Act, as amended (``EPCA''),\1\
authorizes the U.S. Department of Energy (``DOE'') to regulate the
energy efficiency of a number of consumer products and certain
industrial equipment. (42 U.S.C. 6291-6317) Title III, Part B \2\ of
EPCA established the Energy Conservation Program for Consumer Products
Other Than Automobiles, which sets forth a variety of provisions
designed to improve energy efficiency for certain types of consumer
products. These products include consumer water heaters, the focus of
this document. (42 U.S.C. 6292(a)(4))
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\1\ All references to EPCA in this document refer to the statute
as amended through America's Water Infrastructure Act of 2018,
Public Law 115-270 (Oct. 23, 2018).
\2\ For editorial reasons, upon codification in the U.S. Code,
Part B was redesignated as Part A.
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The energy conservation program under EPCA consists essentially of
four parts: (1) Testing, (2) labeling, (3) Federal energy conservation
standards, and (4) certification and enforcement procedures. Relevant
provisions of EPCA include definitions (42 U.S.C. 6291), test
procedures (42 U.S.C. 6293), labeling provisions (42 U.S.C. 6294),
energy conservation standards (42 U.S.C. 6295), and the authority to
require information and reports from manufacturers (42 U.S.C. 6296).
The Federal testing requirements consist of test procedures that
manufacturers of covered products must use as the basis for: (1)
Certifying to DOE that their products comply with the applicable energy
conservation standards adopted pursuant to EPCA (42 U.S.C. 6295(s)),
and (2) making representations about the efficiency of that product (42
U.S.C. 6293(c)). Similarly, DOE must use these test procedures to
determine whether the product complies with relevant standards
promulgated under EPCA. (42 U.S.C. 6295(s))
Under 42 U.S.C. 6293, EPCA sets forth the criteria and procedures
DOE is required to follow when prescribing or amending test procedures
for covered products. EPCA requires that any test procedures prescribed
or amended under this section must be reasonably designed to produce
test results which reflect the energy efficiency, energy use, or
estimated annual operating cost of a covered product during a
representative average use cycle or period of use and requires that
test procedures not be unduly burdensome to conduct. (42 U.S.C.
6293(b)(3)) The test procedure for consumer water heaters is contained
in the Code of Federal Regulations (``CFR'') at 10 CFR part 430,
subpart B, appendix E, Uniform Test Method for Measuring the Energy
Consumption of Water Heaters.
Under 10 CFR 430.27, any interested person may submit a petition
for waiver from DOE's test procedure requirements. DOE will grant a
waiver from the test procedure requirements if DOE determines either
that the basic model for which the waiver was requested contains a
design characteristic that prevents testing of the basic model
according to the prescribed test procedures, or that the prescribed
test procedures evaluate the basic model in a manner so
unrepresentative of its true energy consumption characteristics as to
provide materially inaccurate comparative data. 10 CFR 430.27(f)(2). A
petitioner must include in its petition any alternate test procedures
known to the petitioner to evaluate the basic model in a manner
representative of its energy consumption characteristics. 10 CFR
430.27(b)(1)(iii). DOE may grant the waiver subject to conditions,
including adherence to alternate test procedures. 10 CFR 430.27(f)(2).
As soon as practicable after the granting of any waiver, DOE will
publish in the Federal Register a notice of proposed rulemaking to
amend its regulations so as to eliminate any need for the continuation
of such waiver. 10 CFR 430.27(l). As soon thereafter as practicable,
DOE will publish in the Federal Register a final rule to that effect.
Id.
The waiver process also provides that DOE may grant an interim
waiver if it appears likely that the underlying petition for waiver
will be granted and/or if DOE determines that it would be desirable for
public policy reasons to grant immediate relief pending a determination
on the underlying petition for waiver. 10 CFR 430.27(e)(2). Within one
year of issuance of an interim waiver, DOE will either: (i) Publish in
the Federal Register a determination on the petition for waiver; or
(ii) publish in the Federal Register a new or amended test procedure
that addresses the issues presented in the waiver. 10 CFR 430.27(h)(1).
When DOE amends the test procedure to address the issues presented
in a waiver, the waiver will automatically terminate on the date on
which use of that test procedure is required to demonstrate compliance.
10 CFR 430.27(h)(2).
II. Bradford White Corporation's Petition for Waiver and Application
for Interim Waiver
On July 3, 2019, BWC filed a petition for waiver and a petition for
interim waiver from the test procedure for consumer water heaters set
forth at 10 CFR part 430, subpart B, appendix E.\3\ The test procedure
for water heaters includes a 24-hour Simulated Use Test (SUT) which
consists of a series of hot water draws and standby periods during
which the energy consumption of the water heater is measured. For
storage-type water heaters, as the stored hot water loses heat through
hot water draws and standby losses, the heat source (e.g., the burner,
heat pump, electric heating element) will turn on or ``cut-in'' to heat
water within the tank as needed to maintain the setpoint temperature of
the thermostat. Once the thermostat is satisfied, the heat source will
turn off or ``cut-out.'' The time during which the heat source is on is
referred to as a ``recovery period'' because the water heater is
recovering the heat lost from the stored water. The first recovery
period of the 24-hour SUT is used to calculate the ``recovery
efficiency'' of the water heater, which impacts the overall measure of
efficiency (i.e., the uniform energy factor (UEF)). BWC stated that for
gas and heat pump storage-type consumer water heaters for which the
first cut-out of the 24-hour SUT occurs in the middle of one of the
draws, the use of average water temperatures in the DOE test procedure
calculation for recovery efficiency artificially inflates the
calculated energy delivered from the system. BWC asserted that this
yields an artificially higher recovery efficiency and results in a
lower overall UEF. In support of its waiver request, BWC submitted test
data for an individual model based on the platform of the basic model
for which BWC seeks a waiver.
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\3\ The specific basic model for which the petition applies is
the consumer water heater basic model RG2PV50S*N. Although BWC
initially included 50 consumer water heater basic models in its July
3, 2019 petition for waiver, BWC later limited the request to
include only the RG2PV50S*N basic model via email correspondence on
July 30, 2019. This email correspondence is included in the docket
at: https://www.regulations.gov/docket?D=EERE-2019-BT-WAV-0020.
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BWC also requests an interim waiver from the existing DOE test
procedure. DOE will grant an interim waiver if it appears likely that
the petition for waiver will be granted and/or if DOE determines that
it would be desirable for public policy reasons to grant
[[Page 53712]]
immediate relief pending a determination of the petition for waiver.
See 10 CFR 430.27(e)(2).
Based on the assertions made in support of the petition, absent an
interim waiver, DOE has initially determined that the DOE test
procedure yields unrepresentative results for a consumer water heater
that completes the first recovery in the middle of a draw.
Specifically, calculating the energy delivered during the first
recovery period by using the total mass and average water temperatures
across multiple draws to determine the energy delivered yields a higher
recovery efficiency for those units for which the first cut-out of the
24-hour SUT occurs during a hot water draw. This in turn would result
in a lower overall UEF that is not representative of its true energy
efficiency.
III. Requested Alternate Test Procedure
EPCA requires that manufacturers use DOE test procedures when
making representations about the energy consumption and energy
consumption costs of covered products. (42 U.S.C. 6293(c)) Consistency
is important when making representations about the energy efficiency of
products, including when demonstrating compliance with applicable DOE
energy conservation standards. Pursuant to its regulations at 10 CFR
430.27, and after consideration of public comments on the petition, DOE
may establish in a subsequent Decision and Order an alternate test
procedure for the basic model addressed by the interim waiver.
BWC seeks to use an alternate test procedure to test and rate one
consumer water heater basic model. Specifically, BWC seeks to test the
affected consumer water heater basic model according to the DOE test
procedure at 10 CFR part 430, subpart B, appendix E, except that the
recovery efficiency equation in section 6.3.2 would be replaced with an
alternate equation as shown below. Instead of calculating the recovery
efficiency using the total mass of hot water drawn and average water
temperature rise across all draws that occur until the end of the first
recovery period as is done in the DOE test procedure, the requested
alternate recovery efficiency equation computes the energy delivered
during the first recovery using the mass of hot water drawn and water
temperature rise for each draw individually and sums them. As submitted
by BWC, the alternative test procedure would replace the equation in
section 6.3.2 of Appendix E with the following equation for determining
recovery efficiency, [eta]r:
[GRAPHIC] [TIFF OMITTED] TN08OC19.031
Where:
Nr = number of draws that the first recovery period
occurred during.
First Recovery Period: is defined by when the main burner of a
storage water heater is lit and raising the temperature of the
stored water until cut-out; in the case the cut-out* occurs during a
subsequent draw, the first recovery period is to include the time
until the draw of water from the tank stops.
mi = Mass of draw i.
Cpi = Average Specific heat of draw i.
*If after the first cut-out occurs during a subsequent draw, a
subsequent cut-in occurs prior to the draw completion, the first
recovery period is to include the time until the subsequent cut-out
occurs, prior to another draw.
Based on the Federal test procedure DOE understands the remaining
variables in the equation submitted by BWC to be as follows:
Tdel,i = average water outlet temperature measured during
ith draw of the first recovery period, [deg]F ([deg]C).
Tin,i = average water inlet temperature measured during
the ith draw of the first recovery period, [deg]F ([deg]C).
Vst = as defined in section 6.3.1.
[rho]2 = density of stored hot water evaluated at
(Tmax,1 + To)/2, lb/gal (kg/L).
Cp2 = specific heat of stored hot water evaluated at
(Tmax,1 + To)/2, Btu/(lb[middot][deg]F) (kJ/
(kg[middot][deg]C).
Tmax,1 = maximum mean tank temperature recorded after
cut-out following the first recovery of the 24-hour simulated use
test, [deg]F ([deg]C).
To = maximum mean tank temperature recorded prior to the
first draw of the 24-hour simulated-use test, [deg]F ([deg]C).
Qr = Energy consumption of water heater from the
beginning of the test to the end of the first recovery period.
IV. Grant of an Interim Waiver
DOE has reviewed BWC's application for an interim waiver, the
alternate test procedure requested by BWC, and confidential test data
submitted by BWC, as well as test data from prior DOE testing of
consumer water heaters. For the specified consumer water heater basic
model, BWC's suggested calculation for recovery efficiency, which uses
a summation of measurements for each individual draw rather than
average values to determine the energy in the delivered hot water
during the first recovery period, results in a more accurate
calculation of recovery efficiency when the first cut-out occurs during
a draw, and avoids artificial inflating of the recovery efficiency
(resulting in a lower UEF value) that occurs under the calculation in
DOE's current test procedure.
BWC's petition for waiver suggests that this issue may not occur
for every individual model within a basic model designation. DOE has
modified the suggested alternate test procedure to specify that the
alternate calculation applies only if during testing the first cut-out
of the 24-hour SUT occurs during a hot water draw.
Based on DOE's review of the alternate test procedure suggested by
BWC, as modified by DOE, it appears to allow for the accurate
measurement of efficiency of the specified basic model, while
alleviating the testing problems associated with BWC's implementation
of water heating testing for this basic model. Consequently, DOE has
determined that BWC's petition for waiver will likely be granted.
Furthermore, DOE has determined that it is desirable for public policy
reasons to grant BWC immediate relief pending a determination of the
petition for waiver.
For the reasons stated, DOE has granted an interim waiver to BWC
for the specified consumer water heater basic model in BWC's petition.
Therefore, DOE has issued an Order stating:
(1) BWC must test and rate the following consumer water heater
basic model with the alternate test procedure set forth in paragraph
(2).
------------------------------------------------------------------------
Brand Basic model
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BRADFORD WHITE, JETGLAS............................... RG2PV50S*N
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(2) The alternate test procedure for the BWC basic model referenced
in paragraph (1) of this Order is the test procedure for consumer water
heaters prescribed by DOE at 10 CFR part 430, subpart B, appendix E,
except for equation 6.3.2, as detailed below. All other requirements of
appendix E and DOE's regulations remain applicable.
[[Page 53713]]
The changes to section 6.3.2 of Appendix E read as follows:
6.3.2 Recovery Efficiency.
6.3.2.1 Except as provided in section 6.3.2.2 of this Appendix,
the recovery efficiency for gas storage-type water heaters,
[eta]r, is computed as:
[GRAPHIC] [TIFF OMITTED] TN08OC19.032
Where:
M1 = total mass removed from the start of the 24-hour
simulated-use test to the end of the first recovery period, lb (kg),
or, if the volume of water is being measured,
M1 = V1[rho]1
Where:
V1 = total volume removed from the start of the 24-hour
simulated-use test to the end of the first recovery period, gal (L).
[rho]1 = density of the water at the water temperature
measured at the point where the flow volume is measured, lb/gal (kg/
L).
Cp1 = specific heat of the withdrawn water evaluated at
(Tdel,1 + Tin,1)/2, Btu/(lb[middot][deg]F)
(kJ/(kg[middot][deg]C))
Tdel,1 = average water outlet temperature measured during
the draws from the start of the 24-hour simulated-use test to the
end of the first recovery period, [deg]F ([deg]C).
Tin,1 = average water inlet temperature measured during
the draws from the start of the 24-hour simulated-use test to the
end of the first recovery period, [deg]F ([deg]C).
Vst = as defined in section 6.3.1.
[rho]2 = density of stored hot water evaluated at
(Tmax,1 + To)/2, lb/gal (kg/L).
Cp2 = specific heat of stored hot water evaluated at
(Tmax,1 + To)/2, Btu/(lb[middot][deg]F) (kJ/
(kg[middot][deg]C).
Tmax,1 = maximum mean tank temperature recorded after
cut-out following the first recovery of the 24-hour simulated use
test, [deg]F ([deg]C).
To = maximum mean tank temperature recorded prior to the
first draw of the 24-hour simulated-use test, [deg]F ([deg]C).
Qr = the total energy used by the water heater between
cut-out prior to the first draw and cut-out following the first
recovery period, including auxiliary energy such as pilot lights,
pumps, fans, etc., Btu (kJ). (Electrical auxiliary energy shall be
converted to thermal energy using the following conversion: 1 kWh =
3412 Btu.)
6.3.2.2 For gas storage-type water heaters, if the first cut-out
occurs during a draw, the recovery efficiency, [eta]r, is
computed as:
[GRAPHIC] [TIFF OMITTED] TN08OC19.033
Where:
Nr = number of draws occurring during the first recovery
period. The first recovery period is defined by the time when the
main burner of a storage water heater is lit (``cut-in'') and
continues during the temperature rise of the stored water until the
main burner cuts-off (``cut-out''); if the cut-out occurs during a
subsequent draw, the first recovery period includes the time until
the draw of water from the tank stops. If, after the first cut-out
occurs but during a subsequent draw, a subsequent cut-in occurs
prior to the draw completion, the first recovery period includes the
time until the subsequent cut-out occurs, prior to another draw.
mi = mass of draw i.
Cpi = average specific heat of draw i.
Tdel,i = average water outlet temperature measured during
ith draw of the first recovery period, [deg]F ([deg]C).
Tin,i = average water inlet temperature measured during
the ith draw of the first recovery period, [deg]F ([deg]C).
Vst = as defined in section 6.3.1.
[rho]2 = density of stored hot water evaluated at
(Tmax,1 + To)/2, lb/gal (kg/L).
Cp2 = specific heat of stored hot water evaluated at
(Tmax,1 + To)/2, Btu/(lb[middot][deg]F) (kJ/
(kg[middot][deg]C).
Tmax,1 = maximum mean tank temperature recorded after
cut-out following the first recovery of the 24-hour simulated use
test, [deg]F ([deg]C).
To = maximum mean tank temperature recorded prior to the
first draw of the 24-hour simulated-use test, [deg]F ([deg]C).
Qr = energy consumption of water heater from the
beginning of the test to the end of the first recovery period.
(3) Representations. BWC must make representations about the
efficiency of the basic model listed in paragraph (1) for compliance,
marketing, or other purposes only to the extent that the basic model
has been tested in accordance with the provisions in this alternate
test procedure and such representations fairly disclose the results of
such testing.
(4) This interim waiver shall remain in effect according to the
provisions of 10 CFR 430.27.
(5) This interim waiver is issued to BWC on the condition that
information and test data provided by BWC are valid. DOE may rescind or
modify this waiver at any time if it determines the factual basis
underlying the petition for waiver is incorrect, or the results from
the alternate test procedure are unrepresentative of a basic model's
true energy consumption characteristics. 10 CFR 430.27(k)(1). Likewise,
BWC may request that DOE rescind or modify the interim waiver if BWC
discovers an error in the information provided to DOE as part of its
petition, determines that the interim waiver is no longer needed, or
for other appropriate reasons. 10 CFR 430.27(k)(2).
(6) BWC remains obligated to fulfill any certification requirements
set forth at 10 CFR part 429.
DOE makes decisions on waivers and interim waivers for only those
basic models specifically set out in the petition, not future models
that may be manufactured by the petitioner. BWC may submit a new or
amended petition for waiver and application for an interim waiver, as
appropriate, for additional basic models of consumer water heaters.
Alternatively, if appropriate, BWC may request that DOE extend the
scope of a waiver or an interim waiver to include additional basic
models employing the same technology as the basic model(s) set forth in
the original petition consistent with 10 CFR 430.27(g).
V. Request for Comments
DOE is publishing BWC's petition for waiver in its entirety as
originally submitted, pursuant to 10 CFR 430.27(b)(1)(iv), absent any
confidential business information.\4\ The petition includes a suggested
alternate test procedure, as specified in section III of this document,
to determine the
[[Page 53714]]
efficiency of BWC's specified consumer water heater, which DOE modified
slightly in the grant of an interim waiver as discussed in section IV
of this document. DOE may consider including the alternate procedure
specified in the Interim Waiver Order in a subsequent Decision and
Order.
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\4\ DOE is publishing the July 3, 2019 petition for waiver as
initially submitted by BWC, including the list of basic models in
Attachment 1 that BWC included in its petition for waiver. In
subsequent email correspondence on July 30, 2019, BWC limited the
petition to include only the RG2PV50S*N basic model. This email
correspondence is included in the docket at: https://www.regulations.gov/docket?D=EERE-2019-BT-WAV-0020.
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DOE invites all interested parties to submit in writing by November
7, 2019, comments and information on all aspects of the petition,
including the alternate test procedure. Pursuant to 10 CFR 430.27(d),
any person submitting written comments to DOE must also send a copy of
such comments to the petitioner. The contact information for the
petitioner is Eric Truskoski, [email protected], 725
Talamore Dr., Ambler, PA 19002.
Submitting comments via http://www.regulations.gov. The http://www.regulations.gov web page will require you to provide your name and
contact information. Your contact information will be viewable to DOE
Building Technologies staff only. Your contact information will not be
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name (if any), and submitter representative name (if any). If your
comment cannot be processed properly because of technical difficulties,
DOE will use this information to contact you. If DOE cannot read your
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However, your contact information will be publicly viewable if you
include it in the comment or in any documents attached to your comment.
Any information that you do not want to be publicly viewable should not
be included in your comment, nor in any document attached to your
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organization names, correspondence containing comments, and any
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Do not submit to http://www.regulations.gov information for which
disclosure is restricted by statute, such as trade secrets and
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information submitted. For information on submitting CBI, see the
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DOE processes submissions made through http://www.regulations.gov
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Submitting comments via email, hand delivery/courier, or postal
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information to be publicly viewable, do not include it in your comment
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Include contact information each time you submit comments, data,
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Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
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time.
Confidential Business Information. Pursuant to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email, postal mail, or hand delivery/courier two well-marked copies:
One copy of the document marked ``confidential'' including all the
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marked ``non-confidential'' with the information believed to be
confidential deleted. Submit these documents via email or on a CD, if
feasible. DOE will make its own determination about the confidential
status of the information and treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
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It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
Signed in Washington, DC, on September 23, 2019.
Alexander N. Fitzsimmons,
Acting Deputy Assistant Secretary for Energy Efficiency, Energy
Efficiency and Renewable Energy.
July 3, 2019
U.S. Department of Energy, Building Technologies Program, MS EE-2J Test
Procedure Waivers, 1000 Independence Ave. SW, Washington, DC 20585-0121
Re: Waiver for Test Procedure for Residential Water Heaters
To Whom It May Concern:
Pursuant to the provisions of 10 CFR 430.27(m), Bradford White
Corporation (BWC) is hereby applying for a waiver of the test procedure
for calculating the recovery efficiency of residential gas and heat
pump storage-type water heaters with a rated storage volume greater
than or equal to two gallons, 10 CFR 430, Subpart B, Appendix E,
Section 6.3.2. The calculation of the recovery efficiency is used as
part of the 24-hour Simulated Use Test (SUT) used to calculate the
efficiency, in terms of Uniform Energy Factor (UEF), for residential
water heaters.
Basic Models for This Waiver Petition
The basic models that BWC is respectfully requesting a waiver,
including in the interim are listed in
[[Page 53715]]
Attachment 1. This is for both the ``BRADFORD WHITE'' and ``JETGLAS''
brand names.
Basis for Requested Waiver
When the first cut-out during the SUT occurs in the middle of one
of the draws, the averaging of these temperatures artificially inflates
the calculated energy delivered from the system, which yields an
artificially higher calculated recovery efficiency. With an
artificially higher recovery efficiency, the resulting UEF is lower.
This means that a manufacturer that has a product, as an unintended
result of its design, that completes its recovery in the middle of a
draw would be disadvantaged versus a competitor that has a similarly
designed product but completes its first cut-out between draws, which
will result in less units sold.
The manner in which a product initiates a recovery and completes
its recovery is dependent on a multitude of factors including but not
limited to: Storage volume; input; diptube length; diptube design; tank
construction/geometry; thermostat placement; and thermostat
differential. It is difficult to ascertain which one or more of these
design characteristics would result in the product completing its
recovery while a draw is occurring. Regardless, the resulting manner
that a product recovers from a water draw should not penalize one
product over another.
List of Manufacturers
The list of manufacturers of all other basic models of residential
gas, oil, and heat pump storage- type water heaters with a rated
storage volume greater than or equal to two gallons marketed in the
United States known to BWC is included as Attachment 2.
Proposed Alternative Test Procedure
BWC has reviewed the alternate equation, included as Attachment 3,
for calculating recovery efficiency of residential gas, oil, and heat
pump storage-type water heaters with a rated storage volume greater
than or equal to two gallons with the Air-Conditioning, Heating, &
Refrigeration Institute (AHRI), and other interested parties, and
believes it provides a more accurate calculation of recovery
efficiency. The proposed equation accounts for a recovery that could
end in the middle of any draw or in between draws.
Furthermore, ASHRAE Standard Project Committee 118.2 has reviewed
this equation and included it in the most recent draft of their
standard, Method of Testing for Rating Residential Water Heaters. This
draft will shortly be sent out for public review and comment. We
respectfully request DOE grant a waiver to use this alternative
equation in lieu of the procedure specified in the current DOE
efficiency test procedure.
Interim Waiver Request
Bradford White Corporation also petitions for an interim waiver to
allow us to use the equation shown in Attachment 3 to calculate the
recovery efficiency of the identified basic models. We believe it is in
both our interest and DOE's interest to have an interim test procedure,
which provides a more accurate calculation of the recovery efficiency
of the identified basic models.
If BWC is not granted an interim waiver, BWC will continue to be
put at a competitive advantage where the resulting UEF will be lower
(for the reasons highlighted above) than a similarly designed
competitive model, which will result in less units sold.
Respectfully submitted,
Bradford White Corporation
/s/Eric Truskoski
Eric Truskoski
Director of Government and Regulatory Affairs
Attachments:
1. List of basic models manufactured by Bradford White Corporation.
2. List of manufacturers of residential gas and heat pump storage-
type water heaters with a rated storage volume greater than or equal to
two gallons
3. Alternative recovery efficiency calculation
[Original List Submitted by Bradford White Corporation]
Attachment 1--List of Basic Models manufactured by Bradford White
Corporation
------------------------------------------------------------------------
Brand Names Model No.
------------------------------------------------------------------------
``BRADFORD WHITE'' and ``JETGLAS''........ RC2PV50H*N
``BRADFORD WHITE'' and ``JETGLAS''........ RE2H50S*[hyphen]*****
``BRADFORD WHITE'' and ``JETGLAS''........ RE2H80T*[hyphen]*****
``BRADFORD WHITE'' and ``JETGLAS''........ RG130T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG140T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG150T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG1D30T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG1D40S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG1D40T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG1D50T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG1PV40S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG1PV50S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG1PV55H*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2100H*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG230S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG230T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG240S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG240T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG250H*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG250L*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG250S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG250T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG255H*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG275H*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2D40S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2D50S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2DV40S*N[hyphen]***
``BRADFORD WHITE'' and ``JETGLAS''........ RG2DV50H*N[hyphen]***
``BRADFORD WHITE'' and ``JETGLAS''........ RG2DV50S*N[hyphen]***
``BRADFORD WHITE'' and ``JETGLAS''........ RG2DVMH30T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2DVMH40T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2F40S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2F50S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2MH30T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2MH40T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2PDV40S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2PDV50H*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2PDV50S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2PDV75H*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2PV40S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2PV40T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2PV50H*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2PV50S*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2PV50T*N
``BRADFORD WHITE'' and ``JETGLAS''........ RG2PV75H*N
``BRADFORD WHITE'' and ``JETGLAS''........ URG250H*N
``BRADFORD WHITE'' and ``JETGLAS''........ URG2DV50H*N[hyphen]***
``BRADFORD WHITE'' and ``JETGLAS''........ URG2DV50S*N[hyphen]***
``BRADFORD WHITE'' and ``JETGLAS''........ URG2PDV50H*N
``BRADFORD WHITE'' and ``JETGLAS''........ URG2PV50H*N
------------------------------------------------------------------------
[[Page 53716]]
Attachment 2--List of Manufacturers of Residential Gas, Oil, and Heat
Pump Storage-Type Water Heaters With a Rated Storage Volume Greater
Than or Equal to Two Gallons
Company:
A. O. Smith Corporation
Rheem Sales Company, Inc.
Bock Water Heaters, Inc.
GIANT Factories, Inc.
Bradford White Corp.
HTP Comfort Solutions LLC
Rinnai America Corporation
Vesta DS, Inc.
Vaughn Thermal Corporation
GD Midea Heating & Ventilating Equipment Co., Ltd.
Attachment 3--Alternative Recovery Efficiency Equation
How the current calculation is written:
[GRAPHIC] [TIFF OMITTED] TN08OC19.034
Where this calculation falls short is when our first cut[hyphen]out
occurs into or through subsequent draws. The definition of Tdel,1 and
Tin, 1 are currently defined as the ``average water temperature
measured during the Draws from the start of the 24 hour
simulated[hyphen]use test to the end of the first recovery period,
[deg]F, ([deg]C).''
Our Proposal
We would like to propose the calculation below to avoid inflating
the energy delivered that the averaging causes
[GRAPHIC] [TIFF OMITTED] TN08OC19.035
Nr = number of draws that the first recovery period occurred
during.
First Recovery Period: Is defined by when the main burner of a
storage water heater is lit and raising the temperature of the stored
water until cut[hyphen]out; in the case the cut-out * occurs during a
subsequent draw, the first recovery period is to include the time until
the draw of water from the tank stops.
mi = Mass of draw i.
Cpi = Average Specific heat of draw i.
Qr = Energy consumption of water heater from the beginning of the
test to the end of the first recovery period
For example, if Nr = 2
[GRAPHIC] [TIFF OMITTED] TN08OC19.036
\*\If after the first cut[hyphen]out occurs during a subsequent
draw, a subsequent cut[hyphen]in occurs prior to the draw completion,
the first recovery period is to include the time until the subsequent
cut[hyphen]out occurs, prior to another draw.
[FR Doc. 2019-21935 Filed 10-7-19; 8:45 am]
BILLING CODE 6450-01-P