_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 VersionU.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 ofthe 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 ofthe 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 ofdampers that change airflow 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
2and 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 offresh-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 ofthe 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" ofthe 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 term ination of the previous compressor "on " cycle to the termination ofthe last regular compressor "on" cycle must be within 0
.5 OF (0

.3 DC) of the average temperature ofthe compartment measured for the first part ofthe test. If any 3compressor 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 ofthe test. The test period for the second part ofthe 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 ofthe compartment measured from this initiation ofthe first regular compressor "on" cycle until the initiation ofthe next regular compressor "on" cycle must be within 0
.5 OF (0

.3 DC) ofthe average temperature ofthe compartment measured for the first part ofthe 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 ofthe 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 ofthe 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=(1440xE PlITl)+ LJ(EP2; -(E Pl xT 2;1 Tl)) 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:

44. Test Period 

### ***** 4.2.1.3 Non-uniform Cycling Compressor System. For a system with a cycling compressor, the second port ofthe test storts at the beginning ofthe "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 oftheir overage temperatures measured for the first port of the test. The test period for the second port of the test ends at the termination ofthe series of regular compressor cycles, Cycle BI_k2in Figure 1 below, after the overage temperatures of all comportments are within OSF (0.3 °Cl oftheir overage as measured in the first port ofthe test. As on example, ifthe 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 ofthe 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 ofcycles from 1 through infinity(???] to be averaged to obtain the temperatures ofthe fresh-food and freezer compartments before defrost. 2 Subscripts l-k in Cycle Bdenote the number of cycles from 1through infinity(???] to be averaged to obtain the temperatures ofthe fresh-food and freezer compartments after defrost. 5Figure 3. 

## Non-Uniform Cycling Wa iver Proposal

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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 ofwhich is found in Attachment 2, hereto
. 

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

Earl F
. Jones, eni C ounsel and Authorized Repre of GE Appliances 6ATTACHMENT 1 

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