DEPARTMENT OF ENERGY

10 CFR Part 430

Docket No. EERE-2009-BT-TP-0003

RIN: 1904-AB92 Energy Conservation Program for Consumer Products: Test Procedures for Refrigerators, Refrigerator-Freezers, and Freezers

Clarification of Written Comments Submitted by The Association of Home Appliance Manufacturers (AHAM) September 28, 2010

This memorandum documents a discussion to clarify w ritten comments addressing the refrigerator test procedure rulemaking NOPR. The di scussion took place on on September 23, 2010, in a phone conversation involving DOE’s contr actor (Detlef Westphalen), Jennifer Cleary of AHAM, Bill Brown of General Electric, Richard To pping of Sub Zero-Wolf Incorporated, and Stephen Church of Whirlpool Corporation. The questi ons, submitted prior to the call via email, appear below, as well as notes representing the res ponses.

Question A: Section V.E.14 of the NOPR asked, “Defrost Precooli ng Energy: DOE invites comment on the proposals to include precooling energy in the proce dures for testing products with long-time or

variable defrost controls. DOE also invites comment regarding whether additional test procedure amendments are appropriate in order to address poss ible use of partial recovery to reduce energy use of this part of the test.” On this issue, the AHAM response recommends a “holi stic” approach. At this point, DOE takes this to mean that the test procedure should address the whole defrost cycle. Please let us know if this interpretation is correct, or if other specifi c recommendations were intended.

The procedure should address the whole defrost cycl e. The measurement for the defrost part of the test should start in a period of stead state operation and end in a period of stead state operation, capturing all parts of the defrost cycle , including precooling, defrost, and recovery. However, this does represent a change in the energy use measurement as compared to the current test procedure.

Question B: In the section on dual and multiple system compress ion, AHAM stated, “AHAM proposes simplifying the dual/multiple compression equations by removing the dual compression equation in Appendix A1, 5.2.1.4, and instead covering dual compression in the multiple system compression equation in 5.2.1.6. AHAM also urges DO E to modify the multiple system compression equation in 5.2.1.6 as follows, where: . . . ”. The current Appendix A1 has a section 5.2.1.4 covering the optional third part of the tes t and does not have a section 5.2.1.6. The DOE proposal does include a section 5.2.14 labeled “Dua l Compressor Systems . . .” and section 5.2.1.6 labeled “ . . . Multiple Defrost Cycle Type s”. For this reason, DOE would take the AHAM recommendation to mean that AHAM does not supp ort the “Multiple Defrost Cycle Types” proposal. However, AHAM’s comments regardin g Multiple Defrost Cycle Types (Issue15) on a later page are generally supportive of the multiple defrost cycle types proposal, with the

caution that it “has a significant impact on measur ed energy use, . . .”. Which of these positions should DOE consider to be AHAM’s comment on this pa rt of the NOPR?

AHAM has provided comments specific to the proposed test procedure for multiple defrost cycle types. However, AHAM would prefer that DOE i nstead adopt the test procedure outlined in the AHAM comments for multiple compress ion systems. This approach would cover both single-compressor systems with multiple defrosts and dual- and multiplecompressor systems with multiple defrosts.