Energy Conservation Program: Test Procedures for Certain Commercial and Industrial Equipment; Early Assessment Review: Walk-In Coolers and Freezers, 32332-32356 [2021-12081]
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Federal Register / Vol. 86, No. 115 / Thursday, June 17, 2021 / Proposed Rules
DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE–2017–BT–TP–0010]
RIN 1904–AD78
Energy Conservation Program: Test
Procedures for Certain Commercial
and Industrial Equipment; Early
Assessment Review: Walk-In Coolers
and Freezers
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Request for information.
AGENCY:
The U.S. Department of
Energy (‘‘DOE’’) is undertaking an early
assessment review to determine whether
amendments are warranted for the test
procedures for walk-in coolers and
walk-in freezers (‘‘WICFs’’ or ‘‘walkins’’). DOE has identified certain issues
associated with the currently applicable
test procedures on which DOE is
interested in receiving comment. The
issues outlined in this document
address definitions and equipment
classes of walk-in components, test
procedure waivers received, and other
test procedure issues related to walk-in
doors, panels, and refrigeration systems.
DOE welcomes written comments from
the public on any subject within the
scope of this document, including
topics not raised in this request for
information (‘‘RFI’’).
DATES: Written comments and
information are requested and will be
accepted on or before July 19, 2021.
ADDRESSES: Interested persons are
encouraged to submit comments using
the Federal eRulemaking Portal at
https://www.regulations.gov. Follow the
instructions for submitting comments.
Alternatively, interested persons may
submit comments by email to the
following address: WICF2017TP0010@
ee.doe.gov. Include docket number
EERE–2017–BT–TP–0010 and/or RIN
number 1904–AD78 in the subject line
of the message. Submit electronic
comments in WordPerfect, Microsoft
Word, PDF, or ASCII file format, and
avoid the use of special characters or
any form of encryption. No
telefacsimiles (faxes) will be accepted.
For detailed instructions on submitting
comments and additional information
on the rulemaking process, see section
III (Submission of Comments) of this
document.
Although DOE has routinely accepted
public comment submissions through a
variety of mechanisms, including postal
mail and hand delivery/courier, the
Department has found it necessary to
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SUMMARY:
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make temporary modifications to the
comment submission process in light of
the ongoing Covid–19 pandemic. DOE is
currently accepting only electronic
submissions at this time. If a commenter
finds that this change poses an undue
hardship, please contact Appliance
Standards Program staff at (202) 586–
1445 to discuss the need for alternative
arrangements. Once the Covid–19
pandemic health emergency is resolved,
DOE anticipates resuming all of its
regular options for public comment
submission, including postal mail and
hand delivery/courier.
Docket: The docket for this activity,
which includes Federal Register
notices, comments, and other
supporting documents/materials, is
available for review at https://
www.regulations.gov. All documents in
the docket are listed in the https://
www.regulations.gov index. However,
some documents listed in the index,
such as those containing information
that is exempt from public disclosure,
may not be publicly available.
The docket web page can be found at:
https://www.regulations.gov/#!docket
Detail;D=EERE-2017-BT-TP-0010. The
docket web page contains instructions
on how to access all documents,
including public comments, in the
docket. See section III of this document
for information on how to submit
comments through https://
www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Dr. Stephanie Johnson, U.S. Department
of Energy, Office of Energy Efficiency
and Renewable Energy, Building
Technologies Office, EE–5B, 1000
Independence Avenue SW,
Washington, DC 20585–0121.
Telephone: (202) 287–1943. Email:
ApplianceStandardsQuestions@
ee.doe.gov.
Mr. Michael Kido, U.S. Department of
Energy, Office of the General Counsel,
GC–33, 1000 Independence Avenue
SW, Washington, DC 20585–0121.
Telephone: (202) 586–8145. Email:
Michael.Kido@hq.doe.gov.
For further information on how to
submit a comment or review other
public comments and the docket,
contact the Appliance and Equipment
Standards Program staff at (202) 287–
1445 or by email:
ApplianceStandardsQuestions@
ee.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
A. Authority
B. Rulemaking History
II. Request for Information
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A. Scope and Definitions
1. Walk-In Refrigeration Systems
2.Walk-In Doors
B. Industry Test Standards
1. NFRC 100 and NFRC 102
2. ASTM C518
3. AHRI 1250
C. Test Procedure for Walk-In Doors
1. Surface Area Used for Determining
Compliance With Standards
2. Thermal Transmittance Area
3. Electrical Door Components
4. EER Values To Convert Thermal Load to
Energy Consumption
5. Thermal Transmittance
a. Calibration of Hot Box for Measuring
U-Factor
b. Tolerances of Surface Heat Transfer
Coefficients
6. Air Infiltration Reduction
D. Test Procedure for Walk-In Panels
1. Panel Thickness
2. Parallelism and Flatness
3. Specimen Conditioning
4. Overall Thermal Transmittance
5. Display Panels
E. Test Procedure for Walk-In Refrigeration
Systems
1. Single-Package Systems
a. Calorimeter Method
2. Wine Cellar Refrigeration Systems
3. CO2 Systems
4. Defrost Test Method
a. Moisture Addition
b. Hot Gas Defrost
c. Adaptive Defrost
5. Off-Cycle Energy Use
6. Multi-Capacity and Variable-Capacity
Condensing Units
7. Systems for High-Temperature Freezer
Applications
8. Consideration for Refrigerant Glide
III. Submission of Comments
IV. Issues on Which DOE Seeks Comment
I. Introduction
DOE established an early assessment
review process to conduct a more
focused analysis that would allow DOE
to determine, based on statutory criteria,
whether an amended test procedure is
warranted. 10 CFR 431.4; 10 CFR part
430 subpart C appendix A section 8(a).
This RFI requests information and data
regarding whether an amended test
procedure would more accurately and
fully comply with the requirement that
the test procedure produce results that
measure energy use during a
representative average use cycle for the
equipment, and not be unduly
burdensome to conduct. To inform
interested parties and to facilitate this
process, DOE has identified several
issues associated with the currently
applicable test procedures on which
DOE is interested in receiving comment.
Based on the information received in
response to the RFI and DOE’s own
analysis, DOE will determine whether to
proceed with a rulemaking for an
amended test procedure.
If DOE makes an initial determination
that an amended test procedure would
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more accurately or fully comply with
statutory requirements, or DOE’s
analysis is inconclusive as to whether
amendments are warranted, DOE would
undertake a rulemaking to issue an
amended test procedure. If DOE makes
an initial determination based upon
available evidence that an amended test
procedure would not meet the
applicable statutory criteria, DOE would
engage in notice and comment
rulemaking before issuing a final
determination that an amended test
procedure is not warranted.
and freezers, to determine whether
amended test procedures would more
accurately or fully comply with the
requirements for the test procedures to
not be unduly burdensome to conduct
and be reasonably designed to produce
test results that reflect energy efficiency,
energy use, and estimated operating
costs during a representative average
use cycle. (42 U.S.C. 6314(a)(1)) DOE is
publishing this RFI to collect data and
information to inform its decision to
satisfy the 7-year-lookback review
requirement.
A. Authority
The Energy Policy and Conservation
Act, as amended (‘‘EPCA’’),1 authorizes
DOE to regulate the energy efficiency of
a number of consumer products and
certain industrial equipment. (42 U.S.C.
6291–6317) Title III, Part C 2 of EPCA,
added by Public Law 95–619, Title IV,
section 441(a) (42 U.S.C. 6311–6317 as
codified), established the Energy
Conservation Program for Certain
Industrial Equipment, which sets forth a
variety of provisions designed to
improve energy efficiency. This
equipment includes walk-in coolers and
freezers (collectively, ‘‘walk-ins’’ or
‘‘WICFs’’), the subject of this document.
(42 U.S.C. 6311(1)(G))
Under EPCA, DOE’s energy
conservation program consists
essentially of four parts: (1) Testing, (2)
labeling, (3) Federal energy conservation
standards (‘‘ECS’’), and (4) certification
and enforcement procedures. Relevant
provisions of EPCA include definitions
(42 U.S.C. 6311), test procedures (42
U.S.C. 6314), labeling provisions (42
U.S.C. 6315), energy conservation
standards (42 U.S.C. 6313), and the
authority to require information and
reports from manufacturers (42 U.S.C.
6316).
Federal energy efficiency
requirements for covered equipment
established under EPCA generally
supersede State laws and regulations
concerning energy conservation testing,
labeling, and standards. (42 U.S.C.
6316(a) and (b); 42 U.S.C. 6297) DOE
may, however, grant waivers of Federal
preemption in limited instances for
particular State laws or regulations, in
accordance with the procedures and
other provisions set forth under 42
U.S.C. 6316(b)(2)(D).
EPCA also requires that, at least once
every 7 years, DOE evaluate test
procedures for each type of covered
equipment, including walk-in coolers
B. Rulemaking History
1 All references to EPCA in this document refer
to the statute as amended through the Energy Act
of 2020, Public Law 116–260 (Dec. 27, 2020).
2 For editorial reasons, upon codification in the
U.S. Code, Part C was redesignated Part A–1.
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DOE has established test procedures
to measure walk-in energy use,
establishing separate test procedures for
the principal components that make up
a walk-in (i.e., doors, panels, and
refrigeration systems) with separate test
metrics for each component. 10 CFR
431.304(b). For walk-in doors and
display panels, the efficiency metric is
daily energy consumption, measured in
kilowatt-hours per day (‘‘kWh/day’’),
which accounts for the thermal
conduction through the door or display
panel and the direct and indirect
electricity use of any electrical
components associated with the door.
10 CFR 431.304(b)(1)–(2) and 10 CFR
part 431, subpart R, appendix A,
‘‘Uniform Test Method for the
Measurement of Energy Consumption of
the Components of Envelopes of WalkIn Coolers and Walk-In Freezers’’
(‘‘Appendix A’’).
For walk-in non-display panels and
non-display doors, DOE codified in the
Code of Federal Regulations (‘‘CFR’’)
prescriptive standards established in
EPCA based on R-value, expressed in
units of (h-ft2-°F/Btu),3 which is
calculated as 1/K multiplied by the
thickness of the panel.4 10 CFR
431.304(b)(3) and 10 CFR part 431
subpart R, appendix B, titled ‘‘Uniform
Test Method for the Measurement of
R-Value for Envelope Components of
Walk-In Coolers and Walk-In Freezers’’
(‘‘Appendix B’’). (See also, 42 U.S.C.
6314(a)(9)(A)) The K factor is calculated
based on American Society for Testing
and Materials (‘‘ASTM’’) C518,
‘‘Standard Test Method for Steady-State
Thermal Transmission Properties by
Means of the Heat Flow Meter
Apparatus’’ (‘‘ASTM C518’’), which is
incorporated by reference. Id.
3 The R-value is the capacity of an insulated
material to resist heat-flow. See 42 U.S.C.
6313(f)(1)(C) for the EPCA R-value requirements for
non-display panels and doors.
4 The K factor represents the thermal conductivity
of a material, or its ability to conduct heat, in units
of Btu-in/(h-ft2-°F).
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For walk-in refrigeration systems, the
efficiency metric is Annual Walk-in
Energy Factor (‘‘AWEF’’), which is
determined by conducting the test
procedure set forth in American
National Standards Institute (‘‘ANSI’’)/
Air-Conditioning, Heating, and
Refrigeration Institute (‘‘AHRI’’)
Standard 1250P (I–P), ‘‘2009 Standard
for Performance Rating of Walk-In
Coolers and Freezers,’’ (‘‘AHRI 1250–
2009’’), with certain adjustments
specified in the CFR. 10 CFR
431.304(b)(4) and 10 CFR part 431
subpart R, appendix C, ‘‘Uniform Test
Method for the Measurement of Net
Capacity and AWEF of Walk-In Cooler
and Walk-In Freezer Refrigeration
Systems’’ (‘‘Appendix C’’). A
manufacturer may also determine
AWEF using an alternative efficiency
determination method (‘‘AEDM’’). 10
CFR 429.53(a)(2)(iii). An AEDM enables
a manufacturer to utilize computerbased or mathematical models for
purposes of determining an equipment’s
energy use or energy efficiency
performance in lieu of testing, provided
certain prerequisites have been met. 10
CFR 429.70(f).
On August 5, 2015, DOE published its
intention to establish a Working Group
under the Appliance Standards and
Rulemaking Federal Advisory
Committee (‘‘ASRAC’’) to negotiate
energy conservation standards to
replace the standards established in the
final rule published on June 3, 2014
(‘‘June 2014 ECS final rule’’). 80 FR
46521 (August 5, 2015). The Working
Group assembled its recommendations
into a Term Sheet 5 (Docket EERE–2015–
BT–STD–0016, No. 56) that was
presented to, and approved by, ASRAC
on December 18, 2015 (‘‘Term Sheet’’).
The Term Sheet provided
recommendations for energy
conservation standards to replace
standards that had been vacated by the
United States Court of Appeals for the
Fifth Circuit in a controlling order
issued August 10, 2015. It also included
recommendations regarding definitions
for a number of terms related to the
WICF regulations, as well as
recommendations to amend the test
procedure that the Working Group
viewed as necessary to properly
implement the energy conservation
standards recommendations.
Consequently, DOE initiated both an
energy conservation standards
rulemaking and a test procedure
rulemaking in 2016 to implement these
5 Appliance Standards and Rulemaking Federal
Advisory Committee Refrigeration Systems Walk-in
Coolers and Freezers Term Sheet, available at
https://www.regulations.gov/document?D=EERE2015-BT-STD-0016-0056.
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recommendations. The Term Sheet also
included recommendations for future
amendments to the test procedure
intended to make DOE’s test procedure
more fully representative of walk-in
energy use.
On December 28, 2016, DOE
published a final rule amending the test
procedure (‘‘December 2016 TP final
rule’’), consistent with the Term Sheet
recommendations and provisions to
facilitate implementation of energy
conservation standards for walk-in
components. 81 FR 95758.
Subsequently, on July 10, 2017, DOE
published a final rule amending the
energy conservation standards for WICF
refrigeration systems (‘‘July 2017 ECS
final rule’’). 82 FR 31808.
To address Term Sheet
recommendations regarding hot gas
defrost, DOE published a final rule for
hot gas defrost unit coolers on March
26, 2021 (‘‘March 2021 hot gas defrost
TP final rule’’) that amended the test
procedure to rate hot gas defrost unit
coolers using modified default values
for energy use and heat load
contributions that would make their
ratings more consistent with those of
electric defrost unit coolers. 86 FR
16027.
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II. Request for Information
DOE is publishing this RFI to collect
data and information during the early
assessment review to inform its
decision, consistent with its obligations
under EPCA, as to whether the
Department should proceed with an
amended test procedure rulemaking and
if so, to assist in the development of
proposed amendments. Accordingly, in
the following sections, DOE has
identified specific issues on which it
seeks input to aid in its analysis of
whether an amended test procedure for
walk-in coolers and freezers would
more accurately or fully comply with
the requirement that the test procedure
produces results that measure energy
use during a representative average use
cycle for the equipment, and not be
unduly burdensome to conduct. DOE
also welcomes comments on other
issues relevant to its early assessment
that may not specifically be identified in
this document.
A. Scope and Definitions
This RFI covers equipment meeting
the ‘‘walk-in cooler and walk-in freezer’’
definition codified in 10 CFR 431.302:
An enclosed storage space refrigerated
to temperatures (1) above 32 °F for walkin coolers and (2) at or below 32 °F for
walk-in freezers, that can be walked
into, and has a total chilled storage area
of less than 3,000 square feet, but
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excluding equipment designed and
marketed exclusively for medical,
scientific, or research purposes. 10 CFR
431.302. (See also 42 U.S.C. 6311(20)) In
addition to the prescriptive
requirements for walk-ins established by
EPCA (42 U.S.C. 6313(f)(3)(A)–(D)) and
codified at 10 CFR 431.306(a)–(b), DOE
established performance-based energy
conservation standards for doors and
refrigeration systems. 10 CFR
431.306(c)–(e).
1. Walk-In Refrigeration Systems
DOE is aware of equipment that
would appear to meet the walk-in
definition and for which there is no
current DOE test procedure or energy
conservation standard. DOE indicated in
a public meeting on October 22, 2014
that the WICF test procedures and
standards did not apply to water-cooled
condensing units or systems. (Docket
EERE–2011–BT–TP–0024, No. 109 6 at
p. 11) DOE notes that the EPCA
definition for walk-ins makes no
distinction on how the condenser is
cooled. (42 U.S.C. 6311(20)(A))
The current DOE test procedure for
walk-in refrigeration systems, which
incorporates by reference AHRI 1250–
2009, does not address how to test
liquid-cooled systems. Additionally,
liquid-cooled condensing units are
outside the scope of the most recent
version of AHRI 1250, AHRI 1250–2020.
Liquid-cooled condensing units for
walk-ins are readily available for a wide
range of capacities and refrigerants from
major walk-in refrigeration system
manufacturers. (See for example,
Airdyne W-series indoor units (watercooled), and Russell (water-cooled,
glycol-cooled) (see Docket No. EERE–
2017–BT–TP–0010–0001, Docket No.
EERE–2017–BT–TP0010–0002, and
Docket No. EERE–2017–BT–TP–0010–
0003).
Issue 1: DOE seeks comment on how
liquid-cooled refrigeration systems are
(or could be) used with respect to walkin applications. DOE requests comment
on whether it should consider
establishing a test procedure for liquidcooled refrigeration systems. If test
procedures were considered for liquidcooled refrigeration systems, DOE
requests information on whether there is
an industry standard or standards that
should be considered.
DOE is considering modifying the
current equipment class definitions for
refrigeration systems, which are based
on walk-in application temperature. In
6 Details of Executing the Test Procedures for
Refrigeration Systems use in Walk-in Coolers and
Freezers, available at https://www.regulations.gov/
document?D=EERE-2011-BT-TP-0024-0109.
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the June 2014 ECS final rule, DOE
established equipment classes for
medium- and low- temperature walk-in
refrigeration systems. 79 FR 32050,
32069–32070. While the terms
‘‘medium-temperature’’ and ‘‘lowtemperature’’ are not explicitly defined,
the June 2014 ECS final rule, 2015
ASRAC negotiations, December 2016 TP
final rule, and July 2017 ECS final rule
all consistently used the term ‘‘mediumtemperature’’ to refer to walk-in cooler
refrigeration systems and the term ‘‘lowtemperature’’ to refer to walk-in freezer
refrigeration systems.
Rating conditions are 35 °F for cooler
systems and ¥10 °F for freezer systems.
DOE acknowledges that there are
‘‘medium-temperature’’ systems
designed to operate between these two
rating conditions, specifically between
10 °F and 32 °F. However, the EPCA
definitions for walk-in freezers and
walk-in coolers draws the line between
them at 32 °F, thus classifying such
refrigeration systems as freezer
refrigeration systems. DOE is
considering whether equipment
definitions and requirements should be
amended to address these systems,
which are discussed in detail in Section
II.E.7.
Finally, DOE is considering defining
walk-in wine cellar refrigeration
systems. These systems are typically
designed to provide a cold environment
at a temperature range between 45–65 °F
with 50–70 percent relative humidity
(‘‘RH’’), and typically are kept at 55 °F
and 55 percent RH rather than the 35 °F
and less than 50 percent RH test
condition prescribed by the DOE test
procedure. Operating a wine cellar at
the 35 °F condition would adversely
mechanically alter the intended
performance of the system, which
would include icing of the evaporator
coil that could potentially damage the
compressor, and would not result in an
accurate representation of the
performance of the cooling unit. To
distinguish walk-in wine-cellar
refrigeration systems from other walk-in
cooler systems, DOE is considering
whether to specify 45 °F as the
minimum temperature at which a walkin wine cellar refrigeration system can
effectively operate. If DOE were to
specify a minimum operating
temperature, DOE would need to
develop a definition specific for
products that operate in this
temperature region. Walk-in wine cellar
refrigeration systems are discussed in
more detail in Section II.E.2.
Issue 2: DOE seeks comment on how
wine cellar refrigeration systems should
be defined to best represent the
conditions under which these systems
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are designed to operate and to fully
distinguish these systems from systems
designed to meet safe food storage
requirements. Additionally, DOE
requests comment on applications other
than wine cellar storage for refrigeration
systems that are designed to operate at
temperatures warmer than typical for
coolers and for which testing at 35 °F
would be representative of use. If there
are such additional applications, DOE
seeks information regarding the specific
operating requirements (i.e.,
temperature and humidity) for these
systems.
2. Walk-In Doors
DOE is also reviewing the definitions
applicable to WICF doors. DOE defines
a ‘‘door’’ as an assembly installed in an
opening on an interior or exterior wall
that is used to allow access or close off
the opening and that is movable in a
sliding, pivoting, hinged, or revolving
manner of movement. For walk-in
coolers and walk-in freezers, a door
includes the door panel, glass, framing
materials, door plug, mullion, and any
other elements that form the door or
part of its connection to the wall. 10
CFR 431.302. DOE is interested in using
language that is consistent across the
walk-in door industry to define a door.
Issue 3: DOE requests comment on the
current definition of ‘‘door’’ in 10 CFR
431.302. DOE seeks feedback on the
terminology of door components used
and whether these are consistently
interpreted. DOE seeks specific feedback
from manufacturers on how they use the
term ‘‘door plug’’ and whether it is
essential to the definition of a WICF
‘‘door’’.
DOE differentiates WICF doors by
whether such doors are ‘‘display doors’’
or not display doors. A ‘‘display door’’
is defined as a door that: (1) Is designed
for product display; or (2) has 75
percent or more of its surface area
composed of glass or another
transparent material. 10 CFR 431.302.
WICF doors that are not display doors
are differentiated according to whether
they are ‘‘freight doors’’ or ‘‘passage
doors.’’ A ‘‘freight door’’ is a door that
is not a display door and is equal to or
larger than 4 feet wide and 8 feet tall.
Id. A ‘‘passage door’’ is a door that is not
a freight or display door. Id.
The use of dimensions in the
definition of freight door conveys that
these doors are intended for large
machines (e.g., forklifts) to pass through
carrying freight. However, the definition
does not explicitly provide whether
classification as a freight door occurs
when one of the dimensions exceeds the
dimension provided in the definition,
but the other dimension is smaller than
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the dimension provided in the
definition. For such doors, in some
cases the surface area could be larger
than 32 square feet, the area of a 4-foot
by 8-foot door provided in the definition
(e.g., a door 5 feet wide and 7 feet tall,
with a surface area of 35 square feet); in
other cases, the surface area could be
smaller than 32 square feet (e.g., a door
5 feet wide and 6 feet tall, with a surface
area of 30 square feet). DOE reviewed
the surface area of certified freight and
passage doors in DOE’s Compliance
Certification Management System
(‘‘CCMS’’) Database.7 Among 1,114
unique individual models 8 of freight
doors, 44 unique individual models
have a surface area less than 32 square
feet. These models appear to have been
classified on the understanding that a
door is a freight door if just one
dimension is larger than the dimensions
specified in the freight door definition.
Among 1,540 unique individual models
of passage doors, 789 unique individual
models have a surface area greater than
or equal to 32 square feet.9 These
models either are multi-door
configurations, or they have been
classified assuming that to be a freight
door, both dimensions must be equal to
or exceed the dimensions in the freight
door definition. DOE further notes that
the standards for each class of WICF
doors are a function of surface area, and
that different standards apply for freight
doors and passage doors. DOE seeks
information that would inform any
potential revision of the door
definitions, particularly ‘‘freight door’’
and ‘‘passage door,’’ to improve their
clarity and ensure that there is no
overlap between these definitions.
Issue 4: DOE requests comment on
whether height and width or surface
area are distinct attributes that
effectively distinguish between passage
and freight doors. DOE seeks
information on any building codes,
standards, or industry practices to
support or refute maintaining the
dimensions of a door as the defining
characteristic which separates freight
and passage doors.
Issue 5: Regarding a door that meets
the freight door definition but does so
only because it has a multi-door
configuration in which the individual
component doors each would by
7 Data from the DOE CCMS database was accessed
on March 6, 2020. This database can be found at
https://www.regulations.doe.gov/certification-data/.
8 Unique individual models exclude any
duplicate entries using the same individual model
number.
9 DOE understands that some certified passage
doors may represent multi-door configurations in
which the individual component doors each have
a surface area of less than 32 square feet.
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themselves not meet the freight door
definition, DOE seeks comment on how
such doors should be classified, and
whether such classification should
depend on other factors, such as
whether one or more frame members
divides the door opening into smaller
openings.
Issue 6: DOE seeks comment on
whether any attribute, or combination of
attributes, other than size, would affect
energy use and could be used to
distinguish between freight doors and
passage doors. If so, DOE requests data
and comment on such attributes.
B. Industry Test Standards
The current DOE test procedure for
walk-in coolers and freezers
incorporates the following industry test
standards: NFRC 100 10 into Appendix
A; ASTM C518–04 11 into Appendix B;
and AHRI 1250–2009 12, AHRI 420–
2008 13 and ASHRAE 23.1–2010 14 into
Appendix C.
1. NFRC 100 and NFRC 102
Appendix A requires manufacturers
to determine door thermal transmittance
according to NFRC 100. See Appendix
A, Section 5.3. NFRC 100 includes a
computational method to determine the
thermal transmittance for a product line
of doors if simulated results meet the
validation requirements specified in
NFRC 100. This approach may be less
costly but generally may result in a
higher, more conservative thermal
transmittance value than the thermal
transmittance value determined by
testing each door. Section 4.3.2 of NFRC
100 provides a method for physically
testing the thermal transmittance of
walk-in doors by referencing NFRC 102,
‘‘Procedure for Measuring the SteadyState Thermal Transmittance of
Fenestration Systems’’ (‘‘NFRC 102’’).
DOE is considering explicitly
incorporating by reference NFRC 102 as
10 National Fenestration Rating Council (‘‘NFRC’’)
100–2010, ‘‘Procedure for Determining Fenestration
U-factors’’ (‘‘NFRC 100’’).
11 American Society for Testing and Materials
(‘‘ASTM’’) C518–04, ‘‘Standard Test Method for
Steady-State Thermal Transmission Properties by
Means of the Heat Flow Meter Apparatus’’ (‘‘ASTM
C518–04’’).
12 American National Standards Institute
(‘‘ANSI’’)/Air-Conditioning, Heating, and
Refrigeration Institute (‘‘AHRI’’) Standard 1250P
(I–P), ‘‘2009 Standard for Performance Rating of
Walk-In Coolers and Freezers’’ (‘‘AHRI 1250–
2009’’).
13 AHRI 420–2008, ‘‘Performance Rating of
Forced-Circulation Free-Delivery Unit Coolers for
Refrigeration’’ (‘‘AHRI 420–2008’’).
14 ANSI/ASHRAE 23.1–2010, ‘‘Methods of
Testing for Rating the Performance of Positive
Displacement Refrigerant Compressors and
Condensing Units that Operate at Subcritical
Temperatures of the Refrigerant’’ (‘‘ASHRAE 23.1–
2010’’).
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the test method for determining the
thermal transmittance of walk-in doors
in place of NFRC 100 and adopting
AEDM provisions for walk-in display
and non-display doors to replace the
computational methodology in NFRC
100.
Issue 7: DOE requests comment on the
accuracy of the computational method
in NFRC 100 to predict
U-factor for display and non-display
doors. DOE seeks feedback regarding the
differences in results (if any) between
those obtained using the NFRC 100
computational method and those
obtained when conducting physical
testing using NFRC 102 for display and
non-display doors. DOE is also
interested in the magnitude of these
differences and whether the
computational method can be modified
to yield results that more closely match
the results obtained from actual
physical testing. If manufacturers are
aware of other methods to predict
U-factor for either display doors or nondisplay doors besides NFRC 100, DOE
requests how the results from these
methods compare to physical testing.
Issue 8: DOE seeks information from
manufacturers and other interested
parties regarding how the industry
currently rates individual door models,
including the prevalence within the
industry of using the computational
method from NFRC 100. DOE also
requests information on the costs
associated with the computational
method of NFRC 100 or an alternative
computational method compared to
physically testing the thermal
transmittance of walk-in doors using
NFRC 102.
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2. ASTM C518
Currently, section 4.2 of Appendix B
references ASTM C518 to determine the
thermal conductivity of panel insulation
(the ‘‘K factor’’). EPCA requires that the
measurement of the K factor used to
calculate the R-value ‘‘be based on
ASTM test procedure C518–2004.’’ (42
U.S.C. 6314(a)(9)(A)(ii)) In December
2015, ASTM published a revision of this
standard (‘‘ASTM C518–15’’). ASTM
C518–15 removed references to ASTM
Standard C1363, ‘‘Test Method for
Thermal Performance of Building
Materials and Envelope Assemblies by
Means of a Hot Box Apparatus’’
(‘‘ASTM C1363’’), and added references
to ASTM Standard E456, ‘‘Terminology
Relating to Quality and Statistics’’.
Additionally, ASTM C518–15 relies
solely on the International System of
Units (‘‘SI units’’), with paragraph 1.13
clarifying that these SI unit values are
to be regarded as standard.
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In July 2017, ASTM published
another revision of ASTM C518
(‘‘ASTM C518–17’’). ASTM C518–17
added a summary of precision statistics
from an interlaboratory study from
2002–2004 in section 10 ‘‘Precision and
Bias’’. DOE has initially determined that
the changes made in 2015 and 2017 to
ASTM C518 do not substantively
change the test method and, therefore,
DOE is considering specifying ASTM
C518–17 as the referenced test
procedure in Appendix B. If DOE makes
this change as part of a test procedure
rulemaking, it would also consider any
changes necessary to ensure rounding
consistency when converting the output
of ASTM C518–17 from SI units to
English units.
Issue 9: DOE requests comment on
what issues, if any, would be present if
ASTM C518–17 were to be referenced in
the Appendix B test procedure for
measuring panel K-factor, or average
thermal conductivity. While not
exhaustive, primary areas of interest to
DOE include any differences between
the currently referenced version of the
industry standard (ASTM C518–04) and
ASTM C518–17 that would result in a
difference in the determined R-value
and/or test burden (whether an increase
or decrease), and if there are such
differences, the magnitude of impact to
the determined R-value and/or test
burden.
3. AHRI 1250
The current DOE test procedures for
walk-in refrigeration systems
incorporate by reference AHRI 1250–
2009. 10 CFR 431.303(b)(2). AHRI 1250–
2009 provides test methods for
determination of performance for
matched pair refrigeration systems
consisting of a unit cooler and a
condensing unit, or for the individual
unit cooler or condensing unit alone.15
In 2014, AHRI published a revision to
this standard (‘‘AHRI 1250–2014’’).
AHRI 1250–2014 primarily aligned the
test standard for consistency with the
DOE test procedure, e.g. specifying that
unit coolers be tested using 25 °F
saturated suction temperature for
refrigerator unit coolers and ¥20 °F for
freezer unit coolers.
AHRI again published a revision to
the standard in April 2020 (‘‘AHRI
1250–2020’’). AHRI 1250–2020 includes
many updates, including (a) providing
complete instructions for testing of unit
coolers alone instead of incorporating
15 A split-system refrigeration system consists of
two separate components: A unit cooler that is
installed inside a walk-in enclosure, and a
condensing unit, which is installed outside the
enclosure, either inside a building in which the
walk-in is constructed, or outdoors.
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by reference AHRI 420, (b) providing
complete instructions for testing of
condensing units alone instead of
incorporating by reference ASHRAE
23.1–2010, (c) revision of instrument
accuracy and test tolerances, (d) adding
test methods for testing of singlepackage systems, (e) modified
correlations for default evaporator fan
power, defrost thermal load, and defrost
energy use for use when testing
condensing units alone, (f) correlations
for defrost thermal load and energy use
for use when testing hot gas defrost
systems, (g) measurement of all relevant
off-cycle energy use, including
compressor crankcase heater energy use,
and (h) methods to verify whether a
refrigeration system has hot gas defrost
and/or adaptive defrost capabilities.
DOE may consider incorporating by
reference AHRI 1250–2020 as the test
method for walk-in refrigeration
systems.
Issue 10: DOE requests comment on
what issues, if any, would be present if
AHRI 1250–2020 were to be referenced
in the Appendix C test procedure for
measuring walk-in refrigeration system
AWEF. While not exhaustive, primary
areas of interest to DOE include any
differences between the currently
referenced version of the industry
standard (AHRI 1250–2009) and AHRI
1250–2020 that would result in a
difference in the determined AWEF
and/or test burden (whether an increase
or decrease), and if there are such
differences, the magnitude of impact to
the determined AWEF and/or test
burden.
C. Test Procedure for Walk-In Doors
In the following subsections, DOE
discusses several topics specific to
walk-in doors that may affect the test
procedure’s ability to provide results
that are more fully representative of
walk-in door energy use during an
average use cycle. In particular, the
discussion focuses on: (a) The
distinction between the surface area
used for determining maximum energy
consumption and the surface area used
to calculate thermal transmittance; (b)
walk-in door electrical components,
such as motors, that may require
specific consideration in the test
procedure; (c) assumptions of
refrigeration system energy efficiency
ratio (‘‘EER’’) for calculating energy use
associated with the thermal loads of
walk-in doors; (d) calibrations of the hot
box used for determining thermal
transmittance (also referred to as ‘‘Ufactor’’); (e) maintaining tolerances on
heat transfer coefficients for U-factor
tests; and (f) measuring and accounting
for air infiltration.
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1. Surface Area Used for Determining
Compliance With Standards
The surface area of display doors and
non-display doors (designated as Add
and And, respectively) are used to
determine maximum energy
consumption in kWh/day of a walk-in
door. 10 CFR 431.306(c)–(d). Surface
area is defined in Appendix A as ‘‘the
area of the surface of the walk-in
component that would be external to the
walk-in cooler or walk-in freezer as
appropriate.’’ Appendix A, Section 3.4.
DOE recognizes that this definition may
benefit from additional detail. As
currently written, the definition does
not provide detail on how to determine
the boundaries of the walk-in door from
which height and width are determined
to calculate surface area. Additionally,
the definition does not specify if these
measurements are to be strictly in-plane
with the surface of the wall or panel that
the walk-in door would be affixed to, or
if troughs and other design features on
the exterior surface of the walk-in door
should be included in the surface area.
Inconsistent determination of surface
area, specifically with respect to the
measurement boundaries, may result in
unrepresentative maximum energy
consumption. Display doors are
fundamentally different from nondisplay doors in terms of their overall
construction. For example, display door
assemblies contain a larger frame
encompassing multiple door openings;
the entire assembly fits into an opening
within a walk-in wall. Non-display
doors differ in that they often are affixed
to a panel-like structure that more
closely resembles a walk-in wall rather
than a traditional door frame. For the
purposes of determining compliance
with the standards, DOE interprets the
surface area as the product of the height
and width measurements of the door
made external to the walk-in, where the
height and width measurements are the
maximum edge-to-edge dimensions of
the door measured perpendicular to
each other and parallel to the wall or
panel of the walk-in to which the door
is affixed. In applying this approach,
DOE views the height and width
measurements of display doors to
include the frame and frame flange that
overlaps the external edge of the WICF
panel. For non-display doors, DOE
views the height and width
measurements to include only the
swinging or sliding portion of the door
and not the door frame or any localized
appendages such as hinges or hanging
rails and brackets. DOE seeks feedback
on its interpretation of surface area for
both display and non-display doors.
DOE is also interested in feedback on
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whether additional detail is needed
regarding the surface area for both nondisplay doors and display doors, and if
so, what further detail should be
provided.
Issue 11: DOE requests comment on
how manufacturers determine surface
area for the purpose of evaluating
compliance with the standards for both
display doors and non-display doors.
DOE seeks input on any distinction
between display doors and non-display
doors, especially the door frames, which
may warrant surface area for each to be
determined differently.
Additionally, walk-in doors with
antisweat heaters are subject to
prescriptive standards for power use of
antisweat heaters per square foot of door
opening. 10 CFR 431.306(b)(3)–(4).
Although ‘‘door opening’’ is not
defined, DOE considers the relevant
area for determining ‘‘power use per
square foot of door opening’’ to be
consistent with the surface area used to
determine maximum energy
consumption.
Issue 12: DOE seeks feedback on how
manufacturers interpret and measure
door opening as it relates to prescriptive
standards for antisweat heaters,
including whether or not manufacturers
agree that the door opening considered
for antisweat heat should be consistent
with the surface area used to determine
maximum energy consumption.
2. Thermal Transmittance Area
Currently, equations 4–19 and 4–28 of
Appendix A specify that surface area, as
defined in section 3.4 of Appendix A, of
display doors and non-display doors,
respectively, are used to convert a
door’s U-factor into a conduction load.
This conduction load represents the
amount of heat that transfers from the
exterior to the interior of the walk-in.
Based on recent review of the test
procedure, DOE has identified that this
defined surface area is inconsistent with
the referenced industry test procedures
for determining U-factor.
As stated previously, Appendix A
references NFRC 100 for the
determination of U-factor. When
conducting physical testing,16 U-factor
(Us) is calculated using projected surface
area (As). ASTM C1199–09, Section
8.1.3. As is defined as ‘‘the projected
area of test specimen (same as test
specimen aperture in surround panel)’’.
16 As mentioned previously, NFRC 100 references
NFRC 102 for determining U-factor through
physical testing. NFRC 102 is based on American
Society for Testing and Materials (‘‘ASTM’’) C1199–
09, ‘‘Standard Test Method for Measuring the
Steady-State Thermal Transmittance of Fenestration
Systems Using Hot Box Methods’’ (‘‘ASTM C1199–
09’’) with some modifications.
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ASTM C1199–09, Section 3.3. This area
differs from the currently defined areas
(Add and And) in Appendix A. See
Appendix A, Section 3.4. DOE is
considering whether the surface area
used in calculating the conduction load
in Equations 4–19 and 4–28 of
Appendix A should be the same surface
area used to determine Us to provide
greater consistency with the NFRC 100
definition of U-factor: ‘‘The U-factor
multiplied by the interior-exterior
temperature difference and by the
projected fenestration product area
yields the total heat transfer through the
fenestration product.’’
Issue 13: DOE requests feedback on
specifying the surface area used to
determine thermal conduction through a
walk-in door from the surface area used
to determine the maximum energy
consumption of a walk-in door.
3. Electrical Door Components
Sections 4.4.2 and 4.5.2 of Appendix
A include provisions for calculating the
direct energy consumption of electrical
components of display doors and nondisplay doors, respectively. For
example, electrical components
associated with doors could include, but
are not limited to: Heater wire (for antisweat or anti-freeze application); lights
(including display door lighting
systems); control system units; and
sensors. See Appendix A, Sections 4.4.2
and 4.5.2. For each electricityconsuming component, the calculation
of energy consumption is based on the
component’s ‘‘rated power’’ rather than
an actual measurement of its power
draw. Section 3.5 of Appendix A
defines ‘‘rated power’’ as the electricity
consuming device’s power as specified
on the device’s nameplate, or from the
device’s product data sheet if the device
does not have a nameplate or such
nameplate does not list the device’s
power.
DOE has observed that walk-in doors
often provide a single nameplate for the
door, rather than providing individual
nameplates for each electricityconsuming device. In many cases, the
nameplate does not provide separate
power information for the different
electrical components. Also, the
nameplate often specifies voltage and
amperage (a measure of current) ratings
without providing wattage (a measure of
power) ratings, as is referenced by the
definition of ‘‘rated power’’. While the
wattage is equal to voltage multiplied by
the current for many components, this
may not be true of all components that
may be part of a walk-in door assembly.
Furthermore, nameplate labels typically
do not specify whether any listed values
of rated power or amperage represent
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the maximum operation conditions or
continuous steady-state operating
conditions, which could differ for
components such as motors that
experience an initial surge in power
before leveling off at a lower power
level. These issues make calculating a
door’s total energy consumption
challenging when a test facility does not
have in-depth knowledge of the
electrical characteristics of the door
components.
DOE is considering whether there
may be value in adding an option for
direct measurement of door component
electrical power, either as part of the
test procedure for manufacturers
wishing to make direct measurements,
or for DOE testing, as an alternative to
using the nameplate value. DOE seeks
comment on issues that should be
considered were DOE to develop
requirements for such measurements,
such as any additional instrumentation
or test conditions that would be
required.
Issue 14: DOE seeks comment on
whether, and if so how, an option for
direct component power measurement
could be included in the test procedure
or compliance, certification, and
enforcement (‘‘CCE’’) provisions to
allow more accurate accounting for the
direct electrical energy consumption of
WICF doors. DOE also seeks input on
whether specific provisions should be
provided for determining power input
from the information that is typically
provided on nameplates, noting the
limitations that were described above.
As stated previously, Appendix A
accounts for the energy consumption of
various electrical components,
including lights, sensors, anti-sweat
heater wire, and other miscellaneous
electrical devices. The test procedure
assigns percent time off (‘‘PTO’’) values
to various walk-in door components.17
Table II.1 lists the PTO values in the
DOE test procedure for walk-in doors.
This method provides a means to
compare walk-in door performance
while limiting the test burden on
manufacturers.
TABLE II.1—ASSIGNED PTO VALUES FOR WALK-IN DOOR COMPONENTS
Percent time
off
(PTO) %
Component type
Lights without timers, control system or other demand-based control ...............................................................................................
Lights with timers, control system or other demand-based control ....................................................................................................
Anti-sweat heaters without timers, control system or other demand-based control ...........................................................................
Anti-sweat heaters on walk-in cooler doors with timers, control system or other demand-based control .........................................
Anti-sweat heaters on walk-in freezer doors with timers, control system or other demand-based control ........................................
All other electricity consuming devices without timers, control systems, or other auto-shut-off systems ..........................................
All other electricity consuming devices for which it can be demonstrated that the device is controlled by a preinstalled timer,
control system or other auto- shut-off system .................................................................................................................................
DOE has received several petitions for
waivers and interim waivers with regard
to the PTO used for doors with
motorized door openers.18 These
manufacturers stated that the test
procedure for walk-in doors overstates
the energy consumption of motorized
doors because the applicable PTO value
prescribed in the test procedure is not
representative of the actual energy use
of the motorized doors used in these
applications. Under the current test
procedure, motorized door openers
would be considered ‘‘other electricityconsuming devices,’’ with PTO values
of either 0 percent or 25 percent. See
Appendix A, Sections 4.4.2(a)(3) and
4.5.2(a)(3). Based on the characteristics
of its doors, each manufacturer
requested a different PTO value (shown
25
50
0
75
50
0
25
in Table II.2) to be applied to its basic
models. After reviewing the
performance data, equipment
characteristics, and door-opening
frequency assumptions presented by
door manufacturers, and after soliciting
and reviewing feedback from the public,
DOE granted waivers to the
manufacturers shown in Table II.2.
TABLE II.2—PTO VALUES GRANTED IN DECISION AND ORDERS FOR MANUFACTURERS OF DOORS WITH MOTORIZED
DOOR OPENERS
Percent time
off
(PTO) %
Manufacturer
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HH Technologies ............................................................................................................................
Jamison Door Company .................................................................................................................
Senneca Holdings ..........................................................................................................................
Hercules .........................................................................................................................................
96
93.5
97
92
Decision and order Federal
Register citation
83
83
86
86
FR
FR
FR
FR
53457. (Oct. 23, 2018).
53460. (Oct. 23, 2018).
75. (Jan. 4, 2021).
17801. (Apr. 6, 2021).
DOE is reviewing the test procedure’s
current PTO values and is interested in
establishing standard PTO values for
motorized door openers as well as any
other electricity-consuming devices that
would warrant PTOs different from
those currently in Appendix A, also
listed in Table II.1 of this document.
DOE seeks information regarding how
closely these values represent actual
PTO values experienced in the field. In
addition to motorized door openers,
17 PTO values are applied in order to reflect the
hours in a day that an electricity-consuming device
operates at its full rated or certified power (i.e.,
daily component energy use is calculated assuming
that the component operates at it rated power for
a number of hours equal to 24 multiplied by (1–
PTO)). PTO should not be incorporated into the
rated or certified power of an electricity-consuming
device.
18 By letters dated July 26, 2017, December 21,
2017, March 13, 2020, and June 5, 2020, Jamison
Door Company, HH Technologies, Senneca
Holdings, and Hercules, respectively, submitted
petitions for waivers and interim waivers for basic
models of motorized walk-in doors, requesting the
use of alternate PTO values. (Jamison, EERE–2017–
BT–WAV–0040, No. 2 at p. 2; HH Technologies,
EERE–2018–BT–WAV–0001, No. 1 at p. 2; Senneca
Holdings, EERE–2020–BT–WAV–0009, No. 3 at p.
3; Hercules, EERE–2020–BT–WAV–0027, No. 2 at p.
3).
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DOE is also investigating whether any
additional walk-in door electrical
components, such as heated air vents
and heated thresholds, would warrant
the use of specific PTO values when
calculating door energy use.
Issue 15: DOE requests comment on
the current PTO values and whether
DOE should consider amending any of
the current values or adding specific
values for additional electrical
components, specifically motorized
door openers. DOE requests data from
field studies or similar sources to
support any proposed amendments (or
additions) to these PTO values.
DOE is aware that some
manufacturers design and market walkin cooler display doors for high
humidity applications. Ratings from the
CCMS database 19 show these doors
have more anti-sweat heater power per
door opening area than standard cooler
display doors. The average power use
per door opening area for high humidity
cooler doors is 1.66 W/ft2, while the
average power use for cooler doors not
marketed for high humidity applications
made by the same manufacturers who
produce the high humidity doors is 1.01
W/ft2. Section 4.4.2(a)(2) of Appendix A
requires a PTO value of 50 percent be
used when determining the direct
energy consumption for anti-sweat
heaters with timers, control systems, or
other demand-based controls situated
within a walk-in cooler door (which
would include walk-in cooler doors
marketed for high humidity
applications). This approach assumes
that the anti-sweat heaters are not
operating for 50 percent of the time.
DOE recognizes that anti-sweat heaters
may be in operation for a different
amount of time in high humidity
installations than in standard
installations.
Issue 16: DOE seeks feedback on
whether the current PTO of 50 percent
is appropriate for evaluating direct
energy consumption of anti-sweat
heaters with controls for walk-in cooler
doors marketed for high humidity
applications. DOE seeks feedback on the
average amount of time per day or per
year that anti-sweat heaters with
controls are off for these high humidity
doors and how this compares to
standard (i.e., non-high humidity) walkin cooler display doors.
4. EER Values To Convert Thermal Load
to Energy Consumption
To calculate the daily energy
consumption associated with heat loss
19 This data from the DOE CCMS database was
accessed on March 17, 2021. This database can be
found at https://www.regulations.doe.gov/
certification-data/.
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through a walk-in door, Appendix A
requires dividing the calculated heat
loss rate by specified EER values of 12.4
Btu per Watt-hour (‘‘Btu/(W-h)’’) for
coolers and 6.3 Btu/(W-h) for freezers.
Appendix A, Sections 4.4.4(a) and
4.5.4(a). DOE adopted these EER values
in a final rule published April 15, 2011.
76 FR 21580, 21586, 21594 (‘‘April 2011
TP final rule’’). As explained in a notice
of proposed rulemaking (‘‘NOPR’’)
leading to this final rule, DOE defined
nominal EER values because an
envelope component manufacturer
cannot control what refrigeration
equipment is installed, and the defined
EER value is intended to provide a
nominal means of comparison rather
than reflect an actual walk-in
installation. 75 FR 186, 197 (January 4,
2010) (‘‘January 2010 TP NOPR’’). DOE
selected EER values of 12.4 Btu/(W-h)
for coolers and 6.3 Btu/(W-h) for
freezers because these are typical EER
values of walk-in cooler and walk-in
freezer refrigeration systems,
respectively.20 75 FR 186, 209.
The DOE test procedure also assigns
nominal EER values when testing the
refrigeration systems of walk-in unit
coolers alone. When testing a unit
cooler alone, the energy use attributed
to the condensing unit is represented by
a default value determined using the
representative EER value specified for
the appropriate ‘‘adjusted’’ dew point
temperature in Table 17 of AHRI 1250–
2009.21 The resulting EER values for
unit coolers tested alone are 13.3 Btu/
(W-h) for coolers and 6.6 Btu/(W-h) for
freezers, which are different than the
EER values of 12.4 and 6.3, respectively,
applied to walk-in doors, as described
above. DOE notes that based on Table 17
of AHRI 1250–2009, EER values of 12.4
and 6.3 correspond to Adjusted
20 The difference in EER values between coolers
and freezers reflects the relative efficiency of the
refrigeration equipment for the associated
application. 75 FR 186, 197. As the temperature of
the air surrounding the evaporator coil drops (that
is, when considering a freezer relative to a cooler),
thermodynamics dictates that the system
effectiveness at removing heat per unit of electrical
input energy decreases. Id.
21 The dewpoint temperature to be used for
testing unit coolers alone is defined in section 3.3.1
of Appendix C to be the Suction A saturation
condition provided in Tables 15 or 16 of Appendix
C (for refrigerator unit coolers and freezer unit
coolers, respectively). Table 15 for refrigerator unit
coolers defines the Suction A saturation condition
(i.e., dewpoint temperature) as 25 °F. Table 16 for
freezer unit coolers defines the Suction A dewpoint
temperature as ¥20 °F. Furthermore, section 7.9.1
of AHRI 1250–2009 specifies that for unit coolers
rated at a suction dewpoint other than 19 °F for a
refrigerator and ¥26 °F for a freezer, the Adjusted
Dewpoint Value shall be 2 °F less than the unit
cooler rating suction dewpoint—resulting in
adjusted dewpoint values of 23 °F and ¥22 °F for
refrigerator unit coolers and freezer unit coolers,
respectively.
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Dewpoint Values of 19 °F for a
refrigerator and ¥26 °F for a freezer (in
contrast to Adjusted Dewpoint Values of
23 °F and ¥22 °F for unit cooler
refrigerators and freezers, respectively,
tested alone as defined in Table 15 and
Table 16 of AHRI 1250–2009 and
subtracting 2 °F as specified in section
7.9.1 of AHRI 1250–2009).
DOE is considering whether to make
the EER values used to calculate the
energy consumption of walk-in doors
consistent with the values used to
calculate unit cooler energy
consumption and whether such a
change would provide a more accurate
representation of the energy use of walkins.
Issue 17: DOE seeks feedback on the
current EER values specified in
Appendix A used to calculate daily
energy consumption for walk-in doors
and the values used in testing of unit
coolers alone, as specified in Appendix
C. Specifically, DOE requests comment
on which of these sets of EER values is
more representative, whether DOE
should make the values used for door
testing and unit cooler testing consistent
with each other, and if so, which of the
sets of values should be used.
5. Thermal Transmittance
a. Calibration of Hot Box for Measuring
U-factor
As stated previously, NFRC 100
references NFRC 102 as the physical test
method for measuring U-factor, which
in turn incorporates by reference ASTM
C1199. ASTM C1199 references ASTM
C1363–05, ‘‘Standard Test Method for
Thermal Performance of Building
Materials and Envelope Assemblies by
Means of a Hot Box Apparatus’’
(‘‘ASTM C1363’’). Section 6.1 of ASTM
C1199 and Annexes 5 and 6 of ASTM
C1363 include calibration requirements
to characterize metering box wall loss
and surround panel flanking loss, but
the frequency at which these
calibrations should occur is not
specified in these test standards. DOE
notes that ASHRAE Standard 16–2016,
‘‘Method of Testing for Rating Room Air
Conditioners and Packaged Terminal
Air Conditioners’’ (‘‘ASHRAE 16–
2016’’), which is the test method
incorporated by reference in the DOE
test procedure for room air conditioners
(10 CFR 430.3(g)(1)), uses in its
determination of air conditioner
capacity a value for heat loss through
the partition wall based on prior
calibration of the wall’s heat loss.
Conceptually, this use of a calibrated
heat loss value is similar to the use of
calibrated thermal losses in ASTM
C1199 and ASTM C1363. DOE notes
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further that section 6.1.2.2 of ASHRAE
16–2016 includes a requirement to
calibrate the partition wall thermal loss
at least every two years. DOE is
interested in feedback on the frequency
of calibration and how recalibrations are
performed for test facilities using test
standard ASTM C1199.
Issue 18: DOE requests comment on
how frequently test laboratories perform
each of the calibration procedures
referenced in ASTM C1199 and ASTM
C1363, e.g., those used to determine
calibration coefficients that are used to
calculate metering box wall loss and
surround panel flanking loss. DOE also
requests comment on the magnitude of
variation in the calibration coefficients
measured during successive
calibrations.
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b. Tolerances of Surface Heat Transfer
Coefficients
Section 6 of ASTM C1199 specifies
the standardized heat transfer
coefficients and their tolerances as part
of the procedure to set the surface heat
transfer conditions of the test facility
using the Calibration Transfer Standard
(‘‘CTS’’) test. The warm-side surface
heat transfer coefficient must be within
± 5 percent of the standardized warmside value, and the cold-side surface
heat transfer coefficient must be within
± 10 percent of the standardized coldside value (ASTM C1199–09, sections
6.2.3 and 6.2.4). ASTM C1199 does not
require that the measured surface heat
transfer coefficients match or be within
a certain tolerance of standardized
values during sample testing—although
test facility operational (e.g., cold side
fan settings) condition would remain
identical to those set during the CTS
test. On the other hand, Appendix A
states in section 5.3(a)(1) that the
average surface heat transfer coefficient
on the cold-side of the apparatus shall
be 30 Watts per square-meter-Kelvin ± 5
percent and that the average surface
heat transfer coefficient on the warmside of the apparatus shall be 7.7 Watts
per square-meter-Kelvin ± 5 percent.
DOE originally proposed the heat
transfer values and their associated
tolerances in a supplemental notice of
proposed rulemaking (‘‘SNOPR’’)
published February 20, 2014 (‘‘February
2014 AEDM TP SNOPR’’). 79 FR 9818,
9837, 9847. DOE did not receive any
comments from interested parties
specific to the proposed tolerance of ±5
percent for both the cold-side and
warm-side heat transfer coefficients, and
finalized these values in a final rule
published on May 13, 2014 (‘‘May 2014
AEDM TP final rule’’). 79 FR 27388,
27415.
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DOE has found that meeting the
standardized heat transfer values within
specified tolerances in section 5.3(a)(1)
of Appendix A on the warm-side and
cold-side may not be achievable
depending on the thermal transmittance
through the door. Specifically, the
warm-side heat transfer is dominated by
natural convection and radiation and
the heat transfer coefficient varies as a
function of surface temperature. When
testing doors with higher thermal
resistance, less heat is transferred across
the door from the warm-side to the coldside, so the warm-side surface
temperature is closer to the warm-side
air temperature. However, the CTS
method in ASTM C1199 does not
require measurement of the warm-side
surface temperature of the door. Rather,
this value is calculated based on the
radiative and convective heat flows
from the test specimen’s surface to the
surroundings, which are driven by
values determined from the calibration
of the hot box (e.g., the convection
coefficient). See ASTM C1199, Section
9.2.1. When testing doors with
extremely high- or low-thermal
resistance, the resulting change in
warm-side surface temperature can shift
the warm-side heat transfer coefficient
out of tolerance. The only way to adjust
these coefficients to be within tolerance
would be to recalibrate the hot box for
a specific door, which would be
burdensome and somewhat
unpredictable.
Issue 19: DOE requests feedback on
whether the tolerances in section
5.3(a)(1) of Appendix A applied to the
surface heat transfer coefficients used to
measure thermal transmittance are
achievable for all walk-in doors and if
not, whether the tolerances should be
increased or omitted. Specifically, DOE
seeks data to support any changes to the
tolerances on the surface heat transfer
coefficients.
6. Air Infiltration Reduction
EPCA includes prescriptive
requirements for doors used in walk-in
applications, which are intended to
reduce air infiltration. Specifically,
walk-ins must have (A) automatic door
closers that firmly close all walk-in
doors that have been closed to within 1
inch of full closure (excluding doors
wider than 3 feet 9 inches or taller than
7 feet), and (B) strip doors, springhinged doors, or other method of
minimizing infiltration when doors are
open. 42 U.S.C. 6313(f)(1)(A)–(B). In the
January 2010 TP NOPR and an SNOPR
published on September 9, 2010
(‘‘September 2010 TP SNOPR’’), DOE
proposed methods for determining the
thermal energy leakage due to steady-
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state infiltration through the seals of a
closed door and door opening
infiltration. 75 FR 186, 214–216 and 75
FR 55068, 55107–55108. However, the
April 2011 TP final rule did not include
these methods because DOE concluded
that steady-state infiltration was
primarily influenced by on-site
assembly practices rather than the
performance of individual components.
76 FR 21580, 21594–21595. Similarly,
DOE stated that, based on its experience
with the door manufacturing industry,
door opening infiltration is primarily
reduced by incorporating a separate
infiltration reduction device at the
assembly stage of the complete walk-in.
Id.
In this RFI, DOE is re-considering
whether a method for measuring
infiltration, specifically door opening
infiltration, as well as a method to
measure the impacts from technologies
that reduce infiltration (e.g. fast-acting
doors or air curtains), would improve on
the current test procedure’s accuracy
and ability to produce results reflecting
a given walk-in door’s energy efficiency
during a representative average use
cycle, while not being unduly
burdensome to conduct. Certain types of
doors, like fast-acting doors, may have
higher thermal transmittance, but may
compensate for that factor by reducing
infiltration from door openings—
thereby, reducing a walk-in’s overall
energy use. DOE is considering how it
may account for these types of doors in
the walk-in test procedure.
In the January 2010 TP NOPR, DOE
proposed to require that the thermal
load from air infiltration associated with
each door opening event be calculated
using an analytical method based on
equations published in the ASHRAE
Refrigeration Handbook in combination
with assumed values for door-opening
frequency and duration. That proposed
method would have accounted for the
presence of infiltration reduction
devices by discounting the thermal load
from door opening air infiltration by the
effectiveness of the air infiltration
device. 75 FR 186, 196–197, 214–216. In
order to determine the effectiveness of
an infiltration reduction device, DOE
proposed a two-part test that entailed
measuring the concentration of tracer
gas after a door opening event with and
without the infiltration reduction device
in place. Id. DOE proposed to use this
effectiveness test for every unique doordevice combination offered by a
manufacturer. Id.
In the September 2010 TP SNOPR,
DOE proposed a method for determining
the thermal load associated with steadystate infiltration through walk-in doors.
75 FR 55068, 55084–55085, and 55107–
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55108. For each door type with identical
construction and only differences in
dimensional size, DOE proposed to
require calculating steady-state
infiltration according to NFRC 400–
2010–E0A1 (‘‘Procedure for Determining
Fenestration Product Air Leakage’’) by
testing three representative doors, one
each of a ‘‘small,’’ ‘‘medium,’’ and
‘‘large’’ size.22 Id. The steady-state
infiltration from the representative
doors would then be extrapolated or
interpolated, as appropriate, to other
doors that have the same construction.
Id.
As noted, DOE is considering how to
credit doors with infiltration-reducing
features that reduce overall walk-in
energy use and that are in addition to
the prescriptive requirements mandated
by EPCA. In doing so, DOE may
consider a revised version of one of its
previous proposals related to door
infiltration, or offer a new method for
determining heat load associated with
infiltration.
DOE requests comment on whether it
should account for steady-state and/or
door opening infiltration in its test
procedure—and if so, why; and if not,
why not. With respect to suggestions for
potential test methods, DOE is
particularly interested in
recommendations regarding test
methods and calculation methods used
by the industry to quantify heat load
from infiltration. With respect to each of
these methods, DOE seeks supporting
information regarding the necessary
costs in carrying them out. DOE seeks
information and data on whether testing
results obtained under any of the
methods could be used to interpolate
the load resulting from air infiltration of
other door sizes in a product line. DOE
also requests information on door usage
patterns per door type (e.g., display
doors, passage doors, motorized doors,
and fast-acting doors), including any
supporting data from research or field
studies.
D. Test Procedure for Walk-In Panels
In the following subsections, DOE
presents several topics specific to walkin panels that, if adopted, may improve
the current test procedure’s ability to
provide results that more accurately
depict walk-in panel energy use during
a representative average use cycle
without causing the test procedure to
become unduly burdensome to conduct.
That test procedure, found in 10 CFR
22 DOE proposed a small size door as 48 inches
±0.5 inch wide and 84 inches ±0.5 inch high, a
medium size door as 96 inches ±0.5 inch wide and
144 inches ±0.5 inch high, and a large size door as
144 inches ±0.5 inch wide and 180 inches ±0.5 inch
high. 75 FR 55068, 55107.
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part 431, subpart R, appendix B,
provides a detailed method by which to
measure the energy efficiency of a given
panel used in the construction of a
walk-in. Since publication of the
December 2016 TP final rule, DOE has
identified the potential need to provide
additional clarification to Appendix B
regarding the measurement of the
thickness of walk-in panels (see Section
II.D.1 of this document) and the
procedure for determining parallelism
and flatness of test specimens (see
Section II.D.2 of this document). DOE
also has identified differences between
Appendix B and the industry test
standards referenced, specifically for
specimen 23 conditioning prior to testing
(see Section II.D.3 of this document). In
addition, DOE is examining the prospect
of requiring a measurement for thermal
transmittance for non-display panels
(see Section II.D.4 of this document).
While DOE previously adopted methods
for measuring thermal transmittance in
the April 2011 TP final rule, it later
removed them. 79 FR 27387, 27405–
27406. DOE remains interested in
exploring the possibility of addressing
this issue because of the potential
variation in thermal transmittance of
different panel designs with the same Rvalue, and seeks additional information
regarding market-related and industry
test method-related changes that would
inform DOE’s potential reconsideration
of adopting a test method for measuring
thermal transmittance. Finally, DOE is
seeking comment on the test procedure
for display panels (Section II.D.5 of this
document).
1. Panel Thickness
DOE’s test procedure for walk-in
panels requires manufacturers to
determine the panel’s R-value by
measuring the thermal conductivity,
referred to as the ‘‘K factor’’ of a 1 ± 0.1inch specimen of insulation according
to ASTM C518–04. The R-value of the
walk-in panel is determined by dividing
the panel thickness by the K factor. See
10 CFR 431.304(b)(3) and Appendix B
(detailing the test method used to
measure the R-value for walk-in
envelope components). DOE’s current
test procedure for determining a panel’s
R-value provides some direction for
measuring panel thickness. However,
because of the importance of this
measurement in determining the panel’s
R-value, DOE is considering whether to
include additional details regarding the
thickness measurement.
23 ASTM C518 uses ‘‘specimen’’ to refer to the
piece of insulation that is cut to size for testing,
while the CFR uses ‘‘sample’’. The discussion in
this document is using ‘‘specimen’’ for consistency
with the industry test standard.
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Issue 20: DOE requests comment on
how panel thickness is currently
measured for determining the panel’s
R-value per the DOE test procedure,
including number of measurements,
measurement location, and any steps
that are routinely followed for the
removal of the protective skins or facers
to obtain the full panel thickness. DOE
requests that commenters identify any
specific guidelines, practices or
standardized approaches that are
followed, as well as their date of
publication, if applicable.
2. Parallelism and Flatness
The test procedure for determining Rvalue also requires that the two surfaces
of the tested specimen that contact the
hot plate assemblies (as defined in
ASTM C518) maintain ±0.03 inches
flatness tolerance and also maintain
parallelism with respect to one another
within a tolerance of ±0.03 inches.24
Section 4.5 of Appendix B. The test
procedure provides no direction on how
flatness and parallelism should be
measured or calculated. DOE is
considering whether its test procedure
should provide additional details
indicating how to determine the flatness
and parallelism of the tested specimen.
Issue 21: DOE requests comment on
how flatness and parallelism of the test
specimen surfaces that contact the hot
plate assemblies described in ASTM
C518 are typically determined by test
laboratories and whether the test
procedure should be revised to clarify
how to determine these parameters, e.g.,
what type of instruments are used to
measure these values, how many
measurements are made for a given
specimen, and other details that could
affect conclusions regarding compliance
with the test procedure.
3. Specimen Conditioning
ASTM C518 directs that a test
specimen cut from a panel be
conditioned prior to testing. See ASTM
C518–04, section 7.3 (referring to panel
conditioning as ‘‘specimen
conditioning’’). However, ASTM C518
does not specify the conditions at which
specimen conditioning would be
conducted, nor the duration. ASTM
C518 states that specimen conditioning
details should be provided in the
24 Maintaining a flatness tolerance means that no
part of a given surface is more distant than the
tolerance from the ‘‘best-fit perfectly flat plane’’
representing the surface. Maintaining parallelism
tolerance means that the range of distances between
the best-fit perfectly flat planes representing the two
surfaces is no more than twice the tolerance (e.g.,
for square surfaces, the distance between the most
distant corners of the perfectly flat planes minus the
distance between the closest corners is no more
than twice the tolerance).
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material specifications, and if not
provided, conditions should be selected
so as not to change the specimen in an
irreversible manner. Id. ASTM C518
further states that material
specifications typically call for
specimen conditioning at 22 °C (72 °F)
and 50 percent relative humidity until
less than a 1 percent mass change is
observed over a 24-hour period. Id.
Calculations associated with
conditioning are discussed in section
8.1 of ASTM C518, including
calculation of the ‘‘density of the dry
specimen as tested,’’ which suggests
that the purpose of conditioning is, at
least in part, to dry the specimen, i.e.,
allow water to evaporate and/or diffuse
out.
DOE has not found specimen
conditioning details to be provided by
suppliers of insulation for any of the
common insulation materials used in
walk-ins. Given this lack of supplierprovided specimen conditioning details,
it is DOE’s understanding that ‘‘material
specifications’’ in section 7.3 refers to
ASTM specifications, e.g. ASTM C578–
2019, ‘‘Standard Specification for Rigid,
Cellular Polystyrene Thermal
Insulation’’ or ASTM C1029–2015,
‘‘Standard Specification for SprayApplied Rigid Cellular Polyurethane
Thermal Insulation’’. However, there is
no uniform set of ASTM conditioning
specifications, and the material
specifications identified in ASTM C518
as ‘‘typical’’ do not reflect what is
provided in other ASTM standards. For
example, ASTM C578–2019 calls for
conditioning as specified in the
applicable test procedure—this circular
reference back to ASTM C518 means
that ASTM C578–2019 effectively
provides no explicit conditions. ASTM
C1029–2015 calls for conditioning at
73 ± 2 °F and 50 ± 5 percent relative
humidity for 180 ± 5 days from time of
manufacture. In the context of the DOE
WICF test procedures, the ASTM
C1029–2015 specifications may be
insufficient or inappropriate because the
date of manufacture of the insulation in
a walk-in panel or door may not be
known, and the 180-day condition
would likely represent a significant test
burden.
In the absence of clear instructions in
ASTM C518, test laboratories may be
using conditioning times, temperature,
and humidity consistent with the
conditions identified in ASTM C518–04
section 7.3 as ‘‘typical conditions.’’
Additionally, the provision in section
4.5 of Appendix B requires that testing
per ASTM C518–04 must be completed
within 24 hours of specimens being cut
for the purpose of testing, eliminating
use of the 180-day conditioning
provided in ASTM C1029–2015 or the
example of typical specimen
conditioning provided by ASTM C518.
Issue 22: DOE requests comment on
the extent to which manufacturers of
insulation specify conditioning for
insulation materials that differ from the
typical conditioning approach described
in ASTM C518. DOE also seeks feedback
on whether more than one 24-hour
conditioning period is ever needed to
complete the conditioning (i.e., the
change in specimen mass is less than 1
percent after the first 24 hours of
conditioning) for a specimen extracted
from a WICF panel or door. Finally,
DOE requests information or data on
how specimen conditioning times less
than or equal to 24 hours impacts the
accuracy, repeatability, and
representativeness of the test.
4. Overall Thermal Transmittance
In the April 2011 TP final rule, DOE
adopted a test method for measuring the
overall thermal transmittance of a walkin panel, including the impacts of
thermal bridges 25 and edge effects (e.g.,
due to framing materials and fixtures
used to mount cam locks). This method
drew from an existing industry test
method, incorporating by reference
ASTM C1363–05. 76 FR 21580, 21605–
21612. However, after receiving
comments indicating that only two
independent laboratories could conduct
this test, DOE re-evaluated its earlier
decision and removed this portion of
the walk-in panel test procedure in the
May 2014 AEDM TP final rule. 79 FR
27388, 27405–27406. Despite this
decision to remove its overall thermal
transmittance measurement method
from the walk-in test procedure, DOE
remains concerned that elements like
framing materials and fixtures used to
mount cam locks can significantly affect
walk-in panel energy efficiency
performance. To address this issue, DOE
is re-evaluating whether—and if so,
how—to account for the overall thermal
transmittance of walk-in panels in its
test procedure.
Issue 23: DOE requests information
about panel construction factors that
would affect thermal transmission and
the magnitude of the energy efficiencyrelated impacts of thermal bridges in the
panel assembly. Additionally, DOE
requests comment on alternative test
methods that measure the overall
thermal transmittance of walk-in panels
and the relative advantages and
disadvantages of each. DOE also seeks
feedback on the number and location of
labs that have the facilities and are
qualified to run ASTM C1363–05.
5. Display Panels
Display panels are defined in 10 CFR
431.302 as panels entirely or partially
comprised of glass, a transparent
material, or both that are used for
display purposes. Display panels are
subject to the test procedure in
Appendix A for determining U-factor,
conduction load, and energy use. 10
CFR 431.304(b)(1). Appendix A follows
the procedure in NFRC 100 for
determination of display panel U-factor.
10 CFR 431.303. Although DOE
established a test procedure for display
panels, DOE has not established energy
conservation standards for them. DOE
received no comments in response to
the proposed test procedure outlined for
display panels in the September 2010
TP SNOPR and DOE established
Appendix A as the test procedure for
display panels in the April 2011 TP
Final Rule. 76 FR 21580, 21606. DOE is
interested in any feedback on amending
the current test procedure for display
panels.
Issue 24: DOE seeks feedback on the
current test procedure for display panels
in Appendix A and what amendments
should be made, if any, to it.
E. Test Procedure for Walk-In
Refrigeration Systems
DOE’s test procedure for walk-in
refrigeration systems can be found in
Appendix C to Subpart R of 10 CFR part
431. The test procedure primarily
incorporates by reference AHRI 1250–
2009.
DOE has also recently granted test
procedure interim waivers and waivers
to Appendix C specific to the testing of
single-package systems, wine cellar
refrigeration systems, and carbon
dioxide (‘‘CO2’’) refrigerant based
systems, summarized in Table II.3. Test
procedure waivers provide alternate test
provisions for units that DOE
determines cannot be appropriately
tested to its current test procedure. A
waiver granted by DOE remains in effect
until DOE amends its regulations so as
to eliminate any need for it, pursuant to
10 CFR 431.401(h) for commercial and
industrial equipment. Sections II.E.1,
II.E.2, and II.E.3, below discuss and
request comment on addressing singlepackage systems, wine cellar
25 Thermal bridging occurs when a more
conductive material allows an easy pathway for
heat flow across a thermal barrier.
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refrigeration systems, and CO2 systems
in the test procedure.
TABLE II.3—INTERIM WAIVERS AND WAIVERS GRANTED TO MANUFACTURERS OF WALK-IN REFRIGERATION SYSTEMS
Interim Waiver Federal Register
citation
Manufacturer
Subject
Air Innovations ..............
Vinotheque ...................
CellarPro .......................
Vinotemp ......................
HTPG ............................
Hussmann ....................
Keeprite ........................
Store It Cold .................
Wine Cellar Refrigeration Systems ...................
Wine Cellar Refrigeration Systems ...................
Wine Cellar Refrigeration Systems ...................
Wine Cellar Refrigeration Systems ...................
CO2 Unit Coolers ...............................................
CO2 Unit Coolers ...............................................
CO2 Unit Coolers ...............................................
Single-Package Systems ...................................
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FR
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FR
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FR
2403 (Jan. 12, 2021) .......
11961 (Mar. 1, 2021) .......
11972 (Mar. 1, 2021) .......
23692 (May 4, 2021) .......
83927 (Dec. 23, 2020) ....
10046 (Feb. 18, 2021) .....
12433 (Mar. 3, 2021) .......
11944 (Mar. 29, 2019) .....
Waiver decision and order
Federal Register citation
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FR 23702 (May 4, 2021).
FR 26504 (May 14, 2021).
FR 26496 (May 14, 2021).
FR
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(Mar. 19, 2021).
(May 7, 2021).
(May 7, 2021).
(Aug. 9, 2019).
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* A decision and order granting the manufacturer a waiver has not yet been issued.
As noted earlier, during DOE’s
previous rulemaking to develop
standards for WICF refrigeration
systems, the accompanying Term Sheet
included a series of amendments to the
test procedure that the Working Group
viewed as necessary to properly
implement its recommended energy
conservation standards. Ultimately,
DOE published final rules implementing
the majority of both sets of
recommendations. See 82 FR 31808,
31808–31838 (July 10, 2017) (final rule
amending the energy conservation
standards for walk-ins) and 81 FR 95758
(December 28, 2016) (final rule
amending the walk-in test procedures).
Three test procedure-related
recommendations from the Term Sheet,
however, were not part of DOE’s
December 2016 TP final rule. (Term
Sheet Recommendation #6). The
Working Group believed these
recommendations merited consideration
by DOE as part of future amendments to
help make the test procedure more fully
representative of walk-in energy use.
(Id.) Specifically, the Working Group
recommended that DOE amend its
procedure to (a) measure the energy use
associated with the defrost function,
taking into account the potential savings
associated with hot gas and adaptive
defrost, (b) incorporate the measurement
of off-cycle power consumption,
including crankcase heater power
consumption, and (c) allow for separate
ratings of stand-alone variable-capacity
condensing units. (Id.). Sections II.E.4
through II.E.6 of this document discuss
these issues in more detail.
Sections II.E.7 and II.E.8 discuss other
issues that may also improve the test
procedure’s ability to provide results
that are more representative of walk-in
energy use. Specifically, these include
consideration of amended test
procedures and new equipment classes
for so-called high-temperature freezer
refrigeration systems used for walk-ins
at temperatures between 10 °F and 32
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°F, and discussion of the impact of
refrigerant temperature glide 26 of
zeotropic refrigerants such as R407A.
1. Single-Package Systems
As discussed in the December 2016
TP final rule, single-package systems are
considered a type of dedicated
condensing refrigeration system. 81 FR
95758, 95763–95764. The test methods
in AHRI 1250–2009, which are
incorporated by reference as DOE’s test
procedure for walk-ins (10 CFR
431.303(b)), do not fully address or
account for the features of singlepackage systems. As discussed in the
December 2016 TP final rule,
commenters asserted that one practical
challenge to testing single-package
systems is the need to disassemble the
unit under test in order to be able to
install the refrigerant mass flow meters
required for testing. Id. at 95763. Mass
flow measurement is a key input in the
calculation of capacity, as illustrated in
equations C1 and C2 of AHRI 1250–
2009.
Regarding this class of equipment,
DOE received a petition for waiver with
regard to testing of single-package units.
By letter dated May 9, 2020, Store It
Cold submitted a petition for waiver and
interim waiver from Appendix C for
basic models of single-package systems.
(EERE–2018–BT–WAV–0002, No. 2)
Store It Cold stated that testing singlepackage systems with refrigerant mass
flow meters installed produces results
unrepresentative of their true energy
consumption characteristics and would
provide materially inaccurate
comparative data. The petitioner
requested that DOE permit the use of
psychrometric ‘air-side’ measurements
to determine the Gross Total
Refrigeration Capacity of such systems.
26 ‘‘Temperature glide’’ for a refrigerant refers to
the increase in temperature at a fixed pressure as
liquid refrigerant vaporizes during its conversion
from saturated liquid to saturated vapor.
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DOE granted a test procedure waiver
and interim waiver to Store It Cold for
specified basic models in 2019. 84 FR
39286 (August 9, 2019) (‘‘Store It Cold
Decision and Order’’).
AHRI 1250–2020 addresses testing of
single-package systems in section C9
and incorporates by reference test
standards developed for testing airconditioning units that include
alternative test methods that have been
adapted for testing single-package
systems. The air enthalpy methods in
section C9 of AHRI 1250–2020
incorporate by reference ANSI/ASHRAE
Standard 37–2009 (‘‘ASHRAE 37–
2009’’), ‘‘Methods of Testing for Rating
Electrically Driven Unitary AirConditioning and Heat Pump
Equipment’’ and ANSI/ASHRAE 41.6–
2014 (‘‘ASHRAE 41.6’’), ‘‘Standard
Method for Humidity Measurement’’.
The calorimeter methods in section C9
of AHRI 1250–2020 incorporate by
reference ANSI/ASHRAE Standard 16–
2016 (‘‘ASHRAE 16–2016’’), ‘‘Method of
Testing for Rating Room Air
Conditioners, Packaged Terminal Air
Conditioners, and Packaged Terminal
Heat Pumps for Cooling and Heating
Capacity’’. The compressor calibration
methods in section C9 of AHRI 1250–
2020 incorporate by reference ASHRAE
37 and ANSI/ASHRAE 23.1–2010.
AWEF calculations for matched pair
and single-package systems are detailed
in section 7.1.1 through 7.1.4 of AHRI
1250–2020.
AHRI 1250–2020 requires two
simultaneous measurements of system
capacity (i.e., a primary and secondary
method), and section C9.2.1 of
Appendix C provides a requirement that
the measurements agree within 6
percent. Table C4 to Appendix C to
AHRI 1250–2020 details which of the
test methods (calorimeter, air enthalpy,
and compressor calibration) qualify as
primary and/or secondary methods.
Issue 25: DOE requests comment on
whether the single-package system test
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and calculation methods described in
AHRI 1250–2020 provide representative
energy use. DOE also requests comment
on whether DOE should incorporate by
reference AHRI 1250–2020 as the test
procedure for single-package systems.
DOE also notes that, unlike split
systems (i.e., matched-pair refrigeration
systems), single-package systems may
experience additional thermal losses
because they circulate cold walk-in air
through a cold section that has exterior
surfaces exposed to warm air outside
the walk-in enclosure. This exposure
can contribute to additional infiltration
losses, i.e., leakage of air between the
interior and exterior of a walk-in.
Accordingly, if these losses occur, they
would reduce the net capacity of a
single-package system without being
fully captured by the refrigerant
enthalpy methods established in AHRI
1250–2009.
Issue 26: DOE requests any data or
calculations quantifying the additional
thermal losses associated with testing
single-package systems due to the
exposure of their cold sides to the
exterior air (i.e., surface and infiltration
losses). DOE additionally requests
comment on whether the AHRI 1250–
2020 test methodology for singlepackage systems fully accounts for these
additional losses.
a. Calorimeter Method
As previously mentioned, AHRI
1250–2020 incorporates by reference
ASHRAE 16–2016 as its indoor and
outdoor room calorimeter method test
procedure. ASHRAE 16–2016 includes a
calorimeter test method with
similarities to the calibrated box test
method of AHRI 1250–2009, but with
additional details and provisions.
ASHRAE 16–2016 is used to measure
the capacity and power input of singlepackage system products such as room
air conditioners that have hot and cold
sections, similar to single-package walkin systems. The ASHRAE 16–2016
calorimeter test includes both outdoorand indoor-based calorimetric
measurements of the capacity—the
indoor side measurement is similar to
that of the calibrated box test method,
while the outdoor side provides a
determination of system cooling
capacity by measuring the cooling
required to maintain the outdoor room
temperature and humidity conditions.
DOE’s work in evaluating singlepackage systems using the calorimeter
methods referenced in AHRI 1250–2020
has highlighted the need to make very
precise determination of the calorimeter
chamber cooling fluid heat capacity.
This fluid cannot be pure water, since
it must be below water freezing
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temperature for testing WICF
refrigeration systems. This makes
precise determination of heat capacity
more challenging, since an accurate
determination of glycol concentration is
required.
Issue 27: DOE requests comment and
data on the use of water, glycol, or other
heat transfer liquid in maintaining test
compartment temperature using the
calorimeter methods referenced in AHRI
1250–2020 for the testing of singlepackage refrigeration systems. DOE
requests comment on whether the
description and requirements for
calorimetric testing as provided in AHRI
1250–2020 should be modified or
enhanced in order to better ensure that
measurements are accurate and
repeatable.
In addition, ASHRAE 16–2016
requires that a pressure-equalizing
device be installed between the indoor
and outdoor test compartments to
maintain a balanced pressure between
the compartments and to measure the
air flow required to maintain
equalization. Assuming the test facility
is otherwise airtight, the air flow
transferred and measured by the
pressure-equalizing device represents
air transferred in the opposite direction
through leaks inside the equipment as a
result of pressure differences between
the warm and cold side of the system set
up by its fans.
Given that the related calibrated box
test method has no requirements for
pressure equalization, DOE is
considering the need for pressure
equalization for single-package testing.
Alternatives include (a) no requirement
addressing transfer air or pressure
equalization, or (b) a requirement that
the test facility chambers be leak-free
with no equalization requirement. DOE
expects that the use of a pressure
equalization apparatus would
incrementally increase test facility cost
and test burden, and would ensure
operation with losses consistent with
the measured air leakage, but such
equalized pressure conditions may not
be representative of WICF refrigeration
system use. The alternative options may
reduce facility cost and test burden.
Option (a) may reduce accuracy and
repeatability, while both options may
mask potential performance degradation
associated with air leakage.
Issue 28: DOE requests comment on
whether calorimeter test methods for
single-package systems should
implement a pressure-equalizing device,
as included in ASHRAE 16–2016. DOE
requests information on any additional
cost and resource burdens, if any,
manufacturers would face when
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employing these methods to evaluate
single-package systems.
Issue 29: DOE seeks comment
regarding any alternative test methods
not mentioned in this document that
could be used to measure single-package
system capacity. To the extent that any
alternative test methods could be used
for this purpose, DOE requests
information on their advantages and
disadvantages in measuring singlepackage system capacity.
2. Wine Cellar Refrigeration Systems
DOE is aware of certain equipment
within the walk-in definition that may
be incapable of being tested in a manner
that would yield results measuring the
energy efficiency or energy use of that
equipment during a representative
average use cycle under the current
version of the walk-in test procedure.
Specifically, wine cellars that are
installed in a variety of commercial
settings are set to operate at a
temperature range of 45 °F to 65 °F.
They also meet the criteria established
by Congress in the definition for a walkin. See generally 42 U.S.C. 6311(20).
Under the walk-in test procedure, walkin coolers must be tested while
operating at 35 °F. Section 3.1.1 of
Appendix C. Wines often suffer from
damage when stored at temperatures
below 45 °F. To the extent that a wine
cellar is not operated at 35 °F, applying
the required 35 °F testing temperature
condition when evaluating the energy
usage of this equipment would not
produce results representative of an
average use cycle.
DOE has received requests for waiver
and interim waiver from several
manufacturers from the test procedure
in Appendix C for basic models of wine
cellar refrigeration systems.27( ).
Manufacturers stated that wine cellars
are intended to operate at a temperature
range of 45 to 65 °F and 50–70 percent
relative humidity, rather than the 35 °F
and less than 50 percent relative
humidity test condition prescribed in
Appendix C. Manufacturers asserted
that testing at 35 °F would be
unrepresentative of the true energy
consumption characteristics of the
specified units and that operation at this
temperature may damage wine cellar
refrigeration units. Given the number of
waivers that DOE received, DOE
27 Air Innovations, Vinotheque Wine Cellars,
Cellar Pro Cooling Systems, Vinotemp International
Corp., and LRC Coil Company, respectively,
submitted petitions for waivers and interim waivers
for basic models of wine cellar walk-in refrigeration
systems. (Air Innovations, EERE–2019–BT–WAV–
0029, No. 6; Vinotheque, EERE–2019–BT–WAV–
0038, No. 6; CellarPro, EERE–2019–BT–WAV–0028,
No. 6; Vinotemp, EERE–2020–BT–WAV–0022, No.
10; LRC Coil, EERE–2020–BT–WAV–0040, No. 1).
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engaged with AHRI, the industry trade
association, to discuss how to develop
a consistent alternate test approach for
wine cellars that would be applicable to
all impacted manufacturers. Ultimately,
AHRI submitted a memorandum on
behalf of its wine cellar members
supporting (1) a 45 °F minimum
operating temperature for wine cellar
refrigeration systems, and (2) testing at
50 percent of maximum external static
pressure, with manufacturers providing
maximum external static pressure
values to DOE.28 After reviewing
manufacturer websites, product
specification sheets, suggested alternate
test approaches provided by each
manufacturer and by AHRI, and after
soliciting and reviewing feedback from
the public, DOE has granted interim
waivers or waivers as summarized in
Table II.3.
These waivers have addressed testing
for single-package, matched-pair, and
unit-cooler-only wine cellar
refrigeration systems. The alternative
test procedures prescribed in these
waivers address a number of differences
in operation between wine cellar
refrigeration systems and other walk-in
refrigeration systems, including the
following:
• Unit cooler air inlet condition of 55
°F and 55 percent RH, compared to 35
°F and less than 50 percent RH for
medium-temperature refrigeration
systems in the DOE test procedure;
• For single-package wine cellar
systems, capacity measurement is
conducted using a primary and a
secondary capacity measurement
method as specified in AHRI 1250–
2020, using two of the following: The
indoor air enthalpy method; the outdoor
air enthalpy method; the compressor
calibration method; the indoor room
calorimeter method; the outdoor room
calorimeter method; or the balanced
ambient room calorimeter method.
• Options for ducting on the
condenser side, evaporator side, or both
with specifications for setting the
external static pressure.
• For calculating AWEF, the wine
cellar box load level is set equal to half
of the refrigeration system capacity at
the 95 °F test condition (for outdoor
refrigeration systems) or 90 °F (for
indoor refrigeration systems), rather
than using a two-tiered set of high- and
low-load period box load levels, as
28 Memorandum
from AHRI, ‘‘Department of
Energy (DOE) Wine Cellar Cooling Systems Test
Procedure Waiver Industry Comments from AHRI
Membership’’, August 18, 2020. (EERE–2019–BT–
WAV–0028, No. 5 (CellarPro); EERE–2019–BT–
WAV–0029, No. 5 (Air Innovations); EERE–2019–
BT–WAV–0038, No. 5 (Vinotheque); EERE–2019–
BT–WAV–022, No. 2 (Vinotemp))
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prescribed in AHRI 1250–2009. For
calculating AWEF, the evaporator fan is
assumed to operate for one-tenth of the
compressor off-cycle period at the same
wattage as applies for the compressor
on-cycle. This contrasts with varying
assumptions used for other WICF
refrigeration systems, depending on the
type of evaporator fan controls they use.
Issue 30: DOE requests comment on
the alternative test procedure for wine
cellar walk-in refrigeration systems that
it has granted in the interim waivers and
waivers listed in Table II.3. DOE
additionally seeks comment on whether
the alternative test procedure prescribed
for the specified basic models identified
in the waivers would be appropriate for
similar refrigeration equipment.
As noted previously, wine cellar
refrigeration systems are designed for
both ducted and non-ducted air
delivery; the DOE test procedure does
not address the testing of ducted
systems. For systems that can be
installed with (1) ducted evaporator air,
(2) with or without ducted evaporator
air, (3) ducted condenser air, or (4) with
or without ducted condenser air, the
alternate test approach requires testing
to be conducted at 50 percent of the
maximum external static pressure
(‘‘ESP’’), subject to a tolerance of ¥0.00/
+0.05 in. DOE understands that
maximum ESP is generally not
published in available literature such as
installation instructions, but
manufacturers do generally specify the
size and maximum length of ductwork
that is acceptable for any given unit in
such literature. The duct specifications
determine what ESP would be imposed
on the unit in field operation.29 The
provision of allowable duct dimensions
is more convenient for installers than
maximum ESP, since it relieves the
installer from having to perform duct
pressure drop calculations to determine
ESP. This approach differs from the
approach used in related products/
equipment, e.g., air conditioners, where
ESP is a function of capacity—ESP does
not correlate well with capacity for wine
cellar refrigeration systems.
Issue 31: DOE requests feedback on its
approach for testing ducted units in its
alternate test procedure for wine cellar
refrigeration systems. Specifically, DOE
requests comment and supporting data
on whether testing at 50 percent of
29 The duct material, length, diameter, shape, and
configuration are used to calculate the ESP
generated in the duct, along with the temperature
and flow rate of the air passing through the duct.
The conditions during normal operation that result
in a maximum ESP are used to calculate the
reported maximum ESP values, which are
dependent on individual unit design and represent
manufacturer-recommended installation and use.
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maximum ESP provides representative
performance values, or whether other
fractions of maximum ESP may be more
appropriate. Additionally, DOE seeks
comment on other industry test methods
that include the testing of ducted units.
Finally, DOE is interested in other
alternative approaches for testing
ducted units that have been
demonstrated to provide repeatable and
representative results.
The above discussion assumes that
wine cellar refrigeration systems are
either a single-package system or a
matched-pair.30 However, DOE has also
received a petition for waiver for unit
coolers that are distributed into
commerce without a paired condensing
system.31 DOE recognizes that these unit
cooler-only models will need to be
tested according to the provisions in
AHRI 1250–2020 for unit coolers tested
alone, for which calculation of AWEF
requires use of an appropriate EER
based on the suction dew point
temperature. Table 18 in AHRI 1250–
2020 provides EER values for medium
and low temperature unit coolers tested
alone. However, these values may not be
appropriate for calculating AWEF for
wine cellar unit coolers because this
equipment likely operates with different
suction dew point temperature and the
counterpart condensing units likely use
different compressor designs than those
considered when developing the current
EER values.
Issue 32: DOE requests data and
information on appropriate EER values
for use in calculating AWEF for wine
cellar unit coolers tested alone, and how
these EER values might depend on
refrigerant and/or capacity. DOE
requests that commenters provide
background explanation regarding how
any such EER recommendations have
been developed.
Issue 33: Since unit coolers for wine
cellar systems are sold alone, DOE seeks
information on the characteristics of
condensing units that would typically
be paired with these unit coolers (e.g.,
make/model, compressor style, capacity
range, manufacturers).
30 A ‘‘matched refrigeration system’’ is also called
a ‘‘matched pair’’ and is a refrigeration system
where the condensing system is distributed into
commerce with a specific unit cooler(s). See 10 CFR
431.302.
31 LRC Coil Company submitted a petition for
waiver and interim waiver for specific basic models
of unit cooler only walk-in wine cellar refrigeration
systems. (LRC Coil, EERE–2020–BT–WAV–0040,
No. 1) In reviewing another petition for waiver and
interim waiver from Vinotheque for single-package
system and matched-pair system basic models
(Vinotheque, EERE–2019–BT–WAV–0038, No. 6),
DOE noted that the manufacturer also offered unit
cooler only systems distributed without a paired
condensing system.
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Additionally, DOE notes that its
definitions for ‘‘single-packaged
system’’ and ‘‘unit cooler’’ may not
appropriately define ducted units. DOE
currently defines a ‘‘single-packaged
dedicated system’’ as ‘‘a refrigeration
system (as defined in this section) that
is a single-package system assembly that
includes one or more compressors, a
condenser, a means for forced
circulation of refrigerated air, and
elements by which heat is transferred
from air to refrigerant, without any
element external to the system imposing
resistance to flow of the refrigerated air.
10 CFR 431.302. Similarly, DOE defines
a ‘‘unit cooler’’ as ‘‘an assembly,
including means for forced air
circulation and elements by which heat
is transferred from air to refrigerant,
thus cooling the air, without any
element external to the cooler imposing
air resistance. Id. Both definitions
describe a single-package or unit cooler
system, respectively, that is not ducted
(i.e., there is no element external to the
unit that imposes air resistance).
Issue 34: DOE seeks comment on
whether, and if so how, it should
modify its definitions for ‘‘singlepackaged dedicated system’’ and ‘‘unit
cooler’’ to address units that are
designed to be installed with ducts.
Issue 35: DOE requests comment on
any other issues regarding testing of
wine cellar refrigeration systems that
may not be fully addressed by the
current DOE test procedure.
3. CO2 Systems
DOE has also become aware of WICF
unit coolers that are being used in CO2
transcritical booster systems that cannot
be tested using the current set of test
conditions. DOE has received several
test procedure waiver petitions
regarding CO2 unit coolers used in
transcritical booster systems.
Heat Transfer Product Group
(‘‘HTPG’’), Hussmann, and Keeprite
submitted petitions for waivers and
interim waivers from Appendix C for
specific basic models of CO2 direct
expansion unit coolers).32 The DOE test
procedure for unit coolers requires
testing with liquid inlet saturation
temperature of 105 °F and liquid inlet
subcooling temperature of 9 °F, as
specified by Tables 15 and 16 of AHRI
1250–2009. However, CO2 has a critical
temperature of 87.8 °F; therefore, it does
32 Heat Transfer Products Group, Hussmann
Corporation, and Keeprite Refrigeration,
respectively, submitted petitions for waivers and
interim waivers for basic models of CO2 unit coolers
used in transcritical booster systems. (HTPG, EERE–
2020–BT–WAV–0025, No. 1; Hussmann, EERE–
2020–BT–WAV–0026, No. 1; Keeprite, EERE–2020–
BT–WAV–0028, No. 1).
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not coexist as saturated liquid and gas
above this temperature. The liquid inlet
saturation temperature of 105 °F and the
liquid inlet subcooling temperature of 9
°F specified in Appendix C are not
achievable by CO2 unit coolers. The
three petitioners requested that DOE
modify the test condition values to
reflect typical operating conditions for a
transcritical CO2 booster system (i.e., a
liquid inlet saturation temperature of 38
°F and a liquid inlet subcooling
temperature of 5 °F). After reviewing
manufacturer websites, product
specification sheets, and suggested
alternate test approaches provided by
each manufacturer, DOE has granted
waivers or interim waivers to the
manufacturers listed in Table II.3.
DOE is seeking comment on how to
address CO2 system testing in a way that
is representative of the average use cycle
for these units and is not unduly
burdensome to conduct.
Issue 36: DOE requests comment on
test conditions that would be most
appropriate for evaluating the energy
use of CO2 unit coolers. Additionally,
DOE requests feedback on any
additional changes that would need to
be made to the DOE test procedure to
accurately evaluate energy use of these
systems, while minimizing test burden.
While all CO2 refrigerant waiver
petitions DOE has thus far received
address unit coolers for use in
transcritical booster systems, it is
possible that other CO2 refrigeration
system configurations may be relevant
in the future, e.g., dedicated condensing
units (‘‘DCUs’’), matched pairs, or
single-package systems. DOE reviewed
product literature and other information
for CO2 systems having some of these
alternative configurations. Most of this
information pertains to manufacturers
operating in Europe.
Issue 37: DOE requests comment on
the present and future expected use of
walk-in refrigeration systems using CO2.
DOE requests specific information about
these systems that would suggest a need
to modify the DOE test procedure to
address such equipment. Specifically,
DOE requests information on whether
such equipment is sold in the U.S.,
whether this equipment is sold as
matched pairs or individual
components, and to what extent
dedicated condensing units are
configured to supply subcritical liquid
(rather than supercritical gas) to the unit
coolers.
4. Defrost Test Method
The April 2011 TP final rule
incorporated AHRI 1250–2009 as DOE’s
WICF refrigeration system test
procedure, including that standard’s
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requirement that both frosted and dry
coil defrost tests be conducted.
Appendix C, Section 3. DOE later noted
in the February 2014 AEDM TP SNOPR
that this requirement may be overly
burdensome for manufacturers to
conduct, due to the difficulty of
maintaining the moist air infiltration
conditions for the frosted coil test in a
repeatable manner. 79 FR 9818, 9831.
Accordingly, in DOE’s May 2014 AEDM
TP final rule, DOE adopted a set of
nominal values for calculating defrost
energy use for a frosted coil, number of
defrosts per day if the unit has an
adaptive defrost system, and daily
contribution of heat load.33 79 FR
27388, 27401. To address testing lowtemperature condensing units alone, the
May 2014 AEDM TP final rule
established nominal values for the
defrost energy use and thermal load. In
addressing refrigeration systems with
hot gas defrost, the May 2014 AEDM TP
final rule established nominal values for
calculating hot gas defrost energy use
and heat load. Id.
The December 2016 TP final rule
removed the method for calculating the
defrost energy and defrost heat load of
systems with hot gas defrost and
established a new method to evaluate
hot gas defrost refrigeration systems.
That new method treated these hot gas
defrost refrigeration systems as if they
used electric defrost rather than hot gas
defrost. This method relied on the same
nominal values for defrost energy use
and thermal load that the test procedure
prescribes for electric-defrost
condensing units that are tested alone.
81 FR 95758, 95774–95777. This
approach was modified in the March
2021 hot gas defrost TP final rule that
amended the test procedure to rate hot
gas defrost unit coolers using modified
default values for energy use and heat
load contributions that would make
their ratings more consistent with those
of electric defrost unit coolers. 86 FR
16027. The scope of the March 2021 hot
gas defrost TP final rule is limited to
unit coolers only. 86 FR 16027, 16030.
a. Moisture Addition
DOE is considering whether using a
test method—possibly similar to the one
detailed in section C11.3 of AHRI 1250–
2009—to measure the energy use
associated with the defrosting of frosted
coils would provide a reasonably
accurate accounting of defrost energy
33 In a ‘‘hot gas’’ defrost system, hightemperature, high-pressure hot refrigerant gas from
the discharge side of the compressor is introduced
into the evaporator, where it condenses, thereby
releasing latent heat into the evaporator. This heat
is used to melt the frost that has accumulated on
the outside of the evaporator coil.
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usage and savings associated with
technologies such as adaptive defrost
and hot gas defrost. DOE is also
considering adopting a test method to
assess and confirm defrost adequacy.
Any test method used to measure
defrost energy use and adequacy would
have to provide consistent, repeatable
methods for (1) delivering a frost load to
the test coil and (2) measuring the
thermal load released into the
refrigerated space during the defrost
cycle, regardless of the method of
defrost (e.g., electric or hot gas defrost),
all while ensuring that the procedure
provides results reflecting energy usage
during a representative average use
cycle and not be unduly burdensome to
conduct.
In AHRI 1250–2009, the moisture to
provide a frost load is introduced
through the infiltration of air at 75.2 °F
dry-bulb temperature and 64.4 °F wetbulb temperature into the walk-in
freezer at a constant airflow rate that
depends on the refrigeration capacity of
the tested freezer unit (equations C11
and C12 in section C11.1.1 of AHRI
1250–2009). A key issue with this
approach is the difficulty in ensuring
repeatable frost development on the unit
under test, despite specifying the
infiltration air dry-bulb and wet-bulb
temperatures. For example, in addition
to frost accumulating on the evaporator
of the unit under test, frost may also
accumulate on the evaporator of other
cooling equipment used to condition the
room, which could subsequently affect
the rate of frost accumulation on the
unit under test (by affecting the amount
of moisture remaining in the air).
ASHRAE-supported research—
including a series of projects exploring
frost loads and defrosting dynamics—
suggest the possibility of alternative
methods of creating a frost load. This
work includes ASHRAE Project No.
622–RP ‘‘A Study to Determine Heat
Loads Due to Coil Defrosting’’ 34 (‘‘622–
RP’’) and Project No. 1094–RP ‘‘A Study
to Determine Heat Loads Due to Coil
Defrosting-Phase II’’ 35 (‘‘1094–RP’’). For
the experiments discussed in these
reports, the researchers created a frost
load by introducing steam directly into
the refrigerated space. However, as
discussed in 1094–RP, this approach
can result in the suspension of ice
34 Sherif, S.A., P.J. Mago, and R.S. Theen. A Study
to Determine Heat Loads Due to Coil Defrosting.
1997. University of Florida: Gainesville, FL.
ASHRAE Project No. 622–RP. Report No. UFME/
SEECL–9701.
35 Sherif, S.A., P.J. Mago, and R.S. Theen. A Study
to Determine Heat Loads Due to Coil DefrostingPhase II. 2003. University of Florida: Gainesville,
FL. ASHRAE Project No. 1094–RP. Report No.
UFME/SEECL–200201.
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crystals in the saturated room air and
the formation of snow-like frost on the
test coils. The researchers found that
this snow-like frost degrades
refrigeration system performance more,
and is more difficult to defrost, than the
ice-like frost that forms in sub-saturated
air conditions. 622–RP and 1094–RP
also observed that during the defrost
cycle, a significant portion (a majority
for some trials) of the coil frost was
sublimated (converted to water vapor)
rather than melted. This finding
suggests that measuring the quantity of
frost melt water mass may be a poor
indicator of the frost load, since a
significant portion of the frost would
not be captured as melt water. DOE is
interested in any viable alternate frost
load delivery methods that could be
used to apply a known and repeatable
amount and type of frost.
Issue 38: DOE requests information
regarding potential methods of
providing a measurable frost load and
frost type for defrost testing, including
data and information demonstrating the
repeatability of such a test.
Additionally, DOE requests data and
information indicating what a typical
frost load and frost type would be—for
example, whether the moist air flow of
section C11.1.1 of AHRI 1250–2009
provides the appropriate amount of
moisture, and if so, whether any data
are available to support the use of this
quantity. If such data are available, DOE
asks that interested parties share it with
the agency for further consideration. If
such data are currently unavailable,
DOE is interested in what kind and
amount of testing would be needed to
sufficiently validate an appropriate
method to evaluate frost loads and frost
types during defrost testing.
b. Hot Gas Defrost
Among its various recommendations,
the Working Group recommended that
DOE modify its current test procedure to
account for hot gas defrost system
performance. (Term Sheet
Recommendation #6). As a result of this
recommendation, DOE is interested in
obtaining feedback on the most
practicable method for measuring or
otherwise accounting for hot gas defrost
performance.36 DOE recognizes that in
order to assess the energy performance
of a defrost cycle, the test procedure
36 As previously mentioned, the March 2021 hot
gas defrost TP final rule updated the defrost energy
use and thermal load equations for hot gas defrost
unit coolers tested alone to provide a consistent
performance evaluation between hot gas defrost and
electric defrost unit coolers when tested alone. 86
FR 16027, 16030. However, this approach does not
measure or account for actual hot gas defrost
thermal load and energy use.
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must address both the energy consumed
and the heat released into the
refrigerated space by the defrost system.
In general, for electric resistance heating
systems, all the electrical energy
consumed by the heater is transformed
into heat, such that the energy
consumed by the heater and the heat
released into the space are equivalent.
The procedure outlined in AHRI 1250–
2009 is based on this principle and
estimates the amount of heat released
into the space by measuring energy
consumption and subtracting the energy
associated with frost melt that drains
out of the chamber (section C11.1 of
AHRI 1250–2009).
Alternatively, for hot gas defrost
systems, the heat energy released into
the evaporator (in the form of latent
heat), and ultimately into the
refrigerated space, is greater than the
electrical energy used by the compressor
to drive the hot gas defrost system. The
exact ratio of heat released to electrical
energy consumed depends on the
efficiency of the specific system design.
Therefore, the amount of heat released
into the room cannot be estimated by
measuring the electrical energy
consumption of the heating system.
Because the procedure outlined in AHRI
1250–2009 relies on an assumption that
the energy consumed by the heater
equals the heat released into the space,
it is not applicable to hot gas defrost
systems. DOE is not aware of a test
method that can reliably be used to
directly measure the thermal impact of
hot gas defrost without a substantial
increase in test burden.
Alternatively, DOE could consider the
use of a calculation method. In such an
approach, rather than measure the heat
released into the refrigerated space for
the unit-under-test, that heat load would
be calculated as a function of the
refrigeration system’s steady-state
capacity. The heat load-to-capacity
relationship could be defined based on
test data from actual hot gas defrost
systems. Under this approach, the
energy consumed by the hot gas defrost
system could be quantified either by
direct testing and measurement, or by
using a calculation method, as described
for heat load addition. DOE is aware
that AHRI has developed a calculation
method to represent hot gas defrost heat
load and energy use contributions. This
method is provided in Section C10.1 of
AHRI 1250–2020 and prescribes
equations to represent energy use and
heat addition associated with defrost for
different system configurations
(matched-pair, single-package, unit
cooler, condensing unit) and with
consideration of whether hot gas is used
only to defrost the evaporator or
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whether it also maintains warm
temperatures in the drip pan.
Finally, if DOE were to modify its
walk-in test procedure to account for
hot gas defrost energy consumption and
heat load, DOE would need to
determine the types of refrigeration
system configurations (i.e., matchedpairs, stand-alone unit coolers, and
stand-alone condensing units) to which
a hot gas defrost-specific test procedure
would apply. For each configuration,
DOE would also need to consider which
methods (i.e., testing, calculation, or
both) would be most appropriate.
Issue 39: DOE requests comment on
the specific refrigeration system
configurations (i.e., matched-pairs,
stand-alone unit coolers, and standalone condensing units) to which a hot
gas defrost-specific test procedure
would apply. DOE requests comment on
which methods for determining energy
and heat load (i.e., testing, calculation,
or both) would be most appropriate for
each refrigeration system and why. DOE
requests comment on the methods
related to hot gas defrost systems in
AHRI 1250–2020. Finally, DOE requests
data to help quantify the relationship
between hot gas defrost heat load
addition and energy consumption
versus capacity and/or to confirm the
relationships provided in the AHRI
1250–2020 test methods for hot gas
defrost.
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c. Adaptive Defrost
In the December 2016 TP final rule,
DOE established a method to address
systems with adaptive defrost. That
approach requires that the feature be
deactivated during compliance testing
but allows a manufacturer to account for
a unit’s improved performance with
adaptive defrost activated in its market
representations. 81 FR 95758, 95767,
95777, 95790. At the November 4, 2015
Working Group meeting, Southern
California Edison expressed concern
with the assumption that the overall
energy use of traditional defrost systems
significantly exceeds adaptive defrost
system energy use. Southern California
Edison presented data showing that, for
a tested adaptive defrost system, the
reduction in energy use resulting from
reduced defrost frequency is largely
offset by an increase in energy use
during the refrigeration on-cycle, due to
the thermal resistance of the increased
frost accumulation (Docket EERE–2015–
BT–STD–0016, No. 38 37). The data
presented by Southern California Edison
37 Working Group Meeting Stakeholder
Presentation: Walk-in Refrigeration ASRAC
Meeting, available at https://www.regulations.gov/
document?D=EERE-2015-BT-STD-0016-0038.
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illustrates just one potential
complication in properly addressing the
energy use impact of adaptive defrost—
specifically, that an adaptive system
that waits too long (i.e., when too much
frost builds up on the coils) to defrost
may significantly affect the on-cycle
performance of the refrigeration system.
On the other hand, an adaptive system
that defrosts too frequently could
increase defrost energy use if the defrost
frequency is higher than the four
defrosts per day that is typical for a
conventional timed defrost. The
sensitivity of the adaptive defrost
savings potential to the magnitude of
the moisture load also suggests that a
single adaptive defrost test using a
constant moisture load may not
properly represent this technology’s
benefits. The test procedure may have to
account for the differences in daily and
seasonal frosting patterns experienced
by installed systems (e.g., frequent air
infiltration during business hours and
none during non-business hours—or
infiltration of warm, moist air in
summer and cool, dry air in winter).
Issue 40: DOE requests comment on
how the performance of adaptive defrost
systems should be accounted for in the
walk-in test procedure and which
refrigeration systems (i.e., matchedpairs, stand-alone unit coolers, and
stand-alone condensing units) should be
evaluated under a potential adaptive
defrost test procedure. Specifically, DOE
requests data showing the performance
of adaptive defrost systems relative to
non-controlled defrost systems,
including impacts to on-cycle operation.
DOE requests data demonstrating
seasonal and daily frosting patterns for
walk-in applications.
5. Off-Cycle Energy Use
As discussed previously, the Working
Group recommended that DOE amend
its test procedure to address issues
related to off-cycle power consumption
(Term Sheet Recommendation #6). For
walk-in refrigeration systems, the term
‘‘off-cycle’’ refers to the period when the
compressor is not running and defrost
(if applicable) is not active. During the
off-cycle, unit cooler fans and other
auxiliary equipment will typically run
or cycle on and off, thereby consuming
energy.
While the current DOE test procedure
accounts only for fan power
consumption during the off-cycle
period, AHRI 1250–2020 includes
requirements specific to off-cycle fan
power consumption in Section C3.5,
which addresses power measurements
for unit coolers (including total power
to the fan motor(s), pan heaters, and
controls) and DCUs, in addition to
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prescribing off-cycle measurement
intervals, operating tolerances and data
collection rates. Section C4.2 provides a
method for determining off-cycle power
consumption. DOE is considering the
incorporation of this updated industry
test method into its test procedures
should a rulemaking be initiated.
Issue 41: DOE requests information
and data on whether the off-cycle
methods included in AHRI 1250–2020
provide a representative and repeatable
measure of the off-cycle power use for
matched pairs, single-package systems,
and also for unit coolers and/or
condensing units tested alone, and if
not, what modifications are
recommended. DOE also seeks
information on other off-cycle mode
energy-consuming components that are
not currently addressed by AHRI 1250–
2020. In addition to identifying all offcycle mode energy-consuming
components, DOE seeks information on
the patterns and magnitudes of energy
use by each of these components during
the off-cycle.
6. Multi-Capacity and Variable-Capacity
Condensing Units
In the July 2017 ECS final rule, DOE
noted that it expected the majority of
refrigeration equipment within the
dedicated condensing class to be
certified as stand-alone condensing
units, with a much smaller number of
systems certified as matched-pairs. 82
FR 31808, 31832. However, the current
DOE test procedure does not include a
method for assessing stand-alone multiand variable-capacity systems. To
address this gap, the Working Group
recommended that DOE amend its test
procedure to allow for separate ratings
of stand-alone variable-capacity
condensing units. (Term Sheet
Recommendation #6).
Historically, refrigeration systems
have been designed using a single-speed
compressor, which operates at full
cooling capacity while the compressor
is on. To match the cooling load of the
space, which in most cases is less than
the full cooling capacity of the
compressor, a single-speed compressor
cycles on and off at a particular duty
cycle. This cycling behavior introduces
inefficiencies due to the surge in power
draw experienced at the beginning of
each ‘‘on’’ cycle, before the compressor
reaches steady-state performance. In
contrast, variable-capacity systems
employ an inverter compressor that can
reduce its speed to match the observed
cooling load. Accordingly, a variablespeed compressor runs continuously,
adjusting its speed up or down as
required, thereby avoiding compressor
cycling when the full cooling capacity
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of the compressor is not necessary to
provide sufficient cooling to the space.
Similarly, a multi-capacity compressor
can ‘‘unload’’ individual cylinders
within the compressor, which allows
the compressor to remain on, but at a
reduced capacity, to more closely match
the required cooling load.
The current DOE test procedure
measures the performance of a walk-in
condensing unit while operating under
a full cooling load at a fixed capacity;
i.e., the compressor is operated
continuously in its ‘‘on’’ state. See AHRI
1250–2009, Tables 11 through 14 and
Appendix C, section 3.0. While AHRI
1250–2009 and AHRI 1250–2020 both
include test methods for multi- and
variable-capacity matched pair
refrigeration systems, there is no test
method for multi- and variable-capacity
condensing units when tested alone. As
a result, any inefficiencies due to
compressor cycling, and any
performance benefit associated with
part-load operation, are not captured
during the DOE test. Consequently, the
current test procedure may
underestimate the efficiency benefits of
multi- and variable-capacity systems.
DOE is aware of some multi- or variablecapacity condensing units that are
currently available on the market.38
Issue 42: DOE requests input on the
development of test methods that would
more accurately measure the energy use
performance—including accounting for
the potential efficiency benefits of
multi- and variable-capacity systems—
both for matched-pair and stand-alone
condensing unit testing. DOE seeks data
and information showing the potential
magnitude of energy savings by
reducing cycling losses in these multi
and variable-capacity systems. DOE
requests market information on whether
there are multi- and variable-capacity
condensing units available on the
market (in addition to those already
identified) and the brand name(s) and
model numbers of those additional
units.
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7. Systems for High-Temperature
Freezer Applications
In the June 2014 ECS final rule, DOE
established equipment classes for
medium- and low-temperature walk-in
refrigeration systems. 79 FR 32050,
32069–32070. While the terms
‘‘medium-temperature’’ and ‘‘lowtemperature’’ are not explicitly defined,
the June 2014 ECS final rule, 2015
ASRAC negotiations, December 2016 TP
38 Multi-capacity product information from one
manufacturer can be found at https://
www.regulations.gov Docket No. EERE–2017–BT–
TP–0010–0004.
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final rule, and July 2017 ECS final rule
all consistently used the term ‘‘mediumtemperature’’ to refer to walk-in cooler/
refrigerator refrigeration systems and the
term ‘‘low-temperature’’ to refer to walkin freezer refrigeration systems.
The current test procedure for walkin refrigeration systems specifies rating
conditions of 35 °F for refrigerator
systems and ¥10 °F for freezer systems
(see section 5 of AHRI 1250–2009,
incorporated by reference at 10 CFR
431.303(b)). The 35 °F and ¥10 °F
rating conditions produce a metric,
AWEF, which is generally
representative of the medium- and lowtemperature refrigeration systems’
energy use when installed in walk-in
coolers and freezers, respectively. The
AWEF metric forms the basis for energy
conservation standards for medium- and
low-temperature refrigeration systems.
However, field usage data indicate that
walk-in refrigeration systems operate at
a broad range of application
temperatures both above and below the
respective 35 °F and ¥10 °F rating
points.
As discussed in the December 2016
TP final rule, stakeholders commented
that so-called ‘‘high-temperature’’
freezer walk-ins, which have an
enclosed storage (i.e. room) temperature
range of 10 °F to 32 °F, are refrigerated
with medium-temperature condensing
units. 81 FR 95758, 95790. Under the
statutory definitions of ‘‘walk-in cooler’’
and ‘‘walk-in freezer,’’ this equipment
would be considered a walk-in freezer
because its room temperature is less
than or equal to 32 °F 42 U.S.C.
6311(20). Accordingly, these
refrigeration systems would be tested
using a room temperature of¥10 °F, as
specified in Appendix C. However,
stakeholders commented as to the
difficulty these medium-temperature
refrigeration systems have in meeting
this temperature condition when using
lower GWP refrigerants.39 81 FR 95758,
95790. Lennox offered data suggesting
that medium-temperature units
generally perform more efficiently at the
10 °F operating condition (i.e., the low
end of the cited ‘‘high-temperature
freezer’’ temperature range) than lowtemperature systems. (Docket EERE–
2015–BT–STD–0016, Lennox, No. 89 40
39 Lennox commented that the industry was
moving to low-GWP refrigerants in response to the
Environmental Protection Agency final rule under
the Significant New Alternatives Policy (‘‘SNAP’’)
program that prohibited the use of R–404A in
certain retail food refrigeration applications,
including WICF refrigeration systems starting July
20, 2016. (Docket EERE–2016–BT–TP–0030,
Lennox, No. 13 at p. 2) For further discussion of the
SNAP rule, see section II.E.8 of this document.
40 Available at https://www.regulations.gov/
document?D=EERE-2015-BT-STD-0016-0089.
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at pp. 2–5) Lennox suggested that this
‘‘high-temperature freezer’’ application
may justifiably represent a third class of
walk-in refrigeration systems, but also
noted the reporting and testing burden
that establishing an additional set of
classes would incur. In response, DOE
noted that manufacturers of equipment
that cannot be tested in a way that
properly represents their performance
characteristics may petition DOE for test
procedure waivers, as detailed in 10
CFR 431.401. DOE also indicated that it
may consider amending its regulations
by establishing new equipment classes
and applicable test methods. 81 FR
95758, 95790–95791.
DOE is currently considering how, if
at all, to address high-temperature
freezer walk-ins, including whether to
establish test procedure provisions to
specifically address the refrigeration
systems serving such equipment.
Multiple approaches are under
consideration. One approach would
allow walk-in manufacturers and
contractors to install a medium
temperature refrigeration system that is
tested and certified based on the
standardized 35 °F walk-in cooler
temperature (or corresponding
refrigerant suction conditions) as a
walk-in freezer, if the walk-in
refrigeration system is marketed at or
above 10 °F. By extension, the approach
would also allow representations of
performance (e.g. capacity, power input)
of such medium-temperature
refrigeration systems for walk-in
temperatures at 10 °F and higher
without requiring them to be tested and
certified based on the¥10 °F lowtemperature walk-in test condition. This
approach would alleviate the need for a
new high-temperature freezer
equipment class (thus avoiding the
associated certification test burden),
while still allowing the potentially more
efficient medium temperature
refrigeration systems to be used for high
temperature freezer applications.
(Docket EERE–2015–BT–STD–0016,
Lennox, No. 89 at pp. 2–5 (offering data
suggesting that medium temperature
units generally perform more efficiently
at the 10 °F operating condition than
low-temperature systems)).
DOE could establish new definitions
for the terms ‘‘low-temperature
refrigeration system’’ and ‘‘mediumtemperature refrigeration system,’’ that
implement this potential structure. For
example, ‘‘low-temperature refrigeration
system’’ could be defined as ‘‘a
refrigeration system used to cool the
interior of walk-in freezers and maintain
a refrigerated room temperature of 10 °F
or less,’’ while ‘‘medium-temperature
refrigeration system’’ could be defined
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as ‘‘a refrigeration system used to cool
the interior of a walk-in cooler or a
walk-in freezer operating above 10 °F.’’
Alternatively, another approach
would allow medium-temperature
refrigeration systems used in hightemperature freezer walk-in applications
to be tested and certified at their lowest
application temperature conditions.
This approach would be similar to that
taken for commercial refrigerators,
freezers, and refrigerator-freezers, for
which manufacturers report the lowest
application product temperature, i.e. the
lowest average compartment
temperature at which the equipment is
capable of operating during testing
(section 2.2 of appendix B to 10 CFR
part 431 subpart C). For walk-ins, this
concept could be based on the lowest
evaporator return air temperature for
matched-pair refrigeration systems and
the lowest saturated suction
temperature (and a suitable
corresponding return gas temperature)
for condensing units tested separately.
This approach would result in ratings
for the units in high-temperature freezer
applications that are directly
representative of field performance, as
the refrigeration system would be tested
at a representative box temperature for
such an application. Further, this
approach would not presuppose what
the optimal high-temperature freezer
operating condition would be, i.e., it
avoids selecting a standardized
condition that may be unachievable by
some units. However, AWEF ratings
obtained from the lowest application
temperature for different units, which
would be rated for different box
temperatures, would not be directly
comparable. The approach would also
add testing and reporting burden
associated with the additional test
condition.
DOE is also considering a third
approach that would establish a single
standardized test condition at which
high-temperature freezer refrigeration
equipment would be tested. This
approach would result in AWEF ratings
that are slightly less representative of
field performance than the lowest
application temperature approach,
while still creating the potential need to
establish a new equipment class (or
classes) for low-temperature
refrigeration systems. However, under a
standardized test condition approach,
all high-temperature freezer
refrigeration systems would be rated at
the same condition, providing directly
comparable ratings for models that serve
similar applications.
DOE is investigating if and how the
calculations used for determining the
AWEF of WICF condensing units tested
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alone and with matched systems would
need to be modified for products
certified with the latter two approaches
discussed previously—for example,
whether any potential changes to the
specified duty cycle at 95 °F ambient
temperature for an outdoor system
would be necessary.
Issue 43: DOE requests feedback on
the three approaches discussed in this
section to address high-temperature
freezer walk-ins, as well as any other
potential approaches not raised in this
RFI.
Issue 44: DOE also requests
information that would help inform the
development of test procedures for hightemperature freezer refrigeration
systems, should such an approach be
necessary. Additionally, DOE requests
whether there are specific
characteristics that distinguish a hightemperature freezer refrigeration system
from a medium-temperature
refrigeration system, in order to better
define this category of equipment.
Issue 45: DOE also requests comment
on whether 10 °F is the appropriate
lowest end of the application range for
equipment used in walk-in hightemperature freezers that cannot be
tested using the ¥10 °F freezer test
condition. Furthermore, DOE requests
comment on whether all mediumtemperature systems (matched-pair,
condensing unit, evaporator) can be
operated and tested at 10 °F (or
equivalent refrigerant suction
conditions), or whether there is a wide
range at the low-end of the operating
range that depends on the design of the
system.
Issue 46: Regarding the testing of a
medium-temperature refrigeration
system in the high-temperature freezer
range, DOE requests information on
what specified test procedure
parameters would need to be altered
(and how) in order for the test to be
representative of field operation. (In
answering, DOE requests that
commenters provide the supporting
reasons for any suggested
recommendations.) DOE requests
information on whether a single
standardized high-temperature freezer
room condition could be appropriate for
testing this group of walk-ins, and if so,
what such an appropriate temperature
would be.
Issue 47: Finally, DOE requests
comment on what, if any, changes
would be needed in the calculation of
AWEF for high-temperature freezer
operation, and why.
If DOE were to pursue the lowest
application temperature approach or the
standardized high-temperature freezer
test condition approach, DOE would
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need to establish certain new default
values to calculate the AWEF and net
capacity of stand-alone hightemperature freezer dedicated
condensing units. Currently, the test
procedure provides equations for
determining evaporator fan power,
defrost energy, and defrost heat load, all
of which are used in lieu of matched
unit cooler test data (section 3.4.2 of
Appendix C).
The current test procedure offers two
separate equations that relate the
cooling capacity to the evaporator fan
power for medium- and lowtemperature unit coolers (section 3.4.2.2
of Appendix C). Based on the
condensing unit capacity at the medium
temperature test condition (35 °F box
temperature), using the mediumtemperature equation seems to be the
most appropriate approach since the
condensing units in question would also
be certified as medium-temperature
condensing units. This approach also
assumes that fan energy use at hightemperature freezer conditions will be
the same as fan energy use at mediumtemperature conditions, since it makes
no adjustment in the calculated fan
power for the high-temperature freezer
application.
Issue 48: DOE requests comment on
the appropriateness of using the current
medium-temperature refrigeration
system default fan input power equation
(found at section 3.4.2.2 of Appendix C)
to represent the fan input power of hightemperature freezer refrigeration
systems. If the current mediumtemperature refrigeration system default
fan input power equation is not
representative of the fan input power for
high-temperature freezer refrigeration
systems, DOE requests suggestions for a
more appropriate equation, or
alternative relationships to consider, as
well as any relevant data.
In the current test procedure, defrost
energy and defrost heat load for standalone dedicated condensing units are
estimated based on the condenser
capacity using an equation in section
3.4.2 of Appendix C. The calculations
apply only to freezer models, since they
assume that refrigeration systems
serving walk-in coolers are not
equipped for defrost capability and thus
have no defrost energy or heat load.
However, medium-temperature
refrigeration systems designed for hightemperature freezer applications require
defrost capability because frost that
collects on the evaporator during the
compressor off-cycle will not melt in the
sub-freezing walk-in temperature
conditions. The energy and heat load of
these high-temperature freezer defrost
systems may differ significantly from
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those of ¥10 °F freezers. Therefore,
proper accounting for defrost of hightemperature freezer refrigeration
systems requires developing a modified
calculation. The equation found in
section 3.4.2.4 of Appendix C used to
calculate freezer equipment daily
defrost energy use (‘‘DF’’) uses as inputs
the condenser capacity (‘‘qmix,cd’’) and
the number of defrost cycles per day
(‘‘NDF’’). The daily defrost heat load
(‘‘QDF’’) is directly dependent on DF
(see relevant equation in section 3.4.2.5
of Appendix C). DOE anticipates that a
calculation of defrost impacts for hightemperature freezers, if adopted, would
use similar equations with different
magnitudes.
Issue 49: DOE requests information or
data that would indicate whether and
how the equations used to calculate
daily defrost energy use and heat
addition in the test procedure should be
modified for high-temperature freezer
refrigeration systems rated as standalone condensing units (e.g., defrost
heater wattage and daily energy use as
a function of capacity for a 10 °F walkin temperature). If testing at the lowest
application temperature is adopted,
DOE requests comment on how the
defrost equations should be modified to
account for each model being tested at
different conditions, and why. DOE
requests information on whether frost
loads and/or defrost frequency are
different for high- temperature freezers
than for ¥10 °F freezers. (DOE requests
that commenters include any available
supporting information when
responding.)
8. Consideration for Refrigerant Glide
The analysis for the June 2014 ECS
final rule assumed that the refrigerant
R–404A would be used in all new
refrigeration equipment meeting the
standard. 79 FR 32050, 32074. In its
subsequent negotiated rulemaking effort
in 2015, WICF Working Group members
suggested that DOE revise this approach
by accounting for the use of a different
refrigerant, R–407A, which was
expected to become more commonly
used for WICF applications. Consistent
with that suggestion, DOE conducted
the analysis for the July 2017 ECS final
rule using R–407A as the refrigerant. 82
FR 31808, 31835–31836.
On July 20, 2015, the U.S.
Environmental Protection Agency
(‘‘EPA’’) published a final rule under the
Significant New Alternatives Policy
(‘‘SNAP’’) program listing as
unacceptable the use of certain
hydrofluorocarbons (‘‘HFCs’’), including
the use of R–404A in WICF refrigeration
systems. 80 FR 42870 (‘‘July 2015 EPA
SNAP Rule’’). In October 2016, the 28th
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Meeting of the Parties to the Montreal
Protocol adopted the Kigali Amendment
on HFCs, which, upon ratification,
requires parties to the protocol to reduce
consumption and production of HFCs.41
On December 1, 2016, EPA published a
final rule (‘‘December 2016 EPA SNAP
Rule’’) that listed a number of
refrigerants for use in certain refrigerant
applications as unacceptable, starting
January 1, 2023 for cold storage
warehouse application, and January 1,
2021 for retail food refrigerant
applications. 81 FR 86778. The list of
unacceptable refrigerants included R–
407A. The validity of the SNAP
approach, however, has been the subject
of a legal challenge regarding EPA’s use
of its SNAP authority to require
manufacturers to replace HFCs with a
substitute substance.
In August 2017, the U.S. Court of
Appeals for the District of Columbia
Circuit vacated and remanded the July
2015 EPA SNAP Rule to the extent that
it required manufacturers to replace
HFCs with a substitute
substance.42 Mexichem Fluor, Inc. v.
EPA, 866 F.3d 451 (D.C. Cir. 2017).
Subsequently, the December 2016 SNAP
Rule was partially vacated by the
court.43 While the United States has not
ratified the Kigali Amendment, a
significant portion of walk-in
refrigeration systems currently use HFCbased refrigerants and may become
affected by this Amendment to the
Montreal Protocol. DOE plans to
consider the potential impact (if any) of
both the court’s decision and remand as
well as the Amendment to the Montreal
Protocol on the test procedure issues
addressed in this RFI.
Notwithstanding these legal
developments, key differences between
the refrigerants used in DOE’s separate
analyses of walk-in refrigeration systems
merit discussion. Both R–404A and
R–407A are blends of refrigerants that
have different boiling points. This
means that, unlike pure substances such
41 https://www.unep.org/ozonaction/Portals/105/
documents/7809-e-Factsheet_Kigali_Amendment_
to_MP.pdf (last viewed February 3, 2017).
42 The vacatur and remand in Mexichem, Inc. v.
EPA was of the July 2015 EPA SNAP Rule and did
not directly address the December 2016 EPA SNAP
Rule. At issue was EPA’s use of its SNAP authority
as a means to remove HFCs from the agency’s list
of acceptable substitutes. On April 27, 2018, EPA
published a notice stating that in the near-term it
will not apply the HFC listings in the July 2015
final rule pending a rulemaking and that it plans
to begin a notice-and-comment rulemaking process
to address the remand. 83 FR 18431.
43 Following the decision in the Mexichem case,
the court vacated the December 2016 SNAP Rule to
the extent it requires manufacturers to replace HFCs
that were previously and lawfully installed as
substitutes for ozone-depleting substances. Case No.
17–1024 (D.C. Cir. April 5, 2019).
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as water, the temperature of the
refrigerant changes as it boils or
condenses, because one of the
refrigerants in the blend, having a lower
boiling point, boils off sooner than the
other(s). This phenomenon is called
‘‘glide.’’ The refrigerants that make up
R–404A have nearly identical boiling
points, so this refrigerant has very little
glide. In contrast, R–407A undergoes a
much more significant temperature
change when it boils—the temperature
can rise as much as 8 degrees between
the saturated liquid condition (the
temperature at which a liquid begins to
boil, also called the ‘‘bubble point’’) and
the saturated vapor condition (the
temperature at which a vapor begins to
condense, also called the ‘‘dew point’’).
The average of these two temperatures,
bubble point and dew point, is called
the mid-point temperature.
The current DOE test procedure
specifies that test conditions are based
on dew point. DOE notes that if the
refrigerant condition for a unit cooler is
specified by dew point, the average
refrigerant temperature would be
significantly lower for a high-glide than
for a low-glide refrigerant. As
mentioned previously, DOE is
considering changing its test procedure
to be based on a refrigerant-neutral
approach. One specific option would be
to use the mid-point temperature.
However, with walk-in refrigeration
systems, the refrigerant entering the unit
cooler is typically a two-phase
refrigerant with a temperature higher
than the bubble point. This scenario
results in the average evaporator
temperature being slightly greater than a
mid-point equal to the average of bubble
and dew point temperatures. To account
for this difference, DOE could develop
an approach to calculate and specify
refrigerant temperatures in terms of a
‘‘modified mid-point,’’ which would be
a calculated value slightly higher than
the mid-point of the selected refrigerant.
Issue 50: DOE requests comment on
the appropriateness of specifying
refrigerant temperatures in terms of
mid-point or a modified mid-point,
rather than dew point, which is
currently used. DOE seeks feedback on
potential definitions to use for a
modified mid-point temperature as
applied to WICF refrigeration system
testing. In addition, DOE requests
comments on what other factors should
be considered when modifying the
refrigeration system test conditions from
dew point to mid-point or modified
mid-point specifications.
III. Submission of Comments
DOE invites all interested parties to
submit in writing by the date specified
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in the DATES heading, comments and
information on matters addressed in this
RFI and on other matters relevant to
DOE’s early assessment of whether an
amended test procedure for walk-in
coolers and freezers is warranted and if
so, what such amendments should be.
Submitting comments via https://
www.regulations.gov. The https://
www.regulations.gov web page requires
you to provide your name and contact
information. Your contact information
will be viewable to DOE Building
Technologies staff only. Your contact
information will not be publicly
viewable except for your first and last
names, organization name (if any), and
submitter representative name (if any).
If your comment is not processed
properly because of technical
difficulties, DOE will use this
information to contact you. If DOE
cannot read your comment due to
technical difficulties and cannot contact
you for clarification, DOE may not be
able to consider your comment.
However, your contact information
will be publicly viewable if you include
it in the comment or in any documents
attached to your comment. Any
information that you do not want to be
publicly viewable should not be
included in your comment, nor in any
document attached to your comment.
Persons viewing comments will see only
first and last names, organization
names, correspondence containing
comments, and any documents
submitted with the comments.
Do not submit to https://
www.regulations.gov information for
which disclosure is restricted by statute,
such as trade secrets and commercial or
financial information (hereinafter
referred to as Confidential Business
Information (‘‘CBI’’)). Comments
submitted through https://
www.regulations.gov cannot be claimed
as CBI. Comments received through the
website will waive any CBI claims for
the information submitted. For
information on submitting CBI, see the
Confidential Business Information
section.
DOE processes submissions made
through https://www.regulations.gov
before posting. Normally, comments
will be posted within a few days of
being submitted. However, if large
volumes of comments are being
processed simultaneously, your
comment may not be viewable for up to
several weeks. Please keep the comment
tracking number that https://
www.regulations.gov provides after you
have successfully uploaded your
comment.
Submitting comments via email.
Comments and documents submitted
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via email also will be posted to https://
www.regulations.gov. If you do not want
your personal contact information to be
publicly viewable, do not include it in
your comment or any accompanying
documents. Instead, provide your
contact information in a cover letter.
Include your first and last names, email
address, telephone number, and
optional mailing address. The cover
letter will not be publicly viewable as
long as it does not include any
comments.
Include contact information each time
you submit comments, data, documents,
and other information to DOE. No
telefacsimiles (faxes) will be accepted.
Comments, data, and other
information submitted to DOE
electronically should be provided in
PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file
format. Provide documents that are not
secured, written in English, and free of
any defects or viruses. Documents
should not contain special characters or
any form of encryption and, if possible,
they should carry the electronic
signature of the author.
Campaign form letters. Please submit
campaign form letters by the originating
organization in batches of between 50 to
500 form letters per PDF or as one form
letter with a list of supporters’ names
compiled into one or more PDFs. This
reduces comment processing and
posting time.
Confidential Business Information.
Pursuant to 10 CFR 1004.11, any person
submitting information that he or she
believes to be confidential and exempt
by law from public disclosure should
submit via email two well-marked
copies: One copy of the document
marked ‘‘confidential’’ including all the
information believed to be confidential,
and one copy of the document marked
‘‘non-confidential’’ with the information
believed to be confidential deleted.
Submit these documents via email. DOE
will make its own determination about
the confidential status of the
information and treat it according to its
determination.
It is DOE’s policy that all comments
may be included in the public docket,
without change and as received,
including any personal information
provided in the comments (except
information deemed to be exempt from
public disclosure).
DOE considers public participation to
be a very important part of the process
for developing test procedures and
energy conservation standards. DOE
actively encourages the participation
and interaction of the public during the
comment period in each stage of this
process. Interactions with and between
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members of the public provide a
balanced discussion of the issues and
assist DOE in the process. Anyone who
wishes to be added to the DOE mailing
list to receive future notices and
information about this process should
contact Appliance and Equipment
Standards Program staff at (202) 287–
1445 or via email at
ApplianceStandardsQuestions@
ee.doe.gov.
IV. Issues on Which DOE Seeks
Comment
Although DOE welcomes comments
on any aspect of this proposal, DOE is
particularly interested in receiving
comments and views of interested
parties concerning the following issues:
Issue 1: DOE seeks comment on how
liquid-cooled refrigeration systems are
(or could be) used with respect to walkin applications. DOE requests comment
on whether it should consider
establishing a test procedure for liquidcooled refrigeration systems. If test
procedures were considered for liquidcooled refrigeration systems, DOE
requests information on whether there is
an industry standard or standards that
should be considered.
Issue 2: DOE seeks comment on how
wine cellar refrigeration systems should
be defined to best represent the
conditions under which these systems
are designed to operate and to fully
distinguish these systems from systems
designed to meet safe food storage
requirements. Additionally, DOE
requests comment on applications other
than wine cellar storage for refrigeration
systems that are designed to operate at
temperatures warmer than typical for
coolers and for which testing at 35 °F
would be representative of use. If there
are such additional applications, DOE
seeks information regarding the specific
operating requirements (i.e.,
temperature and humidity) for these
systems.
Issue 3: DOE requests comment on the
current definition of ‘‘door’’ in 10 CFR
431.302. DOE seeks feedback on the
terminology of door components used
and whether these are consistently
interpreted. DOE seeks specific feedback
from manufacturers on how they use the
term ‘‘door plug’’ and whether it is
essential to the definition of a WICF
‘‘door’’.
Issue 4: DOE requests comment on
whether height and width or surface
area are distinct attributes that
effectively distinguish between passage
and freight doors. DOE seeks
information on any building codes,
standards, or industry practices to
support or refute maintaining the
dimensions of a door as the defining
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characteristic which separates freight
and passage doors.
Issue 5: Regarding a door that meets
the freight door definition but does so
only because it has a multi-door
configuration in which the individual
component doors each would by
themselves not meet the freight door
definition, DOE seeks comment on how
such doors should be classified, and
whether such classification should
depend on other factors, such as
whether one or more frame members
divides the door opening into smaller
openings.
Issue 6: DOE seeks comment on
whether any attribute, or combination of
attributes, other than size, would affect
energy use and could be used to
distinguish between freight doors and
passage doors. If so, DOE requests data
and comment on such attributes.
Issue 7: DOE requests comment on the
accuracy of the computational method
in NFRC 100 to predict U-factor for
display and non-display doors. DOE
seeks feedback regarding the differences
in results (if any) between those
obtained using the NFRC 100
computational method and those
obtained when conducting physical
testing using NFRC 102 for display and
non-display doors. DOE is also
interested in the magnitude of these
differences and whether the
computational method can be modified
to yield results that more closely match
the results obtained from actual
physical testing. If manufacturers are
aware of other methods to predict Ufactor for either display doors or nondisplay doors besides NFRC 100, DOE
requests how the results from these
methods compare to physical testing.
Issue 8: DOE seeks information from
manufacturers and other interested
parties regarding how the industry
currently rates individual door models,
including the prevalence within the
industry of using the computational
method from NFRC 100. DOE also
requests information on the costs
associated with the computational
method of NFRC 100 or an alternative
computational method compared to
physically testing the thermal
transmittance of walk-in doors using
NFRC 102.
Issue 9: DOE requests comment on
what issues, if any, would be present if
ASTM C518–17 were to be referenced in
the Appendix B test procedure for
measuring panel K-factor, or average
thermal conductivity. While not
exhaustive, primary areas of interest to
DOE include any differences between
the currently referenced version of the
industry standard (ASTM C518–04) and
ASTM C518–17 that would result in a
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difference in the determined R-value
and/or test burden (whether an increase
or decrease), and if there are such
differences, the magnitude of impact to
the determined R-value and/or test
burden.
Issue 10: DOE requests comment on
what issues, if any, would be present if
AHRI 1250–2020 were to be referenced
in the Appendix C test procedure for
measuring walk-in refrigeration system
AWEF. While not exhaustive, primary
areas of interest to DOE include any
differences between the currently
referenced version of the industry
standard (AHRI 1250–2009) and AHRI
1250–2020 that would result in a
difference in the determined AWEF
and/or test burden (whether an increase
or decrease), and if there are such
differences, the magnitude of impact to
the determined AWEF and/or test
burden.
Issue 11: DOE requests comment on
how manufacturers determine surface
area for the purpose of evaluating
compliance with the standards for both
display doors and nondisplay doors.
DOE seeks input on any distinction
between display doors and nondisplay
doors, especially the door frames, which
may warrant surface area for each to be
determined differently.
Issue 12: DOE seeks feedback on how
manufacturers interpret and measure
door opening as it relates to prescriptive
standards for antisweat heaters,
including whether or not manufacturers
agree that the door opening considered
for antisweat heat should be consistent
with the surface area used to determine
maximum energy consumption.
Issue 13: DOE requests feedback on
specifying the surface area used to
determine thermal conduction through a
walk-in door from the surface area used
to determine the maximum energy
consumption of a walk-in door.
Issue 14: DOE seeks comment on
whether, and if so how, an option for
direct component power measurement
could be included in the test procedure
or compliance, certification, and
enforcement (‘‘CCE’’) provisions to
allow more accurate accounting for the
direct electrical energy consumption of
WICF doors. DOE also seeks input on
whether specific provisions should be
provided for determining power input
from the information that is typically
provided on nameplates, noting the
limitations that were described above.
Issue 15: DOE requests comment on
the current PTO values and whether
DOE should consider amending any of
the current values or adding specific
values for additional electrical
components, specifically motorized
door openers. DOE requests data from
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field studies or similar sources to
support any proposed amendments (or
additions) to these PTO values.
Issue 16: DOE seeks feedback on
whether the current PTO of 50 percent
is appropriate for evaluating direct
energy consumption of anti-sweat
heaters with controls for walk- in cooler
doors marketed for high humidity
applications. DOE seeks feedback on the
average amount of time per day or per
year that anti-sweat heaters with
controls are off for these high humidity
doors and how this compares to
standard (i.e., non-high humidity) walkin cooler display doors.
Issue 17: DOE seeks feedback on the
current EER values specified in
Appendix A used to calculate daily
energy consumption for walk-in doors
and the values used in testing of unit
coolers alone, as specified in Appendix
C. Specifically, DOE requests comment
on which of these sets of EER values is
more representative, whether DOE
should make the values used for door
testing and unit cooler testing consistent
with each other, and if so, which of the
sets of values should be used.
Issue 18: DOE requests comment on
how frequently test laboratories perform
each of the calibration procedures
referenced in ASTM C1199 and ASTM
C1363, e.g., those used to determine
calibration coefficients that are used to
calculate metering box wall loss and
surround panel flanking loss. DOE also
requests comment on the magnitude of
variation in the calibration coefficients
measured during successive
calibrations.
Issue 19: DOE requests feedback on
whether the tolerances in section
5.3(a)(1) of Appendix A applied to the
surface heat transfer coefficients used to
measure thermal transmittance are
achievable for all walk-in doors and if
not, whether the tolerances should be
increased or omitted. Specifically, DOE
seeks data to support any changes to the
tolerances on the surface heat transfer
coefficients.
Issue 20: DOE requests comment on
how panel thickness is currently
measured for determining the panel’s
R-value per the DOE test procedure,
including number of measurements,
measurement location, and any steps
that are routinely followed for the
removal of the protective skins or facers
to obtain the full panel thickness. DOE
requests that commenters identify any
specific guidelines, practices or
standardized approaches that are
followed, as well as their date of
publication, if applicable.
Issue 21: DOE requests comment on
how flatness and parallelism of the test
specimen surfaces that contact the hot
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plate assemblies described in ASTM
C518 are typically determined by test
laboratories and whether the test
procedure should be revised to clarify
how to determine these parameters, e.g.,
what type of instruments are used to
measure these values, how many
measurements are made for a given
specimen, and other details that could
affect conclusions regarding compliance
with the test procedure.
Issue 22: DOE requests comment on
the extent to which manufacturers of
insulation specify conditioning for
insulation materials that differ from the
typical conditioning approach described
in ASTM C518. DOE also seeks feedback
on whether more than one 24-hour
conditioning period is ever needed to
complete the conditioning (i.e., the
change in specimen mass is less than 1
percent after the first 24 hours of
conditioning) for a specimen extracted
from a WICF panel or door. Finally,
DOE requests information or data on
how specimen conditioning times less
than or equal to 24 hours impacts the
accuracy, repeatability, and
representativeness of the test.
Issue 23: DOE requests information
about panel construction factors that
would affect thermal transmission and
the magnitude of the energy efficiencyrelated impacts of thermal bridges in the
panel assembly. Additionally, DOE
requests comment on alternative test
methods that measure the overall
thermal transmittance of walk-in panels
and the relative advantages and
disadvantages of each. DOE also seeks
feedback on the number and location of
labs that have the facilities and are
qualified to run ASTM C1363–05.
Issue 24: DOE seeks feedback on the
current test procedure for display panels
in Appendix A and what amendments
should be made, if any, to it.
Issue 25: DOE requests comment on
whether the single-package system test
and calculation methods described in
AHRI 1250–2020 provide representative
energy use. DOE also requests comment
on whether DOE should incorporate by
reference AHRI 1250–2020 as the test
procedure for single-package systems.
Issue 26: DOE requests any data or
calculations quantifying the additional
thermal losses associated with testing
single-package systems due to the
exposure of their cold sides to the
exterior air (i.e., surface and infiltration
losses). DOE additionally requests
comment on whether the AHRI 1250–
2020 test methodology for singlepackage systems fully accounts for these
additional losses.
Issue 27: DOE requests comment and
data on the use of water, glycol, or other
heat transfer liquid in maintaining test
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compartment temperature using the
calorimeter methods referenced in AHRI
1250–2020 for the testing of singlepackage refrigeration systems. DOE
requests comment on whether the
description and requirements for
calorimetric testing as provided in AHRI
1250–2020 should be modified or
enhanced in order to better ensure that
measurements are accurate and
repeatable.
Issue 28: DOE requests comment on
whether calorimeter test methods for
single-package systems should
implement a pressure-equalizing device,
as included in ASHRAE 16–2016. DOE
requests information on any additional
cost and resource burdens, if any,
manufacturers would face when
employing these methods to evaluate
single-package systems.
Issue 29: DOE seeks comment
regarding any alternative test methods
not mentioned in this document that
could be used to measure single-package
system capacity. To the extent that any
alternative test methods could be used
for this purpose, DOE requests
information on their advantages and
disadvantages in measuring singlepackage system capacity.
Issue 30: DOE requests comment on
the alternative test procedure for wine
cellar walk-in refrigeration systems that
it has granted in the interim waivers and
waivers listed in Table II.3. DOE
additionally seeks comment on whether
the alternative test procedure prescribed
for the specified basic models identified
in the waivers would be appropriate for
similar refrigeration equipment.
Issue 31: DOE requests feedback on its
approach for testing ducted units in its
alternate test procedure for wine cellar
refrigeration systems. Specifically, DOE
requests comment and supporting data
on whether testing at 50 percent of
maximum ESP provides representative
performance values, or whether other
fractions of maximum ESP may be more
appropriate. Additionally, DOE seeks
comment on other industry test methods
that include the testing of ducted units.
Finally, DOE is interested in other
alternative approaches for testing
ducted units that have been
demonstrated to provide repeatable and
representative results.
Issue 32: DOE requests data and
information on appropriate EER values
for use in calculating AWEF for wine
cellar unit coolers tested alone, and how
these EER values might depend on
refrigerant and/or capacity. DOE
requests that commenters provide
background explanation regarding how
any such EER recommendations have
been developed.
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Issue 33: DOESince unit coolers for
wine cellar systems are sold alone, DOE
seeks information on the characteristics
of condensing units that would typically
be paired with these unit coolers (e.g.,
make/model, compressor style, capacity
range, manufacturers).
Issue 34: DOE seeks comment on
whether, and if so how, it should
modify its definitions for ‘‘singlepackaged dedicated system’’ and ‘‘unit
cooler’’ to address units that are
designed to be installed with ducts.
Issue 35: DOE requests comment on
any other issues regarding testing of
wine cellar refrigeration systems that
may not be fully addressed by the
current DOE test procedure.
Issue 36: DOE requests comment on
test conditions that would be most
appropriate for evaluating the energy
use of CO2 unit coolers. Additionally,
DOE requests feedback on any
additional changes that would need to
be made to the DOE test procedure to
accurately evaluate energy use of these
systems, while minimizing test burden.
Issue 37: DOE requests comment on
the present and future expected use of
walk-in refrigeration systems using CO2.
DOE requests specific information about
these systems that would suggest a need
to modify the DOE test procedure to
address such equipment. Specifically,
DOE requests information on whether
such equipment is sold in the U.S.,
whether this equipment is sold as
matched pairs or individual
components, and to what extent
dedicated condensing units are
configured to supply subcritical liquid
(rather than supercritical gas) to the unit
coolers.
Issue 38: DOE requests information
regarding potential methods of
providing a measurable frost load and
frost type for defrost testing, including
data and information demonstrating the
repeatability of such a test.
Additionally, DOE requests data and
information indicating what a typical
frost load and frost type would be—for
example, whether the moist air flow of
section C11.1.1 of AHRI 1250–2009
provides the appropriate amount of
moisture, and if so, whether any data
are available to support the use of this
quantity. If such data are available, DOE
asks that interested parties share it with
the agency for further consideration. If
such data are currently unavailable,
DOE is interested in what kind and
amount of testing would be needed to
sufficiently validate an appropriate
method to evaluate frost loads and frost
types during defrost testing.
Issue 39: DOE requests comment on
the specific refrigeration system
configurations (i.e., matched-pairs,
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stand-alone unit coolers, and standalone condensing units) to which a hot
gas defrost-specific test procedure
would apply. DOE requests comment on
which methods for determining energy
and heat load (i.e., testing, calculation,
or both) would be most appropriate for
each refrigeration system and why. DOE
requests comment on the methods
related to hot gas defrost systems in
AHRI 1250- 2020. Finally, DOE requests
data to help quantify the relationship
between hot gas defrost heat load
addition and energy consumption
versus capacity and/or to confirm the
relationships provided in the AHRI
1250–2020 test methods for hot gas
defrost.
Issue 40: DOE requests comment on
how the performance of adaptive defrost
systems should be accounted for in the
walk-in test procedure and which
refrigeration systems (i.e., matchedpairs, stand-alone unit coolers, and
stand-alone condensing units) should be
evaluated under a potential adaptive
defrost test procedure. Specifically, DOE
requests data showing the performance
of adaptive defrost systems relative to
non-controlled defrost systems,
including impacts to on-cycle operation.
DOE requests data demonstrating
seasonal and daily frosting patterns for
walk-in applications.
Issue 41: DOE requests information
and data on whether the off-cycle
methods included in AHRI 1250–2020
provide a representative and repeatable
measure of the off-cycle power use for
matched pairs, single-package systems,
and also for unit coolers and/or
condensing units tested alone, and if
not, what modifications are
recommended. DOE also seeks
information on other off-cycle mode
energy-consuming components that are
not currently addressed by AHRI 1250–
2020. In addition to identifying all offcycle mode energy-consuming
components, DOE seeks information on
the patterns and magnitudes of energy
use by each of these components during
the off-cycle.
Issue 42: DOE requests input on the
development of test methods that would
more accurately measure the energy use
performance—including accounting for
the potential efficiency benefits of
multi- and variable-capacity systems—
both for matched-pair and stand-alone
condensing unit testing. DOE seeks data
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and information showing the potential
magnitude of energy savings by
reducing cycling losses in these multi
and variable-capacity systems. DOE
requests market information on whether
there are multi- and variable-capacity
condensing units available on the
market (in addition to those already
identified) and the brand name(s) and
model numbers of those additional
units.
Issue 43: DOE requests feedback on
the three approaches discussed in this
section to address high-temperature
freezer walk-ins, as well as any other
potential approaches not raised in this
RFI.
Issue 44: DOE also requests
information that would help inform the
development of test procedures for hightemperature freezer refrigeration
systems, should such an approach be
necessary. Additionally, DOE requests
whether there are specific
characteristics that distinguish a hightemperature freezer refrigeration system
from a medium-temperature
refrigeration system, in order to better
define this category of equipment.
Issue 45: DOE also requests comment
on whether 10 °F is the appropriate
lowest end of the application range for
equipment used in walk-in hightemperature freezers that cannot be
tested using the ¥10 °F freezer test
condition. Furthermore, DOE requests
comment on whether all mediumtemperature systems (matched-pair,
condensing unit, evaporator) can be
operated and tested at 10 °F (or
equivalent refrigerant suction
conditions), or whether there is a wide
range at the low-end of the operating
range that depends on the design of the
system.
Issue 46: Regarding the testing of a
medium-temperature refrigeration
system in the high-temperature freezer
range, DOE requests information on
what specified test procedure
parameters would need to be altered
(and how) in order for the test to be
representative of field operation. (In
answering, DOE requests that
commenters provide the supporting
reasons for any suggested
recommendations.) DOE requests
information on whether a single
standardized high-temperature freezer
room condition could be appropriate for
testing this group of walk-ins, and if so,
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32355
what such an appropriate temperature
would be.
Issue 47: Finally, DOE requests
comment on what, if any, changes
would be needed in the calculation of
AWEF for high-temperature freezer
operation, and why.
Issue 48: DOE requests comment on
the appropriateness of using the current
medium-temperature refrigeration
system default fan input power equation
(found at section 3.4.2.2 of Appendix C)
to represent the fan input power of hightemperature freezer refrigeration
systems. If the current mediumtemperature refrigeration system default
fan input power equation is not
representative of the fan input power for
high-temperature freezer refrigeration
systems, DOE requests suggestions for a
more appropriate equation, or
alternative relationships to consider, as
well as any relevant data.
Issue 49: DOE requests information or
data that would indicate whether and
how the equations used to calculate
daily defrost energy use and heat
addition in the test procedure should be
modified for high-temperature freezer
refrigeration systems rated as standalone condensing units (e.g., defrost
heater wattage and daily energy use as
a function of capacity for a 10 °F walkin temperature). If testing at the lowest
application temperature is adopted,
DOE requests comment on how the
defrost equations should be modified to
account for each model being tested at
different conditions, and why. DOE
requests information on whether frost
loads and/or defrost frequency are
different for high-temperature freezers
than for ¥10 °F freezers. (DOE requests
that commenters include any available
supporting information when
responding.)
Issue 50: DOE requests comment on
the appropriateness of specifying
refrigerant temperatures in terms of
mid-point or a modified mid-point,
rather than dew point, which is
currently used. DOE seeks feedback on
potential definitions to use for a
modified mid-point temperature as
applied to WICF refrigeration system
testing. In addition, DOE requests
comments on what other factors should
be considered when modifying the
refrigeration system test conditions from
dew point to mid-point or modified
mid-point specifications.
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Federal Register / Vol. 86, No. 115 / Thursday, June 17, 2021 / Proposed Rules
lotter on DSK11XQN23PROD with PROPOSALS2
Signing Authority
This document of the Department of
Energy was signed on June 3, 2021, by
Kelly Speakes-Backman, Principal
Deputy Assistant Secretary and Acting
Assistant Secretary for Energy Efficiency
and Renewable Energy, pursuant to
delegated authority from the Secretary
of Energy. That document with the
original signature and date is
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Jkt 253001
maintained by DOE. For administrative
purposes only, and in compliance with
requirements of the Office of the Federal
Register, the undersigned DOE Federal
Register Liaison Officer has been
authorized to sign and submit the
document in electronic format for
publication, as an official document of
the Department of Energy. This
administrative process in no way alters
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the legal effect of this document upon
publication in the Federal Register.
Signed in Washington, DC, on June 4,
2021.
Treena V. Garrett,
Federal Register Liaison Officer, U.S.
Department of Energy.
[FR Doc. 2021–12081 Filed 6–16–21; 8:45 am]
BILLING CODE 6450–01–P
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Agencies
[Federal Register Volume 86, Number 115 (Thursday, June 17, 2021)]
[Proposed Rules]
[Pages 32332-32356]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-12081]
[[Page 32331]]
Vol. 86
Thursday,
No. 115
June 17, 2021
Part II
Department of Energy
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10 CFR Part 431
Energy Conservation Program: Test Procedures for Certain Commercial and
Industrial Equipment; Early Assessment Review: Walk-In Coolers and
Freezers; Proposed Rule
Federal Register / Vol. 86, No. 115 / Thursday, June 17, 2021 /
Proposed Rules
[[Page 32332]]
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DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE-2017-BT-TP-0010]
RIN 1904-AD78
Energy Conservation Program: Test Procedures for Certain
Commercial and Industrial Equipment; Early Assessment Review: Walk-In
Coolers and Freezers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Request for information.
-----------------------------------------------------------------------
SUMMARY: The U.S. Department of Energy (``DOE'') is undertaking an
early assessment review to determine whether amendments are warranted
for the test procedures for walk-in coolers and walk-in freezers
(``WICFs'' or ``walk-ins''). DOE has identified certain issues
associated with the currently applicable test procedures on which DOE
is interested in receiving comment. The issues outlined in this
document address definitions and equipment classes of walk-in
components, test procedure waivers received, and other test procedure
issues related to walk-in doors, panels, and refrigeration systems. DOE
welcomes written comments from the public on any subject within the
scope of this document, including topics not raised in this request for
information (``RFI'').
DATES: Written comments and information are requested and will be
accepted on or before July 19, 2021.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at https://www.regulations.gov. Follow
the instructions for submitting comments. Alternatively, interested
persons may submit comments by email to the following address:
[email protected]. Include docket number EERE-2017-BT-TP-0010
and/or RIN number 1904-AD78 in the subject line of the message. Submit
electronic comments in WordPerfect, Microsoft Word, PDF, or ASCII file
format, and avoid the use of special characters or any form of
encryption. No telefacsimiles (faxes) will be accepted. For detailed
instructions on submitting comments and additional information on the
rulemaking process, see section III (Submission of Comments) of this
document.
Although DOE has routinely accepted public comment submissions
through a variety of mechanisms, including postal mail and hand
delivery/courier, the Department has found it necessary to make
temporary modifications to the comment submission process in light of
the ongoing Covid-19 pandemic. DOE is currently accepting only
electronic submissions at this time. If a commenter finds that this
change poses an undue hardship, please contact Appliance Standards
Program staff at (202) 586-1445 to discuss the need for alternative
arrangements. Once the Covid-19 pandemic health emergency is resolved,
DOE anticipates resuming all of its regular options for public comment
submission, including postal mail and hand delivery/courier.
Docket: The docket for this activity, which includes Federal
Register notices, comments, and other supporting documents/materials,
is available for review at https://www.regulations.gov. All documents
in the docket are listed in the https://www.regulations.gov index.
However, some documents listed in the index, such as those containing
information that is exempt from public disclosure, may not be publicly
available.
The docket web page can be found at: https://www.regulations.gov/#!docketDetail;D=EERE-2017-BT-TP-0010. The docket web page contains
instructions on how to access all documents, including public comments,
in the docket. See section III of this document for information on how
to submit comments through https://www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Dr. Stephanie Johnson, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Office, EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone:
(202) 287-1943. Email: [email protected].
Mr. Michael Kido, U.S. Department of Energy, Office of the General
Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121.
Telephone: (202) 586-8145. Email: [email protected].
For further information on how to submit a comment or review other
public comments and the docket, contact the Appliance and Equipment
Standards Program staff at (202) 287-1445 or by email:
[email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
A. Authority
B. Rulemaking History
II. Request for Information
A. Scope and Definitions
1. Walk-In Refrigeration Systems
2.Walk-In Doors
B. Industry Test Standards
1. NFRC 100 and NFRC 102
2. ASTM C518
3. AHRI 1250
C. Test Procedure for Walk-In Doors
1. Surface Area Used for Determining Compliance With Standards
2. Thermal Transmittance Area
3. Electrical Door Components
4. EER Values To Convert Thermal Load to Energy Consumption
5. Thermal Transmittance
a. Calibration of Hot Box for Measuring U-Factor
b. Tolerances of Surface Heat Transfer Coefficients
6. Air Infiltration Reduction
D. Test Procedure for Walk-In Panels
1. Panel Thickness
2. Parallelism and Flatness
3. Specimen Conditioning
4. Overall Thermal Transmittance
5. Display Panels
E. Test Procedure for Walk-In Refrigeration Systems
1. Single-Package Systems
a. Calorimeter Method
2. Wine Cellar Refrigeration Systems
3. CO2 Systems
4. Defrost Test Method
a. Moisture Addition
b. Hot Gas Defrost
c. Adaptive Defrost
5. Off-Cycle Energy Use
6. Multi-Capacity and Variable-Capacity Condensing Units
7. Systems for High-Temperature Freezer Applications
8. Consideration for Refrigerant Glide
III. Submission of Comments
IV. Issues on Which DOE Seeks Comment
I. Introduction
DOE established an early assessment review process to conduct a
more focused analysis that would allow DOE to determine, based on
statutory criteria, whether an amended test procedure is warranted. 10
CFR 431.4; 10 CFR part 430 subpart C appendix A section 8(a). This RFI
requests information and data regarding whether an amended test
procedure would more accurately and fully comply with the requirement
that the test procedure produce results that measure energy use during
a representative average use cycle for the equipment, and not be unduly
burdensome to conduct. To inform interested parties and to facilitate
this process, DOE has identified several issues associated with the
currently applicable test procedures on which DOE is interested in
receiving comment. Based on the information received in response to the
RFI and DOE's own analysis, DOE will determine whether to proceed with
a rulemaking for an amended test procedure.
If DOE makes an initial determination that an amended test
procedure would
[[Page 32333]]
more accurately or fully comply with statutory requirements, or DOE's
analysis is inconclusive as to whether amendments are warranted, DOE
would undertake a rulemaking to issue an amended test procedure. If DOE
makes an initial determination based upon available evidence that an
amended test procedure would not meet the applicable statutory
criteria, DOE would engage in notice and comment rulemaking before
issuing a final determination that an amended test procedure is not
warranted.
A. Authority
The Energy Policy and Conservation Act, as amended (``EPCA''),\1\
authorizes DOE to regulate the energy efficiency of a number of
consumer products and certain industrial equipment. (42 U.S.C. 6291-
6317) Title III, Part C \2\ of EPCA, added by Public Law 95-619, Title
IV, section 441(a) (42 U.S.C. 6311-6317 as codified), established the
Energy Conservation Program for Certain Industrial Equipment, which
sets forth a variety of provisions designed to improve energy
efficiency. This equipment includes walk-in coolers and freezers
(collectively, ``walk-ins'' or ``WICFs''), the subject of this
document. (42 U.S.C. 6311(1)(G))
---------------------------------------------------------------------------
\1\ All references to EPCA in this document refer to the statute
as amended through the Energy Act of 2020, Public Law 116-260 (Dec.
27, 2020).
\2\ For editorial reasons, upon codification in the U.S. Code,
Part C was redesignated Part A-1.
---------------------------------------------------------------------------
Under EPCA, DOE's energy conservation program consists essentially
of four parts: (1) Testing, (2) labeling, (3) Federal energy
conservation standards (``ECS''), and (4) certification and enforcement
procedures. Relevant provisions of EPCA include definitions (42 U.S.C.
6311), test procedures (42 U.S.C. 6314), labeling provisions (42 U.S.C.
6315), energy conservation standards (42 U.S.C. 6313), and the
authority to require information and reports from manufacturers (42
U.S.C. 6316).
Federal energy efficiency requirements for covered equipment
established under EPCA generally supersede State laws and regulations
concerning energy conservation testing, labeling, and standards. (42
U.S.C. 6316(a) and (b); 42 U.S.C. 6297) DOE may, however, grant waivers
of Federal preemption in limited instances for particular State laws or
regulations, in accordance with the procedures and other provisions set
forth under 42 U.S.C. 6316(b)(2)(D).
EPCA also requires that, at least once every 7 years, DOE evaluate
test procedures for each type of covered equipment, including walk-in
coolers and freezers, to determine whether amended test procedures
would more accurately or fully comply with the requirements for the
test procedures to not be unduly burdensome to conduct and be
reasonably designed to produce test results that reflect energy
efficiency, energy use, and estimated operating costs during a
representative average use cycle. (42 U.S.C. 6314(a)(1)) DOE is
publishing this RFI to collect data and information to inform its
decision to satisfy the 7-year-lookback review requirement.
B. Rulemaking History
DOE has established test procedures to measure walk-in energy use,
establishing separate test procedures for the principal components that
make up a walk-in (i.e., doors, panels, and refrigeration systems) with
separate test metrics for each component. 10 CFR 431.304(b). For walk-
in doors and display panels, the efficiency metric is daily energy
consumption, measured in kilowatt-hours per day (``kWh/day''), which
accounts for the thermal conduction through the door or display panel
and the direct and indirect electricity use of any electrical
components associated with the door. 10 CFR 431.304(b)(1)-(2) and 10
CFR part 431, subpart R, appendix A, ``Uniform Test Method for the
Measurement of Energy Consumption of the Components of Envelopes of
Walk- In Coolers and Walk-In Freezers'' (``Appendix A'').
For walk-in non-display panels and non-display doors, DOE codified
in the Code of Federal Regulations (``CFR'') prescriptive standards
established in EPCA based on R-value, expressed in units of (h-ft\2\-
[deg]F/Btu),\3\ which is calculated as 1/K multiplied by the thickness
of the panel.\4\ 10 CFR 431.304(b)(3) and 10 CFR part 431 subpart R,
appendix B, titled ``Uniform Test Method for the Measurement of R-Value
for Envelope Components of Walk-In Coolers and Walk-In Freezers''
(``Appendix B''). (See also, 42 U.S.C. 6314(a)(9)(A)) The K factor is
calculated based on American Society for Testing and Materials
(``ASTM'') C518, ``Standard Test Method for Steady-State Thermal
Transmission Properties by Means of the Heat Flow Meter Apparatus''
(``ASTM C518''), which is incorporated by reference. Id.
---------------------------------------------------------------------------
\3\ The R-value is the capacity of an insulated material to
resist heat-flow. See 42 U.S.C. 6313(f)(1)(C) for the EPCA R-value
requirements for non-display panels and doors.
\4\ The K factor represents the thermal conductivity of a
material, or its ability to conduct heat, in units of Btu-in/(h-
ft\2\-[deg]F).
---------------------------------------------------------------------------
For walk-in refrigeration systems, the efficiency metric is Annual
Walk-in Energy Factor (``AWEF''), which is determined by conducting the
test procedure set forth in American National Standards Institute
(``ANSI'')/Air-Conditioning, Heating, and Refrigeration Institute
(``AHRI'') Standard 1250P (I-P), ``2009 Standard for Performance Rating
of Walk-In Coolers and Freezers,'' (``AHRI 1250-2009''), with certain
adjustments specified in the CFR. 10 CFR 431.304(b)(4) and 10 CFR part
431 subpart R, appendix C, ``Uniform Test Method for the Measurement of
Net Capacity and AWEF of Walk-In Cooler and Walk-In Freezer
Refrigeration Systems'' (``Appendix C''). A manufacturer may also
determine AWEF using an alternative efficiency determination method
(``AEDM''). 10 CFR 429.53(a)(2)(iii). An AEDM enables a manufacturer to
utilize computer-based or mathematical models for purposes of
determining an equipment's energy use or energy efficiency performance
in lieu of testing, provided certain prerequisites have been met. 10
CFR 429.70(f).
On August 5, 2015, DOE published its intention to establish a
Working Group under the Appliance Standards and Rulemaking Federal
Advisory Committee (``ASRAC'') to negotiate energy conservation
standards to replace the standards established in the final rule
published on June 3, 2014 (``June 2014 ECS final rule''). 80 FR 46521
(August 5, 2015). The Working Group assembled its recommendations into
a Term Sheet \5\ (Docket EERE-2015-BT-STD-0016, No. 56) that was
presented to, and approved by, ASRAC on December 18, 2015 (``Term
Sheet'').
---------------------------------------------------------------------------
\5\ Appliance Standards and Rulemaking Federal Advisory
Committee Refrigeration Systems Walk-in Coolers and Freezers Term
Sheet, available at https://www.regulations.gov/document?D=EERE-2015-BT-STD-0016-0056.
---------------------------------------------------------------------------
The Term Sheet provided recommendations for energy conservation
standards to replace standards that had been vacated by the United
States Court of Appeals for the Fifth Circuit in a controlling order
issued August 10, 2015. It also included recommendations regarding
definitions for a number of terms related to the WICF regulations, as
well as recommendations to amend the test procedure that the Working
Group viewed as necessary to properly implement the energy conservation
standards recommendations. Consequently, DOE initiated both an energy
conservation standards rulemaking and a test procedure rulemaking in
2016 to implement these
[[Page 32334]]
recommendations. The Term Sheet also included recommendations for
future amendments to the test procedure intended to make DOE's test
procedure more fully representative of walk-in energy use.
On December 28, 2016, DOE published a final rule amending the test
procedure (``December 2016 TP final rule''), consistent with the Term
Sheet recommendations and provisions to facilitate implementation of
energy conservation standards for walk-in components. 81 FR 95758.
Subsequently, on July 10, 2017, DOE published a final rule amending the
energy conservation standards for WICF refrigeration systems (``July
2017 ECS final rule''). 82 FR 31808.
To address Term Sheet recommendations regarding hot gas defrost,
DOE published a final rule for hot gas defrost unit coolers on March
26, 2021 (``March 2021 hot gas defrost TP final rule'') that amended
the test procedure to rate hot gas defrost unit coolers using modified
default values for energy use and heat load contributions that would
make their ratings more consistent with those of electric defrost unit
coolers. 86 FR 16027.
II. Request for Information
DOE is publishing this RFI to collect data and information during
the early assessment review to inform its decision, consistent with its
obligations under EPCA, as to whether the Department should proceed
with an amended test procedure rulemaking and if so, to assist in the
development of proposed amendments. Accordingly, in the following
sections, DOE has identified specific issues on which it seeks input to
aid in its analysis of whether an amended test procedure for walk-in
coolers and freezers would more accurately or fully comply with the
requirement that the test procedure produces results that measure
energy use during a representative average use cycle for the equipment,
and not be unduly burdensome to conduct. DOE also welcomes comments on
other issues relevant to its early assessment that may not specifically
be identified in this document.
A. Scope and Definitions
This RFI covers equipment meeting the ``walk-in cooler and walk-in
freezer'' definition codified in 10 CFR 431.302: An enclosed storage
space refrigerated to temperatures (1) above 32 [deg]F for walk-in
coolers and (2) at or below 32 [deg]F for walk-in freezers, that can be
walked into, and has a total chilled storage area of less than 3,000
square feet, but excluding equipment designed and marketed exclusively
for medical, scientific, or research purposes. 10 CFR 431.302. (See
also 42 U.S.C. 6311(20)) In addition to the prescriptive requirements
for walk-ins established by EPCA (42 U.S.C. 6313(f)(3)(A)-(D)) and
codified at 10 CFR 431.306(a)-(b), DOE established performance-based
energy conservation standards for doors and refrigeration systems. 10
CFR 431.306(c)-(e).
1. Walk-In Refrigeration Systems
DOE is aware of equipment that would appear to meet the walk-in
definition and for which there is no current DOE test procedure or
energy conservation standard. DOE indicated in a public meeting on
October 22, 2014 that the WICF test procedures and standards did not
apply to water-cooled condensing units or systems. (Docket EERE-2011-
BT-TP-0024, No. 109 \6\ at p. 11) DOE notes that the EPCA definition
for walk-ins makes no distinction on how the condenser is cooled. (42
U.S.C. 6311(20)(A))
---------------------------------------------------------------------------
\6\ Details of Executing the Test Procedures for Refrigeration
Systems use in Walk-in Coolers and Freezers, available at https://www.regulations.gov/document?D=EERE-2011-BT-TP-0024-0109.
---------------------------------------------------------------------------
The current DOE test procedure for walk-in refrigeration systems,
which incorporates by reference AHRI 1250-2009, does not address how to
test liquid-cooled systems. Additionally, liquid-cooled condensing
units are outside the scope of the most recent version of AHRI 1250,
AHRI 1250-2020. Liquid-cooled condensing units for walk-ins are readily
available for a wide range of capacities and refrigerants from major
walk-in refrigeration system manufacturers. (See for example, Airdyne
W-series indoor units (water-cooled), and Russell (water-cooled,
glycol-cooled) (see Docket No. EERE-2017-BT-TP-0010-0001, Docket No.
EERE-2017-BT-TP0010-0002, and Docket No. EERE-2017-BT-TP-0010-0003).
Issue 1: DOE seeks comment on how liquid-cooled refrigeration
systems are (or could be) used with respect to walk-in applications.
DOE requests comment on whether it should consider establishing a test
procedure for liquid-cooled refrigeration systems. If test procedures
were considered for liquid-cooled refrigeration systems, DOE requests
information on whether there is an industry standard or standards that
should be considered.
DOE is considering modifying the current equipment class
definitions for refrigeration systems, which are based on walk-in
application temperature. In the June 2014 ECS final rule, DOE
established equipment classes for medium- and low- temperature walk-in
refrigeration systems. 79 FR 32050, 32069-32070. While the terms
``medium-temperature'' and ``low-temperature'' are not explicitly
defined, the June 2014 ECS final rule, 2015 ASRAC negotiations,
December 2016 TP final rule, and July 2017 ECS final rule all
consistently used the term ``medium-temperature'' to refer to walk-in
cooler refrigeration systems and the term ``low-temperature'' to refer
to walk-in freezer refrigeration systems.
Rating conditions are 35 [deg]F for cooler systems and -10 [deg]F
for freezer systems. DOE acknowledges that there are ``medium-
temperature'' systems designed to operate between these two rating
conditions, specifically between 10 [deg]F and 32 [deg]F. However, the
EPCA definitions for walk-in freezers and walk-in coolers draws the
line between them at 32 [deg]F, thus classifying such refrigeration
systems as freezer refrigeration systems. DOE is considering whether
equipment definitions and requirements should be amended to address
these systems, which are discussed in detail in Section II.E.7.
Finally, DOE is considering defining walk-in wine cellar
refrigeration systems. These systems are typically designed to provide
a cold environment at a temperature range between 45-65 [deg]F with 50-
70 percent relative humidity (``RH''), and typically are kept at 55
[deg]F and 55 percent RH rather than the 35 [deg]F and less than 50
percent RH test condition prescribed by the DOE test procedure.
Operating a wine cellar at the 35 [deg]F condition would adversely
mechanically alter the intended performance of the system, which would
include icing of the evaporator coil that could potentially damage the
compressor, and would not result in an accurate representation of the
performance of the cooling unit. To distinguish walk-in wine-cellar
refrigeration systems from other walk-in cooler systems, DOE is
considering whether to specify 45 [deg]F as the minimum temperature at
which a walk-in wine cellar refrigeration system can effectively
operate. If DOE were to specify a minimum operating temperature, DOE
would need to develop a definition specific for products that operate
in this temperature region. Walk-in wine cellar refrigeration systems
are discussed in more detail in Section II.E.2.
Issue 2: DOE seeks comment on how wine cellar refrigeration systems
should be defined to best represent the conditions under which these
systems
[[Page 32335]]
are designed to operate and to fully distinguish these systems from
systems designed to meet safe food storage requirements. Additionally,
DOE requests comment on applications other than wine cellar storage for
refrigeration systems that are designed to operate at temperatures
warmer than typical for coolers and for which testing at 35 [deg]F
would be representative of use. If there are such additional
applications, DOE seeks information regarding the specific operating
requirements (i.e., temperature and humidity) for these systems.
2. Walk-In Doors
DOE is also reviewing the definitions applicable to WICF doors. DOE
defines a ``door'' as an assembly installed in an opening on an
interior or exterior wall that is used to allow access or close off the
opening and that is movable in a sliding, pivoting, hinged, or
revolving manner of movement. For walk-in coolers and walk-in freezers,
a door includes the door panel, glass, framing materials, door plug,
mullion, and any other elements that form the door or part of its
connection to the wall. 10 CFR 431.302. DOE is interested in using
language that is consistent across the walk-in door industry to define
a door.
Issue 3: DOE requests comment on the current definition of ``door''
in 10 CFR 431.302. DOE seeks feedback on the terminology of door
components used and whether these are consistently interpreted. DOE
seeks specific feedback from manufacturers on how they use the term
``door plug'' and whether it is essential to the definition of a WICF
``door''.
DOE differentiates WICF doors by whether such doors are ``display
doors'' or not display doors. A ``display door'' is defined as a door
that: (1) Is designed for product display; or (2) has 75 percent or
more of its surface area composed of glass or another transparent
material. 10 CFR 431.302. WICF doors that are not display doors are
differentiated according to whether they are ``freight doors'' or
``passage doors.'' A ``freight door'' is a door that is not a display
door and is equal to or larger than 4 feet wide and 8 feet tall. Id. A
``passage door'' is a door that is not a freight or display door. Id.
The use of dimensions in the definition of freight door conveys
that these doors are intended for large machines (e.g., forklifts) to
pass through carrying freight. However, the definition does not
explicitly provide whether classification as a freight door occurs when
one of the dimensions exceeds the dimension provided in the definition,
but the other dimension is smaller than the dimension provided in the
definition. For such doors, in some cases the surface area could be
larger than 32 square feet, the area of a 4-foot by 8-foot door
provided in the definition (e.g., a door 5 feet wide and 7 feet tall,
with a surface area of 35 square feet); in other cases, the surface
area could be smaller than 32 square feet (e.g., a door 5 feet wide and
6 feet tall, with a surface area of 30 square feet). DOE reviewed the
surface area of certified freight and passage doors in DOE's Compliance
Certification Management System (``CCMS'') Database.\7\ Among 1,114
unique individual models \8\ of freight doors, 44 unique individual
models have a surface area less than 32 square feet. These models
appear to have been classified on the understanding that a door is a
freight door if just one dimension is larger than the dimensions
specified in the freight door definition. Among 1,540 unique individual
models of passage doors, 789 unique individual models have a surface
area greater than or equal to 32 square feet.\9\ These models either
are multi-door configurations, or they have been classified assuming
that to be a freight door, both dimensions must be equal to or exceed
the dimensions in the freight door definition. DOE further notes that
the standards for each class of WICF doors are a function of surface
area, and that different standards apply for freight doors and passage
doors. DOE seeks information that would inform any potential revision
of the door definitions, particularly ``freight door'' and ``passage
door,'' to improve their clarity and ensure that there is no overlap
between these definitions.
---------------------------------------------------------------------------
\7\ Data from the DOE CCMS database was accessed on March 6,
2020. This database can be found at https://www.regulations.doe.gov/certification-data/.
\8\ Unique individual models exclude any duplicate entries using
the same individual model number.
\9\ DOE understands that some certified passage doors may
represent multi-door configurations in which the individual
component doors each have a surface area of less than 32 square
feet.
---------------------------------------------------------------------------
Issue 4: DOE requests comment on whether height and width or
surface area are distinct attributes that effectively distinguish
between passage and freight doors. DOE seeks information on any
building codes, standards, or industry practices to support or refute
maintaining the dimensions of a door as the defining characteristic
which separates freight and passage doors.
Issue 5: Regarding a door that meets the freight door definition
but does so only because it has a multi-door configuration in which the
individual component doors each would by themselves not meet the
freight door definition, DOE seeks comment on how such doors should be
classified, and whether such classification should depend on other
factors, such as whether one or more frame members divides the door
opening into smaller openings.
Issue 6: DOE seeks comment on whether any attribute, or combination
of attributes, other than size, would affect energy use and could be
used to distinguish between freight doors and passage doors. If so, DOE
requests data and comment on such attributes.
B. Industry Test Standards
The current DOE test procedure for walk-in coolers and freezers
incorporates the following industry test standards: NFRC 100 \10\ into
Appendix A; ASTM C518-04 \11\ into Appendix B; and AHRI 1250-2009 \12\,
AHRI 420-2008 \13\ and ASHRAE 23.1-2010 \14\ into Appendix C.
---------------------------------------------------------------------------
\10\ National Fenestration Rating Council (``NFRC'') 100-2010,
``Procedure for Determining Fenestration U-factors'' (``NFRC 100'').
\11\ American Society for Testing and Materials (``ASTM'') C518-
04, ``Standard Test Method for Steady-State Thermal Transmission
Properties by Means of the Heat Flow Meter Apparatus'' (``ASTM C518-
04'').
\12\ American National Standards Institute (``ANSI'')/Air-
Conditioning, Heating, and Refrigeration Institute (``AHRI'')
Standard 1250P (I-P), ``2009 Standard for Performance Rating of
Walk-In Coolers and Freezers'' (``AHRI 1250-2009'').
\13\ AHRI 420-2008, ``Performance Rating of Forced-Circulation
Free-Delivery Unit Coolers for Refrigeration'' (``AHRI 420-2008'').
\14\ ANSI/ASHRAE 23.1-2010, ``Methods of Testing for Rating the
Performance of Positive Displacement Refrigerant Compressors and
Condensing Units that Operate at Subcritical Temperatures of the
Refrigerant'' (``ASHRAE 23.1-2010'').
---------------------------------------------------------------------------
1. NFRC 100 and NFRC 102
Appendix A requires manufacturers to determine door thermal
transmittance according to NFRC 100. See Appendix A, Section 5.3. NFRC
100 includes a computational method to determine the thermal
transmittance for a product line of doors if simulated results meet the
validation requirements specified in NFRC 100. This approach may be
less costly but generally may result in a higher, more conservative
thermal transmittance value than the thermal transmittance value
determined by testing each door. Section 4.3.2 of NFRC 100 provides a
method for physically testing the thermal transmittance of walk-in
doors by referencing NFRC 102, ``Procedure for Measuring the Steady-
State Thermal Transmittance of Fenestration Systems'' (``NFRC 102'').
DOE is considering explicitly incorporating by reference NFRC 102 as
[[Page 32336]]
the test method for determining the thermal transmittance of walk-in
doors in place of NFRC 100 and adopting AEDM provisions for walk-in
display and non-display doors to replace the computational methodology
in NFRC 100.
Issue 7: DOE requests comment on the accuracy of the computational
method in NFRC 100 to predict U-factor for display and non-display
doors. DOE seeks feedback regarding the differences in results (if any)
between those obtained using the NFRC 100 computational method and
those obtained when conducting physical testing using NFRC 102 for
display and non-display doors. DOE is also interested in the magnitude
of these differences and whether the computational method can be
modified to yield results that more closely match the results obtained
from actual physical testing. If manufacturers are aware of other
methods to predict U-factor for either display doors or non-display
doors besides NFRC 100, DOE requests how the results from these methods
compare to physical testing.
Issue 8: DOE seeks information from manufacturers and other
interested parties regarding how the industry currently rates
individual door models, including the prevalence within the industry of
using the computational method from NFRC 100. DOE also requests
information on the costs associated with the computational method of
NFRC 100 or an alternative computational method compared to physically
testing the thermal transmittance of walk-in doors using NFRC 102.
2. ASTM C518
Currently, section 4.2 of Appendix B references ASTM C518 to
determine the thermal conductivity of panel insulation (the ``K
factor''). EPCA requires that the measurement of the K factor used to
calculate the R-value ``be based on ASTM test procedure C518-2004.''
(42 U.S.C. 6314(a)(9)(A)(ii)) In December 2015, ASTM published a
revision of this standard (``ASTM C518-15''). ASTM C518-15 removed
references to ASTM Standard C1363, ``Test Method for Thermal
Performance of Building Materials and Envelope Assemblies by Means of a
Hot Box Apparatus'' (``ASTM C1363''), and added references to ASTM
Standard E456, ``Terminology Relating to Quality and Statistics''.
Additionally, ASTM C518-15 relies solely on the International System of
Units (``SI units''), with paragraph 1.13 clarifying that these SI unit
values are to be regarded as standard.
In July 2017, ASTM published another revision of ASTM C518 (``ASTM
C518-17''). ASTM C518-17 added a summary of precision statistics from
an interlaboratory study from 2002-2004 in section 10 ``Precision and
Bias''. DOE has initially determined that the changes made in 2015 and
2017 to ASTM C518 do not substantively change the test method and,
therefore, DOE is considering specifying ASTM C518-17 as the referenced
test procedure in Appendix B. If DOE makes this change as part of a
test procedure rulemaking, it would also consider any changes necessary
to ensure rounding consistency when converting the output of ASTM C518-
17 from SI units to English units.
Issue 9: DOE requests comment on what issues, if any, would be
present if ASTM C518-17 were to be referenced in the Appendix B test
procedure for measuring panel K-factor, or average thermal
conductivity. While not exhaustive, primary areas of interest to DOE
include any differences between the currently referenced version of the
industry standard (ASTM C518-04) and ASTM C518-17 that would result in
a difference in the determined R-value and/or test burden (whether an
increase or decrease), and if there are such differences, the magnitude
of impact to the determined R-value and/or test burden.
3. AHRI 1250
The current DOE test procedures for walk-in refrigeration systems
incorporate by reference AHRI 1250-2009. 10 CFR 431.303(b)(2). AHRI
1250-2009 provides test methods for determination of performance for
matched pair refrigeration systems consisting of a unit cooler and a
condensing unit, or for the individual unit cooler or condensing unit
alone.\15\ In 2014, AHRI published a revision to this standard (``AHRI
1250-2014''). AHRI 1250-2014 primarily aligned the test standard for
consistency with the DOE test procedure, e.g. specifying that unit
coolers be tested using 25 [deg]F saturated suction temperature for
refrigerator unit coolers and -20 [deg]F for freezer unit coolers.
---------------------------------------------------------------------------
\15\ A split-system refrigeration system consists of two
separate components: A unit cooler that is installed inside a walk-
in enclosure, and a condensing unit, which is installed outside the
enclosure, either inside a building in which the walk-in is
constructed, or outdoors.
---------------------------------------------------------------------------
AHRI again published a revision to the standard in April 2020
(``AHRI 1250-2020''). AHRI 1250-2020 includes many updates, including
(a) providing complete instructions for testing of unit coolers alone
instead of incorporating by reference AHRI 420, (b) providing complete
instructions for testing of condensing units alone instead of
incorporating by reference ASHRAE 23.1-2010, (c) revision of instrument
accuracy and test tolerances, (d) adding test methods for testing of
single-package systems, (e) modified correlations for default
evaporator fan power, defrost thermal load, and defrost energy use for
use when testing condensing units alone, (f) correlations for defrost
thermal load and energy use for use when testing hot gas defrost
systems, (g) measurement of all relevant off-cycle energy use,
including compressor crankcase heater energy use, and (h) methods to
verify whether a refrigeration system has hot gas defrost and/or
adaptive defrost capabilities.
DOE may consider incorporating by reference AHRI 1250-2020 as the
test method for walk-in refrigeration systems.
Issue 10: DOE requests comment on what issues, if any, would be
present if AHRI 1250-2020 were to be referenced in the Appendix C test
procedure for measuring walk-in refrigeration system AWEF. While not
exhaustive, primary areas of interest to DOE include any differences
between the currently referenced version of the industry standard (AHRI
1250-2009) and AHRI 1250-2020 that would result in a difference in the
determined AWEF and/or test burden (whether an increase or decrease),
and if there are such differences, the magnitude of impact to the
determined AWEF and/or test burden.
C. Test Procedure for Walk-In Doors
In the following subsections, DOE discusses several topics specific
to walk-in doors that may affect the test procedure's ability to
provide results that are more fully representative of walk-in door
energy use during an average use cycle. In particular, the discussion
focuses on: (a) The distinction between the surface area used for
determining maximum energy consumption and the surface area used to
calculate thermal transmittance; (b) walk-in door electrical
components, such as motors, that may require specific consideration in
the test procedure; (c) assumptions of refrigeration system energy
efficiency ratio (``EER'') for calculating energy use associated with
the thermal loads of walk-in doors; (d) calibrations of the hot box
used for determining thermal transmittance (also referred to as ``U-
factor''); (e) maintaining tolerances on heat transfer coefficients for
U-factor tests; and (f) measuring and accounting for air infiltration.
[[Page 32337]]
1. Surface Area Used for Determining Compliance With Standards
The surface area of display doors and non-display doors (designated
as Add and And, respectively) are used to determine maximum energy
consumption in kWh/day of a walk-in door. 10 CFR 431.306(c)-(d).
Surface area is defined in Appendix A as ``the area of the surface of
the walk-in component that would be external to the walk-in cooler or
walk-in freezer as appropriate.'' Appendix A, Section 3.4. DOE
recognizes that this definition may benefit from additional detail. As
currently written, the definition does not provide detail on how to
determine the boundaries of the walk-in door from which height and
width are determined to calculate surface area. Additionally, the
definition does not specify if these measurements are to be strictly
in-plane with the surface of the wall or panel that the walk-in door
would be affixed to, or if troughs and other design features on the
exterior surface of the walk-in door should be included in the surface
area.
Inconsistent determination of surface area, specifically with
respect to the measurement boundaries, may result in unrepresentative
maximum energy consumption. Display doors are fundamentally different
from non-display doors in terms of their overall construction. For
example, display door assemblies contain a larger frame encompassing
multiple door openings; the entire assembly fits into an opening within
a walk-in wall. Non-display doors differ in that they often are affixed
to a panel-like structure that more closely resembles a walk-in wall
rather than a traditional door frame. For the purposes of determining
compliance with the standards, DOE interprets the surface area as the
product of the height and width measurements of the door made external
to the walk-in, where the height and width measurements are the maximum
edge-to-edge dimensions of the door measured perpendicular to each
other and parallel to the wall or panel of the walk-in to which the
door is affixed. In applying this approach, DOE views the height and
width measurements of display doors to include the frame and frame
flange that overlaps the external edge of the WICF panel. For non-
display doors, DOE views the height and width measurements to include
only the swinging or sliding portion of the door and not the door frame
or any localized appendages such as hinges or hanging rails and
brackets. DOE seeks feedback on its interpretation of surface area for
both display and non-display doors. DOE is also interested in feedback
on whether additional detail is needed regarding the surface area for
both non-display doors and display doors, and if so, what further
detail should be provided.
Issue 11: DOE requests comment on how manufacturers determine
surface area for the purpose of evaluating compliance with the
standards for both display doors and non-display doors. DOE seeks input
on any distinction between display doors and non-display doors,
especially the door frames, which may warrant surface area for each to
be determined differently.
Additionally, walk-in doors with antisweat heaters are subject to
prescriptive standards for power use of antisweat heaters per square
foot of door opening. 10 CFR 431.306(b)(3)-(4). Although ``door
opening'' is not defined, DOE considers the relevant area for
determining ``power use per square foot of door opening'' to be
consistent with the surface area used to determine maximum energy
consumption.
Issue 12: DOE seeks feedback on how manufacturers interpret and
measure door opening as it relates to prescriptive standards for
antisweat heaters, including whether or not manufacturers agree that
the door opening considered for antisweat heat should be consistent
with the surface area used to determine maximum energy consumption.
2. Thermal Transmittance Area
Currently, equations 4-19 and 4-28 of Appendix A specify that
surface area, as defined in section 3.4 of Appendix A, of display doors
and non-display doors, respectively, are used to convert a door's U-
factor into a conduction load. This conduction load represents the
amount of heat that transfers from the exterior to the interior of the
walk-in. Based on recent review of the test procedure, DOE has
identified that this defined surface area is inconsistent with the
referenced industry test procedures for determining U-factor.
As stated previously, Appendix A references NFRC 100 for the
determination of U-factor. When conducting physical testing,\16\ U-
factor (Us) is calculated using projected surface area (As). ASTM
C1199-09, Section 8.1.3. As is defined as ``the projected area of test
specimen (same as test specimen aperture in surround panel)''. ASTM
C1199-09, Section 3.3. This area differs from the currently defined
areas (Add and And) in Appendix A. See Appendix A, Section 3.4. DOE is
considering whether the surface area used in calculating the conduction
load in Equations 4-19 and 4-28 of Appendix A should be the same
surface area used to determine Us to provide greater consistency with
the NFRC 100 definition of U-factor: ``The U-factor multiplied by the
interior-exterior temperature difference and by the projected
fenestration product area yields the total heat transfer through the
fenestration product.''
---------------------------------------------------------------------------
\16\ As mentioned previously, NFRC 100 references NFRC 102 for
determining U-factor through physical testing. NFRC 102 is based on
American Society for Testing and Materials (``ASTM'') C1199-09,
``Standard Test Method for Measuring the Steady-State Thermal
Transmittance of Fenestration Systems Using Hot Box Methods''
(``ASTM C1199-09'') with some modifications.
---------------------------------------------------------------------------
Issue 13: DOE requests feedback on specifying the surface area used
to determine thermal conduction through a walk-in door from the surface
area used to determine the maximum energy consumption of a walk-in
door.
3. Electrical Door Components
Sections 4.4.2 and 4.5.2 of Appendix A include provisions for
calculating the direct energy consumption of electrical components of
display doors and non-display doors, respectively. For example,
electrical components associated with doors could include, but are not
limited to: Heater wire (for anti-sweat or anti-freeze application);
lights (including display door lighting systems); control system units;
and sensors. See Appendix A, Sections 4.4.2 and 4.5.2. For each
electricity-consuming component, the calculation of energy consumption
is based on the component's ``rated power'' rather than an actual
measurement of its power draw. Section 3.5 of Appendix A defines
``rated power'' as the electricity consuming device's power as
specified on the device's nameplate, or from the device's product data
sheet if the device does not have a nameplate or such nameplate does
not list the device's power.
DOE has observed that walk-in doors often provide a single
nameplate for the door, rather than providing individual nameplates for
each electricity-consuming device. In many cases, the nameplate does
not provide separate power information for the different electrical
components. Also, the nameplate often specifies voltage and amperage (a
measure of current) ratings without providing wattage (a measure of
power) ratings, as is referenced by the definition of ``rated power''.
While the wattage is equal to voltage multiplied by the current for
many components, this may not be true of all components that may be
part of a walk-in door assembly. Furthermore, nameplate labels
typically do not specify whether any listed values of rated power or
amperage represent
[[Page 32338]]
the maximum operation conditions or continuous steady-state operating
conditions, which could differ for components such as motors that
experience an initial surge in power before leveling off at a lower
power level. These issues make calculating a door's total energy
consumption challenging when a test facility does not have in-depth
knowledge of the electrical characteristics of the door components.
DOE is considering whether there may be value in adding an option
for direct measurement of door component electrical power, either as
part of the test procedure for manufacturers wishing to make direct
measurements, or for DOE testing, as an alternative to using the
nameplate value. DOE seeks comment on issues that should be considered
were DOE to develop requirements for such measurements, such as any
additional instrumentation or test conditions that would be required.
Issue 14: DOE seeks comment on whether, and if so how, an option
for direct component power measurement could be included in the test
procedure or compliance, certification, and enforcement (``CCE'')
provisions to allow more accurate accounting for the direct electrical
energy consumption of WICF doors. DOE also seeks input on whether
specific provisions should be provided for determining power input from
the information that is typically provided on nameplates, noting the
limitations that were described above.
As stated previously, Appendix A accounts for the energy
consumption of various electrical components, including lights,
sensors, anti-sweat heater wire, and other miscellaneous electrical
devices. The test procedure assigns percent time off (``PTO'') values
to various walk-in door components.\17\ Table II.1 lists the PTO values
in the DOE test procedure for walk-in doors. This method provides a
means to compare walk-in door performance while limiting the test
burden on manufacturers.
---------------------------------------------------------------------------
\17\ PTO values are applied in order to reflect the hours in a
day that an electricity-consuming device operates at its full rated
or certified power (i.e., daily component energy use is calculated
assuming that the component operates at it rated power for a number
of hours equal to 24 multiplied by (1-PTO)). PTO should not be
incorporated into the rated or certified power of an electricity-
consuming device.
Table II.1--Assigned PTO Values for Walk-In Door Components
------------------------------------------------------------------------
Percent time
Component type off (PTO) %
------------------------------------------------------------------------
Lights without timers, control system or other demand- 25
based control..........................................
Lights with timers, control system or other demand-based 50
control................................................
Anti-sweat heaters without timers, control system or 0
other demand-based control.............................
Anti-sweat heaters on walk-in cooler doors with timers, 75
control system or other demand-based control...........
Anti-sweat heaters on walk-in freezer doors with timers, 50
control system or other demand-based control...........
All other electricity consuming devices without timers, 0
control systems, or other auto-shut-off systems........
All other electricity consuming devices for which it can 25
be demonstrated that the device is controlled by a
preinstalled timer, control system or other auto- shut-
off system.............................................
------------------------------------------------------------------------
DOE has received several petitions for waivers and interim waivers
with regard to the PTO used for doors with motorized door openers.\18\
These manufacturers stated that the test procedure for walk-in doors
overstates the energy consumption of motorized doors because the
applicable PTO value prescribed in the test procedure is not
representative of the actual energy use of the motorized doors used in
these applications. Under the current test procedure, motorized door
openers would be considered ``other electricity-consuming devices,''
with PTO values of either 0 percent or 25 percent. See Appendix A,
Sections 4.4.2(a)(3) and 4.5.2(a)(3). Based on the characteristics of
its doors, each manufacturer requested a different PTO value (shown in
Table II.2) to be applied to its basic models. After reviewing the
performance data, equipment characteristics, and door-opening frequency
assumptions presented by door manufacturers, and after soliciting and
reviewing feedback from the public, DOE granted waivers to the
manufacturers shown in Table II.2.
---------------------------------------------------------------------------
\18\ By letters dated July 26, 2017, December 21, 2017, March
13, 2020, and June 5, 2020, Jamison Door Company, HH Technologies,
Senneca Holdings, and Hercules, respectively, submitted petitions
for waivers and interim waivers for basic models of motorized walk-
in doors, requesting the use of alternate PTO values. (Jamison,
EERE-2017-BT-WAV-0040, No. 2 at p. 2; HH Technologies, EERE-2018-BT-
WAV-0001, No. 1 at p. 2; Senneca Holdings, EERE-2020-BT-WAV-0009,
No. 3 at p. 3; Hercules, EERE-2020-BT-WAV-0027, No. 2 at p. 3).
Table II.2--PTO Values Granted in Decision and Orders for Manufacturers of Doors With Motorized Door Openers
----------------------------------------------------------------------------------------------------------------
Percent time
Manufacturer off (PTO) % Decision and order Federal Register citation
----------------------------------------------------------------------------------------------------------------
HH Technologies............................. 96 83 FR 53457. (Oct. 23, 2018).
Jamison Door Company........................ 93.5 83 FR 53460. (Oct. 23, 2018).
Senneca Holdings............................ 97 86 FR 75. (Jan. 4, 2021).
Hercules.................................... 92 86 FR 17801. (Apr. 6, 2021).
----------------------------------------------------------------------------------------------------------------
DOE is reviewing the test procedure's current PTO values and is
interested in establishing standard PTO values for motorized door
openers as well as any other electricity-consuming devices that would
warrant PTOs different from those currently in Appendix A, also listed
in Table II.1 of this document. DOE seeks information regarding how
closely these values represent actual PTO values experienced in the
field. In addition to motorized door openers,
[[Page 32339]]
DOE is also investigating whether any additional walk-in door
electrical components, such as heated air vents and heated thresholds,
would warrant the use of specific PTO values when calculating door
energy use.
Issue 15: DOE requests comment on the current PTO values and
whether DOE should consider amending any of the current values or
adding specific values for additional electrical components,
specifically motorized door openers. DOE requests data from field
studies or similar sources to support any proposed amendments (or
additions) to these PTO values.
DOE is aware that some manufacturers design and market walk-in
cooler display doors for high humidity applications. Ratings from the
CCMS database \19\ show these doors have more anti-sweat heater power
per door opening area than standard cooler display doors. The average
power use per door opening area for high humidity cooler doors is 1.66
W/ft\2\, while the average power use for cooler doors not marketed for
high humidity applications made by the same manufacturers who produce
the high humidity doors is 1.01 W/ft\2\. Section 4.4.2(a)(2) of
Appendix A requires a PTO value of 50 percent be used when determining
the direct energy consumption for anti-sweat heaters with timers,
control systems, or other demand-based controls situated within a walk-
in cooler door (which would include walk-in cooler doors marketed for
high humidity applications). This approach assumes that the anti-sweat
heaters are not operating for 50 percent of the time. DOE recognizes
that anti-sweat heaters may be in operation for a different amount of
time in high humidity installations than in standard installations.
---------------------------------------------------------------------------
\19\ This data from the DOE CCMS database was accessed on March
17, 2021. This database can be found at https://www.regulations.doe.gov/certification-data/.
---------------------------------------------------------------------------
Issue 16: DOE seeks feedback on whether the current PTO of 50
percent is appropriate for evaluating direct energy consumption of
anti-sweat heaters with controls for walk-in cooler doors marketed for
high humidity applications. DOE seeks feedback on the average amount of
time per day or per year that anti-sweat heaters with controls are off
for these high humidity doors and how this compares to standard (i.e.,
non-high humidity) walk-in cooler display doors.
4. EER Values To Convert Thermal Load to Energy Consumption
To calculate the daily energy consumption associated with heat loss
through a walk-in door, Appendix A requires dividing the calculated
heat loss rate by specified EER values of 12.4 Btu per Watt-hour
(``Btu/(W-h)'') for coolers and 6.3 Btu/(W-h) for freezers. Appendix A,
Sections 4.4.4(a) and 4.5.4(a). DOE adopted these EER values in a final
rule published April 15, 2011. 76 FR 21580, 21586, 21594 (``April 2011
TP final rule''). As explained in a notice of proposed rulemaking
(``NOPR'') leading to this final rule, DOE defined nominal EER values
because an envelope component manufacturer cannot control what
refrigeration equipment is installed, and the defined EER value is
intended to provide a nominal means of comparison rather than reflect
an actual walk-in installation. 75 FR 186, 197 (January 4, 2010)
(``January 2010 TP NOPR''). DOE selected EER values of 12.4 Btu/(W-h)
for coolers and 6.3 Btu/(W-h) for freezers because these are typical
EER values of walk-in cooler and walk-in freezer refrigeration systems,
respectively.\20\ 75 FR 186, 209.
---------------------------------------------------------------------------
\20\ The difference in EER values between coolers and freezers
reflects the relative efficiency of the refrigeration equipment for
the associated application. 75 FR 186, 197. As the temperature of
the air surrounding the evaporator coil drops (that is, when
considering a freezer relative to a cooler), thermodynamics dictates
that the system effectiveness at removing heat per unit of
electrical input energy decreases. Id.
---------------------------------------------------------------------------
The DOE test procedure also assigns nominal EER values when testing
the refrigeration systems of walk-in unit coolers alone. When testing a
unit cooler alone, the energy use attributed to the condensing unit is
represented by a default value determined using the representative EER
value specified for the appropriate ``adjusted'' dew point temperature
in Table 17 of AHRI 1250-2009.\21\ The resulting EER values for unit
coolers tested alone are 13.3 Btu/(W-h) for coolers and 6.6 Btu/(W-h)
for freezers, which are different than the EER values of 12.4 and 6.3,
respectively, applied to walk-in doors, as described above. DOE notes
that based on Table 17 of AHRI 1250-2009, EER values of 12.4 and 6.3
correspond to Adjusted Dewpoint Values of 19 [deg]F for a refrigerator
and -26 [deg]F for a freezer (in contrast to Adjusted Dewpoint Values
of 23 [deg]F and -22 [deg]F for unit cooler refrigerators and freezers,
respectively, tested alone as defined in Table 15 and Table 16 of AHRI
1250-2009 and subtracting 2 [deg]F as specified in section 7.9.1 of
AHRI 1250-2009).
---------------------------------------------------------------------------
\21\ The dewpoint temperature to be used for testing unit
coolers alone is defined in section 3.3.1 of Appendix C to be the
Suction A saturation condition provided in Tables 15 or 16 of
Appendix C (for refrigerator unit coolers and freezer unit coolers,
respectively). Table 15 for refrigerator unit coolers defines the
Suction A saturation condition (i.e., dewpoint temperature) as 25
[deg]F. Table 16 for freezer unit coolers defines the Suction A
dewpoint temperature as -20 [deg]F. Furthermore, section 7.9.1 of
AHRI 1250-2009 specifies that for unit coolers rated at a suction
dewpoint other than 19 [deg]F for a refrigerator and -26 [deg]F for
a freezer, the Adjusted Dewpoint Value shall be 2 [deg]F less than
the unit cooler rating suction dewpoint--resulting in adjusted
dewpoint values of 23 [deg]F and -22 [deg]F for refrigerator unit
coolers and freezer unit coolers, respectively.
---------------------------------------------------------------------------
DOE is considering whether to make the EER values used to calculate
the energy consumption of walk-in doors consistent with the values used
to calculate unit cooler energy consumption and whether such a change
would provide a more accurate representation of the energy use of walk-
ins.
Issue 17: DOE seeks feedback on the current EER values specified in
Appendix A used to calculate daily energy consumption for walk-in doors
and the values used in testing of unit coolers alone, as specified in
Appendix C. Specifically, DOE requests comment on which of these sets
of EER values is more representative, whether DOE should make the
values used for door testing and unit cooler testing consistent with
each other, and if so, which of the sets of values should be used.
5. Thermal Transmittance
a. Calibration of Hot Box for Measuring U-factor
As stated previously, NFRC 100 references NFRC 102 as the physical
test method for measuring U-factor, which in turn incorporates by
reference ASTM C1199. ASTM C1199 references ASTM C1363-05, ``Standard
Test Method for Thermal Performance of Building Materials and Envelope
Assemblies by Means of a Hot Box Apparatus'' (``ASTM C1363''). Section
6.1 of ASTM C1199 and Annexes 5 and 6 of ASTM C1363 include calibration
requirements to characterize metering box wall loss and surround panel
flanking loss, but the frequency at which these calibrations should
occur is not specified in these test standards. DOE notes that ASHRAE
Standard 16-2016, ``Method of Testing for Rating Room Air Conditioners
and Packaged Terminal Air Conditioners'' (``ASHRAE 16-2016''), which is
the test method incorporated by reference in the DOE test procedure for
room air conditioners (10 CFR 430.3(g)(1)), uses in its determination
of air conditioner capacity a value for heat loss through the partition
wall based on prior calibration of the wall's heat loss. Conceptually,
this use of a calibrated heat loss value is similar to the use of
calibrated thermal losses in ASTM C1199 and ASTM C1363. DOE notes
[[Page 32340]]
further that section 6.1.2.2 of ASHRAE 16-2016 includes a requirement
to calibrate the partition wall thermal loss at least every two years.
DOE is interested in feedback on the frequency of calibration and how
recalibrations are performed for test facilities using test standard
ASTM C1199.
Issue 18: DOE requests comment on how frequently test laboratories
perform each of the calibration procedures referenced in ASTM C1199 and
ASTM C1363, e.g., those used to determine calibration coefficients that
are used to calculate metering box wall loss and surround panel
flanking loss. DOE also requests comment on the magnitude of variation
in the calibration coefficients measured during successive
calibrations.
b. Tolerances of Surface Heat Transfer Coefficients
Section 6 of ASTM C1199 specifies the standardized heat transfer
coefficients and their tolerances as part of the procedure to set the
surface heat transfer conditions of the test facility using the
Calibration Transfer Standard (``CTS'') test. The warm-side surface
heat transfer coefficient must be within 5 percent of the
standardized warm-side value, and the cold-side surface heat transfer
coefficient must be within 10 percent of the standardized
cold-side value (ASTM C1199-09, sections 6.2.3 and 6.2.4). ASTM C1199
does not require that the measured surface heat transfer coefficients
match or be within a certain tolerance of standardized values during
sample testing--although test facility operational (e.g., cold side fan
settings) condition would remain identical to those set during the CTS
test. On the other hand, Appendix A states in section 5.3(a)(1) that
the average surface heat transfer coefficient on the cold-side of the
apparatus shall be 30 Watts per square-meter-Kelvin 5
percent and that the average surface heat transfer coefficient on the
warm-side of the apparatus shall be 7.7 Watts per square-meter-Kelvin
5 percent.
DOE originally proposed the heat transfer values and their
associated tolerances in a supplemental notice of proposed rulemaking
(``SNOPR'') published February 20, 2014 (``February 2014 AEDM TP
SNOPR''). 79 FR 9818, 9837, 9847. DOE did not receive any comments from
interested parties specific to the proposed tolerance of 5
percent for both the cold-side and warm-side heat transfer
coefficients, and finalized these values in a final rule published on
May 13, 2014 (``May 2014 AEDM TP final rule''). 79 FR 27388, 27415.
DOE has found that meeting the standardized heat transfer values
within specified tolerances in section 5.3(a)(1) of Appendix A on the
warm-side and cold-side may not be achievable depending on the thermal
transmittance through the door. Specifically, the warm-side heat
transfer is dominated by natural convection and radiation and the heat
transfer coefficient varies as a function of surface temperature. When
testing doors with higher thermal resistance, less heat is transferred
across the door from the warm-side to the cold-side, so the warm-side
surface temperature is closer to the warm-side air temperature.
However, the CTS method in ASTM C1199 does not require measurement of
the warm-side surface temperature of the door. Rather, this value is
calculated based on the radiative and convective heat flows from the
test specimen's surface to the surroundings, which are driven by values
determined from the calibration of the hot box (e.g., the convection
coefficient). See ASTM C1199, Section 9.2.1. When testing doors with
extremely high- or low-thermal resistance, the resulting change in
warm-side surface temperature can shift the warm-side heat transfer
coefficient out of tolerance. The only way to adjust these coefficients
to be within tolerance would be to recalibrate the hot box for a
specific door, which would be burdensome and somewhat unpredictable.
Issue 19: DOE requests feedback on whether the tolerances in
section 5.3(a)(1) of Appendix A applied to the surface heat transfer
coefficients used to measure thermal transmittance are achievable for
all walk-in doors and if not, whether the tolerances should be
increased or omitted. Specifically, DOE seeks data to support any
changes to the tolerances on the surface heat transfer coefficients.
6. Air Infiltration Reduction
EPCA includes prescriptive requirements for doors used in walk-in
applications, which are intended to reduce air infiltration.
Specifically, walk-ins must have (A) automatic door closers that firmly
close all walk-in doors that have been closed to within 1 inch of full
closure (excluding doors wider than 3 feet 9 inches or taller than 7
feet), and (B) strip doors, spring-hinged doors, or other method of
minimizing infiltration when doors are open. 42 U.S.C. 6313(f)(1)(A)-
(B). In the January 2010 TP NOPR and an SNOPR published on September 9,
2010 (``September 2010 TP SNOPR''), DOE proposed methods for
determining the thermal energy leakage due to steady-state infiltration
through the seals of a closed door and door opening infiltration. 75 FR
186, 214-216 and 75 FR 55068, 55107-55108. However, the April 2011 TP
final rule did not include these methods because DOE concluded that
steady-state infiltration was primarily influenced by on-site assembly
practices rather than the performance of individual components. 76 FR
21580, 21594-21595. Similarly, DOE stated that, based on its experience
with the door manufacturing industry, door opening infiltration is
primarily reduced by incorporating a separate infiltration reduction
device at the assembly stage of the complete walk-in. Id.
In this RFI, DOE is re-considering whether a method for measuring
infiltration, specifically door opening infiltration, as well as a
method to measure the impacts from technologies that reduce
infiltration (e.g. fast-acting doors or air curtains), would improve on
the current test procedure's accuracy and ability to produce results
reflecting a given walk-in door's energy efficiency during a
representative average use cycle, while not being unduly burdensome to
conduct. Certain types of doors, like fast-acting doors, may have
higher thermal transmittance, but may compensate for that factor by
reducing infiltration from door openings--thereby, reducing a walk-in's
overall energy use. DOE is considering how it may account for these
types of doors in the walk-in test procedure.
In the January 2010 TP NOPR, DOE proposed to require that the
thermal load from air infiltration associated with each door opening
event be calculated using an analytical method based on equations
published in the ASHRAE Refrigeration Handbook in combination with
assumed values for door-opening frequency and duration. That proposed
method would have accounted for the presence of infiltration reduction
devices by discounting the thermal load from door opening air
infiltration by the effectiveness of the air infiltration device. 75 FR
186, 196-197, 214-216. In order to determine the effectiveness of an
infiltration reduction device, DOE proposed a two-part test that
entailed measuring the concentration of tracer gas after a door opening
event with and without the infiltration reduction device in place. Id.
DOE proposed to use this effectiveness test for every unique door-
device combination offered by a manufacturer. Id.
In the September 2010 TP SNOPR, DOE proposed a method for
determining the thermal load associated with steady-state infiltration
through walk-in doors. 75 FR 55068, 55084-55085, and 55107-
[[Page 32341]]
55108. For each door type with identical construction and only
differences in dimensional size, DOE proposed to require calculating
steady-state infiltration according to NFRC 400-2010-E0A1 (``Procedure
for Determining Fenestration Product Air Leakage'') by testing three
representative doors, one each of a ``small,'' ``medium,'' and
``large'' size.\22\ Id. The steady-state infiltration from the
representative doors would then be extrapolated or interpolated, as
appropriate, to other doors that have the same construction. Id.
---------------------------------------------------------------------------
\22\ DOE proposed a small size door as 48 inches 0.5
inch wide and 84 inches 0.5 inch high, a medium size
door as 96 inches 0.5 inch wide and 144 inches 0.5 inch high, and a large size door as 144 inches 0.5 inch wide and 180 inches 0.5 inch high. 75 FR
55068, 55107.
---------------------------------------------------------------------------
As noted, DOE is considering how to credit doors with infiltration-
reducing features that reduce overall walk-in energy use and that are
in addition to the prescriptive requirements mandated by EPCA. In doing
so, DOE may consider a revised version of one of its previous proposals
related to door infiltration, or offer a new method for determining
heat load associated with infiltration.
DOE requests comment on whether it should account for steady-state
and/or door opening infiltration in its test procedure--and if so, why;
and if not, why not. With respect to suggestions for potential test
methods, DOE is particularly interested in recommendations regarding
test methods and calculation methods used by the industry to quantify
heat load from infiltration. With respect to each of these methods, DOE
seeks supporting information regarding the necessary costs in carrying
them out. DOE seeks information and data on whether testing results
obtained under any of the methods could be used to interpolate the load
resulting from air infiltration of other door sizes in a product line.
DOE also requests information on door usage patterns per door type
(e.g., display doors, passage doors, motorized doors, and fast-acting
doors), including any supporting data from research or field studies.
D. Test Procedure for Walk-In Panels
In the following subsections, DOE presents several topics specific
to walk-in panels that, if adopted, may improve the current test
procedure's ability to provide results that more accurately depict
walk-in panel energy use during a representative average use cycle
without causing the test procedure to become unduly burdensome to
conduct. That test procedure, found in 10 CFR part 431, subpart R,
appendix B, provides a detailed method by which to measure the energy
efficiency of a given panel used in the construction of a walk-in.
Since publication of the December 2016 TP final rule, DOE has
identified the potential need to provide additional clarification to
Appendix B regarding the measurement of the thickness of walk-in panels
(see Section II.D.1 of this document) and the procedure for determining
parallelism and flatness of test specimens (see Section II.D.2 of this
document). DOE also has identified differences between Appendix B and
the industry test standards referenced, specifically for specimen \23\
conditioning prior to testing (see Section II.D.3 of this document). In
addition, DOE is examining the prospect of requiring a measurement for
thermal transmittance for non-display panels (see Section II.D.4 of
this document). While DOE previously adopted methods for measuring
thermal transmittance in the April 2011 TP final rule, it later removed
them. 79 FR 27387, 27405-27406. DOE remains interested in exploring the
possibility of addressing this issue because of the potential variation
in thermal transmittance of different panel designs with the same R-
value, and seeks additional information regarding market-related and
industry test method-related changes that would inform DOE's potential
reconsideration of adopting a test method for measuring thermal
transmittance. Finally, DOE is seeking comment on the test procedure
for display panels (Section II.D.5 of this document).
---------------------------------------------------------------------------
\23\ ASTM C518 uses ``specimen'' to refer to the piece of
insulation that is cut to size for testing, while the CFR uses
``sample''. The discussion in this document is using ``specimen''
for consistency with the industry test standard.
---------------------------------------------------------------------------
1. Panel Thickness
DOE's test procedure for walk-in panels requires manufacturers to
determine the panel's R-value by measuring the thermal conductivity,
referred to as the ``K factor'' of a 1 0.1-inch specimen
of insulation according to ASTM C518-04. The R-value of the walk-in
panel is determined by dividing the panel thickness by the K factor.
See 10 CFR 431.304(b)(3) and Appendix B (detailing the test method used
to measure the R-value for walk-in envelope components). DOE's current
test procedure for determining a panel's R-value provides some
direction for measuring panel thickness. However, because of the
importance of this measurement in determining the panel's R-value, DOE
is considering whether to include additional details regarding the
thickness measurement.
Issue 20: DOE requests comment on how panel thickness is currently
measured for determining the panel's R-value per the DOE test
procedure, including number of measurements, measurement location, and
any steps that are routinely followed for the removal of the protective
skins or facers to obtain the full panel thickness. DOE requests that
commenters identify any specific guidelines, practices or standardized
approaches that are followed, as well as their date of publication, if
applicable.
2. Parallelism and Flatness
The test procedure for determining R-value also requires that the
two surfaces of the tested specimen that contact the hot plate
assemblies (as defined in ASTM C518) maintain 0.03 inches
flatness tolerance and also maintain parallelism with respect to one
another within a tolerance of 0.03 inches.\24\ Section 4.5
of Appendix B. The test procedure provides no direction on how flatness
and parallelism should be measured or calculated. DOE is considering
whether its test procedure should provide additional details indicating
how to determine the flatness and parallelism of the tested specimen.
---------------------------------------------------------------------------
\24\ Maintaining a flatness tolerance means that no part of a
given surface is more distant than the tolerance from the ``best-fit
perfectly flat plane'' representing the surface. Maintaining
parallelism tolerance means that the range of distances between the
best-fit perfectly flat planes representing the two surfaces is no
more than twice the tolerance (e.g., for square surfaces, the
distance between the most distant corners of the perfectly flat
planes minus the distance between the closest corners is no more
than twice the tolerance).
---------------------------------------------------------------------------
Issue 21: DOE requests comment on how flatness and parallelism of
the test specimen surfaces that contact the hot plate assemblies
described in ASTM C518 are typically determined by test laboratories
and whether the test procedure should be revised to clarify how to
determine these parameters, e.g., what type of instruments are used to
measure these values, how many measurements are made for a given
specimen, and other details that could affect conclusions regarding
compliance with the test procedure.
3. Specimen Conditioning
ASTM C518 directs that a test specimen cut from a panel be
conditioned prior to testing. See ASTM C518-04, section 7.3 (referring
to panel conditioning as ``specimen conditioning''). However, ASTM C518
does not specify the conditions at which specimen conditioning would be
conducted, nor the duration. ASTM C518 states that specimen
conditioning details should be provided in the
[[Page 32342]]
material specifications, and if not provided, conditions should be
selected so as not to change the specimen in an irreversible manner.
Id. ASTM C518 further states that material specifications typically
call for specimen conditioning at 22 [deg]C (72 [deg]F) and 50 percent
relative humidity until less than a 1 percent mass change is observed
over a 24-hour period. Id. Calculations associated with conditioning
are discussed in section 8.1 of ASTM C518, including calculation of the
``density of the dry specimen as tested,'' which suggests that the
purpose of conditioning is, at least in part, to dry the specimen,
i.e., allow water to evaporate and/or diffuse out.
DOE has not found specimen conditioning details to be provided by
suppliers of insulation for any of the common insulation materials used
in walk-ins. Given this lack of supplier-provided specimen conditioning
details, it is DOE's understanding that ``material specifications'' in
section 7.3 refers to ASTM specifications, e.g. ASTM C578-2019,
``Standard Specification for Rigid, Cellular Polystyrene Thermal
Insulation'' or ASTM C1029-2015, ``Standard Specification for Spray-
Applied Rigid Cellular Polyurethane Thermal Insulation''. However,
there is no uniform set of ASTM conditioning specifications, and the
material specifications identified in ASTM C518 as ``typical'' do not
reflect what is provided in other ASTM standards. For example, ASTM
C578-2019 calls for conditioning as specified in the applicable test
procedure--this circular reference back to ASTM C518 means that ASTM
C578-2019 effectively provides no explicit conditions. ASTM C1029-2015
calls for conditioning at 73 2 [deg]F and 50
5 percent relative humidity for 180 5 days from time of
manufacture. In the context of the DOE WICF test procedures, the ASTM
C1029-2015 specifications may be insufficient or inappropriate because
the date of manufacture of the insulation in a walk-in panel or door
may not be known, and the 180-day condition would likely represent a
significant test burden.
In the absence of clear instructions in ASTM C518, test
laboratories may be using conditioning times, temperature, and humidity
consistent with the conditions identified in ASTM C518-04 section 7.3
as ``typical conditions.'' Additionally, the provision in section 4.5
of Appendix B requires that testing per ASTM C518-04 must be completed
within 24 hours of specimens being cut for the purpose of testing,
eliminating use of the 180-day conditioning provided in ASTM C1029-2015
or the example of typical specimen conditioning provided by ASTM C518.
Issue 22: DOE requests comment on the extent to which manufacturers
of insulation specify conditioning for insulation materials that differ
from the typical conditioning approach described in ASTM C518. DOE also
seeks feedback on whether more than one 24-hour conditioning period is
ever needed to complete the conditioning (i.e., the change in specimen
mass is less than 1 percent after the first 24 hours of conditioning)
for a specimen extracted from a WICF panel or door. Finally, DOE
requests information or data on how specimen conditioning times less
than or equal to 24 hours impacts the accuracy, repeatability, and
representativeness of the test.
4. Overall Thermal Transmittance
In the April 2011 TP final rule, DOE adopted a test method for
measuring the overall thermal transmittance of a walk-in panel,
including the impacts of thermal bridges \25\ and edge effects (e.g.,
due to framing materials and fixtures used to mount cam locks). This
method drew from an existing industry test method, incorporating by
reference ASTM C1363-05. 76 FR 21580, 21605-21612. However, after
receiving comments indicating that only two independent laboratories
could conduct this test, DOE re-evaluated its earlier decision and
removed this portion of the walk-in panel test procedure in the May
2014 AEDM TP final rule. 79 FR 27388, 27405-27406. Despite this
decision to remove its overall thermal transmittance measurement method
from the walk-in test procedure, DOE remains concerned that elements
like framing materials and fixtures used to mount cam locks can
significantly affect walk-in panel energy efficiency performance. To
address this issue, DOE is re-evaluating whether--and if so, how--to
account for the overall thermal transmittance of walk-in panels in its
test procedure.
---------------------------------------------------------------------------
\25\ Thermal bridging occurs when a more conductive material
allows an easy pathway for heat flow across a thermal barrier.
---------------------------------------------------------------------------
Issue 23: DOE requests information about panel construction factors
that would affect thermal transmission and the magnitude of the energy
efficiency-related impacts of thermal bridges in the panel assembly.
Additionally, DOE requests comment on alternative test methods that
measure the overall thermal transmittance of walk-in panels and the
relative advantages and disadvantages of each. DOE also seeks feedback
on the number and location of labs that have the facilities and are
qualified to run ASTM C1363-05.
5. Display Panels
Display panels are defined in 10 CFR 431.302 as panels entirely or
partially comprised of glass, a transparent material, or both that are
used for display purposes. Display panels are subject to the test
procedure in Appendix A for determining U-factor, conduction load, and
energy use. 10 CFR 431.304(b)(1). Appendix A follows the procedure in
NFRC 100 for determination of display panel U-factor. 10 CFR 431.303.
Although DOE established a test procedure for display panels, DOE has
not established energy conservation standards for them. DOE received no
comments in response to the proposed test procedure outlined for
display panels in the September 2010 TP SNOPR and DOE established
Appendix A as the test procedure for display panels in the April 2011
TP Final Rule. 76 FR 21580, 21606. DOE is interested in any feedback on
amending the current test procedure for display panels.
Issue 24: DOE seeks feedback on the current test procedure for
display panels in Appendix A and what amendments should be made, if
any, to it.
E. Test Procedure for Walk-In Refrigeration Systems
DOE's test procedure for walk-in refrigeration systems can be found
in Appendix C to Subpart R of 10 CFR part 431. The test procedure
primarily incorporates by reference AHRI 1250-2009.
DOE has also recently granted test procedure interim waivers and
waivers to Appendix C specific to the testing of single-package
systems, wine cellar refrigeration systems, and carbon dioxide
(``CO2'') refrigerant based systems, summarized in Table
II.3. Test procedure waivers provide alternate test provisions for
units that DOE determines cannot be appropriately tested to its current
test procedure. A waiver granted by DOE remains in effect until DOE
amends its regulations so as to eliminate any need for it, pursuant to
10 CFR 431.401(h) for commercial and industrial equipment. Sections
II.E.1, II.E.2, and II.E.3, below discuss and request comment on
addressing single-package systems, wine cellar
[[Page 32343]]
refrigeration systems, and CO2 systems in the test
procedure.
Table II.3--Interim Waivers and Waivers Granted to Manufacturers of Walk-In Refrigeration Systems
----------------------------------------------------------------------------------------------------------------
Waiver decision and
Manufacturer Subject Interim Waiver Federal order Federal
Register citation Register citation
----------------------------------------------------------------------------------------------------------------
Air Innovations.................... Wine Cellar Refrigeration 86 FR 2403 (Jan. 12, 86 FR 23702 (May 4,
Systems. 2021). 2021).
Vinotheque......................... Wine Cellar Refrigeration 86 FR 11961 (Mar. 1, 86 FR 26504 (May 14,
Systems. 2021). 2021).
CellarPro.......................... Wine Cellar Refrigeration 86 FR 11972 (Mar. 1, 86 FR 26496 (May 14,
Systems. 2021). 2021).
Vinotemp........................... Wine Cellar Refrigeration 86 FR 23692 (May 4, (*)
Systems. 2021).
HTPG............................... CO2 Unit Coolers........... 85 FR 83927 (Dec. 23, 86 FR 14887 (Mar. 19,
2020). 2021).
Hussmann........................... CO2 Unit Coolers........... 86 FR 10046 (Feb. 18, 86 FR 24606 (May 7,
2021). 2021).
Keeprite........................... CO2 Unit Coolers........... 86 FR 12433 (Mar. 3, 86 FR 24603 (May 7,
2021). 2021).
Store It Cold...................... Single-Package Systems..... 84 FR 11944 (Mar. 29, 84 FR 39286 (Aug. 9,
2019). 2019).
----------------------------------------------------------------------------------------------------------------
* A decision and order granting the manufacturer a waiver has not yet been issued.
As noted earlier, during DOE's previous rulemaking to develop
standards for WICF refrigeration systems, the accompanying Term Sheet
included a series of amendments to the test procedure that the Working
Group viewed as necessary to properly implement its recommended energy
conservation standards. Ultimately, DOE published final rules
implementing the majority of both sets of recommendations. See 82 FR
31808, 31808-31838 (July 10, 2017) (final rule amending the energy
conservation standards for walk-ins) and 81 FR 95758 (December 28,
2016) (final rule amending the walk-in test procedures).
Three test procedure-related recommendations from the Term Sheet,
however, were not part of DOE's December 2016 TP final rule. (Term
Sheet Recommendation #6). The Working Group believed these
recommendations merited consideration by DOE as part of future
amendments to help make the test procedure more fully representative of
walk-in energy use. (Id.) Specifically, the Working Group recommended
that DOE amend its procedure to (a) measure the energy use associated
with the defrost function, taking into account the potential savings
associated with hot gas and adaptive defrost, (b) incorporate the
measurement of off-cycle power consumption, including crankcase heater
power consumption, and (c) allow for separate ratings of stand-alone
variable-capacity condensing units. (Id.). Sections II.E.4 through
II.E.6 of this document discuss these issues in more detail.
Sections II.E.7 and II.E.8 discuss other issues that may also
improve the test procedure's ability to provide results that are more
representative of walk-in energy use. Specifically, these include
consideration of amended test procedures and new equipment classes for
so-called high-temperature freezer refrigeration systems used for walk-
ins at temperatures between 10 [deg]F and 32 [deg]F, and discussion of
the impact of refrigerant temperature glide \26\ of zeotropic
refrigerants such as R407A.
---------------------------------------------------------------------------
\26\ ``Temperature glide'' for a refrigerant refers to the
increase in temperature at a fixed pressure as liquid refrigerant
vaporizes during its conversion from saturated liquid to saturated
vapor.
---------------------------------------------------------------------------
1. Single-Package Systems
As discussed in the December 2016 TP final rule, single-package
systems are considered a type of dedicated condensing refrigeration
system. 81 FR 95758, 95763-95764. The test methods in AHRI 1250-2009,
which are incorporated by reference as DOE's test procedure for walk-
ins (10 CFR 431.303(b)), do not fully address or account for the
features of single-package systems. As discussed in the December 2016
TP final rule, commenters asserted that one practical challenge to
testing single-package systems is the need to disassemble the unit
under test in order to be able to install the refrigerant mass flow
meters required for testing. Id. at 95763. Mass flow measurement is a
key input in the calculation of capacity, as illustrated in equations
C1 and C2 of AHRI 1250-2009.
Regarding this class of equipment, DOE received a petition for
waiver with regard to testing of single-package units. By letter dated
May 9, 2020, Store It Cold submitted a petition for waiver and interim
waiver from Appendix C for basic models of single-package systems.
(EERE-2018-BT-WAV-0002, No. 2) Store It Cold stated that testing
single-package systems with refrigerant mass flow meters installed
produces results unrepresentative of their true energy consumption
characteristics and would provide materially inaccurate comparative
data. The petitioner requested that DOE permit the use of psychrometric
`air-side' measurements to determine the Gross Total Refrigeration
Capacity of such systems. DOE granted a test procedure waiver and
interim waiver to Store It Cold for specified basic models in 2019. 84
FR 39286 (August 9, 2019) (``Store It Cold Decision and Order'').
AHRI 1250-2020 addresses testing of single-package systems in
section C9 and incorporates by reference test standards developed for
testing air-conditioning units that include alternative test methods
that have been adapted for testing single-package systems. The air
enthalpy methods in section C9 of AHRI 1250-2020 incorporate by
reference ANSI/ASHRAE Standard 37-2009 (``ASHRAE 37-2009''), ``Methods
of Testing for Rating Electrically Driven Unitary Air-Conditioning and
Heat Pump Equipment'' and ANSI/ASHRAE 41.6-2014 (``ASHRAE 41.6''),
``Standard Method for Humidity Measurement''. The calorimeter methods
in section C9 of AHRI 1250-2020 incorporate by reference ANSI/ASHRAE
Standard 16-2016 (``ASHRAE 16-2016''), ``Method of Testing for Rating
Room Air Conditioners, Packaged Terminal Air Conditioners, and Packaged
Terminal Heat Pumps for Cooling and Heating Capacity''. The compressor
calibration methods in section C9 of AHRI 1250-2020 incorporate by
reference ASHRAE 37 and ANSI/ASHRAE 23.1-2010. AWEF calculations for
matched pair and single-package systems are detailed in section 7.1.1
through 7.1.4 of AHRI 1250-2020.
AHRI 1250-2020 requires two simultaneous measurements of system
capacity (i.e., a primary and secondary method), and section C9.2.1 of
Appendix C provides a requirement that the measurements agree within 6
percent. Table C4 to Appendix C to AHRI 1250-2020 details which of the
test methods (calorimeter, air enthalpy, and compressor calibration)
qualify as primary and/or secondary methods.
Issue 25: DOE requests comment on whether the single-package system
test
[[Page 32344]]
and calculation methods described in AHRI 1250-2020 provide
representative energy use. DOE also requests comment on whether DOE
should incorporate by reference AHRI 1250-2020 as the test procedure
for single-package systems.
DOE also notes that, unlike split systems (i.e., matched-pair
refrigeration systems), single-package systems may experience
additional thermal losses because they circulate cold walk-in air
through a cold section that has exterior surfaces exposed to warm air
outside the walk-in enclosure. This exposure can contribute to
additional infiltration losses, i.e., leakage of air between the
interior and exterior of a walk-in. Accordingly, if these losses occur,
they would reduce the net capacity of a single-package system without
being fully captured by the refrigerant enthalpy methods established in
AHRI 1250-2009.
Issue 26: DOE requests any data or calculations quantifying the
additional thermal losses associated with testing single-package
systems due to the exposure of their cold sides to the exterior air
(i.e., surface and infiltration losses). DOE additionally requests
comment on whether the AHRI 1250-2020 test methodology for single-
package systems fully accounts for these additional losses.
a. Calorimeter Method
As previously mentioned, AHRI 1250-2020 incorporates by reference
ASHRAE 16-2016 as its indoor and outdoor room calorimeter method test
procedure. ASHRAE 16-2016 includes a calorimeter test method with
similarities to the calibrated box test method of AHRI 1250-2009, but
with additional details and provisions. ASHRAE 16-2016 is used to
measure the capacity and power input of single-package system products
such as room air conditioners that have hot and cold sections, similar
to single-package walk-in systems. The ASHRAE 16-2016 calorimeter test
includes both outdoor- and indoor-based calorimetric measurements of
the capacity--the indoor side measurement is similar to that of the
calibrated box test method, while the outdoor side provides a
determination of system cooling capacity by measuring the cooling
required to maintain the outdoor room temperature and humidity
conditions.
DOE's work in evaluating single-package systems using the
calorimeter methods referenced in AHRI 1250-2020 has highlighted the
need to make very precise determination of the calorimeter chamber
cooling fluid heat capacity. This fluid cannot be pure water, since it
must be below water freezing temperature for testing WICF refrigeration
systems. This makes precise determination of heat capacity more
challenging, since an accurate determination of glycol concentration is
required.
Issue 27: DOE requests comment and data on the use of water,
glycol, or other heat transfer liquid in maintaining test compartment
temperature using the calorimeter methods referenced in AHRI 1250-2020
for the testing of single-package refrigeration systems. DOE requests
comment on whether the description and requirements for calorimetric
testing as provided in AHRI 1250-2020 should be modified or enhanced in
order to better ensure that measurements are accurate and repeatable.
In addition, ASHRAE 16-2016 requires that a pressure-equalizing
device be installed between the indoor and outdoor test compartments to
maintain a balanced pressure between the compartments and to measure
the air flow required to maintain equalization. Assuming the test
facility is otherwise airtight, the air flow transferred and measured
by the pressure-equalizing device represents air transferred in the
opposite direction through leaks inside the equipment as a result of
pressure differences between the warm and cold side of the system set
up by its fans.
Given that the related calibrated box test method has no
requirements for pressure equalization, DOE is considering the need for
pressure equalization for single-package testing. Alternatives include
(a) no requirement addressing transfer air or pressure equalization, or
(b) a requirement that the test facility chambers be leak-free with no
equalization requirement. DOE expects that the use of a pressure
equalization apparatus would incrementally increase test facility cost
and test burden, and would ensure operation with losses consistent with
the measured air leakage, but such equalized pressure conditions may
not be representative of WICF refrigeration system use. The alternative
options may reduce facility cost and test burden. Option (a) may reduce
accuracy and repeatability, while both options may mask potential
performance degradation associated with air leakage.
Issue 28: DOE requests comment on whether calorimeter test methods
for single-package systems should implement a pressure-equalizing
device, as included in ASHRAE 16-2016. DOE requests information on any
additional cost and resource burdens, if any, manufacturers would face
when employing these methods to evaluate single-package systems.
Issue 29: DOE seeks comment regarding any alternative test methods
not mentioned in this document that could be used to measure single-
package system capacity. To the extent that any alternative test
methods could be used for this purpose, DOE requests information on
their advantages and disadvantages in measuring single-package system
capacity.
2. Wine Cellar Refrigeration Systems
DOE is aware of certain equipment within the walk-in definition
that may be incapable of being tested in a manner that would yield
results measuring the energy efficiency or energy use of that equipment
during a representative average use cycle under the current version of
the walk-in test procedure. Specifically, wine cellars that are
installed in a variety of commercial settings are set to operate at a
temperature range of 45 [deg]F to 65 [deg]F. They also meet the
criteria established by Congress in the definition for a walk-in. See
generally 42 U.S.C. 6311(20). Under the walk-in test procedure, walk-in
coolers must be tested while operating at 35 [deg]F. Section 3.1.1 of
Appendix C. Wines often suffer from damage when stored at temperatures
below 45 [deg]F. To the extent that a wine cellar is not operated at 35
[deg]F, applying the required 35 [deg]F testing temperature condition
when evaluating the energy usage of this equipment would not produce
results representative of an average use cycle.
DOE has received requests for waiver and interim waiver from
several manufacturers from the test procedure in Appendix C for basic
models of wine cellar refrigeration systems.\27\( ). Manufacturers
stated that wine cellars are intended to operate at a temperature range
of 45 to 65 [deg]F and 50-70 percent relative humidity, rather than the
35 [deg]F and less than 50 percent relative humidity test condition
prescribed in Appendix C. Manufacturers asserted that testing at 35
[deg]F would be unrepresentative of the true energy consumption
characteristics of the specified units and that operation at this
temperature may damage wine cellar refrigeration units. Given the
number of waivers that DOE received, DOE
[[Page 32345]]
engaged with AHRI, the industry trade association, to discuss how to
develop a consistent alternate test approach for wine cellars that
would be applicable to all impacted manufacturers. Ultimately, AHRI
submitted a memorandum on behalf of its wine cellar members supporting
(1) a 45 [deg]F minimum operating temperature for wine cellar
refrigeration systems, and (2) testing at 50 percent of maximum
external static pressure, with manufacturers providing maximum external
static pressure values to DOE.\28\ After reviewing manufacturer
websites, product specification sheets, suggested alternate test
approaches provided by each manufacturer and by AHRI, and after
soliciting and reviewing feedback from the public, DOE has granted
interim waivers or waivers as summarized in Table II.3.
---------------------------------------------------------------------------
\27\ Air Innovations, Vinotheque Wine Cellars, Cellar Pro
Cooling Systems, Vinotemp International Corp., and LRC Coil Company,
respectively, submitted petitions for waivers and interim waivers
for basic models of wine cellar walk-in refrigeration systems. (Air
Innovations, EERE-2019-BT-WAV-0029, No. 6; Vinotheque, EERE-2019-BT-
WAV-0038, No. 6; CellarPro, EERE-2019-BT-WAV-0028, No. 6; Vinotemp,
EERE-2020-BT-WAV-0022, No. 10; LRC Coil, EERE-2020-BT-WAV-0040, No.
1).
\28\ Memorandum from AHRI, ``Department of Energy (DOE) Wine
Cellar Cooling Systems Test Procedure Waiver Industry Comments from
AHRI Membership'', August 18, 2020. (EERE-2019-BT-WAV-0028, No. 5
(CellarPro); EERE-2019-BT-WAV-0029, No. 5 (Air Innovations); EERE-
2019-BT-WAV-0038, No. 5 (Vinotheque); EERE-2019-BT-WAV-022, No. 2
(Vinotemp))
---------------------------------------------------------------------------
These waivers have addressed testing for single-package, matched-
pair, and unit-cooler-only wine cellar refrigeration systems. The
alternative test procedures prescribed in these waivers address a
number of differences in operation between wine cellar refrigeration
systems and other walk-in refrigeration systems, including the
following:
Unit cooler air inlet condition of 55 [deg]F and 55
percent RH, compared to 35 [deg]F and less than 50 percent RH for
medium-temperature refrigeration systems in the DOE test procedure;
For single-package wine cellar systems, capacity
measurement is conducted using a primary and a secondary capacity
measurement method as specified in AHRI 1250-2020, using two of the
following: The indoor air enthalpy method; the outdoor air enthalpy
method; the compressor calibration method; the indoor room calorimeter
method; the outdoor room calorimeter method; or the balanced ambient
room calorimeter method.
Options for ducting on the condenser side, evaporator
side, or both with specifications for setting the external static
pressure.
For calculating AWEF, the wine cellar box load level is
set equal to half of the refrigeration system capacity at the 95 [deg]F
test condition (for outdoor refrigeration systems) or 90 [deg]F (for
indoor refrigeration systems), rather than using a two-tiered set of
high- and low-load period box load levels, as prescribed in AHRI 1250-
2009. For calculating AWEF, the evaporator fan is assumed to operate
for one-tenth of the compressor off-cycle period at the same wattage as
applies for the compressor on-cycle. This contrasts with varying
assumptions used for other WICF refrigeration systems, depending on the
type of evaporator fan controls they use.
Issue 30: DOE requests comment on the alternative test procedure
for wine cellar walk-in refrigeration systems that it has granted in
the interim waivers and waivers listed in Table II.3. DOE additionally
seeks comment on whether the alternative test procedure prescribed for
the specified basic models identified in the waivers would be
appropriate for similar refrigeration equipment.
As noted previously, wine cellar refrigeration systems are designed
for both ducted and non-ducted air delivery; the DOE test procedure
does not address the testing of ducted systems. For systems that can be
installed with (1) ducted evaporator air, (2) with or without ducted
evaporator air, (3) ducted condenser air, or (4) with or without ducted
condenser air, the alternate test approach requires testing to be
conducted at 50 percent of the maximum external static pressure
(``ESP''), subject to a tolerance of -0.00/+0.05 in. DOE understands
that maximum ESP is generally not published in available literature
such as installation instructions, but manufacturers do generally
specify the size and maximum length of ductwork that is acceptable for
any given unit in such literature. The duct specifications determine
what ESP would be imposed on the unit in field operation.\29\ The
provision of allowable duct dimensions is more convenient for
installers than maximum ESP, since it relieves the installer from
having to perform duct pressure drop calculations to determine ESP.
This approach differs from the approach used in related products/
equipment, e.g., air conditioners, where ESP is a function of
capacity--ESP does not correlate well with capacity for wine cellar
refrigeration systems.
---------------------------------------------------------------------------
\29\ The duct material, length, diameter, shape, and
configuration are used to calculate the ESP generated in the duct,
along with the temperature and flow rate of the air passing through
the duct. The conditions during normal operation that result in a
maximum ESP are used to calculate the reported maximum ESP values,
which are dependent on individual unit design and represent
manufacturer-recommended installation and use.
---------------------------------------------------------------------------
Issue 31: DOE requests feedback on its approach for testing ducted
units in its alternate test procedure for wine cellar refrigeration
systems. Specifically, DOE requests comment and supporting data on
whether testing at 50 percent of maximum ESP provides representative
performance values, or whether other fractions of maximum ESP may be
more appropriate. Additionally, DOE seeks comment on other industry
test methods that include the testing of ducted units. Finally, DOE is
interested in other alternative approaches for testing ducted units
that have been demonstrated to provide repeatable and representative
results.
The above discussion assumes that wine cellar refrigeration systems
are either a single-package system or a matched-pair.\30\ However, DOE
has also received a petition for waiver for unit coolers that are
distributed into commerce without a paired condensing system.\31\ DOE
recognizes that these unit cooler-only models will need to be tested
according to the provisions in AHRI 1250-2020 for unit coolers tested
alone, for which calculation of AWEF requires use of an appropriate EER
based on the suction dew point temperature. Table 18 in AHRI 1250-2020
provides EER values for medium and low temperature unit coolers tested
alone. However, these values may not be appropriate for calculating
AWEF for wine cellar unit coolers because this equipment likely
operates with different suction dew point temperature and the
counterpart condensing units likely use different compressor designs
than those considered when developing the current EER values.
---------------------------------------------------------------------------
\30\ A ``matched refrigeration system'' is also called a
``matched pair'' and is a refrigeration system where the condensing
system is distributed into commerce with a specific unit cooler(s).
See 10 CFR 431.302.
\31\ LRC Coil Company submitted a petition for waiver and
interim waiver for specific basic models of unit cooler only walk-in
wine cellar refrigeration systems. (LRC Coil, EERE-2020-BT-WAV-0040,
No. 1) In reviewing another petition for waiver and interim waiver
from Vinotheque for single-package system and matched-pair system
basic models (Vinotheque, EERE-2019-BT-WAV-0038, No. 6), DOE noted
that the manufacturer also offered unit cooler only systems
distributed without a paired condensing system.
---------------------------------------------------------------------------
Issue 32: DOE requests data and information on appropriate EER
values for use in calculating AWEF for wine cellar unit coolers tested
alone, and how these EER values might depend on refrigerant and/or
capacity. DOE requests that commenters provide background explanation
regarding how any such EER recommendations have been developed.
Issue 33: Since unit coolers for wine cellar systems are sold
alone, DOE seeks information on the characteristics of condensing units
that would typically be paired with these unit coolers (e.g., make/
model, compressor style, capacity range, manufacturers).
[[Page 32346]]
Additionally, DOE notes that its definitions for ``single-packaged
system'' and ``unit cooler'' may not appropriately define ducted units.
DOE currently defines a ``single-packaged dedicated system'' as ``a
refrigeration system (as defined in this section) that is a single-
package system assembly that includes one or more compressors, a
condenser, a means for forced circulation of refrigerated air, and
elements by which heat is transferred from air to refrigerant, without
any element external to the system imposing resistance to flow of the
refrigerated air. 10 CFR 431.302. Similarly, DOE defines a ``unit
cooler'' as ``an assembly, including means for forced air circulation
and elements by which heat is transferred from air to refrigerant, thus
cooling the air, without any element external to the cooler imposing
air resistance. Id. Both definitions describe a single-package or unit
cooler system, respectively, that is not ducted (i.e., there is no
element external to the unit that imposes air resistance).
Issue 34: DOE seeks comment on whether, and if so how, it should
modify its definitions for ``single-packaged dedicated system'' and
``unit cooler'' to address units that are designed to be installed with
ducts.
Issue 35: DOE requests comment on any other issues regarding
testing of wine cellar refrigeration systems that may not be fully
addressed by the current DOE test procedure.
3. CO2 Systems
DOE has also become aware of WICF unit coolers that are being used
in CO2 transcritical booster systems that cannot be tested
using the current set of test conditions. DOE has received several test
procedure waiver petitions regarding CO2 unit coolers used
in transcritical booster systems.
Heat Transfer Product Group (``HTPG''), Hussmann, and Keeprite
submitted petitions for waivers and interim waivers from Appendix C for
specific basic models of CO2 direct expansion unit
coolers).\32\ The DOE test procedure for unit coolers requires testing
with liquid inlet saturation temperature of 105 [deg]F and liquid inlet
subcooling temperature of 9 [deg]F, as specified by Tables 15 and 16 of
AHRI 1250-2009. However, CO2 has a critical temperature of
87.8 [deg]F; therefore, it does not coexist as saturated liquid and gas
above this temperature. The liquid inlet saturation temperature of 105
[deg]F and the liquid inlet subcooling temperature of 9 [deg]F
specified in Appendix C are not achievable by CO2 unit
coolers. The three petitioners requested that DOE modify the test
condition values to reflect typical operating conditions for a
transcritical CO2 booster system (i.e., a liquid inlet
saturation temperature of 38 [deg]F and a liquid inlet subcooling
temperature of 5 [deg]F). After reviewing manufacturer websites,
product specification sheets, and suggested alternate test approaches
provided by each manufacturer, DOE has granted waivers or interim
waivers to the manufacturers listed in Table II.3.
---------------------------------------------------------------------------
\32\ Heat Transfer Products Group, Hussmann Corporation, and
Keeprite Refrigeration, respectively, submitted petitions for
waivers and interim waivers for basic models of CO2 unit
coolers used in transcritical booster systems. (HTPG, EERE-2020-BT-
WAV-0025, No. 1; Hussmann, EERE-2020-BT-WAV-0026, No. 1; Keeprite,
EERE-2020-BT-WAV-0028, No. 1).
---------------------------------------------------------------------------
DOE is seeking comment on how to address CO2 system
testing in a way that is representative of the average use cycle for
these units and is not unduly burdensome to conduct.
Issue 36: DOE requests comment on test conditions that would be
most appropriate for evaluating the energy use of CO2 unit
coolers. Additionally, DOE requests feedback on any additional changes
that would need to be made to the DOE test procedure to accurately
evaluate energy use of these systems, while minimizing test burden.
While all CO2 refrigerant waiver petitions DOE has thus
far received address unit coolers for use in transcritical booster
systems, it is possible that other CO2 refrigeration system
configurations may be relevant in the future, e.g., dedicated
condensing units (``DCUs''), matched pairs, or single-package systems.
DOE reviewed product literature and other information for
CO2 systems having some of these alternative configurations.
Most of this information pertains to manufacturers operating in Europe.
Issue 37: DOE requests comment on the present and future expected
use of walk-in refrigeration systems using CO2. DOE requests
specific information about these systems that would suggest a need to
modify the DOE test procedure to address such equipment. Specifically,
DOE requests information on whether such equipment is sold in the U.S.,
whether this equipment is sold as matched pairs or individual
components, and to what extent dedicated condensing units are
configured to supply subcritical liquid (rather than supercritical gas)
to the unit coolers.
4. Defrost Test Method
The April 2011 TP final rule incorporated AHRI 1250-2009 as DOE's
WICF refrigeration system test procedure, including that standard's
requirement that both frosted and dry coil defrost tests be conducted.
Appendix C, Section 3. DOE later noted in the February 2014 AEDM TP
SNOPR that this requirement may be overly burdensome for manufacturers
to conduct, due to the difficulty of maintaining the moist air
infiltration conditions for the frosted coil test in a repeatable
manner. 79 FR 9818, 9831. Accordingly, in DOE's May 2014 AEDM TP final
rule, DOE adopted a set of nominal values for calculating defrost
energy use for a frosted coil, number of defrosts per day if the unit
has an adaptive defrost system, and daily contribution of heat
load.\33\ 79 FR 27388, 27401. To address testing low-temperature
condensing units alone, the May 2014 AEDM TP final rule established
nominal values for the defrost energy use and thermal load. In
addressing refrigeration systems with hot gas defrost, the May 2014
AEDM TP final rule established nominal values for calculating hot gas
defrost energy use and heat load. Id.
---------------------------------------------------------------------------
\33\ In a ``hot gas'' defrost system, high-temperature, high-
pressure hot refrigerant gas from the discharge side of the
compressor is introduced into the evaporator, where it condenses,
thereby releasing latent heat into the evaporator. This heat is used
to melt the frost that has accumulated on the outside of the
evaporator coil.
---------------------------------------------------------------------------
The December 2016 TP final rule removed the method for calculating
the defrost energy and defrost heat load of systems with hot gas
defrost and established a new method to evaluate hot gas defrost
refrigeration systems. That new method treated these hot gas defrost
refrigeration systems as if they used electric defrost rather than hot
gas defrost. This method relied on the same nominal values for defrost
energy use and thermal load that the test procedure prescribes for
electric-defrost condensing units that are tested alone. 81 FR 95758,
95774-95777. This approach was modified in the March 2021 hot gas
defrost TP final rule that amended the test procedure to rate hot gas
defrost unit coolers using modified default values for energy use and
heat load contributions that would make their ratings more consistent
with those of electric defrost unit coolers. 86 FR 16027. The scope of
the March 2021 hot gas defrost TP final rule is limited to unit coolers
only. 86 FR 16027, 16030.
a. Moisture Addition
DOE is considering whether using a test method--possibly similar to
the one detailed in section C11.3 of AHRI 1250-2009--to measure the
energy use associated with the defrosting of frosted coils would
provide a reasonably accurate accounting of defrost energy
[[Page 32347]]
usage and savings associated with technologies such as adaptive defrost
and hot gas defrost. DOE is also considering adopting a test method to
assess and confirm defrost adequacy. Any test method used to measure
defrost energy use and adequacy would have to provide consistent,
repeatable methods for (1) delivering a frost load to the test coil and
(2) measuring the thermal load released into the refrigerated space
during the defrost cycle, regardless of the method of defrost (e.g.,
electric or hot gas defrost), all while ensuring that the procedure
provides results reflecting energy usage during a representative
average use cycle and not be unduly burdensome to conduct.
In AHRI 1250-2009, the moisture to provide a frost load is
introduced through the infiltration of air at 75.2 [deg]F dry-bulb
temperature and 64.4 [deg]F wet-bulb temperature into the walk-in
freezer at a constant airflow rate that depends on the refrigeration
capacity of the tested freezer unit (equations C11 and C12 in section
C11.1.1 of AHRI 1250-2009). A key issue with this approach is the
difficulty in ensuring repeatable frost development on the unit under
test, despite specifying the infiltration air dry-bulb and wet-bulb
temperatures. For example, in addition to frost accumulating on the
evaporator of the unit under test, frost may also accumulate on the
evaporator of other cooling equipment used to condition the room, which
could subsequently affect the rate of frost accumulation on the unit
under test (by affecting the amount of moisture remaining in the air).
ASHRAE-supported research--including a series of projects exploring
frost loads and defrosting dynamics--suggest the possibility of
alternative methods of creating a frost load. This work includes ASHRAE
Project No. 622-RP ``A Study to Determine Heat Loads Due to Coil
Defrosting'' \34\ (``622-RP'') and Project No. 1094-RP ``A Study to
Determine Heat Loads Due to Coil Defrosting-Phase II'' \35\ (``1094-
RP''). For the experiments discussed in these reports, the researchers
created a frost load by introducing steam directly into the
refrigerated space. However, as discussed in 1094-RP, this approach can
result in the suspension of ice crystals in the saturated room air and
the formation of snow-like frost on the test coils. The researchers
found that this snow-like frost degrades refrigeration system
performance more, and is more difficult to defrost, than the ice-like
frost that forms in sub-saturated air conditions. 622-RP and 1094-RP
also observed that during the defrost cycle, a significant portion (a
majority for some trials) of the coil frost was sublimated (converted
to water vapor) rather than melted. This finding suggests that
measuring the quantity of frost melt water mass may be a poor indicator
of the frost load, since a significant portion of the frost would not
be captured as melt water. DOE is interested in any viable alternate
frost load delivery methods that could be used to apply a known and
repeatable amount and type of frost.
---------------------------------------------------------------------------
\34\ Sherif, S.A., P.J. Mago, and R.S. Theen. A Study to
Determine Heat Loads Due to Coil Defrosting. 1997. University of
Florida: Gainesville, FL. ASHRAE Project No. 622-RP. Report No.
UFME/SEECL-9701.
\35\ Sherif, S.A., P.J. Mago, and R.S. Theen. A Study to
Determine Heat Loads Due to Coil Defrosting- Phase II. 2003.
University of Florida: Gainesville, FL. ASHRAE Project No. 1094-RP.
Report No. UFME/SEECL-200201.
---------------------------------------------------------------------------
Issue 38: DOE requests information regarding potential methods of
providing a measurable frost load and frost type for defrost testing,
including data and information demonstrating the repeatability of such
a test. Additionally, DOE requests data and information indicating what
a typical frost load and frost type would be--for example, whether the
moist air flow of section C11.1.1 of AHRI 1250-2009 provides the
appropriate amount of moisture, and if so, whether any data are
available to support the use of this quantity. If such data are
available, DOE asks that interested parties share it with the agency
for further consideration. If such data are currently unavailable, DOE
is interested in what kind and amount of testing would be needed to
sufficiently validate an appropriate method to evaluate frost loads and
frost types during defrost testing.
b. Hot Gas Defrost
Among its various recommendations, the Working Group recommended
that DOE modify its current test procedure to account for hot gas
defrost system performance. (Term Sheet Recommendation #6). As a result
of this recommendation, DOE is interested in obtaining feedback on the
most practicable method for measuring or otherwise accounting for hot
gas defrost performance.\36\ DOE recognizes that in order to assess the
energy performance of a defrost cycle, the test procedure must address
both the energy consumed and the heat released into the refrigerated
space by the defrost system. In general, for electric resistance
heating systems, all the electrical energy consumed by the heater is
transformed into heat, such that the energy consumed by the heater and
the heat released into the space are equivalent. The procedure outlined
in AHRI 1250-2009 is based on this principle and estimates the amount
of heat released into the space by measuring energy consumption and
subtracting the energy associated with frost melt that drains out of
the chamber (section C11.1 of AHRI 1250-2009).
---------------------------------------------------------------------------
\36\ As previously mentioned, the March 2021 hot gas defrost TP
final rule updated the defrost energy use and thermal load equations
for hot gas defrost unit coolers tested alone to provide a
consistent performance evaluation between hot gas defrost and
electric defrost unit coolers when tested alone. 86 FR 16027, 16030.
However, this approach does not measure or account for actual hot
gas defrost thermal load and energy use.
---------------------------------------------------------------------------
Alternatively, for hot gas defrost systems, the heat energy
released into the evaporator (in the form of latent heat), and
ultimately into the refrigerated space, is greater than the electrical
energy used by the compressor to drive the hot gas defrost system. The
exact ratio of heat released to electrical energy consumed depends on
the efficiency of the specific system design. Therefore, the amount of
heat released into the room cannot be estimated by measuring the
electrical energy consumption of the heating system. Because the
procedure outlined in AHRI 1250-2009 relies on an assumption that the
energy consumed by the heater equals the heat released into the space,
it is not applicable to hot gas defrost systems. DOE is not aware of a
test method that can reliably be used to directly measure the thermal
impact of hot gas defrost without a substantial increase in test
burden.
Alternatively, DOE could consider the use of a calculation method.
In such an approach, rather than measure the heat released into the
refrigerated space for the unit-under-test, that heat load would be
calculated as a function of the refrigeration system's steady-state
capacity. The heat load-to-capacity relationship could be defined based
on test data from actual hot gas defrost systems. Under this approach,
the energy consumed by the hot gas defrost system could be quantified
either by direct testing and measurement, or by using a calculation
method, as described for heat load addition. DOE is aware that AHRI has
developed a calculation method to represent hot gas defrost heat load
and energy use contributions. This method is provided in Section C10.1
of AHRI 1250-2020 and prescribes equations to represent energy use and
heat addition associated with defrost for different system
configurations (matched-pair, single-package, unit cooler, condensing
unit) and with consideration of whether hot gas is used only to defrost
the evaporator or
[[Page 32348]]
whether it also maintains warm temperatures in the drip pan.
Finally, if DOE were to modify its walk-in test procedure to
account for hot gas defrost energy consumption and heat load, DOE would
need to determine the types of refrigeration system configurations
(i.e., matched-pairs, stand-alone unit coolers, and stand-alone
condensing units) to which a hot gas defrost-specific test procedure
would apply. For each configuration, DOE would also need to consider
which methods (i.e., testing, calculation, or both) would be most
appropriate.
Issue 39: DOE requests comment on the specific refrigeration system
configurations (i.e., matched-pairs, stand-alone unit coolers, and
stand-alone condensing units) to which a hot gas defrost-specific test
procedure would apply. DOE requests comment on which methods for
determining energy and heat load (i.e., testing, calculation, or both)
would be most appropriate for each refrigeration system and why. DOE
requests comment on the methods related to hot gas defrost systems in
AHRI 1250-2020. Finally, DOE requests data to help quantify the
relationship between hot gas defrost heat load addition and energy
consumption versus capacity and/or to confirm the relationships
provided in the AHRI 1250-2020 test methods for hot gas defrost.
c. Adaptive Defrost
In the December 2016 TP final rule, DOE established a method to
address systems with adaptive defrost. That approach requires that the
feature be deactivated during compliance testing but allows a
manufacturer to account for a unit's improved performance with adaptive
defrost activated in its market representations. 81 FR 95758, 95767,
95777, 95790. At the November 4, 2015 Working Group meeting, Southern
California Edison expressed concern with the assumption that the
overall energy use of traditional defrost systems significantly exceeds
adaptive defrost system energy use. Southern California Edison
presented data showing that, for a tested adaptive defrost system, the
reduction in energy use resulting from reduced defrost frequency is
largely offset by an increase in energy use during the refrigeration
on-cycle, due to the thermal resistance of the increased frost
accumulation (Docket EERE-2015-BT-STD-0016, No. 38 \37\). The data
presented by Southern California Edison illustrates just one potential
complication in properly addressing the energy use impact of adaptive
defrost--specifically, that an adaptive system that waits too long
(i.e., when too much frost builds up on the coils) to defrost may
significantly affect the on-cycle performance of the refrigeration
system. On the other hand, an adaptive system that defrosts too
frequently could increase defrost energy use if the defrost frequency
is higher than the four defrosts per day that is typical for a
conventional timed defrost. The sensitivity of the adaptive defrost
savings potential to the magnitude of the moisture load also suggests
that a single adaptive defrost test using a constant moisture load may
not properly represent this technology's benefits. The test procedure
may have to account for the differences in daily and seasonal frosting
patterns experienced by installed systems (e.g., frequent air
infiltration during business hours and none during non-business hours--
or infiltration of warm, moist air in summer and cool, dry air in
winter).
---------------------------------------------------------------------------
\37\ Working Group Meeting Stakeholder Presentation: Walk-in
Refrigeration ASRAC Meeting, available at https://www.regulations.gov/document?D=EERE-2015-BT-STD-0016-0038.
---------------------------------------------------------------------------
Issue 40: DOE requests comment on how the performance of adaptive
defrost systems should be accounted for in the walk-in test procedure
and which refrigeration systems (i.e., matched-pairs, stand-alone unit
coolers, and stand-alone condensing units) should be evaluated under a
potential adaptive defrost test procedure. Specifically, DOE requests
data showing the performance of adaptive defrost systems relative to
non-controlled defrost systems, including impacts to on-cycle
operation. DOE requests data demonstrating seasonal and daily frosting
patterns for walk-in applications.
5. Off-Cycle Energy Use
As discussed previously, the Working Group recommended that DOE
amend its test procedure to address issues related to off-cycle power
consumption (Term Sheet Recommendation #6). For walk-in refrigeration
systems, the term ``off-cycle'' refers to the period when the
compressor is not running and defrost (if applicable) is not active.
During the off-cycle, unit cooler fans and other auxiliary equipment
will typically run or cycle on and off, thereby consuming energy.
While the current DOE test procedure accounts only for fan power
consumption during the off-cycle period, AHRI 1250-2020 includes
requirements specific to off-cycle fan power consumption in Section
C3.5, which addresses power measurements for unit coolers (including
total power to the fan motor(s), pan heaters, and controls) and DCUs,
in addition to prescribing off-cycle measurement intervals, operating
tolerances and data collection rates. Section C4.2 provides a method
for determining off-cycle power consumption. DOE is considering the
incorporation of this updated industry test method into its test
procedures should a rulemaking be initiated.
Issue 41: DOE requests information and data on whether the off-
cycle methods included in AHRI 1250-2020 provide a representative and
repeatable measure of the off-cycle power use for matched pairs,
single-package systems, and also for unit coolers and/or condensing
units tested alone, and if not, what modifications are recommended. DOE
also seeks information on other off-cycle mode energy-consuming
components that are not currently addressed by AHRI 1250-2020. In
addition to identifying all off-cycle mode energy-consuming components,
DOE seeks information on the patterns and magnitudes of energy use by
each of these components during the off-cycle.
6. Multi-Capacity and Variable-Capacity Condensing Units
In the July 2017 ECS final rule, DOE noted that it expected the
majority of refrigeration equipment within the dedicated condensing
class to be certified as stand-alone condensing units, with a much
smaller number of systems certified as matched-pairs. 82 FR 31808,
31832. However, the current DOE test procedure does not include a
method for assessing stand-alone multi- and variable-capacity systems.
To address this gap, the Working Group recommended that DOE amend its
test procedure to allow for separate ratings of stand-alone variable-
capacity condensing units. (Term Sheet Recommendation #6).
Historically, refrigeration systems have been designed using a
single-speed compressor, which operates at full cooling capacity while
the compressor is on. To match the cooling load of the space, which in
most cases is less than the full cooling capacity of the compressor, a
single-speed compressor cycles on and off at a particular duty cycle.
This cycling behavior introduces inefficiencies due to the surge in
power draw experienced at the beginning of each ``on'' cycle, before
the compressor reaches steady-state performance. In contrast, variable-
capacity systems employ an inverter compressor that can reduce its
speed to match the observed cooling load. Accordingly, a variable-speed
compressor runs continuously, adjusting its speed up or down as
required, thereby avoiding compressor cycling when the full cooling
capacity
[[Page 32349]]
of the compressor is not necessary to provide sufficient cooling to the
space. Similarly, a multi-capacity compressor can ``unload'' individual
cylinders within the compressor, which allows the compressor to remain
on, but at a reduced capacity, to more closely match the required
cooling load.
The current DOE test procedure measures the performance of a walk-
in condensing unit while operating under a full cooling load at a fixed
capacity; i.e., the compressor is operated continuously in its ``on''
state. See AHRI 1250-2009, Tables 11 through 14 and Appendix C, section
3.0. While AHRI 1250-2009 and AHRI 1250-2020 both include test methods
for multi- and variable-capacity matched pair refrigeration systems,
there is no test method for multi- and variable-capacity condensing
units when tested alone. As a result, any inefficiencies due to
compressor cycling, and any performance benefit associated with part-
load operation, are not captured during the DOE test. Consequently, the
current test procedure may underestimate the efficiency benefits of
multi- and variable-capacity systems. DOE is aware of some multi- or
variable- capacity condensing units that are currently available on the
market.\38\
---------------------------------------------------------------------------
\38\ Multi-capacity product information from one manufacturer
can be found at https://www.regulations.gov Docket No. EERE-2017-BT-
TP-0010-0004.
---------------------------------------------------------------------------
Issue 42: DOE requests input on the development of test methods
that would more accurately measure the energy use performance--
including accounting for the potential efficiency benefits of multi-
and variable-capacity systems--both for matched-pair and stand-alone
condensing unit testing. DOE seeks data and information showing the
potential magnitude of energy savings by reducing cycling losses in
these multi and variable-capacity systems. DOE requests market
information on whether there are multi- and variable-capacity
condensing units available on the market (in addition to those already
identified) and the brand name(s) and model numbers of those additional
units.
7. Systems for High-Temperature Freezer Applications
In the June 2014 ECS final rule, DOE established equipment classes
for medium- and low-temperature walk-in refrigeration systems. 79 FR
32050, 32069-32070. While the terms ``medium-temperature'' and ``low-
temperature'' are not explicitly defined, the June 2014 ECS final rule,
2015 ASRAC negotiations, December 2016 TP final rule, and July 2017 ECS
final rule all consistently used the term ``medium-temperature'' to
refer to walk-in cooler/refrigerator refrigeration systems and the term
``low-temperature'' to refer to walk-in freezer refrigeration systems.
The current test procedure for walk-in refrigeration systems
specifies rating conditions of 35 [deg]F for refrigerator systems and -
10 [deg]F for freezer systems (see section 5 of AHRI 1250-2009,
incorporated by reference at 10 CFR 431.303(b)). The 35 [deg]F and -10
[deg]F rating conditions produce a metric, AWEF, which is generally
representative of the medium- and low-temperature refrigeration
systems' energy use when installed in walk-in coolers and freezers,
respectively. The AWEF metric forms the basis for energy conservation
standards for medium- and low-temperature refrigeration systems.
However, field usage data indicate that walk-in refrigeration systems
operate at a broad range of application temperatures both above and
below the respective 35 [deg]F and -10 [deg]F rating points.
As discussed in the December 2016 TP final rule, stakeholders
commented that so-called ``high-temperature'' freezer walk-ins, which
have an enclosed storage (i.e. room) temperature range of 10 [deg]F to
32 [deg]F, are refrigerated with medium-temperature condensing units.
81 FR 95758, 95790. Under the statutory definitions of ``walk-in
cooler'' and ``walk-in freezer,'' this equipment would be considered a
walk-in freezer because its room temperature is less than or equal to
32 [deg]F 42 U.S.C. 6311(20). Accordingly, these refrigeration systems
would be tested using a room temperature of-10 [deg]F, as specified in
Appendix C. However, stakeholders commented as to the difficulty these
medium-temperature refrigeration systems have in meeting this
temperature condition when using lower GWP refrigerants.\39\ 81 FR
95758, 95790. Lennox offered data suggesting that medium-temperature
units generally perform more efficiently at the 10 [deg]F operating
condition (i.e., the low end of the cited ``high-temperature freezer''
temperature range) than low-temperature systems. (Docket EERE-2015-BT-
STD-0016, Lennox, No. 89 \40\ at pp. 2-5) Lennox suggested that this
``high-temperature freezer'' application may justifiably represent a
third class of walk-in refrigeration systems, but also noted the
reporting and testing burden that establishing an additional set of
classes would incur. In response, DOE noted that manufacturers of
equipment that cannot be tested in a way that properly represents their
performance characteristics may petition DOE for test procedure
waivers, as detailed in 10 CFR 431.401. DOE also indicated that it may
consider amending its regulations by establishing new equipment classes
and applicable test methods. 81 FR 95758, 95790-95791.
---------------------------------------------------------------------------
\39\ Lennox commented that the industry was moving to low-GWP
refrigerants in response to the Environmental Protection Agency
final rule under the Significant New Alternatives Policy (``SNAP'')
program that prohibited the use of R-404A in certain retail food
refrigeration applications, including WICF refrigeration systems
starting July 20, 2016. (Docket EERE-2016-BT-TP-0030, Lennox, No. 13
at p. 2) For further discussion of the SNAP rule, see section II.E.8
of this document.
\40\ Available at https://www.regulations.gov/document?D=EERE-2015-BT-STD-0016-0089.
---------------------------------------------------------------------------
DOE is currently considering how, if at all, to address high-
temperature freezer walk-ins, including whether to establish test
procedure provisions to specifically address the refrigeration systems
serving such equipment. Multiple approaches are under consideration.
One approach would allow walk-in manufacturers and contractors to
install a medium temperature refrigeration system that is tested and
certified based on the standardized 35 [deg]F walk-in cooler
temperature (or corresponding refrigerant suction conditions) as a
walk-in freezer, if the walk-in refrigeration system is marketed at or
above 10 [deg]F. By extension, the approach would also allow
representations of performance (e.g. capacity, power input) of such
medium-temperature refrigeration systems for walk-in temperatures at 10
[deg]F and higher without requiring them to be tested and certified
based on the-10 [deg]F low-temperature walk-in test condition. This
approach would alleviate the need for a new high-temperature freezer
equipment class (thus avoiding the associated certification test
burden), while still allowing the potentially more efficient medium
temperature refrigeration systems to be used for high temperature
freezer applications. (Docket EERE-2015-BT-STD-0016, Lennox, No. 89 at
pp. 2-5 (offering data suggesting that medium temperature units
generally perform more efficiently at the 10 [deg]F operating condition
than low-temperature systems)).
DOE could establish new definitions for the terms ``low-temperature
refrigeration system'' and ``medium-temperature refrigeration system,''
that implement this potential structure. For example, ``low-temperature
refrigeration system'' could be defined as ``a refrigeration system
used to cool the interior of walk-in freezers and maintain a
refrigerated room temperature of 10 [deg]F or less,'' while ``medium-
temperature refrigeration system'' could be defined
[[Page 32350]]
as ``a refrigeration system used to cool the interior of a walk-in
cooler or a walk-in freezer operating above 10 [deg]F.''
Alternatively, another approach would allow medium-temperature
refrigeration systems used in high-temperature freezer walk-in
applications to be tested and certified at their lowest application
temperature conditions. This approach would be similar to that taken
for commercial refrigerators, freezers, and refrigerator-freezers, for
which manufacturers report the lowest application product temperature,
i.e. the lowest average compartment temperature at which the equipment
is capable of operating during testing (section 2.2 of appendix B to 10
CFR part 431 subpart C). For walk-ins, this concept could be based on
the lowest evaporator return air temperature for matched-pair
refrigeration systems and the lowest saturated suction temperature (and
a suitable corresponding return gas temperature) for condensing units
tested separately. This approach would result in ratings for the units
in high-temperature freezer applications that are directly
representative of field performance, as the refrigeration system would
be tested at a representative box temperature for such an application.
Further, this approach would not presuppose what the optimal high-
temperature freezer operating condition would be, i.e., it avoids
selecting a standardized condition that may be unachievable by some
units. However, AWEF ratings obtained from the lowest application
temperature for different units, which would be rated for different box
temperatures, would not be directly comparable. The approach would also
add testing and reporting burden associated with the additional test
condition.
DOE is also considering a third approach that would establish a
single standardized test condition at which high-temperature freezer
refrigeration equipment would be tested. This approach would result in
AWEF ratings that are slightly less representative of field performance
than the lowest application temperature approach, while still creating
the potential need to establish a new equipment class (or classes) for
low-temperature refrigeration systems. However, under a standardized
test condition approach, all high-temperature freezer refrigeration
systems would be rated at the same condition, providing directly
comparable ratings for models that serve similar applications.
DOE is investigating if and how the calculations used for
determining the AWEF of WICF condensing units tested alone and with
matched systems would need to be modified for products certified with
the latter two approaches discussed previously--for example, whether
any potential changes to the specified duty cycle at 95 [deg]F ambient
temperature for an outdoor system would be necessary.
Issue 43: DOE requests feedback on the three approaches discussed
in this section to address high-temperature freezer walk-ins, as well
as any other potential approaches not raised in this RFI.
Issue 44: DOE also requests information that would help inform the
development of test procedures for high-temperature freezer
refrigeration systems, should such an approach be necessary.
Additionally, DOE requests whether there are specific characteristics
that distinguish a high-temperature freezer refrigeration system from a
medium-temperature refrigeration system, in order to better define this
category of equipment.
Issue 45: DOE also requests comment on whether 10 [deg]F is the
appropriate lowest end of the application range for equipment used in
walk-in high-temperature freezers that cannot be tested using the -10
[deg]F freezer test condition. Furthermore, DOE requests comment on
whether all medium-temperature systems (matched-pair, condensing unit,
evaporator) can be operated and tested at 10 [deg]F (or equivalent
refrigerant suction conditions), or whether there is a wide range at
the low-end of the operating range that depends on the design of the
system.
Issue 46: Regarding the testing of a medium-temperature
refrigeration system in the high-temperature freezer range, DOE
requests information on what specified test procedure parameters would
need to be altered (and how) in order for the test to be representative
of field operation. (In answering, DOE requests that commenters provide
the supporting reasons for any suggested recommendations.) DOE requests
information on whether a single standardized high-temperature freezer
room condition could be appropriate for testing this group of walk-ins,
and if so, what such an appropriate temperature would be.
Issue 47: Finally, DOE requests comment on what, if any, changes
would be needed in the calculation of AWEF for high-temperature freezer
operation, and why.
If DOE were to pursue the lowest application temperature approach
or the standardized high-temperature freezer test condition approach,
DOE would need to establish certain new default values to calculate the
AWEF and net capacity of stand-alone high-temperature freezer dedicated
condensing units. Currently, the test procedure provides equations for
determining evaporator fan power, defrost energy, and defrost heat
load, all of which are used in lieu of matched unit cooler test data
(section 3.4.2 of Appendix C).
The current test procedure offers two separate equations that
relate the cooling capacity to the evaporator fan power for medium- and
low-temperature unit coolers (section 3.4.2.2 of Appendix C). Based on
the condensing unit capacity at the medium temperature test condition
(35 [deg]F box temperature), using the medium-temperature equation
seems to be the most appropriate approach since the condensing units in
question would also be certified as medium-temperature condensing
units. This approach also assumes that fan energy use at high-
temperature freezer conditions will be the same as fan energy use at
medium-temperature conditions, since it makes no adjustment in the
calculated fan power for the high-temperature freezer application.
Issue 48: DOE requests comment on the appropriateness of using the
current medium-temperature refrigeration system default fan input power
equation (found at section 3.4.2.2 of Appendix C) to represent the fan
input power of high- temperature freezer refrigeration systems. If the
current medium-temperature refrigeration system default fan input power
equation is not representative of the fan input power for high-
temperature freezer refrigeration systems, DOE requests suggestions for
a more appropriate equation, or alternative relationships to consider,
as well as any relevant data.
In the current test procedure, defrost energy and defrost heat load
for stand-alone dedicated condensing units are estimated based on the
condenser capacity using an equation in section 3.4.2 of Appendix C.
The calculations apply only to freezer models, since they assume that
refrigeration systems serving walk-in coolers are not equipped for
defrost capability and thus have no defrost energy or heat load.
However, medium-temperature refrigeration systems designed for high-
temperature freezer applications require defrost capability because
frost that collects on the evaporator during the compressor off-cycle
will not melt in the sub-freezing walk-in temperature conditions. The
energy and heat load of these high-temperature freezer defrost systems
may differ significantly from
[[Page 32351]]
those of -10 [deg]F freezers. Therefore, proper accounting for defrost
of high-temperature freezer refrigeration systems requires developing a
modified calculation. The equation found in section 3.4.2.4 of Appendix
C used to calculate freezer equipment daily defrost energy use (``DF'')
uses as inputs the condenser capacity (``qmix,cd'') and the
number of defrost cycles per day (``NDF''). The daily
defrost heat load (``QDF'') is directly dependent on DF (see
relevant equation in section 3.4.2.5 of Appendix C). DOE anticipates
that a calculation of defrost impacts for high-temperature freezers, if
adopted, would use similar equations with different magnitudes.
Issue 49: DOE requests information or data that would indicate
whether and how the equations used to calculate daily defrost energy
use and heat addition in the test procedure should be modified for
high-temperature freezer refrigeration systems rated as stand-alone
condensing units (e.g., defrost heater wattage and daily energy use as
a function of capacity for a 10 [deg]F walk-in temperature). If testing
at the lowest application temperature is adopted, DOE requests comment
on how the defrost equations should be modified to account for each
model being tested at different conditions, and why. DOE requests
information on whether frost loads and/or defrost frequency are
different for high- temperature freezers than for -10 [deg]F freezers.
(DOE requests that commenters include any available supporting
information when responding.)
8. Consideration for Refrigerant Glide
The analysis for the June 2014 ECS final rule assumed that the
refrigerant R-404A would be used in all new refrigeration equipment
meeting the standard. 79 FR 32050, 32074. In its subsequent negotiated
rulemaking effort in 2015, WICF Working Group members suggested that
DOE revise this approach by accounting for the use of a different
refrigerant, R-407A, which was expected to become more commonly used
for WICF applications. Consistent with that suggestion, DOE conducted
the analysis for the July 2017 ECS final rule using R-407A as the
refrigerant. 82 FR 31808, 31835-31836.
On July 20, 2015, the U.S. Environmental Protection Agency
(``EPA'') published a final rule under the Significant New Alternatives
Policy (``SNAP'') program listing as unacceptable the use of certain
hydrofluorocarbons (``HFCs''), including the use of R-404A in WICF
refrigeration systems. 80 FR 42870 (``July 2015 EPA SNAP Rule''). In
October 2016, the 28th Meeting of the Parties to the Montreal Protocol
adopted the Kigali Amendment on HFCs, which, upon ratification,
requires parties to the protocol to reduce consumption and production
of HFCs.\41\ On December 1, 2016, EPA published a final rule
(``December 2016 EPA SNAP Rule'') that listed a number of refrigerants
for use in certain refrigerant applications as unacceptable, starting
January 1, 2023 for cold storage warehouse application, and January 1,
2021 for retail food refrigerant applications. 81 FR 86778. The list of
unacceptable refrigerants included R-407A. The validity of the SNAP
approach, however, has been the subject of a legal challenge regarding
EPA's use of its SNAP authority to require manufacturers to replace
HFCs with a substitute substance.
---------------------------------------------------------------------------
\41\ https://www.unep.org/ozonaction/Portals/105/documents/7809-e-Factsheet_Kigali_Amendment_to_MP.pdf (last viewed February 3,
2017).
---------------------------------------------------------------------------
In August 2017, the U.S. Court of Appeals for the District of
Columbia Circuit vacated and remanded the July 2015 EPA SNAP Rule to
the extent that it required manufacturers to replace HFCs with a
substitute substance.\42\ Mexichem Fluor, Inc. v. EPA, 866 F.3d 451
(D.C. Cir. 2017). Subsequently, the December 2016 SNAP Rule was
partially vacated by the court.\43\ While the United States has not
ratified the Kigali Amendment, a significant portion of walk-in
refrigeration systems currently use HFC- based refrigerants and may
become affected by this Amendment to the Montreal Protocol. DOE plans
to consider the potential impact (if any) of both the court's decision
and remand as well as the Amendment to the Montreal Protocol on the
test procedure issues addressed in this RFI.
---------------------------------------------------------------------------
\42\ The vacatur and remand in Mexichem, Inc. v. EPA was of the
July 2015 EPA SNAP Rule and did not directly address the December
2016 EPA SNAP Rule. At issue was EPA's use of its SNAP authority as
a means to remove HFCs from the agency's list of acceptable
substitutes. On April 27, 2018, EPA published a notice stating that
in the near-term it will not apply the HFC listings in the July 2015
final rule pending a rulemaking and that it plans to begin a notice-
and-comment rulemaking process to address the remand. 83 FR 18431.
\43\ Following the decision in the Mexichem case, the court
vacated the December 2016 SNAP Rule to the extent it requires
manufacturers to replace HFCs that were previously and lawfully
installed as substitutes for ozone-depleting substances. Case No.
17-1024 (D.C. Cir. April 5, 2019).
---------------------------------------------------------------------------
Notwithstanding these legal developments, key differences between
the refrigerants used in DOE's separate analyses of walk-in
refrigeration systems merit discussion. Both R-404A and R-407A are
blends of refrigerants that have different boiling points. This means
that, unlike pure substances such as water, the temperature of the
refrigerant changes as it boils or condenses, because one of the
refrigerants in the blend, having a lower boiling point, boils off
sooner than the other(s). This phenomenon is called ``glide.'' The
refrigerants that make up R-404A have nearly identical boiling points,
so this refrigerant has very little glide. In contrast, R-407A
undergoes a much more significant temperature change when it boils--the
temperature can rise as much as 8 degrees between the saturated liquid
condition (the temperature at which a liquid begins to boil, also
called the ``bubble point'') and the saturated vapor condition (the
temperature at which a vapor begins to condense, also called the ``dew
point''). The average of these two temperatures, bubble point and dew
point, is called the mid-point temperature.
The current DOE test procedure specifies that test conditions are
based on dew point. DOE notes that if the refrigerant condition for a
unit cooler is specified by dew point, the average refrigerant
temperature would be significantly lower for a high-glide than for a
low-glide refrigerant. As mentioned previously, DOE is considering
changing its test procedure to be based on a refrigerant-neutral
approach. One specific option would be to use the mid-point
temperature. However, with walk-in refrigeration systems, the
refrigerant entering the unit cooler is typically a two-phase
refrigerant with a temperature higher than the bubble point. This
scenario results in the average evaporator temperature being slightly
greater than a mid-point equal to the average of bubble and dew point
temperatures. To account for this difference, DOE could develop an
approach to calculate and specify refrigerant temperatures in terms of
a ``modified mid-point,'' which would be a calculated value slightly
higher than the mid-point of the selected refrigerant.
Issue 50: DOE requests comment on the appropriateness of specifying
refrigerant temperatures in terms of mid-point or a modified mid-point,
rather than dew point, which is currently used. DOE seeks feedback on
potential definitions to use for a modified mid-point temperature as
applied to WICF refrigeration system testing. In addition, DOE requests
comments on what other factors should be considered when modifying the
refrigeration system test conditions from dew point to mid-point or
modified mid-point specifications.
III. Submission of Comments
DOE invites all interested parties to submit in writing by the date
specified
[[Page 32352]]
in the DATES heading, comments and information on matters addressed in
this RFI and on other matters relevant to DOE's early assessment of
whether an amended test procedure for walk-in coolers and freezers is
warranted and if so, what such amendments should be.
Submitting comments via https://www.regulations.gov. The https://www.regulations.gov web page requires you to provide your name and
contact information. Your contact information will be viewable to DOE
Building Technologies staff only. Your contact information will not be
publicly viewable except for your first and last names, organization
name (if any), and submitter representative name (if any). If your
comment is not processed properly because of technical difficulties,
DOE will use this information to contact you. If DOE cannot read your
comment due to technical difficulties and cannot contact you for
clarification, DOE may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment or in any documents attached to your comment.
Any information that you do not want to be publicly viewable should not
be included in your comment, nor in any document attached to your
comment. Persons viewing comments will see only first and last names,
organization names, correspondence containing comments, and any
documents submitted with the comments.
Do not submit to https://www.regulations.gov information for which
disclosure is restricted by statute, such as trade secrets and
commercial or financial information (hereinafter referred to as
Confidential Business Information (``CBI'')). Comments submitted
through https://www.regulations.gov cannot be claimed as CBI. Comments
received through the website will waive any CBI claims for the
information submitted. For information on submitting CBI, see the
Confidential Business Information section.
DOE processes submissions made through https://www.regulations.gov
before posting. Normally, comments will be posted within a few days of
being submitted. However, if large volumes of comments are being
processed simultaneously, your comment may not be viewable for up to
several weeks. Please keep the comment tracking number that https://www.regulations.gov provides after you have successfully uploaded your
comment.
Submitting comments via email. Comments and documents submitted via
email also will be posted to https://www.regulations.gov. If you do not
want your personal contact information to be publicly viewable, do not
include it in your comment or any accompanying documents. Instead,
provide your contact information in a cover letter. Include your first
and last names, email address, telephone number, and optional mailing
address. The cover letter will not be publicly viewable as long as it
does not include any comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. No telefacsimiles (faxes) will
be accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, written in English, and free of any defects or
viruses. Documents should not contain special characters or any form of
encryption and, if possible, they should carry the electronic signature
of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. Pursuant to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email two well-marked copies: One copy of the document marked
``confidential'' including all the information believed to be
confidential, and one copy of the document marked ``non-confidential''
with the information believed to be confidential deleted. Submit these
documents via email. DOE will make its own determination about the
confidential status of the information and treat it according to its
determination.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
DOE considers public participation to be a very important part of
the process for developing test procedures and energy conservation
standards. DOE actively encourages the participation and interaction of
the public during the comment period in each stage of this process.
Interactions with and between members of the public provide a balanced
discussion of the issues and assist DOE in the process. Anyone who
wishes to be added to the DOE mailing list to receive future notices
and information about this process should contact Appliance and
Equipment Standards Program staff at (202) 287-1445 or via email at
[email protected].
IV. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposal, DOE
is particularly interested in receiving comments and views of
interested parties concerning the following issues:
Issue 1: DOE seeks comment on how liquid-cooled refrigeration
systems are (or could be) used with respect to walk-in applications.
DOE requests comment on whether it should consider establishing a test
procedure for liquid-cooled refrigeration systems. If test procedures
were considered for liquid-cooled refrigeration systems, DOE requests
information on whether there is an industry standard or standards that
should be considered.
Issue 2: DOE seeks comment on how wine cellar refrigeration systems
should be defined to best represent the conditions under which these
systems are designed to operate and to fully distinguish these systems
from systems designed to meet safe food storage requirements.
Additionally, DOE requests comment on applications other than wine
cellar storage for refrigeration systems that are designed to operate
at temperatures warmer than typical for coolers and for which testing
at 35 [deg]F would be representative of use. If there are such
additional applications, DOE seeks information regarding the specific
operating requirements (i.e., temperature and humidity) for these
systems.
Issue 3: DOE requests comment on the current definition of ``door''
in 10 CFR 431.302. DOE seeks feedback on the terminology of door
components used and whether these are consistently interpreted. DOE
seeks specific feedback from manufacturers on how they use the term
``door plug'' and whether it is essential to the definition of a WICF
``door''.
Issue 4: DOE requests comment on whether height and width or
surface area are distinct attributes that effectively distinguish
between passage and freight doors. DOE seeks information on any
building codes, standards, or industry practices to support or refute
maintaining the dimensions of a door as the defining
[[Page 32353]]
characteristic which separates freight and passage doors.
Issue 5: Regarding a door that meets the freight door definition
but does so only because it has a multi-door configuration in which the
individual component doors each would by themselves not meet the
freight door definition, DOE seeks comment on how such doors should be
classified, and whether such classification should depend on other
factors, such as whether one or more frame members divides the door
opening into smaller openings.
Issue 6: DOE seeks comment on whether any attribute, or combination
of attributes, other than size, would affect energy use and could be
used to distinguish between freight doors and passage doors. If so, DOE
requests data and comment on such attributes.
Issue 7: DOE requests comment on the accuracy of the computational
method in NFRC 100 to predict U-factor for display and non-display
doors. DOE seeks feedback regarding the differences in results (if any)
between those obtained using the NFRC 100 computational method and
those obtained when conducting physical testing using NFRC 102 for
display and non-display doors. DOE is also interested in the magnitude
of these differences and whether the computational method can be
modified to yield results that more closely match the results obtained
from actual physical testing. If manufacturers are aware of other
methods to predict U-factor for either display doors or non-display
doors besides NFRC 100, DOE requests how the results from these methods
compare to physical testing.
Issue 8: DOE seeks information from manufacturers and other
interested parties regarding how the industry currently rates
individual door models, including the prevalence within the industry of
using the computational method from NFRC 100. DOE also requests
information on the costs associated with the computational method of
NFRC 100 or an alternative computational method compared to physically
testing the thermal transmittance of walk-in doors using NFRC 102.
Issue 9: DOE requests comment on what issues, if any, would be
present if ASTM C518-17 were to be referenced in the Appendix B test
procedure for measuring panel K-factor, or average thermal
conductivity. While not exhaustive, primary areas of interest to DOE
include any differences between the currently referenced version of the
industry standard (ASTM C518-04) and ASTM C518-17 that would result in
a difference in the determined R-value and/or test burden (whether an
increase or decrease), and if there are such differences, the magnitude
of impact to the determined R-value and/or test burden.
Issue 10: DOE requests comment on what issues, if any, would be
present if AHRI 1250-2020 were to be referenced in the Appendix C test
procedure for measuring walk-in refrigeration system AWEF. While not
exhaustive, primary areas of interest to DOE include any differences
between the currently referenced version of the industry standard (AHRI
1250-2009) and AHRI 1250-2020 that would result in a difference in the
determined AWEF and/or test burden (whether an increase or decrease),
and if there are such differences, the magnitude of impact to the
determined AWEF and/or test burden.
Issue 11: DOE requests comment on how manufacturers determine
surface area for the purpose of evaluating compliance with the
standards for both display doors and nondisplay doors. DOE seeks input
on any distinction between display doors and nondisplay doors,
especially the door frames, which may warrant surface area for each to
be determined differently.
Issue 12: DOE seeks feedback on how manufacturers interpret and
measure door opening as it relates to prescriptive standards for
antisweat heaters, including whether or not manufacturers agree that
the door opening considered for antisweat heat should be consistent
with the surface area used to determine maximum energy consumption.
Issue 13: DOE requests feedback on specifying the surface area used
to determine thermal conduction through a walk-in door from the surface
area used to determine the maximum energy consumption of a walk-in
door.
Issue 14: DOE seeks comment on whether, and if so how, an option
for direct component power measurement could be included in the test
procedure or compliance, certification, and enforcement (``CCE'')
provisions to allow more accurate accounting for the direct electrical
energy consumption of WICF doors. DOE also seeks input on whether
specific provisions should be provided for determining power input from
the information that is typically provided on nameplates, noting the
limitations that were described above.
Issue 15: DOE requests comment on the current PTO values and
whether DOE should consider amending any of the current values or
adding specific values for additional electrical components,
specifically motorized door openers. DOE requests data from field
studies or similar sources to support any proposed amendments (or
additions) to these PTO values.
Issue 16: DOE seeks feedback on whether the current PTO of 50
percent is appropriate for evaluating direct energy consumption of
anti-sweat heaters with controls for walk- in cooler doors marketed for
high humidity applications. DOE seeks feedback on the average amount of
time per day or per year that anti-sweat heaters with controls are off
for these high humidity doors and how this compares to standard (i.e.,
non-high humidity) walk-in cooler display doors.
Issue 17: DOE seeks feedback on the current EER values specified in
Appendix A used to calculate daily energy consumption for walk-in doors
and the values used in testing of unit coolers alone, as specified in
Appendix C. Specifically, DOE requests comment on which of these sets
of EER values is more representative, whether DOE should make the
values used for door testing and unit cooler testing consistent with
each other, and if so, which of the sets of values should be used.
Issue 18: DOE requests comment on how frequently test laboratories
perform each of the calibration procedures referenced in ASTM C1199 and
ASTM C1363, e.g., those used to determine calibration coefficients that
are used to calculate metering box wall loss and surround panel
flanking loss. DOE also requests comment on the magnitude of variation
in the calibration coefficients measured during successive
calibrations.
Issue 19: DOE requests feedback on whether the tolerances in
section 5.3(a)(1) of Appendix A applied to the surface heat transfer
coefficients used to measure thermal transmittance are achievable for
all walk-in doors and if not, whether the tolerances should be
increased or omitted. Specifically, DOE seeks data to support any
changes to the tolerances on the surface heat transfer coefficients.
Issue 20: DOE requests comment on how panel thickness is currently
measured for determining the panel's R-value per the DOE test
procedure, including number of measurements, measurement location, and
any steps that are routinely followed for the removal of the protective
skins or facers to obtain the full panel thickness. DOE requests that
commenters identify any specific guidelines, practices or standardized
approaches that are followed, as well as their date of publication, if
applicable.
Issue 21: DOE requests comment on how flatness and parallelism of
the test specimen surfaces that contact the hot
[[Page 32354]]
plate assemblies described in ASTM C518 are typically determined by
test laboratories and whether the test procedure should be revised to
clarify how to determine these parameters, e.g., what type of
instruments are used to measure these values, how many measurements are
made for a given specimen, and other details that could affect
conclusions regarding compliance with the test procedure.
Issue 22: DOE requests comment on the extent to which manufacturers
of insulation specify conditioning for insulation materials that differ
from the typical conditioning approach described in ASTM C518. DOE also
seeks feedback on whether more than one 24-hour conditioning period is
ever needed to complete the conditioning (i.e., the change in specimen
mass is less than 1 percent after the first 24 hours of conditioning)
for a specimen extracted from a WICF panel or door. Finally, DOE
requests information or data on how specimen conditioning times less
than or equal to 24 hours impacts the accuracy, repeatability, and
representativeness of the test.
Issue 23: DOE requests information about panel construction factors
that would affect thermal transmission and the magnitude of the energy
efficiency-related impacts of thermal bridges in the panel assembly.
Additionally, DOE requests comment on alternative test methods that
measure the overall thermal transmittance of walk-in panels and the
relative advantages and disadvantages of each. DOE also seeks feedback
on the number and location of labs that have the facilities and are
qualified to run ASTM C1363-05.
Issue 24: DOE seeks feedback on the current test procedure for
display panels in Appendix A and what amendments should be made, if
any, to it.
Issue 25: DOE requests comment on whether the single-package system
test and calculation methods described in AHRI 1250-2020 provide
representative energy use. DOE also requests comment on whether DOE
should incorporate by reference AHRI 1250-2020 as the test procedure
for single-package systems.
Issue 26: DOE requests any data or calculations quantifying the
additional thermal losses associated with testing single-package
systems due to the exposure of their cold sides to the exterior air
(i.e., surface and infiltration losses). DOE additionally requests
comment on whether the AHRI 1250-2020 test methodology for single-
package systems fully accounts for these additional losses.
Issue 27: DOE requests comment and data on the use of water,
glycol, or other heat transfer liquid in maintaining test compartment
temperature using the calorimeter methods referenced in AHRI 1250-2020
for the testing of single-package refrigeration systems. DOE requests
comment on whether the description and requirements for calorimetric
testing as provided in AHRI 1250-2020 should be modified or enhanced in
order to better ensure that measurements are accurate and repeatable.
Issue 28: DOE requests comment on whether calorimeter test methods
for single-package systems should implement a pressure-equalizing
device, as included in ASHRAE 16-2016. DOE requests information on any
additional cost and resource burdens, if any, manufacturers would face
when employing these methods to evaluate single-package systems.
Issue 29: DOE seeks comment regarding any alternative test methods
not mentioned in this document that could be used to measure single-
package system capacity. To the extent that any alternative test
methods could be used for this purpose, DOE requests information on
their advantages and disadvantages in measuring single-package system
capacity.
Issue 30: DOE requests comment on the alternative test procedure
for wine cellar walk-in refrigeration systems that it has granted in
the interim waivers and waivers listed in Table II.3. DOE additionally
seeks comment on whether the alternative test procedure prescribed for
the specified basic models identified in the waivers would be
appropriate for similar refrigeration equipment.
Issue 31: DOE requests feedback on its approach for testing ducted
units in its alternate test procedure for wine cellar refrigeration
systems. Specifically, DOE requests comment and supporting data on
whether testing at 50 percent of maximum ESP provides representative
performance values, or whether other fractions of maximum ESP may be
more appropriate. Additionally, DOE seeks comment on other industry
test methods that include the testing of ducted units. Finally, DOE is
interested in other alternative approaches for testing ducted units
that have been demonstrated to provide repeatable and representative
results.
Issue 32: DOE requests data and information on appropriate EER
values for use in calculating AWEF for wine cellar unit coolers tested
alone, and how these EER values might depend on refrigerant and/or
capacity. DOE requests that commenters provide background explanation
regarding how any such EER recommendations have been developed.
Issue 33: DOESince unit coolers for wine cellar systems are sold
alone, DOE seeks information on the characteristics of condensing units
that would typically be paired with these unit coolers (e.g., make/
model, compressor style, capacity range, manufacturers).
Issue 34: DOE seeks comment on whether, and if so how, it should
modify its definitions for ``single-packaged dedicated system'' and
``unit cooler'' to address units that are designed to be installed with
ducts.
Issue 35: DOE requests comment on any other issues regarding
testing of wine cellar refrigeration systems that may not be fully
addressed by the current DOE test procedure.
Issue 36: DOE requests comment on test conditions that would be
most appropriate for evaluating the energy use of CO\2\ unit coolers.
Additionally, DOE requests feedback on any additional changes that
would need to be made to the DOE test procedure to accurately evaluate
energy use of these systems, while minimizing test burden.
Issue 37: DOE requests comment on the present and future expected
use of walk-in refrigeration systems using CO2. DOE requests
specific information about these systems that would suggest a need to
modify the DOE test procedure to address such equipment. Specifically,
DOE requests information on whether such equipment is sold in the U.S.,
whether this equipment is sold as matched pairs or individual
components, and to what extent dedicated condensing units are
configured to supply subcritical liquid (rather than supercritical gas)
to the unit coolers.
Issue 38: DOE requests information regarding potential methods of
providing a measurable frost load and frost type for defrost testing,
including data and information demonstrating the repeatability of such
a test. Additionally, DOE requests data and information indicating what
a typical frost load and frost type would be--for example, whether the
moist air flow of section C11.1.1 of AHRI 1250-2009 provides the
appropriate amount of moisture, and if so, whether any data are
available to support the use of this quantity. If such data are
available, DOE asks that interested parties share it with the agency
for further consideration. If such data are currently unavailable, DOE
is interested in what kind and amount of testing would be needed to
sufficiently validate an appropriate method to evaluate frost loads and
frost types during defrost testing.
Issue 39: DOE requests comment on the specific refrigeration system
configurations (i.e., matched-pairs,
[[Page 32355]]
stand-alone unit coolers, and stand-alone condensing units) to which a
hot gas defrost-specific test procedure would apply. DOE requests
comment on which methods for determining energy and heat load (i.e.,
testing, calculation, or both) would be most appropriate for each
refrigeration system and why. DOE requests comment on the methods
related to hot gas defrost systems in AHRI 1250- 2020. Finally, DOE
requests data to help quantify the relationship between hot gas defrost
heat load addition and energy consumption versus capacity and/or to
confirm the relationships provided in the AHRI 1250-2020 test methods
for hot gas defrost.
Issue 40: DOE requests comment on how the performance of adaptive
defrost systems should be accounted for in the walk-in test procedure
and which refrigeration systems (i.e., matched-pairs, stand-alone unit
coolers, and stand-alone condensing units) should be evaluated under a
potential adaptive defrost test procedure. Specifically, DOE requests
data showing the performance of adaptive defrost systems relative to
non-controlled defrost systems, including impacts to on-cycle
operation. DOE requests data demonstrating seasonal and daily frosting
patterns for walk-in applications.
Issue 41: DOE requests information and data on whether the off-
cycle methods included in AHRI 1250-2020 provide a representative and
repeatable measure of the off-cycle power use for matched pairs,
single-package systems, and also for unit coolers and/or condensing
units tested alone, and if not, what modifications are recommended. DOE
also seeks information on other off-cycle mode energy-consuming
components that are not currently addressed by AHRI 1250-2020. In
addition to identifying all off-cycle mode energy-consuming components,
DOE seeks information on the patterns and magnitudes of energy use by
each of these components during the off-cycle.
Issue 42: DOE requests input on the development of test methods
that would more accurately measure the energy use performance--
including accounting for the potential efficiency benefits of multi-
and variable-capacity systems--both for matched-pair and stand-alone
condensing unit testing. DOE seeks data and information showing the
potential magnitude of energy savings by reducing cycling losses in
these multi and variable-capacity systems. DOE requests market
information on whether there are multi- and variable-capacity
condensing units available on the market (in addition to those already
identified) and the brand name(s) and model numbers of those additional
units.
Issue 43: DOE requests feedback on the three approaches discussed
in this section to address high-temperature freezer walk-ins, as well
as any other potential approaches not raised in this RFI.
Issue 44: DOE also requests information that would help inform the
development of test procedures for high-temperature freezer
refrigeration systems, should such an approach be necessary.
Additionally, DOE requests whether there are specific characteristics
that distinguish a high-temperature freezer refrigeration system from a
medium-temperature refrigeration system, in order to better define this
category of equipment.
Issue 45: DOE also requests comment on whether 10 [deg]F is the
appropriate lowest end of the application range for equipment used in
walk-in high-temperature freezers that cannot be tested using the -10
[deg]F freezer test condition. Furthermore, DOE requests comment on
whether all medium-temperature systems (matched-pair, condensing unit,
evaporator) can be operated and tested at 10 [deg]F (or equivalent
refrigerant suction conditions), or whether there is a wide range at
the low-end of the operating range that depends on the design of the
system.
Issue 46: Regarding the testing of a medium-temperature
refrigeration system in the high-temperature freezer range, DOE
requests information on what specified test procedure parameters would
need to be altered (and how) in order for the test to be representative
of field operation. (In answering, DOE requests that commenters provide
the supporting reasons for any suggested recommendations.) DOE requests
information on whether a single standardized high-temperature freezer
room condition could be appropriate for testing this group of walk-ins,
and if so, what such an appropriate temperature would be.
Issue 47: Finally, DOE requests comment on what, if any, changes
would be needed in the calculation of AWEF for high-temperature freezer
operation, and why.
Issue 48: DOE requests comment on the appropriateness of using the
current medium-temperature refrigeration system default fan input power
equation (found at section 3.4.2.2 of Appendix C) to represent the fan
input power of high-temperature freezer refrigeration systems. If the
current medium-temperature refrigeration system default fan input power
equation is not representative of the fan input power for high-
temperature freezer refrigeration systems, DOE requests suggestions for
a more appropriate equation, or alternative relationships to consider,
as well as any relevant data.
Issue 49: DOE requests information or data that would indicate
whether and how the equations used to calculate daily defrost energy
use and heat addition in the test procedure should be modified for
high-temperature freezer refrigeration systems rated as stand-alone
condensing units (e.g., defrost heater wattage and daily energy use as
a function of capacity for a 10 [deg]F walk-in temperature). If testing
at the lowest application temperature is adopted, DOE requests comment
on how the defrost equations should be modified to account for each
model being tested at different conditions, and why. DOE requests
information on whether frost loads and/or defrost frequency are
different for high-temperature freezers than for -10 [deg]F freezers.
(DOE requests that commenters include any available supporting
information when responding.)
Issue 50: DOE requests comment on the appropriateness of specifying
refrigerant temperatures in terms of mid-point or a modified mid-point,
rather than dew point, which is currently used. DOE seeks feedback on
potential definitions to use for a modified mid-point temperature as
applied to WICF refrigeration system testing. In addition, DOE requests
comments on what other factors should be considered when modifying the
refrigeration system test conditions from dew point to mid-point or
modified mid-point specifications.
[[Page 32356]]
Signing Authority
This document of the Department of Energy was signed on June 3,
2021, by Kelly Speakes-Backman, Principal Deputy Assistant Secretary
and Acting Assistant Secretary for Energy Efficiency and Renewable
Energy, pursuant to delegated authority from the Secretary of Energy.
That document with the original signature and date is maintained by
DOE. For administrative purposes only, and in compliance with
requirements of the Office of the Federal Register, the undersigned DOE
Federal Register Liaison Officer has been authorized to sign and submit
the document in electronic format for publication, as an official
document of the Department of Energy. This administrative process in no
way alters the legal effect of this document upon publication in the
Federal Register.
Signed in Washington, DC, on June 4, 2021.
Treena V. Garrett,
Federal Register Liaison Officer, U.S. Department of Energy.
[FR Doc. 2021-12081 Filed 6-16-21; 8:45 am]
BILLING CODE 6450-01-P