Energy Conservation Program: Test Procedures for Walk-In Coolers and Walk-In Freezers, 55068-55108 [2010-21364]
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Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
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
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Supplemental notice of
proposed rulemaking.
AGENCY:
The U.S. Department of
Energy (DOE) previously published a
notice of proposed rulemaking to adopt
test procedures for measuring the energy
consumption of walk-in coolers and
walk-in freezers, pursuant to the Energy
Policy and Conservation Act (EPCA), as
amended. DOE is continuing to consider
those proposals, but is now soliciting
comments on several alternative
proposed options. Once any final test
procedure is effective, any
representation as to the energy use of
walk-in equipment must reflect the
results of testing that equipment using
the test procedure. Concurrently, DOE is
undertaking an energy conservation
standards rulemaking for this
equipment. If DOE receives data in this
test procedure rulemaking that are
pertinent to the development of
standards, it will use that data in
evaluating potential standards for this
equipment. Once these standards are
promulgated, the adopted test
procedures will be used to determine
compliance with the standards.
DATES: DOE will accept comments, data,
and information regarding this
supplemental notice of proposed
rulemaking (SNOPR) no later than
October 12, 2010. See section V of this
SNOPR for details.
ADDRESSES: Any comments submitted
must identify the SNOPR for Test
Procedures for Walk-In Coolers and
Walk-In Freezers and provide docket
number EERE–2008–BT–TP–0014 and/
or Regulation Identifier Number (RIN)
1904–AB85. Comments may be
submitted using any of the following
methods:
1. Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
2. E-mail: WICF–2008–TP–
0014@hq.doe.gov. Include the docket
number EERE–2008–BT–TP–0014 and/
or RIN 1904–AB85 in the subject line of
the message.
3. Postal Mail: Ms. Brenda Edwards,
U.S. Department of Energy, Building
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SUMMARY:
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Technologies Program, Mailstop EE–2J,
1000 Independence Avenue, SW.,
Washington, DC 20585–0121. Please
submit one signed original paper copy.
4. Hand Delivery/Courier: Ms. Brenda
Edwards, U.S. Department of Energy,
Building Technologies Program, 950
L’Enfant Plaza, 6th Floor, Washington,
DC 20024. Please submit one signed
original paper copy.
For detailed instructions on
submitting comments and additional
information on the rulemaking process,
see section V of this document.
Docket: For access to the docket to
read background documents or
comments received, visit the U.S.
Department of Energy, Resource Room
of the Building Technologies Program,
950 L’Enfant Plaza, 6th Floor,
Washington, DC 20024, (202) 586–2945,
between 9 a.m. and 4 p.m. Monday
through Friday, except Federal holidays.
Please call Ms. Brenda Edwards at the
above telephone number for additional
information regarding visiting the
Resource Room.
FOR FURTHER INFORMATION CONTACT: Mr.
Charles Llenza, U.S. Department of
Energy, Building Technologies Program,
EE–2J, 1000 Independence Avenue,
SW., Washington, DC 20585–0121, (202)
586–2192, Charles.Llenza@ee.doe.gov;
Mr. Michael Kido, U.S. Department of
Energy, Office of General Counsel, GC–
71, 1000 Independence Avenue, SW.,
Washington, DC 20585–0121, (202) 586–
8145, Michael.Kido@hq.doe.gov; or Ms.
Elizabeth Kohl, U.S. Department of
Energy, Office of General Counsel, GC–
71, 1000 Independence Avenue, SW.,
Washington, DC 20585–0121, (202) 586–
7796. E-mail:
Elizabeth.Kohl@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
I. Authority and Background
II. Summary of the Proposal
III. Discussion
A. Overall Issues
1. Definition of Walk-In Cooler or Freezer:
Temperature Limit
2. Testing and Compliance Responsibility
3. Basic Model of Envelope
4. Basic Model of Refrigeration Systems
B. Envelope
1. Heat Conduction Through Structural
Members
2. Use of ASTM C1303 or EN 13165:2009–
02
3. EN 13165:2009–02 as a Proposed
Alternative to ASTM C1303–10
4. Version of ASTM C1303
5. Improvements to ASTM C1303
Methodology
6. Heat Transfer Through Concrete
a. Floorless Coolers
b. Pre-Installed Freezer Floor
c. Insulated Floor Shipped by
Manufacturer
7. Walk-in Sited Within a Walk-In: A
‘‘Hybrid’’ Walk-In
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8. U–Factor of Doors and Windows
9. Walk-In Envelope Steady-State
Infiltration Test
10. Door Steady-State Infiltration Test
11. Door Opening Infiltration Assumptions
12. Infiltration Reduction Device
Effectiveness
13. Relative Humidity Assumptions
C. Refrigeration System
1. Definition of Refrigeration System
2. Version of AHRI 1250
3. Annual Walk-In Energy Factor
IV. Regulatory Review
A. Review Under Executive Order 12866
B. Review Under the National
Environmental Policy Act
C. Review Under the Regulatory Flexibility
Act
1. Reasons for the Proposed Rule
2. Objectives of and Legal Basis for the
Proposed Rule
3. Description and Estimated Number of
Small Entities Regulated
4. Description and Estimate of Compliance
Requirements
5. Duplication, Overlap, and Conflict With
Other Rules and Regulations
6. Significant Alternatives to the Rule
D. Review Under the Paperwork Reduction
Act
E. Review Under the Unfunded Mandates
Reform Act of 1995
F. Review Under the Treasury and General
Government Appropriations Act, 1999
G. Review Under Executive Order 13132
H. Review Under Executive Order 12988
I. Review Under the Treasury and General
Government Appropriations Act, 2001
J. Review Under Executive Order 13211
K. Review Under Executive Order 12630
L. Review Under Section 32 of the Federal
Energy Administration (FEA) Act of 1974
V. Public Participation
A. Submitting Public Comment
B. Issues on Which DOE Seeks Comment
1. Upper Limit of Walk-In Cooler
2. Basic Model of Envelope
3. Basic Model of Refrigeration
4. Updates to Standards
5. Heat Conduction Through Structural
Members
6. Alternatives to ASTM C1303–10
7. Improvements to ASTM C1303
Methodology
8. Conduction Through Floors
9. ‘‘Hybrid’’ Walk-Ins
10. U–Factor of Doors and Windows
11. Envelope Infiltration
12. Relative Humidity Assumptions
13. Definition of Refrigeration System
14. Annual Walk-In Energy Factor
15. Impacts on Small Businesses
VI. Approval of the Office of the Secretary
I. Authority and Background
Title III of the Energy Policy and
Conservation Act of 1975, as amended
(‘‘EPCA’’ or, in context, ‘‘the Act’’) sets
forth a variety of provisions designed to
improve energy efficiency. Part B of
Title III (42 U.S.C. 6291–6309) provides
for the Energy Conservation Program for
Consumer Products Other Than
Automobiles. The National Energy
Conservation Policy Act (NECPA),
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Public Law 95–619, amended EPCA to
add Part C of Title III, which established
an energy conservation program for
certain industrial equipment. (42 U.S.C.
6311–6317) (These parts were
subsequently redesignated as Parts A
and A–1, respectively, for editorial
reasons.) Section 312 of the Energy
Independence and Security Act of 2007
(‘‘EISA 2007’’) further amended EPCA by
adding certain equipment to this energy
conservation program, including walkin coolers and walk-in freezers
(collectively ‘‘walk-in equipment,’’
‘‘walk-ins,’’ or ‘‘WICF’’), the subject of
this rulemaking. (42 U.S.C 6311(1), (20),
6313(f), and 6314(a)(9))
At its most basic level, the term
‘‘walk-in equipment’’ encompasses
enclosed storage spaces of under 3,000
square feet that can be walked into and
are refrigerated to specified
temperatures—above 32 degrees
Fahrenheit (°F) for coolers and at or
below 32 °F for freezers. (42 U.S.C.
6311(20)(A)) The term does not include
equipment designed and marketed
exclusively for medical, scientific or
research purposes. (42 U.S.C.
6311(20)(B))
Walk-ins that meet this definition
may be located indoors or outdoors.
They may be used exclusively for
storage, but they may also have
transparent doors or panels for the
purpose of displaying stored items.
Examples of items that may be stored in
walk-ins include, but are not limited to,
food, beverages, and flowers.
Under the Act, the overall program
consists of three parts: testing, labeling,
and Federal energy conservation
standards. The testing requirements
consist of test procedures prescribed
under the authority of EPCA. These test
procedures are used in several different
ways: (1) DOE uses them to aid in the
development of standards for covered
products or equipment; (2)
manufacturers of covered equipment
must use them to establish that their
equipment complies with standards
promulgated under EPCA and when
making representations about
equipment efficiency; and (3) DOE must
use them to determine whether
equipment complies with applicable
standards.
Section 343 of EPCA (42 U.S.C. 6314)
sets forth generally applicable criteria
and procedures for DOE’s adoption and
amendment of such test procedures.
That provision requires that the test
procedures promulgated by DOE be
reasonably designed to produce test
results which reflect energy efficiency,
energy use, and estimated operating
costs of the covered equipment during
a representative average use cycle. It
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also requires that the test procedure not
be unduly burdensome to conduct. (42
U.S.C. 6314(a)(2)) As part of the process
for promulgating a test procedure, DOE
must publish a proposed procedure and
offer the public an opportunity to
present oral and written comments in
response to that procedure. DOE
solicited comments on the notice of
proposed rulemaking (‘‘NOPR’’) setting
forth proposed test procedures,
published on January 4, 2010 (‘‘the
January NOPR’’). 75 FR 186. DOE also
held a public meeting to discuss the
January 2010 NOPR on March 24, 2010.
DOE is now soliciting further comment
through this SNOPR.
The January NOPR and the March
2010 meeting provided interested
parties an opportunity to submit
comments on the proposals. Interested
parties raised significant issues and
suggested changes to the proposed test
procedures. DOE determined that some
of these comments warrant further
consideration. In today’s notice, DOE
addresses those comments and proposes
adjustments to the initial test
procedures proposed for walk-in
equipment in the January 2010 NOPR.
II. Summary of the Proposal
DOE is proposing several changes to
the proposal presented in the January
NOPR. These changes involve:
(1) Definition of walk-in cooler and
walk-in freezer.
(2) Testing and compliance
responsibility.
(3) Versions of standards incorporated
by reference.
(4) Basic model for envelope.
(5) Basic model for refrigeration
system.
(6) Conduction through structural
members.
(7) Alternatives to ASTM C1303.
(8) Heat transfer through concrete.
(9) U-factor of glass and non-glass
doors.
(10) Steady-state infiltration through
panel interfaces and doors.
(11) Door opening infiltration
assumptions.
(12) Infiltration reduction device
effectiveness.
(13) Relative humidity assumptions.
(14) Definition of refrigeration system.
(15) Annual walk-in energy factor.
Concurrently, DOE is undertaking an
energy conservation standards
rulemaking to address the statutory
requirement to establish performance
standards for walk-in equipment no
later than January 1, 2012. (42 U.S.C.
6313(f)(4)(A)) DOE will use the test
procedure in the concurrent process of
evaluating potential performance
standards for the equipment. After
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performance standards become
applicable, manufacturers must use the
test procedures to determine
compliance with the standards, and
DOE must use the test procedure to
ascertain compliance with the standards
in any enforcement action. Moreover,
once any final test procedure is
effective, any representation as to the
energy use of walk-in equipment must
reflect the results of testing that
equipment using the test procedure.
III. Discussion
This section addresses issues raised
by interested parties in response to the
January NOPR and provides detail
regarding DOE’s proposed changes to
the test procedure. Interested parties
include trade associations (American
Chemistry Council/Center for the
Polyurethanes Industry (ACC/CPI),
AHRI); manufacturers of the covered
equipment (Craig Industries, Metl-Span,
Nor-Lake, Carpenter, Master-Bilt,
American Panel Corporation, Arctic
Industries, Amerikooler, Kason, Hill
Phoenix, TAFCO/TMP (TAFCO),
International Cold Storage (ICS),
ThermalRite, Manitowoc, Kysor Panel,
HeatCraft, and Crown Tonka); suppliers
of components used in the covered
equipment (Honeywell, BASF, Dyplast,
ITW Insulation, Owens Corning, HH
Technologies (Hired Hand), Dow
Chemical, and Schott Gemtron); utilities
(Southern California Edison (SCE), San
Diego Gas and Electric (SDGE), and the
Sacramento Municipal Utility District
(SMUD)); and energy efficiency
advocates (American Council for an
Energy-Efficient Economy (ACEEE)).
A. Overall Issues
1. Definition of Walk-In Cooler or
Freezer: Temperature Limit
EPCA defines walk-in equipment as
follows:
(A) In general.—
The terms ‘‘walk-in cooler’’ and ‘‘walk-in
freezer’’ mean an enclosed storage space
refrigerated to temperatures, respectively,
above, and at or below 32 degrees Fahrenheit
that can be walked into, and has a total
chilled storage area of less than 3,000 square
feet.
(B) Exclusion.—
The terms ‘‘walk-in cooler’’ and ‘‘walk-in
freezer’’ do not include products designed
and marketed exclusively for medical,
scientific, or research purposes. (42 U.S.C.
6311(20))
During the public meeting on the
January NOPR and in written
comments, several interested parties
stated that DOE should clarify this
definition with respect to temperature
limits and exclusions. Multiple
interested parties commented that DOE
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should set an upper temperature limit
for walk-ins. Three temperature limits
were proposed: (1) 40 or 41 °F; (2) 45
°F; and (3) between 31 °F and 55 °F.
Kysor stated that DOE should align with
the National Sanitation Foundation
(NSF) definition of 41 °F as the
maximum high temperature for food
storage. (Kysor, Public Meeting
Transcript, No. 1.2.010 at p. 85) ICS
agreed with Kysor but cautioned that
this temperature could be different from
the temperature set by the customer.
(ICS, Public Meeting Transcript, No.
1.2.010 at p. 86)
In written comments, Kysor also
suggested 40 °F as the upper limit
because NSF/ANSI Standard 7,
‘‘Commercial Refrigerators and Freezers’’
uses such a requirement. See NSF/ANSI
Standard 7, ‘‘Commercial Refrigerators
and Freezers,’’ Section 6.10.1,
‘‘Performance (‘‘Storage refrigerators and
refrigerated food transport cabinets shall
be capable of maintaining an air
temperature of 40 °F (4 °C) or lower in
the interior.’’) (Kysor, No. 1.3.035 at p.
1) Craig and Hired Hand both indicated
that 45 °F or 41 °F would be an
acceptable upper limit. (Craig, Public
Meeting Transcript, No. 1.2.010 at p. 86;
Craig, No. 1.3.017 at p. 1 and Public
Meeting Transcript, No. 1.2.010 at p. 19;
Hired Hand, Public Meeting Transcript,
No. 1.2.010 at p. 88) A comment
submitted jointly by SCE, SDGE, and
SMUD, hereafter referred to collectively
as ‘‘the Joint Comment,’’ recommended
that DOE develop a definition to clarify
that walk-in coolers operate at
temperatures between 55 °F and 32 °F.
(Joint Comment, No. 1.3.019 at p. 17)
SCE pointed out that California’s
building energy standards consider 55
°F and below to be refrigerated. (SCE,
Public Meeting Transcript, No. 1.2.010
at p. 85) TAFCO agreed that DOE should
impose an upper limit of 55 °F because
this is the highest temperature at which
most refrigeration systems will operate.
(TAFCO, No. 1.3.022 at p. 1) Craig
disagreed with a 55 °F limit because this
temperature is the typical holding
temperature for wine coolers, but the
walk-in wine cooler might be rated at a
lower temperature. (Craig, Public
Meeting Transcript, No. 1.2.010 at p. 86)
DOE infers from the comment that Craig
was concerned that the energy
consumption of a wine cooler at the test
procedure rating temperature might not
represent the energy consumption at the
actual holding temperature. Hired Hand
stated that air conditioning is the first
stage of cooling for walk-ins inside airconditioned warehouses, which echoed
the concerns of other commenters that
the complete absence of an upper
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temperature limit might inadvertently
include a wider variety of conditioned
spaces than contemplated. (Hired Hand,
Public Meeting Transcript, No. 1.2.010
at p. 87)
EPCA defines walk-in equipment, in
part, as meaning a space that is
‘‘refrigerated,’’ and as having a ‘‘chilled
storage area.’’ (42 U.S.C. 6311(20)) DOE
proposes clarifying the term
‘‘refrigerated’’ within the statutory
definition to distinguish walk-in
equipment from air-conditioned storage
spaces. DOE could not find a consensus
among the industry for the definition of
‘‘refrigerated’’ or ‘‘chilled storage.’’
However, the Joint Comment, SCE, and
TAFCO suggested that 55 °F represented
a boundary between ‘‘refrigerated space’’
and ‘‘conditioned space’’ as refrigeration
systems typically do not operate above
55 °F, and air-conditioning systems
typically do not operate below this
limit. DOE found that preparation
rooms, wine coolers, and storage coolers
for most fruits and vegetables are
considered refrigerated spaces and are
typically cooled to temperatures
between 45 °F and 55 °F. DOE proposes
adopting a clarifying definition that
would set an upper limit of 55 °F for
walk-in equipment. DOE believes that
using the upper limit of food storage
temperatures (i.e., 40 °F or 45 °F) to
define walk-in equipment, as suggested
by some commenters, would exclude
some equipment that is ‘‘refrigerated’’
and has a ‘‘chilled storage area.’’ Such an
approach would, in DOE’s view,
exclude from coverage equipment that
falls within the statutorily-prescribed
scope of EPCA’s walk-in definition. The
space in which a walk-in is located (e.g.,
a grocery store, warehouse, or other
conditioned space) would not itself be
considered a walk-in unless it meets the
statutory definition of a walk-in and
DOE’s proposed clarifying definition
that would set an upper limit on the
temperature range. DOE requests
comment on its proposal of clarifying
‘‘refrigerated’’ to mean at or below 55 °F.
2. Testing and Compliance
Responsibility
In responding to comments received
on the framework document, the
January NOPR detailed DOE’s proposal
to create separate test procedures for the
envelope and the refrigeration system,
the two discrete systems that comprise
a walk-in. 75 FR 191. These two systems
may or may not each be manufactured
by a separate manufacturing entity.
Additionally, other manufacturers may
be involved in producing secondary
components—such as fan assemblies or
lighting—that are then incorporated as
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parts of the refrigeration system or
envelope.
In the January NOPR, DOE proposed
that the envelope manufacturer would
be responsible for testing the envelope
according to the envelope test
procedure, and the refrigeration system
manufacturer would be responsible for
testing the refrigeration system
according to the refrigeration system test
procedure. 75 FR 191. DOE believed
that the manufacturers of the envelope
and refrigeration systems—as parties
most likely to be intimately familiar
with the design and operation of their
own equipment—would be more likely
than installers to have the resources,
equipment, and trained personnel
needed to conduct the tests necessary to
certify WICF equipment as compliant
with any energy conservation standards
that DOE develops. 75 FR 191.
However, interested parties
commented that DOE’s concept of a
single envelope manufacturer may not
align with the actual market.
Commenters suggested that the panel
manufacturers, whom DOE assumed
would serve as the envelope
manufacturers for purposes of testing
compliance, did not necessarily control
the design of the walk-in envelopes for
which their panels were used. Many of
the comments from interested parties
suggested that DOE should assign
compliance testing responsibility to
parties involved in the physical
assembly (e.g., installers) and/or designlevel specification (e.g., general
contractors) of the walk-in envelope
because actions taken by these parties
could have a significant effect on walkin performance over its lifetime. Some
commenters suggested various forms of
joint responsibility between the
manufacturer(s) of the envelope
components and the parties responsible
for the physical assembly and/or designlevel specification of the envelope.
Other interested parties commented that
these options would not constitute a
viable approach and that DOE should
focus on the panel manufacturers for
compliance testing because they would
be more likely to have the proper
equipment and expertise to test the
panels.
Likewise, interested parties
commented that DOE’s concept of a
single refrigeration system manufacturer
may be inaccurate because the
condensing unit and unit cooler of a
single refrigeration system may be
manufactured by separate entities and
the whole system may be manufactured
from these separate parts by a third
manufacturer. Commenters generally
suggested assigning joint responsibility
between the manufacturer(s) of the unit
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cooler and condensing unit and the
manufacturer of the system as a whole.
Others suggested that DOE break a
refrigeration system down into its
individual components (e.g.,
compressor, coils) and regulate each
component separately.
DOE believes that many of the
comments concerning compliance
testing responsibility stem from the
definition of the term ‘‘manufacture,’’
which EPCA defines as ‘‘to manufacture,
produce, assemble or import.’’ (42 U.S.C.
6291(10)) Several interested parties
requested clarification of the definition
of ‘‘manufacture’’ and the implications
of that role. DOE generally requires a
single party, whose role falls under the
term ‘‘manufacture,’’ to assume
compliance responsibility for a given
appliance or equipment; typically, the
party responsible for demonstrating
compliance would conduct the
necessary testing or arrange for testing
to be conducted by a third party (e.g.,
a testing lab). DOE recognizes that the
walk-in envelope and refrigeration
system markets rely on multiple supply
chain scenarios in which several
distinct parties could serve different
roles that may fall under the term
‘‘manufacture.’’ In the case of both walkin envelopes and refrigeration systems,
DOE recognizes that assigning
compliance responsibility to a single
entity that may not be involved in all
aspects of the design and construction
of these systems may present certain
logistical issues. Accordingly, DOE
plans to further address these issues
during the standards rulemaking when
developing the required efficiency
levels and when developing
certification and compliance
responsibilities.
3. Basic Model of Envelope
Although often manufactured
according to the same basic design,
many walk-in envelopes can be highly
customized. To address this possibility,
DOE proposed the following approach
in the January NOPR: (1) Grouping
walk-in envelopes with essentially
identical construction methods,
materials, and components into a single
basic model; and (2) adopting a
calculation methodology for
determining the energy consumption of
units within the basic model. For walkin envelopes, DOE proposed to define a
‘‘basic model’’ as ‘‘all units of a given
type of walk-in equipment
manufactured by a single manufacturer,
and—(1) With respect to envelopes,
which do not have any differing
construction methods, materials,
components, or other characteristics
that significantly affect the energy
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consumption characteristics.’’ 75 FR
189.
Master-Bilt, BASF, ACC/CPI, Craig,
Kason, and ThermalRite supported the
concept of the basic model for WICF
envelopes. (Master-Bilt, No. 1.3.009 at p.
1; BASF, No. 1.3.003 at p. 3; ACC/CPI,
No. 1.3.006 at p. 2 and No. 1.3.028 at
p. 1; Craig, Public Meeting Transcript,
No. 1.2.010 at p. 102; Kason, No. 1.3.037
at p. 1 and Public Meeting Transcript,
No. 1.2.010 at p. 124; and ThermalRite,
No. 1.3.031 at p. 1) Craig supported an
approach consisting of a single basic
model test on a baseline model and
adding component loads. (Craig, Public
Meeting Transcript, No. 1.2.010 at p.
123) Kason stated that the basic model
test should include provisions at the
component level, where manufacturers
could pick new components as long as
the components were certified to exceed
the performance of the old components.
(Kason, Public Meeting Transcript, No.
1.2.010 at p. 124) Kysor and Nor-Lake
both believed that the concept of the
basic model may not be realistic if
envelope components such as doors and
lights were not purchased or installed
by the panel manufacturers; in that case,
Kysor and Nor-Lake stated that
component manufacturers should be
responsible for rating individual
components. (Nor-Lake, No. 1.3.029 at
p. 2; Kysor, No. 1.3.035 at p. 2) Arctic
proposed expanding the basic model
concept to eliminate testing for units
using the same materials and
construction methods as a previously
certified model, adding that it would be
impractical and infeasible for them to
test every kind of equipment they
manufacture because of the great variety
of box dimensions. (Arctic, No. 1.3.012
at p. 1) BASF and Kason also stated that
manufacturers must be able to reduce
the number of models to test to ensure
minimal manufacturer burden. (BASF,
No. 1.3.003 at p. 3 and Kason, No.
1.3.037 at p. 1)
Other interested parties disagreed
with the proposed basic model
approach. Bally stated that the company
produces tens of thousands of basic
models, making basic model testing
infeasible. (Bally, Public Meeting
Transcript, No. 1.2.010 at p. 132) Hill
Phoenix believed that use of a basic
model for testing would not accurately
represent the energy usage of most walkins because of equipment variability,
that an energy usage calculation
program would have to be created and
maintained and be consistent across the
industry, and that basic model testing
would require costly government
oversight. Instead, Hill Phoenix
recommended component-level
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modeling. (Hill Phoenix, No. 1.3.023 at
p. 2)
Several interested parties requested
clarification of the proposed definition
of basic model. ACC/CPI and Honeywell
recommended that different types of
foam and/or different blowing agents
should trigger different basic models
(ACC/CPI, No. 1.3.006 at p. 2 and Public
Meeting Transcript, No. 1.2.010 at p. 43;
Honeywell, No. 1.3.020 at p. 1)
Honeywell also recommended that a
different facer material should trigger a
new basic model. (Honeywell, No.
1.3.020 at p. 1) Owens Corning stated
that the insulation material should not
trigger a new basic model because the Rvalue of the insulation is addressed in
EISA and that panel construction
(framed or frameless) should be used to
differentiate between basic models.
(Owens Corning, No. 1.3.030 at p. 2) ICS
stated that different applications should
constitute different basic models:
holding storage, quick chilling or
freezing, or blast freezing. (ICS, No.
1.3.027 at p. 1) TAFCO commented that
the use of strip curtains or air curtains
should not constitute a new basic
model. (TAFCO, No. 1.3.022 at p. 2)
Other interested parties requested that
DOE specify standard characteristics for
a certain basic unit that every
manufacturer would test. American
Panel, ThermalRite, and Craig
recommended that DOE specify a
standardized basic model size.
(American Panel, No. 1.3.024 at p. 2;
ThermalRite, No. 1.3.031 at p. 1; Craig,
Public Meeting Transcript, No. 1.2.010
at pp. 102, 106, and 119) Craig
suggested a basic size applicable to the
food industry—an 8 foot × 10 foot cooler
and a 6 foot × 8 foot freezer, both with
a height of 7 feet 6 inches tall—and
added that size would only be
applicable to the infiltration test
because other characteristics could be
calculated. (Craig, Public Meeting
Transcript, No. 1.2.010 at p. 105 and No.
1.2.010 at pp. 102, 106, and 119) Kysor
suggested that only height could be
specified, arguing that walk-ins cannot
be characterized by size. (Kysor, Public
Meeting Transcript, No. 1.2.010 at p.
106)
Finally, interested parties commented
on the proposed scaling methodology
associated with the basic model
concept. Manitowoc stated that a scaling
methodology based on surface area
would not give an accurate
representation of energy use because
energy scales not only with surface area
but with other factors as well such as
the number of installed doors and door
size. In other words, individual
component loads scale with individual
component characteristics. (Manitowoc,
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Public Meeting Transcript, No. 1.2.010
at p. 108) ThermalRite also questioned
whether there is a linear relationship
between energy consumption and WICF
size that would allow for scaling.
(ThermalRite, Public Meeting
Transcript, No. 1.2.010 at p. 110)
Upon consideration of these
comments, DOE believes that the basic
model concept would provide
manufacturers with a standardized
method of categorizing their products.
However, the definition of basic model
proposed in the January NOPR could
make the concept difficult to use as
originally intended to reduce testing
burden. Specifically, the phrase ‘‘* * *
characteristics that significantly affect
the energy consumption * * *’’ could
be interpreted inconsistently by
manufacturers. The paragraphs below
describe DOE’s proposed alternative
approach to defining the term ‘‘basic
model’’. Additionally, feedback from
interested parties indicated a desire for
DOE to specify prescriptive design
characteristics for a basic model.
Because EPCA requires DOE to
promulgate performance-based
standards for this equipment, DOE does
not intend to specify design
characteristics that do not affect
normalized energy consumption, as
suggested by ACC/CPI, Honeywell,
Owens Corning, ICS and TAFCO. See 42
U.S.C. 6313(f) (instructing DOE to set
performance-based standards for walkins).
DOE is considering adopting a revised
definition of the term ‘‘basic model’’ that
would be consistent with the definition
of basic model used elsewhere in the
appliance standards program, improve
the clarity of the definition, and narrow
the scope of the basic model concept.
Most notably, this revision would not
allow walk-in models to differ in terms
of their normalized energy
consumption. Models grouped within a
basic model could still differ in terms of
their non-energy characteristics (e.g.,
color, shelving, metal skin material
type, exterior finish, door kick-plate) but
any change to a characteristic that
affects normalized energy consumption
(e.g., panel systems, door systems,
electrical components, and infiltration
reduction devices) would constitute a
new basic model.
DOE’s proposed revision, while
reducing the possibility of inconsistent
interpretation of the term ‘‘basic model’’,
could increase the testing burden
relative to the burden under the
definition of ‘‘basic model’’ as proposed
in the January NOPR. Some of the
burden may be offset, however, by
burden-reducing measures proposed
elsewhere in the test procedure. These
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measures include incorporating scaling
factors for the infiltration test (section
III.B.9), the panel U-factor test (section
III.B.1), and representative doorway
sizes for infiltration reduction device
testing. With these measures, DOE
attempts to minimize the number of
physical tests that would need to be
performed for the test procedure and
instead provide a calculation
methodology that would allow for rating
equipment based on physical tests
conducted on other equipment. DOE
believes that this approach would
sufficiently address the concerns of
BASF, Kason, Arctic, Bally, and Hill
Phoenix regarding the number of basic
models to be tested and the cost of
testing. A DOE-specified calculation
methodology would also address Hill
Phoenix’s recommendation that the
energy use calculation program be
consistent across the industry.
Regarding Arctic’s view that the basic
model concept should be expanded to
include similar units with the same
materials and construction methods that
have been previously certified, DOE
notes that models with the same
characteristics as previously certified
models would be considered the same
basic model only if they met the
conditions in the basic model
definition. In other words, the models
would need to have the same
manufacturer and not have any differing
characteristics that affect normalized
energy consumption.
The proposed test procedure revisions
considered in this SNOPR also rely
more heavily on component testing,
consistent with the suggestions made by
Craig, Kason, Kysor, Nor-Lake, and Hill
Phoenix. This approach removes the
burden of testing an entire walk-in for
which only one component is different
from a previously rated walk-in: the test
procedure revisions in this SNOPR
would allow for testing the new
component and then using the proposed
calculation methodology to obtain the
new rating of the walk-in. Additionally,
the proposed component tests allow for
testing one component and then
applying those results to other
components that meet certain similar
criteria. DOE believes this method is
more accurate than allowing for scaling
of the entire walk-in, because each
walk-in could contain many customized
parts. Adopting this method would
address the concerns raised by
Manitowoc and ThermalRite that energy
may not scale directly with walk-in
external surface area or other size
characteristics. For some proposed
component tests, DOE specifies
characteristics of the part that must be
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physically tested (i.e., the geometry of a
panel test sample), instead of specifying
characteristics of the tested walk-in unit
as a whole as suggested by American
Panel, ThermalRite, Craig, and Kysor,
because (1) complete walk-in units may
be very different from one another even
if they use similar components, and (2)
the scaling calculations are more
accurate on the component level than
on the level of the entire walk-in, which
supports testing certain components as
part of the compliance procedure. For
additional details on these proposed
component tests, see section III.B.
With respect to certification, in
general, DOE requires that
manufacturers of a covered basic model
submit a certification report providing
details, which demonstrate compliance
with the applicable energy conservation
standards or design standards
prescribed by DOE or established by
Congress. DOE estimates that
approximately 50 percent of the market
consists of standardized walk-ins that
are produced in large quantities. For the
other half of the market, walk-ins may
have custom features and components
that could qualify each as a different
basic model. In this situation,
manufacturers could produce many
basic models in a year.
DOE is unsure, however, how
burdensome this would be in terms of
the actual number of hours or personnel
required to certify additional basic
models under this approach. If requiring
a certification report for each basic
model under the approach outlined in
today’s SNOPR would impose an
unreasonable burden, DOE may
consider a compliance certification
approach similar to that taken for
distribution transformers (another case
in which some equipment is highly
customized). 10 CFR 431.371(a)(6)(ii).
Distribution transformer manufacturers
are required to maintain records on all
basic models sold (or built), but must
submit a compliance report to DOE that
certifies only the least efficient basic
model within larger groupings that may
encompass many basic models. 10 CFR
431.371(a)(6)(ii). The manufacturer
would certify that every other
transformer in the larger grouping is no
less efficient than the certified basic
model certified to DOE. Given the
nature of the market, DOE is willing to
consider variations on this approach for
walk-ins, such as requiring certification
for the least and most efficient basic
models within a larger group. Such an
approach could help address the
concern of Hill Phoenix about the cost
of an oversight strategy.
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DOE requests comment on its
proposed definition and approach
regarding basic models for envelopes.
4. Basic Model of Refrigeration Systems
In the January NOPR, DOE proposed
that the definition of the term ‘‘basic
model’’ in the context of a refrigeration
system would refer to all units with the
same energy source and without any
different electrical, physical, and
functional characteristics that affect
energy consumption. DOE then stated
during the NOPR public meeting that it
was considering a new definition that
would not allow units within a basic
model to differ in energy consumption.
DOE also stated during the public
meeting that it would consider the
default of including no provision for a
basic model, under which
manufacturers would be required to test
every model they manufacture.
AHRI and ACEEE agreed with DOE’s
proposed approach and definition of
basic model. (AHRI, No. 1.3.032 at p. 2
and Public Meeting Transcript, No.
1.2.010 at p. 169; ACEEE, No. 1.3.034 at
p. 2) Craig also agreed with the
proposed approach given that
improvements could be applied to
existing systems. (Craig, Public Meeting
Transcript, No. 1.2.010 at p. 172) ICS,
Manitowoc, and HeatCraft
recommended that the basic model of
refrigeration be allowed to vary
minimally (a 5 percent tolerance) in
energy consumption, while HeatCraft
also stated that in Europe, the tolerance
is typically 8 percent. (ICS, No. 1.3.027
at p. 1; Manitowoc, Public Meeting
Transcript, No. 1.2.010 at p. 159; and
HeatCraft, Public Meeting Transcript,
No. 1.2.010 at p. 162) On the other
hand, Master-Bilt expressed concern
that too many refrigeration system
combinations may exist for the basic
model concept to be applied effectively.
(Master-Bilt, No. 1.3.009 at p. 1)
HeatCraft stated that it was concerned
about testing highly variable
refrigeration systems and combinations,
and whether they would be able to
incorporate new technologies.
(HeatCraft, Public Meeting Transcript,
No. 1.2.010 at p. 42) Nor-Lake was also
concerned about the potential testing
burden because it has distinct energy
efficiency ratio values on over 250
models. It recommended either defining
basic model to account for how many
basic models a manufacturer would
have or to replace the basic model
approach with a component-based one.
(Nor-Lake, No. 1.3.005 at pp. 2 and 5
and No. 1.3.029 at p. 2) Manitowoc
suggested considering a unit cooler its
own basic model (not the combination
of unit cooler and condensing unit),
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making it unnecessary to test all
combinations but only individual parts
of the system. (Manitowoc, Public
Meeting Transcript, No. 1.2.010 at p.
158)
TAFCO identified refrigeration system
components that, if changed, would
significantly affect energy consumption.
These components include the
compressor, condensing coil, fan
motors, head pressure control, and
evaporator coil. (TAFCO, No. 1.3.022 at
p. 2) American Panel added that
headmasters (which control pressure)
must be included on outdoor
condensing units if the unit will be
exposed to low temperatures. (American
Panel, No. 24 at p. 3) Some interested
parties discussed whether DOE should
specify certain characteristics of the
basic model. Specifically, HeatCraft
stated that the basic model should
include some common parts such as a
filter dryer to permit a valid comparison
between manufacturers, but
manufacturers should be allowed to add
unique features. (HeatCraft, Public
Meeting Transcript, No. 1.2.010 at p.
162) ACEEE agreed that the basic model
should include parts that have a
reasonable probability of affecting
energy consumption to encourage
manufacturers to include all necessary
components in their WICF equipment.
(ACEEE, Public Meeting Transcript, No.
1.2.010 at p. 168) AHRI disagreed,
stating that DOE should not specify
design requirements in defining basic
model groups, but rather agreed with
DOE’s proposed definition. (AHRI,
Public Meeting Transcript, No. 1.2.010
at p. 169) (Although ACEEE did not
elaborate further on what it considers
‘‘all necessary components,’’ DOE is
interpreting this phrase as referring to
any components that would be needed
to have the unit work in a manner as
designed without the addition of
aftermarket components that would
impact the equipment’s energy usage.)
As with envelopes, DOE must ensure
that all refrigeration systems are
accurately rated and comply with the
standard. To avoid differing
interpretations of what a ‘‘significant
difference’’ in energy consumption
might be, DOE believes that it is
appropriate to clarify certain aspects of
that definition to eliminate differences
in the measured energy consumption of
models belonging to the same basic
model group. Accordingly, DOE
proposes a revised definition of basic
model of refrigeration where units
cannot differ in electrical, physical, or
functional characteristics that affect
energy consumption. DOE recognizes
that the components identified by
TAFCO affect the energy consumption
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of the refrigeration system.
Nevertheless, DOE believes that listing
only certain components where changes
would constitute a new basic model
could overlook changes to other
components that affect energy
consumption. In addition, the question
of significance would remain under
such an approach. DOE believes that the
definition proposed here is sufficient to
define basic model—a basic model
would necessarily have to include all
components that affect energy
consumption.
DOE also acknowledges the concerns
of interested parties, specifically MasterBilt, HeatCraft, and Nor-Lake, that a
manufacturer could produce many
condensing unit and unit cooler
combinations—i.e., many basic models
—and that testing could be burdensome.
DOE notes that the proposed
refrigeration system test procedure,
AHRI 1250–2009, allows for testing the
condensing unit and unit cooler
separately and then, using the
calculation methodology in AHRI 1250–
2009, determining the performance of
the combined system, similar to the
approach suggested by Manitowoc.
Under this approach, each combination
would not have to be tested, which
would decrease the number of physical
equipment tests, even though each
different combination would be
considered a different basic model and
would receive a different rating.
At this time, DOE does not intend to
incorporate a tolerance into the
definition of basic model, as suggested
by ICS, Manitowoc, and HeatCraft, in
order to ensure that the rating applying
to each basic model is as accurate as
possible. DOE notes that one potential
issue with introducing a tolerance
approach may be that neither DOE nor
the eventual purchaser of the equipment
could expect that the rating of a
particular model would be equal to that
model’s actual energy consumption. It is
unclear to DOE how significant this
issue may be if such an approach were
adopted.
DOE acknowledges, however, that
units within a basic model are expected
to differ slightly as a result of
manufacturing and materials variations.
As a result, DOE may consider
accounting for these variations in
sampling plans used for compliance
testing and developed as part of any
future certification and enforcement
rulemaking. DOE’s existing compliance
and certification regulations, developed
for certain other commercial equipment,
provide that when a random sample of
equipment is taken for determining
compliance with the standard for
commercial refrigeration equipment,
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represented values of estimated energy
consumption of a basic model shall be
no less than the higher of the mean of
the test sample or the upper 95 percent
confidence limit of the true mean
divided by 1.10. 75 FR 652, 666–71 (Jan.
5, 2010), codified at 10 CFR 431.372.
This rule also provides that, in
enforcement proceedings, DOE’s
determination that a basic model
complies with the standard is based on
a confidence limit which accounts for
statistical variation within a basic
model. 75 FR 674, codified at 10 CFR
part 431, Appendix D to Subpart T.
These sampling provisions are only
intended to reduce the burden on
manufacturers associated with
certification and enforcement.
Manufacturers would still be required to
use the test procedure to rate their
equipment and, once energy
conservation standards take effect, to
determine whether each basic model of
the equipment they manufacture
complies with the standard.
As discussed above for envelopes,
DOE could consider a compliance
certification approach similar to that
taken for distribution transformers
(another case in which some equipment
is highly customized) to reduce the
burden while ensuring that the energy
conservation standards are being met.
10 CFR 431.371(a)(6)(ii). DOE describes
this approach in detail in section III.A.3.
DOE requests comment on the
definition of and approach to basic
model of refrigeration systems.
B. Envelope
The envelope consists of the insulated
box in which items are stored and
refrigerated. To meet one element of the
statutory requirement that the DOE test
procedure ‘‘measure the energy use’’ of
walk-ins (42 U.S.C. 6314(a)(9)(B)(i)),
DOE had proposed to incorporate a
metric for the energy use associated
with the envelope of a walk-in cooler or
walk-in freezer. Under the applicable
EPCA definition of ‘‘energy use’’—the
amount of energy directly consumed by
a piece of equipment at the point of use
(42 U.S.C. 6311(4))—DOE has
tentatively determined that the energy
use of a walk-in envelope is the sum of
(1) the electrical energy consumption of
envelope components and (2) other
energy consumption of the walk-in
equipment resulting from the heat
transfer performance of the envelope.
The proposed envelope test procedure
contains 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
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components. The proposed procedure
uses data obtained from these methods
to calculate a measure of 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. These characteristics and
components would include 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 effect on the
refrigeration system would be
determined by calculating the energy
consumption of a theoretical or
‘‘nominal’’ refrigeration system if it were
paired with the tested envelope. The
test procedure uses the same nominal
refrigeration system efficiency for all
tested envelopes to allow for direct
comparison of the performance of walkin envelopes across a range of sizes,
product classes, and levels of feature
implementation.
1. Heat Conduction Through Structural
Members
In the January NOPR, DOE proposed
that the long-term thermal resistance
(LTTR) value of the insulating foam
after 5 years of equivalent aging be
determined using ASTM C1303–08,
‘‘Standard Test Method for Predicting
Long-Term Thermal Resistance of
Closed-Cell Foam Insulation.’’ This
value would be used as the R-value for
all non-glass envelope sections
constructed with foam insulation, for
purposes of calculating the energy
consumption of the walk-in. Other
components of the panel, such as
structural members, were not included
in the conduction calculations of the
test procedure.
Craig, Owens Corning, and American
Panel pointed out that conduction
through structural members must be
considered when determining the Rvalue of a composite walk-in insulation
panel. (Craig, No. 1.3.036 at p. 3 and
Public Meeting Transcript, No. 1.2.010
at pp. 20 and 61; Owens Corning, Public
Meeting Transcript, No. 1.2.010 at p. 56;
and American Panel, No. 1.3.024 at p.
3) The Joint Comment recommended
that the current R-value requirement for
the foam be converted to an overall Ufactor requirement for the assembled
panel. (Joint Comment, No. 1.3.019 at p.
11) (U-factor is a measure of heat
transmission, including conduction and
radiation. A lower U-factor indicates a
lower rate of heat transmission.) MetlSpan, BASF, Kysor, and ACC/CPI
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agreed with the approach of
determining the performance of the
panel as a whole and recommended that
DOE use ASTM C1363–05, ‘‘Standard
Test Method for Thermal Performance
of Building Materials and Envelope
Assemblies by Means of a Hot Box
Apparatus,’’ for evaluating the fully
assembled panel. (Metl-Span, No.
1.3.004 at p. 1; BASF, No. 1.3.003 at p.
2; Kysor, No. 1.3.035 at p. 2; ACC/CPI,
No. 1.3.006 at p. 2)
In view of these comments, DOE
proposes to account for conduction
through structural members, as urged by
Craig and American Panel, by
measuring the overall U-factor of fully
assembled panels as recommended by
the Joint Comment. All panels (walls,
ceiling, and floor) would be tested using
ASTM C1363–05 for measuring the
overall U-factor of fully assembled
panels, as stated by Metl-Span, BASF,
Kysor, and ACC/CPI. The resulting
composite panel U-factor from ASTM
C1363–05 would then be corrected
using the LTTR results from ASTM
C1303–10, if foam is used as the
primary insulating material. See section
3.1.6 of Appendix A for details. DOE
believes using the results from ASTM
C1363–05 modified by ASTM C1303–10
best captures the effect of structural
members and long-term R-value of foam
products.
DOE recognizes the burden involved
when testing an entire representative
walk-in using ASTM C1363–05; i.e.,
requiring a representative walk-in
composed of 18 panels to be tested 18
times. DOE also notes that testing a
single representative panel would be
less burdensome but very inaccurate.
Panels are often manufactured in
dimensions close to 8 feet long by 4 feet
wide, but panel geometry frequently
deviates from this size as walk-ins are
made larger. In addition, structural
members are normally placed in the
perimeter of panels (if used at all).
Therefore, the heat transfer of a given
panel is most closely related to the ratio
of perimeter structural materials to nonperimeter core panel materials.
If DOE were to require an ASTM
C1363–05 test using only one panel size,
the test would be representative of only
this single perimeter-to-core ratio. If a
walk-in were constructed of panels that
deviated from this representative size in
either extreme (i.e., much smaller or
larger), the resulting energy calculations
could be inaccurate. To balance the
competing interests of minimizing
burden while ensuring measurement
accuracy, DOE is proposing to specify
two test regions of a pair of
representative panels. At one test
region, the tester would measure the U-
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factor of the perimeter and panel-topanel interface area (‘‘Panel Edge’’),
while at the other region the tester
would measure the U-factor of the core
area of the panel (‘‘Panel Core’’). The
details of this procedure are described
in section 4.1.1 of Appendix A.
DOE seeks comment on the use of
ASTM C1363–05 for this portion of the
test procedure.
2. Use of ASTM C1303 or EN
13165:2009–02
In the January NOPR, DOE proposed
using ASTM C1303–08, ‘‘Standard Test
Method of Predicting Long Term
Thermal Resistance of Closed-Cell Foam
Insulation,’’ to determine the long-term
R-value of foam insulations used in
walk-ins. 75 FR 194. (That test method
has since been updated to ASTM
C1303–10, which, as discussed in
section III.B.4, DOE is now proposing to
adopt as part of this test procedure. All
references to ASTM C1303 in today’s
notice refer to the ASTM C1303–10
version of the protocol.) As discussed
later in section III.B.3, DOE also
proposes, in the alternative, the use of
EN 13165:2009–02 (a Europeandeveloped material standard), and seeks
comment on the use of these
procedures.
DOE recognizes that R-value decline
occurs over time in unfaced and
permeably faced foams. In the published
January NOPR, DOE cited a body of
research indicating that R-value decline
also occurs in foams with impermeable
facers because the metal skins delay, but
do not prevent, R-value decline because
the panel edges are unprotected. DOE
55075
recognized that using ASTM C1303–10
would require testing foams without
their metal facers because the test
procedure was designed for unfaced or
permeably faced foams. In the published
NOPR and at the NOPR public meeting,
DOE requested that interested parties
submit data related to using ASTM
C1303–10 for walk-ins.
DOE received many comments related
to ASTM C1303–10. Supporting
documents submitted during the
comment period are listed in the table
below and identified with reference
numbers. DOE conducted further
research and identified additional
documents that provide information on
the use of ASTM C1303–10. These are
also listed in the table below with
reference numbers preceded by ‘‘DOE.’’
TABLE III.1—RESEARCH CITED BY INTERESTED PARTIES AND BY DOE
Commenter
Paper Citation
ACC/CPI ..........................................
SPI Polyurethane Division k Factor Task Force, ‘‘Rigid Polyurethane and
Polyisocyanurate Foams: An Assessment of Their Insulating Properties,’’ Proceedings
of the SPI 31st Annual Technical/Marketing Conference, Oct. 18–21, 1988 Philadelphia, PA. pp. 323–327.
Wilkes, K. E., Yarbrough, D.W., Nelson, G. E., Booth, J. R., ‘‘Aging of Polyurethane
Foam Insulation in Simulated Refrigerator Panels—Four-Year Results with Third-Generation Blowing Agents’’, The Earth Technologies Forum, Washington, DC, April 22–
24, 2003.
Norton, F.J., ‘‘Thermal Conductivity and Life of Polymer Foams’’, Journal of Cellular Plastics, 1967, pp. 23–37.
Shankland, I. R. ‘‘Blowing Agent Emissions from Insulation Foam’’, Polyurethanes World
Congress 1991 pp. 91–98.
Oertel, Dr. Gunter, Polyurethane Handbook, p. 256 ............................................................
Ottens et al., ‘‘Industrial Experiences with CO2 Blown .........................................................
Polyurethane Foams in the Manufacture of Metal Faced Sandwich Panels,’’ Polyurethane
World.
Congress ’97’ ........................................................................................................................
Bertucelli et al., ‘‘Phase-Out of Ozone Depleting Substances in the Manufacture of Metal
Faced Sandwich Panels with Polyurethane Foam Core,’’ Utech Asia ’99’.
The Role of Barriers in Reducing the Aging of Foam Panels by Leon R. Glicksman .........
European standard EN 13165 ..............................................................................................
Wilkes, K. E., Yarbrough, D. W., Nelson, G. E., Booth, J. R., ‘‘Aging of Polyurethane
Foam Insulation in Simulated Refrigerator Panels—Four-Year Results with Third-Generation Blowing Agents,’’ The Earth Technologies Forum Conference Proceedings,
2003.
Paquet, A., Vo C., ‘‘An Evaluation of the Thermal Conductivity of Extruded Polystyrene
Foam Blown with HFC–134a and HCFC–142b,’’ Journal of Cellular Plastics, Volume
40, May 2004.
Federal Trade Commission, ‘‘Labeling and Advertising of Home Insulation: Trade Regulation Rule; Final Rule,16 CFR Part 460,’’ Federal Register/Vol. 70, No. 103/Tuesday,
May 31, 2005.
Roe, Richard, ‘‘Long-Term Thermal Resistance (LTTR): 5 Years Later’’ RCI–057–Interface, March 2007.
Stovall, Therese, ‘‘Measuring the Impact of Experimental Parameters upon the Estimated
Thermal Conductivity of Closed-Cell Foam Insulation Subjected to an Accelerated
Aging Protocol: Two-Year Results, Journal of ASTM International, Vol. 6, No. 5 Paper
ID JAI102025, April 2009.
Kalinger, P., and Drouin, M. (Johns Manville), ‘‘Closed Cell Foam Insulation: Resolving
the issue of thermal performance,’’ October/November 2001.
Mukhopadhyaya, P., Bomberg, M. T., Kumaran, M. K., Drouin, M., Lackey, J., van
Reenen, D., and Normandin, N., ‘‘Long-Term Thermal Resistance of Polyisocyanurate
Foam Insulation with Impermeable Facers ,’’ Insulation Materials: Testing and Applications: 4th Volume, ASTM STP 1426, A. O. Desjarlais, Ed., American Society for Testing and Materials, West Conshohocken, PA, 2002.
ACC/CPI, Carpenter, Honeywell ......
ACC/CPI, Honeywell ........................
ACC/CPI, Honeywell ........................
Dow ..................................................
Dow ..................................................
Dow ..................................................
Owens Corning ................................
Dow ..................................................
DOE .................................................
DOE .................................................
DOE .................................................
DOE .................................................
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DOE .................................................
DOE .................................................
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2
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4
5
6
7
8
9
DOE 1
DOE 2
DOE 3
DOE 4
DOE 5
DOE 6
DOE 7
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TABLE III.1—RESEARCH CITED BY INTERESTED PARTIES AND BY DOE—Continued
Commenter
Paper Citation
DOE .................................................
Mukhopadhyaya, P., Bomberg, M. T., Kumaran, M. K., Drouin, M., Lackey, J., van
Reenen, D., and Normandin, N., ‘‘Long-term Thermal Resistance of Polyisocyanurate
Foam Insulation with Gas Barrier,’’ IX International Conference on Performance of Exterior Envelopes of Whole Buildings, Clearwater Beach, Florida, Dec. 5–10, 2004, pp.
1–10.
Mukhopadhyaya, P.; Kumaran, M.K., ‘‘Long-Term Thermal Resistance of Closed-Cell
Foam Insulation: Research Update From Canada,’’ 3rd Global Insulation Conference
and Exhibition, Oct. 16–17, 2008, Barcelona, Spain, pp. 1–12, NRCC–50839.
Bomberg, M., Branreth, D., ‘‘Evaluation of Long-Term Thermal Resistance of Gas-Filled
Foams: State of the Art,’’ Insulation Materials, Testing and Applications, ASTM STP
1030, ASTM, Philadelphia, 1990, p. 156–173.
H. Macchi-Tejeda, H. Opatova, D. Leducq, Contribution to the gas chromatographic analysis for both refrigerants composition and cell gas in insulating foams—Part I: Method,
International Journal of Refrigeration, Volume 30, Issue 2, March 2007, Pages 329–
337.
H. Macchi-Tejeda, H. Opatova, J. Guilpart, Contribution to the gas chromatographic analysis for both refrigerants composition and cell gas in insulating foams—Part II: Aging
of insulating foams, International Journal of Refrigeration, Volume 30, Issue 2, March
2007, Pages 338–344.
DOE .................................................
DOE .................................................
DOE .................................................
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DOE .................................................
ACC/CPI, in reference to paper [1],
stated that the Task Force found that
polyurethane foam encased in and
adhered to impermeable facers does not
age significantly. (ACC/CPI, No. 1.3.006
at p. 3) In reference to [2], Honeywell
stated that Wilkes et al. concluded that
‘‘the increment of thermal conductivity
of foams with facers is less than those
of enclosed foams’’, and regarding that,
ASTM C1303–08 is likely to
underestimate the aged thermal
insulation value of panel foams with
facers. (Honeywell, No. 1.3.020 at p. 3)
Honeywell suggested that ‘‘DOE
consider adapting the aging prediction
methodology presented’’ in either [3] or
[4]. (Honeywell, No. 1.3.020 at p. 2)
Dow stated that [5], [6], and [7]
indicated that change in thermal
conductivity due to aging is limited in
blown polyurethane foams. (Dow, No.
1.3.026 at p. 2) In reference to [8],
Owens Corning stated that the study
showed that blowing agent can diffuse
under metal skins, that it migrates to the
surface and that it can permeate out
even underneath an air-impermeable
surface. (Owens Corning, No. 1.2.010 at
p. 256) Dow noted that [9] ‘‘provides
methods for evaluating the aged lambda
(λ) or R-values for both exposed foam
and faced foam using an accelerated
procedure. The standard uses safety
factors depending on thickness and
blowing agent used in the foam and also
uses incremental factors for exposed
foams versus foams with facings.’’
However, Dow also noted that ‘‘even
though the standard and the procedure
apply to foams with and without
impermeable facings,’’ the aging factor is
four times higher for exposed foam than
it is for impermeably faced foam. (Dow,
No. 1.3.026 at p. 1)
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With regard to papers cited by
interested parties, DOE makes the
following observations (the numbering
refers to the paper reference number in
Table III.1).
1. On p. 325 of paper [1], the SPI
Polyurethane Division k Factor Task
Force states ‘‘* * * thermal
performance changes little with time if
the foam is protected against gas
diffusion by a non-permeable facer that
adheres well to the foam.’’ However,
immediately following this statement
SPI says, ‘‘The literature emphasizes that
not only the foam but the entire package
or composite must resist gas diffusion.’’
This statement supports DOE’s position
that it is critical to ensure that all of the
foam is encapsulated by an
impermeable barrier to prevent
diffusion of gases, not just the face of
the material. However, the study also
provides a number of studies that
suggest that aging is delayed on the
order of three to nine years rather than
two to three years as DOE previously
suggested.
2. In paper [2], Wilkes et al. measured
the LTTR of 2-inch-thick foam samples
faced with either Acrylonitrile
Butadiene Styrene (ABS) or High Impact
Polystyrene (HIPS) plastic. The edges of
the samples were covered with
aluminum foil tape to reduce lateral
diffusion through the panel edges. The
samples were aged for 4 years in 90 °F,
40 °F, and ¥10 °F environments. In
conclusion, Wilkes et al. found that for
‘‘both ABS and HIPS plastics, the
conductivity increases after four years
were less than those predicted for
unenclosed full-thickness core-foam,
showing that the plastic liners reduce
the rate of aging. The panels with HIPS
sheets showed average increases of
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DOE 8
DOE 9
DOE 10
DOE 11
DOE 12
[thermal conductivity] of 19 percent to
28 percent with aging at 90 °F, 12
percent to 23 percent at 40 °F, and 3
percent to 8 percent at ¥10 °F. The
panels with ABS sheets showed smaller
increases of 14 percent to 21 percent at
90 °F, 10 percent to 17 percent at 40 °F,
and 2 percent to 5 percent at ¥10 °F.’’
(p. 10). The results demonstrate that
facers reduce the rate of aging. However,
the plastic facers used, with the
exception of the foil around the edges,
are gas permeable. In addition, Wilkes et
al. specifically attempted to eliminate
lateral diffusion with the foil tape on the
edges of the samples, which is not
representative of actual walk-in panels.
3. Honeywell suggested that DOE
adopt aging methodology presented by
the Norton article [3], which was one of
the key citations for the development of
ASTM C1303–10. Norton completed
much of the original research in the
field of foam insulation aging.
Therefore, DOE is proposing to adopt a
test procedure, ASTM C1303–10, which
already incorporates Honeywell’s
suggested methodology.
4. The Shankland paper [4] proposes
an analytical approach to calculating
lateral gas diffusion through foam
panels with open edges. A similar
methodology is proposed in [DOE 8]
and [DOE 9], but researchers have had
difficulty modeling and predicting
blowing agent diffusion coefficients.
[DOE 8] has found that direct analytical
approach is not possible, but numerical
computer simulation to predict lateral
gas diffusion rates may be viable in a
few years.
5. The Oertel paper [5] describes
research conducted to predict the
amount of blowing agent that permeates
through building walls after being
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released from the underlying foam
insulation. The researcher notes, ‘‘if the
rigid foam is faced with a diffusion
barrier, the equilibration process cannot
occur. The original composition of the
cell gas remains unchanged and the low
initial thermal conductivity is
maintained. This was proven when
impermeable facing materials were
used. Only metallic surfaces are
impermeable.’’ This section does not cite
research confirming this claim, but as
previously mentioned, DOE agrees that
metal facers, particularly ones used in
WICF panels, are gas impermeable.
However, because the metal skins used
in WICF panels do not fully encapsulate
the foam in a contiguous manner (i.e.,
metal skin on the panel face and all
edges), gas diffusion may still occur
laterally through the panel edges.
6. DOE notes that the Ottens study [6]
is one of two of which DOE is aware that
has been completed on polyurethane
foam-in-place panels, with open edges
intended to simulate metal skinned
walk-in panels. This paper summarizes
studies completed by IMA
(Materialforschungs- und
Anwendungstechnik Dresden GmbH,
translation: Materials and Applications
Research) as requested by
Arbeitsgemeinschaft Industrieller
Forschung (translation: Association of
Industrial Research) to assess the longterm insulating behavior of sandwich
elements. In particular, this paper cites
data on carbon dioxide (CO2) blown
foams as an alternative to other blowing
agents. On page 30 of the study, Figures
4 and 5 show aging results for both core
and edge regions of test panels. The
areas greater than approximately 12
inches from the edge exhibit 2 to 3
percent aging after 6 months at a
temperature of approximately 160 °F.
Regions within 12 inches of the edge
show 5 to 17 percent aging, with the
highest rate of aging occurring at the
panel corners. Dow noted in its
reference to this paper that CO2 ‘‘has
higher diffusion speeds, [therefore] the
aged thermal conductivity would be
even better for the HFC blown foams
used in many walk-in applications.’’
DOE agrees with Dow that CO2 exhibits
a faster rate of diffusion than
hydrofluorocarbon (HFC) blowing
agents typically used in foams, which
indicates that the study is likely more
representative of a worst case aging
scenario. This study clearly
demonstrates that lateral gas diffusion
occurs in metal faced panels with open
edges. DOE also notes that the majority
of aging has occurred at the panel
perimeter, which is an expected result
because the rate of diffusion should
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decay exponentially with increased
distance (or thickness of foam) from the
exposed edge as described in ASTM
C1303–10. The authors did not note the
aging period that their test, which was
conducted over 6 months at an elevated
temperature, was intended to simulate,
but because elevated temperature
dramatically increases gas diffusion
rates, the tests are likely representative
of panels aged for at least 5 years.
7. The Bertucelli paper [7], other than
[5], is the only one that DOE has
reviewed that directly tests aging of
actual walk-in panels. Bertucelli et al.
state that, ‘‘in practice, for metal faced
sandwich panels the diffusion
phenomena can only take place through
the open sides of the panels. The initial
thermal conductivity value remains for
a long time practically unchanged for
the largest part of the panel due to the
long path for diffusion.’’ (p. 2) Again,
this research supports DOE’s claim that
significant lateral diffusion occurs
through open edges of panels. This
statement appears to be based on data
shown on page 17 that are very similar
to data shown in [6] for CO2 blown
foams. However, this test was on a 4
foot by 8 foot panel aged at room
temperature for a year. Close to the
geometric center of the panel, the
thermal performance has aged by 2 to 5
percent from its initial value.
Measurements approximately 20 inches
from the edges range from 2 to 6
percent. These data are similar to data
submitted by Carpenter (see Table III.2)
which were also from a panel aged at
room temperature but with an HFC
blowing agent. The Bertucelli paper also
notes that EN 13165, a European
material standard that was developed in
Germany but certified by the European
Committee for Standardization (CEN),
provides certified aging values for
various blowing agents used in metal
faced sandwiched foam-in-place panels.
The researchers also note that the
certified aging value for water-blown
foams, HCFC–141b and pentane is 10
percent.
8. The Glicksman paper [8] found that
the effectiveness of impermeable facers
is highly dependent on adhesion of the
foam to the facer. Slight separation
allows gas diffusion to occur
perpendicularly to the barrier and
laterally between the barrier and the
foam, which permits more rapid aging
than if the diffusion is forced through
the foam material only in the lateral
direction. This research supports DOE’s
assertion that delamination is a major
contributing factor to aging of panels.
9. EN 13165 is a material standard for
‘‘factory made rigid polyurethane foam
(PUR) products.’’ Dow noted that this
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standard has provisions for accelerated
aging of panels. This is one of the
material standards that uses the aging
factor described in [7]. DOE was
previously unaware that the CEN had
established aging factors for insulated
panels and believes that this standard
may serve as an alternative to ASTM
C1303–10 (see section III.B.3 for more
details).
In addition to comments on specific
papers submitted by stakeholders, DOE
received many general comments on the
use of ASTM C1303. DOE addresses
these additional comments below.
BASF stated that there was
insufficient evidence to support DOE’s
assertion that the diffusion as a result of
delamination, holes drilled for shelves,
and gaps at windows and doors causes
a dramatic decrease in insulation
performance of the panel, and that DOE
should publish and make available any
supporting data. (BASF, No. 1.3.003 at
p. 3–4) Honeywell stated that ASTM
C1303 was inappropriate because the
data used to select it were based on foilfaced board stock rather than metalfaced panels. (Honeywell, No. 1.3.002 at
p. 1) BASF proposes to delay a decision
on modifying ASTM C1303 to apply to
impermeably skinned panels due to a
lack of data, and instead proposes that
DOE first test and compare (1) panels
from the field that are at a known age
that is greater than 5 years, (2) newly
manufactured panels measuring the Rvalue at different points in the panels,
and (3) newly manufactured panels that
are sliced and aged according to the
methods in ASTM C1303–10. (BASF,
No. 1.3.003 at p. 4)
Carpenter submitted data, shown in
Table III.2, of panels that had been in
the field for one year. These data suggest
that R-value decreases approximately
3.1 to 4.3 percent within 1 year.
(Carpenter, No. 1.3.007a at p. 3) Dow
stated that ASTM C1303–10 states that
it is not to be used with impermeably
faced foams, and that industry literature
states that metallic, impermeable
surfaces will prevent blowing agent
diffusion. (Dow, No. 1.3.026 at p. 1)
Owens Corning submits that research
has shown that an effective barrier can
substantially reduce the rate of foam
aging. In its view, to be effective, the
barrier must have a low permeability
and the foam/barrier interface must not
allow lateral gas flow. However, all
cellular foams have some amount of
lateral gas flow. (Owens Corning, No.
1.3.030 at p. 1) In addition, Owens
Corning referenced a Massachusetts
Institute of Technology study on
insulation with metal skins using dye to
observe the diffusion of blowing agent.
The study showed that blowing agent
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can diffuse under metal skins, that it
migrates to the surface, and that it can
permeate out even underneath an air-
impermeable surface. (Owens Corning,
No. 1.2.010 at p. 256)
TABLE III.2—TESTED DATA SUBMITTED BY CARPENTER
R-value
ft2 hr° F/Btu in
Sample ID
20° F
11/2008
(initial)
Panel middle ....................................................................................
Panel edge .......................................................................................
In response to BASF’s comment that
DOE should publish and make available
any supporting data for the use of
ASTM C1303–10, DOE lists all papers in
Table III.1. Most of these papers were
already described in detail in January
NOPR, but DOE welcomes further
comment on these studies.
In response to Honeywell’s comment
regarding foil facers, DOE recognizes
that foil faced foams may not have
identical characteristics to metal skins,
but believes that foils would serve as a
reasonable proxy for general aging
behavior.
With regard to BASF’s comment that
DOE should collect field data on panels
older than 5 years of age, DOE believes
that the data submitted by Carpenter
support DOE’s assertion that significant
aging occurs over the 15 to 20 year life
of a panel and that the diffusion is
occurring laterally because aging of 3–
4 percent occurred within about 1 year,
with the edge samples aging more than
the core. DOE welcomes additional data
on this issue from panel manufacturers
and other interested parties.
As to Dow’s comments regarding the
scope of ASTM C1303–10, although
DOE agrees with Dow that ASTM
55° F
01/2010
(aged)
7.89
7.89
11/2008
(initial)
7.63
7.54
C1303–10 states that the test does not
apply to impermeably faced foams, DOE
has not proposed the use of ASTM
C1303–10 on panels themselves.
Instead, DOE has proposed that the
procedure be followed when testing the
underlying unfaced foam as a proxy for
the actual aging provisions outlined in
the NOPR that describe how the unfaced
foam samples are prepared for testing by
ASTM C1303–10. See section 4.1.2 of
Appendix A for details.
With regard to Owens Corning’s
comments that an effective barrier can
substantially reduce the rate of foam
aging, DOE agrees that impermeable
facers affect the diffusion pathway of
gases through foam. However, DOE
believes that impermeable facers delay
aging, rather than eliminate it as Dow
and ACC/CPI suggest. In addition, the
International Institute of Refrigeration
(IIR), which serves as an international
body with 61 member countries to
‘‘promote knowledge of refrigeration
technology and all its applications in
order to address today’s major issues,
including food safety and protection of
the environment,’’ states that the
thermal properties of insulation can
change over time: ‘‘It is well known that
01/2010
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7.00
7.00
thermal conductivity can increase in
plastic foams in which gaseous blowing
agent has been used * * * with such
materials, there will inevitably be a
deterioration of insulation properties
over time due to the diffusion of the
blowing agent.’’ (Insulation and
Airtightness of Cold Rooms, 2002
Edition, IIR, p.154) Because walk-in
panel perimeters are not protected by
gas impermeable materials such as the
metal skins, gas diffusion can still occur
laterally through the panel. DOE notes
that Owens Corning’s second comment
regarding the Massachusetts Institute of
Technology study on diffusion of
blowing agents points to data that
suggest the lateral flow of gas occurs at
the foam surface to metal skin interface
due to poor adhesion of the foam to
metal.
In addition to the data presented
above, DOE presents aged R-values of a
number of foam types in Table III.3.
These results are based on CAN/ULC S–
770, the Canadian thin slicing method
that is based on various versions of
ASTM C1303. Each data point is an
average of dozens of tests at the
thicknesses shown.
TABLE III.3—FOAM THIN-SLICING TEST RESULTS, SOURCE: CANADIAN LABORATORY
5-Year Long Term Thermal Resistance, CAN/ULC S–770, @ 75° F mean temperature
Permeably Faced Polyisocyanurate
Board Thermal Resistivity
°F-ft 2-h/Btu-in.
Extruded Polystyrene Board
Thermal Resistivity
°F-ft 2-h/Btu-in.
Spray-in-Place
Polyurethane Foam
Thermal Resistivity
°F-ft 2-h/Btu-in.
Thickness
Thermal Resistivity
Thermal Resistivity
Thermal Resistivity
(mm)
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Product
(°F.ft2.h/Btu.in
(°F.ft2.h/Btu.in
(°F.ft2.h/Btu.in )
100
6.178
5.607
6.197
75
6.127
5.490
5.958
50
6.028
5.339
5.703
25
5.880
5.019
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These data address concerns raised by
various interested parties that the thin
slicing method would unfairly predict
that polyurethane would perform at a
lower level than extruded polystyrene
and, in some cases, would perform at a
level as low as expanded polystyrene.
Instead, these data appear to predict that
polyurethane products would continue
to outperform extruded polystyrene on
a per inch basis. It is also important to
note that if DOE were not to propose the
use ASTM C1303–10, DOE would still
be indirectly accounting for aging in one
of two classes of foams: Board stock
foams such as extruded polystyrene.
Because board-stock insulation is
manufactured at one location, stored for
a period of time, and then shipped to
WICF panel manufacturers, the foam is
exposed to ambient temperatures and
unprotected by metal skins for a
significant period of time prior to its
installation in a WICF envelope.
Therefore, before board stock based
foams are even laminated into WICF
panels, significant aging has already
occurred. DOE believes that all of the
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above factors tend to support the use of
a test procedure that, as accurately as
possible, will uniformly represent aging
of all foam classes.
In light of the research and data
submitted by interested parties, and the
German data regarding the use of aging
factors specifically for foam-in-place
metal faced panels, DOE continues to
maintain that (1) foam aging occurs in
WICF panels, (2) the aging is possible,
even with metal facers, due to the gas
permeable edges of panels, and (3) Rvalue degradation is significant enough,
over the life of a walk-in cooler or
freezer, to warrant a long-term foam
aging test. DOE continues to urge
manufacturers and interested parties to
submit R-value data for panels aged 5 or
more years to support their particular
claims. While DOE believes there are
enough indirect and direct data to
incorporate aging into the WICF test
procedure, DOE is interested in
ensuring, to the extent possible, that it
incorporates manufacturer-submitted
data as part of its analysis.
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DOE requests comments from
interested parties regarding the proposal
to use ASTM C1303–10 to measure the
long-term R-value decline in WICF foam
insulation. DOE requests that interested
parties consider in their comments the
research and papers provided by DOE
and other commenters.
3. EN 13165:2009–02 as a Proposed
Alternative to ASTM C1303–10
As noted in the previous section,
Germany has developed a test procedure
(that was certified as a European
standard by the CEN) and calculation
methodology to determine the aged Rvalue of metal skin panels. EN
13165:2009–02, Thermal insulation
products for buildings—Factory made
rigid polyurethane foam (PUR)
products—Specification describes two
alternatives in Annex C, the fixed
increment procedure and the
accelerated aging procedure for
determining aged R-value. An overview
of the two alternatives is shown in
Figure 1 below:
BILLING CODE 6450–01–P
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BILLING CODE 6450–01–C
The alternative procedures—the fixed
increment procedure and the
accelerated aging procedure—are
selected based on certain criteria and
availability of historical data as defined
in EN 13165:2009–02. In summary, the
fixed increment procedure determines if
a facing or panel construction is ‘‘gas
diffusion tight’’ by subjecting it to an
elevated temperature for 60 days and
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determining whether there is any
decrease in the R-value. If the panel is
found to be gas tight and the test
material is also made with blowing
agents of known characteristics, then
the LTTR of the foam is determined
using assumed increments of R-value
loss. The assumed aging values have
been certified by Germany through
testing. Otherwise, the accelerated aging
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procedure must be used to determine
the LTTR. The accelerated aging
procedure subjects the panel to an
elevated temperature for 180 days and
determines the decrease in the R-value.
Like EN 13165:2009–02, which is a
standard for polyurethane products, a
similar standard exists for extruded
polystyrene: EN 13164:2009–02
Thermal insulation products for
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buildings—Factory made products of
extruded polystyrene foam (XPS)—
Specification. Annex C of EN
13164:2009–02 also provides a
methodology for determining the LTTR
of impermeably faced or ‘‘gas tight’’
products. DOE proposes, as an
alternative to ASTM C1303–10, the use
of the test procedures of these respective
standards for determining the LTTR of
walk-in polyurethane and extruded
polystyrene products. DOE proposes to
directly rely on the methods described
in EN 13164:2009–02 and EN
13165:2009–02 with two exceptions: (1)
The initial R-value must be measured at
the EPCA defined mean test
temperatures (instead of the specified
~75 °F) of 55 °F for coolers and 20 °F
for freezers and (2) the final R-value
must also be measured using the EPCA
defined mean test temperatures. Using
the initial and final R-values, a
calculated foam ‘‘derating’’ factor would
be used in place of the similar
calculation using results from ASTM
C1303–10. DOE seeks comment on the
use of EN 13164:2009–02 and EN
13165:2009–02 for determining the
LTTR of walk-in panels made from
extruded polystyrene or polyurethane,
respectively.
DOE also seeks comment on the
proposed use of CEN’s certified aged
values as an alternative to requiring
testing using ASTM C1303–10.
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
4. Version of ASTM C1303
As indicated earlier, DOE initially
proposed that the test procedure
incorporate ASTM C1303–08. 75 FR
194. Nor-Lake pointed out that a more
recent version of this testing method
was published in 2009, ASTM C1303–
09a. (Nor-Lake, No. 1.3.005 at p. 3) DOE
then determined that an even more
recent version has recently been
published, ASTM C1303–10. To address
these comments, DOE compared ASTM
C1303–08, ASTM C1303–09a and
ASTM C1303–10 and found no
substantive differences between them
that would appreciably affect the
accuracy or manner in which to
measure a given foam’s R-value. In light
of this finding, DOE is revising its
proposal to adopt the most recent
version, ASTM C1303–10.
DOE invites comment on this
proposed approach.
5. Improvements to ASTM C1303
Methodology
In the January NOPR, DOE proposed
several exceptions to ASTM C1303–08
related to sample preparation of foamin-place products. 75 FR 194.
Specifically, DOE proposed that, rather
than requiring that foam be sprayed
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onto a single sheet of wood in
accordance with section A2.3 of ASTM
C1303–08, the sample ‘‘shall be foamed
into a fully closed box of internal
dimension 60 cm × 60 cm by desired
product thickness (2 ft × 2 ft × desired
thickness). The box shall be made of 3⁄4
inch plywood and internal surfaces are
wrapped in 4 to 6 mil polyethylene film
to prevent the foam from adhering to the
box material.’’ DOE had intended for
this proposed approach to minimize
manufacturer burden while ensuring
uniform sample preparation.
In reference to this proposal,
Honeywell stated that the sample
preparation method is too prescriptive
for foam-in-place products and argued
that DOE should not dictate materials
for building the sample mold or
dimensions of the mold. Rather, it
recommended that foam-in-place
samples be prepared in a fashion that
represents the average foam properties
(or bulk foam properties) of the
commercial panel. (Honeywell, No.
1.3.020 at p. 3) ACC/CPI stated that the
sample preparation methods of
polyurethane foam are too prescriptive
when describing mold materials that
must be used, and instead
recommended adopting a modified
version of section 3.1 of ASTM C1303–
10 to account for a product
manufacturer’s typical method of panel
cavity preparation, foam injection and
cure time. (ACC/CPI, No. 1.3.006 at p.
5)
DOE agrees that spatial variation
during foam injection is a relevant
concern. To represent foam properties
more closely for various manufacturers,
DOE proposes the following changes:
1. Mold/Sample Panel Geometry
a. A panel must be prepared following
the manufacturer’s injection, curing and
assembly methods. The width and
length of the panel must be 48 inches
±1 inch and 96 inches ±1 inch,
respectively.
b. As proposed in the January NOPR,
the panel thickness shall be equal to the
desired test thickness. 75 FR 194.
2. Materials
The panel should be identical to
panels sold by the manufacturer, with
one key exception: The inner surfaces
must be lined with a material, such as
4 to 6 mil polyethylene film, to prevent
the foam from adhering to the panel
internal surfaces. (This ensures that
when the panel metal skin is removed
for testing, the underlying foam is not
damaged.)
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3. Sample Preparation
a. After the foam has cured and the
panel is ready to be tested, the facing
and framing materials must be carefully
removed to ensure that the underlying
foam is not damaged or altered.
b. A 12-inch × 12-inch square (×
desired thickness) cut from the exact
geometric center of the panel must be
used as the sample for completing
ASTM C1303–08.
These additions will allow for more
representative samples while
maintaining consistency across
manufacturers. DOE also believes, based
on its analysis of the likely impacts from
the adoption of this procedure, that
these proposed modifications will not
lead to any appreciable deviations from
the measured energy use of the
envelope. DOE invites comments from
interested parties on the reasonableness
of this prediction.
Certain interested parties raised
specific concerns as to the applicability
of ASTM C1303 to ‘‘bun stock’’ foam.
‘‘Bun stock’’ foam is foam formed in
large cylindrical tubes or ‘‘buns.’’
Dyplast, ACC/CPI, Honeywell, and ITW
all stated that DOE should not consider
ASTM C1303 because ASTM C1303
specifically states that the test method
does not apply to rigid closed-cell bun
stock foams. (Dyplast, No. 1.3.008 at p.
1; ACC/CPI, No. 1.3.006 at p. 3;
Honeywell, No. 1.3.020 at p. 2; and
ITW, No. 1.3.013 at p. 1) Dyplast
mentioned that this was due to the nonhomogenous nature of the bun stock
foams. (Dyplast, No. 1.3.008 at p. 1) ITW
further stated that ASTM C1303 would
not be applicable because it is not
possible to determine a consistent initial
time for the test and because sheets may
be cut from bun stock in different
orientations, resulting in different form
morphology. (ITW, No. 1.3.013 at p. 1)
DOE recognizes that bun stock foam is
different from other types of foam used
in WICF equipment. The foam
resembles the wood grain found in trees
and has cells that vary in size and
density by location. When the buns are
cut into board stock of various
dimensions, the foam morphology
varies from one board to another as the
boards may be cut from the bun stock
in different orientations.
DOE specified in the January NOPR
that manufacturers must use the
prescriptive method defined in ASTM
C1303 (Part A: The Prescriptive
Method), but as noted by interested
parties, the prescriptive method is not
applicable to bun stock foam. 75 FR 193.
However, in addition to Part A of ASTM
C1303, Part B: Research Method allows
for testing of bun-stock or other non-
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the research method of ASTM C1303–
10, Part B be used for testing the LTTR
for bun stock foam only.
6. Heat Transfer Through Concrete
In the January NOPR, DOE proposed
the use of the following equation to
calculate the heat transfer through the
floor of both insulated and uninsulated
WICF. 75 FR 213. That equation, along
with its defined variables, is as follows:
i ⎛
⎞ j ⎛
⎞ k ⎛
Afloor , j
Aceiling,k
Awalls,i
Qcond-door-glass = ∑ ⎜ ΔTi ×
⎟ + ∑ ⎜ ΔTj ×
⎟ + ∑ ⎜ ΔTk ×
⎜
R non glass floor,j ⎟ l ⎜
R non glass ceiling,k
R non glass wall,i ⎟ l ⎜
l ⎝
⎝
⎝
⎠
⎠
Where:
Rnon-glass,wall, i = R-value of foam used in wall
panels, of type i, h-ft2 ¥ °F/Btu,
Rnon-glass,floor, j = R-value of foam used in
floor panels, of type j, h-ft2 ¥ °F/Btu,
Rnon-glass,ceil, k = R-value of foam used in
ceiling panels, of type k, h-ft2 ¥ °F/Btu,
Rnon-glass,door, l = R-value of foam used in
non-glass doors, of type l, h-ft2 ¥ °F/Btu,
Awalls,I = area of wall, of thickness and
underlying materials of type i,
Afloor,j = area of floor, of thickness and
underlying materials of type j,
Aceiling,k = area of ceiling, of thickness and
underlying materials of type k,
Anon-glass door,l = area of doors, of thickness
and underlying materials of type l,
ΔTi = dry bulb temperature differential
between internal and external air, of type i,
°F,
ΔTj = dry bulb temperature differential
between internal and external air, of type
j, °F,
ΔTk = dry bulb temperature differential
between internal and external air, of type
k, °F, and
ΔTl = dry bulb temperature differential
between internal and external air, of type
l, °F.
To complete the calculation, DOE
proposed temperature assumptions for
the internal cooled air and the surface
temperature of the floor. The cooled air
temperature was selected based on
WICF type: 35 °F and ¥10 °F for coolers
and freezers, respectively. DOE also
assumed that the finished subfloor
surface material was made of concrete.
Additionally, DOE proposed a 55 °F
subfloor surface temperature for all
walk-ins. The temperature difference
across the floor (ΔT) could be calculated
using the 55 °F subfloor surface
temperature and the internal cooled air
assumption. With a known floor area
(Afloor), DT, and floor R-value, the heat
transfer through the floor could be
readily calculated. However, the
specific floor R-value was incorporated
into the calculation based on certain
conditions. These conditions are
described in greater detail below.
Floorless Coolers: For the scenario of
uninsulated (‘‘floorless’’) coolers, DOE
proposed a concrete R-value of 0.6 ft2 ¥
°F ¥ h/Btu, based on typical concrete
density and thickness as reported in the
2009 ASHRAE Fundamentals
Handbook.
Pre-Installed Freezer Floor: For the
scenario where (1) a manufacturer does
not provide a freezer floor; and (2) an
insulated floor has been installed on-site
by the end-user, DOE proposed that
manufacturers use R = 28 ft2 ¥ °F ¥ h/
Btu for completing the heat transfer
calculations. This R-value is the same as
the EPCA-prescribed minimum
requirement for freezer floors. BASF,
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
k ⎛
i ⎛
⎞
Aceiling,k
Awalls,i
Qcond non-glass = ∑ ⎜ ΔTi ×
⎟ + qfloor × Afloor + ∑ ⎜ ΔTk ×
⎟
⎜
⎜
R non glass wall,i ⎠
R non glass ceiling,k
l ⎝
l ⎝
Where:
If Afloor ≤ 750 ft2, qfloor = 33.153 × Afloor¥0.364,
If Afloor > 750 ft2, qfloor = 0.0002 × Afloor +
2.84,
qfloor = heat flow correction factor,
Rnon-glass,wall, i = R-value of foam used in wall
panels of type i, h ¥ ft2 ¥ °F/Btu,
Rnon-glass,floor, j = R-value of foam used in floor
panels of type j, h ¥ ft2 ¥°F/Btu,
Rnon-glass,ceil, k = R-value of foam used in
ceiling panels of type k, h ¥ ft2 ¥ °F/
Btu,
Rnon-glass,door, l = R-value of foam used in nonglass doors of type l, h ¥ ft2 ¥ °F/Btu,
Aceiling,k = area of ceiling of thickness and
underlying materials of type k,
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Anon-glass door,l = area of doors of thickness and
underlying materials of type l,
Afloor = area of floor, ft2,
DTi = dry bulb temperature differential
between internal and external air, of type
i, °F,
DTj = dry bulb temperature differential
between internal and external air, of type
j, °F,
DTk = dry bulb temperature differential
between internal and external air, of type
k, °F, and
DTl = dry bulb temperature differential
between internal and external air, of type
l, °F.
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⎞ l ⎛
Anon glass doors,l ⎞
⎟ + ∑ ⎜ ΔTl ×
⎟
⎜
⎟
R non glass doors,l ⎟
⎠ l ⎝
⎠
Eq. 1
ThermalRite, and American Panel
supported using an assumption of R–28,
while Nor-Lake stated that a value of R–
20 would be more appropriate but did
not specify why. (BASF, No. 1.3.003 at
p. 4; ThermalRite, No. 1.3.031 at p. 2;
American Panel, Public Meeting
Transcript, No. 1.2.010 at p. 263; NorLake, No. 1.3.029 at p. 4) DOE, however,
continues to hold the view that its
proposed approach best reflects the
statutory framework set out by Congress
because R–28 is the minimum freezer
floor R-value required by EISA 2007.
See 42 U.S.C. 6313(f)(1)(D).
Insulated Floor Shipped by
Manufacturer: For both coolers and
freezers, if a manufacturer provided the
floor, DOE proposed in the January
NOPR that the floor R-value (as
measured by the test procedure) be used
for the heat transfer calculations. 75 FR
198.
Between the publication of the
January NOPR and the public meeting,
DOE completed additional finite
element model (FEM) computer
simulations of floorless coolers. Based
on FEM simulation results, DOE
described a new equation during the
public meeting for calculating heat
transfer through floorless coolers:
⎞ l ⎛
Anon glass doors,l ⎞
⎟
⎟ + ∑ ⎜ ΔTl ×
⎟
⎜
R non glass doors,l ⎟
⎠
⎠ l ⎝
Eq. 2
The FEM simulations demonstrated
that using 60 °F and 65 °F would result
in more accurate energy calculations.
DOE indicated at the NOPR public
meeting that it was considering
modifying the surface temperature
assumptions for freezers and coolers to
60 °F and 65 °F, respectively, and
sought comment from interested parties
on these revised temperatures.
Several manufacturers recommended
that DOE maintain the original
assumption of 55 °F for sub-floor surface
temperature. ThermalRite requested that
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homogenous foams. DOE believes that
the research method in Part B is
appropriate and applicable for testing of
bun-stock foams. Therefore, to address
the comments from Dyplast, ACC/CPI,
Honeywell, and ITW, DOE proposes that
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55 °F be retained because it believed
that the equations were based on solid
engineering principles and data.
(ThermalRite, No. 1.3.031 at p. 2) NorLake agreed that 55 °F would be more
appropriate. (Nor-Lake, No. 1.3.029 at p.
4) Kysor and TAFCO preferred 55 °F
because it would be consistent with
industry assumptions. (Kysor, Public
Meeting Transcript, No. 1.2.010 at p.
270 and TAFCO, No. 1.3.022 at p. 3) ICS
recommended that 55 °F be maintained
as the assumption for both coolers and
freezers because a walk-in with an
insulated floor would not have an effect
on sub-floor temperature regardless of
WICF temperature. (ICS, No. 1.3.027 at
p. 2) In light of this general support and
the absence of any comments explaining
why use of a 55 °F temperature
assumption would be inappropriate,
DOE proposes continuing to apply its 55
°F assumption for all WICF for three
reasons: (1) 55 °F is the general industry
accepted value; (2) using a single
assumption simplifies calculations; and
(3) using a single temperature avoids the
complexity of accounting for various
field installation variations (such as
concrete thickness and proximity to
building walls).
Regarding the heat transfer
calculations for floorless coolers, NorLake supported using Eq. 1 as proposed
in the January NOPR. (Nor-Lake, No.
1.3.029 at p. 4) Master-Bilt and Nor-Lake
recommended that DOE consider using
the minimum thickness of 3.5 inches
rather the 6 inches as proposed in the
January NOPR for calculating the
concrete R-value, because the building
industry uses 3.5 inches. (Master-Bilt,
No. 1.3.009 at p. 2 and Nor-Lake, No.
1.3.005 at p. 4)
In this SNOPR, DOE proposes
different equations for calculating heat
transfer through floor panels, non-floor
panels (i.e., wall and ceiling panels),
and non-glass doors. Although Nor-Lake
supported using Eq. 1 as proposed in
the January NOPR, the equations
proposed in this SNOPR allow greater
flexibility in calculating heat transfer
through the envelope because they are
able to account for unique temperature
differences across each component. See
section III.B.7 for a more detailed
description of the equations in the
SNOPR. The equation for floor heat
transfer incorporates the results of FEM
simulation by using the values for the
heat flow correction factor (qfloor) that
appear in Eq. 2 above. In performing the
FEM simulation, DOE assumed 6-inchthick concrete despite Master Bilt and
Nor-Lake’s comments, because that is
the recommended floor thickness in the
ASHRAE Handbook of Fundamentals
(ASHRAE Fundamentals 2005).
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However, DOE will continue to consider
other values if they are more
appropriate for the application and asks
for comment on a more appropriate
value.
7. Walk-In Sited Within a Walk-In: A
‘‘Hybrid’’ Walk-In
In the January NOPR, the calculation
procedure provided a means of rating all
walk-ins, including the scenario where
a freezer is sited inside a cooler or
where a cooler and freezer share a
common wall.
Modifications described in this
SNOPR ensure that the rating of these
walk-in cooler/freezer hybrids is
properly captured. For example, every
panel or door may have a unique
temperature differential across the
material to reflect either a panel that
divides a cooler and freezer or a door
that may open from freezer temperatures
to cooler temperatures. See section 3.1
of Appendix A for details. In the event
an individual non-floor panel, floor
panel or door spans two temperature
regimes, the lower temperature must be
used for the purpose of calculating the
heat transfer across that component. For
example, if a floor panel spans a section
of the floor, where 80 percent of the
panel is exposed to cooler temperatures
and the other 20 percent is exposed to
freezer temperatures, the heat transfer
calculation through the floor panel must
use only the freezer temperature.
DOE believes the equations shown in
section 3.1 of Appendix A provide an
accurate means of testing a given walkin cooler, freezer or hybrid walk-in.
DOE seeks comment on the equations
and their accuracy, particularly for
hybrid walk-ins.
8. U-Factor of Doors and Windows
Conduction heat gain through doors
and windows contributes to the energy
load of the envelope. To account for this
fact, DOE proposes to measure heat gain
through doors (with and without glass)
and any other glass surfaces such as
windows, as well as through the framing
materials used for doors and windows.
In the January NOPR, DOE proposed
measuring heat gain through doors and
windows using one of the following
options: (1) For doors with a National
Fenestration Rating Council (NFRC)
rating, thermal performance would have
been determined from the NFRC label;
or (2) for doors without an NFRC rating,
thermal performance parameters would
have been determined using Window
5.2, a computer program developed by
Lawrence Berkeley National Laboratory.
75 FR 198. (The NRFC is a non-profit,
public-private partnership of the
window, door, and skylight industry.) In
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either case, DOE proposed using the
thermal performance parameters as
inputs for calculations specified in the
Test Procedure NOPR.
DOE’s proposed method was
supported by BASF, Master-Bilt, and
Nor-Lake. (BASF, No. 1.3.003 at p. 4;
Master-Bilt, No. 1.3.009 at p. 2; NorLake, No. 1.3.005 at p. 4) Kason agreed
that using third-party software (such as
Window 5.2) to evaluate window
performance is reasonable. (Kason, No.
1.3.037 at p. 4) However, NFRC
recommended using a standard size
door for all calculations to ensure a full
rating that includes frame effects and
allow for accurate reporting. (NFRC,
Public Meeting Transcript, No. 1.2.010
at p. 280) Furthermore, Schott Gemtron
pointed out that the standard glass door
in Window 5.2 is not the same as a
typical glass door used in walk-ins.
(Schott Gemtron, Public Meeting
Transcript, No. 1.2.010 at p. 284) ACEEE
stated that the manufacturers of doors
with glass surfaces should use NFRC
rating methods to certify performance.
(ACEEE, No. 1.3.034 at p. 2)
In response to the comment from
Schott Gemtron, the Window 5.2
program does not incorporate WICFspecific doors at this time because
NFRC, the primary user of Window 5.2,
has never rated WICF doors. To remedy
this situation, the typical WICF door
geometries would simply need to be
added to the Window 5.2 database.
Because use of the NFRC ratings would
avoid the need for DOE to prescribe
specific geometries or testing scenarios,
however, DOE proposes in this SNOPR
that instead of using Window 5.2,
manufacturers shall rate the total
thermal transmittance (known as Ufactor) of doors and windows, including
their framing materials, using the test
procedure NFRC 100–2010–E0A1,
‘‘Procedure for Determining Fenestration
Product U-Factors.’’ NFRC 100–2010–
E0A1 specifies a test procedure but does
not specify test conditions, which
depend on the product. Details of
proposed test conditions may be found
in section 4.1.3 of Appendix A. DOE
welcomes comments on improvements
that could be made to Window 5.2,
however, and would consider allowing
use of Window 5.2 provided that such
improvements led to results as
consistent as those achieved with the
NFRC rating.
In addition, DOE proposes applying
the provisions in section 5.2 of NFRC
100–2010–E0A1, which would provide
a uniform and reasonably accurate
method of measuring the thermal
transmittance of the door and window
components installed in a walk-in. The
section contains reference methods for
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jlentini on DSKJ8SOYB1PROD with PROPOSALS2
determining heat transfer properties for
specific side-hinged exterior door
systems, to all doors (i.e. doors without
any glass, doors with glass windows,
glass display doors, etc.) and glass
walls. Doors, as defined in Appendix A
2.1(b) of these proposed regulations,
includes the user movable components
and the framing components that
support the door hinges such as the
center mullions in display doors or door
plugs found commonly in passage
doors. The complete assembly must be
tested to find the door U-factor.
NFRC 100–2010–E0A1 provides a
means of testing representative door
geometry that can then be extrapolated
to other doors of similar materials and
geometry. This approach is less costly
but generally results in more
conservative test results. However, if a
door manufacturer or other party
responsible for testing would prefer to
perform the complete physical test
described in NFRC 100–2010–E0A1 for
all doors (i.e. not rely on NFRC’s
extrapolation methodology), the testing
entity may do so.
DOE seeks comment on the proposal
requiring windows and doors, including
their framing materials, to be rated using
NFRC 100–2010–E0A1. As stated above,
DOE also seeks comment on
improvements to the Window 5.2
program that would make its use in the
test procedure appropriate.
9. Walk-In Envelope Steady-State
Infiltration Test
In the January NOPR, DOE noted two
air exchange pathways for walk-in
envelopes: (1) Air exchange
(‘‘infiltration’’) occurring during door
opening events, the extent of which
depended on door opening area and the
frequency of door opening, and (2)
infiltration during ‘‘steady-state’’
conditions. DOE defined steady-state as
the period of time when all access
methods, such as doors, were in the
closed position. During steady-state
conditions, infiltration could occur via
cracks in door sweeps, bi-directional
pressure relief valves, and panel-topanel interfaces. Infiltration during door
opening events accounts for the majority
of infiltration into the envelope, but
steady-state infiltration could be
significant as well. Because air
infiltration plays a role in determining
the overall efficiency of a given WICF
and the likely energy consumption in
keeping its refrigerated areas cool, DOE
proposed using ASTM E741–06,
‘‘Standard Test Method for Determining
Air Change in a Single Zone by Means
of a Tracer Gas Dilution,’’ for testing the
steady-state air infiltration of walk-in
coolers and walk-in freezers. DOE
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detailed a number of requirements, such
as internal and external temperatures
during testing, sampling methods, and
gas tracer calculation type.
In comments on the January NOPR,
interested parties noted the role that
pressure relief valves play with respect
to infiltration testing. These valves are
standard equipment with walk-in
envelopes and are designed to ensure
the proper operation of a WICF unit by
relieving pressure changes that
accompany rapid cooling of warm air
after door opening events. Craig stated
that the standard pressure relief valve
on walk-ins could interfere with
infiltration testing, and Kason added
that WICF manufacturers use pressure
relief ports that allow gas to move
through the envelope and further
suggested that these ports would need to
be blocked to test infiltration. (Craig,
No. 1.3.017 at p. 2 and Kason, No. at p.
3)
Because bi-directional pressure relief
valves are considered standard
equipment for all walk-in freezers,
today’s notice clarifies that they should
be included in the general steady-state
infiltration test if they are part of the
walk-in being tested. In addition,
because valves contribute to steady-state
infiltration, it is necessary to measure
their contribution. The duration of the
steady-state test is long enough to
ensure that the average valve operation
time is accurately represented. In
addition, properly sited and designed
valves should not be opening and
closing frequently, if at all, during
steady-state conditions. Because these
valves are intended to relieve large
pressure swings caused by rapid cooling
of warm air that has entered during door
opening events, the pressure differential
across the valve should be low enough
that it remains closed during steady
state operation.
In the January NOPR, DOE also
proposed to reduce testing burden by
allowing manufacturers to test the
infiltration of a limited number of
envelopes and then scale those results
to all other envelopes manufactured.
Interested parties agreed with DOE’s
approach to reduce the testing burden
but suggested that it was necessary for
DOE to provide detailed requirements of
how the test units should be
constructed. Craig, American Panel, and
ThermalRite stated that DOE must
specify the basic unit to be tested in
terms of size and certain components,
which would be standardized across all
manufacturers. (Craig, No. 1.2.010 at pp.
102–103; American Panel, No. 1.3.024 at
p. 2; ThermalRite, No. 1.3.031 at p. 1)
DOE agrees with this approach and
proposes that with respect to the steady-
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state infiltration test, the techniques,
materials, and final assembly must be
identical to units that are shipped to
customers. The unit must be assembled
following the instruction manual
supplied by the manufacturer. Details
may be found in section 4.2 of
Appendix A.
DOE seeks comment on the
modifications to the steady-state
infiltration testing.
10. Door Steady-State Infiltration Test
In the January NOPR, DOE proposed
testing steady-state infiltration on fully
assembled envelopes using the gas
tracer method described in ASTM
E741–06, ‘‘Standard Test Method for
Determining Air Change in a Single
Zone by Means of a Tracer Gas
Dilution.’’ The NOPR proposed an
additional series of tests, using ASTM
E741–06, under certain conditions, and
would have required testing of all
possible combinations of panels and
doors.
Interested parties recommended
several alternatives for DOE to consider.
The Joint Utilities recommended the
NFRC rating method for determining
infiltration related to doors, in part
because this method, in their collective
view, provides a means to test and
sample products that would assure that
the sold product matches the quality of
the tested sample. (Joint Utilities, No.
1.3.019 at p. 12–13) Hired Hand
recommended ASTM E330–97,
‘‘Standard Test Method for Structural
Performance of Exterior Windows,
Doors, Skylights and Curtain Walls by
Uniform Static Air Pressure Difference,’’
or ASTM E283–92, ‘‘Standard Test
Method for Determining Rate of Air
Leakage Through Exterior Windows,
Curtain Walls, and Doors Under
Specified Pressure Differences Across
the Specimen.’’ (Hired Hand, No.
1.3.033 at p. 5)
In this SNOPR, DOE is proposing
measuring steady-state infiltration
through panels and doors using separate
tests for each rather than using a single
test for both as proposed in the January
NOPR. DOE is considering this
modification to reduce testing burden;
the January NOPR proposed to require
a new test for each unique panel and
door configuration, which could be
overly burdensome to test because of the
many possible configurations. For all
doors, DOE is considering NFRC 400–
2010–E0A1, ‘‘Procedure Determining
Fenestration Product Air Leakage.’’
NFRC 400–2010–E0A1 is based on
ASTM E283–04, the most recent version
of ASTM E283–92, one of the test
methods recommended by Hired Hand.
This test method is appropriate for this
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application because it was specifically
designed to measure the air leakage
through doors and fenestration
products. DOE adapted NFRC 400–
2010–E0A1 for use with doors on walkin envelopes by establishing standard
assumptions for the pressure
differences, in Pascals (Pa), across
cooler and freezer doors and requiring
the infiltration at these pressures to be
determined using a pressure-infiltration
relationship determined through testing.
Section 4.4.2 of proposed Appendix A
contains the assumptions and the
method for finding the pressureinfiltration relationship. DOE does not
intend to incorporate ASTM E330–97,
‘‘Standard Test Method for Structural
Performance of Exterior Windows,
Doors, Skylights and Curtain Walls by
Uniform Static Air Pressure Difference,’’
as suggested by Hired Hand because this
procedure measures structural
performance, which does not impact
efficiency; but DOE invites Hired Hand
to submit further justification in support
of this standard. DOE seeks comment on
the proposal to test steady-state
infiltration through doors separately
from steady-state infiltration through
panels and using NFRC 400–2010–E0A1
for both tests. DOE seeks comment on
the proposed assumptions for the
pressure differential across cooler doors
(1.5 Pa) and freezer doors (3.5 Pa). DOE
seeks comment on the proposal to
determine infiltration across cooler and
freezer doors using tests of infiltration
and exfiltration at 10 Pa to 60 Pa to
establish a pressure-infiltration
relationship with which to extrapolate
the infiltration occurring across cooler
and freezer doors.
11. Door Opening Infiltration
Assumptions
In the January NOPR, DOE proposed
to incorporate several assumptions from
the ASHRAE Handbook of
Fundamentals 2009 related to door
opening infiltration that would be used
to calculate the portion of time each
doorway is open, Dt:
(
)
⎡ P × θp + ( 60 × θο ) ⎤
⎦
Dt = ⎣
[3600 × θd ]
Eq. 3
Where:
P = number of doorway passages (i.e.,
number of doors opening events),
qp = door open-close time (seconds/P),
qo = time door stands open (minutes), and
qd = daily time period (h). 75 FR 197.
For glass display doors and all other
doors, DOE specified P = 72 and 60,
respectively. Required values for qp: (1)
reach-in glass doors, qp = 8 seconds; (2)
all other doors, qp = 15 seconds; and (3)
if an automatic door opener/closer is
used, qp = 10 seconds. DOE required
glass display doors qo = 0 minutes and
all other doors, qo= 15 minutes.
Hired Hand proposed revised
parameters for the number of door
openings (P), steady-state time, and all
other parameters in the equation for
infiltration due to door openings both
for doors with automatic door closures
and manually closed larger doors,
because, in its view, the proposed
parameters are adequate for display
cases and small walk-ins but
insufficient for evaluating large retail
supermarket applications (storage
warehouse coolers and freezers where
door entry width is greater than 4 feet
and serviced by employees only). (Hired
Hand, No. 1.3.033 at p. 3) Schott
Gemtron stated that DOE needs to
distinguish between glass display doors
and service doors because service doors
are not opened as often. (Schott
Gemtron, Public Meeting Transcript,
No. 1.2.010 at p. 314) Hired Hand also
stated that DOE should clarify the
coverage of doors because they believe
the intent of EISA 2007 was targeted
mainly at retail applications with doors
smaller than 45 inches in width. (Hired
Hand, No. 1.3.033 at p. 1)
DOE agrees with Hired Hand and
Schott Gemtron that additional
refinement to assumptions can be made
to differentiate between glass display,
passage (or service), and freight doors.
In addition, to reflect the benefit from
the use of automated doors, DOE
proposes to modify the value of qo when
a sensor and automated open/close
system is included. Therefore, DOE
proposes to define ‘‘glass display door’’
as a door designed for the movement
and/or display of product rather than
the passage of persons, ‘‘passage door’’
(or ‘‘service door’’) as an opaque door
that is less than or equal to a 45-inch
width and designed for the passage of
persons, and ‘‘freight door’’ as an opaque
door that is greater than 45-inch width.
DOE cannot specifically exclude doors
wider than 45 inches if they are used on
a walk-in cooler or walk-in freezer that
is not excluded from coverage by EISA
2007, as suggested by Hired Hand.
The new assumptions regarding doors
are reflected in Table III.4.
TABLE III.4—ASSUMPTIONS TO DIFFERENTIATE DOOR TYPES
Door type
qp
sec
P
qp,w sensor
sec
qo
min
qo,w/sensor
min
qd
hrs
Note
72
8
—
0
—
24
Proposed in
NOPR.
Passage ...........................
Freight ..............................
Glass Display ..........................
Passage ...........................
Freight ..............................
60
60
72
60
120
15
15
8
15
60
10
10
—
10
30
15
15
0
30
60
—
—
—
10
20
24
24
24
24
24
SNOPR.
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
DOE seeks comment on this
alternative approach and modified
assumptions.
12. Infiltration Reduction Device
Effectiveness
DOE discovered an error in Eq. 3–25
after the January NOPR was published.
DOE notified stakeholders of the error
and correction at the public meeting.
DOE proposes to use the corrected Eq.
3–25 in the final rule.
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ThermalRite supported the infiltration
reduction device (IRD) effectiveness test
methodology, but stated that
manufacturers of IRDs should perform
the testing. (ThermalRite, No. 1.3.031 at
p. 2) DOE acknowledges that it may be
more appropriate for a third party to test
an IRD by itself, whether that third party
is the IRD manufacturer or a different
entity, because IRD effectiveness is
largely independent of other envelope
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characteristics. Therefore, DOE proposes
several modifications to the IRD
effectiveness test that it initially
proposed. These modifications would
permit testing to be done by the IRD
manufacturer, the envelope
manufacturer, or another entity. The
modifications that DOE is considering
as alternatives to its initially proposed
approach may be found in section 4.3 of
Appendix A.
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Hired Hand stated that DOE should
include an assumed performance value
for IRDs that are subject to degradation
and do not perform consistently over
time. (Hired Hand, No. 1.3.033 at p. 5
and Public Meeting Transcript, No.
1.2.010 at p. 310) DOE believes it is
reasonable to incorporate assumed
performance values because an
established body of research supports
these values. While the assumptions do
not reflect all real-world WICF door use
scenarios or applications, it is necessary
for DOE to assume values to ensure a
uniform testing method to rate walk-ins.
These assumptions are stated in section
4.3 of proposed Appendix A to this
SNOPR.
DOE seeks comment on this
alternative approach.
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
13. Relative Humidity Assumptions
In the January NOPR, DOE proposed
the assumption of an internal walk-in
relative humidity of 45 percent. This
value was selected to match AHRI–1250
test dry-coil conditions. However, these
conditions do not necessarily reflect
general walk-in humidity conditions;
rather, the conditions were chosen to
test refrigeration systems when there is
little or no frost load on the evaporator
coil. DOE recognizes that, in practice,
the relative humidity (RH) varies
significantly depending on the product
stored within a walk-in.
In order to reflect higher RH values
experienced in practice, DOE proposes
a new assumption of 75 percent RH for
both freezer and cooler internal
conditions. This RH level is within the
65–85 percent range of humidity levels
used in practice for products from
canned beverages such as beer to
packaged fruits and vegetables. DOE
seeks comment on this assumption in
addition to assumptions found in
proposed Appendix A, section 2.1(e).
C. Refrigeration System
As previously discussed, DOE is
proposing for the purposes of this test
procedure to draw a distinction between
the envelope or structure of the walk-in
cooler or walk-in freezer and the
mechanical refrigeration system
performing the physical work necessary
to cool the interior space. The
refrigeration system itself could be one
of three types: (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) rack systems
utilizing unit coolers, which receive
refrigerant from a shared loop. The
following section addresses issues
raised by interested parties that
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prompted DOE to consider other options
in addition to those proposed in the
January NOPR.
1. Definition of Refrigeration System
During the NOPR public meeting,
DOE stated that it was considering the
following changes to the definition of
refrigeration system: substituting
‘‘integrated single package refrigeration
unit’’ with ‘‘a packaged system where the
unit cooler and condensing unit are
integrated into a single piece of
equipment’’ in order to clarify the term
and substituting ‘‘central rack system’’
with ‘‘multiplex condensing system’’
because the latter is a more inclusive
term and may be more technically
accurate.
Thermal-Rite and Nor-Lake expressed
support for the revised definition of
refrigeration system. (Thermal-Rite, No.
1.3.031 at p. 1; Nor-Lake, No. 1.3.029 at
p. 2) ACEEE stated that the definition
proposed in the January NOPR seemed
appropriate and seems to recognize the
varieties serving the marketplace.
(ACEEE, No. 1.3.034 at p. 2) Master-Bilt,
BASF, and Kason all stated that they
agreed with the definition but did not
specify which version they supported.
(Master-Bilt, No. 1.3.009 at p. 2; BASF,
No. 1.3.003 at p. 5; Kason, No. 1.3.037
at p. 4) On the other hand, Craig stated
that the definition of refrigeration
system should include a temperature
limit and suggested 45 °F as the upper
limit. (Craig, No. 1.3.036 at p. 84) A
person affiliated with Gonzaga Law also
viewed the proposed definition of
refrigeration equipment as too inclusive
but did not specify how DOE could
improve it. (William Gray, Gonzaga
Law, No. FDMS 0003 at p. 1) HeatCraft
stated that DOE should have an
exemption for refrigeration equipment
that serves loads other than walk-ins.
(HeatCraft, Public Meeting Transcript,
No. 1.2.010 at p. 92)
Regarding the above comments, DOE
believes that adding a temperature limit
to the definition of refrigeration system,
as suggested by Craig, is unnecessary
because DOE is already proposing to
add a temperature limit to the definition
of walk-ins that will cover both
envelopes and refrigeration systems. To
address HeatCraft’s concern, DOE has
included the term ‘‘multiplex
equipment’’ in the definition to refer to
refrigeration equipment serving loads
other than walk-ins. DOE’s revised
definition includes unit coolers
connected to multiplex systems,
meaning that only the unit cooler is
covered in any refrigeration system that
incorporates a multiplex system. The
multiplex systems themselves would
not be covered.
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Consistent with its discussions at the
public meeting, DOE is also proposing
to revise its proposed definition of the
term ‘‘refrigeration system’’ with respect
to WICF equipment. DOE requests
comment on the proposed alternative
definition.
2. Version of AHRI 1250
In the January NOPR, DOE proposed
to incorporate the industry standard
AHRI 1250P–2009, ‘‘Standard for
Performance Rating of Walk-In Coolers
and Freezers,’’ into the test procedure.
The January NOPR inadvertently
referred to the preliminary version of
this standard, while the final published
version is AHRI 1250–2009, which was
published in September 2009. DOE
found no significant differences
between the preliminary version and the
final version; nevertheless, DOE
proposes to incorporate the most recent
version, AHRI 1250–2009, into the final
test procedure.
3. Annual Walk-In Energy Factor
DOE is required by EPCA to establish
a test procedure to measure the energy
use of walk-in coolers and walk-in
freezers. (42 U.S.C. 6314(a)(9)(B)(i))
AHRI 1250–2009 determines the annual
walk-in energy factor (AWEF) as its final
metric, the ratio of the annual net heat
removed from the box, which includes
the internal heat gains from nonrefrigeration components but excludes
the heat gains from the refrigeration
components in the box to the annual
energy consumption. Because AWEF is
essentially a measure of efficiency, DOE
proposed in the January NOPR to
develop equations to derive energy
consumption from AWEF. 75 FR 202–
203. DOE also proposed to require
manufacturers to report both AWEF and
energy consumption and asked for
comment on this approach. 75 FR 202–
203.
Nor-Lake agreed with the proposed
method of measuring and calculating
the energy use of refrigeration systems
(Nor-Lake, No. 1.3.005 at p. 4) but also
cautioned that both the methodology for
deriving annual energy consumption
from AWEF and the reporting
requirements should be consistent
across all manufacturers. (Nor-Lake, No.
1.3.029 at p. 5) Manitowoc, on the other
hand, stated that AWEF is a more useful
metric than energy consumption
because the calculated energy
consumption may not be an accurate
representation of actual energy
consumption in the field as the load
profile in the test procedure is arbitrary.
Rather, AWEF can be used to easily
estimate actual energy consumption if
the actual load is known, and AWEF
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also allows for comparisons between
higher and lower efficiency systems.
(Manitowoc, Public Meeting Transcript,
No. 1.2.010 at p. 375) Arctic suggested
that DOE could develop software to
assist businesses with calculating
energy consumption. (Arctic, Public
Meeting Transcript, No. 1.2.010 at p.
392)
Because EISA requires that the test
procedure measure energy use, as
explained above, DOE continues to
propose that manufacturers measure
and report both AWEF and the measure
of energy use derived from AWEF as
determined by the test procedure. The
calculation methodology and reporting
requirements will be consistent across
manufacturers as suggested by NorLake.
DOE notes that in the course of
performing the test procedure and
determining AWEF, the annual energy
use of a walk-in refrigeration system
may be found as an intermediate result
or easily derived from AWEF or other
intermediate results. Thus, DOE
proposes to simplify the method by
which energy use is determined by
introducing revised calculations in the
rule language. DOE requests comment
on the simplified calculations.
DOE does not intend to develop
software for calculating energy use, as
suggested by Arctic, because this is
outside the scope of the rulemaking.
The proposed test procedure contains
all the necessary calculations for
determining AWEF and energy use, and
manufacturers may develop or use their
own software that assists them in
performing these calculations if they
choose.
IV. Regulatory Review
A. Review Under Executive Order 12866
The Office of Management and Budget
(OMB) has determined that test
procedure rulemakings do not constitute
‘‘significant regulatory actions’’ under
Executive Order (E.O.) 12866,
‘‘Regulatory Planning and Review.’’ 58
FR 51735 (October 4, 1993).
Accordingly, this action was not subject
to review under that Executive Order by
the Office of Information and Regulatory
Affairs (OIRA) of the OMB.
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
B. Review Under the National
Environmental Policy Act
In this proposed rule, DOE proposes
to adopt test procedures and related
provisions for walk-in equipment. The
test procedures would be used initially
for considering the adoption of energy
conservation standards for walk-ins, and
DOE would require their use only if
standards were subsequently adopted.
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The proposed test procedures will not
affect the quality or distribution of
energy and therefore will not result in
environmental impacts. Therefore, DOE
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. More specifically, today’s
proposed rule is covered by the
categorical exclusion in paragraph A5 to
subpart D, 10 CFR part 1021.
Accordingly, neither an environmental
assessment nor an environmental
impact statement is required.
C. 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 (IRFA) 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 E.O. 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
rulemaking process. 68 FR 7990. DOE
has made its procedures and policies
available on the Office of General
Counsel’s Web site, https://
www.gc.doe.gov.
DOE reviewed the test procedures
considered in today’s supplemental
notice of proposed rulemaking under
the provisions of the Regulatory
Flexibility Act and the procedures and
policies published on February 19,
2003.
As discussed in more detail below,
DOE found that because the proposed
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 the proposed rule, if
promulgated, would not have a
significant effect on a substantial
number of small entities. Therefore,
DOE prepared an IRFA for this
rulemaking. The IRFA describes
potential impacts on small businesses
associated with walk-in cooler and
freezer testing requirements. DOE has
transmitted a copy of this IRFA to the
Chief Counsel for Advocacy of the Small
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55087
Business Administration (SBA) for
review. This SNOPR includes changes
made to the IRFA in light of comments
from interested parties on the January
NOPR, specifically regarding the
number of small entities regulated and
the potential testing burden. The revised
IRFA also considers the burden of new
tests that DOE is proposing in this
SNOPR.
1. Reasons for the Proposed Rule
The reasons for this proposed rule are
discussed elsewhere in the preamble
and not repeated here.
2. Objectives of and Legal Basis for the
Proposed Rule
The objectives of and legal basis for
the proposed rule are discussed
elsewhere in the preamble and not
repeated here.
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 https://www.sba.gov/idc/
groups/public/documents/
sba_homepage/serv_sstd_tablepdf.pdf.
In the January NOPR, 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 204.
After reviewing industry sources and
publicly available data, DOE identified
at least 37 small manufacturers of walkin cooler and freezer envelopes and at
least 5 small manufacturers of walk-in
cooler and freezer refrigeration systems
that met this criterion.
In comments on the January NOPR,
both American Panel and Kysor said
that virtually all panel and walk-in
manufacturers are small businesses
under this standard. (American Panel,
Public Meeting Transcript, No. 1.2.010
at p. 379; Kysor, No. 1.3.035 at p. 3)
Craig said that it was a small business
under this standard. (Craig, Public
Meeting Transcript, No. 1.2.010 at p. 17)
Schott Gemtron stated that over 90
percent of the membership of the trade
association of North American Food
Equipment Manufacturers (NAFEM)
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was under $12 million in sales. (Schott
Gemtron, Public Meeting Transcript,
No. 1.2.010 at p. 389) Several
commenters listed sources DOE could
use to identify small businesses: NorLake recommended the NSF Standard 7
listings, Arctic recommended the
NAFEM database, and ICS
recommended the central contractor
registry. (Nor-Lake, No. 1.3.029 at p. 5;
Arctic, Public Meeting Transcript, No.
1.2.010 at p. 388; and ICS, Public
Meeting Transcript, No. 1.2.010 at p.
390)
In light of these comments and
additional research conducted by DOE,
the industry can be characterized by a
few manufacturers that are subsidiaries
of much larger companies (who 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. DOE acknowledges
the sources provided by Nor-Lake,
Arctic, and ICS and will consider these
sources in its characterization of the
industry in the final regulatory
flexibility analysis (FRFA).
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
4. Description and Estimate of
Compliance Requirements
In the NOPR, DOE described potential
impacts of the proposed test procedures.
DOE received comments from
manufacturers regarding the estimated
impacts. Arctic stated that potential
impacts of the proposed test procedures
on manufacturers, including small
businesses, come from impacts
associated with the cost of testing.
(Arctic, No. 1.3.012 at p. 1) ICS
commented that burden would come
both from testing cost and length of time
required to perform the tests. (ICS, No.
1.3.027 at p. 2) BASF commented on
specific tests, stating that ASTM C1303–
08 is more expensive than ASTM C518–
04 and that ASTM E741–06 and AHRI
1250–2009 were even more expensive.
(BASF, No. 1.3.003 at p. 5) Master-Bilt,
American Panel, and Hill Phoenix all
commented that the test procedure
would be particularly burdensome to
small businesses. (Master-Bilt, No.
1.3.009 at p. 3; American Panel, No.
1.3.024 at p. 4; Hill Phoenix, No. 1.2.023
at p. 3) Craig asserted that the cost of
testing could be up to $1 million and
would be likely to put small companies
out of business or force them to sell
noncompliant products. (Craig, No.
1.3.017 at p. 1; No. 1.3.036 at p. 4; and
Public Meeting Transcript, No. 1.2.010
at p. 18)
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Envelope Manufacturer Testing Impacts
In the January NOPR, DOE proposed
to require envelope manufacturers to
test their equipment in accordance with
two industry test standards: ASTM
C1303–08, ‘‘Standard Test Method of
Predicting Long Term Thermal
Resistance of Closed-Cell Foam
Insulation,’’ and ASTM E741–06,
‘‘Standard Test Method for Determining
Air Change in a Single Zone by Means
of a Tracer Gas Dilution’’ (ASTM C1303–
08 has since been updated to ASTM
C1303–10, but the updated version
contains no substantive changes that
would affect the testing cost). DOE
spoke with industry experts to
determine the approximate cost of each
test and determined that a test using
ASTM C1303–08 costs between
approximately $5,000 and $10,000, and
a test using ASTM E741–06 costs
between $1,000 and $5,000. Therefore,
in the January NOPR, DOE estimated
that the cost of testing for one walk-in
would range from $6,000 to $15,000.
Also, DOE estimated that a typical
manufacturer would have
approximately 8 basic envelope
configurations that would need to be
tested, so the total cost of compliance
due to testing would be approximately
$84,000 (ranging from $48,000 to
$120,000). This estimated total cost only
includes the cost of one test on each
basic configuration, and does not
include additional testing on the same
basic model that may be required as part
of a sampling plan. DOE may consider
development of a sampling plan in a
future rulemaking.
The revisions to the proposed test
procedure that are proposed in this
SNOPR for envelope manufacturers
would require testing in accordance
with the two tests mentioned above as
well as an additional test: ASTM
C1363–05, ‘‘Standard Test Method for
Thermal Performance of Building
Materials and Envelope Assemblies by
Means of a Hot Box Apparatus.’’ The
SNOPR would also require the
measurement of heat gain through doors
(with and without IRD and including
glass doors) to be tested using NFRC
procedures, rather than allowing for use
of either the NFRC procedures or the
Window 5.2 program. DOE determined
that a test using ASTM C1363–05 costs
between $1,000 and $3,000, and NFRC
testing cost varies between $1,000 and
$10,000 for all doors and IRDs
depending on product lines. However,
NFRC has reduced fees for small
businesses, which it defines as
companies with less than $1 million in
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sales.1 These reduced fees are 50
percent of members’ annual fees and
product line fees (33 percent of nonmembers’ annual fees and product line
fees), and a waiver of label fees. DOE
realizes that this definition differs from
the SBA size threshold set out for walkin envelope manufacturers but believes
that some entities that are small
businesses pursuant to SBA’s size
threshold could also qualify for these
reduced fees.
To address the comments from Arctic,
ICS, BASF, Master-Bilt, American Panel,
Hill Phoenix, and Craig regarding
testing costs, DOE notes that provisions
in the January NOPR and revisions to
the proposed test procedure that are
considered in this SNOPR allow
manufacturers to test a limited number
of models and model components and
then calculate the performance of other
models from the test results.
Measurements incorporating these
revisions include heat transfer through
panels (see section III.B.1), steady state
infiltration through the envelope (see
section III.B.9), and door and IRD
performance (see section III.B.12). DOE
estimates that a typical envelope
manufacturer could be required to
perform ASTM C1303–10 on between 1
and 2 types of foam; ASTM C1363–05
on 1 to 2 types of panel pairs; ASTM
E741–06 on 1 to 2 envelopes; and NFRC
testing on 1 to 3 types of doors and 1
to 3 types of IRD. The total cost of one
test on each type of walk-in or
component listed could range from
$8,000 to $46,000. This estimated cost
could vary significantly depending on
the number of unique components
incorporated into a particular
manufacturer’s walk-ins. Furthermore,
the estimated total cost only includes
the cost of one test on each item listed.
DOE may consider developing a
sampling plan in a future rulemaking to
determine how many tests need to be
performed on the same type of envelope
or component, to ensure the test results
are repeatable and statistically valid.
Therefore, DOE welcomes comment on
this estimate.
Refrigeration System Manufacturer
Testing Impacts
The proposed test procedure for
refrigeration systems would require
manufacturers to perform testing in
accordance with a single industry test
standard: AHRI Standard 1250–2009,
‘‘2009 Standard for Performance Rating
of Walk-In Coolers and Freezers.’’
Because this test was recently
developed by the industry and has not
1 https://www.nfrc.org/documents/
ProgramCostsFactsheet.pdf.
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yet been widely used to test
refrigeration systems, DOE could not
determine how much the test currently
costs. However, DOE researched the cost
of other, similar standards and
estimated in the January NOPR that a
test using AHRI Standard 1250–2009
would likely cost approximately $5,000.
DOE has not received evidence to the
contrary and thus maintains this
estimate for the SNOPR for a single test.
In the January NOPR, DOE estimated
that the total testing cost for a typical
refrigeration manufacturer could be
approximately $250,000, based on an
estimate of 50 basic models, but 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 million. Master-Bilt
stated that they sell over 160 models of
condensing units and 130 models of
evaporators, with over 1500
combinations. (Master-Bilt, No. 1.3.009
at p. 3) (DOE notes that Master-Bilt is
not considered a small business because
it has more than 750 employees
including its parent company.) In
comments on the January NOPR, Craig
stated that under DOE’s estimated cost
of $250,000, small manufacturers would
be forced to discontinue assembling
their own refrigeration systems and
instead purchase units from large
manufacturers, making them less
competitive. (Craig, No. 1.3.017 at p. 2)
DOE further notes that the estimated
testing cost does not include cost of the
tested equipment and asks whether
manufacturers could sell equipment that
had been tested, thus reducing this cost.
To address these concerns, DOE is
proposing burden-reducing measures for
refrigeration system manufacturers
similar to those for envelope
manufacturers. The test procedure
proposed in the January NOPR, AHRI
1250–2009, which DOE continues to
propose in this SNOPR, allows for rating
the condensing unit and the unit cooler
separately and then calculating their
combined efficiency; this would reduce
testing burden by not requiring every
combination to be tested. Allowing for
the use of such a calculation would
significantly decrease the number of
tests.
DOE recognizes the particular burden
of the envelope and refrigeration tests
on small manufacturers. Because the
cost of running each test is the same for
all manufacturers, both small and large,
and because DOE has proposed
measures to reduce burden on all such
manufacturers, manufacturers would
likely incur comparable absolute costs
as a result of the proposed test
procedures. However, Kason stated that
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the burden of testing will be greater on
small manufacturers because they will
sell fewer units per type of basic model.
(Kason, No. 1.3.037 at p. 4) Indeed, DOE
does not expect that small
manufacturers would have fewer basic
models than large manufacturers,
because the equipment is highly
customized throughout the industry. 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 above.
DOE requests comment on quantitative
differential impacts and will consider
presenting such impacts in the FRFA.
To further address concerns about
costs, DOE notes that for both envelopes
and refrigeration systems, DOE may
consider development of a sampling
plan to determine how many units must
be tested to establish compliance and
enforcement requirements. In such a
rulemaking, however, DOE could also
consider additional methods to reduce
the testing burden on manufacturers.
For example, DOE could consider
allowing manufacturers to rely on
component suppliers for test results,
and manufacturers could then use these
values in their calculations of energy
consumption of the walk-in. DOE could
also allow manufacturers to group basic
models into a ‘‘family’’ of models and
only require the lowest-efficiency basic
model in the family to be certified. DOE
could also consider allowing
manufacturers to use validated
alternative efficiency determination
methods, or AEDMs, which could
consist of a calculation or computer
program, to rate their equipment. DOE
will consider the impacts to small
businesses of future certification,
compliance, and enforcement
provisions for walk-in coolers and
freezers in a later rulemaking.
5. Duplication, Overlap, and Conflict
with Other Rules and Regulations
DOE is not aware of any rules or
regulations that duplicate, overlap, or
conflict with the rule being considered
today.
6. Significant Alternatives to the Rule
DOE considered a number of
alternatives to the proposed test
procedure, including test procedures
that incorporate industry test standards
other than the three proposed standards,
ASTM C1303–08, ASTM E741–06, and
AHRI Standard 1250P–2009, described
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above. Instead of requiring ASTM
C1303–08 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 (i.e., the point of
manufacture). (Because ASTM C1303–
08 incorporates ASTM C518–04,
requiring ASTM C1303–08 is consistent
with the statutory requirement for
basing measurement of the thermal
conductivity of the insulation on ASTM
C518–04.) (42 U.S.C. 6314(a)(9)(A)) A
test of ASTM C518–04 alone costs
approximately $500 to $1,000. However,
DOE is considering ASTM C1303 for
other reasons; namely, the concern that
ASTM C518–04 alone does not capture
the performance characteristics of a
walk-in over the period of its use,
because it does not account for
significant changes in the thermal
properties of insulation over time.
DOE also considered ASTM E1827–
96(2007), ‘‘Standard Test Methods for
Determining Airtightness of Buildings
Using an Orifice Blower Door,’’ instead
of ASTM E741–06, for testing
infiltration. ASTM E1827–96(2007)
costs about $300–$ to 500 for a single
test. However, DOE believes that ASTM
E1827–96(2007) is not appropriate for
walk-ins because it is conducted by
placing test equipment in the door and
thus does not account for infiltration
through the door, which is a major
component of infiltration in walk-ins. In
addition, it is not intended for testing
envelope systems, such as a walk-in,
that have a large temperature difference
between the internal and external air.
Therefore, to complete a blower-door
test, the walk-in could not be tested at
or close to operational temperatures,
resulting in a test that does not
accurately reflect its performance.
In the framework document, DOE
considered adapting an existing test
procedure for commercial refrigeration
equipment, such as ARI Standard 1200–
2006, ‘‘Performance Rating of
Commercial Refrigerated Display
Merchandisers and Storage Cabinets,’’ as
an alternative to AHRI Standard 1250–
2009. The two tests are based on a
similar methodology for rating
refrigeration equipment in general, but
ARI Standard 1200–2006 requires
testing at only one set of ambient
conditions, whereas AHRI Standard
1250–2009 requires testing at three sets
of ambient conditions for refrigeration
systems with the condensing units
located outdoors. The additional time
required to test the system at three sets
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of conditions would incur additional
cost and could make AHRI Standard
1250–2009 more burdensome than ARI
Standard 1200–2006. However, DOE
believes that AHRI Standard 1250–2009
is more appropriate for testing walk-ins
than ARI Standard 1200–2006. A test
procedure based on ARI Standard 1200–
2006 would require the entire walk-in to
be tested as a whole, but manufacturers
might not have a large enough test
facility to make the measurements
necessary for the ARI 1200–2006 test
procedure in a controlled environment.
Also, the refrigeration system is often
manufactured separately from the
insulated envelope. In this case,
whoever assembled the two components
would bear the burden of conducting
ARI 1200–2006; this party might not be
the manufacturer of the refrigeration
system. In contrast, AHRI 1250–2009
tests only the refrigeration system. It
does not require a larger test chamber
than other, similar tests and can be
conducted by the manufacturer of the
refrigeration system. Because AHRI
1250–2009 requires the system to be
tested at three ambient temperatures, it
captures energy savings from features
(e.g., floating head pressure) that allow
the system to use less energy at lower
ambient temperatures.
DOE requests comment on the
impacts to small business manufacturers
for these and any other possible
alternatives to the proposed rule.
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
D. Review Under the Paperwork
Reduction Act
DOE recognizes that if it adopts
standards for walk-in coolers and walkin freezers, once the standards become
operative, manufacturers would become
subject to record-keeping requirements
associated with compliance with the
standards. Such record-keeping
requirements would require OMB
approval pursuant to the Paperwork
Reduction Act, 44 U.S.C. 3501, et seq.
DOE will comply with the requirements
of the Paperwork Reduction Act if and
when energy conservation standards are
adopted.
E. Review Under the Unfunded
Mandates Reform Act of 1995
Title II of the Unfunded Mandates
Reform Act of 1995 (Pub. L. 104–4)
(UMRA) requires each Federal agency to
assess the effects of Federal regulatory
actions on State, local, and Tribal
governments and the private sector.
With respect to a proposed regulatory
action that may result in the
expenditure by State, local, and Tribal
governments, in the aggregate, or by the
private sector of $100 million or more
(adjusted annually for inflation), section
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202 of UMRA requires a Federal agency
to publish estimates of the resulting
costs, benefits, and other effects on the
national economy. (2 U.S.C. 1532(a), (b))
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 before establishing any
requirements that might significantly or
uniquely potentially affect small
governments. On March 18, 1997, DOE
published a statement of policy on its
process for intergovernmental
consultation under UMRA. 62 FR12820.
(also available at https://
www.gc.doe.gov). The proposed rule
published today does not provide for
any Federal mandate likely to result in
an aggregate expenditure of $100
million or more. Therefore, the UMRA
does not require a cost benefit analysis
of today’s proposal.
F. Review Under the Treasury 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
that may affect family well-being. This
proposed rule would 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.
G. 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 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 has examined today’s
proposed rule and has determined that
it does not preempt State law and does
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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 proposed 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) No further action is required by
E.O. 13132.
H. Review Under Executive Order 12988
With respect to the review of existing
regulations and the promulgation of
new regulations, section 3(a) of E.O.
12988, ‘‘Civil Justice Reform’’, 61 FR
4729 (February 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; and (3) provide a
clear legal standard for affected conduct
rather than a general standard and
promote simplification and burden
reduction. Section 3(b) of E.O. 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 E.O. 12988 requires Executive
agencies to review regulations in light of
applicable standards in section 3(a) and
section 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
proposed rule meets the relevant
standards of E.O. 12988.
I. Review Under the Treasury and
General Government Appropriations
Act, 2001
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. Both OMB’s and DOE’s guidelines
were published. 67 FR 8452 (February
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22, 2002) and 67 FR 62446 (October 7,
2002), respectively. DOE has reviewed
today’s notice under the OMB and DOE
guidelines and has concluded that it is
consistent with applicable policies in
those guidelines.
J. 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 the Office of
Information and Regulatory Affairs
(OIRA), OMB, a Statement of Energy
Effects for any proposed 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 is (1) a significant regulatory
action under E.O. 12866, or any
successor order; and (2) likely to have
a significant adverse effect on the
supply, distribution, or use of energy; or
(3) designated by the Administrator of
OIRA as a significant energy action. For
any proposed significant energy action,
the agency must give a detailed
statement of any adverse effects on
energy supply, distribution, or use
should the proposal be 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 E.O.
12866. Moreover, it would not have a
significant adverse effect on the supply,
distribution, or use of energy. The
Administrator of OIRA also did not
designate today’s action as a significant
energy action. Therefore, it is not a
significant energy action, and DOE has
not prepared a Statement of Energy
Effects.
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
K. Review Under Executive Order 12630
DOE has determined pursuant to E.O.
12630, ‘‘Governmental Actions and
Interference with Constitutionally
Protected Property Rights’’, 53 FR 8859
(March 18, 1988), that this proposed
rule would not result in any takings
which might require compensation
under the Fifth Amendment to the U.S.
Constitution.
L. Review Under Section 32 of the
Federal Energy Administration (FEA)
Act of 1974
Under section 301 of the Department
of Energy Organization Act (Pub. L. 95–
91), 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) Section 32
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provides in part that where a proposed
rule contains or involves use of
commercial standards, the rulemaking
must inform the public of the use and
background of such standards. The rule
proposed in this notice incorporates
testing methods contained in the
following commercial standards: ASTM
C1303–08, ‘‘Standard Test Method of
Predicting Long Term Thermal
Resistance of Closed-Cell Foam
Insulation;’’ ASTM E741–06, ‘‘Standard
Test Method for Determining Air
Change in a Single Zone by Means of a
Tracer Gas Dilution;’’ and AHRI
Standard 1250P, ‘‘2009 Standard for
Performance Rating of Walk in Coolers
and Freezers.’’ DOE has evaluated these
standards and is unable to conclude
whether they fully comply with the
requirements of section 32(b) of the
Federal Energy Administration Act, i.e.,
whether they were developed in a
manner that fully provides for public
participation, comment, and review. As
required by section 32(c) of the Federal
Energy Administration Act of 1974, as
amended, DOE will consult with the
Attorney General and the Chairman of
the Federal Trade Commission before
prescribing a final rule concerning the
impact on competition of requiring
manufacturers to use the methods
contained in these standards to test
walk-in equipment.
V. Public Participation
A. Submitting Public Comment
DOE will accept comments, data, and
information regarding the supplement to
the proposed rule no later than the date
provided at the beginning of this notice.
Comments, data, and information
submitted to DOE’s e-mail address for
this rulemaking should be provided in
WordPerfect, Microsoft Word, PDF, or
text (ASCII) file format. Interested
parties should avoid the use of special
characters or any form of encryption,
and wherever possible, comments
should include the electronic signature
of the author. Comments, data, and
information submitted to DOE via mail
or hand delivery/courier should include
one signed original paper copy. No
telefacsimiles (faxes) will be accepted.
According to 10 CFR 1004.11, any
person submitting information that he
or she believes to be confidential and
exempt by law from public disclosure
should submit two copies: One copy of
the document including all the
information believed to be confidential,
and one copy of the document with the
information believed to be confidential
deleted. DOE will make its own
determination as to the confidential
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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 items; (2) whether
and why such items are customarily
treated as confidential within the
industry; (3) whether the information is
generally known by or available from
other sources; (4) whether the
information has previously been made
available to others without obligation
concerning its confidentiality; (5) an
explanation of the competitive injury to
the submitting person which would
result from public disclosure; (6) a date
upon which such information might
lose its confidential nature due to the
passage of time; and (7) why disclosure
of the information would be contrary to
the public interest.
B. Issues on Which DOE Seeks Comment
DOE is particularly interested in
receiving comments on the following
issues:
1. Upper Limit of Walk-In Cooler
EPCA defines walk-in cooler or walkin freezer as ‘‘an enclosed storage space
refrigerated to temperatures,
respectively, above, and at or below 32
degrees Fahrenheit that can be walked
into, and has a total chilled storage area
of less than 3,000 square feet.’’ (42
U.S.C. 6311(20)(A)) DOE proposes
clarifying the term ‘‘refrigerated’’ within
the definition of walk-in cooler or walkin freezer to distinguish walk-ins from
conditioned storage spaces. DOE
proposes an upper limit of 55 °F
because this is a generally accepted
boundary between ‘‘refrigerated space’’
and ‘‘conditioned space.’’ DOE requests
comment on this proposal. For details,
see section III.A.1.
2. Basic Model of Envelope
Although often manufactured
according to the same basic design,
walk-in envelopes are so highly
customized that each walk-in a
manufacturer builds may be unique. To
address this possibility, DOE proposed
the following in the January NOPR: (1)
Grouping walk-in envelopes with
essentially identical construction
methods, materials, and components
into a single basic model; and (2)
adopting a calculation methodology for
determining the energy consumption of
units within the basic model. 75 FR 189.
Upon further consideration, DOE
proposes in this SNOPR that a basic
model of walk-in envelope should
include equipment with the same
design features, components,
manufacturing method, etc., such that
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units within the basic model are the
same with respect to the normalized
energy consumption as determined by
the test procedure (i.e., the energy
consumption divided by square feet of
surface area.) DOE believes that this
definition of basic model will ensure
that all equipment is accurately rated
and complies with the standard.
DOE recognizes this revised definition
of ‘‘basic model’’ is narrower than the
definition proposed in the January
NOPR. However, the increase in test
burden resulting from the narrower
definition could be offset by the burdenreducing measures proposed elsewhere
in the test procedure. Additionally, this
definition would be consistent with the
definition of basic model elsewhere in
the appliance standards program. The
proposed definition would provide a
way of distinguishing walk-ins that
differ in energy consumption from walkins that differ only in cosmetic or nonenergy-related features. DOE requests
comment on the proposed definition.
For details, see section III.A.3.
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
3. Basic Model of Refrigeration
Interested parties commented that the
definition proposed in the January
NOPR was ambiguous; thus, DOE
proposes to clarify the definition.
As with envelopes, DOE must ensure
that all refrigeration systems are
accurately rated and comply with the
standard. Therefore, DOE proposes a
definition for basic model of walk-in
refrigeration such that units within the
basic model must be the same with
respect to energy consumption as
determined by the test procedure. To
relieve potential testing burden of many
combinations of equipment, the
proposed test procedure provides for
rating a refrigeration system’s condenser
and evaporator separately and then
calculating the system energy
consumption. DOE requests comment
on the revised approach and definition
of basic model of refrigeration. For
details, see section III.A.4.
SNOPR, DOE proposes that panels
(walls, ceilings, and floors) made with
foam insulation are tested using ASTM
C1363–05, ‘‘Standard Test Method for
Thermal Performance of Building
Materials and Envelope Assemblies by
Means of a Hot Box Apparatus,’’ for
measuring the overall U-factor of fullyassembled panels. The resulting
composite panel U-factor found by
ASTM C1363–05 will then be corrected
using the LTTR results from ASTM
C1303–10. DOE believes that using the
results from ASTM C1363–05 modified
by ASTM C1303–10 best captures the
impact of structural members and longterm R-value of foam products. DOE
requests comment on this approach. For
details, see section III.B.1.
6. Alternatives to ASTM C1303–10
DOE proposes the use of alternative
test methods found in Annex C of EN
13165:2009–02 and EN 13164:2009–02
for determining the long term thermal
resistance (LTTR) of walk-in panels
made using foam insulation. For details,
see section III.B.3.
7. Improvements to ASTM C1303
Methodology
DOE proposes several modifications
to the ASTM C1303 methodology to
address sample preparation and
applicability to certain types of foam
used in walk-ins and requests comment
on these modifications. For details, see
section III.B.5.
4. Updates to Standards
After the NOPR was published, DOE
learned that two of the standards
incorporated by reference had been
updated. DOE proposes to incorporate
the updated versions in the final rule.
For details, see sections III.B.4 and
III.C.2.
8. Conduction Through Floors
In the January NOPR, DOE proposed
an equation to calculate the heat transfer
through the floor of both insulated and
uninsulated WICF, and proposed
assumptions for subfloor temperature
and floor R-value (where the floor is
provided separately from the panels).
Between the publication of the January
NOPR and the public meeting, DOE
completed additional finite element
model (FEM) computer simulations of
floorless coolers. Based on FEM
simulation results, DOE described a new
equation during the public meeting for
calculating heat transfer through
floorless coolers. In light of this
modeling and additional comments
from interested parties, DOE is
proposing a new method for calculating
the heat transfer through certain floors.
See section III.B.6 for more details.
5. Heat Conduction Through Structural
Members
Interested parties commented that
DOE’s proposed test procedure did not
account for heat conduction through
structural members of the envelope such
as a wood frame. Therefore, in this
9. ‘‘Hybrid’’ Walk-ins
In the January NOPR, the calculation
procedure provided a means of rating all
walk-ins including the scenario when a
freezer is sited inside a cooler or a
cooler and freezer share a wall.
Modifications described in this SNOPR
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ensure that the rating of these walk-in
cooler/freezer hybrids is properly
captured. DOE seeks comment on these
modifications and the accuracy of the
new equations. See section III.B.7 for
details.
10. U–Factor of Doors and Windows
DOE proposes to base the calculation
of U-factor of doors and glass windows
on NFRC 100–2010–E0A1, ‘‘Procedure
for Determining Fenestration Product
U–Factors’’ and requests comment on
this proposal. For details, see section
III.B.7.
11. Envelope Infiltration
DOE proposes modifications to its
calculations and methodology for
determining steady state infiltration rate
through panel-to-panel and door-topanel interfaces. DOE also modified its
proposed assumptions for door opening
infiltration and effectiveness of
infiltration reduction devices. DOE
requests comment on its approach and
assumptions related to infiltration. For
details, see sections III.B.9, III.B.10,
III.B.11, and III.B.12.
12. Relative Humidity Assumptions
In the January NOPR, DOE proposed
the assumption of an internal walk-in
relative humidity of 45 percent to be
consistent with dry-coil conditions in
the proposed refrigeration system test.
DOE recognizes that in practice the
relative humidity (RH) varies
significantly depending on the product
stored within a walk-in. Therefore, in
order to reflect higher RH values
experienced in practice, DOE proposes
a new assumption of 75 percent RH for
both freezer and cooler internal
conditions. DOE seeks comment on this
assumption. See section III.B.7 for
details.
13. Definition of Refrigeration System
In the January NOPR, DOE proposed
a definition of refrigeration system and
then presented a revised definition at
the NOPR public meeting. In light of
comments from interested parties, DOE
is proposing to incorporate its revised
definition with some modification. DOE
requests comment on the revised
definition and whether any previously
proposed versions of the definition are
preferable. See section III.C.1 for details.
14. Annual Walk-In Energy Factor
DOE is required by EPCA to establish
a test procedure to measure the energy
use of walk-in coolers and walk-in
freezers. (42 U.S.C. 6314(a)(9)(B)(i))
AHRI 1250–2009 determines the annual
walk-in energy factor (AWEF) as its final
metric, which is the ratio of the annual
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net heat removed from the box, which
includes the internal heat gains from
non-refrigeration components but
excludes the heat gains from the
refrigeration components in the box, to
the annual energy consumption. In the
course of performing the test procedure
and determining AWEF, the annual
energy use of a walk-in refrigeration
system may be found as an intermediate
result or easily derived from AWEF or
other intermediate results. Thus, DOE
proposes to simplify the method by
which energy use is determined and
require manufacturers to determine both
energy use and AWEF. DOE requests
comment on the simplified calculations
in the rule language. For details, see
section III.C.3.
15. Impacts on Small Businesses
In the January NOPR, DOE prepared
an initial regulatory flexibility analysis
(IRFA) as required by the Regulatory
Flexibility Act (5 U.S.C. 601 et seq.)
because it could not certify that the rule,
if promulgated, will not have a
significant economic impact on a
substantial number of small entities.
DOE received comment from interested
parties on the number of small entities
and the expected economic impact of
the proposed test procedure on small
entities and has revised the IRFA
accordingly. DOE continues to request
comment on impacts to small business
manufacturers, particularly differential
impacts to small and large businesses.
More information, along with revisions
to the IRFA, can be found in section
IV.C.
VI. Approval of the Office of the
Secretary
The Secretary of Energy has approved
publication of this supplement to the
proposed rule.
List of Subjects in 10 CFR Part 431
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
Administrative practice and
procedure, Confidential business
information, Energy conservation,
Incorporation by reference, Reporting
and recordkeeping requirements.
Issued in Washington, DC, on August 23,
2010.
Cathy Zoi,
Assistant Secretary, Energy Efficiency and
Renewable Energy.
For the reasons stated in the
preamble, DOE proposes to revise part
431 of chapter II of title 10, of the Code
of Federal Regulations, to read as set
forth below.
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PART 431—ENERGY EFFICIENCY
PROGRAM FOR CERTAIN
COMMERCIAL AND INDUSTRIAL
EQUIPMENT
1. The authority citation for part 431
continues to read as follows:
Authority: 42 U.S.C. 6291–6317.
2. Section 431.302 is amended by
adding the definitions for ‘‘Basic
Model,’’ ‘‘Envelope,’’ ‘‘Refrigerated,’’
‘‘Refrigeration system,’’ and ‘‘Walk-in
equipment’’ in alphabetical order to read
as follows:
§ 431.302 Definitions concerning walk-in
coolers and walk-in freezers.
Basic model means—
(1) With respect to envelopes, all
units manufactured by a single entity,
which do not have any differing features
or characteristics that affect normalized
energy consumption.
(2) With respect to refrigeration
systems, all units manufactured by a
single entity, which do not have any
differing electrical, physical, or
functional characteristics that affect
energy consumption.
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.
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
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.
*
*
*
*
*
Walk-in equipment means either the
envelope or the refrigeration system of
a walk-in cooler or freezer.
3. In § 431.303, add new paragraphs
(b)(2), (b)(3), (b)(4), (b)(5), (c), (d), and
(e) to read as follows:
§ 431.303 Materials incorporated by
reference.
*
*
*
*
*
(b) * * *
(2) ASTM C1303–10, Standard Test
Method of Predicting Long Term
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55093
Thermal Resistance of Closed-Cell Foam
Insulation, approved 2010, IBR
approved for § 431.304.
(3) ASTM C1363–05, Standard Test
Method for Thermal Performance of
Building Materials and Envelope
Assemblies by Means of a Hot Box
Apparatus, approved 2005, IBR
approved for § 431.304.
(4) ASTM E283–04, Standard Test
Method for Determining Rate of Air
Leakage Through Exterior Windows,
Curtain Walls, and Doors Under
Specified Pressure Differences Across
the Specimen, approved 2004, IBR
approved for § 431.304.
(5) ASTM E741–06 Standard Test
Method for Determining Air Change in
a Single Zone by Means of a Tracer Gas
Dilution, approved October 1, 2006, IBR
approved for Sec. 431.304.
(c) AHRI. Air-Conditioning, Heating,
and Refrigeration Institute, 2111 Wilson
Boulevard, Suite 500, Arlington, VA
22201, (703) 600–0366, or https://
www.ahrinet.org.
(1) AHRI Standard 1250–2009, 2009
Standard for Performance Rating of
Walk-In Coolers and Freezers, approved
September 2009, IBR approved for
§ 431.304.
(2) [Reserved].
(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
https://www.cen.eu/.
(1) EN 13164:2009–02, Thermal
insulation products for buildings—
Factory made products of extruded
polystyrene foam (XPS)—Specification,
approved February 2009, IBR approved
for § 431.304.
(2) EN 13165:2009–02, Thermal
insulation products for buildings—
Factory made rigid polyurehane foam
(PUR) products—Specification,
approved February 2009, IBR approved
for § 431.304.
(e) NFRC. National Fenestration
Rating Council, 6305 Ivy Lane, Ste. 140,
Greenbelt, MD 20770, (301) 589–1776,
or https://www.nfrc.org.
(1) NFRC 100–2010–E0A1, Procedure
for Determining Fenestration Product Ufactors, approved June 2010, IBR
approved for § 431.304.
(2) NFRC 400–2010–E0A1, Procedure
for Determining Fenestration Product
Air Leakage, approved June 2010, IBR
approved for § 431.304.
4. Section 431.304 is revised to read
as follows:
§ 431.304 Uniform test method for the
measurement of energy consumption of
walk-in coolers and walk-in freezers.
(a) Scope. This section provides test
procedures for measuring, pursuant to
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(ii) Determine the annual energy
consumption of walk-in cooler and
walk-in freezer refrigeration systems:
(A) For systems consisting of an
integrated single-package refrigeration
unit or a split system with separate unit
cooler and condensing unit sections,
where the condensing unit is located
outdoors, by conducting the test
procedure set forth in AHRI Standard
1250–2009 (incorporated by reference,
see § 431.303) and recording the annual
energy consumption term in the
equation for annual walk-in energy
factor in section 7:
˙
˙
where BLH and BLL for refrigerator and
freezer systems are defined in section
6.2.1 and 6.2.2, respectively, of AHRI
Standard 1250–2009 (incorporated by
reference, see § 431.303) and the annual
˙
˙
where BLH and BLL refrigerator and freezer
systems are defined in section 7.9.2.2
and 7.9.2.3, respectively, of AHRI
Standard 1250–2009 (incorporated by
reference, see § 431.303) and the annual
walk-in energy factor is calculated from
the results of the test procedures set forth
in AHRI Standard 1250–2009
(incorporated by reference, see
§ 431.303).
5. Appendix A is added to subpart R
of part 431 to read as follows:
Appendix A to Subpart R of Part 431—
Uniform Test Method for the
Measurement of Energy Consumption of
the Envelopes of Walk-In Coolers and
Walk-In Freezers
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
1.0 SCOPE
This appendix covers the test requirements
used to measure the energy consumption of
the envelopes of walk-in coolers and walk-in
freezers.
2.0 DEFINITIONS
The definitions contained in § 431.302 are
applicable to this appendix.
2.1 Additional Definitions
(a) Steady-state: The condition where the
average internal temperature changes less
than 1°C (2 °F) from one hour period to the
next.
(b) Door: An assembly installed in or on an
interior or exterior wall; that is movable in
a sliding, pivoting, hinged, or revolving
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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 Standard 1250–2009
(incorporated by reference, see
§ 431.303).
(B) For systems consisting of an
integrated single-package refrigeration
unit or a split system with separate unit
cooler and condensing unit sections,
where the condensing unit is located in
a conditioned space, by performing the
following calculation:
(C) For systems consisting of a unit
cooler connected to a rack system, by
performing the following calculation:
0.33 × BLH + 0.67 × BLL
Annual Walk-in Energy Factor
manner of movement; and that is used to
produce or close off an opening in the walkin. For walk-ins, 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.
(1) Passage door: A door designed for
human passage or movement of product
through the walk-in. A passage door may
accommodate a hand cart or equivalent.
(2) Freight door: A door designed for
human passage or movement of product
through the walk-in. A freight door may
accommodate a forklift or equivalent.
(3) Display door: A door designed for the
movement and/or display of product rather
than the passage of persons
(4) Glass door: A door comprised of 50
percent or more glass, irrespective of
intended use.
(c) Surface area: Unless explicitly stated
otherwise, the surface area for all
measurements is the area as measured on the
external surface of the walk-in.
(d) Automatic door opener/closer: A device
or control system that ‘‘automatically’’ opens
and closes doors without direct user contact
(e.g., a motion sensor that senses when a
forklift is approaching the entrance to a door,
opens, and then closes after the forklift has
passed).
(e) Rating conditions: Unless explicitly
stated otherwise, all calculations and test
procedure measurements shall use the
temperature and relative humidity data
shown in Table A.VI.1. For installations
where two or more walk-in envelopes share
PO 00000
( )
0.33 × BLH + 0.67 × BLL
Annual Walk-in Energy Factor
walk-in energy factor is calculated from
the results of the test procedures set forth
in AHRI Standard 1250–2009
(incorporated by reference, see
§ 431.303).
Annual Energy Consumption =
j =1
Sfmt 4700
any surface(s), the ‘‘external conditions’’ of
the shared surface(s) should reflect the
internal conditions of the neighboring walkin.
TABLE A.VI.1—TEMPERATURE AND
RELATIVE HUMIDITY CONDITIONS
Value
Units
Internal Conditions (cooled space within
envelope)
Cooler:
Dry Bulb Temperature ..
Relative Humidity ..........
Freezer:
Dry Bulb Temperature ..
Relative Humidity ..........
35
75
°F
%
¥10
75
°F
%
External Conditions (space external to the
envelope)
Freezer and Cooler:
Dry Bulb Temperature ..
Relative Humidity ..........
75
52
°F
%
Subfloor Temperature
Freezers & Coolers:
Temperature ..................
E:\FR\FM\09SEP2.SGM
09SEP2
55
°F
EP09SE10.039
Annual Energy Consumption =
n
Annual Energy Consumption = ∑ E t j
EP09SE10.038
EPCA, the energy consumption of walkin coolers and walk-in freezers.
(b) Testing and Calculations
(1) Determine the energy consumption
of walk-in cooler and walk-in freezer
envelopes by conducting the test
procedure specified in Appendix A to
this subpart.
(i) 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 Standard 1250–2009
(incorporated by reference, see
§ 431.303).
EP09SE10.037
55094
(
)
A glass door,tot = ∑ ⎡ Wglass door,i × H glass door,i × n i ⎤
⎣
⎦
l
Where:
i = index for each type of unique glass door
used in cooler or freezer being tested;
ni = number of identical glass doors of type
i;
Wglass door,i = width of glass door (including
door frame), ft; and
Hglass door,i= height of glass door (including
door frame), ft.
(
(c) Calculate the glass wall individual and
total glass surface area, Aglass,wall, as follows,
ft2:
)
A glass wall,i = Wglass wall,i × H glass wall,i × n i
i
(
(3-2)
(3-3)
)
A glass wall,tot = ∑ ⎡ Wglass wall,i × H glass wall,i × n i ⎤
⎣
⎦
l
Where:
i = index for each type of unique glass wall
used in cooler or freezer being tested;
ni = number of identical glass walls of type
i;
Wglass,wall,i = width of glass wall (including
glass framing), ft; and
A glass,tot = A glass door,tot + A glass wall,tot
Where:
Aglass door, tot= total glass door area, ft2; and
Aglass wall, tot= total glass wall area, ft2.
Hglass,wall,i= height of glass wall (including
glass framing), ft.
(d) Calculate the total combined glass door
and glass wall area, Aglass,tot, as follows, ft2:
(3-5)
3.1.2 Temperature Difference Across Glass
Areas
(a) Calculate the temperature differential(s)
DTglass door,j for each unique glass door as
follows, °F:
ΔTglass door , j = TDB,int,glass door , j − TDB,ext ,glass door , j
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
Where:
j= index for each type of unique glass door
temperature differential used—for
example if a freezer glass door opens into
a cooler internal conditioned
temperature and a freezer glass door
opens into external temperature, j=2;
TDB,int,glass door,j = dry-bulb air temperature
inside the cooler or freezer where the
door is located, °F;
ΔTglass wall, j = TDB,int,glass wall, j − TDB,ext ,glass wall, j
Where:
j = index for each type of unique glass wall
temperature differential used;
TDB,int,glass,wall,j = dry-bulb air temperature
inside the cooler or freezer, °F; and
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(3-4)
EP09SE10.042
i
(3-1)
TDB,ext,glass,wall,j = dry-bulb air temperature
external to cooler or freezer, °F.
3.1.3
Non-Glass Area
Calculate the individual and total surface
area of the walk-in non-glass envelope
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(3-6)
TDB,ext,glass door,j = dry-bulb air temperature
external to the door of type j, °F.
(b) Calculate the temperature differential(s)
DTglass,wall,j for each unique glass wall, as
follows (°F):
(3-7)
components Anon-floor panel edge,i, Anon-floor panel
Anon-floor panel core,i, Anon-floor panel core,tot,
Afloor panel edge,i, Afloor panel edge,tot, Afloor panel
core,i, Afloor panel core,tot, Anon-glass door,i, and
Anon-glass door,tot, as follows (ft2):
edge,tot,
E:\FR\FM\09SEP2.SGM
EP09SE10.045
)
09SEP2
EP09SE10.041
(
A glass door,i = Wglass door,i × H glass door,i × n i
EP09SE10.044
3.1 Conduction Heat Gain
3.1.1 Glass Area
(a) All dimensional measurements for glass
doors include the door frame and glass.
EP09SE10.043
(b) Calculate the individual and total glass
door surface area, Aglass door, as follows, ft2:
EP09SE10.040
3.0 TEST APPARATUS AND GENERAL
INSTRUCTIONS
55095
EP09SE10.046
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
55096
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
Wnon-floor panel,i = non-floor panel width, of
thickness and underlying materials of
type i, ft; and
Lnon-floor panel,i = non-floor panel length, of
thickness and underlying materials of
type i, ft;
(b) Anon-floor panel edge,tot, ft2
i
Anon-floor panel edge,tot = ∑ Anon -floor panel edge,i
(3-9)
1
Where:
i = index for each type of unique non-floor
panel; and
Anon-floor panel edge, i= non-floor panel edge area,
of thickness and underlying materials of
type i, ft2.
(c) Anon-floor panel core,i, ft2
i
Anon-floor panel core,i = ∑ ⎡ Wnon-floor panel,i × Lnon-floor panel,i × ni ⎤ − Anon-floor panel edge,i
⎣
⎦
(3-10)
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
1
Where:
i = index for each type of unique non-floor
panel;
ni = number of identical panels, of thickness
and underlying materials of type i;
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Anon-floor panel edge,i= panel non-floor edge area,
of thickness and underlying materials of
type i, ft2;
Wnon-floor panel,i = non-floor panel width, of
thickness and underlying materials of
type i, ft; and
PO 00000
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Sfmt 4700
Lnon-floor panel,i = non-floor panel length, of
thickness and underlying materials of
type i, ft;
(d) Anon-floor panel core,tot, ft2
E:\FR\FM\09SEP2.SGM
09SEP2
EP09SE10.048
walk-in is constructed of non-floor
panels that are all of identical
thicknesses and identical materials but
of non-floor panels of 15 different
dimensions, i=15;
ni = number of identical panels of type i;
Xedge test region = Panel Edge Test Region width,
as shown in Figure 3, ft;
Where:
i = index for each type of unique non-floor
panel—for example, if a walk-in is
constructed of non-floor panels that are
of two different thicknesses or
manufactured using two different foam
insulation products but panel
dimensions are all identical, i=2 or, if a
EP09SE10.047
(3-8)
1
EP09SE10.031
i
Anon-floor panel edge,i = ∑ ⎡ Xedge test region × ⎡ Wnon-floor panel,i + Lnon-floor panel,i − Xedge test region ⎤ × ni ⎤
⎣
⎦
⎣
⎦
EP09SE10.049
(a) Anon-floor panel edge,i, ft2, (see Figure 2 to
help visualize the area calculations)
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
i
Anon-floor panel core,tot = ∑ Anon-floor panel core,i
55097
(3 − 11)
1
Xedge test region = Panel Edge Test Region width,
as shown in Figure 3, ft;
Wfloor panel,i = floor panel width, of thickness
and underlying materials of type i, ft;
and
Lfloor panel,i = floor panel length, of thickness
and underlying materials of type i, ft;
(f) Afloor panel edge,tot, ft2;
i
Afloor panel edge,tot = ∑ Afloor panel edge,i
(3-13)
1
Where:
i = index for each type of unique floor panel;
and
Afloor panel edge, i= floor panel edge area, of
thickness and underlying materials of
type i, ft2.
(g) Afloor panel core,i, ft2
i
Afloor panel core,i = ∑ ⎡ Wfloor panel,i × Lfloor panel,i × ni ⎤ − Afloor panel edge,i
⎣
⎦
(3-14)
1
Where:
i = index for each type of unique floor panel;
ni = number of identical panels, of thickness
and underlying materials of type i;
Afloor panel edge,i= floor panel edge area, of
thickness and underlying materials of
type i, ft2;
Wnon-floor panel,i = floor panel width, of
thickness and underlying materials of
type i, ft; and
Lnon-floor panel,i = floor panel length, of
thickness and underlying materials of
type i, ft;
(h) Afloor panel core,tot, ft2
i
Afloor panel core,tot = ∑ Afloor panel core,i
(3-15)
1
Where:
i = index for each type of unique floor
panel; and
Afloor panel core, i= floor panel core area, of
thickness and underlying materials of
type i, ft2.
(i) Anon-glass door,i, ft2
i
Anon-glass door,i = ∑ ⎡ Wnon-glass door,i × Hnon-glass door,i ⎤ × ni
⎣
⎦
(3-16)
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
1
Where:
i = index for each type of unique non-glass
door;
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ni = number of identical glass doors, of
thickness and underlying materials of
type i;
Wnon-glass door,i = non-glass door width, of
thickness and underlying materials of
type i, ft; and
PO 00000
Frm 00031
Fmt 4701
Sfmt 4700
Hnon-glass door,i = non-glass door height, of
thickness and underlying materials of
type i, ft.
(j) Anon-glass door,tot, ft2
E:\FR\FM\09SEP2.SGM
09SEP2
EP09SE10.054
Where:
i = index for each type of unique floor panel;
ni = number of identical panels, of thickness
and underlying materials of type i;
EP09SE10.053
(3-12)
1
EP09SE10.052
i
Afloor panel edge,i = ∑ ⎡ Xedge test region × ⎡ Wfloor panel,i + Lfloor panel,i − Xedge test region ⎤ × n1 ⎤
⎣
⎦
⎣
⎦
EP09SE10.055
(e) Afloor panel edge,i, ft2
EP09SE10.051
Anon-floor panel core, i= non-floor panel core area,
of thickness and underlying materials of
type i, ft2;
EP09SE10.050
Where:
i = index for each type of unique non-floor
panel; and
55098
Anon-glass tot = Anon-floor panel edge,tot + Anon-floor panel core,tot + Afloor panel edge,tot + Afloor panel core,tot + Anon-glass door,tot
Where:
Anon-floor panel edge, tot= non-floor panel edge
total area, ft2;
Anon-floor panel core, tot= non-floor panel core
total area, ft2;
Afloor panel edge, tot= floor panel edge total area,
ft2;
Afloor panel core, tot= floor panel core total area,
ft2; and
Anon-glass door,tot= non-glass door total area, ft2.
3.1.4 Temperature Difference Across NonGlass Areas
Calculate the temperature differential(s)
DTnon-floor panel,j, DTfloor panel,j, and DTnon-glass
door,j, °F, as follows:
(a) >Tnon-floor panel, j, °F
ΔTnon-floor panel, j = TDB,int,non-floor panel, j − TDB,ext , non-floor panel, j
Where:
j = index for each type of non-floor panel
temperature differential;
TDB,int, non-floor panel,j = dry-bulb air internal
temperature, °F. If the panel spans both
cooler and freezer temperatures, the
freezer temperature must be used; and
TDB, int, floor panel, j = dry-bulb air internal
temperature, °F. If the panel spans both
cooler and freezer temperatures, the
freezer temperature must be used; and
(3-20)
TDB, ext, floor panel, j = 55° F, as defined in Table
A.VI.1.
(c) >Tnon-glass door, j, °F
ΔTnon-glass door, j = TDB,int,non-glass door, j − TDB,ext ,non -glass door, j
Where:
j = index for each type of non-glass door
temperature differential;
TDB, int, non-glass door, j = dry-bulb air internal
temperature, °F. If the panel spans both
cooler and freezer temperatures, the
freezer temperature must be used; and
TDB, ext, non-glass door, j = dry-bulb air external
temperature, °F.
i
3.1.5 Conduction Heat Load Across Glass
Areas
(a) Calculate the conduction load through the
glass doors, Qcond-glass, door, as follows btu/
h:
1
Qcond,glass door = ∑ ∑ ⎡ Aglass door,i × ΔTglass door, j × Uglass door,i × ni, j ⎤
⎣
⎦
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
Where:
i = index for each type of unique glass door;
j = index for each type of glass door
temperature differential;
ni, j = number of identical glass doors of type
i with temperature differential j;
Uglass door, i = thermal transmittance, U-factor
of the door, of type i, as rated by NFRC
see section 4.4.1, Btu/h-ft2-°F;
Aglass door, i = total surface area of all walkin glass doors of type i, ft2; and
i
j
1
VerDate Mar<15>2010
1
i = index for each type of unique glass wall;
18:18 Sep 08, 2010
Jkt 220001
(3-22)
>Tglass door, j = temperature differential
between refrigerated and adjacent zones
of type j, °F.
(b) Calculate the conduction load through the
glass walls, (Qcond-glass, wall), btu/h, as
follows:
Qcond,glass wall = ∑ ∑ ⎡ Aglass wall,i × ΔTglass wall,j × Uglass wall,i × ni, j ⎤
⎣
⎦
Where:
(3-21)
j
1
(3-19)
TDB, ext, non-floor panel, j = dry-bulb air external
temperature, °F.
(b) >Tfloor, j, °F
ΔTfloor panel, j = TDB,int,floor panel, j − TDB,ext ,floor panel, j
Where:
j = index for each type of floor panel
temperature differential;
(3-18)
PO 00000
Frm 00032
Fmt 4701
Sfmt 4700
(3-23)
j = index for each type of glass wall
temperature differential;
E:\FR\FM\09SEP2.SGM
09SEP2
EP09SE10.060
(k) Anon-glass tot, ft2
EP09SE10.059
Anon-glass door,i= non-glass door area, of
thickness and underlying materials of
type i, ft2.
EP09SE10.058
Where:
i = index for each type of unique non-glass
door; and
EP09SE10.057
(3-17)
1
EP09SE10.056
i
Anon-glass door,tot = ∑ Anon-glass door,i
EP09SE10.061
EP09SE10.062
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
Unon-floor panel core, i = the U-factor, per 4.1.1 of
foam type i, Btu/h-ft2-°F; and
DFi = the degradation of foam type i, unitless.
ULT,floor panel core,i =
Where:
i= index each type of unique foam used in
the walk-in envelope;
Ufloor panel core, i = the U-factor, per 4.1.1 of
foam type i, Btu/h-ft2-°F; and
j
(3-25)
DFi
Ufloor panel core,i
(3-26)
DFi
DFi = the degradation of foam type i, unitless.
3.1.7 Conduction Heat Load Across NonGlass Areas
Calculate the conduction heat load through
all non-glass components: Qcond-non-floor panel,
(
(c) Calculate the long term thermal
transmittance, (ULT, floor panel core, i), Btu/h-ft2°F, as follows:
Qcond-floor panel, Qcond-non-glass door and
Qcond-non-glass, as follows btu/h:
(a) Qcond-non-floor panel, btu/h,
(
)
)
Qcond-non-floor panel = ∑ ∑ ⎡ ΔTnon-floor panel, j × ⎡ Anon-floor panel edge,i × Unon-floor panel edge,i × ni, j + Anon-floor panel core,i × ULT,non-floor panel, core,i × ni, j ⎤ ⎤ (3-27)
⎢
⎥⎥
⎢
⎣
⎦⎦
1 1 ⎣
DTnon-floor panel,j = temperature differential
across the non-floor panels of type i, °F;
Unon-floor panel edge,i = U-factor for panel edge
area type i, per 4.1.1, Btu/h-ft2-°F;
ULT,non-floor panel core,i = Long term thermal
transmittance of foam type i, per section
4.1.1, Btu/h-ft2-°F;
Where:
i = index for each type of unique component
of type i;
j = index for each unique temperature
differential of type j;
ni,j = number of identical non-floor panels of
type i with temperature differential;
i
j
(
)
Anon-floor panel edge,i = area of non-floor panel
edge of type i, ft2; and
Anon-floor panel core,i = area of non-floor panel
core of type i, ft2.
(b) Qcond-floor panel, btu/h,
(
)
Qcond-floor panel i, j = ∑ ∑ ⎡ ΔTfloor panel, j × ⎡ Afloor panel edge,i × Ufloor panel edge,i × ni , j + Afloor panel core,i × ULT,floor panel core,i × ni , j ⎤ ⎤
⎢
⎥⎥
⎢
⎣
⎦⎦
1 1 ⎣
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
Where:
i = index for each type of unique component
of type i;
j = index for each unique temperature
differential of type j;
ni,j = number of identical floor panels of type
i with temperature differential j;
DTnon-floor panel,j = temperature differential
across the floor panels of type i, °F;
Ufloor panel edge,i = U-factor for panel edge area
type i, per 4.1.1, Btu/h-ft2-°F;
ULT,floor panel core,i = Long term thermal
transmittance of foam type i, per 4.1.1,
Btu/h-ft2-°F;
Afloor panel edge,i = area of floor panel edge of
type i, ft2; and
−0.364
Qcond-floor panel = 33.153 × Afloor × Afloor
Afloor panel core,i = area of floor panel core of
type i, ft2.
(1) Exception to Qcond-floor panel: If the walkin is at cooler temperature and has an
uninsulated floor, then Qcond-floor panel, btu/h,
is as follows:
(i) If Afloor ≤ 750 ft2, then
(3-28)
(ii) If Afloor > 750 ft2, then
VerDate Mar<15>2010
18:18 Sep 08, 2010
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Fmt 4701
Sfmt 4700
(3-28)
E:\FR\FM\09SEP2.SGM
09SEP2
EP09SE10.067
Where:
i= index each type of unique foam used in
the walk-in envelope;
Unon-floor panel core,i
EP09SE10.066
Where:
i= index each type of unique foam used in
the walk-in envelope—for example if a
ULT,non-floor panel core,i =
i
(3-24)
R 0,i
EP09SE10.065
R LTTR ,i
EP09SE10.064
DFi =
walk-in uses one foam type for non-floor
panels and another foam type for floor
panels, i=2;
RLTTR, i = the R-value, from ASTM C1303–10,
per 4.1.2 of foam type i, h-ft2-°F/Btu; and
R0, i = the R-value of foam used for
determining EPCA compliance of foam
type i, h-ft2-°F/Btu.
(b) Calculate the long term thermal
transmittance, (ULT, non-floor panel core, i), Btu/hft2-°F, as follows:
EP09SE10.063
3.1.6 Panel Long Term Thermal
Transmittance
(a) Calculate the foam degradation factor,
(DFi), unitless, as follows:
ni, j = number of identical glass walls of type
i with temperature differential j;
Uglass, wall, i = thermal transmittance, U-factor
of the glass wall, of type i, as rated by
NFRC see section 4.4.1 Btu/h-ft2-°F;
Aglass, wall, i = total surface area of all walkin glass walls of type i, ft2; and
>Tglass, wall, j= temperature differential
between refrigerated and adjacent zones
of type j, °F.
EP09SE10.068
55099
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
R Freezer floor
(3-30)
DTfloor = temperature differential across the
freezer floor as defined in 3.1.4(b), °F
Rfreezer floor = 28 ft2-°F-h/Btu, as required by
EPCA.
Where:
Afloor = total area of the floor, as measured
from the walk-in architectural drawing,
ft2.
i
j
1
(c) Qcond-non-glass door, btu/h,
1
Qcond-non-glass door = ∑ ∑ ⎡ ΔTnon -glass door, j × ⎡ Anon -glass door,i × Unon-glass door,i ⎤ × ni , j ⎤
⎣
⎦
⎣
⎦
Where:
i = index for each type of unique component
of type i;
j = index for each unique temperature
differential of type j;
ni,j = number of identical non-glass doors of
type i with temperature differential j;
DTnon-non glass door,j = temperature differential
across the floor panels of type i, °F;
Unon-glass door,i = U-factor for panel edge area
type i, per 4.4.1, Btu/h-ft2-°F; and
Anon-glass door,i = area of floor panel edge of
type i, ft2.
(d) Total conduction load for non-glass
areas, Qcond-non-glass, as follows btu/h:
Qcond-non-glass = Qcond-non-floor panel + Qcond-floor panel + Qcond-non-glass door
Where:
Qcond-non-floor panel = conduction through nonfloor panels, btu/h;
Qcond-floor panel = conduction through floor
panels, btu/h; and
Qcond-non-glass door = conduction through nonglass doors, btu/h.
Qcond-floor panel = conduction through floor, as
found in 3.1.7(b)(1) or (2) btu/h; and
Qcond-non-glass door = conduction through nonglass doors, btu/h.
Qcond = Qcond-non-glass + Qcond ,glass wall + Qcond ,glass door
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
Where:
Qcond-non-glass = total conduction load through
non-glass components of walk-in, Btu/h;
Qcond-glass,wall = total conduction load through
walk-in glass walls, Btu/h; and
Qcond-glass,door = total conduction load through
walk-in glass doors, Btu/h.
3.2 Infiltration Heat Gain
3.2.1 Steady State Infiltration Calculations
(a) Convert dry-bulb internal and external
air temperatures from °F to Rankine (°R), as
follows:
18:18 Sep 08, 2010
Jkt 220001
(3-35)
TDB-ext,R = TDB-ext + 459.67
VerDate Mar<15>2010
TDB-int,R = TDB-int + 459.67
(3-36)
PO 00000
Frm 00034
Fmt 4701
Sfmt 4700
(3-32)
(1) Exception: If calculating Qcond-non-glass
for an uninsulated cooler or for a freezer
where an insulated floor is not part of walkin, calculate as follows:
Qcond-non-glass = Qcond-floor panel + Qcond -non -floor panel + Qcond -non -glass door
Where:
Qcond-non-floor panel = conduction through nonfloor panels, btu/h;
(3-31)
(3-33)
3.1.8 Total Conduction Load
(a) Calculate total conduction load, Qcond,
as follows btu/h:
(3-34)
Where:
TDB-int,R = the dry-bulb temperature of
internal walk-in air, °R; and
TDB-ext,R = the average dry-bulb temperature
of air surrounding the walk-in, °R.
(b) Calculate the water vapor saturation
pressure for the external air and the internal
refrigerated air, as follows:
(1) If TDB,R < 491.67 °R (32 °F), use the
following equation to calculate water vapor
saturation pressure (Pws in psia):
E:\FR\FM\09SEP2.SGM
09SEP2
EP09SE10.076
1
EP09SE10.074
Qcond-floor panel = ΔTfloor × Afloor ×
EP09SE10.073
(2) Exception to Qcond-floor panel: If the walkin is at freezer temperature and an insulated
floor has not being shipped with the walkin, then Qcond-floor panel, is as follows btu/h:
Afloor = total area of the floor, as measured
from the walk-in architectural drawing,
ft2.
EP09SE10.072
Where:
(3-29)
EP09SE10.071
Qcond-floor panel = [ 0.0002 × Afloor + 2.84] × Afloor
EP09SE10.070
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
EP09SE10.069
55100
C2 = ¥4.8932428 E+00,
C3 = ¥5.3765794 E–03,
C4 = 1.9202377 E–07,
C5 = 3.5575832 E–10,
C6 = ¥9.0344688 E–14, and
Where:
TDB,R = dry-bulb temperature (for the internal
and external air), °R;
C8 = ¥1.0440397 E+04;
C9 = ¥1.1294650 E+01;
C10 = ¥2.7022355 E–02;
C11 = 1.2890360 E–05;
C12 = ¥2.4780681 E–09; and
) (
) (
C13 = 6.5459673 E+00.
(c) Calculate the absolute humidity ratio,
w, as follows:
⎡ 0.621945 × ( RH × Pws ) ⎤
ω=⎢
⎥
⎢ 14.696 − ( RH × Pws ) ⎥
⎣
⎦
(3-39)
v = ⎢(0.025209989) × TDB,R × (1 + (1.6078 × ω)) ⎥
⎣
⎦
Where:
TDB,R = dry-bulb temperature (for the internal
or external air), °R; and
v = specific volume of air, ft3/lb.
1
ν
(3-41)
(
h = ( 0.240 × TDB,F ) + ω × 1061 + ( 0.444 × TDB,F )
Where:
TDB,F = dry-bulb temperature (for the internal
or external air), °F; and
w = absolute humidity ratio, unitless.
(g) Calculate the total crack length, CL,(ft),
using the architectural drawing of the walkin,
)
(h) Calculate the steady state infiltration
˙
rate of the walk-in,Vj, ft3/h:
Vj = VL × CL
(3-43)
Where:
j = index of type cooler or freezer;
(
)
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
Qinfilt panel = ρext , j × hext, j − ρ int, j × h int, j × V1
Where:
j = index of cooler or freezer temperature;
˙
Vj = the infiltration rate measured at test
temperature j, per section 4.2, ft3/h;
rint,j = internal air density, lb/ft3;
rext,j = external air density, lb/ft3;
hint,j = internal air enthalpy, Btu/lb; and
hext,j = external air enthalpy, Btu/lb.
3.2.2 Door Steady-State Infiltration
Calculations
(a) Calculate the steady-state infiltration
˙
associated with doors as follows, Vdoor
3
steady,i /h:
i
Vdoor steady,i = ∑ Vdoori × ni
1
VerDate Mar<15>2010
18:18 Sep 08, 2010
Jkt 220001
PO 00000
Frm 00035
Fmt 4701
Sfmt 4700
⎤
)⎥
⎥
(3-38)
⎦
Where:
RH = relative humidity in (for the internal or
external air), and
Pws = water vapor saturation pressure, psia.
(d) Calculate air specific volume, v, (ft3/lb),
as follows:
(3-40)
(e) Calculate air density, air density, lb/ft3,
as follows:
ρ=
(3-37)
⎦
C7 = 4.1635019 E+00.
(2) If TDB,R > 491.67 °R (32 °F), use the
following equation to calculate water vapor
saturation pressure, Pws, psia:
⎞
3
2
⎟ + C9 + ( C10 × TDB,R ) + C11 × TDB,R + C12 × TDB,R + C13 × 1n ( TDB,R )
⎟
⎠
(
⎤
)⎥
⎥
(3-45)
Where:
v = specific volume of air, ft3/lb.
(f) Calculate the enthalpy for the internal
and external air, h, as follows btu/lb:
(3-42)
˙
VL = the normalized infiltration rate per
section 4.2 of this document using the
architectural drawing of the walk-in,
ft3/h-ft; and
CL = total crack length, ft.
(i) Calculate the total infiltration load due
to steady-state infiltration, (Qinfilt panel), Btu/h,
as follows:
(3-44)
Where:
i = index of each unique door geometry and
temperature differential combination;
ni = number of identical doors of type i,
unitless; and
˙
Vdoor1Q = door steady state infiltration as
found following section 4.4.2, ft3/h.
(b) Calculate the total infiltration load due
to steady-state infiltration through doors,
Qdoor steady, btu/h, as follows:
E:\FR\FM\09SEP2.SGM
09SEP2
EP09SE10.084
) (
EP09SE10.082
⎡⎛ C
pws = exp ⎢⎜ 8
⎢⎜ TDB,R
⎣⎝
) (
EP09SE10.081
Where:
TDB,R = dry-bulb temperature in Rankine (for
the internal or external air),
C1 = ¥1.0214165 E+04,
) (
EP09SE10.080
(
EP09SE10.079
⎞
2
3
4
⎟ + C2 + ( C3 × TDB,R ) + C4 × TDB,R + C5 × TDB,R + C6 × TDB,R + C 7× 1n ( TDB,R )
⎟
⎠
EP09SE10.078
⎡⎛ C
Pws = exp ⎢⎜ 1
⎢⎜ TDB,R
⎣⎝
55101
EP09SE10.077
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
55102
(3-47)
Where:
i = index for each unique door—for example
a unique door must be of the same
(
qi = 795.6 × Ai × hext ,i − h int,i
Where:
i = index for each unique door;
Ai = doorway area, of door type i, ft2;
hint,i = internal air enthalpy, of door type i,
Btu/lb;
hext,i = external air enthalpy, of door type i,
Btu/lb;
rint,i = internal air density, of door type i, lb/
ft3;
rext,i = external air density, of door type i, lb/
ft3;
Hi = doorway height, of door type i, ft;
Fm,i = density factor, of door type i, and
g = acceleration of gravity, 32.174 ft/sec.2.
)
⎛ ρext ,i
× ρint,i × ⎜1 −
⎜ ρint,i
⎝
Vrate,with-device i, j
(3-50)
Vrate,without-device i, j
j
1
1
(
)
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
Qdoor open = ∑ ∑ qi × Dt ,i × Df × 1 − Ei, j × ni
Where:
i = index for each unique combination of
doorway size, temperature difference and Dt,
of type i—for example, if the walk-in has a
small, medium and large door, i = 3, or if the
walk-in has ten identical dimensioned
display doors and one passage door all with
the same temperature differential, i = 2;
j = index for the effectiveness of IRD type j;
ni = number of doorways of type i being
considered in the calculation;
qi = infiltration load for fully established
flow, Btu/h;
Dt,i = doorway open-time factor as calculated
for each unique door way, unitless;
Df = doorway flow factor, 0.8 for freezers and
coolers (from ASHRAE Fundamentals),
unitless;
Qtot = Q infilt panel + Qdoor steady + Qdoor open +Qcond
VerDate Mar<15>2010
21:59 Sep 08, 2010
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PO 00000
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Sfmt 4725
(3-49)
j = index for each unique infiltration
reduction device (IRD) of type i;
Vrate,with-device i,j = air infiltration rate, with
door open and reduction device active,
4.3, 1/h, if a device j is not used with the
doorway i, Vrate,with-device i,j =
Vrate,without-device i,j ; and
Vrate,without-device i,j = air infiltration rate, with
door open and reduction device disabled
or removed, using 4.3, 1/h.
(e) Calculate the total door opening
infiltration load for all door-IRD
combinations, Qdoor open, (Btu/h), as
follows:
(3-51)
Ei,j = effectiveness of doorway type i with IRD
type j, as measured by gas tracer test, %.
3.3 Energy Consumption Due to Total Heat
Gain
(a) Calculate the total thermal load, Qtot,
(Btu/h), as follows:
(3-52)
E:\FR\FM\09SEP2.SGM
09SEP2
EP09SE10.091
(3-48)
1/2
Where:
i = index for each unique doorway size of
type small, medium or large;
i
3/2
⎤
⎥
⎥
⎥
1/3
⎞ ⎥
⎟ ⎥
⎟ ⎥
⎠ ⎦
Where:
i = index for each unique door
rint,i = internal air density, of door type i,
lb/ft3; and
rext,i = external air density, of door type i,
lb/ft3.
(c) Calculate the infiltration load for fully
established flow through each door,
qi (Btu/h), as follows:
⎞
1/2
⎟ × ( g × Hi ) × Fm,i
⎟
⎠
(d) Calculate the doorway infiltration
reduction device effectiveness, E (%), at the
same test conditions as described in steadystate infiltration section, as follows:
(1) Calculate the infiltration reduction
effectiveness:
Ei, j = 1 −
Fm,i
⎡
⎢
⎢
2
=⎢
⎢ ⎛ ρint,i
⎢1 + ⎜
⎢ ⎜ ρext ,i
⎣ ⎝
EP09SE10.090
)
qo = 10 minutes and for freight doors qo = 20
minutes.
(6) Daily time period: All walk-ins, qd = 24
hours
(b) Calculate the density factor, Fm, for
each door, as follows:
EP09SE10.089
(
⎡ P × θp + ( 60 × θθ ) ⎤
⎦
Dt,i = ⎣
[3600 × θd ]
geometry, underlying materials,
function, and have the same temperature
difference across the door;
P = number of doorway passages (i.e.,
number of door opening events);
qp = door open-close time, seconds per
opening P;
qθ = time door stands open, minutes; and
qd = daily time period, h.
(1) Number of doorway passages: For
display glass doors, P = 72, for passage doors,
P = 60 and for freight doors, P = 120.
(2) Door open-close time: For display glass
doors, qp = 8 seconds, for passage doors, qp
= 15 and for freight doors, qp = 60.
(3) Door open-close time if an automatic
door opener/closer is used: For passage
doors, qp = 10 and for freight doors, qp = 30.
(4) Time door stands open: Display glass
doors, qo = 0 minutes, for passage doors qo
= 30 minutes and for freight doors qo = 60
minutes.
(5) Time door stands open if an automatic
door opener/closer is used: For passage doors
EP09SE10.088
Where:
i = index of type cooler or freezer
temperature;
˙
Vdoor steady,i = total door steady-state
infiltration, ft3/h;
rint,i = internal air density, as found in 3.2.1
above, lb/ft3;
rext,i = external air density, as found in 3.2.1
above, lb/ft3;
hint,i = internal air enthalpy, as found in 3.2.1
above, Btu/lb; and
hext,i = external air enthalpy, as found in 3.2.1
above, Btu/lb.
3.2.3 Door Opening Infiltration Calculations
(a) Calculate the portion of time each
doorway is open, Dt, unitless, as follows:
EP09SE10.087
(3-46)
1
EP09SE10.086
i
Qdoor steady = ∑ ( ρext ,i × hext ,i − ρint,i × hint,i ) × Vdoor steady,i
EP09SE10.092
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
Qdoor open = total load due to door opening
infiltration, Btu/h.
(b) 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.
Pcomp,u , t = Pr ated ,u , t × (1 − PTOu , t ) × nu , t ×
Where:
u = index for each type of electricity
consuming device sited inside the walkin envelope and/or sited external the
walk-in envelope, inside, u=int, external,
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, Ptot, (kWh/day), as follows:
t
Ptot ,int = ∑ Pcomp,int, t
(3-55)
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
1
24h
day
t
Ptot ,ext = ∑ Pcomp,ext , t
(3-56)
(3-54)
Cload = Ptot,int × 3.
1
Where:
t = index for each type of electricity
consuming device with identical rated
power;
Pcomp,int, t = the energy usage for an electricity
consuming device sited inside the walkin envelope, of type t, kWh/day; and
Pcomp,ext, t = the energy usage for an electricity
consuming device sited outside the
walk-in envelope, of type t, kWh/day.
3.4.2 Total Indirect Electricity Consumption
Due to Electrical Devices
(a) Calculate the additional compressor
load due to thermal output from electrical
components sited inside the envelope, Cload,
(kWh/day), as follows:
3.5 Total Energy Consumption and
Normalized Energy Consumption
3.5.1
Total Energy Consumption
Calculate the total energy load of the walkin envelope per unit of surface area and nonnormalized total energy consumption,
Etot,non-glass,norm, Etot,glass,norm, Etot,electrical,norm,
and Etot,(kWh/ft2/day), as follows:
(a) Etot,non-glass,norm, kWh/ft2/day,
(3-58)
(b) Etot,glass,norm, kWh/ft2/day,
18:18 Sep 08, 2010
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(3-57)
Where:
EER = EER of walk-in (cooler=12.4 or
freezer=6.3), Btu/Wh; and
Ptot,int = The total electrical load due to
components sited inside the walk-in
envelope, kWh/day
⎡
⎤ ⎡
⎤
Anon-glass,tot
Qtot,EER
Etot,non-glass = ⎢
⎥×⎢
⎥
⎢
⎥ ⎢
⎥
⎣ Anon-glass,tot + Aglass,tot ⎦ ⎣ Anon-glass,tot + Aglass,tot ⎦
VerDate Mar<15>2010
412 Btu
EER Wh
E:\FR\FM\09SEP2.SGM
09SEP2
EP09SE10.098
control by door open or closed position for
display doors, PTO=99.33 percent. With
control by door open or closed position for
other doors, PTO=99.17 percent.
(4) 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 preinstalled timers, control
system or other auto-shut-off systems,
PTO=25 percent.
(b) Calculate the power usage for each type
of electricity consuming device, Pcomp,t,
(kWh/day), as follows:
EP09SE10.097
(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
required): Without timers, control system or
other demand-based control, PTO=0 percent.
With timers, control system or other demandbased control, PTO=75 percent. For antisweat heaters on freezers (if required):
Without timers, control system or other autoshut-off systems, PTO=0 percent. With
timers, control system or other demand-based
control, PTO=50 percent.
(3) For active infiltration reduction
devices: Without control by door open or
closed position, PTO=25 percent. With
EP09SE10.096
3.4 Energy Consumption Related to
Electrical Components
Electrical components contained within a
walk-in 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.
3.4.1 Direct Energy Consumption of
Electrical Components
(a) Select the required value for percent
time off for each type of electricity
consuming device, PTOt (%):
(3-53)
EP09SE10.095
Where:
Qtot = total thermal load, Btu/h; and
EER= EER of walk-in (cooler or freezer),
Btu/Wh.
Qtot
24 h × 1 kW
×
EER 1 day × 1000 W
EP09SE10.094
Qtot ,EER =
(c) Calculate the total daily energy
consumption due to thermal load, Qtot,EER,
(kWh/day), as follows:
EP09SE10.093
Where:
Qinfilt panel = total load due to steady-state
infiltration, Btu/h;
Qcond = total load due to conduction, Btu/h;
Qdoor steady = total load due to door steadystate infiltration, Btu/h; and
55103
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Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
⎡
⎤ ⎡
⎤
Aglass,tot
Qtot,EER
Etot,glass = ⎢
⎥×⎢
⎥
⎢
⎥ ⎢
⎥
⎣ Anon-glass,tot + Aglass,tot ⎦ ⎣ Anon-glass,tot + Aglass,tot ⎦
(3-59)
(c) Etot,electrical,norm, kWh/ft2/day,
Etot,electric device =
(3-60)
4.0 TEST METHODS AND
MEASUREMENTS
(d) Etot, kWh/day,
Etot = Qtot ,EER + Ptot + Cload
Ptot + Cload
Anon-glass,tot + Aglass,tot
(3-61)
(b) Testing Conditions
(1) The air temperature on the ‘‘hot side’’
of the box should be maintained at 75 °F ±
1 °F.
(i) Exception: When testing floors, the air
temperature should be maintained at 55 °F
± 1 °F.
(2) The temperature in the ‘‘cold side’’ of
the envelope should be maintained at 35 °F
± 1 °F for the panels used for walk-in coolers
and ¥10 °F ± 1 °F for panels used for walkin freezers.
(3) The air velocity should be maintained
as natural convection conditions as described
in ASTM C1363–05 (incorporated by
reference, see § 431.303). The test must be
completed using the masked method and
with surround panel in place as described in
ASTM C1363–05.
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09SEP2
EP09SE10.100
(c) Required Test Samples
(1) Wall and Ceiling Panels
(i) Cooler conditions, Panel Edge Region
U-factor: Unon-floor panel edge,cooler
(ii) Cooler conditions, Panel Core Region
U-factor: Unon-floor panel core,cooler
(iii) Freezer conditions, Panel Edge Region
U-factor: Unon-floor panel edge,freezer
(iv) Freezer conditions, Panel Core Region
U-factor: Unon-floor panel core,freezer
EP09SE10.099
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
EP09SE10.101
EP09SE10.206
Where:
Qtot,EER = the total thermal load, kWh/day;
Ptot = the total electrical load, kWh/day;
Anon-glass,tot = total surface area of the nonglass envelope, ft2;
Aglass,tot = total surface area glass envelope,
ft2; and
Cload = additional compressor load due to
thermal output from electrical components
contained within the envelope, kWh/day.
4.1 Conduction Performance Testing and
Measurements
4.1.1 Measuring Panel and Floor U-factors
using ASTM C1363–05
(a) Test Sample Geometry Requirements
(1) Two (2) panels, 8’ ± 1’’ long and 4’ wide
± 1’’ must be prepared.
(2) The panel edges must be joined using
a given manufacturer’s panel interface
joining system (i.e. camlocks).
(3) Panel Edge Test Region must be cut
from the joined panels such that X = 2’ ±
0.25’’ and Z = 7’ ± 0.5’’. (See Figure 3)
(i) Exception: Walk-in panels that utilize
vacuum insulated panels (VIP) for
insulation, X = 2’± 2’’. The wider tolerance
is meant to allow the cutting line, when
preparing the Panel Edge Test Region, to
match the VIP junctions such that VIP will
not lose vacuum by being pierced by the
cutting device.
(4) Panel Core Test Region must also be cut
from one of the two panels such that Y = 2’
± 0.25’’ and Z = 7’ ± 0.5’’. (See Figure 3)
(i) Exception: As above, walk-in panels that
use VIP for insulation, Y = 2’± 2’’.
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
4.1.2 Measuring R–Value of Insulating
Foam
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
(a) Follow the test procedure in ASTM
C1303–10 exactly, with these exceptions
(incorporated by reference, see § 431.303):
(1) Mold/Sample Panel Geometry
(i) A panel must be prepared following
typical manufacturer injection, curing and
assembly methods. The width and length
of the panel must be 48 inches ± 1 inch and
96 inches ± 1 inch, respectively.
(ii) The panel thickness shall be equal to the
desired test thickness.
(2) Materials
(i) The panel materials should exactly mimic
a commercially viable panel; that is, the
panel should be exactly identical to panels
sold by the manufacturer, with one key
exception: The inner surfaces must be
lined with a material, such as 4 to 6 mil
polyethylene film, to prevent the foam
from adhering to the panel internal
surfaces. (This ensures that when the panel
metal skin is removed for testing, the
underlying foam is not damaged).
(3) Sample Preparation
(i) After the foam has cured and the panel is
ready to be tested, the facing and framing
materials must be carefully removed to
ensure that the underlying foam is not
damaged or altered.
(ii) A 12-inch × 12-inch square (× desired
thickness) cut from the exact geometric
center of the panel must be used as the
sample for completing ASTM C1303–10.
(4) Section 6.6.2, where several types of hot
plate methods are recommended, use ASTM
C518–04 (incorporated by reference, see
§ 431.303), for measuring the R-value. In
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19:22 Sep 08, 2010
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section 6.6.2.1 of ASTM C1303–10, in
reference to ASTM C518–04, the mean test
temperature of the foam during R-value
measurement must be 20 +/¥ 4 °F (¥6.7
+/¥ 2 °C) with a temperature difference of 40
+/¥ 4 °F (22 +/¥ 2 °C) for freezers and 55
+/¥ 4 °F (12.8 +/¥ 2 °C) with a temperature
difference of 40 +/¥ 4 °F (22 +/¥ 2 °C) for
coolers.
(5) Section 6.6.2.1, in reference to ASTM
C518–04, the mean test temperature of the
foam during R-value measurement must be:
(i) For freezers: ¥6.7 +/¥ 2 °C (20 +/¥ 4 °F)
with a temperature difference of 22
+/¥ 2 °C (40 +/¥ 4 °F)
(ii) For coolers: 12.8 +/¥ 2 °C (55 +/¥ 4 °F)
with a temperature difference of 22
+/¥ 2 °C (40 +/¥ 4 °F)
(b) At least one sample set must be
prepared, comprised of three stacks, while
adhering to all preparation methods and
uniformity specifications described in ASTM
C1303–10 (incorporated by reference, see
§ 431.303).
(c) The value resulting LTTR for the foam
shall be reported as Rfoam, but for the
purposes of calculations in this test
procedure calculations it will be converted to
RLTTR, as follows:
R LTTR = Rfoam
(4-1)
Where:
Rfoam = R-value of foam as measured by
ASTM C1303–10, h-ft2¥°F/Btu.
4.1.3
U-Factor of Doors
(a) All doors must be tested using NFRC
100–2010–E0A1.
(b) Internal conditions:
(1) Air temperature of 35 °F (1.7 °C) for
cooler doors and ¥10 °F (¥23.3 °C) for
freezer doors.
(2) Mean inside radiant temperature same
as shown in (b)(1) above.
(c) External conditions
(1) Air temperature of 75 °F (23.9 °C).
(2) Mean outside radiant temperature same
as shown in (c)(1) above.
(d) Direct solar irradiance = 0 W/m2
(0 Btu/h-ft2).
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(e) The average convective heat transfer
coefficient on both interior and exterior
surfaces of the door should be based on
‘‘natural convection’’ as described in section
4.3 of NFRC 100–2010–E0A1 (incorporated
by reference, see § 431.303).
4.2
Steady State Infiltration Testing
(a) Follow the test procedure in ASTM
E741–06 exactly, except for these changes
and exceptions to the procedure.
(incorporated by reference, see § 431.303):
(1) Concentration decay method: The
‘‘concentration decay method’’ must be used
instead of other available options described
in ASTM E741–06.
(2) Gas Tracer: CO2 or SF6 must be used
as the gas tracer for all testing.
(3) Air change rate: Measure the air change
rate in 1/h, rather than the air change flow
described in ASTM E741–06 (incorporated
by reference, see § 431.303).
(4) Spatial measurements: Spatial
measurements must be taken in a minimum
of six locations or one location/20 ft2 of floor
area (whichever results in a greater number
of measurements) at a height of 3 ft +/¥ 0.5
ft, at a minimum distance of 2 ft +/¥ 0.5 ft
from the walk-in walls or doors.
(b) The internal air temperature for freezers
and for coolers shall be +/¥ 4 °F (2 °C) of the
values shown in Table A.VI.1.
(c) The external air temperature must be
75 °F (24 °C) +/¥ 5 °F (2.5 °C) surrounding
the walk-in.
(d) The test must be completed with the
walk-in door closed.
(e) Number of tests:
(1) One unit must be tested at freezer
conditions with an insulated floor in place.
(2) One unit must be tested at cooler
conditions.
(f) Geometry of standard walk-in test unit:
(1) External dimensions:
(i) Width = 12 ft ± 6’’
(ii) Length = 18 ft ± 6’’
(iii) Height = 8 ft ± 6’’
(2) Rectangular Shape (see Figure 4)
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EP09SE10.102
(2) Floor Panels
(i) Cooler conditions, Floor Panel Edge
Region U-factor: Ufloor panel edge,cooler
(ii) Cooler conditions, Floor Panel Core
Region U-factor: Unon-floor panel core,cooler
(iii) Freezer conditions, Floor Panel Edge
Region U-factor: Ufloor panel edge,freezer
(iv) Freezer conditions, Floor Panel Core
Region U-factor: Ufloor panel core,freezer
55105
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
(4-2)
and
Vcooler = Vrate,cooler × Vref-space
(4-3)
Where:
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
CL,door-wall = H × ⎡ Npanels,door-wall − 2 ⎤
⎣
⎦
Where:
H = height of the walk-in unit per Figure 4,
ft; and
18:18 Sep 08, 2010
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1
Npanels,door-wall = number of panels used to
build the door wall
(iii) CL,ceiling-floor, ft:
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)
(4-4)
(4-6)
E:\FR\FM\09SEP2.SGM
09SEP2
EP09SE10.105
(
Where:
i = index for walls from 1 to 3, i = 1: wall
of length 18′ and height 8′, i = 2: other
wall of length 18′ and height 8′ and i =
3: wall opposite of the door of width 12′
and height 8′;
H = height of the walk-in unit per Figure 4,
ft; and
Npanels,i = number of panels used to build wall
of type i.
(ii) CL,door-wall, ft:
(4-5)
CL,ceiling-floor = W × ⎡ Npanels,ceiling − 1⎤ + Pfloor + L × 2
⎣
⎦
VerDate Mar<15>2010
i
CL, wall = ∑ ⎡ H × Npanels,i ⎤
⎦
⎣
EP09SE10.104
Vfreezer = Vrate,freezer × Vref-space
Vref-space = the total enclosed volume of the
walk-in, of the test unit shown in Figure
4, ft3; and
Vrate,cooler= the infiltration rate from the
cooler test, 1/h
Vrate,freezer= the infiltration rate from the
cooler test, 1/h
(2) Using the architectural drawing of the
test unit, calculate total effective crack
length, CL,wall, CL,door-wall, CL,ceiling-floor and
CL,(ft), as follows:
(i) CL,wall, ft:
EP09SE10.103
(4) The standard unit internal volume must
be empty and unoccupied except for items
necessary for testing or for cooling the test
unit (such as test equipment or evaporator
fans).
(i) Test Results
(1) At cooler conditions, the result
following ASTM E741–06, is:
(i) First, correct the result to standard test
conditions per ASTM E 283.
(ii) The final and corrected infiltration rate,
Vrate,cooler, (1/h)
(2) At freezer conditions,
(i) First, correct the result to standard test
conditions per ASTM E 283.
(ii) The final and corrected infiltration rate,
Vrate,freezer, (1/h)
(j) Calculations
(1) Convert Vrate,freezer and Vrate,cooler to
˙
˙
Vfreezer and, Vcooler, (ft3/h), as follows:
EP09SE10.207
(g) Equipment Specifications
(1) One Passage Door (see Figure 4)
(i) Width = 36 inches ± 2 inches
(ii) Height = 78 inches ± 4 inches
(2) At freezer temperature, a pressure relief
valve must be in-place and operational
during testing.
(i) Valve flow rate > 8 cubic ft per minute @
1 inch of H2O (250 Pa))
(3) Prescribed wall and ceiling panel
geometry
(i) Wall panels
1. Width < 4 ft ± 1 inch
2. Height < 8 ft ± 1 inch
(ii) Ceiling panels
1. Width < 4 ft ± 1 inch
(h) Test Procedure Requirements
(1) The unit must be assemble following
instructions provided in the standard panel
manufacturer installation instructions that
are normally provided with a shipped walkin.
(2) The unit may be tested only after it has
reached a steady-state condition, normally
greater than 24 hours after the refrigeration
system has been activated.
(3) The infiltration measurement period
must be over a duration greater than one hour
EP09SE10.106
EP09SE10.107
55106
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
Npanels,ceiling = number of panels used to build
the door wall, ft;
Pfloor = external perimeter of the floor, ft; and
Where:
CL = the total crack length of the test unit as
shown in Figure 4, ft; and
˙
Vfreezer-ft = infiltration rate from the freezer
test, ft3/h.
˙
(ii) Vcooler-ft, ft3/h-ft:
Vcooler-ft =
Vcooler
CL
(4-9)
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
Where:
CL = the total crack length of the test unit as
shown in Figure 4, ft; and
˙
Vcooler = infiltration rate from the cooler test,
ft3/h.
4.3 IRD Effectiveness Testing
4.3.1 IRD Test Alternatives
(a) The following IRD effectiveness
assumptions may be used:
(1) Strip Curtains Effectiveness: E = 0.5
(2) Air Curtains Effectiveness: E = 0.3
(b) If an IRD is tested and found to have
a higher performing effectiveness than the
default values proposed above, that value
may be used in the energy calculations.
(c) All non-strip curtain and non-air
curtain IRD’s must be tested following the
test procedure below.
4.3.2 Doorway Testing Geometry
(a) IRD effectiveness tests must use the
following door sizes:
(1) The testing must be completed for each
device at the correct representative size for
small, medium and/or large doorways.
(2) For doors with width ≤ 48 inches and
height ≤ 84 inches, the small door test
opening size may be used (‘‘small test’’):
width = 48 inches ± 0.5 inch and height =
84 inches ± 0.5 inch
(3) For doors with width ≤ 96 inches and
height ≤ 144 inches, the medium door test
opening size may be used (‘‘medium test’’):
width = 96 inches ± 0.5 inch and height =
144 inches ± 0.5 inch
(4) For doors of any width or height, the
large door test opening size may be used
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IRD Test Procedure Requirements
(a) Use ASTM E741–06 (incorporated by
reference, see § 431.303), with the following
exceptions to the procedure:
(1) Within 3 minutes +/¥ 30 seconds of
achieving gas concentration uniformity, with
the infiltration reduction device in place, a
hinged door should be opened at an angle
greater than or equal to 90 degrees.
(2) The elapsed time, from zero degrees
position (closed) to greater than or equal to
90 degrees (open) must be no longer than 5
seconds.
(3) The door must then be held at an angle
greater than or equal to 90 degrees for 5 min
+/¥ 5 seconds and then closed over a period
no longer than 5 seconds. For non-hinged
doors, the door must reach its maximum
opened position, be held open, and reach a
fully closed position in the same elapsed
time as described above for hinge-type doors.
(4) The gas concentration must be sampled
again after the door has been closed. Samples
should continue being taken until the gas
concentration is once again uniform spatially
within the walk-in.
(5) A gas concentration sample set must be
taken once the tracer gas has uniformly
dispersed in the internal space using the
methodology described in 4.2.
(i) Following ASTM E741–06, the calculated
result is Vrate,with-device i,j
(6) The test should be repeated exactly as
described with the infiltration reduction
device (IRD) removed or deactivated.
(i) Following ASTM E741–06, the calculated
result is Vrate,without-device i,j
4.4 NFRC Door Testing
4.4.1 Door Conduction Testing
(a) All doors, as defined in section 2.1(b),
must be tested using NFRC 100–2010–E0A1
(incorporated by reference, see § 431.303).
(1) Internal conditions:
(i) Air temperature of 35 °F (1.7 °C) for cooler
doors and ¥10 °F (¥23.3 °C) for freezer
doors.
(ii) Mean inside radiant temperature same as
shown in (1)(i) above.
(2) External conditions.
(i) Air temperature of 75 °F (23.9 °C).
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Vdoor = Ci (ΔP)ni
(4-10)
Where:
i = index corresponding to the exfiltration or
infiltration test;
˙
VdoorQ = the airflow rate, ft3/h (m3/s);
DP = the differential pressure, in-H2O (Pa);
Ci = coefficient determined based on
goodness of fit to test data of type i; and
ni = exponent determined based on goodness
of fit to test data of type i.
(f) Find the average C and n:
C=
Cinfiltration + Cexfiltration
2
(4-11)
n=
ninfiltration + nexfiltration
2
(4-12)
Where:
Cinfiltration = coefficient determined using loglinear regression of infiltration test;
Cexfiltration = coefficient determined using loglinear regression of exfiltration test;
E:\FR\FM\09SEP2.SGM
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EP09SE10.113
4.3.3
(4-8)
EP09SE10.112
Vfreezer
CL
(ii) Mean outside radiant temperature same
as shown in (2)(i) above.
(iii) Direct solar irradiance = 0 Btu/h-ft2
(0 W/m2).
(iv) The average convective heat transfer
coefficient on both interior and exterior
surfaces of the door should be based on
‘‘natural convection’’ as described in
section 4.3 of NFRC 100–2010–E0A1.
4.4.2 Door Infiltration Testing
(a) All doors must be tested using NFRC
400–2010–E0A1 (incorporated by reference,
see § 431.303).
(b) Number of tests:
(1) One door system of representative sizes
of ‘‘small,’’ ‘‘medium,’’ and ‘‘large’’ as defined
in 4.3.2(a), that have identical construction
(i.e. only differ in dimensional size) may be
used for extrapolating the infiltration of other
doors that only differ in size as described in
4.3.2(a).
(c) Testing must be completed at six
pressure differentials for both positive and
negative pressure (exfiltration and
infiltration):
(1) 0.0401 in-H2O (10 Pa).
(2) 0.0803 in-H2O (20 Pa).
(3) 0.1204 in-H2O (30 Pa).
(4) 0.1606 in-H2O (40 Pa).
(5) 0.2007 in-H2O (50 Pa).
(6) 0.2409 in-H2O (60 Pa).
(d) At each of the six pressure differentials
described above, the airflow rate must be
measured.
(e) Using the six pressure differentials and
measured flow rates (in both directions) the
values for Ci and ni, must be found using loglinear regression equation below:
EP09SE10.111
Vfreezer-ft =
(‘‘large test’’): Width = 144 inches ± 0.5 inch
and height = 180 inches ± 0.5 inch.
(5) For the small door test, a test volume
of dimension and construction and door
location shown in Figure 4 must be used.
(6) For all medium and large door tests, the
width and height of the test unit must be
increased in size, directly proportional to the
increased door size over the small door test.
For example since the medium doorway
width is twice the size of the small door, the
test unit must be twice as wide as shown in
Figure 4.
EP09SE10.110
Where:
CL,wall = the total crack length of the non-door
walls, ft;
CL,door-wall = the total crack length of the door
wall, ft; and
CL,ceiling-floor = the total crack length of the
ceiling and floor, ft;
(3) Calculate the infiltration per unit crack
˙
length for the freezer, Vfreezer-ft and cooler,
˙
Vcooler-ft, tests, (ft3/h-ft), respectively as
follows:
˙
(i) Vfreezer-ft, ft3/h-ft:
(4-7)
EP09SE10.109
CL = CL,wall + CL,door-wall + CL,ceiling-floor
L = length of the walk-in unit per Figure 4,
ft.
(iv) CL, ft:
EP09SE10.108
Where:
W = width of the walk-in unit per Figure 4,
ft;
55107
55108
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 / Proposed Rules
Vdoor = C(ΔP)n
(4-13)
Vdoor
Pdoor crack
(4-14)
Where:
˙
VdoorQ = the airflow rate, ft3/h (m3/s); and
Pdoor crack = door operable crack perimeter, ft.
˙
(j) Vdoor normQ, for the corresponding
representative door test size, may be used for
calculating the infiltration rate of doors with
differing operable crack perimeter.
˙
(k) If a testing entity desires such, VdoorQ
may be found for all doors instead of
calculating an infiltration rate based on
˙
Vdoor normQ.
[FR Doc. 2010–21364 Filed 9–8–10; 8:45 am]
BILLING CODE 6450–01–P
EP09SE10.115
Where:
˙
VdoorQ = the airflow rate, ft3/h (m3/s);
DP = the differential pressure, in-H2O (Pa);
C = coefficient determined based on
goodness of fit; and
n = exponent determined based on goodness
of fit.
˙
(i) Using the resulting VdoorQ for coolers
and freezers, calculate the normalized
infiltration rate per length of ‘‘operable crack
˙
perimeter,’’ Vdoor normQ, as defined in ASTM
E–283–04 (ASTM E–283–04 section 12.3.1)
(incorporated by reference, see § 431.303)
must be calculated.
Vdoor norm =
VerDate Mar<15>2010
18:18 Sep 08, 2010
Jkt 220001
PO 00000
Frm 00042
Fmt 4701
Sfmt 9990
E:\FR\FM\09SEP2.SGM
09SEP2
EP09SE10.114
jlentini on DSKJ8SOYB1PROD with PROPOSALS2
ninfiltration = exponent determined using loglinear regression of infiltration test; and
nexfiltration = exponent determined using loglinear regression of exfiltration test.
(g) If n is found to be less than 0.5 or
greater than 1.0 the test is considered invalid
and the infiltration and exfiltration tests must
be repeated until valid value for n is
determined.
(h) Using the valid n, corresponding C and
˙
the equation below, determine,VdoorQ, the
infiltration for the corresponding pressure
differentials (m3/s) for both cooler and
freezer application:
(1) Coolers: 0.006 in-H2O (1.5 Pa).
(2) Freezers: 0.014 in-H2O (3.5 Pa).
Agencies
[Federal Register Volume 75, Number 174 (Thursday, September 9, 2010)]
[Proposed Rules]
[Pages 55068-55108]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-21364]
[[Page 55067]]
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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; Proposed Rule
Federal Register / Vol. 75, No. 174 / Thursday, September 9, 2010 /
Proposed Rules
[[Page 55068]]
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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: Supplemental notice of proposed rulemaking.
-----------------------------------------------------------------------
SUMMARY: The U.S. Department of Energy (DOE) previously published a
notice of proposed rulemaking to adopt test procedures for measuring
the energy consumption of walk-in coolers and walk-in freezers,
pursuant to the Energy Policy and Conservation Act (EPCA), as amended.
DOE is continuing to consider those proposals, but is now soliciting
comments on several alternative proposed options. Once any final test
procedure is effective, any representation as to the energy use of
walk-in equipment must reflect the results of testing that equipment
using the test procedure. Concurrently, DOE is undertaking an energy
conservation standards rulemaking for this equipment. If DOE receives
data in this test procedure rulemaking that are pertinent to the
development of standards, it will use that data in evaluating potential
standards for this equipment. Once these standards are promulgated, the
adopted test procedures will be used to determine compliance with the
standards.
DATES: DOE will accept comments, data, and information regarding this
supplemental notice of proposed rulemaking (SNOPR) no later than
October 12, 2010. See section V of this SNOPR for details.
ADDRESSES: Any comments submitted must identify the SNOPR for Test
Procedures for Walk-In Coolers and Walk-In Freezers and provide docket
number EERE-2008-BT-TP-0014 and/or Regulation Identifier Number (RIN)
1904-AB85. Comments may be submitted using any of the following
methods:
1. Federal eRulemaking Portal: https://www.regulations.gov. Follow
the instructions for submitting comments.
2. E-mail: WICF-2008-TP-0014@hq.doe.gov. Include the docket number
EERE-2008-BT-TP-0014 and/or RIN 1904-AB85 in the subject line of the
message.
3. Postal Mail: Ms. Brenda Edwards, U.S. Department of Energy,
Building Technologies Program, Mailstop EE-2J, 1000 Independence
Avenue, SW., Washington, DC 20585-0121. Please submit one signed
original paper copy.
4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Program, 950 L'Enfant Plaza, 6th Floor,
Washington, DC 20024. Please submit one signed original paper copy.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section V of this document.
Docket: For access to the docket to read background documents or
comments received, visit the U.S. Department of Energy, Resource Room
of the Building Technologies Program, 950 L'Enfant Plaza, 6th Floor,
Washington, DC 20024, (202) 586-2945, between 9 a.m. and 4 p.m. Monday
through Friday, except Federal holidays. Please call Ms. Brenda Edwards
at the above telephone number for additional information regarding
visiting the Resource Room.
FOR FURTHER INFORMATION CONTACT: Mr. Charles Llenza, U.S. Department of
Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue,
SW., Washington, DC 20585-0121, (202) 586-2192,
Charles.Llenza@ee.doe.gov; Mr. Michael Kido, U.S. Department of Energy,
Office of General Counsel, GC-71, 1000 Independence Avenue, SW.,
Washington, DC 20585-0121, (202) 586-8145, Michael.Kido@hq.doe.gov; or
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of General
Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC 20585-
0121, (202) 586-7796. E-mail: Elizabeth.Kohl@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
I. Authority and Background
II. Summary of the Proposal
III. Discussion
A. Overall Issues
1. Definition of Walk-In Cooler or Freezer: Temperature Limit
2. Testing and Compliance Responsibility
3. Basic Model of Envelope
4. Basic Model of Refrigeration Systems
B. Envelope
1. Heat Conduction Through Structural Members
2. Use of ASTM C1303 or EN 13165:2009-02
3. EN 13165:2009-02 as a Proposed Alternative to ASTM C1303-10
4. Version of ASTM C1303
5. Improvements to ASTM C1303 Methodology
6. Heat Transfer Through Concrete
a. Floorless Coolers
b. Pre-Installed Freezer Floor
c. Insulated Floor Shipped by Manufacturer
7. Walk-in Sited Within a Walk-In: A ``Hybrid'' Walk-In
8. U-Factor of Doors and Windows
9. Walk-In Envelope Steady-State Infiltration Test
10. Door Steady-State Infiltration Test
11. Door Opening Infiltration Assumptions
12. Infiltration Reduction Device Effectiveness
13. Relative Humidity Assumptions
C. Refrigeration System
1. Definition of Refrigeration System
2. Version of AHRI 1250
3. Annual Walk-In Energy Factor
IV. Regulatory Review
A. Review Under Executive Order 12866
B. Review Under the National Environmental Policy Act
C. Review Under the Regulatory Flexibility Act
1. Reasons for the Proposed Rule
2. Objectives of and Legal Basis for the Proposed Rule
3. Description and Estimated Number of Small Entities Regulated
4. Description and Estimate of Compliance Requirements
5. Duplication, Overlap, and Conflict With Other Rules and
Regulations
6. Significant Alternatives to the Rule
D. Review Under the Paperwork Reduction Act
E. Review Under the Unfunded Mandates Reform Act of 1995
F. Review Under the Treasury and General Government
Appropriations Act, 1999
G. Review Under Executive Order 13132
H. Review Under Executive Order 12988
I. Review Under the Treasury and General Government
Appropriations Act, 2001
J. Review Under Executive Order 13211
K. Review Under Executive Order 12630
L. Review Under Section 32 of the Federal Energy Administration
(FEA) Act of 1974
V. Public Participation
A. Submitting Public Comment
B. Issues on Which DOE Seeks Comment
1. Upper Limit of Walk-In Cooler
2. Basic Model of Envelope
3. Basic Model of Refrigeration
4. Updates to Standards
5. Heat Conduction Through Structural Members
6. Alternatives to ASTM C1303-10
7. Improvements to ASTM C1303 Methodology
8. Conduction Through Floors
9. ``Hybrid'' Walk-Ins
10. U-Factor of Doors and Windows
11. Envelope Infiltration
12. Relative Humidity Assumptions
13. Definition of Refrigeration System
14. Annual Walk-In Energy Factor
15. Impacts on Small Businesses
VI. Approval of the Office of the Secretary
I. Authority and Background
Title III of the Energy Policy and Conservation Act of 1975, as
amended (``EPCA'' or, in context, ``the Act'') sets forth a variety of
provisions designed to improve energy efficiency. Part B of Title III
(42 U.S.C. 6291-6309) provides for the Energy Conservation Program for
Consumer Products Other Than Automobiles. The National Energy
Conservation Policy Act (NECPA),
[[Page 55069]]
Public Law 95-619, amended EPCA to add Part C of Title III, which
established an energy conservation program for certain industrial
equipment. (42 U.S.C. 6311-6317) (These parts were subsequently
redesignated as Parts A and A-1, respectively, for editorial reasons.)
Section 312 of the Energy Independence and Security Act of 2007 (``EISA
2007'') further 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''), the
subject of this rulemaking. (42 U.S.C 6311(1), (20), 6313(f), and
6314(a)(9))
At its most basic level, the term ``walk-in equipment'' encompasses
enclosed storage spaces of under 3,000 square feet that can be walked
into and are refrigerated to specified temperatures--above 32 degrees
Fahrenheit ([deg]F) for coolers and at or below 32 [deg]F for freezers.
(42 U.S.C. 6311(20)(A)) The term does not include equipment designed
and marketed exclusively for medical, scientific or research purposes.
(42 U.S.C. 6311(20)(B))
Walk-ins that meet this definition may be located indoors or
outdoors. They may be used exclusively for storage, but they may also
have transparent doors or panels for the purpose of displaying stored
items. Examples of items that may be stored in walk-ins include, but
are not limited to, food, beverages, and flowers.
Under the Act, the overall program consists of three parts:
testing, labeling, and Federal energy conservation standards. The
testing requirements consist of test procedures prescribed under the
authority of EPCA. These test procedures are used in several different
ways: (1) DOE uses them to aid in the development of standards for
covered products or equipment; (2) manufacturers of covered equipment
must use them to establish that their equipment complies with standards
promulgated under EPCA and when making representations about equipment
efficiency; and (3) DOE must use them to determine whether equipment
complies with applicable standards.
Section 343 of EPCA (42 U.S.C. 6314) sets forth generally
applicable criteria and procedures for DOE's adoption and amendment of
such test procedures. That provision requires that the test procedures
promulgated by DOE be reasonably designed to produce test results which
reflect energy efficiency, energy use, and estimated operating costs of
the covered equipment during a representative average use cycle. It
also requires that the test procedure not be unduly burdensome to
conduct. (42 U.S.C. 6314(a)(2)) As part of the process for promulgating
a test procedure, DOE must publish a proposed procedure and offer the
public an opportunity to present oral and written comments in response
to that procedure. DOE solicited comments on the notice of proposed
rulemaking (``NOPR'') setting forth proposed test procedures, published
on January 4, 2010 (``the January NOPR''). 75 FR 186. DOE also held a
public meeting to discuss the January 2010 NOPR on March 24, 2010. DOE
is now soliciting further comment through this SNOPR.
The January NOPR and the March 2010 meeting provided interested
parties an opportunity to submit comments on the proposals. Interested
parties raised significant issues and suggested changes to the proposed
test procedures. DOE determined that some of these comments warrant
further consideration. In today's notice, DOE addresses those comments
and proposes adjustments to the initial test procedures proposed for
walk-in equipment in the January 2010 NOPR.
II. Summary of the Proposal
DOE is proposing several changes to the proposal presented in the
January NOPR. These changes involve:
(1) Definition of walk-in cooler and walk-in freezer.
(2) Testing and compliance responsibility.
(3) Versions of standards incorporated by reference.
(4) Basic model for envelope.
(5) Basic model for refrigeration system.
(6) Conduction through structural members.
(7) Alternatives to ASTM C1303.
(8) Heat transfer through concrete.
(9) U-factor of glass and non-glass doors.
(10) Steady-state infiltration through panel interfaces and doors.
(11) Door opening infiltration assumptions.
(12) Infiltration reduction device effectiveness.
(13) Relative humidity assumptions.
(14) Definition of refrigeration system.
(15) Annual walk-in energy factor.
Concurrently, DOE is undertaking an energy conservation standards
rulemaking to address the statutory requirement to establish
performance standards for walk-in equipment no later than January 1,
2012. (42 U.S.C. 6313(f)(4)(A)) DOE will use the test procedure in the
concurrent process of evaluating potential performance standards for
the equipment. After performance standards become applicable,
manufacturers must use the test procedures to determine compliance with
the standards, and DOE must use the test procedure to ascertain
compliance with the standards in any enforcement action. Moreover, once
any final test procedure is effective, any representation as to the
energy use of walk-in equipment must reflect the results of testing
that equipment using the test procedure.
III. Discussion
This section addresses issues raised by interested parties in
response to the January NOPR and provides detail regarding DOE's
proposed changes to the test procedure. Interested parties include
trade associations (American Chemistry Council/Center for the
Polyurethanes Industry (ACC/CPI), AHRI); manufacturers of the covered
equipment (Craig Industries, Metl-Span, Nor-Lake, Carpenter, Master-
Bilt, American Panel Corporation, Arctic Industries, Amerikooler,
Kason, Hill Phoenix, TAFCO/TMP (TAFCO), International Cold Storage
(ICS), ThermalRite, Manitowoc, Kysor Panel, HeatCraft, and Crown
Tonka); suppliers of components used in the covered equipment
(Honeywell, BASF, Dyplast, ITW Insulation, Owens Corning, HH
Technologies (Hired Hand), Dow Chemical, and Schott Gemtron); utilities
(Southern California Edison (SCE), San Diego Gas and Electric (SDGE),
and the Sacramento Municipal Utility District (SMUD)); and energy
efficiency advocates (American Council for an Energy-Efficient Economy
(ACEEE)).
A. Overall Issues
1. Definition of Walk-In Cooler or Freezer: Temperature Limit
EPCA defines walk-in equipment as follows:
(A) In general.--
The terms ``walk-in cooler'' and ``walk-in freezer'' mean an
enclosed storage space refrigerated to temperatures, respectively,
above, and at or below 32 degrees Fahrenheit that can be walked
into, and has a total chilled storage area of less than 3,000 square
feet.
(B) Exclusion.--
The terms ``walk-in cooler'' and ``walk-in freezer'' do not
include products designed and marketed exclusively for medical,
scientific, or research purposes. (42 U.S.C. 6311(20))
During the public meeting on the January NOPR and in written
comments, several interested parties stated that DOE should clarify
this definition with respect to temperature limits and exclusions.
Multiple interested parties commented that DOE
[[Page 55070]]
should set an upper temperature limit for walk-ins. Three temperature
limits were proposed: (1) 40 or 41 [deg]F; (2) 45 [deg]F; and (3)
between 31 [deg]F and 55 [deg]F. Kysor stated that DOE should align
with the National Sanitation Foundation (NSF) definition of 41 [deg]F
as the maximum high temperature for food storage. (Kysor, Public
Meeting Transcript, No. 1.2.010 at p. 85) ICS agreed with Kysor but
cautioned that this temperature could be different from the temperature
set by the customer. (ICS, Public Meeting Transcript, No. 1.2.010 at p.
86)
In written comments, Kysor also suggested 40 [deg]F as the upper
limit because NSF/ANSI Standard 7, ``Commercial Refrigerators and
Freezers'' uses such a requirement. See NSF/ANSI Standard 7,
``Commercial Refrigerators and Freezers,'' Section 6.10.1,
``Performance (``Storage refrigerators and refrigerated food transport
cabinets shall be capable of maintaining an air temperature of 40
[deg]F (4 [deg]C) or lower in the interior.'') (Kysor, No. 1.3.035 at
p. 1) Craig and Hired Hand both indicated that 45 [deg]F or 41 [deg]F
would be an acceptable upper limit. (Craig, Public Meeting Transcript,
No. 1.2.010 at p. 86; Craig, No. 1.3.017 at p. 1 and Public Meeting
Transcript, No. 1.2.010 at p. 19; Hired Hand, Public Meeting
Transcript, No. 1.2.010 at p. 88) A comment submitted jointly by SCE,
SDGE, and SMUD, hereafter referred to collectively as ``the Joint
Comment,'' recommended that DOE develop a definition to clarify that
walk-in coolers operate at temperatures between 55 [deg]F and 32
[deg]F. (Joint Comment, No. 1.3.019 at p. 17) SCE pointed out that
California's building energy standards consider 55 [deg]F and below to
be refrigerated. (SCE, Public Meeting Transcript, No. 1.2.010 at p. 85)
TAFCO agreed that DOE should impose an upper limit of 55 [deg]F because
this is the highest temperature at which most refrigeration systems
will operate. (TAFCO, No. 1.3.022 at p. 1) Craig disagreed with a 55
[deg]F limit because this temperature is the typical holding
temperature for wine coolers, but the walk-in wine cooler might be
rated at a lower temperature. (Craig, Public Meeting Transcript, No.
1.2.010 at p. 86) DOE infers from the comment that Craig was concerned
that the energy consumption of a wine cooler at the test procedure
rating temperature might not represent the energy consumption at the
actual holding temperature. Hired Hand stated that air conditioning is
the first stage of cooling for walk-ins inside air-conditioned
warehouses, which echoed the concerns of other commenters that the
complete absence of an upper temperature limit might inadvertently
include a wider variety of conditioned spaces than contemplated. (Hired
Hand, Public Meeting Transcript, No. 1.2.010 at p. 87)
EPCA defines walk-in equipment, in part, as meaning a space that is
``refrigerated,'' and as having a ``chilled storage area.'' (42 U.S.C.
6311(20)) DOE proposes clarifying the term ``refrigerated'' within the
statutory definition to distinguish walk-in equipment from air-
conditioned storage spaces. DOE could not find a consensus among the
industry for the definition of ``refrigerated'' or ``chilled storage.''
However, the Joint Comment, SCE, and TAFCO suggested that 55 [deg]F
represented a boundary between ``refrigerated space'' and ``conditioned
space'' as refrigeration systems typically do not operate above 55
[deg]F, and air-conditioning systems typically do not operate below
this limit. DOE found that preparation rooms, wine coolers, and storage
coolers for most fruits and vegetables are considered refrigerated
spaces and are typically cooled to temperatures between 45 [deg]F and
55 [deg]F. DOE proposes adopting a clarifying definition that would set
an upper limit of 55 [deg]F for walk-in equipment. DOE believes that
using the upper limit of food storage temperatures (i.e., 40 [deg]F or
45 [deg]F) to define walk-in equipment, as suggested by some
commenters, would exclude some equipment that is ``refrigerated'' and
has a ``chilled storage area.'' Such an approach would, in DOE's view,
exclude from coverage equipment that falls within the statutorily-
prescribed scope of EPCA's walk-in definition. The space in which a
walk-in is located (e.g., a grocery store, warehouse, or other
conditioned space) would not itself be considered a walk-in unless it
meets the statutory definition of a walk-in and DOE's proposed
clarifying definition that would set an upper limit on the temperature
range. DOE requests comment on its proposal of clarifying
``refrigerated'' to mean at or below 55 [deg]F.
2. Testing and Compliance Responsibility
In responding to comments received on the framework document, the
January NOPR detailed DOE's proposal to create separate test procedures
for the envelope and the refrigeration system, the two discrete systems
that comprise a walk-in. 75 FR 191. These two systems may or may not
each be manufactured by a separate manufacturing entity. Additionally,
other manufacturers may be involved in producing secondary components--
such as fan assemblies or lighting--that are then incorporated as parts
of the refrigeration system or envelope.
In the January NOPR, DOE proposed that the envelope manufacturer
would be responsible for testing the envelope according to the envelope
test procedure, and the refrigeration system manufacturer would be
responsible for testing the refrigeration system according to the
refrigeration system test procedure. 75 FR 191. DOE believed that the
manufacturers of the envelope and refrigeration systems--as parties
most likely to be intimately familiar with the design and operation of
their own equipment--would be more likely than installers to have the
resources, equipment, and trained personnel needed to conduct the tests
necessary to certify WICF equipment as compliant with any energy
conservation standards that DOE develops. 75 FR 191.
However, interested parties commented that DOE's concept of a
single envelope manufacturer may not align with the actual market.
Commenters suggested that the panel manufacturers, whom DOE assumed
would serve as the envelope manufacturers for purposes of testing
compliance, did not necessarily control the design of the walk-in
envelopes for which their panels were used. Many of the comments from
interested parties suggested that DOE should assign compliance testing
responsibility to parties involved in the physical assembly (e.g.,
installers) and/or design-level specification (e.g., general
contractors) of the walk-in envelope because actions taken by these
parties could have a significant effect on walk-in performance over its
lifetime. Some commenters suggested various forms of joint
responsibility between the manufacturer(s) of the envelope components
and the parties responsible for the physical assembly and/or design-
level specification of the envelope. Other interested parties commented
that these options would not constitute a viable approach and that DOE
should focus on the panel manufacturers for compliance testing because
they would be more likely to have the proper equipment and expertise to
test the panels.
Likewise, interested parties commented that DOE's concept of a
single refrigeration system manufacturer may be inaccurate because the
condensing unit and unit cooler of a single refrigeration system may be
manufactured by separate entities and the whole system may be
manufactured from these separate parts by a third manufacturer.
Commenters generally suggested assigning joint responsibility between
the manufacturer(s) of the unit
[[Page 55071]]
cooler and condensing unit and the manufacturer of the system as a
whole. Others suggested that DOE break a refrigeration system down into
its individual components (e.g., compressor, coils) and regulate each
component separately.
DOE believes that many of the comments concerning compliance
testing responsibility stem from the definition of the term
``manufacture,'' which EPCA defines as ``to manufacture, produce,
assemble or import.'' (42 U.S.C. 6291(10)) Several interested parties
requested clarification of the definition of ``manufacture'' and the
implications of that role. DOE generally requires a single party, whose
role falls under the term ``manufacture,'' to assume compliance
responsibility for a given appliance or equipment; typically, the party
responsible for demonstrating compliance would conduct the necessary
testing or arrange for testing to be conducted by a third party (e.g.,
a testing lab). DOE recognizes that the walk-in envelope and
refrigeration system markets rely on multiple supply chain scenarios in
which several distinct parties could serve different roles that may
fall under the term ``manufacture.'' In the case of both walk-in
envelopes and refrigeration systems, DOE recognizes that assigning
compliance responsibility to a single entity that may not be involved
in all aspects of the design and construction of these systems may
present certain logistical issues. Accordingly, DOE plans to further
address these issues during the standards rulemaking when developing
the required efficiency levels and when developing certification and
compliance responsibilities.
3. Basic Model of Envelope
Although often manufactured according to the same basic design,
many walk-in envelopes can be highly customized. To address this
possibility, DOE proposed the following approach in the January NOPR:
(1) Grouping walk-in envelopes with essentially identical construction
methods, materials, and components into a single basic model; and (2)
adopting a calculation methodology for determining the energy
consumption of units within the basic model. For walk-in envelopes, DOE
proposed to define a ``basic model'' as ``all units of a given type of
walk-in equipment manufactured by a single manufacturer, and--(1) With
respect to envelopes, which do not have any differing construction
methods, materials, components, or other characteristics that
significantly affect the energy consumption characteristics.'' 75 FR
189.
Master-Bilt, BASF, ACC/CPI, Craig, Kason, and ThermalRite supported
the concept of the basic model for WICF envelopes. (Master-Bilt, No.
1.3.009 at p. 1; BASF, No. 1.3.003 at p. 3; ACC/CPI, No. 1.3.006 at p.
2 and No. 1.3.028 at p. 1; Craig, Public Meeting Transcript, No.
1.2.010 at p. 102; Kason, No. 1.3.037 at p. 1 and Public Meeting
Transcript, No. 1.2.010 at p. 124; and ThermalRite, No. 1.3.031 at p.
1) Craig supported an approach consisting of a single basic model test
on a baseline model and adding component loads. (Craig, Public Meeting
Transcript, No. 1.2.010 at p. 123) Kason stated that the basic model
test should include provisions at the component level, where
manufacturers could pick new components as long as the components were
certified to exceed the performance of the old components. (Kason,
Public Meeting Transcript, No. 1.2.010 at p. 124) Kysor and Nor-Lake
both believed that the concept of the basic model may not be realistic
if envelope components such as doors and lights were not purchased or
installed by the panel manufacturers; in that case, Kysor and Nor-Lake
stated that component manufacturers should be responsible for rating
individual components. (Nor-Lake, No. 1.3.029 at p. 2; Kysor, No.
1.3.035 at p. 2) Arctic proposed expanding the basic model concept to
eliminate testing for units using the same materials and construction
methods as a previously certified model, adding that it would be
impractical and infeasible for them to test every kind of equipment
they manufacture because of the great variety of box dimensions.
(Arctic, No. 1.3.012 at p. 1) BASF and Kason also stated that
manufacturers must be able to reduce the number of models to test to
ensure minimal manufacturer burden. (BASF, No. 1.3.003 at p. 3 and
Kason, No. 1.3.037 at p. 1)
Other interested parties disagreed with the proposed basic model
approach. Bally stated that the company produces tens of thousands of
basic models, making basic model testing infeasible. (Bally, Public
Meeting Transcript, No. 1.2.010 at p. 132) Hill Phoenix believed that
use of a basic model for testing would not accurately represent the
energy usage of most walk-ins because of equipment variability, that an
energy usage calculation program would have to be created and
maintained and be consistent across the industry, and that basic model
testing would require costly government oversight. Instead, Hill
Phoenix recommended component-level modeling. (Hill Phoenix, No.
1.3.023 at p. 2)
Several interested parties requested clarification of the proposed
definition of basic model. ACC/CPI and Honeywell recommended that
different types of foam and/or different blowing agents should trigger
different basic models (ACC/CPI, No. 1.3.006 at p. 2 and Public Meeting
Transcript, No. 1.2.010 at p. 43; Honeywell, No. 1.3.020 at p. 1)
Honeywell also recommended that a different facer material should
trigger a new basic model. (Honeywell, No. 1.3.020 at p. 1) Owens
Corning stated that the insulation material should not trigger a new
basic model because the R-value of the insulation is addressed in EISA
and that panel construction (framed or frameless) should be used to
differentiate between basic models. (Owens Corning, No. 1.3.030 at p.
2) ICS stated that different applications should constitute different
basic models: holding storage, quick chilling or freezing, or blast
freezing. (ICS, No. 1.3.027 at p. 1) TAFCO commented that the use of
strip curtains or air curtains should not constitute a new basic model.
(TAFCO, No. 1.3.022 at p. 2)
Other interested parties requested that DOE specify standard
characteristics for a certain basic unit that every manufacturer would
test. American Panel, ThermalRite, and Craig recommended that DOE
specify a standardized basic model size. (American Panel, No. 1.3.024
at p. 2; ThermalRite, No. 1.3.031 at p. 1; Craig, Public Meeting
Transcript, No. 1.2.010 at pp. 102, 106, and 119) Craig suggested a
basic size applicable to the food industry--an 8 foot x 10 foot cooler
and a 6 foot x 8 foot freezer, both with a height of 7 feet 6 inches
tall--and added that size would only be applicable to the infiltration
test because other characteristics could be calculated. (Craig, Public
Meeting Transcript, No. 1.2.010 at p. 105 and No. 1.2.010 at pp. 102,
106, and 119) Kysor suggested that only height could be specified,
arguing that walk-ins cannot be characterized by size. (Kysor, Public
Meeting Transcript, No. 1.2.010 at p. 106)
Finally, interested parties commented on the proposed scaling
methodology associated with the basic model concept. Manitowoc stated
that a scaling methodology based on surface area would not give an
accurate representation of energy use because energy scales not only
with surface area but with other factors as well such as the number of
installed doors and door size. In other words, individual component
loads scale with individual component characteristics. (Manitowoc,
[[Page 55072]]
Public Meeting Transcript, No. 1.2.010 at p. 108) ThermalRite also
questioned whether there is a linear relationship between energy
consumption and WICF size that would allow for scaling. (ThermalRite,
Public Meeting Transcript, No. 1.2.010 at p. 110)
Upon consideration of these comments, DOE believes that the basic
model concept would provide manufacturers with a standardized method of
categorizing their products. However, the definition of basic model
proposed in the January NOPR could make the concept difficult to use as
originally intended to reduce testing burden. Specifically, the phrase
``* * * characteristics that significantly affect the energy
consumption * * *'' could be interpreted inconsistently by
manufacturers. The paragraphs below describe DOE's proposed alternative
approach to defining the term ``basic model''. Additionally, feedback
from interested parties indicated a desire for DOE to specify
prescriptive design characteristics for a basic model. Because EPCA
requires DOE to promulgate performance-based standards for this
equipment, DOE does not intend to specify design characteristics that
do not affect normalized energy consumption, as suggested by ACC/CPI,
Honeywell, Owens Corning, ICS and TAFCO. See 42 U.S.C. 6313(f)
(instructing DOE to set performance-based standards for walk-ins).
DOE is considering adopting a revised definition of the term
``basic model'' that would be consistent with the definition of basic
model used elsewhere in the appliance standards program, improve the
clarity of the definition, and narrow the scope of the basic model
concept. Most notably, this revision would not allow walk-in models to
differ in terms of their normalized energy consumption. Models grouped
within a basic model could still differ in terms of their non-energy
characteristics (e.g., color, shelving, metal skin material type,
exterior finish, door kick-plate) but any change to a characteristic
that affects normalized energy consumption (e.g., panel systems, door
systems, electrical components, and infiltration reduction devices)
would constitute a new basic model.
DOE's proposed revision, while reducing the possibility of
inconsistent interpretation of the term ``basic model'', could increase
the testing burden relative to the burden under the definition of
``basic model'' as proposed in the January NOPR. Some of the burden may
be offset, however, by burden-reducing measures proposed elsewhere in
the test procedure. These measures include incorporating scaling
factors for the infiltration test (section III.B.9), the panel U-factor
test (section III.B.1), and representative doorway sizes for
infiltration reduction device testing. With these measures, DOE
attempts to minimize the number of physical tests that would need to be
performed for the test procedure and instead provide a calculation
methodology that would allow for rating equipment based on physical
tests conducted on other equipment. DOE believes that this approach
would sufficiently address the concerns of BASF, Kason, Arctic, Bally,
and Hill Phoenix regarding the number of basic models to be tested and
the cost of testing. A DOE-specified calculation methodology would also
address Hill Phoenix's recommendation that the energy use calculation
program be consistent across the industry. Regarding Arctic's view that
the basic model concept should be expanded to include similar units
with the same materials and construction methods that have been
previously certified, DOE notes that models with the same
characteristics as previously certified models would be considered the
same basic model only if they met the conditions in the basic model
definition. In other words, the models would need to have the same
manufacturer and not have any differing characteristics that affect
normalized energy consumption.
The proposed test procedure revisions considered in this SNOPR also
rely more heavily on component testing, consistent with the suggestions
made by Craig, Kason, Kysor, Nor-Lake, and Hill Phoenix. This approach
removes the burden of testing an entire walk-in for which only one
component is different from a previously rated walk-in: the test
procedure revisions in this SNOPR would allow for testing the new
component and then using the proposed calculation methodology to obtain
the new rating of the walk-in. Additionally, the proposed component
tests allow for testing one component and then applying those results
to other components that meet certain similar criteria. DOE believes
this method is more accurate than allowing for scaling of the entire
walk-in, because each walk-in could contain many customized parts.
Adopting this method would address the concerns raised by Manitowoc and
ThermalRite that energy may not scale directly with walk-in external
surface area or other size characteristics. For some proposed component
tests, DOE specifies characteristics of the part that must be
physically tested (i.e., the geometry of a panel test sample), instead
of specifying characteristics of the tested walk-in unit as a whole as
suggested by American Panel, ThermalRite, Craig, and Kysor, because (1)
complete walk-in units may be very different from one another even if
they use similar components, and (2) the scaling calculations are more
accurate on the component level than on the level of the entire walk-
in, which supports testing certain components as part of the compliance
procedure. For additional details on these proposed component tests,
see section III.B.
With respect to certification, in general, DOE requires that
manufacturers of a covered basic model submit a certification report
providing details, which demonstrate compliance with the applicable
energy conservation standards or design standards prescribed by DOE or
established by Congress. DOE estimates that approximately 50 percent of
the market consists of standardized walk-ins that are produced in large
quantities. For the other half of the market, walk-ins may have custom
features and components that could qualify each as a different basic
model. In this situation, manufacturers could produce many basic models
in a year.
DOE is unsure, however, how burdensome this would be in terms of
the actual number of hours or personnel required to certify additional
basic models under this approach. If requiring a certification report
for each basic model under the approach outlined in today's SNOPR would
impose an unreasonable burden, DOE may consider a compliance
certification approach similar to that taken for distribution
transformers (another case in which some equipment is highly
customized). 10 CFR 431.371(a)(6)(ii). Distribution transformer
manufacturers are required to maintain records on all basic models sold
(or built), but must submit a compliance report to DOE that certifies
only the least efficient basic model within larger groupings that may
encompass many basic models. 10 CFR 431.371(a)(6)(ii). The manufacturer
would certify that every other transformer in the larger grouping is no
less efficient than the certified basic model certified to DOE. Given
the nature of the market, DOE is willing to consider variations on this
approach for walk-ins, such as requiring certification for the least
and most efficient basic models within a larger group. Such an approach
could help address the concern of Hill Phoenix about the cost of an
oversight strategy.
[[Page 55073]]
DOE requests comment on its proposed definition and approach
regarding basic models for envelopes.
4. Basic Model of Refrigeration Systems
In the January NOPR, DOE proposed that the definition of the term
``basic model'' in the context of a refrigeration system would refer to
all units with the same energy source and without any different
electrical, physical, and functional characteristics that affect energy
consumption. DOE then stated during the NOPR public meeting that it was
considering a new definition that would not allow units within a basic
model to differ in energy consumption. DOE also stated during the
public meeting that it would consider the default of including no
provision for a basic model, under which manufacturers would be
required to test every model they manufacture.
AHRI and ACEEE agreed with DOE's proposed approach and definition
of basic model. (AHRI, No. 1.3.032 at p. 2 and Public Meeting
Transcript, No. 1.2.010 at p. 169; ACEEE, No. 1.3.034 at p. 2) Craig
also agreed with the proposed approach given that improvements could be
applied to existing systems. (Craig, Public Meeting Transcript, No.
1.2.010 at p. 172) ICS, Manitowoc, and HeatCraft recommended that the
basic model of refrigeration be allowed to vary minimally (a 5 percent
tolerance) in energy consumption, while HeatCraft also stated that in
Europe, the tolerance is typically 8 percent. (ICS, No. 1.3.027 at p.
1; Manitowoc, Public Meeting Transcript, No. 1.2.010 at p. 159; and
HeatCraft, Public Meeting Transcript, No. 1.2.010 at p. 162) On the
other hand, Master-Bilt expressed concern that too many refrigeration
system combinations may exist for the basic model concept to be applied
effectively. (Master-Bilt, No. 1.3.009 at p. 1) HeatCraft stated that
it was concerned about testing highly variable refrigeration systems
and combinations, and whether they would be able to incorporate new
technologies. (HeatCraft, Public Meeting Transcript, No. 1.2.010 at p.
42) Nor-Lake was also concerned about the potential testing burden
because it has distinct energy efficiency ratio values on over 250
models. It recommended either defining basic model to account for how
many basic models a manufacturer would have or to replace the basic
model approach with a component-based one. (Nor-Lake, No. 1.3.005 at
pp. 2 and 5 and No. 1.3.029 at p. 2) Manitowoc suggested considering a
unit cooler its own basic model (not the combination of unit cooler and
condensing unit), making it unnecessary to test all combinations but
only individual parts of the system. (Manitowoc, Public Meeting
Transcript, No. 1.2.010 at p. 158)
TAFCO identified refrigeration system components that, if changed,
would significantly affect energy consumption. These components include
the compressor, condensing coil, fan motors, head pressure control, and
evaporator coil. (TAFCO, No. 1.3.022 at p. 2) American Panel added that
headmasters (which control pressure) must be included on outdoor
condensing units if the unit will be exposed to low temperatures.
(American Panel, No. 24 at p. 3) Some interested parties discussed
whether DOE should specify certain characteristics of the basic model.
Specifically, HeatCraft stated that the basic model should include some
common parts such as a filter dryer to permit a valid comparison
between manufacturers, but manufacturers should be allowed to add
unique features. (HeatCraft, Public Meeting Transcript, No. 1.2.010 at
p. 162) ACEEE agreed that the basic model should include parts that
have a reasonable probability of affecting energy consumption to
encourage manufacturers to include all necessary components in their
WICF equipment. (ACEEE, Public Meeting Transcript, No. 1.2.010 at p.
168) AHRI disagreed, stating that DOE should not specify design
requirements in defining basic model groups, but rather agreed with
DOE's proposed definition. (AHRI, Public Meeting Transcript, No.
1.2.010 at p. 169) (Although ACEEE did not elaborate further on what it
considers ``all necessary components,'' DOE is interpreting this phrase
as referring to any components that would be needed to have the unit
work in a manner as designed without the addition of aftermarket
components that would impact the equipment's energy usage.)
As with envelopes, DOE must ensure that all refrigeration systems
are accurately rated and comply with the standard. To avoid differing
interpretations of what a ``significant difference'' in energy
consumption might be, DOE believes that it is appropriate to clarify
certain aspects of that definition to eliminate differences in the
measured energy consumption of models belonging to the same basic model
group. Accordingly, DOE proposes a revised definition of basic model of
refrigeration where units cannot differ in electrical, physical, or
functional characteristics that affect energy consumption. DOE
recognizes that the components identified by TAFCO affect the energy
consumption of the refrigeration system. Nevertheless, DOE believes
that listing only certain components where changes would constitute a
new basic model could overlook changes to other components that affect
energy consumption. In addition, the question of significance would
remain under such an approach. DOE believes that the definition
proposed here is sufficient to define basic model--a basic model would
necessarily have to include all components that affect energy
consumption.
DOE also acknowledges the concerns of interested parties,
specifically Master-Bilt, HeatCraft, and Nor-Lake, that a manufacturer
could produce many condensing unit and unit cooler combinations--i.e.,
many basic models --and that testing could be burdensome. DOE notes
that the proposed refrigeration system test procedure, AHRI 1250-2009,
allows for testing the condensing unit and unit cooler separately and
then, using the calculation methodology in AHRI 1250-2009, determining
the performance of the combined system, similar to the approach
suggested by Manitowoc. Under this approach, each combination would not
have to be tested, which would decrease the number of physical
equipment tests, even though each different combination would be
considered a different basic model and would receive a different
rating.
At this time, DOE does not intend to incorporate a tolerance into
the definition of basic model, as suggested by ICS, Manitowoc, and
HeatCraft, in order to ensure that the rating applying to each basic
model is as accurate as possible. DOE notes that one potential issue
with introducing a tolerance approach may be that neither DOE nor the
eventual purchaser of the equipment could expect that the rating of a
particular model would be equal to that model's actual energy
consumption. It is unclear to DOE how significant this issue may be if
such an approach were adopted.
DOE acknowledges, however, that units within a basic model are
expected to differ slightly as a result of manufacturing and materials
variations. As a result, DOE may consider accounting for these
variations in sampling plans used for compliance testing and developed
as part of any future certification and enforcement rulemaking. DOE's
existing compliance and certification regulations, developed for
certain other commercial equipment, provide that when a random sample
of equipment is taken for determining compliance with the standard for
commercial refrigeration equipment,
[[Page 55074]]
represented values of estimated energy consumption of a basic model
shall be no less than the higher of the mean of the test sample or the
upper 95 percent confidence limit of the true mean divided by 1.10. 75
FR 652, 666-71 (Jan. 5, 2010), codified at 10 CFR 431.372. This rule
also provides that, in enforcement proceedings, DOE's determination
that a basic model complies with the standard is based on a confidence
limit which accounts for statistical variation within a basic model. 75
FR 674, codified at 10 CFR part 431, Appendix D to Subpart T.
These sampling provisions are only intended to reduce the burden on
manufacturers associated with certification and enforcement.
Manufacturers would still be required to use the test procedure to rate
their equipment and, once energy conservation standards take effect, to
determine whether each basic model of the equipment they manufacture
complies with the standard.
As discussed above for envelopes, DOE could consider a compliance
certification approach similar to that taken for distribution
transformers (another case in which some equipment is highly
customized) to reduce the burden while ensuring that the energy
conservation standards are being met. 10 CFR 431.371(a)(6)(ii). DOE
describes this approach in detail in section III.A.3.
DOE requests comment on the definition of and approach to basic
model of refrigeration systems.
B. Envelope
The envelope consists of the insulated box in which items are
stored and refrigerated. To meet one element of the statutory
requirement that the DOE test procedure ``measure the energy use'' of
walk-ins (42 U.S.C. 6314(a)(9)(B)(i)), DOE had proposed to incorporate
a metric for the energy use associated with the envelope of a walk-in
cooler or walk-in freezer. Under the applicable EPCA definition of
``energy use''--the amount of energy directly consumed by a piece of
equipment at the point of use (42 U.S.C. 6311(4))--DOE has tentatively
determined that the energy use of a walk-in envelope is the sum of (1)
the electrical energy consumption of envelope components and (2) other
energy consumption of the walk-in equipment resulting from the heat
transfer performance of the envelope.
The proposed envelope test procedure contains 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 uses data obtained from these methods to
calculate a measure of 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. These
characteristics and components would include 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 effect on the
refrigeration system would be determined by calculating the energy
consumption of a theoretical or ``nominal'' refrigeration system if it
were paired with the tested envelope. The test procedure uses the same
nominal refrigeration system efficiency for all tested envelopes to
allow for direct comparison of the performance of walk-in envelopes
across a range of sizes, product classes, and levels of feature
implementation.
1. Heat Conduction Through Structural Members
In the January NOPR, DOE proposed that the long-term thermal
resistance (LTTR) value of the insulating foam after 5 years of
equivalent aging be determined using ASTM C1303-08, ``Standard Test
Method for Predicting Long-Term Thermal Resistance of Closed-Cell Foam
Insulation.'' This value would be used as the R-value for all non-glass
envelope sections constructed with foam insulation, for purposes of
calculating the energy consumption of the walk-in. Other components of
the panel, such as structural members, were not included in the
conduction calculations of the test procedure.
Craig, Owens Corning, and American Panel pointed out that
conduction through structural members must be considered when
determining the R-value of a composite walk-in insulation panel.
(Craig, No. 1.3.036 at p. 3 and Public Meeting Transcript, No. 1.2.010
at pp. 20 and 61; Owens Corning, Public Meeting Transcript, No. 1.2.010
at p. 56; and American Panel, No. 1.3.024 at p. 3) The Joint Comment
recommended that the current R-value requirement for the foam be
converted to an overall U-factor requirement for the assembled panel.
(Joint Comment, No. 1.3.019 at p. 11) (U-factor is a measure of heat
transmission, including conduction and radiation. A lower U-factor
indicates a lower rate of heat transmission.) Metl-Span, BASF, Kysor,
and ACC/CPI agreed with the approach of determining the performance of
the panel as a whole and recommended that DOE use ASTM C1363-05,
``Standard Test Method for Thermal Performance of Building Materials
and Envelope Assemblies by Means of a Hot Box Apparatus,'' for
evaluating the fully assembled panel. (Metl-Span, No. 1.3.004 at p. 1;
BASF, No. 1.3.003 at p. 2; Kysor, No. 1.3.035 at p. 2; ACC/CPI, No.
1.3.006 at p. 2)
In view of these comments, DOE proposes to account for conduction
through structural members, as urged by Craig and American Panel, by
measuring the overall U-factor of fully assembled panels as recommended
by the Joint Comment. All panels (walls, ceiling, and floor) would be
tested using ASTM C1363-05 for measuring the overall U-factor of fully
assembled panels, as stated by Metl-Span, BASF, Kysor, and ACC/CPI. The
resulting composite panel U-factor from ASTM C1363-05 would then be
corrected using the LTTR results from ASTM C1303-10, if foam is used as
the primary insulating material. See section 3.1.6 of Appendix A for
details. DOE believes using the results from ASTM C1363-05 modified by
ASTM C1303-10 best captures the effect of structural members and long-
term R-value of foam products.
DOE recognizes the burden involved when testing an entire
representative walk-in using ASTM C1363-05; i.e., requiring a
representative walk-in composed of 18 panels to be tested 18 times. DOE
also notes that testing a single representative panel would be less
burdensome but very inaccurate. Panels are often manufactured in
dimensions close to 8 feet long by 4 feet wide, but panel geometry
frequently deviates from this size as walk-ins are made larger. In
addition, structural members are normally placed in the perimeter of
panels (if used at all). Therefore, the heat transfer of a given panel
is most closely related to the ratio of perimeter structural materials
to non-perimeter core panel materials.
If DOE were to require an ASTM C1363-05 test using only one panel
size, the test would be representative of only this single perimeter-
to-core ratio. If a walk-in were constructed of panels that deviated
from this representative size in either extreme (i.e., much smaller or
larger), the resulting energy calculations could be inaccurate. To
balance the competing interests of minimizing burden while ensuring
measurement accuracy, DOE is proposing to specify two test regions of a
pair of representative panels. At one test region, the tester would
measure the U-
[[Page 55075]]
factor of the perimeter and panel-to-panel interface area (``Panel
Edge''), while at the other region the tester would measure the U-
factor of the core area of the panel (``Panel Core''). The details of
this procedure are described in section 4.1.1 of Appendix A.
DOE seeks comment on the use of ASTM C1363-05 for this portion of
the test procedure.
2. Use of ASTM C1303 or EN 13165:2009-02
In the January NOPR, DOE proposed using ASTM C1303-08, ``Standard
Test Method of Predicting Long Term Thermal Resistance of Closed-Cell
Foam Insulation,'' to determine the long-term R-value of foam
insulations used in walk-ins. 75 FR 194. (That test method has since
been updated to ASTM C1303-10, which, as discussed in section III.B.4,
DOE is now proposing to adopt as part of this test procedure. All
references to ASTM C1303 in today's notice refer to the ASTM C1303-10
version of the protocol.) As discussed later in section III.B.3, DOE
also proposes, in the alternative, the use of EN 13165:2009-02 (a
European-developed material standard), and seeks comment on the use of
these procedures.
DOE recognizes that R-value decline occurs over time in unfaced and
permeably faced foams. In the published January NOPR, DOE cited a body
of research indicating that R-value decline also occurs in foams with
impermeable facers because the metal skins delay, but do not prevent,
R-value decline because the panel edges are unprotected. DOE recognized
that using ASTM C1303-10 would require testing foams without their
metal facers because the test procedure was designed for unfaced or
permeably faced foams. In the published NOPR and at the NOPR public
meeting, DOE requested that interested parties submit data related to
using ASTM C1303-10 for walk-ins.
DOE received many comments related to ASTM C1303-10. Supporting
documents submitted during the comment period are listed in the table
below and identified with reference numbers. DOE conducted further
research and identified additional documents that provide information
on the use of ASTM C1303-10. These are also listed in the table below
with reference numbers preceded by ``DOE.''
Table III.1--Research Cited by Interested Parties and by DOE
----------------------------------------------------------------------------------------------------------------
Commenter Paper Citation Ref. No.
----------------------------------------------------------------------------------------------------------------
ACC/CPI.................................................... SPI Polyurethane Division k Factor 1
Task Force, ``Rigid Polyurethane
and Polyisocyanurate Foams: An
Assessment of Their Insulating
Properties,'' Proceedings of the
SPI 31st Annual Technical/
Marketing Conference, Oct. 18-21,
1988 Philadelphia, PA. pp. 323-327.
ACC/CPI, Carpenter, Honeywell.............................. Wilkes, K. E., Yarbrough, D.W., 2
Nelson, G. E., Booth, J. R.,
``Aging of Polyurethane Foam
Insulation in Simulated
Refrigerator Panels--Four-Year
Results with Third-Generation
Blowing Agents'', The Earth
Technologies Forum, Washington,
DC, April 22-24, 2003.
ACC/CPI, Honeywell......................................... Norton, F.J., ``Thermal 3
Conductivity and Life of Polymer
Foams'', Journal of Cellular
Plastics, 1967, pp. 23-37.
ACC/CPI, Honeywell......................................... Shankland, I. R. ``Blowing Agent 4
Emissions from Insulation Foam'',
Polyurethanes World Congress 1991
pp. 91-98.
Dow........................................................ Oertel, Dr. Gunter, Polyurethane 5
Handbook, p. 256.
Dow........................................................ Ottens et al., ``Industrial 6
Experiences with CO2 Blown.
Polyurethane Foams in the
Manufacture of Metal Faced
Sandwich Panels,'' Polyurethane
World.
Congress '97'......................
Dow........................................................ Bertucelli et al., ``Phase-Out of 7
Ozone Depleting Substances in the
Manufacture of Metal Faced
Sandwich Panels with Polyurethane
Foam Core,'' Utech Asia '99'.
Owens Corning.............................................. The Role of Barriers in Reducing 8
the Aging of Foam Panels by Leon
R. Glicksman.
Dow........................................................ European standard EN 13165......... 9
DOE........................................................ Wilkes, K. E., Yarbrough, D. W., DOE 1
Nelson, G. E., Booth, J. R.,
``Aging of Polyurethane Foam
Insulation in Simulated
Refrigerator Panels--Four-Year
Results with Third-Generation
Blowing Agents,'' The Earth
Technologies Forum Conference
Proceedings, 2003.
DOE........................................................ Paquet, A., Vo C., ``An Evaluation DOE 2
of the Thermal Conductivity of
Extruded Polystyrene Foam Blown
with HFC-134a and HCFC-142b,''
Journal of Cellular Plastics,
Volume 40, May 2004.
DOE........................................................ Federal Trade Commission, DOE 3
``Labeling and Advertising of Home
Insulation: Trade Regulation Rule;
Final Rule,16 CFR Part 460,''
Federal Register/Vol. 70, No. 103/
Tuesday, May 31, 2005.
DOE........................................................ Roe, Richard, ``Long-Term Thermal DOE 4
Resistance (LTTR): 5 Years Later''
RCI-057-Interface, March 2007.
DOE........................................................ Stovall, Therese, ``Measuring the DOE 5
Impact of Experimental Parameters
upon the Estimated Thermal
Conductivity of Closed-Cell Foam
Insulation Subjected to an
Accelerated Aging Protocol: Two-
Year Results, Journal of ASTM
International, Vol. 6, No. 5 Paper
ID JAI102025, April 2009.
DOE........................................................ Kalinger, P., and Drouin, M. (Johns DOE 6
Manville), ``Closed Cell Foam
Insulation: Resolving the issue of
thermal performance,'' October/
November 2001.
DOE........................................................ Mukhopadhyaya, P., Bomberg, M. T., DOE 7
Kumaran, M. K., Drouin, M.,
Lackey, J., van Reenen, D., and
Normandin, N., ``Long-Term Thermal
Resistance of Polyisocyanurate
Foam Insulation with Impermeable
Facers ,'' Insulation Materials:
Testing and Applications: 4th
Volume, ASTM STP 1426, A. O.
Desjarlais, Ed., American Society
for Testing and Materials, West
Conshohocken, PA, 2002.
[[Page 55076]]
DOE........................................................ Mukhopadhyaya, P., Bomberg, M. T., DOE 8
Kumaran, M. K., Drouin, M.,
Lackey, J., van Reenen, D., and
Normandin, N., ``Long-term Thermal
Resistance of Polyisocyanurate
Foam Insulation with Gas
Barrier,'' IX International
Conference on Performance of