SAMSUNG ELECTRONICS AMERICA, INC 

Samsung QA Lab 

19 Chapin Road Building 0 

Pine Brook, NJ 07058 

Tel 973-808-6360 

Fax: 973-808-6361 

February 5, 2013 

Dr. David Danielson 

Energy Effic iency and Renewable Energy 

Department of Energy 

1000 Independence Avenue, SW. 

Washington, DC 20585 

Dear Assistant Secreta ry Danielson: 

Samsung Electronics America, Inc. ("Samsung") respectfull y submits this Application 

for Interim Waiver and Petition for Waiver to the Department of Energy ("DOE" or " the 

Department") for Samsung's compressor refri gerator-freezers with multipl e defrost cycles. 

Reasoning 

10 CFR Part 430.27(a)(I) allows a person to submit a petition to waive fo r a particular 

basic model any requirements of §430.23 upon the grounds that the basic model contains one or 

more design characteristics whi ch either prevent testing of the basic model according to the 

prescribed test procedures, or the prescribed test procedures may evaluate the basic model in a 

manner so unrepresentative of its true energy consumption characteristics as to provide 

materiall y inaccurate comparative data. 

Current test procedures as prescribed in Appendix A 1 to Subpart B of Part 430 

("Appendix A I ") do not adeq uate ly provide a way for Samsung to accurately represent the 

energy consumption of its refri gerator-freezers with multiple defrost cycles. DO E concurred with 

Samsung's understanding in the interim waiver granted to Samsung in 76 FR 167601 and 

subsequently granted the waiver on January 10,2012 (77 FR 1474). Add itionall y, DOE 

communi cated that all man ufacturers planning on marketing refrigerator-freezers with multipl e 

defrost cyc les must seek a waiver from the Department.2 

For the reasons that DOE described in its granting of waiver (77 FR 1474) fo r Samsung 

refri gerator freezers with multiple defrost cycles, Samsung believes that the granting of Interim 

Waiver and Waiver for the models listed below are warranted. 

1 DOE undcrstan ds, howevcr, that abscnt an interim waiver. Samsung's products would not be accuratcly testcd and ratcd for 

encrgy consumption bccausc th c currcnt encrgy test procedurc does not include test procedures for products with multiple defrost 

cyclc typcs. 

2 Untilthcsc amcndmcnts arc rcquired in conjunction with the 20 14 standards, manufacturers introducing products equipped with 

multiple defrost cycle types should, consistent with 10 CFR 430.27, petition for a waiver since the modificd vcrsion of I\ppendix 

1\ I set out in today' s notice will not include a specifiecimethoci for capturing this energy usage. 
Request 

Samsung requests that the alternate test procedure for refrigerators with mUltiple defrost 

cycles, as prescribed in the waiver (77 FR 1474) and in the interim waiver (77 FR 13109) 

granted to Samsung, be granted for the following basic Samsung refri gerator-freezers with 

multiple defrost cycles models: 

RS27FD***** 

Please fee l free to contact me if you have any questions regarding this Petition fo r Waiver 

and Application for Interim Waiver. I will be happy to discuss should any questions arise. 

Sincerely, 

Michael Moss 

Director of Corporate Environmental Affairs