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Federal Register / Vol. 86, No. 110 / Thursday, June 10, 2021 / Proposed Rules
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proprietary technology that represents a unique pathway to achieving a given efficiency level, that technology will not be considered further.
10 CFR part 430, subpart C, appendix A, sections 6c3 and 7b. In summary, if DOE determines that a technology, or a combination of technologies, fails to meet one or more of the listed five criteria, it will be excluded from further consideration in the engineering analysis.
a. Screened-Out Technologies In response to the August 2019 RFI, DOE received several comments related to the suggested technology options.
A.O. Smith stated that the technologies used to increase the efficiency of UFHWSTs are limited to changes in installation thickness, location, and materials. A.O. Smith, No. 8 at p. 2
BWC stated that many of the technologies listed would be very difficult to apply to UFHWSTs due to the wide variety of tank sizes, configurations, and fittings.
Additionally, BWC stated that the majority of the technologies identified would present significant manufacturability issues due to the variability of tank configurations and fittings, and that increasing insulation thickness and/or changing to another insulating solutions could present issues with fittings that would not occur otherwise. BWC also asserted that the technology options listed could increase the fragility of tanks, which could cause difficulties in moving the tanks to their final installation location. BWC, No. 5
at p. 2 As discussed in section IV.A of this document, DOE also conducted interviews with manufacturers. During these interviews, which were conducted under NDAs, manufacturers made statements similar to those comments submitted by BWC in response to the August 2019 RFI.
In response to these comments, DOE
acknowledges that requiring use of advanced insulation types such as vacuum panels or aerogels could necessitate an extremely difficult change to the UFHWST manufacturing process due to the rigid nature of these materials and the high degree of customization and ports on UFHWSTs.
Applying these materials closely around ports and configuring them to all tank shapes and setups e.g., number of ports, port locations may not be possible where tight curvatures would be required and/or due to the high level of customization of UFHWSTs.
Additionally, DOE is not aware of equipment on the market that incorporate aerogels, vacuum panels, or inert gas-filled panels at the time of this
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analysis. Therefore, in the analysis for this NOPD, DOE did not consider any advanced insulation types as a technology option to increase the insulation R-value for UFHWSTs.
To explain what technologies are commonly used, BWC stated that most manufacturers use polyurethane foam to achieve the minimum R12.5
requirement, although high density fiberglass may be applied in certain areas where it is difficult to apply foam.
BWC, No. 5 at p. 2 Relatedly, A.O.
Smith stated that certain technology options proposed by DOE, such as insulation on tank bottoms, would be impractical to implement because bottom mounted drain connections must be kept accessible. A.O. Smith, No. 8 at p. 2 AHRI commented that technologies such as pipe insulation cannot be pre-configured by the manufacturer for installation in the field. AHRI, No. 6 at p. 2
As suggested by BWC, and supported by DOEs review of publicly-available manufacturer information, polyurethane foam is the most commonly used type of insulation for meeting the minimum insulation requirement, but fiberglass and/or Styrofoam are often used in specific regions e.g. tank tops or bottoms, or regions around ports where doing so could limit access to ports or be impractical to manufacture. For its analyses, DOE has estimated energy losses based on tanks being covered primarily with polyurethane foam, but the agency has also included several regions with alternative insulation materials. Therefore, DOE included a minimum amount of insulation around pipes and fittings in its analysis of baseline equipment, but it did not consider requiring different insulation materials in these regions. Likewise, DOE did not consider additional insulation coverage around pipes and fittings as a technology option for the analysis.
b. Remaining Technologies Ultimately, after reviewing all of the proposed technologies, DOE did not screen out improved insulation R-value due to increased polyurethane foam thickness, so the Department included this as a design option in the engineering analysis. DOE determined that this technology option is technologically feasible because it only involves an increase in thickness of the same insulation material that is currently commonly used on UFHWSTs, and can be achieved with the same processes that are currently being used in commercially-available equipment or working prototypes e.g., fabricating jackets or foaming.

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B. Engineering Analysis The purpose of the engineering analysis is to establish the relationship between the efficiency and cost of UFHWSTs at different levels of reduced heat loss efficiency levels.6 This relationship serves as the basis for the cost-benefit calculations for commercial consumers, manufacturers, and the Nation. There are typically two elements to consider in the engineering analysis; the selection of efficiency levels to analyze i.e., the efficiency analysis and the determination of equipment cost at each efficiency level i.e., the cost analysis. In determining the performance of higher-efficiency equipment, DOE considers technologies and design option combinations not eliminated by the screening analysis.
DOE then typically estimates the manufacturing production cost MPC at the baseline and the change in MPC
associated with reducing the heat loss of equipment above the baseline, up to the max-tech efficiency level for each equipment class. The typical output of the engineering analysis is a set of costefficiency curves that are used in downstream analyses i.e., the LCC and PBP analyses and the NIA. However, for the reasons discussed in IV.B.3 of this document, the cost analysis was not performed for this NOPD.
1. Efficiency Levels for Analysis DOE typically uses one of two approaches to develop energy efficiency levels for the engineering analysis: 1
Relying on observed efficiency levels in the market i.e., the efficiency-level approach, or 2 determining the incremental efficiency improvements associated with incorporating specific design options to a baseline model i.e., the design-option approach. Using the efficiency-level approach, the efficiency levels established for the analysis are determined based on the market distribution of existing equipment in other words, based on the range of efficiencies and efficiency level clusters that already exist on the market, without regard to the specific design options used to achieve those levels. Using the design-option approach, the efficiency levels established for the analysis are determined through detailed engineering calculations and/or computer simulations of the efficiency improvements resulting from implementation of specific design 6 While the UFHWSTs standard addresses heat loss through establishing a minimum level of insulation, for the purpose of this analysis, the levels of improvement are referred to generally as efficiency levels.

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