SAMSUNG ELECTRONICS AMERICA, INC 

Samsung QA Lab 

19 Chapin Road Building D 

Pine Brook, NJ 07058 

Tei 973-808-6360 

Fax: 973-808-6361 

January 7, 201 3 

The Honorabl e David Dani elson 

Assistant Secretary, Energy Effi ciency and Renewable Energy 

United States Department of Energy 

Mail Station EE-l 

Forrestal Building 

1000 Independence Avenue, SW 

Washington, DC 20585 

Dear Assistant Secretary Dani elson: 

Samsung Electroni cs America, Inc. ("Samsung") respec full y submits the Applicati on fo r 

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

" the Department") regards to Samsung's residential refri gerator-freezers that use shared dual 

compressors. 

Reasoning 

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

basic model any requirements of §430.23 when ( I) the basic m Idel contains one or more design 

characteristi cs whi ch either prevent testing of the basic model according to the prescribed test 

procedures, or (2) the prescribed test procedures may evaluate t?e basic model in a manner so 

unrepresentati ve of its true energy consumption characteristics as to provide materi all y 

inaccurate comparati ve data. 

Current test procedures as prescribed in Appendi x A 1 to Subpart B of 10 Part 430 do ot 

adequately provide a way for Samsung to accurately represent ~e energy consumption of its 

refri gerator-freezers that use shared dual compressors. Meanwhile, based on similar itu ti ~, 

DOE has already granted a waiver to Sub-Zero in 77 FR 5784 0 February 6, 201 2, and similarl y, 

an interim waiver to LG in 77 FR 44603 on Jul y 30, 201 2. 

However, unlike Subzero's design which features two compressors, two evaporators, and 

two defrost heaters, Samsung's design features two compressors, four evaporators, and three 

defrost heaters. 
Samsung's design features four compartments that have their own evaporators. Three 

compartments, freezer/convertible/fresh food compartment, are accessible with an exterior d or 

and the fourth ice room compartment is a sub compartment and located inside of the fresh fO<i>d 

compartment. Defrost heaters are adopted at three evaporators freezer/convertible/ice room) 

except the fresh food compartment evaporator and those heater operate all together at the sa le 

time according to the control logic. So essentially, there is only one defrost type. Despite the e 

diffe rences of the composition, Samsung believes that the test rocedure, as prescribed in thel 

waiver granted to Subzero and in the interim waiver granted to G, is equally applicable and 

appropriate. 

More specifically, Samsung's residential efri gerator-fr~eze s that use shared dual I 

compressors can be tested and calculate to a reasonable result ith same test proced ure granted 

to Subzero's waiver because the test procedure of Subzero's waiver adopt a multiple defrost 

system of 1,2 or more compartment with distinct defrost syste and Samsung's dual units have 

one defrost system despite of having four compartments and three defrost heaters as explaine8 

above. 

Therefore, Samsung respectfull y requests a waiver and an interim waiver for the alternate 

test procedure that DOE has already granted Sub-Zero and LG pertaining to the refrigeratorfreezers that use shared dual compressors, with minor modification suggested below: 

Before: 5.2.1.4 Dual Compressor Systems with dual Automati c Defrost 

With Minor Change: 5.2.1.4 Dual Compressor Systems with Automatic Defrost (i=1 is 

mono, i=2 is dual) 

Alternate Test Procedure 

Replace the multiple defrost system section 5.2.1.4 of Appendix A I with the fo llowil g: 

5.2. 1.4 Dual Compressor Systems with Automatic Defr st. The two-part test method· n 

section 4.2.1 must be used, and the energy consumption in kilowatt-hours per day shall be 

calcul ated equivalent to: 

D 

ET = (1440 X EPIITl) + L [(EP2 j - (EPI 

1= 1 

Where: 

• 1440 = number of minutes in a day 

• ET is the test cycle energy (kWh/day); 

T2/TI)) X (I2/ClrDJ 

• i is the variable that can equal to 1, 2 or more that ident fies the compartment with 

distinct defrost system; 

• D is the total number of compartments with distinct de ost systems; 

• EP 1 is the dual compressor energy expended during the first part ofthe test (it is 

calculated for a whole number of freezer compressor c cles at least 24 hours in duration 
• 

• 

• 

• 

and may be the summation of several running periods that do not include any precool, 

defro st, or recovery periods); 

Tl is the length of time for EPl (minutes); 

EP2i is the total energy consumed during the second (ddfro st) part of the test being 

conducted for compartment i. (kWh); 

T2 i is the length of time (minutes) for the second (defrost) part of the test being 

conducted for compartment i. 

CTi is the compressor on time between defrosts for only compartment i. CTi for 

compartment i with long time automatic defrost system js calculated as per 10 CFR part 

430 subpart B appendix Al clause 5.2. 1.2. CTi for compartment i with vari abl e defrost 

system is calcul ated as per 10 CFR part 430 subpart B appendix Al clause 5.2. 1.3. (h I urs 

rounded to the nearest tenth of an hour). 

Stabili zation: 

The test shall start after a minimum 24 hours stabilization run for each temperature 

control setting. 

Steady State fo r EP 1: 

The temperature average for the first and last compress r cycle of the test peri od must be 

within I.O°F (0.6°C) of the test period temperature average for each compartment. Make this 

determination for the fresh food compartment for the fresh food compressor cycles closest to the 

start and end of the test period. If multiple segments are used for test period 1, each segment 

must comply with above requirement. 

Steady State for EP2i: 

The second (defrost) part of the test must be preceded and fo llowed by regular 

compressor cyc les. The temperature average for the first and last compressor cycle of the test 

peri od must be within l.Oop (0.6°C) of the EP I test period temperature average for each 

compartment. 

Test Period fo r EP2i, T2i: 

EP2i includes precool, defrost, and recovery time for co partment i, as we ll as suffi cient 

dual compressor steady state run cycles to allow T2i to be at Ie st 24 hours. The test period s all 

start at the end of a regular freezer compressor on-cycle after ~ previous defrost occurrence 

(refri gerator or freezer). The test period also includes the target defrost and following regul ar 

freezer compressor cycles, ending at the end of a regular freezer compressor oncycle before the 

next defrost occurrence (refri gerator or freezer). If the previous condition does not meet 24 hhurs 

time, additional EP I steady state segment data could be included. Steady state run cycle data can 

be utili zed in EP I and EP2i. 

Test Measurement Frequency 

Measurements shall be taken at regular interval not exc eding 1 minute. 

For the reasons that DOE described in its granting of waiver and interim waiver for SubZero and LG for refri gerato r-freezers with shared dual compressors, Samsung beli eves that tl1e 

expeditious granting of Waiver and Interim Waiver for the model listed below is warranted: 

RF32FS***** 
Please feel free to contact me if you have any questions regarding this Application fo '. 

Petition for Waiver and Application for Interim Waiver. r will I e happy to discuss should any 

questions arise. I 

Sincerely, 

~ 

. I 

Michael t10ss 

I 

Director 0 Corporate Environmental Affairs