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 Whirlpool Corporation 

September 28, 2010 

This memorandum documents a discussion to clarify written comments addressing the 

refrigerator test procedure rulemaking NOPR. The discussion took place on on September 23, 

2010, in a phone conversation involving DOE’s contractor (Detlef Westphalen) and Stephen 

Church of Whirlpool Corporation. The questions, submitted 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 Impacts 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 to take effect prior to the effective date of 

the new energy conservations standards (scheduled per EPCA to be January 1, 2014), have a 

significant impact on measured energy use. DOE requests information quantifying these impacts, 

if any.” 

For this question, Whirlpool listed proposed amendments that have an “a significant impact on: 

measured energy use, manufacturer cost, testing capability and/or leadtime.” These included 

a) #1, Revised refrigerator definition; 

b) #7, Testing of convertible and special compartments 

c) #11, Variable anti-sweat heater energy consumption 

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 temperatures 

Can you clarify for which of the listed amendments there is an impact on measured energy use? 

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

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

39  ̊F, would result in added thermal load when tested for a 45  ̊F standardized temperature, 

thus increasing energy use. 

Adding ice to the ice bin would impact measured energy use—as discussed in the meeting, 

due to the added thermal capacity. 

And not allowing a measurement for products that don’t meet standardized temperatures 

certainly would change the measurement for any product for which this occurs. 
Question B:

Section V.E.7 of the NOPR asked, “Convertible Temperature Compartments and Special 

Compartments: DOE invites comment on the proposed clarifications of test procedures for 

treatment of convertible-temperature compartments and the proposed amendments to the test 

procedures for special compartments. DOE also requests comment on whether a size limit should 

be established for classification of a special compartment, 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 position. As this change could impact the measured 

efficiency, it should be considered in the new energy standard.” Does “this change” in the second 

sentence refer to the first sentence or to the proposed amendment? Same question for the words 

“in this fashion” in the first sentence of the second 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 weighted” should be considered a separate 

comment, not tied to the compartment size, which would apply whether the highest energy 

use setting or the coldest setting were used. 

Question C:

Section V.E.14 of the NOPR asked, “Defrost Precooling Energy: DOE invites comment on the 

proposals to include precooling energy in the procedures 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 possible 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. within 0.5 degrees F of what? 

This is intended to mean within 0.5 degrees F of the 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 period of steady state operation.