DEPARTMENT OF ENERGY

10 CFR Part 430

Docket No. EERE-2009-BT-TP-0003

RIN: 1904-AB92 Energy Conservation Program for Consumer Products: Test Procedures for Refrigerators, Refrigerator-Freezers, and Freezers

Clarification of Written Comments Submitted by Whir lpool Corporation September 28, 2010

This memorandum documents a discussion to clarify w ritten comments addressing the refrigerator test procedure rulemaking NOPR. The di scussion took place on on September 23, 2010, in a phone conversation involving DOE’s contr actor (Detlef Westphalen) and Stephen Church of Whirlpool Corporation. The questions, sub mitted prior to the call via email, appear below, as well as notes representing the responses.

Question A: Section V.E.2 of the NOPR asked, “Measured Energy I mpacts of Amendments Proposed To

Take Effect Prior to the Effective Date of the New Energy Conservation Standards: DOE invites comment on whether any of the amendments proposed t o take effect prior to the effective date of the new energy conservations standards (scheduled p er EPCA to be January 1, 2014), have a significant impact on measured energy use. DOE requ ests information quantifying these impacts, if any.” For this question, Whirlpool listed proposed amendm ents that have an “a significant impact on: measured energy use, manufacturer cost, testing cap ability and/or leadtime.” These included a) #1, Revised refrigerator definition; b) #7, Testing of convertible and special compartme nts c) #11, Variable anti-sweat heater energy consumpti on d) #14, Long time or variable defrost e) #15, Multiple defrost cycle types f) #19, Presence/absence of ice in bin g) #20, Product not reaching standardized temperatu res Can you clarify for which of the listed amendments there is an impact on measured energy use?

All of the listed test procedure modifications woul d affect measured energy use.

The revised refrigerator definition, by not allowin g the compartment temperature to go above

39  ̊ F, would result in added thermal load when tested f or a 45  ̊ F standardized temperature, thus increasing energy use.

Adding ice to the ice bin would impact measured ene rgy use—as discussed in the meeting, due to the added thermal capacity.

And not allowing a measurement for products that do n’t meet standardized temperatures certainly would change the measurement for any prod uct for which this occurs.Question B:

Section V.E.7 of the NOPR asked, “Convertible Tempe rature Compartments and Special Compartments: DOE invites comment on the proposed c larifications of test procedures for treatment of convertible-temperature compartments a nd the proposed amendments to the test procedures for special compartments. DOE also reque sts comment on whether a size limit should be established for classification of a special comp artment, and what a reasonable size limit might

be.” For this question, the comment response starts, “We concur that such special compartments should be tested at their coldest temperature posit ion. As this change could impact the measured efficiency, it should be considered in the new ener gy standard.” Does “this change” in the second sentence refer to the first sentence or to the prop osed amendment? Same question for the words

“in this fashion” in the first sentence of the seco nd paragraph of the response? Does “total capacity” in the response refer to the total volume of the product, or to the volume of a compartment? Does the sentence “Temperatures should be volume weighted” depend on the 10% of the total capacity size limitation mentioned in the previous paragraph?

“This change” in the second sentence refers to the proposed amendment, not the first

sentence. Likewise for the words “in this fashion” in the second paragraph of the response for this request for comment.

“Total capacity” in the response means the product’ s total refrigerated volume (including all freezer and fresh food compartments)

The statement “temperatures should be volume weight ed” should be considered a separate comment, not tied to the compartment size, which wo uld apply whether the highest energy use setting or the coldest setting were used.

Question C: Section V.E.14 of the NOPR asked, “Defrost Precooli ng Energy: DOE invites comment on the proposals to include precooling energy in the proce dures for testing products with long-time or

variable defrost controls. DOE also invites comment regarding whether additional test procedure amendments are appropriate in order to address poss ible use of partial recovery to reduce energy use of this part of the test.” For question 14, the response mentions “within 0.5 degrees F”. Does the meaning of the response depend on completing the thought, i.e. wit hin 0.5 degrees F of what?

This is intended to mean within 0.5 degrees F of th e temperature average for the first part of the test. The defrost part of the test should start in a period of steady state operation prior to any part of the defrost sequence, and end in a peri od of steady state operation.