January 7, 2013

The Honorable David Danielson Assistant Secretary, Energy Effi ciency and Renewable Energy United States Department of Energy

Mail Station EE-1 Forrestal Building 1000 Independence Avenue, SW Washington, DC 20585

Dear Assistant Secretary Danielson:

Samsung Electronics America, Inc. (“Samsung”) respectfully submits the Application for Petition for Waiver and Application for Interim Waiver to the Department of Energy (“DOE” or “the Department”) regards to Samsung’s reside ntial refrigerator-freezer s that use shared dual

compressors.

Reasoning

10 CFR Part 430.27(a)(1) allows a person to su bmit a petition to waive for a particular basic model any requirements of §430.23 when (1) th e basic model contains one or more design characteristics which either prevent testing of the basic model according to the prescribed test procedures, or (2) the prescribed test procedures may evaluate the basic model in a manner so unrepresentative of its true en ergy consumption characteristic s as to provide materially inaccurate comparative data.

Current test procedures as pr escribed in Appendix A1 to Subpart B of 10 Part 430 do not adequately provide a way for Samsung to accurate ly represent the energy consumption of its refrigerator-freezers that use shared dual compre ssors. Meanwhile, based on similar situations, DOE has already granted a waiver to Sub-Zero in 77 FR 5784 on February 6, 2012, and similarly, an interim waiver to LG in 77 FR 44603 on July 30, 2012.

However, unlike Subzero’s design which feat ures two compressors, two evaporators, and two defrost heaters, Samsung’s de sign features two compressors , four evaporators, and three

defrost heaters.Samsung’s design features four compartments that have their own evaporators. Three compartments, freezer/convertible/f resh food compartment, are accessible with an exterior door and the fourth ice room compartment is a sub co mpartment and located inside of the fresh food compartment. Defrost heaters are adopted at th ree evaporators (freezer/convertible/ice room) except the fresh food compartment evaporator and t hose heaters operate all together at the same time according to the control logic. So essentiall y, there is only one defrost type. Despite these differences of the composition, Samsung believes that the test procedure, as prescribed in the waiver granted to Subzero and in the interim wa iver granted to LG, is equally applicable and appropriate.

More specifically, Samsung’s residential refrigerator-fre ezers that use shared dual compressors can be tested and calculate to a reas onable result with same test procedure granted to Subzero’s waiver because the test procedur e of Subzero’s waiver adopt a multiple defrost system of 1, 2 or more compartment with distin ct defrost system and Samsung’s dual units have one defrost system despite of having four compar tments and three defrost heaters as explained

above.

Therefore, Samsung respectfully requests a waiv er and an interim waiv er for the alternate test procedure that DOE has alr eady granted Sub-Zero and LG pe rtaining to the refrigeratorfreezers that use shared dual compressors, w ith minor modification suggested below:

Before : 5.2.1.4 Dual Compressor Systems with dual Automatic 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 A1 with the following:

5.2.1.4 Dual Compressor Systems with Automatic Defrost. The two-part test method in section 4.2.1 must be used, a nd the energy consumption in kilowatt-hours per day shall be calculated equivalent to:

Where:

 1440 = number of minutes in a day

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

 i is the variable that can equal to 1, 2 or more that identifies the compartment with distinct defrost system;

 D is the total number of compartments with distinct defrost systems;

 EP1 is the dual compressor energy expended dur ing the first part of the test (it is calculated for a whole number of freezer compressor cycles at least 24 hours in durationand may be the summation of several running periods that do not include any precool, defrost, or recovery periods);

 T1 is the length of time for EP1 (minutes);

 EP2i is the total energy consumed during th e second (defrost) part of the test being conducted for compartment i. (kWh);

 T2i 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 defros t system is calculated as per 10 CFR part 430 subpart B appendix A1 clause 5.2.1.2. CTi fo r compartment i with variable defrost system is calculated as per 10 CFR part 430 subpart B appendix A1 clause 5.2.1.3. (hours rounded to the nearest tenth of an hour).

Stabilization:

The test shall start after a minimum 24 hours stabilization run for each temperature control setting. Steady State for EP1: The temperature average for the first and last compressor cycle of the test period must be within 1.0°F (0.6°C) of the test period temper ature 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 segm ents are used for test period 1, each segment must comply with above requirement. Steady State for EP2i: The second (defrost) part of the test mu st be preceded and followed by regular compressor cycles. The temperature average for th e first and last compressor cycle of the test period must be within 1.0°F (0.6°C) of the EP1 test period temperature average for each
compartment. Test Period for EP2i, T2i: EP2i includes precool, defrost, and recovery time for compartment i, as well as sufficient dual compressor steady state run cycles to allow T2 i to be at least 24 hours. The test period shall start at the end of a regular freezer compressor on-cycle after the previous defrost occurrence (refrigerator or freezer). The test period also in cludes the target defrost and following regular freezer compressor cycles, ending at the end of a regular freezer compressor oncycle before the next defrost occurrence (refrige rator or freezer). If the previous condition does not meet 24 hours time, additional EP1 steady state segment data could be included. Steady state run cycle data can

be utilized in EP1 and EP2i. Test Measurement Frequency Measurements shall be taken at regu lar interval not exceeding 1 minute.

For the reasons that DOE described in its gr anting of waiver and interim waiver for SubZero and LG for refrigerator-freezers with sh ared dual compressors, Samsung believes that the expeditious granting of Waiver and Interim Waiver for the model listed below is warranted:



### RF32FM*****Please feel free to contact me if you have a ny questions regarding this Application for Petition for Waiver and Application for Interi m Waiver. I will be happy to discuss should any questions arise.

Sincerely,

Michael Moss

Director of Corporate Environmental Affairs