memorandum - hmg

Statewide Utilities Codes and Standards Program 2013 CASE Initiative

Memorandum February 7, 2011

To: Stakeholders

Cc: C+S Statewide team

From: Mike McGaraghan, on behalf of the C&S Statewide Team

Re: Stakeholder Meeting #2 for Process Air Compressors, Boilers, and Water Heaters Topics, January 19, 2011, San Ramon

In Person Attendees:

Mike McGaraghan, Energy Solutions

Ransom Byers, Energy Solutions

Russell Torres, Energy Solutions

Matt Tyler, Portland Energy Conservation, Inc.

Yanda Zhang, Heschong Mahone Group

Stu Tartaglia, Pacific Gas & Electric (PG&E)

Ed Nordstrom, Heat Transfer Products

Cory Weiss, Field Controls

James York, Rinnai

Ryan Flanigan, Flanigan Law

Gregory Straughnn, Associated Compressors

Steve Hoover, Kaeser Air Compressors

John Portzer, AccurateAir

Kevin O’Brien, Ecos Consulting

Ryan Crane, ASME

Patrick Sullivan, Energy Protection Systems

Amin Delagah, Food Service Technology Center

Robert Barrett, PG&E

Eddie Huestis, PG&E

Rich Fromberg, PG&E

Justin Kjeldsen, PG&E

MEMORANDUM (continued)To: Process Air Compressors, Boilers, and Water Heaters Stakeholders January 27, 2011Re: CEC/IOU Process Topics CASE Stakeholder Meeting

of 14

Webex Attendees:

Tai Voong, PG&E

Jon McHugh, McHugh Energy

Bill Scales, Scales Air

David Booth, Sullair

Al Moreno, Kaeser Air Compressors

Adam Neugebauer, Consol

Lynn Qualmann, SBW Consulting

Patricia Goudge, SBW Consulting

Eric Bessey, Pneu-Logic

Robert Glass, Raypak

Ron Marshall, Hydro MBA, Compressed Air Challenge (CAC)

Corbin ______, Thermo Technologies

Tom Osborn, Bonneville Power Administration (BPA), CAC

Aniruddh Roy, AHRI

Dale Shropshire, A.O. Smith

Devin Liebmann, Ecos Consulting

Eric Adaird, Duravent

Eric Braddock, Ecos Consulting

Frank Stanonik, AHRI

Gary Elder, Rheem

Greg Wheeler, Washington State

Jim Smelcer, Lochinvar

John Confrey, Noritz

Mark Kiser, Atlas Copco

Nick Carter, Atlas Copco

Nicolas De Deken, EnergAir

Ron Yasny, California Energy Commission (CEC)

Sabaratnam Thamilseran (Seran), CEC

Tuan Ngo, CEC

Rob Hudler, CEC

Tom Buescher, Emerson


of 14

MEETING NOTES

This memo summarizes the comments that were made during the second Investor Owned Utility (IOU) sponsored 2013 Title 24 stakeholder meeting for Process Air Compressors, Boilers, and Water Heaters related topics. The meeting was held at the San Ramon Conference Center January 19, 2011. Most of the discussions focused on the specific code change proposals and the initial results of cost-effectiveness and feasibility analysis.

For a full understanding of the scope of each code change proposal, this memo should be read in conjunction with the power point materials that were presented at the stakeholder meeting.

Air Compressors New Code Proposals: VSDs on all systems and Smart Controls on Multi-

Compressor Systems

Minimum Requirements for Smart Controls

Commenter: Is there a minimum size that this requirement is cost-effective? Does this also apply to reciprocating compressors as well?

CASE team: We're still looking into system size as a constraint and will address this as we talk about the baseline systems. We believe this will apply to all compressors (hence the requirement to work with various types, not necessarily just 1).

Commenter: Any requirement for logging power consumption, pressure and flow so one can evaluate if performance is degrading over time?

CASE team: I do agree that this would be information that could be extremely useful, both for the owner and for our own statistics [but this is not part of our code proposal?].

Key Assumptions for Baseline Systems

Total System Size

Commenter: What do you mean by system size? What is the “+ 25% on slide 33?


of 14

CASE Team: We’re expecting systems to be oversized and the additional +25% of rated CFM is on top of what the full load requirements are for the system.

Primary Storage (and Storage in General)

Suggestion from commenter that 2 gal/cfm for primary storage is best for the trim compressor.

Another suggestion that 1 gal/cfm is typical in installations now, with 2 gal/cfm being more typical for systems after an audit is performed.

Primary storage also is different depending on the type of compressor. Lubricated rotary screw compressors usually have a recommended minimum of 3 gal/cfm (and up to 10 gal/cfm) because of the lead time during unloading. 2 gal/cfm is usually recommended for oil-free rotary screw compressors.

Furthermore, with storage, one sizes the tank based on the duration of the peak load. You want to maintain system pressure to avoid starting up another compressor and this is where storage comes into place.

Commenter mentioned that AirMaster+ has a very specific use for primary storage. It only comes into play during the part-load performance of lubricant-injected screw compressors.

Storage is also needed for proper multiple compressor controls. Otherwise, the handoff between compressors will not operate correctly.

Commenter: Were you only going to consider storage before the end uses? This is clearly not an industry standard. Usually, there’s 2 receivers: a wet and a dry one.

CASE Team: We had previously made the assumption that we were only looking at primary storage prior to the end uses, but we may have to re-evaluate this assumption.

Commenter suggested that storage needs to be considered both upstream of the equipment and at the end uses. Usually there is both a wet receiver and a dry receiver.

Also, that piping volume should be considered.

Requirements for Compliance (Sizing and Permitting)

Commenter: Over what size systems are we talking about? There’s a lot of small compressed air systems (less than 10hp) that could be affected by this.


of 14

CASE Team: We’re mostly looking at new construction and major facility renovations.

Commenter: But what are the size cutoffs?

CASE Team: At this point, it’s more about when a permit needs to be pulled.

Commenter: Though I don’t work that much in California so I can’t speak for California, but I can’t imagine that a permit needs to be pulled for industrial facilities. Furthermore, if a building permit is key, then every car dealership and autobody shop becomes liable for these new standards.

Assumed Baseline Pressure

Commenter: I had a question about the 90psi on slide 33. Is that supply side or demand side?

CASE Team: Supply side. Basically where the controls are sensing pressure to determine control.

Commenter: I think 90 psi is an idealistic goal, but it does depend on which side. The psi is pretty tight and I don’t think it’s realistic

Commenter: I think 100 psi is better.

Commenter: For farm equipment, 120 psi might even be appropriate.

Commenter: You may want to consider various pressures for various applications. Downstream, it’s often 90-100 psi, so its often 125 psi at the discharge.

Commenter: The entire bottling industry may be at 500-600 psi.

Commenter: Maybe you could incorporate a pressure drop rather than a discharge pressure.

Commenter: A pressure range you might consider is 90-100 psi downstream, 135 psi upstream.

Commenter: Clarifying that previous commenter was inquiring about existing systems. For new systems, that pressure range may change.

CASE Team: Does anyone know what portion of the market is higher than 200 psi range?

Requirements for Compliance (Sizing and Permitting, continued)

Commenter: We should make clear whether or not these systems are new construction or existing.


of 14

CASE Team: These systems are based off when a permit is pulled.

Commenter: Will this change affect when a permit is pulled? I’m confident adding a compressor never pulls a permit.

Key Assumptions for Baseline Systems

Baseline #2 (slide 36)

Stakeholders: At this size, this case would likely not be a multi-compressor system. This would probably be a single compressor

CASE Team: It looks like we’ll need to increase the size of these systems. Any suggestions?

Commenter: If you doubled the system size that would probably be a multi-compressor system.

Another Commenter: I think 100 hp minimum would justify multiple compressors.

Commenter: Also, the VSD compressor shouldn’t be the smallest of the compressors – that would be a small trim capacity.


Commenter: Still on the small side for a multi-compressor system.


CASE Team: We’ll likely need to increase the size.

Commenter: Why not use CFM/kW as a metric? Also, ASME has a standard for storage.

When is a permit required?

Commenter: None of these systems would need a permit to be installed

Commenter: My understanding is that these trigger electrical code andthat these definitely would need an electrical permit.

Commenter: Industrial facilities tend to be exempt nationwide. Commercial end may not be so, but typically permits are not required for industrial facilities. In my experience, an electrical inspector would inspect up to the service entrance.


of 14

Commenter: If a new project, inspector will actually check a new compressor being installed (UL, conduit connections, etc.), as a new compressor does change the electrical system.

CASE Team: We’re talking about new construction or major renovation and for industrial facilities alike, Title 24 Building Efficiency Standards should be triggered.

Typical Practice and VSDs

Commenter: It’s my understanding that you’re trying to identify what new installations will be. I would assume that VFDs are the new baselines.

Commenter: What is the new market share for VFDs?

Commenter: More than half. Maybe 60%. Compressed Air and Gas Institute (CAGI) could likely tell you more accurately what the market share is.

CASE team: Still, for the purposes of our LCC analysis (demonstrating cost-effectiveness of VFDs, we will be comparing VFDs in the standards case to no-VFDs in the base case.

Commenter: I also want to caution that we often see VFDs misapplied.

Oversizing and Baseline Systems

Commenter: One concern I have: consulting engineers will normally oversize systems. Sometimes there are three compressors, and they only end up using 1. So its very hard to assess savings in a facility before it is running.

Cost Effectiveness Methodology

Costs

The VFD costs are based on new construction are all exclusive of incentives. Additionally:

Commenter: Usually incremental costs do not include labor

CASE team: Our analysis will assume all incremental costs associated with the installation of the required equipment – including the material cost and the incremental labor costs for installation.


of 14

Temperature Reset Controls CEC Commenter: Are there any layout issues related to the plumbing

systems or any related distribution losses? Are there installation guidelines that may apply here with additional savings? I want to ensure we're making a big impact towards CA's energy goals.

CEC Commenter: DesignDay model is not currently used by the CEC. Is this current version used often? What about the other climate zones for modeling?

Commenter: We're using this because it is more accurate than the current versions. We will be using the same version of this tool for both before and after cases with the same assumptions.

Process BoilersSize Limits and Costs

Commenter: Are there going to be any formal definitions for what falls under this proposal? Will this include a specified input range? What about an upper limit?

CASE Team: This is definitely driven by a cost effectiveness threshold, but I have not set an upper limit.

Commenter: Given that, I have a couple comments. First, Flue dampers no longer cost $1,000 once you past say 10, 30, 40-million BTUs. Nor is it terrible cost-effective at this point. Second, why not just set a minimum efficiency requirement for boilers?

CASE Team: Taylor Engineering is currently working with the ASHRAE 90.1 committee on part-load efficiency standards for boilers.

Commenter: I'm not concerned about part-load. What about using combusting efficiency for process boilers? I'm not sure about a good testing procedure for boilers.

Commenter: Actually there's a simple flue gas temperature tool that will tell you combustion efficiency. However, there are many different variables that play into this efficiency.

Commenter: I think you need to think of a reasonable input range that defines process boilers. As mentioned earlier, if you're talking about large (>10 or 15-million BTUs), $1,000 is not reasonable for a flue damper.


of 14

Commenter: Where did the cost estimate come from? For larger boilers, construction requirements are a lot different. Results are also not identical for capping at either the inlet or outlet, though both will result in energy savings.

CASE Team: We have a single data point from a flue damper manufacturer. It seems like we'll need to look at a wider range for incremental costs. Ultimately, we're looking at positive shutoff.

CASE Team: Does anyone from the commission want to weigh in about Title 20 potential for combustion efficiency?

CEC Commenter: No one who works on Title 20 is on this call, but I will look into it. It does seem like it could be a good application for Title 20.

CEC Commenter: I also agree that a size limitation is necessary. I have concern with O2 trim control as I'm not sure if it will be cost-effective for smaller units.

Commenter: For large systems, I would think that the baseline would be high already. If someone is installing a process boiler with a huge capacity, I would think that they're already considering their energy costs as a significant concern.

Further concerns on combustion efficiency

CASE Team: We can't just deal with combustion efficiency - thermal efficiency is very important. Combustion efficiency doesn't change that much, but it’s the thermal efficiency that does change based on a variety of factors.

Commenter: In the federal regulations, the requirements change from thermal to combustion once over 2 MMBtuh because there is no reasonable way to run a thermal efficiency test at that size.

CASE Team: I agree that thermal efficiency is difficult to measure, but combustion efficiency is not a good indicator.

Commenter: It is a good starting point.

Commenter: Combustion efficiency is a measure of stack loss. We need to be concerned about jacket loss. These process boilers are dependent on temperature requirements. A single number is simply not possible for process as it is dependent on application.

CEC Commenter: Combustion efficiency is not what we're going to go after. Thermal efficiency is more important to us. I believe that parallel positioning with oxygen trim control will take care of your concerns about combustion efficiency.


of 14

Commenter: R-values for casing are very similar between manufacturers. Need to consider system and operation, not just boilers.

Commenter: We need to consider what Process Boilers are being used for in CA.

CASE Team: We have this data from the air quality permits that are pulled, and can provide that to stakeholders.

Requested data inserted into meeting notes below:

This is derived from the boiler permit database obtained from the San Joaquin Valley Air Pollution Control District.

Type of Facility# of

Facilities % of total

Food Processing 76 38%

Fuel Production 33 17%

Dairy 25 13%

Manufacturing 16 8%

Healthcare 10 5%

Wine 9 5%

Power Generation 7 4%

Water Treatment 6 3%

Animal Feed Processing 5 3%

Corrections 4 2%

Laundry 3 2%

Education 2 1%

Government 2 1%

Grand Total 198 100%

Parallel Positioning and Combustion Fan VFD Costs

Commenter: Are these costs also from just a single data point?

CASE Team: No, those are more robust - the parallel positioning measure costs are from 4 vendors and the cost is constant across the range of 50


of 14

HP to 800 HP units, with the VFD costs developed through data from one of the PECI retrocommissioning programs.

Commenter: Parallel positioning requirement is very design restrictive for a given size. You need to be careful about forcing controls on smaller systems. You may be forcing controls on smaller units that are not cost-effective.

CASE Team: Where do you think the threshold should be?

Commenter: I would guess the threshold would be 10 MMBtuh and above. Also, there's no way this could be done with a packaged boiler.

CEC Commenter: Could you contact the manufacturers and ask them for a cost range of different size units. This will help us identify a lower limit.

CASE Team: We do have a range of costs for VFDs of different sizes, but we will look into this for Flue Dampers and Parallel Positioning.

Packaged Boilers

Commenter: There is a trend for boilers 5 MMBtuh and below (which are mostly packaged) to be using VFDs and a negative pressure gas valve, which essentially does the same things as PP. Therefore, I don't believe you should be considering boilers 5 MMBtuh and below.

Commenter: I agree there's a trend, but I disagree that everyone is doing it. There are products out there that can achieve low NOx levels without a VFD, like horizontal staged positioning. For ultra-low NOx, a VFD will be used.

Further comments

Commenter: Is the life of equipment considered? What about the old boilers now? Will they really last 15 years?

CASE Team: We're really looking at just the savings of the measure, not necessarily the changes in savings because of a new boiler.

Commenter: How is liability and certification taken into consideration? Typically, the manufacturer of a boiler will be liable if a burner is changed out. Who will be liable for ensuring that it's re-installed safely?

CASE Team: But this measure is not requiring burner change-out. This just requires that controls be installed if people choose to do burner change-outs. Burner change-out happens frequently.

Commenter: Change-outs don't happen that frequently in the range of 5 MMBtuh or below.


of 14

Standing Losses and High-Efficiency Water Heaters Code Change Proposals

Pipe Sizing

Commenter: Why is a 3/4" pipe recommended? What about a higher pressure?

CASE Team: A 3/4" pipe is appropriate for the demand of a tankless water heater. I'm not sure about using a higher pressure.

Commenter: Still need to regulate at each application. It is a good option for a retrofit, but not for new construction.

Commenter: Even for a new house, you can have a 2 psi pressure, but each application will require a regulated pressure. There are 2 lb systems designed, but any appliance is not going to see more than a 14" water column. Some instance of piping to this application will need to be sized appropriately.

Federal standards

Commenter: Why not require manufacturers to increase the R-value of the insulation rather than requiring the water heater blanket?

CASE Team: Unfortunately, the DOE did not adopt this as a minimum standard.

Commenter: Is California intending on requesting a waiver to be exempt from Federal standards? If not, you're not going to be able to require anything on this.

CASE Team: The utilities and the CEC have requested exemption from Federal standards in the past, but they have not gotten positive feedback from the DOE in the past and I do not believe they'll be requesting it now. So our proposal is focused on measures that would not conflict with federal standards or cause pre-emption concerns.

Flue Dampers

Availability of Third-Party Flue Dampers

There were several stakeholders that confirmed that third party flue dampers are not available as a stand alone part because they are an integral component to a water heater. Aftermarket installations are a huge safety concern and


of 14

liability problem as many tests need to be performed. No testing/validation will happen for any aftermarket flue damper.

Ideally the damper should be at 90 degrees, but because of the variability of units, the water heater may be able to fire at 84 degrees – and they have to be tested at the worst case scenario, the lowest angle at which with WH still fires. And this varies greatly between manufacturers and models.

CASE Team: We recognize there is not a universal product right now - but going forward it seems like it would be a good idea, and it seems like this would be possible.

Manufacturer Comment: I agree that it's possible, but I don’t think we’d ever get there given the industry and what’s involved. Ultimately the WH manufacturers would have to give the final Ok on what can go on their product.

Flue damper specifications

Flue-damper effectiveness represents the percentage of flue loss during standby. Flue damper cost represents that of the equipment itself (retail price). Installation costs need to be included for controls modification because modification is required.

High Efficiency Water Heater Ready Homes

Commenter: Having a dedicated 110 V outlet makes sense. However, as for an exhaust pipe, water heaters actually have vent systems. There are a lot of high-efficiency retrofits that would not be able to use existing vent systems. The critical thing would be to provide a designated area in the side wall that in the future could be used as a point of connection for venting the new product horizontally.

Commenter: What you need is to ensure that the hole in the wall or the space reserved is in a place that is appropriate and will safely vent horizontally. This is likely a lot less expensive than putting in a stainless steel pipe.

Commenter: However, there are some cost savings installing this during new construction, as labor is cheaper.

Commenter: But this assumes that they'll be able to use that stainless steel piping in the future. It really all depends on the type of water heater. It may not even be the right size.

CASE Team: But at least it could work for some people, as opposed to the alternative which will not work for anyone.

Commenter: A horizontal vent will lower future costs. I support the proposal for a designated sidewall area.


of 14

Commenter: As for the 3/4" pipeline, I'm very ambivalent about this one. What if someone puts in a condensing storage water heater? This gas line because obsolete.

CASE Team: Agreed, but this is the same argument mentioned for the venting pipe, but the cost at new construction is minimal and opens up a lot of options to the consumer considering various high-efficiency options.

Further comments

Long Term Goals

Commenter: How will the NOx regulations and these energy efficiency regulations affect the market? What kinds of products will be available that meet both? Basically, is there some joint end goal in sight?

Commenter: In the short term, this limits the amount of products that are currently available. However, 4-5 years down the road, there will likely be products available.

Commenter: In the long term, the NOx regulations will ratchet down and to use high-efficiency water heaters that meet these standards, a 110 V outlet will be necessary.

Water Heater Blankets

Commenter: From a manufacturer perspective, I am not comfortable with installing blankets on water heaters. With new efficiency requirements, the benefits of blankets will be less since blankets have diminishing returns.

CASE Team: Are there any dangers to a blanket?

Multiple Commenters:

o Covering up air intake may prevent product from working.

o Issues with covering up labels.

o May affect earthquake straps.

Commenter: Depending on ambient conditions, blanket may raise water temperature because the pilot light continues to be on. This may engage the over-temperature (OT) limit.

Commenter: There may be instances where it isn't the right option, so you need to be cautious in making it mandatory.

memorandum - hmg

Documents