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Federal Register / Vol. 86, No. 96 / Thursday, May 20, 2021 / Proposed Rules 2018 version in turn references Table 6
of the ASME standard, which provides the required test pressures. Section 8.6.4
of ASME A112.19.22008 and the 2018
version also provides performance specifications that are not relevant for the purpose of meeting DOE water use standards in 10 CFR 430.32r.
Accordingly, DOE proposes to reference Table 6 directly for the purpose of specifying the required test pressures.
DOE requests comment on replacing the static pressure requirements in Appendix T section 3.b from section 8.6.4 of ASME A112.19.22008 with Table 6 of ASME A112.19.22018.
F. Additional Directions Regarding Recorded & Calculated Values Appendix T provides direction regarding the resolution of the recorded values; rounding of recorded and calculated values; and test set-up as it relates to manufacturer installation instructions. In the August 2019 RFI, DOE requested comment on whether these directions are necessary to ensure that the test procedures are reasonably designed to measure the water use of water closets and urinals during a representative average use cycle or period of use. 84 FR 37973.
In response, PMI suggested, without elaboration, that DOE should remove the additional directions beyond the ASME standard in Appendix T as they are no longer necessary. PMI, No. 3 at p. 3 NRDC and ASAP commented that the additional directions to the version currently incorporated by reference in Appendix T, ASME A112.19.22008, are necessary because the industry standard has several weaknesses that subsequent revisions of the voluntary industry standard have failed to remedy.
NRDC and ASAP, No. 5 at p. 1
Having considered these comments, DOE is not proposing to eliminate the additional directions in Appendix T. As noted, PMI did not provide any explanation as to why the additional directions are no longer necessary, and did not indicate that these additional instructions are the cause of any burden to manufacturers. As discussed, the additional directions include consistent resolution of the recorded values;
rounding of calculated values; and test set-up as it relates to manufacturer installation instructions, which are not specified in ASME A112.19.22018, but are needed for compliance purposes.
Section 2 of Appendix T specifies that any measurements shall be recorded at the resolution of the test apparatus, and calculations of water consumption i.e., flush volume are consistently rounded to the same number of significant digits as the previous step. While sections
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7.3.2 and 8.6.1 of ASME A112.19.2
2018 specify the resolutions of the test apparatus to be used, sections 7.3.3 and 8.6.2 of ASME A112.19.22018 do not specify the resolution of recorded measurements. Instead, sections 7.3.3
and 8.6.2 of ASME A112.19.22018
specify only how the total calculated flush volume must be rounded, which is consistent with the resolution of the test apparatus. Accordingly, section 2 of Appendix T provides further detail for resolution and rounding requirements, which is consistent with ASME
A112.19.22018.
Section 3.a.iii. of Appendix T
provides further specifications on water level and trim setting for cases in which the manufacturer has provided no instructions regarding such settings.
Otherwise, the same section requires that flush volume and tank trim component adjustments shall be set in accordance with the printed instructions supplied by the manufacturer, consistent with section 7.1.2 of ASME A112.19.22018. In the October 2013 final rule, DOE concluded that the specifications in ASME
A112.19.22008 may not be adequate to ensure that manufacturers test gravity tank water closets at the maximum flush volume. 78 FR 62977. Specifically, DOE
concluded that while section 7.1.2 of ASME A112.19.22008 specifies adjustments made to the tank water level and fill time, it does not specify adjustments made to other trim components such as but not limited to the flapper valve, fill valve and tank water level, which could be adjusted to increase flush volume. Id. Accordingly, for those products that do not include printed installation instructions, Appendix T specifies setting these trim components to the maximum water use setting so that the maximum flush volume is produced without causing the water closet to malfunction or leak. The latest version of the ASME standard, ASME A112.19.22018, does not provide any further specifications on adjusting the trim components in cases where the manufacturer has provided no instructions regarding these components. Therefore, the additional specifications provided by Appendix T
are still warranted for testing products without printed instructions supplied by the manufacturer. For these reasons, DOE is proposing that the current additional directions provided in Appendix T be maintained.
NRDC and ASAP also suggested adding other directions to increase the precision of the measurement and rounding requirements for measuring flush volume from the 0.07 gallons specified in ASME 112.19.22008 and
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112.19.22018 to 0.01 gallons.15 NRDC
and ASAP, No. 5 at p. 2 NRDC and ASAP, No. 5 at p. 2 They asserted that Appendix T results in measurements that are not representative of water consumption during a representative average usage cycle or period of use. Id.
NRDC and ASAP stated that the current measurement and rounding requirements allow for models that use up to 0.07 gallons per flush gpf in excess of the DOE standard to be certified as meeting the standard. Id.
NRDC and ASAP commented that at the current DOE standard of 1.6 gpf for water closets, Appendix T allows for a model with an exceedance of up to 4.4% to be certified and, at the current DOE standard of 1.0 gpf for urinals, Appendix T allows for an exceedance of up to 7% to be certified. Id. While NRDC and ASAP noted that DOE
requirements at 10 CFR 429.30b and 10 CFR 429.31b require certification reports for water closets and urinals to include the maximum water use in gallons per flush rounded to the nearest 0.01 gallon, they stated that the current ASME test procedure incorporated by reference is not adequate to achieve the precision required by the current certification requirements for water closets. Id. Accordingly, NRDC and ASAP recommended that DOE add directions for testing water closet and urinal water consumption to require test equipment resolution of 0.01 gallon and rounding to the nearest 0.01 gallon. Id.
In the context of rounding resolution, ASME A112.19.22018 provides resolution requirements that are incorporated by reference in Appendix T. The rounding resolution for flush volume is derived from the resolution specification in ASME A112.19.22018
for the apparatus used to measure flush volume. ASME A112.19.22018
specifies that the receiving vessel, load cell, or other apparatus used to measure flush volume be capable of measuring volumes to within 0.25 L 0.07 gal. See sections 7.3.2 and 8.6.1 of ASME
A112.19.22018 for water closets and 15 ASME A112.19.22008, section 7.4.2
Apparatus, which is the version currently incorporated by reference, specifies that the apparatus for measuring flush volumes of water closets must be capable of reading increments not exceeding 0.25 liters 0.07 gallons. Section 7.4.3
Procedure, which is incorporated by reference, specifies that the results of each test run are to be rounded down to the nearest 0.25 L 0.07 gal. The requirements are applicable to urinals in section 8.6.1 Apparatus and 8.6.2 Procedure. The same requirements are also found in the latest version of the ASME standard, ASME A112.19.2
2018. Appendix T requires recording measurements at the resolution of the test instrumentation and rounding calculations of water consumption for each tested unit to that same number of significant digits. Section 2a and b of Appendix T.

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