# 75 FR 186: Energy Conservation Program: Test Procedures for Walk-In Coolers and Walk-In Freezers

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URL: https://www.frixlaw.com/law-library/statutes/FR_PRORULE_E9-30884

## Section

- **Citation:** 75 FR 186
- **Heading:** Energy Conservation Program: Test Procedures for Walk-In Coolers and Walk-In Freezers
- **Jurisdiction:** Federal
- **Kind:** Regulations
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** Federal Register / Vol. 75 / 75 FR 186

## Text

DEPARTMENT OF ENERGY 10 CFR Part 431 [Docket No. EERE-2008-BT-TP-0014] RIN 1904-AB85 Energy Conservation Program: Test Procedures for Walk-In Coolers and Walk-In Freezers AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION:
Notice of proposed rulemaking and public meeting.

SUMMARY:
Pursuant to the Energy Policy and Conservation Act, as amended, the U.S. Department of Energy (DOE) is proposing test procedures for measuring the energy consumption of walk-in coolers and walk-in freezers (collectively “walk-in equipment” or “walk-in(s)”), definitions to delineate the products covered by the test procedures, and provisions (including a sampling plan) for manufacturers to implement the test procedures. The notice also addresses enforcement issues as they relate to walk-in equipment. Concurrently, DOE is undertaking an energy conservation standards rulemaking for this equipment. Any data gathered through the use of the test procedure adopted by DOE will be used in evaluating any potential standards for this equipment. Once these standards are promulgated, the adopted test procedures will be used to determine equipment efficiency and compliance with the standards.

DATES:
DOE will hold a public meeting in Washington, DC on Thursday, February 11, 2010, beginning at 9 a.m. DOE must receive requests to speak at the meeting before 4 p.m., Thursday, January 28, 2010. DOE must receive a signed original and an electronic copy of statements to be given at the public meeting before 4 p.m., Thursday, January 28, 2010.
DOE will accept comments, data, and information regarding this notice of proposed rulemaking (NOPR) before or after the public meeting, but no later than March 22, 2010. See section V, “Public Participation,” of this NOPR for details.

ADDRESSES:
The public meeting will be held at the U.S. Department of Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue, SW., Washington, DC 20585-0121. To attend the public meeting, please notify Ms
ng this notice of proposed rulemaking (NOPR) before or after the public meeting, but no later than March 22, 2010. See section V, “Public Participation,” of this NOPR for details.

ADDRESSES:
The public meeting will be held at the U.S. Department of Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue, SW., Washington, DC 20585-0121. To attend the public meeting, please notify Ms. Brenda Edwards at (202) 586-2945. Please note that foreign nationals participating in the public meeting are subject to advance security screening procedures, requiring a 30-day advance notice. If you are a foreign national and wish to participate in the public meeting, please inform DOE as soon as possible by contacting Ms. Brenda Edwards at (202) 586-2945 so that the necessary procedures can be completed.
Any comments submitted must identify the NOPR for Test Procedures for Walk-in Coolers and Freezers, and provide docket number EERE-2008-BT-TP-0014 and/or Regulation Identifier Number (RIN) 1904-AB85. Comments may be submitted using any of the following methods:
1. Federal eRulemaking Portal: http://www.regulations.gov . Follow the instructions for submitting comments.
2. E-mail: WICF-2008-TP-0014@hq.doe.gov . Include the docket number EERE-2008-BT-TP-0014 and/or RIN 1904-AB85 in the subject line of the message.
3. Postal Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Please submit one signed original paper copy.
4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 950 L'Enfant Plaza, SW., 6th Floor, Washington, DC 20024. Please submit one signed original paper copy.
For detailed instructions on submitting comments and additional information on the rulemaking process, see section V, “Public Participation,” of this document.
Docket: For access to the docket to read background documents or comments received, visit the U.S
gy, Building Technologies Program, 950 L'Enfant Plaza, SW., 6th Floor, Washington, DC 20024. Please submit one signed original paper copy.
For detailed instructions on submitting comments and additional information on the rulemaking process, see section V, “Public Participation,” of this document.
Docket: For access to the docket to read background documents or comments received, visit the U.S. Department of Energy, Resource Room of the Building Technologies Program, 950 L'Enfant Plaza, SW., 6th Floor, Washington, DC 20024, (202) 586-2945, between 9 a.m. and 4 p.m. Monday through Friday, except Federal holidays. Please call Ms. Brenda Edwards at the above telephone number for additional information regarding visiting the Resource Room.
FOR FURTHER INFORMATION CONTACT:
Mr. Charles Llenza, U.S. Department of Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121, (202) 586-2192, Charles.Llenza@ee.doe.gov or Mr. Michael Kido, Esq., U.S. Department of Energy, Office of General Counsel, GC-72, 1000 Independence Avenue, SW., Washington, DC 20585- 0121, (202) 586-8145, Michael.Kido@hq.doe.gov .

SUPPLEMENTARY INFORMATION:
Table of Contents
I. Authority and Background II. Summary of the Proposal III. Discussion A. Overall Approach 1. Basic Model 2. Approach Option 1: Test the Unit as a Whole 3. Approach Option 2: Allow Manufacturers To Use Alternative Energy Determination Methods (AEDMs) 4. Proposed Option and Recommendation: Separate Envelope and Refrigeration Tests B. Envelope 1. Overview of the Test Procedure 2. Test Methods a. Insulation b. Air Infiltration c. Steady-State Infiltration Test 3. Calculations a. Energy Efficiency Ratio b. Heat Gain Through the Envelope Due to Conduction c. Heat Gain Due to Infiltration d. Envelope Component Electrical Loads e. Normalization f. Daily Energy Consumption Coefficients C. Refrigeration System 1. Overview of the Test Procedure 2. Test Conditions 3. Test Methods 4. Measurements and Calculations D
Infiltration c. Steady-State Infiltration Test 3. Calculations a. Energy Efficiency Ratio b. Heat Gain Through the Envelope Due to Conduction c. Heat Gain Due to Infiltration d. Envelope Component Electrical Loads e. Normalization f. Daily Energy Consumption Coefficients C. Refrigeration System 1. Overview of the Test Procedure 2. Test Conditions 3. Test Methods 4. Measurements and Calculations D. Compliance, Certification, and Enforcement 1. Provisions for Energy Conservation Standards Developed by the Department of Energy 2. Provisions for Existing Design Standards Prescribed by Congress IV. Regulatory Review A. Review Under Executive Order 12866 B. Review Under the National Environmental Policy Act C. Review Under the Regulatory Flexibility Act D. Review Under the Paperwork Reduction Act E. Review Under the Unfunded Mandates Reform Act of 1995 F. Review Under the Treasury and General Government Appropriations Act, 1999 G. Review Under Executive Order 13132 H. Review Under Executive Order 12988 I. Review Under the Treasury and General Government Appropriations Act, 2001 J. Review Under Executive Order 13211 K. Review Under Executive Order 12630 L. Review Under Section 32 of the Federal Energy Administration (FEA) Act of 1974 V. Public Participation A. Attendance at Public Meeting B. Procedure for Submitting Requests to Speak C. Conduct of Public Meeting D. Submission of Comments E. Issues on Which DOE Seeks Comment 1. Test Procedure Improvements 2. Basic Model 3. Separate Envelope and Refrigeration Tests 4. Definition of Envelope 5. Effect of Impermeable Skins on Long-Term R Value 6. Measuring Long-Term R Value Using American Society for Testing and Materials (ASTM) C1303-08 7. Infiltration 8. Nominal Coefficient of Performance of Refrigeration 9. Measuring the U Value of glass 10. Floor R Value 11. Electrical Duty Cycle 12. Normalization Factor 13. Daily Energy Consumption Coefficients 14. Definition of Refrigeration System 15. Measurements and Calculations of Energy Use of Refrigeration Systems 16
alue Using American Society for Testing and Materials (ASTM) C1303-08 7. Infiltration 8. Nominal Coefficient of Performance of Refrigeration 9. Measuring the U Value of glass 10. Floor R Value 11. Electrical Duty Cycle 12. Normalization Factor 13. Daily Energy Consumption Coefficients 14. Definition of Refrigeration System 15. Measurements and Calculations of Energy Use of Refrigeration Systems 16. Impacts on Small Businesses VI. Approval of the Office of the Secretary I. Authority and Background
Title III of the Energy Policy and Conservation Act of 1975, as amended (EPCA or the Act) sets forth a variety of provisions designed to improve energy efficiency. Part B of Title III (42 U.S.C. 6291-6309) provides for the Energy Conservation Program for Consumer Products Other Than Automobiles. The National Energy Conservation Policy Act (NECPA), Public Law 95-619, amended EPCA to add Part C of Title III, which established an energy conservation program for certain industrial equipment. (42 U.S.C. 6311-6317) (These parts were subsequently redesignated as Parts A and A-1, respectively, for editorial reasons.) Section 312 of the Energy Independence and Security Act of 2007 (EISA 2007) further amended EPCA by adding certain equipment to this energy conservation program, including walk-in coolers and walk-in freezers (collectively “walk-in equipment” or “walk-ins”), the subject of this rulemaking. (42 U.S.C. 6311(1), (2), 6313(f) and 6314(a)(9))
EPCA defines walk-in equipment as follows:
(A) In general.—
The terms “walk-in cooler” and “walk-in freezer” mean an enclosed storage space refrigerated to temperatures, respectively, above, and at or below 32 degrees Fahrenheit that can be walked into, and has a total chilled storage area of less than 3,000 square feet.
(B) Exclusion.—
The terms “walk-in cooler” and “walk-in freezer” do not include products designed and marketed exclusively for medical, scientific, or research purposes. (42 U.S.C
r” mean an enclosed storage space refrigerated to temperatures, respectively, above, and at or below 32 degrees Fahrenheit that can be walked into, and has a total chilled storage area of less than 3,000 square feet.
(B) Exclusion.—
The terms “walk-in cooler” and “walk-in freezer” do not include products designed and marketed exclusively for medical, scientific, or research purposes. (42 U.S.C. 6311(20))
Walk-ins covered by this rulemaking may be located indoors or outdoors. They may be used exclusively for storage, but they may also have transparent doors or panels for the purpose of displaying stored items. Examples of items that may be stored in walk-ins include, but are not limited to, food, beverages, and flowers. DOE notes that any equipment that meets the above definition is potentially subject to regulation.
Under the Act, the overall program consists essentially of the following parts: testing, labeling, and Federal energy conservation standards. The testing requirements for covered equipment consist of test procedures, prescribed under EPCA. These test procedures are used in several different ways: (1) Any data from the use of these procedures are used as a basis in developing standards for covered products or equipment; (2) the test procedure is used when determining equipment compliance with those standards; and (3) manufacturers of covered equipment must use the procedure to establish that their equipment complies with energy conservation standards promulgated pursuant to EPCA and when making representations about equipment efficiency.
Section 343 of EPCA (42 U.S.C. 6314) sets forth generally applicable criteria and procedures for DOE's adoption and amendment of such test procedures. That provision requires that the test procedures promulgated by DOE be reasonably designed to produce test results which reflect energy efficiency, energy use, and estimated operating costs of the covered equipment during a representative average use cycle
343 of EPCA (42 U.S.C. 6314) sets forth generally applicable criteria and procedures for DOE's adoption and amendment of such test procedures. That provision requires that the test procedures promulgated by DOE be reasonably designed to produce test results which reflect energy efficiency, energy use, and estimated operating costs of the covered equipment during a representative average use cycle. It also requires that the test procedure not be unduly burdensome to conduct. See 42 U.S.C. 6314(a)(2). As part of the process for promulgating a test procedure, DOE must publish the procedure that it plans to propose and offer the public an opportunity to present oral and written comments on them. Consistent with Executive Order 12889 and EPCA (see 42 U.S.C. 6314(b)), DOE provides a minimum comment period of 75 days on a proposed test procedure. As to the test procedures for walk-in equipment, EPCA prescribes the following requirements:
(A) In general.—
For the purpose of test procedures for walk-in coolers and walk-in freezers:
(i) The R value shall be the 1/K factor multiplied by the thickness of the panel.
(ii) The K factor shall be based on ASTM [American Society for Testing and Materials] test procedure C518-2004.
(iii) For calculating the R value for freezers, the K factor of the foam at 20 °F (average foam temperature) shall be used.
(iv) For calculating the R value for coolers, the K factor of the foam at 55 °F (average foam temperature) shall be used.
(B) Test Procedure.—
f the panel.
(ii) The K factor shall be based on ASTM [American Society for Testing and Materials] test procedure C518-2004.
(iii) For calculating the R value for freezers, the K factor of the foam at 20 °F (average foam temperature) shall be used.
(iv) For calculating the R value for coolers, the K factor of the foam at 55 °F (average foam temperature) shall be used.
(B) Test Procedure.—
(i) In general.—Not later than January 1, 2010, the Secretary shall establish a test procedure to measure the energy-use of walk-in coolers and walk-in freezers.
(ii) Computer modeling.—The test procedure may be based on computer modeling, if the computer model or models have been verified using the results of laboratory tests on a significant sample of walk-in coolers and walk-in freezers. (42 U.S.C. 6314(a)(9))
On February 4, 2009, DOE held a public meeting on the framework document it issued concerning the DOE rulemaking to evaluate walk-in equipment for energy conservation standards. See 74 FR 411 (Jan. 6, 2009) and 74 FR 1992 (Jan. 14, 2009). Both the framework document and meeting discussed the possible test procedures for this equipment that DOE was considering at that time, and gave interested parties an opportunity to submit comments. Today's notice addresses those comments and proposes test procedures for walk-in equipment.
II. Summary of the Proposal
In today's notice, DOE proposes to adopt new test procedures for determining the energy use of walk-in cooler and walk-in freezer equipment to address the statutory requirement to establish a test procedure by January 1, 2010. (42 U.S.C. 6314(a)(9)(B)) Concurrently, DOE is undertaking an energy conservation standards rulemaking for walk-in equipment to address the statutory requirement to establish performance standards no later than January 1, 2012. (42 U.S.C. 6313(f)(4)(A)) DOE will use any data resulting from use of the test procedure that DOE adopts to evaluate potential performance standards for this equipment
010. (42 U.S.C. 6314(a)(9)(B)) Concurrently, DOE is undertaking an energy conservation standards rulemaking for walk-in equipment to address the statutory requirement to establish performance standards no later than January 1, 2012. (42 U.S.C. 6313(f)(4)(A)) DOE will use any data resulting from use of the test procedure that DOE adopts to evaluate potential performance standards for this equipment. Furthermore, once performance standards are issued, manufacturers would be required to use the test procedures to determine compliance with such standards and for any representations regarding the energy use of walk-in equipment they produce. This test procedure, once adopted, would serve as the means for ascertaining compliance with the appropriate standards in an enforcement action.
For the reasons described below, DOE proposes to adopt a test procedure that contains two separate test methods. This approach is necessary because there are typically two manufacturers of walk-in equipment: One who manufactures the envelope ( i.e. , the insulated box in which the refrigerated or frozen items are stored) and one who manufactures the refrigeration system ( i.e. , the mechanism that provides the means by which to feed chilled air into the envelope). One method determines the
Using this approach, DOE believes that the proposed test procedures will adequately measure the energy consumption of walk-in equipment by capturing the energy consumption of both components. However, DOE requests comment from stakeholders on improvements or changes to the proposed test procedures and will consider modifications that improve the accuracy, appropriateness for the equipment being tested, repeatability of test results for the same or similar units, comparability of results for different types of units, burden on manufacturers, precision of language, or other elements of the procedures
requests comment from stakeholders on improvements or changes to the proposed test procedures and will consider modifications that improve the accuracy, appropriateness for the equipment being tested, repeatability of test results for the same or similar units, comparability of results for different types of units, burden on manufacturers, precision of language, or other elements of the procedures. In submitting comments, interested parties should state the nature of the recommended modification and explain how it would improve upon the test procedure proposed in this NOPR. Commenters should also submit data, if any, to support their positions.
DOE's adoption of the proposed test procedures, which would be applicable to all walk-in equipment, would not necessarily mean that DOE would adopt a single energy conservation standard or set of labeling requirements for all walk-in equipment. In the separate rulemaking proceeding concerning energy conservation standards for walk-in equipment, DOE may divide such equipment into classes and may conclude that standards are not warranted for some classes of equipment that are within the scope of today's test procedure. Furthermore, DOE may create a separate standard for each class of equipment that includes a utility- or performance-related feature that another equipment class lacks, and that affects energy consumption.
DOE also notes that the National Technology Transfer and Advancement Act of 1995 (Pub. L. 104-113) directs Federal agencies to use voluntary consensus standards in lieu of Government standards whenever possible
may create a separate standard for each class of equipment that includes a utility- or performance-related feature that another equipment class lacks, and that affects energy consumption.
DOE also notes that the National Technology Transfer and Advancement Act of 1995 (Pub. L. 104-113) directs Federal agencies to use voluntary consensus standards in lieu of Government standards whenever possible. Consequently, as described in the following paragraphs, DOE attempted to incorporate by reference in its test procedures generally accepted rules or recognized industry standards such as those issued by the Air-Conditioning, Heating and Refrigeration Institute (AHRI), the American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE), the American National Standards Institute (ANSI), and/or ASTM International (ASTM), that provide either specific aspect(s) of the test procedure, or the complete test procedure, for the specified equipment.
III. Discussion
In the following section, DOE describes the overall approach it proposes to follow with respect to the adoption of a test procedure for walk-ins. This approach results from the characteristics of walk-in equipment and is based in part on the basic model definition that DOE currently uses to help establish testing requirements for manufacturers to follow. The following section also addresses issues raised by commenters, which included: Manufacturers (Craig Industries (Craig), Manitowoc, Nor-Lake); trade associations (AHRI); utility companies (Southern California Edison (SCE), Sacramento Municipal Utility District (SMUD), San Diego Gas and Electric (SDG&E)); and advocacy groups (Appliance Standards Awareness Project (ASAP), American Council for an Energy-Efficient Economy (ACEEE), Natural Resources Defense Council (NRDC), Northwest Energy Efficiency Alliance (NEEA)).
A. Overall Approach
DOE developed today's proposed test procedure to set forth the testing requirements for walk-in equipment
ity District (SMUD), San Diego Gas and Electric (SDG&E)); and advocacy groups (Appliance Standards Awareness Project (ASAP), American Council for an Energy-Efficient Economy (ACEEE), Natural Resources Defense Council (NRDC), Northwest Energy Efficiency Alliance (NEEA)).
A. Overall Approach
DOE developed today's proposed test procedure to set forth the testing requirements for walk-in equipment. In the framework document, DOE considered two overall approaches manufacturers could take to determine the energy consumption of walk-in coolers and freezers. First, DOE considered using a modified version of the Air-Conditioning and Refrigeration Institute (ARI) Standard 1200-2006, “Performance Rating of Commercial Refrigerated Display Merchandisers and Storage Cabinets” (ARI 1200-2006), which uses the test method described in the American National Standards Institute/American Society of Heating, Refrigerating, and Air Conditioning Engineers (ANSI/ASHRAE) Standard 72-2005, “Method of Testing Commercial Refrigerators and Freezers” (ANSI/ASHRAE 72-2005). Second, DOE considered allowing manufacturers to determine the efficiency of some of their products using alternative efficiency determination methods (AEDMs). (An AEDM is a predictive mathematical model, developed from engineering analyses of design data and substantiated by actual test data, which represents the energy consumption characteristics of one or more basic models.)
DOE received comments on these proposed approaches, many of which were opposed to both approaches. The comments DOE received, and DOE's responses, are discussed in more detail below. After considering these comments and reviewing the matter further, DOE is proposing separate test procedures for the envelope (insulated box) and the refrigeration system. DOE discusses the details of its proposals and addresses manufacturer comments in the following subsections.
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ere opposed to both approaches. The comments DOE received, and DOE's responses, are discussed in more detail below. After considering these comments and reviewing the matter further, DOE is proposing separate test procedures for the envelope (insulated box) and the refrigeration system. DOE discusses the details of its proposals and addresses manufacturer comments in the following subsections.
1. Basic Model
Under EPCA, which prohibits the distribution in commerce of covered equipment that do not comply with the applicable standard, each model of covered equipment is potentially subject to energy efficiency testing consistent with the relevant requirements for that equipment. However, walk-in manufacturers typically make numerous envelope models and, even within a single model, the units are often customized in multiple ways. To reduce this potential burden, DOE proposes following the approach it has used for other equipment by allowing manufacturers to group equipment or models with essentially identical energy consumption characteristics into a single family of models, called a basic model. This concept has been established both for residential appliances and commercial and industrial equipment covered under EPCA. (See Title 10 of the Code of Federal Regulations (10 CFR) 430.2, which covers 26 products, and 10 CFR 431.12, 431.62, 431.132, 431.172, 431.192, 431.202, 431.222, 431.262, and 431.292, which cover various equipment.)
Walk-in refrigeration systems are often manufactured according to the same basic blueprint design, and any particular model could incorporate modifications that do not significantly affect the energy efficiency of the system. For example, manufacturers often sell systems that are designed to operate at different voltages. This allows them to market to customers with different electrical capabilities
lk-in refrigeration systems are often manufactured according to the same basic blueprint design, and any particular model could incorporate modifications that do not significantly affect the energy efficiency of the system. For example, manufacturers often sell systems that are designed to operate at different voltages. This allows them to market to customers with different electrical capabilities. The operating voltage affects the energy
Walk-in envelopes are often manufactured according to the same basic design, but the equipment is so highly customized that each walk-in a manufacturer builds may be unique, and potentially subject to testing as a separate basic model. For instance, changing the size of the envelope would affect the energy consumption obtained by the test procedure, even if the construction methods and materials were the same. To address this possibility, DOE proposes (1) grouping walk-in envelopes with essentially identical construction methods, materials, and components into a single basic model, and (2) adopting a calculation methodology for determining the energy consumption of units within the basic model. This methodology would require a manufacturer to test one unit of the basic model and then calculate daily energy consumption coefficients (DECCs) for that basic model according to the test procedure. The manufacturer could then apply those DECCs to other units within a basic model even if those units were not identical, to obtain the energy consumption of those units. Although units within a basic model need not share identical dimensions, finishes, and non-energy-related features ( e.g. , shelving or door kick plates), they must have been manufactured using substantially the same construction methods, materials, and components. A few examples of factors that would necessitate a different basic model include changing the type of insulating foam, the method of locking together the panels of the walk-in envelope, or the electrical characteristics of the lighting
ated features ( e.g. , shelving or door kick plates), they must have been manufactured using substantially the same construction methods, materials, and components. A few examples of factors that would necessitate a different basic model include changing the type of insulating foam, the method of locking together the panels of the walk-in envelope, or the electrical characteristics of the lighting. Examples of factors that may not constitute a different basic model include the type of exterior metal finish, the dimensions of the envelope, and the number of doors of the same type. The exterior metal finish would not have a substantial impact on the efficiency of the envelope. Dimensions and number of doors, on the other hand, would be accounted for in the energy consumption calculation using the DECCs from the unit of the basic model that was tested. (See section III.B.3.f for further discussion of DECCs.)
All of the equipment included in a basic model must be within the same equipment class. Components of similar design may be substituted in a basic model without requiring additional testing if the represented energy consumption measurements continue to satisfy the provisions for sampling and testing. Only representative samples within each basic model would be tested.
For walk-ins, DOE is considering adopting the following definition of “basic model:” “Basic Model means all units of a given type of walk-in equipment manufactured by a single manufacturer, and—(1) With respect to envelopes, which do not have any differing construction methods, materials, components, or other characteristics that significantly affect the energy consumption characteristics. (2) With respect to refrigeration systems, which have the same primary energy source and which do not have any differing electrical, physical, or functional characteristics that significantly affect energy consumption.” DOE requests comment on its proposed basic model approach.
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ds, materials, components, or other characteristics that significantly affect the energy consumption characteristics. (2) With respect to refrigeration systems, which have the same primary energy source and which do not have any differing electrical, physical, or functional characteristics that significantly affect energy consumption.” DOE requests comment on its proposed basic model approach.
2. Approach Option 1: Test the Unit as a Whole
In the framework document, DOE considered developing a test procedure for walk-ins by adapting an existing test procedure for commercial refrigeration equipment, such as ARI 1200-2006. This approach would require an entire walk-in cooler or freezer to be physically tested within a controlled test chamber in order to evaluate its energy consumption over a period of time. During the standards framework public meeting, DOE requested comments on the feasibility of this approach. Interested parties responded with significant reservations about using a modified version of the ARI 1200-2006 test procedure, citing crucial differences between walk-ins and commercial refrigeration equipment.
In particular, interested parties noted that walk-ins are physically different from commercial refrigerators in ways that make a full-system test burdensome or impractical. Manitowoc stated that for very large walk-ins, around the 3,000-square-foot limit in the EPCA definition, manufacturers might not have a large enough test facility to make the measurements necessary for the ARI 1200-2006 test procedure in a controlled environment. (Manitowoc, Public Meeting Transcript, No. 15 at p. 59) (In this and subsequent citations, “Public Meeting Transcript” refers to the transcript of the February 4, 2009, public meeting on standards for walk-in coolers and freezers. “No. 15” refers to the document number of the transcript in the Docket for the DOE rulemaking on standards for walk-in coolers and freezers, Docket No
olled environment. (Manitowoc, Public Meeting Transcript, No. 15 at p. 59) (In this and subsequent citations, “Public Meeting Transcript” refers to the transcript of the February 4, 2009, public meeting on standards for walk-in coolers and freezers. “No. 15” refers to the document number of the transcript in the Docket for the DOE rulemaking on standards for walk-in coolers and freezers, Docket No. EERE-2008-BT-TP-0014; and the page references refer to the place in the transcript where the statement preceding appears.) Kason Industries also stated that it would be practically impossible to have a large enough controlled climate enclosure to test medium to large walk-ins, and added that if a walk-in were a free-standing structure, testing it as a whole building would not be practical. (Kason, No. 16 at pp. 1, 4) (In this and subsequent citations, the document number refers to the number of the comment in the Docket for the DOE rulemaking on standards for walk-in coolers and freezers, Docket No. EERE-2008-BT-TP-0014; and the page references refer to the place in the document where the statement preceding appears.) The Air-Conditioning, Heating, and Refrigeration Institute (AHRI) stated that the proposed test procedures were not practical because it would be costly to physically test walk-ins. (AHRI, No. 33 at p. 2)
Commenters also noted that the market for walk-in coolers and freezers is structured differently from the market for commercial refrigeration equipment, making a direct comparison between these types of equipment difficult. Manitowoc stated that the envelope of a particular unit of walk-in equipment may be manufactured by one company and the refrigeration system by another company. ARI 1200-2006 would require the two systems to be integrated before running the test, which would place the burden on the installer or someone beyond the manufacturer of the subsystems. (Manitowoc, Public Meeting Transcript, No. 15 at p
t. Manitowoc stated that the envelope of a particular unit of walk-in equipment may be manufactured by one company and the refrigeration system by another company. ARI 1200-2006 would require the two systems to be integrated before running the test, which would place the burden on the installer or someone beyond the manufacturer of the subsystems. (Manitowoc, Public Meeting Transcript, No. 15 at p. 59) AHRI agreed that the ARI 1200-2006 standard might not be the right approach and that DOE would need to separate the mechanical system from the envelope. (AHRI, Public Meeting Transcript, No. 15 at p. 62)
In addition to these concerns, commenters identified a deficiency in the ARI 1200-2006 test procedure. SCE stated that the majority of potential energy savings can be achieved using floating head pressure and variable-speed evaporator fans, both of which have varying effects depending on the time of day and the regional climate
After considering these comments, DOE believes that an adapted version of ARI 1200-2006 would be inadequate to use as the test procedure for walk-in equipment. ARI 1200-2006 contains too many limitations and practical difficulties that would make it very difficult to effectively implement as a workable test procedure for walk-in. Therefore, DOE is no longer considering this approach.
3. Approach Option 2: Allow Manufacturers To Use Alternative Energy Determination Methods (AEDMs)
DOE's framework document also presented an alternative that would permit the use of an AEDM when determining walk-in energy consumption to help relieve the testing burden on manufacturers. An AEDM is a predictive mathematical model, developed from engineering analyses of design data and substantiated by actual test data which represents the energy consumption characteristics of one or more basic models. After confirming the accuracy of an AEDM, the manufacturer would apply the AEDM to basic models to determine their energy consumption without conducting any physical testing
cturers. An AEDM is a predictive mathematical model, developed from engineering analyses of design data and substantiated by actual test data which represents the energy consumption characteristics of one or more basic models. After confirming the accuracy of an AEDM, the manufacturer would apply the AEDM to basic models to determine their energy consumption without conducting any physical testing.
Applying this approach, the manufacturer would confirm the accuracy of the AEDM using the following method. First, the manufacturer would determine through actual testing the energy consumption of a certain number of its basic models that would be selected in accordance with criteria specified in the procedure. Second, the manufacturer would apply the AEDM to these same basic models. The AEDM would be considered sufficiently accurate only if: (1) The predicted total energy consumption of each of these basic models, calculated by applying the AEDM, is within a certain percentage of the total energy consumption determined from the testing of that basic model; and (2) the average of the predicted total energy consumption for the tested basic models, calculated by applying the AEDM, is within a certain percent of the average of the total energy consumption determined from testing these basic models. Under this approach, once the manufacturer verifies the accuracy of the AEDM, the manufacturer can use the AEDM to determine the energy consumption of other basic models without having to test those models. DOE requested comments on this approach during the framework public meeting, both in terms of how to implement the approach and whether such an approach was valid for walk-ins at all. DOE received several relevant comments, which are described and addressed below.
Given the unprecedented nature of using an AEDM to rate this type of equipment, DOE needed to determine both an appropriate sample size for verifying an AEDM and an acceptable minimum accuracy percentage for an AEDM
in terms of how to implement the approach and whether such an approach was valid for walk-ins at all. DOE received several relevant comments, which are described and addressed below.
Given the unprecedented nature of using an AEDM to rate this type of equipment, DOE needed to determine both an appropriate sample size for verifying an AEDM and an acceptable minimum accuracy percentage for an AEDM. During the framework public meeting, DOE requested comments on these two values. AHRI could not provide feedback on how accurate the AEDM should be because DOE had not yet determined the test metric to apply. (AHRI, Public Meeting Transcript, No. 15 at p. 69) Manitowoc agreed that the test methodology needs to be established and experiments conducted to collect data that would be used to validate AEDMs. (Manitowoc, Public Meeting Transcript, No. 15 at p. 70) In a written comment, Kason Industries stated that an AEDM with a minimum accuracy of 66 percent would encompass a majority of the wide range of walk-in cooler and freezer applications. (Kason, No. 16 at p. 2) No commenter provided substantive data that DOE would use in its analysis to help support a particular sample size. Accordingly, DOE did not receive enough data from stakeholders that could help it determine an appropriate sample size or accuracy range to substantiate an AEDM.
During the public meeting, DOE also requested comments on the possibility of allowing manufacturers to take this approach to rate their walk-ins. Kason stated that an AEDM procedure would be preferable to using a physical test because the majority of walk-ins are custom-made by size, ambient temperature, and refrigeration demands. Therefore, it would be very difficult to create a test procedure that encompasses the range of walk-in equipment. (Kason, No. 16 at p
ibility of allowing manufacturers to take this approach to rate their walk-ins. Kason stated that an AEDM procedure would be preferable to using a physical test because the majority of walk-ins are custom-made by size, ambient temperature, and refrigeration demands. Therefore, it would be very difficult to create a test procedure that encompasses the range of walk-in equipment. (Kason, No. 16 at p. 1) Kason suggested that, as an alternative to testing the system as a whole, an AEDM could be based on determining efficiencies and performance characteristics for the principal components of a walk-in considering three factors: insulation and air tightness of the external envelope and door, efficiency of the refrigeration system for steady-state storage load (similar to the efficiency rating system for HVAC), and performance of the refrigeration system for removal of process heat and equipment-generated heat. (Kason, No. 16 at p. 2)
Other interested parties commented that allowing manufacturers to develop their own calculation methodology or software program as an AEDM could be problematic. Owens Corning questioned whether there could be a comparison among ratings published by manufacturers that developed different AEDMs. (Owens Corning, Public Meeting Transcript, No. 15 at p. 64) Craig stated that manufacturers who devise their own test procedures could write them in a way that benefits their own company. (Craig, Public Meeting Transcript, No. 15 at pp. 68-69) SCE stated that allowing manufacturers to develop their own software as an AEDM could be unfair to manufacturers with fewer resources, because the software is expensive and time-consuming to develop. Instead, SCE suggested that it would be better to have a transparent analysis method with the algorithms available to all participants and the data in a standardized format. (SCE, Public Meeting Transcript, No. 15 at p
lowing manufacturers to develop their own software as an AEDM could be unfair to manufacturers with fewer resources, because the software is expensive and time-consuming to develop. Instead, SCE suggested that it would be better to have a transparent analysis method with the algorithms available to all participants and the data in a standardized format. (SCE, Public Meeting Transcript, No. 15 at p. 71) Craig replied that many manufacturers have sizing programs, which may be proprietary, to calculate the total load of the walk-in, accessories, and product load, and to size the refrigeration system properly for the energy requirements of the envelope. (Craig, Public Meeting Transcript, No. 15 at pp. 77-78 and No. 22 at p. 4) However, Craig stressed that requiring manufacturers to follow the same model developed or approved by DOE, would be fair to different manufacturers and provide consistent information to end users. (Craig, Public Meeting Transcript, No. 15 at p. 94 and No. 22 at p. 5)
ACEEE asserted that it would be difficult for DOE to work with many proprietary models, some of which might be difficult to verify. (ACEEE, Public Meeting Transcript, No. 15 at p. 94) NEEA also said that if an AEDM were used, the software should be equally available to all manufacturers and code officials for the purpose of determining compliance. (NEEA, No. 18 at p. 3) Crown Tonka stated that a standard configuration and standard test should be developed to create a baseline
DOE had previously understood that manufacturers would develop their own AEDMs and would verify their accuracy by testing a small number of walk-in models. However, as discussed above, most interested parties indicated that allowing manufacturers to develop their own rating calculations or software could be problematic, despite the fact that the calculations and software would need to be verified. Therefore, DOE does not propose to allow manufacturers to develop their own AEDMs
would verify their accuracy by testing a small number of walk-in models. However, as discussed above, most interested parties indicated that allowing manufacturers to develop their own rating calculations or software could be problematic, despite the fact that the calculations and software would need to be verified. Therefore, DOE does not propose to allow manufacturers to develop their own AEDMs. Instead, DOE developed its own calculation methodology for manufacturers to use in rating similar, but not identical, units of walk-in equipment. For further discussion on this methodology, see section III.B.3.f.
4. Proposed Option and Recommendation: Separate Envelope and Refrigeration Tests
Both methods described above were predicated on the assumption that an entire walk-in unit is manufactured by a single entity, which could either test the walk-in as a whole according to ARI Standard 1200-2006, or calculate the overall efficiency using an AEDM. In fact, as DOE learned, most walk-ins have two main manufacturers: One who manufactures the envelope and one who manufactures the refrigeration system that cools the interior of the envelope. (Other manufacturers may be involved in producing secondary components —such as fan assemblies or lighting— that are then purchased by the main manufacturers and incorporated as part of the refrigeration system or envelope.) These two parts are manufactured separately, and are often assembled together in the field by a third-party contractor who may not have been responsible for the manufacture of either part, and who may not have testing or evaluation capabilities. Because of this situation, DOE developed, and is proposing, a different approach for testing walk-ins, as described below.
Specifically, DOE proposes separate test procedures for the envelope and the refrigeration system
together in the field by a third-party contractor who may not have been responsible for the manufacture of either part, and who may not have testing or evaluation capabilities. Because of this situation, DOE developed, and is proposing, a different approach for testing walk-ins, as described below.
Specifically, DOE proposes separate test procedures for the envelope and the refrigeration system. The envelope manufacturer would be responsible for testing the envelope according to the envelope test procedure, and the refrigeration system manufacturer would be responsible for testing the refrigeration system according to the refrigeration system test procedure. Such an approach would be more likely to generate usable data in support of standards for both the envelope and the refrigeration system during the development of any energy conservation standards for walk-in coolers and freezers. The two test procedures are described in sections III.B and III.C, respectively.
There are several advantages to this approach. First, having separate test procedures would allow individual component manufacturers to test their components—the envelope and the refrigeration system. These component manufacturers would be more likely to have access to the resources, equipment, and personnel needed to conduct the tests. On the other hand, the “manufacturer” of an entire walk-in system ( i.e., envelope and refrigeration system combined), could be a third party: A contractor who assembles the walk-in from the separate components and/or installs it in the field. This third-party assembler may even be the end-user or owner of the equipment. If a walk-in is assembled in the field, testing of the entire assembled system may not be feasible due to lack of expertise and the need for additional testing equipment.
Second, this approach would result in a significantly reduced testing burden while ensuring compliance with any standard DOE may develop
the field. This third-party assembler may even be the end-user or owner of the equipment. If a walk-in is assembled in the field, testing of the entire assembled system may not be feasible due to lack of expertise and the need for additional testing equipment.
Second, this approach would result in a significantly reduced testing burden while ensuring compliance with any standard DOE may develop. There are many more assemblers and installers of walk-ins than there are component manufacturers. Because EPCA requires manufacturers to demonstrate compliance with energy conservation standards, interpreting the term “manufacturer” to include assemblers and installers, who may be contractors or end-users, to demonstrate compliance with a standard would impose the compliance burden on entities who, more likely than not, may not have participated in the design and manufacture (and therefore energy efficiency) of the component parts. Furthermore, this approach would create substantial difficulties for DOE to enforce any standards it promulgates for walk-in equipment. While DOE considered the possibility that including assemblers and installers as parties involved in the manufacture of this equipment could encourage these parties to take steps to ensure that compliant equipment is installed, at this time, DOE believes that the testing burdens are best met by the envelope and refrigeration system manufacturers for the reasons discussed above. Accordingly, under today's proposal, only envelope and refrigeration system manufacturers would need to demonstrate compliance with any proposed standard through the use of the test procedure. (DOE notes that possible remedial action for failing to satisfy these requirements include civil penalties and injunctive relief to prevent the continued sale and distribution of noncompliant equipment.) (42 U.S.C. 6303-6304)
DOE requests comment on this proposed approach and whether it is appropriate for walk-ins.
B
compliance with any proposed standard through the use of the test procedure. (DOE notes that possible remedial action for failing to satisfy these requirements include civil penalties and injunctive relief to prevent the continued sale and distribution of noncompliant equipment.) (42 U.S.C. 6303-6304)
DOE requests comment on this proposed approach and whether it is appropriate for walk-ins.
B. Envelope
As described earlier, the envelope consists of the insulated box in which the stored items reside. The following discussion describes in greater detail the test procedure DOE is proposing for the walk-in envelope. DOE also addresses issues raised by interested parties.
This procedure contains the proposed methodology for evaluating the performance characteristics of the insulation as well as methods for testing thermal energy gains related to air infiltration caused by use (door openings) and imperfections in wall interfaces or door gasketing material. Heat gain due to internal electrical components is an additional consideration.
The proposed procedure utilizes the data obtained to calculate a measure of energy use associated with the envelope. In other words, the test procedure calculates the effect of the envelope's characteristics and components on the energy consumption of the walk-in as a whole. This includes the energy consumption of electrical components present in the envelope (such as lights) and variation in the energy consumption of the refrigeration system due to heat loads introduced as a function of envelope performance, such as conduction of heat through the walls of the envelope. The effect on the refrigeration system is determined by calculating the energy consumption of a theoretical, or nominal, refrigeration system, were it to be paired with the tested envelope. Using the same nominal refrigeration system characteristics allows for direct comparison of the performance of walk-in envelopes across a range of sizes, product classes, and levels of feature implementation
e. The effect on the refrigeration system is determined by calculating the energy consumption of a theoretical, or nominal, refrigeration system, were it to be paired with the tested envelope. Using the same nominal refrigeration system characteristics allows for direct comparison of the performance of walk-in envelopes across a range of sizes, product classes, and levels of feature implementation.
The test procedure obtains a metric of energy use associated with the envelope of a walk-in cooler or freezer, consistent with the statutory requirement (42 U.S.C. 6314(a)(9)(B)(i)). For purposes of this rulemaking, DOE interprets the term “energy use” to describe the sum of (a) the electrical energy consumption of envelope components and (b) the energy consumption of the walk-in refrigeration equipment that is
1. Overview of the Test Procedure
In accordance with EPCA, DOE is developing test procedures to evaluate the energy use associated with the envelope of walk-in coolers and freezers. The walk-in envelope includes, but may not be limited to, walls, floor, ceiling, seals, windows, and/or doors comprised of single or composite materials designed to isolate the interior, refrigerated environment from the ambient, external environment. For the purposes of developing this test procedure and evaluating potential performance standards for walk-in equipment, DOE considers the envelope to also include lighting and other energy-consuming components of the walk-in that are not part of its refrigeration system ( e.g., motors for automatic doors, anti-sweat heaters, etc.). DOE is considering the following definition for “envelope,” which would be inserted into 10 CFR part 431:
(1) The portion of a walk-in cooler or walk-in freezer that isolates the interior, refrigerated environment from the ambient, external environment; and
ming components of the walk-in that are not part of its refrigeration system ( e.g., motors for automatic doors, anti-sweat heaters, etc.). DOE is considering the following definition for “envelope,” which would be inserted into 10 CFR part 431:
(1) The portion of a walk-in cooler or walk-in freezer that isolates the interior, refrigerated environment from the ambient, external environment; and
(2) All energy-consuming components of the walk-in cooler or walk-in freezer that are not part of its refrigeration system.
DOE requests comments on this proposed definition.
DOE also evaluated several available industry test procedures to measure the energy performance of various components of the walk-in envelope, but was unable to find a test procedure that would evaluate the entire envelope system. Consequently, DOE developed its own methodology, including a prescriptive calculation procedure, which incorporates specific component tests and allows for an overall energy performance value of the envelope to be determined. The proposed test measurements and accompanying calculation procedures to ascertain the overall energy performance value are described in the following sections.
2. Test Methods
As discussed above, DOE was unable to find a single, existing comprehensive test procedure for evaluating walk-in cooler and freezer envelopes. However, DOE identified and evaluated many recognized industry standards that could be applied to the testing of certain components and characteristics of walk-in envelopes. DOE incorporated an insulation test and an air infiltration test, with some modifications, into the proposed test procedure. The evaluation process, the results of the evaluation, and details of the proposed test methods are described in the following sections.
a. Insulation
Insulation comprises a significant component of walk-in units
rtain components and characteristics of walk-in envelopes. DOE incorporated an insulation test and an air infiltration test, with some modifications, into the proposed test procedure. The evaluation process, the results of the evaluation, and details of the proposed test methods are described in the following sections.
a. Insulation
Insulation comprises a significant component of walk-in units. EPCA specifies that ASTM C518-04, “Standard Test Method for Steady-State Thermal Transmission Properties by Means of the Heat Flow Meter Apparatus,” must be used, along with specific foam temperatures for freezer or cooler applications specified in EPCA, to determine the R value of individual walk-in envelope insulation materials. (42 U.S.C. 6314(a)(9)(A)) Commenters identified two issues of significance for DOE to consider when developing a test procedure for insulation: aging and moisture absorption. DOE discusses these issues in the subsections that follow.
i. Aging of Foam Insulation
EPCA requires that the test procedure for walk-ins use an R value that shall be the 1/K factor multiplied by the thickness of the panel. (42 U.S.C. 6314(a)(9)(A)) The Act does not specify when the R value should be calculated, a key issue interested parties raised at the framework public meeting. Specifying when the R-value should be calculated is a critical consideration because several sources indicate that the R-value of certain materials can change over time.
Craig stated that R values tend to deteriorate over time and that different materials exhibit unique rates of deterioration. (Craig, Public Meeting Transcript, No. 15 at p. 215 and No. 8 at p. 1) Craig expressed concern that using an initial R value (R value as measured within two weeks of manufacture) to determine compliance would ignore deterioration that occurs in blown foams over time
time.
Craig stated that R values tend to deteriorate over time and that different materials exhibit unique rates of deterioration. (Craig, Public Meeting Transcript, No. 15 at p. 215 and No. 8 at p. 1) Craig expressed concern that using an initial R value (R value as measured within two weeks of manufacture) to determine compliance would ignore deterioration that occurs in blown foams over time. Craig argued that underestimating the energy use of walk-ins would be the likely outcome of using initial R-value, that it would be misleading for end-users, and that it would be inconsistent with the goals of the EISA 2007 legislation and the rulemaking process. (Craig, Public Meeting Transcript, No.15 at p. 215) A comment submitted jointly by representatives of ASAP, ACEEE, and NRDC (hereafter referred to as the “Joint Comment”) stated that the test procedures used should account for the potential degradation of panel insulation and door seals over time. (Joint Comment, No. 21 at p. 2) Craig also recommended that DOE develop an accelerated test procedure that represents lifetime energy use and can be completed within 6 months. (Craig, No. 8 at p. 1)
In the context of foam insulation for walk-ins and the building industry, long-term thermal resistance (LTTR), described in greater detail below, refers to the impact of diffusion on the thermal resistance of insulation materials. In other words, the concentration of gaseous blowing agents contained in the foam, and which provide the foam with much of its insulating value, is reduced by both the diffusion of air into the foam and the secondary process of the blowing agent diffusing out of the foam. Because air has a significantly lower insulating value, the increased ratio of air to blowing agent reduces the foam insulation performance (this process is also known as “aging”). This diffusion process causes foam to lose insulating value, which is represented by its R-value
duced by both the diffusion of air into the foam and the secondary process of the blowing agent diffusing out of the foam. Because air has a significantly lower insulating value, the increased ratio of air to blowing agent reduces the foam insulation performance (this process is also known as “aging”). This diffusion process causes foam to lose insulating value, which is represented by its R-value. As a concept, LTTR represents the R-value of foam material over its lifetime by describing insulating performance changes due to diffusion over time.
DOE investigated the issue of aging in foam insulation and found that it is widely accepted that the material properties of foam insulation made with gaseous blowing agents, other than air and including HFC-134a, HFC-245fa, HFC-365mfc, cyclopentanes, change over time. The amount of degradation can range from roughly 10-35 percent within 2 years of manufacture. Because use of ASTM C518-04 reflects the properties of a material at the time it is tested, using ASTM C518-04 to measure the insulating performance of a foam material at the time of manufacture would yield a result that differs from that produced by the same test conducted at some later point in time. Additionally, research has found that the vast majority of diffusion into and out of foam materials manufactured with blowing agents other than air occurs within the first 5 years of manufacture. Because the rate of diffusion follows an exponential curve, the majority occurs within the first year, after which the diffusion curve changes very little as it asymptotically approaches the equilibrium point.
DOE found that various methods of “conditioning” foam prior to measuring its insulating ability with American Society for Testing and Materials (ASTM) C518 have been developed in order to test aged insulating value, or LTTR. These standards are contained in five foam material specifications:
(1) ASTM C578-09, “Standard Specification for Rigid, Cellular Polystyrene Thermal Insulation;”
point.
DOE found that various methods of “conditioning” foam prior to measuring its insulating ability with American Society for Testing and Materials (ASTM) C518 have been developed in order to test aged insulating value, or LTTR. These standards are contained in five foam material specifications:
(1) ASTM C578-09, “Standard Specification for Rigid, Cellular Polystyrene Thermal Insulation;”
(2) ASTM C591-08a, “Standard Specification for Unfaced Preformed Rigid Cellular Polyisocyanurate Thermal Insulation;”
(3) ASTM C1029-08, “Standard Specification for Spray-Applied Rigid Cellular Polyurethane Thermal Insulation;”
(4) ASTM C1126-04, “Standard Specification for Faced or Unfaced Rigid Cellular Phenolic Thermal Insulation;” and
(5) ASTM C1289-08, “Standard Specification for Faced Rigid Cellular Polyisocyanurate Thermal Insulation Board.”
DOE found that since their development in the 1980s, the most widely accepted conditioning methods are the 180-day conditioning at 73 °F or a 90-day conditioning at 140 °F. The goal of the 90-day conditioning method was to achieve the same aging result as the 180-day method in a shorter period of time. 180-day conditioning is used by ASTM C591-08a and ASTM C578-09 and the 90-day condition is typically used for ASTM C1089-08 and ASTM C1126-04. By accelerating the conditioning, the 90-day test sought to reduce the time and cost burdens for manufacturers. Although elevating the temperature of foams did achieve a faster rate of aging, subsequent research found that the results were not reliable indicators of actual aging because the relationship between the diffusion coefficient (a proportionality constant that describes the force or rate of diffusion for a given substance) and temperature are different for each gas. (Therese Stovall, “Measuring the Impact of Experimental Parameters upon the Estimated Thermal Conductivity of Closed-Cell Foam Insulation Subjected to an Accelerated Aging Protocol: Two-Year Results,” p
cause the relationship between the diffusion coefficient (a proportionality constant that describes the force or rate of diffusion for a given substance) and temperature are different for each gas. (Therese Stovall, “Measuring the Impact of Experimental Parameters upon the Estimated Thermal Conductivity of Closed-Cell Foam Insulation Subjected to an Accelerated Aging Protocol: Two-Year Results,” p. 1)
DOE found that efforts to develop an accelerated aging method that did not use elevated temperatures resulted in the creation of ASTM C1303, which in 1995 introduced the slicing and scaling method, also known as the “thin slicing” method (a technique used to slice the foam so that it ages more rapidly as a function of reduced thickness). In contrast to ASTM C578-09, ASTM C591-08a, ASTM C1029-08, ASTM C1126-04, and ASTM C1289-08, which specify the use of either the 180-day conditioning method or 90-day accelerate conditioning method to age the foam before measuring its thermal resistance. In contrast, the thin slicing method used in ASTM C1303-08 (the most recent version of ASTM C1303) was designed specifically to test the aging of foam insulation in duration shorter than 180 days, and without the temperature elevation methodology used in the 90-day test. (ASTM C1303-08, section 5.3, at p. 3) By reducing the length of the pathway for diffusion to take place, the “aging” can be accelerated without the confounding effects caused by unique gas properties of the material and blowing agent. The results are used to determine the R-value of foam 5 years after manufacture, a value that has been shown to correlate strongly with the average R-value of foam 15 years after manufacture. (ASTM C1303-08, section 5.4, at p. 3)
In early 2000, the National Research Council Canada and Institute for Research in Construction (NRC-IRC) developed CAN/ULC-S770-00
es of the material and blowing agent. The results are used to determine the R-value of foam 5 years after manufacture, a value that has been shown to correlate strongly with the average R-value of foam 15 years after manufacture. (ASTM C1303-08, section 5.4, at p. 3)
In early 2000, the National Research Council Canada and Institute for Research in Construction (NRC-IRC) developed CAN/ULC-S770-00. CAN/ULC-S770-00 incorporated elements of ASTM C1303-95 (the first version of ASTM C1303) but altered that standard by clarifying the slicing procedure used in ASTM C1303-95, as differing interpretations of the previous procedure were thought to be causing variations in the test results among third-party testing facilities. These changes sought to eliminate inconsistency in the interpretation of the slicing procedure and test setup to ensure uniformity across testing labs. In December 2000, CAN/ULC-S770-00 became the Canadian national mandatory test for calculating the LTTR of all foam insulation products (this test has since been updated; the most recent version is CAN/ULC-S770-03). Members of the U.S.-based Polyisocyanurate Insulation Manufacturers Association (PIMA) began to test their products using the same procedure on January 1, 2003. The LTTR calculated from this test procedure is used for all building insulation product labeling in Canada and PIMA products in the United States. Also in 2000, ASTM C1303-95 was updated as ASTM C1303-00.
In a 2005 rule by the U.S. Federal Trade Commission (FTC) in which the FTC considered requiring ASTM C1303-00 (the most recent version at that time) for product labeling on all foam insulation products, the FTC's review process revealed several unresolved issues related to the test procedure
Canada and PIMA products in the United States. Also in 2000, ASTM C1303-95 was updated as ASTM C1303-00.
In a 2005 rule by the U.S. Federal Trade Commission (FTC) in which the FTC considered requiring ASTM C1303-00 (the most recent version at that time) for product labeling on all foam insulation products, the FTC's review process revealed several unresolved issues related to the test procedure. (70 FR 31258 (May 31, 2005); 16 CFR Part 460, Labeling and Advertising of Home Insulation: Trade Regulation Rule, Final Rule) Subsequently, ASTM C1303-00 was updated to address these issues, which included foam stack composition, minimum slice thickness and slice source, the time between manufacture and test initiation, preparation of foam-in-place samples, and other clarifications of the procedure. This updated version was published as ASTM C1303-08 and is the most recent version of the standard to date.
Some commenters noted during the framework meeting that the application of an impermeable vapor barrier to the surface of the foam could reduce the impact of aging. Depending on its end use, foam insulation may have facers or skins applied to act as a vapor barrier and/or to enhance the bond of construction glues. Kysor stated that proper use of skins eliminates aging and the associated reduction of R-value in polyurethane panels. (Kysor (attachment), No. 29 at p. 1)
DOE examined this issue and found that foams used in walk-in panels are sometimes protected by impermeable barriers designed to prevent vapor and/or air exchange into or out of the foam or the interior of the walk-in. DOE found research conducted by the National Resource Council Canada (NRCC) suggesting that impermeable facers do not eliminate aging but may delay the rate of aging and/or the final equilibrium of the aged state
und that foams used in walk-in panels are sometimes protected by impermeable barriers designed to prevent vapor and/or air exchange into or out of the foam or the interior of the walk-in. DOE found research conducted by the National Resource Council Canada (NRCC) suggesting that impermeable facers do not eliminate aging but may delay the rate of aging and/or the final equilibrium of the aged state. (Mukhopadhyaya, P.; Bomberg, M.T.; Kumaran, M.K.; Drouin, M.; Lackey, J.; van Reenen, D.; Normandin, N., “Long-Term Thermal Resistance of Polyisocyanurate Foam Insulation With Impermeable Facers”; Mukhopadhyaya, P.; Bomberg, M.T.; Kumaran, M.K.; Drouin, M.; Lackey, J.; van Reenen, D.; Normandin, N., “Long-Term Thermal Resistance of Polyisocyanurate Foam Insulation With Gas Barrier”; Mukhopadhyaya, P.; Kumaran, M.K. “Long-Term Thermal Resistance Of Closed-Cell Foam Insulation: Research Update From Canada.”) In one of the summary observations of “Long-Term Thermal Resistance of Polyisocyanurate Foam Insulation With Gas Barrier,” the NRCC noted, “a considerable amount of aging occurred in thin slice specimens despite having untouched impermeable facers, as well as a glass plate at the bottom of the specimens and edges sealed completely with epoxy coating.”
Additionally, the relationship between the skin and the rate of aging in foam depends on preserving the integrity of both the skin surface and the bonding between the skin and insulation. Punctures, made to allow for the installation of light fixtures, doors, and shelving, undermine the integrity of the skin. Walk-in insulation panels and their skins also typically separate over time due to shrinkage of foam materials after manufacture. While most foam materials contract by less than 1 percent of their total volume, shrinkage at this level is enough to create significant air gaps. DOE found that current methods of conditioning foam materials do not account for impermeable facers
integrity of the skin. Walk-in insulation panels and their skins also typically separate over time due to shrinkage of foam materials after manufacture. While most foam materials contract by less than 1 percent of their total volume, shrinkage at this level is enough to create significant air gaps. DOE found that current methods of conditioning foam materials do not account for impermeable facers.
Finally, like the conditioning standards that are currently in use, ASTM C1303-08 is not designed to test impermeably faced foams that may be
DOE also requests feedback on the use of ASTM C1303-08 with impermeably faced foams. DOE may recommend the use of a test procedure specifically designed for impermeably faced foam if one is developed.
As a result of this evaluation, DOE proposes requiring manufacturers to use ASTM C1303-08 to determine the LTTR of walk-in foam insulation for the purposes of calculating the energy consumption of walk-in equipment. DOE requests comments on this proposal.
DOE is also proposing and seeking comment on the following exceptions to ASTM C1303-08:
(1) Section 6.6.2 of C1303-08 suggests that two standards for measuring the thermal resistance may be used. DOE proposes to allow use only of ASTM C518-04 (in EPCA, an incorrect form of the date suffix was used, e.g., ASTM C518-[20]04), as specified in EPCA. (42 U.S.C. 6314(a)(9)(A)(ii))
(2) In section 6.6.2.1, in reference to ASTM C518-04, the mean test temperature of the foam during R-value measurement would be −6.7 ± 2 °C (20 ± 4 °F) with a temperature difference of 22 ± 2 °C (40 ± 4 °F) for freezers and 12.8 ± 2 °C (55 ± 4 °F) with a temperature difference of 22 ± 2 °C (40 ± 4 °F) for coolers. This change replaces the standard mean temperature of 75 °F for ASTM C518-04 with the EPCA specified values.
n reference to ASTM C518-04, the mean test temperature of the foam during R-value measurement would be −6.7 ± 2 °C (20 ± 4 °F) with a temperature difference of 22 ± 2 °C (40 ± 4 °F) for freezers and 12.8 ± 2 °C (55 ± 4 °F) with a temperature difference of 22 ± 2 °C (40 ± 4 °F) for coolers. This change replaces the standard mean temperature of 75 °F for ASTM C518-04 with the EPCA specified values.
(3) For the purposes of preparing samples with foam-in-place method, section A2 should be followed exactly except for the following modifications to accommodate foam-in-place methods that may be used during the manufacture of walk-in panels:
• (3.1) Instead of following A2.3, which specifies that the foam be sprayed onto a single sheet of wood, the sample shall be foamed into a fully closed box of internal dimension 60 cm x 60 cm by desired product thickness (2ft x 2ft x Desired thickness). The box shall be made of 3/4 inch plywood and internal surfaces wrapped in 4 to 6 mil polyethylene film to prevent the foam from adhering to the box material.
• (3.2) Instead of following section A2.4, which specifies the spraying of foam layers onto a open sheet of plywood, the cavity shall be filled using the manufacturer's typical foam-in-place method through a standard injection port or other process typically used to foam the product being tested.
• (3.3) In section A2.6, which defines the single surface in contact with the board to be the “surface,” the definition of the foam's “surface” shall be the two surface regions in contact with the 60 x 60 cm sections of the box.
• (3.4) Section A2.8 shall not be followed because the prepared sample will not have any “free rise” component.
DOE proposes that manufacturers select foam test thicknesses based on design specifications and practice
surface in contact with the board to be the “surface,” the definition of the foam's “surface” shall be the two surface regions in contact with the 60 x 60 cm sections of the box.
• (3.4) Section A2.8 shall not be followed because the prepared sample will not have any “free rise” component.
DOE proposes that manufacturers select foam test thicknesses based on design specifications and practice. If a foam's thickness as manufactured varies from the tested product thickness, DOE proposes that the R-value of that foam at its manufactured thickness may be interpolated using the results of ASTM C1303-08, provided that the manufactured thickness does not vary from the tested product thickness by more than ± 0.5 inches. For example, if 4-inch and 6-inch products were prepared, interpolation between 3.5 and 4.5 inches would be allowed for the 4-inch foam and 5.5 and 6.5 inches for the 6-inch foam. If the manufacturer determines that final foam thickness should be outside of the tested range, then additional testing would be necessary to fit the criterion for interpolation. Manufacturers should make their sample selections accordingly to avoid the need for additional testing. DOE requests feedback on the use of interpolation within the specified ± 0.5 inch range.
DOE proposes that the results for each of the sample sets of three stacks should be reported as specified by ASTM C1303-08. As defined by ASTM C1303-08, after thin slices of foam are cut, the slices are organized into “stacks” of slices to match the original overall thickness of the sample. The procedure defines three stack types: (1) Stacks comprised of only surface slices of foam, (2) stacks of only core slices and (3) a mixture of core and surface slices
three stacks should be reported as specified by ASTM C1303-08. As defined by ASTM C1303-08, after thin slices of foam are cut, the slices are organized into “stacks” of slices to match the original overall thickness of the sample. The procedure defines three stack types: (1) Stacks comprised of only surface slices of foam, (2) stacks of only core slices and (3) a mixture of core and surface slices. A “surface” slice and a “core” slice are defined in ASTM C1303 as “a thin-slice foam specimen that was originally adjacent to the surface of the full-thickness product and that includes any facing that was adhered to the surface of the original full-thickness product” and “a thin-slice foam specimen that was taken at least 5 mm (0.2 in.) or 25% of the product thickness, whichever is greater, away from the surface of the full thickness product,” respectively. The R-value of only the mixed stack would be used to calculate the energy performance of walk-ins. DOE requests feedback on this approach. ASTM is currently conducting a 5-year “ruggedness” test. Upon completion of the test, DOE may consider a rulemaking to modify the required number of stacks and/or which stack is best suited for labeling and calculating energy performance. DOE requests feedback on the use of the mixed stack R-value for the purpose of calculating walk-in energy use.
Additionally, DOE notes that ASTM C1303-08 is specifically intended for measuring the LTTR of foam materials. In light of this situation, the process contained in this standard would not apply to advanced insulation technologies such as vacuum insulated panels (VIPs) or aerogels. However, ASTM C518-04 can be used to measure the thermal properties of these new technologies, which, as specified in EPCA, is the required test for measuring insulating performance. (42 U.S.C. 6314(a)(9)(A)(ii)) DOE requests feedback on whether non-foam advanced technologies, such as VIPs or aerogels, would be likely to be used for walk-ins in the next 5 years
insulated panels (VIPs) or aerogels. However, ASTM C518-04 can be used to measure the thermal properties of these new technologies, which, as specified in EPCA, is the required test for measuring insulating performance. (42 U.S.C. 6314(a)(9)(A)(ii)) DOE requests feedback on whether non-foam advanced technologies, such as VIPs or aerogels, would be likely to be used for walk-ins in the next 5 years. If DOE determines that these materials may be used in walk-ins in the next 5 years, DOE may consider alternative test procedures for capturing the long-term insulating value of any non-foam materials.
ii. Water Absorption in Foam
At the framework public meeting, interested parties raised the issue of R-value deterioration in foams due to moisture absorption. Craig stated that moisture penetration causes a decline in the R-value of foam insulation, at a rate that depends on the type of foam used. (Craig, No. 22 at p. 3) As is the case with aging, insulating foams exhibit different characteristics in the presence of moisture. Polystyrene foam is highly resistant to water absorption, whereas polyurethanes and polyisocyanurates are more easily damaged by exposure to moisture. In general, the solution to moisture issues involves creating an impermeable barrier between the insulation and the moisture source. However, Owens Corning asserted that customers routinely puncture metal skins to allow for the installation of lighting fixtures, shelving, and doors, creating holes that allow moisture to enter the insulation. (Owens Corning, Public Meeting Transcript, No. 15 at p. 61)
Although vapor permeance and water absorption tests exist, they are designed for measuring specific material properties rather than measuring system performance of composite structures like walk-ins
skins to allow for the installation of lighting fixtures, shelving, and doors, creating holes that allow moisture to enter the insulation. (Owens Corning, Public Meeting Transcript, No. 15 at p. 61)
Although vapor permeance and water absorption tests exist, they are designed for measuring specific material properties rather than measuring system performance of composite structures like walk-ins. For a variety of reasons, e.g., blowing agent, foam type, barriers, gasketing materials, panel joint type, and method), the following considerations exemplify the challenges inherent in accounting for and quantifying insulating performance: (1) The rate at which the walk-in envelope collects water over its life must be measured or predicted using an accelerated test; (2) a saturation level or maximum absorption, if any, must be determined; and (3) a correlation between water absorption levels and insulation performance must be quantified. At this time, test procedures for each of these considerations are not yet recognized by a nationally recognized organization such as ASTM.
DOE reviewed several methods for testing vapor permeance and water absorption in foam insulation materials including ASTM E96, “Standard Test Methods for Water Vapor Transmission of Materials,” ASTM C209, “Standard Test Methods for Cellulosic Fiber Insulation Board,” ASTM C272-01 (2007), “Standard Test Method for Water Absorption of Core Materials for Structural Sandwich Constructions,” and ASTM D2842-06, “Standard Test Method for Water Absorption of Rigid Cellular Plastics.” Each of these standards describes a method for submerging a sample in water for a specified amount of time and then measuring the amount of water absorbed on a volume or weight basis. However, each one specifies significantly different immersion durations (ranging from 2 to 96 hours) and methods of weighing samples (blotting surfaces before measurement or using a buoyancy measurement)
r Plastics.” Each of these standards describes a method for submerging a sample in water for a specified amount of time and then measuring the amount of water absorbed on a volume or weight basis. However, each one specifies significantly different immersion durations (ranging from 2 to 96 hours) and methods of weighing samples (blotting surfaces before measurement or using a buoyancy measurement). DOE believes that using the longest test period, 96 hours, would likely result in near worst case or maximum water absorption, but it is unclear how this directly translates to reduction in insulation performance for various materials.
Additionally, ASTM E96-05 measures vapor permeance under low vapor pressure gradient conditions. However, the temperature differentials in which walk-ins operate cause a high vapor pressure gradient, which has the effect of continuously driving moisture through the envelope. Neither ASTM E96-05 nor any other known procedures currently provide a methodology to accurately calculate the vapor permeance in walk-ins at the pressure gradients typically experienced in the field.
Some research has been completed, including a major study by the Cold Regions Research and Engineering Lab (CRREL). The CRREL study developed and applied a method for creating a vapor pressure gradient across various materials to quantify the rate at which these materials absorb and retain water over time. The insulating performance of the materials was also tested at various levels of moisture content to develop equations for the purpose of calculating the insulating properties at any moisture percentage relative to its dry weight. No other testing body has applied CRREL's testing procedures to replicate the results and most of CRREL's research was completed nearly 20 years ago. One of DOE's national labs has also begun development of procedures to evaluate the impact of moisture on insulation R-values, but this activity remains incomplete
ating the insulating properties at any moisture percentage relative to its dry weight. No other testing body has applied CRREL's testing procedures to replicate the results and most of CRREL's research was completed nearly 20 years ago. One of DOE's national labs has also begun development of procedures to evaluate the impact of moisture on insulation R-values, but this activity remains incomplete.
Given the discussion above, DOE does not propose to include the impact of water absorption on R-value in the test procedure because no well-accepted method has been developed. However, DOE will evaluate such a procedure if it is developed in the future.
b. Air Infiltration
Another major pathway for energy loss in walk-ins is air infiltration, or air exchanged into and out of a walk-in while all access points are closed or during door-opening cycles ( i.e., the openings of doors for the removal or stocking of product, or passage of customers, personnel, and/or machinery, also referred to as “door-opening events”). Compared with other energy consumption factors such as conduction losses through insulation, air infiltration may be the largest contributing factor to envelope energy losses. Air infiltration can occur through steady-state leakage or from door opening events. As a result, designs and technologies that reduce infiltration during steady-state operation and door-opening events should be considered to reduce these losses.
EPCA includes prescriptive requirements for doors used on walk-ins, recognizing that a major portion of energy is lost through door opening cycles. All walk-in coolers or freezers “manufactured on or after January 1, 2009, shall (A) have automatic door closers that firmly close all walk-in doors that have been closed to within 1 inch of full closure, except * * * doors wider than 3 feet 9 inches or taller than 7 feet; [and] (B) have strip doors, spring hinged doors, or other method of minimizing infiltration when doors are open * * *” (42 U.S.C
l walk-in coolers or freezers “manufactured on or after January 1, 2009, shall (A) have automatic door closers that firmly close all walk-in doors that have been closed to within 1 inch of full closure, except * * * doors wider than 3 feet 9 inches or taller than 7 feet; [and] (B) have strip doors, spring hinged doors, or other method of minimizing infiltration when doors are open * * *” (42 U.S.C. 6313(f)(1)) During the framework public meeting, interested parties suggested methods for calculating infiltration from door-opening events within the test procedure.
These two infiltration pathways, steady-state leakage, and air losses due to door-opening events, are mitigated using distinct methods.
Steady-state infiltration (the air exchanged between the interior and exterior of a walk-in while all doors are closed, also referred to as “leakage”) occurs because of the significant pressure gradient caused by the large temperature difference between the refrigerated space and the external environment. This pressure differential continuously induces air movement from the outside to the inside of a walk-in where leakage pathways exist. Leakage typically occurs through door frames, door gaskets, wall panel-to-panel interfaces, and wall-to-floor and wall-to-ceiling junctions. While considered minimal for small walk-ins, leakage becomes more significant as the walk-in size increases.
Air infiltration due to door openings is mostly a function of door area, opening frequency, duration, and air density. The primary means of reducing the amount of infiltration is by the use of active or passive infiltration reduction devices and devices that help reduce the time that doors are left accidentally ajar. Air curtains and strip curtains are good examples of active versus passive devices. The sections below describe the methods for testing the effectiveness of such devices and procedure for calculating air infiltration's impact on energy use in walk-ins
ation is by the use of active or passive infiltration reduction devices and devices that help reduce the time that doors are left accidentally ajar. Air curtains and strip curtains are good examples of active versus passive devices. The sections below describe the methods for testing the effectiveness of such devices and procedure for calculating air infiltration's impact on energy use in walk-ins.
Hired Hand recommended that the energy analysis for warehouse coolers and freezers include the performance of the door, including the number of door-opening cycles each day or week and factoring in optional door configurations such as automatic doors with or without strip curtains. (Hired Hand, No. 27 at p. 1) Eliason recommended that DOE consider average door cycling and door-ajar conditions in its test procedure. (Eliason, No. 19 at p. 1) Eliason noted that both of these conditions are part of the company's internal life-cycling test and represent real-world conditions. (Eliason, No. 19 at p. 1) Hired Hand stated that a simple rating for door infiltration performance could be based on door-opening cycles per week. (Hired Hand, No. 27 at p. 2) Hired Hand also suggested that DOE require consumer labeling to indicate the cost per minute of leaving the door open based on door
Based on stakeholder comments and DOE review of the impact of air infiltration on energy use, DOE identified two methods that could be used to measure air infiltration in walk-ins: the blower door method and the gas tracer method. These methods are described in the following subsections.
i. Blower Door Method
DOE reviewed ASTM E1827-96 (2007), “Standard Test Methods for Determining Airtightness of Buildings Using an Orifice Blower Door,” as a possible candidate test procedure for testing walk-ins. This method pressurizes or depressurizes the internal space using a large fan, typically placed in a doorway
tracer method. These methods are described in the following subsections.
i. Blower Door Method
DOE reviewed ASTM E1827-96 (2007), “Standard Test Methods for Determining Airtightness of Buildings Using an Orifice Blower Door,” as a possible candidate test procedure for testing walk-ins. This method pressurizes or depressurizes the internal space using a large fan, typically placed in a doorway. The infiltration rate of the space can be directly calculated by measuring the pressure difference between the exterior and interior space and the air-flow rate through the fan.
After reviewing this test method, DOE identified reasons why the test might not be suitable for walk-ins. The blower door method is better suited for structures with relatively high rates of infiltration, such as buildings and homes, rather than the relatively low levels typically observed in walk-ins. In addition, known calibration curves for the blower door method require small temperature differentials (generally less than 10 °F) between the inside and outside of the envelope. However, walk-ins typically operate with a far greater differential that is normally greater than 40 °F. Another drawback to using this method with walk-ins is that the test setup procedure requires blocking a main entrance to the structure with the blower door. Because infiltration around the main door is a key source of infiltration in walk-ins and would not be measured as part of the test, this approach would not adequately capture the majority of the infiltration. For these reasons, DOE does not propose the use of the blower door method for measuring the air infiltration of walk-ins.
ii. Gas Tracer Method
DOE also reviewed ASTM E741-06, “Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution.” Although not as widely used as the blower door method, the gas tracer method has been used for decades by the building industry
reasons, DOE does not propose the use of the blower door method for measuring the air infiltration of walk-ins.
ii. Gas Tracer Method
DOE also reviewed ASTM E741-06, “Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution.” Although not as widely used as the blower door method, the gas tracer method has been used for decades by the building industry. The test is conducted by injecting a tracer gas, such as carbon dioxide or perfluorocarbons, into the internal space and measuring its concentration at recorded times. From these measurements, the average air change rate can be determined. While manual tools, such as syringes, or automated systems can be used to sample the air spaces, the test procedure lends itself to automation both for calibration and data collection. Depending on the gas and sampling method used, the gas concentration can be measured immediately with portable equipment. This method is also more accurate than the blower door method because it allows for direct measurement of infiltration without modification of the design conditions. (ASTM, ASTM E741-06 (2006), “Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution,” section 5.6, p. 3)
c. Steady-State Infiltration Test
For the reasons described above, DOE proposes using the gas tracer method described in ASTM-E741-06 for measuring the steady-state air infiltration of walk-ins, with the following six exceptions:
First, DOE proposes using the “concentration decay method” instead of other available options described in ASTM E741-06. DOE considers this method to be the simplest, fastest, most cost efficient, and most accurate.
Second, carbon dioxide (CO 2 ) is the recommended gas tracer for all testing because of the few human hazards related to its use, and the availability and relative cost of sampling equipment
OE proposes using the “concentration decay method” instead of other available options described in ASTM E741-06. DOE considers this method to be the simplest, fastest, most cost efficient, and most accurate.
Second, carbon dioxide (CO 2 ) is the recommended gas tracer for all testing because of the few human hazards related to its use, and the availability and relative cost of sampling equipment.
Third, the test would use the “average air change rate” method, in changes per hour (1/h), rather than the “average air change flow” method described in ASTM E741-06. The “air change flow” method allows for the direct measure of the exchange of air in cubic feet per hour and does not require measurement of the internal volume of the space but requires a more complex test setup and sampling method. In contrast, the “air change rate” method measures the rate of exchange of air per unit of time can be completed using relatively simple equipment. However, converting this value to a measurement of the flow, e.g., volume of air exchanged per unit time, requires a precise measurement of internal volume. Since the precise internal volume of a given walk-in is readily available, DOE considers the “air change rate” method preferable to the “air change flow” method because the equipment is less expensive and the measurements are easier to obtain.
Fourth, ASTM E741-06 describes the importance of verifying proper gas mixing but does not describe where or how many spatial locations should be sampled. DOE proposes that spatial measurements shall be taken in a minimum of six locations or one location per 20 square feet (ft 2 ) of floor area (whichever results in a greater number of measurements), at a height of 3 ft ± 0.5 ft, or a minimum of 2 ft ± 0.5 ft from the inside wall of the walk-in envelope, to verify that the air space is uniformly mixed.
Fifth, DOE proposes the test be completed close to operational temperature to mimic the thermally induced pressure gradient seen in walk-ins
tion per 20 square feet (ft 2 ) of floor area (whichever results in a greater number of measurements), at a height of 3 ft ± 0.5 ft, or a minimum of 2 ft ± 0.5 ft from the inside wall of the walk-in envelope, to verify that the air space is uniformly mixed.
Fifth, DOE proposes the test be completed close to operational temperature to mimic the thermally induced pressure gradient seen in walk-ins. The internal air temperature shall be −23.3 (−10 °F) ± 2 °C (4 °F) for freezers and 1.7 (35 °F) ± 2 °C (4 °F) for coolers. The external air temperature should be 24 °C (75 °F) ± 2.5 °C (5 °F).
Sixth, the test should be completed with all doors closed. The resulting measurement shall be in units of changes per hour.
DOE requests feedback on its proposal to use ASTM E741-06 as the method for determining air infiltration and on the proposed exceptions to the test procedure.
For the purposes of administering the test, DOE considered the following options for the location of the test: (1) Require testing at a third-party testing facility. DOE believes that requiring that manufacturers to ship every walk-in manufactured, or a representative model, to a third-party facility for testing, would place a substantial burden on manufacturers; (2) require testing by a third party on site at a walk-in manufacturing facility. Completing the infiltration test at the manufacturing facility reduces logistical complexity and costs associated with testing. Since the equipment used to complete infiltration testing was originally designed for testing the performance of buildings, the equipment and protocols are designed to be mobile.
DOE believes that the most viable option is allowing testing to occur at the manufacturing facility, if preferred by the manufacturer. DOE requests feedback on the flexibility of location required for completion of any infiltration test.
iii
to complete infiltration testing was originally designed for testing the performance of buildings, the equipment and protocols are designed to be mobile.
DOE believes that the most viable option is allowing testing to occur at the manufacturing facility, if preferred by the manufacturer. DOE requests feedback on the flexibility of location required for completion of any infiltration test.
iii. Door Infiltration Reduction Device Test
DOE is considering incorporating a door-opening test to quantify the impact of technologies such as strip curtains, air curtains, or other infiltration reduction devices during door-opening events. Due to the limited data available on these devices and the variety of technologies, DOE believes a standardized test would provide a more comprehensive and accurate picture regarding the effectiveness of these devices when compared to simply using effectiveness assumptions.
DOE proposes a two-part test to account for the effect of the door infiltration reduction device. First, measurements should be taken once the tracer gas has uniformly dispersed in the internal space using the methodology described in ASTM E741-06. Within 3 minutes ± 30 seconds, with the infiltration reduction device in place, a door should be opened at an angle of 90 degrees over a period no longer than 3 seconds, then held at 90 degrees in the open position for 5 minutes ± 5 seconds, then closed over a period no longer than 3 seconds. The gas concentration should be sampled again after the door has been closed. Samples should continue being taken until the gas concentration is once again uniformly mixed within the walk-in. Second, the test should be repeated exactly as described above with the infiltration reduction device removed or deactivated
tion for 5 minutes ± 5 seconds, then closed over a period no longer than 3 seconds. The gas concentration should be sampled again after the door has been closed. Samples should continue being taken until the gas concentration is once again uniformly mixed within the walk-in. Second, the test should be repeated exactly as described above with the infiltration reduction device removed or deactivated.
Using the measured infiltration with the device in place and without the device in place, the infiltration reduction effectiveness can be directly calculated:
EP04JA10.025 Where: V rate,with-device = air infiltration rate, with door open and reduction device active, using 4.2, 1/h; V rate,without-device = air infiltration rate, with door open and reduction device disabled or removed, using 4.2, 1/h. This calculation will yield a value between 0 and 100 percent, with 100 percent meaning that the device prevents all air infiltration when the door is open. DOE proposes using this calculated effectiveness for every unique door-device combination that a manufacturer may offer. DOE requests feedback on the proposed method for measuring the effectiveness of an infiltration reduction device.
iv. Infiltration Due to Door Openings
DOE does not propose to require manufacturers to measure the infiltration from all door-opening events. The complexity of testing, the variation of walk-in design, and various end-use behavior factors would make such a recommendation very difficult to execute. Instead, DOE proposes using analytical methods based on equations published in the ASHRAE Refrigeration Handbook in combination with assumed door-opening frequency, and duration of door cycles, to calculate the air infiltration associated with each door-opening event.
ASHRAE recommends using Gosney and Olama's (1975) air exchange equations for fully established flow through door openings (Equation 2)
ad, DOE proposes using analytical methods based on equations published in the ASHRAE Refrigeration Handbook in combination with assumed door-opening frequency, and duration of door cycles, to calculate the air infiltration associated with each door-opening event.
ASHRAE recommends using Gosney and Olama's (1975) air exchange equations for fully established flow through door openings (Equation 2). Several key assumptions have the greatest impact on predicated air exchange and are related to the calculation of the decimal portion or time a doorway is open, D t . (ASHRAE, Refrigeration Handbook , 2006, section 13.5)
EP04JA10.026 Where: D t = fractional door opening, P = the number of doorway passages (or number of door-opening cycles for a given door), θ p = the door open-close time, θ o = the time the door stands open, and θ d = daily time period. D t is important for properly calculating the energy impact of air infiltration due to door-opening events. Therefore, the assumed values of P, θ p , and θ o will drive the result. The daily time period, θ d , is simply assumed to be 24 hours.
For display glass doors, a P of 72 per day, θ p of 8 seconds per passage, θ o of 0 minutes and θ d of 24 hours could be used. P of 72 per day is based on comments by Hired Hand and research on cold store infiltration. Hired Hand commented that the reach in frequency is approximately 400-600 per week (or one passage every 20 minutes assuming 18 hours per day per week). (Hired Hand, Public Meeting Transcript, No. 15 at p. 154) However, DOE identified a study by A.R. East, P.B. Jeffrey, and D.J. Cleland, “Air Infiltration into Walk-in Cold Rooms,” which suggested that this number should be closer to one passage every 10 minutes (assuming 18 hours per day per week). DOE suggests that the average of the two values of one passage every 15 minutes or P of 72 per day could be used. DOE chose the value of 8 seconds per passage but seeks comment on whether another value may be more appropriate
. Cleland, “Air Infiltration into Walk-in Cold Rooms,” which suggested that this number should be closer to one passage every 10 minutes (assuming 18 hours per day per week). DOE suggests that the average of the two values of one passage every 15 minutes or P of 72 per day could be used. DOE chose the value of 8 seconds per passage but seeks comment on whether another value may be more appropriate.
For all other door or access types, a P of 60 per day, θ p of 12 seconds per passage, θ o of 15 minutes, and θ d of 24 hours could be used. The number of passages reflects that other door types are typically accessed less frequently than glass doors. The value of 12 seconds per passage was selected based on the assumption that non-glass doors, such as those through which forklifts are driven in order to load product, will be open for longer periods of time than a typical display door. DOE selected the θ o of 15 minutes due to the probability that a non-glass door will be propped open accidentally or intentionally. If an automatic door opener/closer is used for doors larger than 7 feet tall and 3 feet, 9 inches wide, then a θ p of 10 seconds should be used.
DOE recognizes that with the variety of walk-in types and end-users, the frequency and duration of door-opening events is likely to vary significantly. As a result, DOE requests comments on the DOE assumed values for P, θ p , and θ o .
3. Calculations
In this section, DOE proposes a calculation methodology for using the results obtained from the measurements in the aforementioned tests, along with other known quantities, to calculate an energy use metric associated with the envelope. The steps in the proposed methodology are explained below.
a. Energy Efficiency Ratio
EPCA requires that the test procedure “measure the energy use of walk-in coolers and walk-in freezers.” (42 U.S.C. 6314(a)(9)(B)(i)) However, EPCA does not specify the units of measurement or units for reporting that are required
nown quantities, to calculate an energy use metric associated with the envelope. The steps in the proposed methodology are explained below.
a. Energy Efficiency Ratio
EPCA requires that the test procedure “measure the energy use of walk-in coolers and walk-in freezers.” (42 U.S.C. 6314(a)(9)(B)(i)) However, EPCA does not specify the units of measurement or units for reporting that are required. Based on a review of commonly used energy consumption metrics, DOE recommends the use of kWh/day as this unit is commonly recognized by end-users, manufacturers and other interested parties. However, a majority of metrics used to describe heat transfer losses are in units of British Thermal Units (BTU) per unit time. Therefore, to convert the British Thermal Units per hour (BTU/h) thermal energy transmission calculation into a measure of electrical energy consumed by the refrigeration equipment to remove the heat, DOE proposes using an energy efficiency ratio (EER) conversion based on a nominal efficiency of an assumed refrigeration system.
Because an envelope manufacturer cannot control where the refrigeration equipment is sited and the EER is intended to provide a means of comparison and not directly reflect a real walk-in installation, DOE proposes that the EER be 12.4 Btu per Watt hour (Btu/W-h) for coolers and 6.3 Btu/W-h for freezers. The difference in EER for coolers and freezers reflects the relative efficiency of the refrigeration equipment for the associated application. 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. DOE requests feedback on the relative EERs of refrigeration equipment for a comparison basis.
b
refrigeration equipment for the associated application. 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. DOE requests feedback on the relative EERs of refrigeration equipment for a comparison basis.
b. Heat Gain Through the Envelope Due to Conduction
The energy calculation for all components that comprise the external surface area of the walk-in may be determined using the measured surface area, the measured foam R-value for the walls and ceiling, the R-value (or U-value) for glass doors, the design operation temperature, and the average ambient air temperature. Then, the associated heat transfer due to conduction can then be directly calculated.
i. Conduction Through Glass Display Doors
The heat conduction through the glass is one of the largest single contributors to energy consumption for walk-ins with a high ratio of glass surface area to non-glass surface. The thermal conductivity, the inverse of thermal resistivity or R-value, is commonly represented by the U-value in units of Btu/ft 2 -°F-h. The thermal conductivity for most glass products, such as glass doors and windows used in buildings, is certified by a third party organization such as the National Fenestration Rating Council (NFRC). After certification, the product is granted a NFRC label and thermal conductivity performance rating. This rating represents an overall component performance including but not limited to the glass and the glass frame. However, in the case of glass products manufactured for the use in walk-ins, such as display doors, inset window and glass walls, DOE believes that glass component manufacturers currently do not participate in any third party rating programs nor do they provide products with performance labels. In addition, the performance data of these products is not readily available able in product literature
However, in the case of glass products manufactured for the use in walk-ins, such as display doors, inset window and glass walls, DOE believes that glass component manufacturers currently do not participate in any third party rating programs nor do they provide products with performance labels. In addition, the performance data of these products is not readily available able in product literature.
In order for the thermal conductivity performance of glass products be incorporated into the walk-in test procedure, DOE proposes these two options: (1) If manufacturers of glass doors used in walk-ins participate in the same NFRC rating program, the performance of the door shall be simply read from its label and used for calculations in this test procedure. If glass door manufacturers do not participate in the same NFRC rating program, then (2) DOE would require manufacturers to use the free software package Window 5.2 (available here: http://windows.lbl.gov/software/window/window.html ), that calculates the U-value, or thermal conductivity, of a glass door given precise specifications such as the size of the door, the number of panes of glass, the gas fill between the panes, etc. This tool was developed by Lawrence Berkeley National Lab (LBNL) and is known in the glass component industry to accurately predict glass door thermal performance from the given door characteristics. It has been used for many years and has been heavily verified by empirical test data. In order to ensure that inputs used to calculate overall door performance are not being manipulated by manufacturers, DOE intends to require the walk-in manufacturer to report the exact inputs and settings used in Window 5.2 to represent the door materials and glazing system. This will ensure transparency and accuracy by enabling other manufacturers and DOE to verify the integrity of the data and calculated performance
t inputs used to calculate overall door performance are not being manipulated by manufacturers, DOE intends to require the walk-in manufacturer to report the exact inputs and settings used in Window 5.2 to represent the door materials and glazing system. This will ensure transparency and accuracy by enabling other manufacturers and DOE to verify the integrity of the data and calculated performance.
DOE seeks comment on the availability of performance data on glass products used in walk-in applications, glass component manufacturers' participation in third party certification programs such as NFRC, and the proposed method for predicting the thermal performance of glass components using LBNL's Window 5.2 software package.
ii. Conduction Through Floors
In general, walk-in coolers are installed on top of concrete surfaces regardless of the walk-in type. For a walk-in cooler that does not have a floor supplied by the manufacturer, the average insulating performance of concrete will be assumed for the floor surface of the walk-in. Therefore, DOE proposes using an R-value of 0.6 ft 2 -F-h/Btu for calculating the energy lost assuming the walk-in cooler are sited on 6-inch concrete floors of 150 lb/ft 3 density (ASHRAE Fundamentals Handbook). DOE requests feedback on the use of this R-value for coolers that are not shipped with an insulated floor.
Generally, walk-in manufacturers that sell large freezers do not install freezer floors. This task is normally subcontracted by the end-user before the walk-in is installed to ensure EPCA compliance. Therefore, DOE proposes using the minimum R-value specified in EPCA for walk-in freezer floors, R-28 ft 2 -F-h/Btu, for energy performance calculations if the manufacture does not supply a floor to ensure EPCA compliance. (42 U.S.C. 6313(f)(1)(D)) DOE requests comments on the use of this proposed R-value for freezer floors.
c
he end-user before the walk-in is installed to ensure EPCA compliance. Therefore, DOE proposes using the minimum R-value specified in EPCA for walk-in freezer floors, R-28 ft 2 -F-h/Btu, for energy performance calculations if the manufacture does not supply a floor to ensure EPCA compliance. (42 U.S.C. 6313(f)(1)(D)) DOE requests comments on the use of this proposed R-value for freezer floors.
c. Heat Gain Due to Infiltration
The amount of embodied energy in an air sample is primarily a function of its temperature and density or what is typically referred to as the enthalpy in a thermodynamic system such as a walk-in. The required amount of energy needed to remove heat from the air is calculated as the difference between the enthalpy of air entering the refrigerated space and enthalpy of the air inside the refrigerated space. This calculation is commonly used when designing walk-ins and typically uses dry-bulb and wet-bulb temperatures. The difference, per unit mass or volume of air, is calculated using the functional relationship between temperature and enthalpy. Using the measured infiltration rate from the required steady-state test described above or calculated analytical value for air infiltration for door-opening events and the calculated internal and external enthalpy, a rate of energy lost per hour (Btu/h) due to air exchange can be calculated.
d. Envelope Component Electrical Loads
Because the energy use of the walk-in refrigeration equipment is being analyzed separately from the envelope energy use, DOE is considering calculating the electricity consumption of lights, sensors, and other miscellaneous electrical devices using name-plate rating and assumptions about their daily operation, all of which would be incorporated into the evaluation of envelope energy use
al Loads
Because the energy use of the walk-in refrigeration equipment is being analyzed separately from the envelope energy use, DOE is considering calculating the electricity consumption of lights, sensors, and other miscellaneous electrical devices using name-plate rating and assumptions about their daily operation, all of which would be incorporated into the evaluation of envelope energy use. In addition, because the test procedure for the refrigeration system will not include heating loads caused by lighting, heater wires, and other miscellaneous components, the thermal load from these components will be factored into the envelope calculations. DOE proposes as part of the test procedure calculations that 100 percent of the electrical energy consumed to operate the devices that are internal located in the walk-in, will be converted to thermal energy. This assumption is accurate since at steady-state, all the input electrical energy is converted completely into heat adhering to the physical laws of conservation of energy. While some electrical energy, which has been converted into light, may escape the controlled space via translucent glass display doors, this escaping energy is negligible. The associated thermal energy will then be used to calculate an additional compressor load that would be required to remove the additional heat generated by these components.
DOE recommends using the following equation to calculate the power usage for each electricity-consuming device type, P comp , (kWh):
EP04JA10.027 Where: P rated,t = rated power of each component, PTO t = percent time off, and n t = the number of devices at the rated power. DOE proposes that the rated power must be read from each electricity-consuming device product data sheet or name plate, and the n t is the number of identical devices for which the P comp calculation is being made
city-consuming device type, P comp , (kWh):
EP04JA10.027 Where: P rated,t = rated power of each component, PTO t = percent time off, and n t = the number of devices at the rated power. DOE proposes that the rated power must be read from each electricity-consuming device product data sheet or name plate, and the n t is the number of identical devices for which the P comp calculation is being made.
DOE further proposes the use of the following equation to calculate additional compressor load due to heat generated by electrical components, C load , (kWh):
EP04JA10.028 Where: EER = EER of walk-in (cooler = 12.4 or freezer = 6.3), Btu/W-h P tot,int = The total electrical load due to components sited inside the walk-in envelope The percent time off (PTO) value accounts for the reduction in energy use in walk-ins with component control systems installed and to specify the possible number of hours for various component types. While this value may not reflect behaviorally related energy consumption, such as how long an end-user typically leaves the lights on, it will provide a means for comparison of walk-in performance. To address the wide variety of devices that could be employed in a walk-in unit, DOE proposes the following PTO values:
(1) For lights, DOE proposes a PTO value of 25 percent for systems without timers or other auto shut-off systems and 50 percent for systems with timers or other auto shut-off systems installed.
(2) For anti-sweat heaters, DOE proposes a PTO value of 0 percent for all systems without direct or indirect relative humidity sensing controls. DOE further proposes that a PTO value of 75 percent be used for walk-in coolers, and 50 percent for walk-in freezers with these controls. (Focus on Energy, BP-3429-0304, “Anti-Sweat Heater Controls,” 2004, p. 1)
(3) For electrically powered devices (such as air curtains) that mitigate air infiltration but are not actively controlled based on door open or closed positions, DOE proposes a PTO value of 25 percent.
ses that a PTO value of 75 percent be used for walk-in coolers, and 50 percent for walk-in freezers with these controls. (Focus on Energy, BP-3429-0304, “Anti-Sweat Heater Controls,” 2004, p. 1)
(3) For electrically powered devices (such as air curtains) that mitigate air infiltration but are not actively controlled based on door open or closed positions, DOE proposes a PTO value of 25 percent.
(4) For electrically powered devices that mitigate air infiltration that are also actively controlled based on door open or closed position for display doors , DOE proposes a PTO value of 99.33 percent.
(5) For electrically powered devices that mitigate air infiltration that are also actively controlled based on door open or closed position for all other doors , DOE proposes a PTO value of 99.17 percent.
(6) For all other devices, DOE proposes a PTO value of 0 percent, unless the walk-in manufacturer can demonstrate that the device is controllable by a preset control system. If this can be demonstrated, then DOE proposes a value of 25 percent for the device in question.
DOE seeks comments on these assumptions.
e. Normalization
A single metric would make comparing the energy use of walk-ins much more straightforward. DOE proposes using a calculation for energy consumption per unit time and a normalization factor to account for differences in glass and non-glass external surface area depending on the product class. During the framework public meeting and in written comments, some interested parties recommended that DOE use volume as the normalization factor for performance standards. (Manitowoc, Public Meeting Transcript, No. 15 at p. 56; EEI, Public Meeting Transcript, No. 15 at p. 116; NEEA, No. 18 at p. 3) Crown Tonka, in a written comment, recommended that the test metric be kWh per cubic foot ( i.e. , energy consumption normalized by volume). (Crown Tonka, No. 23 at p. 1) The Joint Comment recommended that DOE use surface area as the normalization factor. (Joint Comment, No. 21 at p
Public Meeting Transcript, No. 15 at p. 56; EEI, Public Meeting Transcript, No. 15 at p. 116; NEEA, No. 18 at p. 3) Crown Tonka, in a written comment, recommended that the test metric be kWh per cubic foot ( i.e. , energy consumption normalized by volume). (Crown Tonka, No. 23 at p. 1) The Joint Comment recommended that DOE use surface area as the normalization factor. (Joint Comment, No. 21 at p. 2) A comment submitted jointly by representatives of SCE, SMUD, and SDG&E (hereafter referred to as the Utilities Joint Comment) also stated that DOE should use surface area as a normalization factor. (Utilities Joint Comment, No. 32 at p. 7)
Many established metrics use a per-day time scale normalized by product volume. However, surface area is the key geometric characteristic related to both conduction and infiltration because volumetric normalization cannot directly account for the higher conduction and infiltration losses associated with glass doors and windows. Conduction and infiltration losses through glass become particularly important considerations as the ratio of glass door area to total wall area increases, as is the case in walk-ins designed for customer access. Using surface area as the normalization factor would account for these losses through any glass door or window used in a walk-in. Therefore, DOE proposes the use of surface area as a normalization factor for performance calculations of wa

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/FR_PRORULE_E9-30884. Check the current official text before relying on it. Not legal advice.