_U.S. Department af Energy 

Application for Interim Waiver and Petition for Waiver, 10CFR430, Subpart B, Appendix A1-

Uniform Test Method for Measuring the Energy Consumption of Refrigerator-freezers 

Submitted by: 

Earl F. Jones 

Senior Counsel 

GE Appliances 

Appliance Park 2-225 

Louisville, KY 40225 

earl.jones@ge.com 

502-452-3164 (voice) 

502-452-0395 (fax) 

Case No. 

Non-Confidential Version 
U.S. Department of Energy Application for Interim Waiver and Petition for Waiver, 

10CFR430, Subpart B, Appendix A1--Uniform Test Method 

for Measuring Refrigerator-Freezers 

I. Introduction 

GE Appliances, an operating division of General Electric Co., ("GE") is a leading 

manufacturer and marketer of household appliances, including, as relevant to this 

proceeding, refrigerators, files this Petition for Waiver and Application for Interim Waiver 

(collectively, "Petition"). GE requests that the Assistant Secretary grant it a waiver from 

certain parts of the test procedure promulgated by the U.S. Department of Energy ("DOE" 

or "the Department") for determining refrigerator-freezer energy consumption and allow 

GE to test its new refrigerator-freezer model pursuant to the modified procedure 

submitted herewith. This request is filed pursuant to 10 C.F.R. §430.27. 

The Department's regulations provide that the Assistant Secretary will grant a Petition 

upon "determin[ationl that the basic model for which the waiver was requested contains a 

design characteristic which either prevents testing of the basic model according to the 

prescribed test procedures, or 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." 10 C.F.R. §430.27(i). 

GE requests that the Assistant Secretary grant this Application for Interim Waiver 

(Application) and Petition for Waiver (Petition) on the grounds that the refrigerator energy 

test procedure, 10CFR430, Subpart B, Appendix A1, does not allow the energy used by GE's 

new refrigerator to be accurately calculated. 

II. Background 

GE has designed and plans to market a new refrigerator. The new models, which are 

listed in Attachment 1, are manufactured in Louisville, KY, will replace products that were 

previously manufactured in Mexico. They are part of GE's $1 billion investment in GE 

Appliances that will revitalize U.s. manufacturing and introduce new energy efficient and 

market-leading products. 

The new refrigerator has at least three compartments, the temperatures of which must be 

maintained at different levels. Temperature management is achieved by variable-speed 

fans and a system of dampers that change air flow based on information from 

temperature sensors placed in the various compartments. An electronic control drives 

the fans and dampers. The electronic controller also drives compressor operation and a 

unique three-way valve in the sealed system, which diverts refrigerant to the fresh-food 

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and freezer evaporators. GE has also installed separate heaters on the fresh-food and 

freezer evaporators. The compressor and tri-valve operations, combined with fan and 

damper operations and the separate defrost for fresh-food and freezer compartments, 

enable the new refrigerator to achieve significant improvements in temperature 

management. As a direct result of the frequent temperature adjustments, the compressor 

cycles on and off more frequently but in less regular cycles, i.e., it does not cycle in the 

uniform fashion envisioned by the test procedure. 

Hence, this Application and Petition. 

III. GE's Proposed Test Procedure 

In order to be assured that it is correctly calculating the energy consumption of the 

product, that it meets the minimum energy requirements for its product class and is 

properly labeled, GE seeks the Department's expeditious concurrence to its proposed 

amendment to the refrigerator test procedure to provide for testing of non-uniform 

compressor cycling models. 

The test procedure in 10 C.F.R. 430, Subpart S, Appendix A1 was developed in the era of 

electro-mechanical controls when the only refrigerator function--compressor on-off-was 

based on one input: the temperature of a mix of fresh-food and freezer air. The resulting 

compressor cycling was so uniform-and the test procedure assumed that to be the 

case-that regularity of cycles is not even relevant to calculating unit energy 

consumption. The test procedure identifies a period as typical or representative of the 

energy used by the product in normal operation. The energy measured during this period 

is then used to calculate total product energy per a formula provided in the rule. For 

cycling compressors, the relevant section of the test procedure is found at 4.2.1.1: 

Long-time Automatic Defrost. If the model being tested has a long-time automatic 

defrost system, the test time period may consist of two parts. A first part would be 

the same as the test for a unit having no defrost provisions (section 4.1.1). The 

second part would start when a defrost is initiated when the compressor "on" cycle 

is terminated prior to start of the defrost heater and terminates at the second turn 

"on" of the compressor or four hours from the initiation of the defrost heater, 

whichever comes first. See diagram in Figure 1 to this section. 

The 2014 test procedure, 10 C.F.R. 430, Subpart S, Appendix A at 4.1.2.1, similarly is 

predicated upon the existence refrigerator compressors operating with uniform cycles: 

[T]he second part starts at the termination of the last regular compressor "on" 

cycle. The average temperature of the compartment measured from the 

termination of the previous compressor "on" cycle to the termination of the last 

regular compressor "on" cycle must be within 0.5 OF (0.3 DC) of the average 

temperature of the compartment measured for the first part of the test. If any 

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compressor cycles occur prior to the defrost heater being energized that cause the 

average temperature in the compartment to deviate from the first part 

temperature by more than 0.5 OF (0.3 DCI. these compressor cycles are not 

considered regular compressor cycles and must be included in the second part of 

the test. As an example, a "precool" cycle, which is an extended compressor cycle 

that lowers the compartment temperature prior to energizing the defrost heater, 

must be included in the second part of the test. The test period for the second part 

of the test ends at the initiation of the first regular compressor cycle after the 

compartment temperatures have fully recovered to their stable conditions. The 

average temperature of the compartment measured from this initiation of the first 

regular compressor "on" cycle until the initiation of the next regular compressor 

"on" cycle must be within 0.5 OF (0.3 DC) of the average temperature of the 

compartment measured for the first part of the test. See Figure 1. 

The Figure 1 referred to in this section also makes clear that the compressor cycles are 

presumed to be uniform. 

GE's new refrigerator contains a separate fresh-food evaporator, which means that the 

models cannot be tested per the test procedure now in effect found at 10 C.F.R. 430, 

Subpart B, Appendix A1. Nor can GE use the 2014 test procedure found at 10 C.F.R. 430, 

Subpart B, Appendix A because it would compare the temperature of one cycle to the 

temperatures of the many cycles needed for Part 1, i.e. the compartment temperatures of 

non-uniform compressor cycling models do not attain the required .5° temperature 

differential from the average temperature "measured for the first part of the test." (See at 

4.2.1.1 l. 

GE's proposed test procedure would allow for the testing of models like the ones listed on 

Attachment 1 with separate evaporators for the fresh-food compartment that also have 

non-uniform compressor cycling operations. 

Approving this Application and Petition will not require a change in the energy 

calculation formula: 

D 

ET=(1440 xEPlITl)+ LJ(EP2; -(EPl xT2;1Tl)) x (1 2/C7;)] 

; = 1 

It would, however, define Part 2, or T2; in the above formula, as the series of cycles, further 

defined as Al-j Cycles and Bl-k Cycles, on either side of defrost that would be averaged to 

determine when the .so differential had been achieved. The full text of the proposed test 

procedure amendment to be found in a new section 4.1.2.3 is the following: 

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4. Test Period 

***** 

4.2.1.3 Non-uniform Cycling Compressor System. For a system with a cycling compressor, 

the second port of the test storts at the beginning of the "on" cycle of the series of regular 

compressor cycles, Cycle AI} in Figure 1 below. The overage temperature of all 

comportments measured during Cycles AI-j must be within 0.5 of (0.3 °Cl of their overage 

temperatures measured for the first port of the test. The test period for the second port of 

the test ends at the termination of the series of regular compressor cycles, Cycle BI_k2 in 

Figure 1 below, after the overage temperatures of all comportments are within OSF (0.3 

°Cl of their overage as measured in the first port of the test. 

As on example, if the overage temperatures for Port 1 of the test are 37.8 of and 0.2 of in 

the fresh food and freezer comportments, respectively, and the temperatures for the Cycle 

B series of Port 2 of the test, i.e., Cycles BI-k, are as follows, 

Fresh Food Freezer 

B1 42.1 of 4.3 of 

Bl-2 40.2 of 2.1°F 

Bl-3 38.0 of 0.0 of 

then the overage temperatures for the Cycle B series are 38.0 of and 0.0 of, which are 

within the 0.5 of (0.3 °Cl requirement. In this example, Port 2 ends after cycle B3. 

Subscripts l-j in Cycle A denote the number of cycles from 1 through infinity(???] to be averaged to 

obtain the temperatures of the fresh-food and freezer compartments before defrost. 

2 Subscripts l-k in Cycle B denote the number of cycles from 1 through infinity(???] to be averaged to 

obtain the temperatures of the fresh-food and freezer compartments after defrost. 

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Figure 3. 

Non-Uniform Cycling Waiver Proposal 

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IV. Conclusion 

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81 and Bt cycles 

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. 

For the obove reasons, GE respectfully requests that the Assistant Secretary gront the 

above Application for Interim Waiver and Petition for Waiver so that the Company can 

proceed to production of its new electronic-controlled refrigerator models listed on 

Attochment 1. We requests expedited treatment of the Petition ond Application and 

would be pleased to discuss these requests with DOE and provide further information as 

needed. 

We hereby certify that all manufacturers of domestically marketed units of the same 

product type have been notified by letter of this Petition and Application, a list of which is 

found in Attachment 2, hereto. 

Res pecgfJ.IlIy-sa'lrn'IiWe&,----.. 

Earl F. Jones, eni Counsel and 

Authorized Repre 

of GE Appliances 

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ATTACHMENT 1 

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