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 written comments addressing the 

refrigerator test procedure rulemaking NOPR. The discussion took place on on September 23, 

2010, in a phone conversation involving DOE’s contractor (Detlef Westphalen), Jennifer Cleary 

of AHAM, Bill Brown of General Electric, Richard Topping of Sub Zero-Wolf Incorporated, and 

Stephen Church of Whirlpool Corporation. The questions, submitted prior to the call via email, 

appear below, as well as notes representing the responses. 

Question A:

Section V.E.14 of the NOPR asked, “Defrost Precooling Energy: DOE invites comment on the 

proposals to include precooling energy in the procedures 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 possible use of partial recovery to reduce energy 

use of this part of the test.” 

On this issue, the AHAM response recommends a “holistic” 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 specific recommendations were intended. 

The procedure should address the whole defrost cycle. 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 compression, 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 DOE 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 test and does not have a section 5.2.1.6. The DOE 

proposal does include a section 5.2.14 labeled “Dual Compressor Systems . . .” and section 

5.2.1.6 labeled “ . . . Multiple Defrost Cycle Types”. For this reason, DOE would take the 

AHAM recommendation to mean that AHAM does not support the “Multiple Defrost Cycle 

Types” proposal. However, AHAM’s comments regarding Multiple Defrost Cycle Types (Issue 
15) on a later page are generally supportive of the multiple defrost cycle types proposal, with the 

caution that it “has a significant impact on measured energy use, . . .”. Which of these positions 

should DOE consider to be AHAM’s comment on this part of the NOPR? 

AHAM has provided comments specific to the proposed test procedure for multiple defrost 

cycle types. However, AHAM would prefer that DOE instead adopt the test procedure 

outlined in the AHAM comments for multiple compression systems. This approach would 

cover both single-compressor systems with multiple defrosts and dual- and multiplecompressor systems with multiple defrosts.