December 13, 2013

The Honorable David Danielson Assistant Secretary, Energy Efficiency and Renewable Energy

United States Department of Energy Forrestal Building (Mail Station EE

- 1) 1000 Independence Avenue, SW Washington, DC 20585

Dear Assistant Secretary Danielson :

Samsung Electronics America, Inc. (“ Samsung ”) respectfully submits th e 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 d ual

compressor s.

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

u nrepresentative of its true energy consumption characteristics as to provide materially

inacc urate 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 compartment s that have their own evaporator s

. 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 fre sh 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 specifica lly, Samsung’s residential refrigerator

- freezers that use shared dual

compressor s can be tested a nd calculate to a reasonable result w ith 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 S amsung ’ 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 a nd an interim waiver for the alternate test procedure that DOE has already granted Sub

- Zero and LG pertaining to the refrigerator

freezers 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 e nergy expended during 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 perio ds);

 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 EP 2i, 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

- cycl e 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 occurrenc e (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 ta ken at regular interval not exceeding 1 minute.Request

For the reasons that DOE descr ibed in its granting of waiver and interim waiver for Sub

Zero 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 :



### RF34H99****

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