January 7, 2013 

The Honorable David Danielson 

Assistant Secretary, Energy Efficiency 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 residential refrigerator-freezers that use shared dual 

compressors. 

Reasoning 

10 CFR Part 430.27(a)(1) allows a person to submit a petition to waive for a particular 

basic model any requirements of §430.23 when (1) the 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 energy consumption characteristics as to provide materially 

inaccurate comparative data. 

Current test procedures as prescribed in Appendix A1 to Subpart B of 10 Part 430 do not 

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

refrigerator-freezers that use shared dual compressors. 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 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 door 

and the fourth ice room compartment is a sub compartment and located inside of the fresh food 

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

except the fresh food compartment evaporator and those heaters operate all together at the same 

time according to the control logic. So essentially, 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 waiver granted to LG, is equally applicable and 

appropriate. 

More specifically, Samsung’s residential refrigerator-freezers that use shared dual 

compressors can be tested and calculate to a reasonable result with same test procedure 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 system and Samsung’s dual units have 

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

above. 

Therefore, Samsung respectfully 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 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, and 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 during the first part of the test (it is 

calculated for a whole number of freezer compressor cycles at least 24 hours in duration 
and 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 the 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 defrost system is calculated as per 10 CFR part 

430 subpart B appendix A1 clause 5.2.1.2. CTi for 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 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 followed by regular 

compressor cycles. 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 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 T2i 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 includes the target defrost and following regular 

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

next defrost occurrence (refrigerator 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 regular interval not exceeding 1 minute. 

For the reasons that DOE described in its granting of waiver and interim waiver for SubZero and LG for refrigerator-freezers with shared 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 any questions regarding this Application for 

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

questions arise. 

Sincerely, 

 

Michael Moss 

Director of Corporate Environmental Affairs