1 | Energy Efficiency and Renewable Energy 

[INSERT PICTURE(S) OF PRODUCT(S)]

[INSERT PICTURE(S) OF PRODUCT(S)]

Proposed Test Procedure for

Refrigerators, Refrigerator‐Freezers,

and Freezers

7/25/2013

Lucas Adin

Department of Building Techno

EERE‐2012‐BT‐T

Res‐Refrig‐Freez

TP‐0016@ee.do
2

Welcome• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete tra

this meeting.

– Be concise – share the ‘air‐time’.

– Keep the focus here – cell phones on silent; limit sidebar

conversations.

– Webinar participants turn phone on mute; “raise your hand

recognized to speak.

• Housekeeping Items• Agenda Review

• Opening Remarks
3

Agenda1) 9:00 AM Introductions

2) 9:15 AM Stakeholder Opening Statements

3) 9:45 AM Regulatory History

4) 10:00 AM Products Covered by the Test Procedure 

5) 10:45 AM Test Procedure Amendments

6) 3:15 PM Other Issues Under Consideration

7) 3:35 PM Compliance with Other EPCA Requireme

8) 3:55PM Closing Remarks
4

Public Meeting Slides Topics

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Products Covered by the Test Procedure Changes5 Proposed Test Procedure Amendments6 Other Issues Under Consideration

7 Compliance with Other EPCA Requirements8 Closing Remarks
5

Listening Via the Webcast• The Department is broadcasting this meeting live ov

Internet.

• DOE is providing the webcast to accommodate stake

that are unable to attend the public meeting in perso

• The web broadcast allows stakeholders to listen in an

the slides.

• All stakeholders are encouraged to submit written co

after the public meeting.
6

Purpose of the Public Meeting• Present DOE’s proposed standards for refrigerators,

refrigerator‐freezers, and freezers.

• Invite comment on the notice of proposed rulemakin

(NOPR) document.

• Discuss next steps in the rulemaking.

• Invite participants to provide summary comments or

statements and raise additional issues for discussion.
7

Steps in the Test Procedures Rulemaking• NOPR published by DOE on July 10, 2013

• NOPR Public Meeting today, July 25, 2013

• Comments on NOPR from interested parties

• Transcript records oral comments from today’s public m

• Written comments (comment period closes September 

75 days after publication in the Federal Register)

• DOE reviews and considers all comments• Final Rule Publication

Final

Rule NOPR
8

Public Meeting Slides Topics

1 Introductions

2 Stakeholder Opening Statements3 Regulatory History4 Products Covered by the Test Procedure Changes5 Proposed Test Procedure Amendments6 Other Issues Under Consideration

7 Compliance with Other EPCA Requirements8 Closing Remarks
9

Stakeholder Comments• Workshop participants are invited to provide summa

comments or statements

• Participants are also invited to raise their issues on th

Procedure NOPR for discussion today
10

Issues for Discussion

• Issue box numbering corresponds to the list of issues publi

the end of the NOPR document, available at:

http://www.gpo.gov/fdsys/pkg/FR‐2013‐07‐10/pdf/2013‐1

• The deadline for submitting comments is September 23, 20

Issue Box: DOE welcomes comments, data, and information concerning its proposed standards fo[PRODUCT(S)]. Issues that correspond to those raised in DOE’s published material will be numberin accordance with that material. Whether invited ban issue box or not, comments are welcome on anpart of DOE’s analysis.
11

Opening Remarks

Meeting participants are invited to provide opening rem

statements at this time.
12

Public Meeting Slides Topics

1 Introductions2 Stakeholder Opening Statements3 Regulatory History

4 Products Covered by the Test Procedure Changes5 Proposed Test Procedure Amendments6 Other Issues Under Consideration

7 Compliance with Other EPCA Requirements8 Closing Remarks
13

Regulatory History: Refrigerator/Refrigerator‐F

Citation Date DescriptionTest Procedure Final Rules42 FR 46140 9/14/1977 Test procedure established.47 FR 34517 8/10/1982 Revised Test Procedure based on AHAM‐HRF‐1

54 FR 36238 8/31/1989 Variable Defrost Control; Dual System Defrost

68 FR 10957 3/7/2003 Long‐time Defrost Test Procedure Modification

75 FR 78810 12/16/2010 Appendix A1 Final Rule; Appendix A Interim Fi

77 FR 3559 1/25/2012 Appendix A Final Rule

Waivers Recently Granted*

Wine Cooler‐Refrigerators Sanyo (08/16/12) and Panasonic (Interim ‐ 6/14/13)

Refrigerators with Multiple

Defrost Cycles

GE (12/20/12 and 06/27/13)Samsung (12/20/12 and 6/14/13)

Refrigerators with Dual/Multiple Compressors Sub‐Zero (2/6/12), LG (3/26/13) Samsung (6/14/13), GE (6/27/13)

*For a listing of all waivers granted by DOE that are currently in effect, see:

https://www1.eere.energy.gov/buildings/appliance_standards/current_test_procedure_waivers.html
14

Regulatory History: Freezer

Citation Date DescriptionTest Procedure Final Rules42 FR 46140 9/14/1977 Test procedure established.47 FR 34517 8/10/1982 Revised Test Procedure based on AHAM‐HRF‐1

54 FR 36238 8/31/1989 Variable Defrost Control; Quick Freeze

75 FR 78810 12/16/2010 Appendix B1 Final Rule; Appendix B Interim Fi

77 FR 3559 1/25/2012 Appendix B Final Rule
15

Public Meeting Slides Topics

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Products Covered by the Test Procedure Changes

5 Proposed Test Procedure Amendments6 Other Issues Under Consideration

7 Compliance with Other EPCA Requirements8 Closing Remarks
16

Products Covered

Residential refrigerators, refrigerator‐freezers, and fre

defined in 10 CFR 430.2:

• Electric refrigerator means a cabinet designed for the refrigerated storage of 

designed to be capable of achieving storage temperatures above 32 °F (0 °C) 

°F (3.9 °C), and having a source of refrigeration requiring single phase, altern

electric energy input only. An electric refrigerator may include a compartmen

freezing and storage of food at temperatures below 32 °F (0 °C), but does no

separate low temperature compartment designed for the freezing and storag

temperatures below 8 °F (−13.3 °C).

• Electric refrigerator‐freezer means a cabinet which consists of two or more c

with at least one of the compartments designed for the refrigerated storage 

designed to be capable of achieving storage temperatures above 32 °F (0 °C) °F (3.9 °C), and with at least one of the compartments designed for the freez

storage of food at temperatures below 8 °F (−13.3 °C) which may be adjusted 

to a temperature of 0 °F (−17.8 °C) or below. The source of refrigeration requ

phase, alternating current electric energy input only.

• Freezer means a cabinet designed as a unit for the freezing and storage of fo

temperatures of 0 °F. or below, and having a source of refrigeration requiring 

alternating current electric energy input only.
17

Public Meeting Slides Topics

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Products Covered by the Test Procedure Changes5 Proposed Test Procedure Amendments

6 Other Issues Under Consideration

7 Compliance with Other EPCA Requirements8 Closing Remarks
18

Proposed Test Procedure Amendments

New Test Procedures1. Icemaking Test Procedure

2. Multiple Compressor Test

Optional Test

1. TriangulationTest Procedure Clarifications1. Anti

‐Circumvention Language

2. Incomplete Cycling

3. Mechanical Temperature Controls

4. Ambient Temperature Gradient

5. Definitions Associated with

Defrost Cycles

6. Package Loading

7. Minimum Compressor Run

‐Time

Between Defrosts for Variable

Defrost Models

8. Treatment of “Connec

Products

9. Product Clearance to 

During Testing

10. Relocation of Shelving 

Temperature Sensors

Corrections

1. Corrections to Tempe

Setting Logic Tables

2. Other Minor Correctio

CCE Modifications

1. Measurement of Prod2. Elimination of Report

Product Height

3. Changes to Confident

Certification Data
19

Icemaking Test Procedure

DOE proposes adopting the AHAM icemaking test proc

with several modifications.

• Add definition for “ice piece”.

• Clarify anti‐sweat heaters are off

during testing.

• Require a minimum acquisition rate

of one minute.

• Clarify icemaking cycle start/end

times.

• Specify alternative methods for

icemaking cycle indication for

products without mold heaters.

• Modify requirements for

compartment temperatures and

temperature control settings during

baseline and icemaking tests.

• Prescribe baseline tes

consistent with Appen

4.1.

• Modify the form of th

equations.

• Apply a temperature s

criterion for the icemaperiod.

• Specify an earlier start 

icemaking test after d

• Simplify testing of pro

multiple icemakers.

• Specify a 1.8 lb/day da

production rate
20

Icemaking Test Procedure

DOE’s proposal does not specifically address “electricrefrigerators” or products with manual defrost.

Issue 2.a: Refrigerators with Automatic Icemakers

DOE requests comment on whether any refrigerators (i.e., “electric re

defined in 10 CFR 430.2 rather than “electric refrigerator-freezer”) a

automatic icemakers. If so, DOE also seeks comment on whether te

for automatic icemakers should cover these “electric refrigerators” 

extent, if any, the test procedure would need to be modified to accom

testing of these products. DOE is seeking comment on this issue 

ascertain whether this aspect of today’s proposal should apply to ref

opposed to only refrigerator-freezers. DOE is currently unawar

refrigerators that are also equipped with an automatic icema

Issue 2.b: Manual Defrost Products with Automatic Icem

DOE requests comment on whether any manual defrost refrigerato

freezers are sold with automatic icemakers and whether any modific

proposed test procedure are required to address such prod
21

Icemaking Test Procedure

DOE proposes the following definitions related to icem

• “Harvest” means the process of freeing or removing ice piece

automatic icemaker.

• “Ice Storage Bin” means a container in which ice can be store

• “Ice Piece” means a piece of ice made by an automatic icema

has not been reduced in size by crushing or other mechanical 

• “Through the door ice/water dispenser” means a device inco

within the cabinet, but outside the boundary of the refrigerat

that delivers to the user on demand ice or water from within 

refrigerated space without opening an exterior door. This def

includes dispensers that are capable of dispensing ice and wa

only, or water only.

Issue 2.c: Icemaking Definitions

DOE requests comment on the proposal to establish definit

“Harvest”, “Ice storage bin”, “Ice piece”, and “Through the 

ice/water dispenser” in the test procedures.
22

Icemaking Test Procedure

DOE proposes to require all anti‐sweat heater switche

the “off” position for the icemaking test.

• This would prevent random activation of variable anti‐sweat he

during testing if humidity levels in the test room vary during th

• The proposal also calls for testing in low ambient humidity for 

with variable anti‐sweat heater control without an anti‐sweat h

switch.

Issue 2.d: Anti-Sweat Heater Switch

DOE requests comment on the proposed requirements that 

with anti-sweat heater switches be tested with the switches 

position and that products with variable anti-sweat heater 

without an anti-sweat heater switch be tested in an amb

environment with sufficiently low humidity to prevent the an

heaters from being energized. DOE also requests sugge

regarding how the objectives of these requirements could be 

with alternative approaches.
23

Icemaking Test Procedure

DOE proposes to modify unit installation to allow for p

operation of icemakers.

• DOE would revise sections 2.6(a) and 2.6(g) of Appendix A an

2.4(a) and 2.4(g) of Appendix B to read as follows:

– (a) Connection of water lines and installation of water filters are 

only when conducting the icemaking test described in section 8

– (g) Ice storage bins shall be emptied of ice, except as required fo

icemaking test described in section 8.

Issue 2.e: Setup for Icemaking

DOE requests comment on the proposed modification of th

requirements, specifically the requirements addressing wat

water filters, and ice storage bins.
24

Icemaking Test Procedure

DOE proposes a 90 °F ambient temperature condition 

icemaking tests.

• Consistent with current energy test to limit test bur

For icemaker water supply conditions, DOE proposes 9

temperature and 60 psig ± 15 psig.

• No need for temperature control other than equilib

water supply tubing with room air temperature.

• Pressure range well within acceptable range for mo

makers.

• Consistent with AHAM Revised Draft Test Procedure

Issue 2.f: Icemaking Water Temperature and Pressure Co

DOE seeks comment on its proposal to require 90 +/-2  ̊F w

temperature and 60 ± 15 psig inlet pressure conditions. DO

seeks comment on its proposal to require a 90  ̊F ambient tem
25

Icemaking Test Procedure

DOE proposes to require data collection at least once 

minute rather than every four minutes.

• Icemaker operation involves multiple recurring events that ar

synchronized (icemaker cycles and compressor cycles). Increa

data acquisition rate helps to ensure accuracy of the measure

• DOE believes most, if not all, test facilities already record time

data once per minute, making it unlikely to add testing burde

Issue 2.g: Icemaking Data Collection Rate for Icemaki

DOE requests comments on the proposed at least once pe

data collection interval for the proposed icemaking test a

assumption that most test facilities record data for refrigeratio

energy tests at a frequency of at least once per minu
26

Icemaking Test Procedure

DOE proposes that icemaking cycles would end when i

harvested and proposes methods for identifying icemacycles for icemakers without harvest heaters.

• To correlate refrigeration system and harvest heater e

with ice harvested from the previous cycle, each cycl

end when the harvest heater turns off.

• For icemakers without harvest heaters, one of three a

methods would be used to identify icemaking cycles:

– Changes in mold temperature

– Changes in water supply temperature, or

– Actuation of the water valve solenoid
27

Issue 2.i: Alternative Icemaker Cycle Indication

DOE requests comment on the follow aspects of its proposal fproducts whose icemakers have no mold heaters:• Details of the three proposed methods.• Requirement to use one of the three identified methods.• Identification of the method used in test reports.• Whether to further clarify when an alternative must be used• Whether additional alternative methods should be allowed.• Icemaker cycle delineation based on water flow into the ice

Icemaking Test Procedure

Issue 2.h: Icemaker Cycles

DOE requests comment on its proposed delineation between 

cycles at the end of the harvest of a batch of ice.
28

Icemaking Test Procedure

DOE proposes that temperature control settings be ad

both baseline and icemaking portions of the test.

• Analysis based on NIST research shows the potential for signi

variation of results if compartment temperatures drift far fro

standardized temperatures.

• Compartment temperatures should be no more than 1  ̊F war

standardized temperatures for baseline test.

• Compartment temperature should rise no more than 1  ̊F dur

icemaking test.

Baseline Test Variation from Target Temperatures Icemaking Test Temperature C
29

Issue 2.k: Icemaking Temperature Setting

DOE requests comments on its proposed variation limits on compartment temperatures during different parts of the icemawhich would require that:(1) compartment temperatures be set to their warmest setting 

which compartment temperatures are no more than 1  ̊F wthan their standardized temperatures for the baseline test

(2) if the compartment temperatures increase during icemaki

they be adjusted to their warmest setting for which compatemperatures are no more than 1  ̊F warmer during the ic

test than they were in the baseline test, 

(3) for mechanical controls these settings be aligned with sym

the temperature dial, and 

(4) products that use quick-freeze control during icemaking b

without disabling this feature during the test.

Icemaking Test Procedure
30

Icemaking Test Procedure

Icemaking Daily production rate and typical icemaking 

• DOE proposes use of the 1.8 lb/day ice production 

initially suggested by AHAM.

– Although higher than estimates based on NEEA data, this 

consistent with the current fixed placeholder value for ice

energy use in Appendix A.

• DOE’s proposals for temperature control settings du

icemaking test are based on the assumption that th

limited deviation of cabinet temperatures during fie

icemaking operations.

– Extended consecutive‐cycle operation expected to be rare

– Thermal mass of loaded refrigerator limits temperature d
31

Issue 2.r: Ice Production Rate

DOE seeks information on consumer daily ice production 

determine the most appropriate ice production rate for th

procedure. DOE further seeks comment on whether the pro

pounds per day ice production rate should be retained or w

lower rate, as suggested by data provided by the Northwes

Efficiency Alliance, should be considered.

Icemaking Test Procedure

Issue 2.j: Icemaker Field Operation

DOE assumes that in the field, continuous icemaking would 

occur only for initial filling of the bin and successive icemak

would occur after a portion of ice has been withdrawn from t

DOE seeks comment and data confirming DOE’s assumptio

assumption is incorrect, information suggesting an alternative 

and description with respect to icemaking operation in th
32

Icemaking Test Procedure

DOE’s proposals for baseline and icemaking test periodslight adjustments of the AHAM revised draft proposa

• Baseline test period consistent with Appendix A, se

– At least three hours in duration, consisting of at least two

compressor cycles (for systems with cycling compressors)

• Icemaking test period:

– At least 24 hours of icemaking, unless interrupted by fillin

ice storage bin or a defrost.

– Initiate icemaking during compressor operation shortly af

defrost.

– For products whose compressors do not cycle during icem

test period includes a whole number of icemaking cycles.

– For products whose compressors cycle during icemaking, 

periods based on compressor cycles and on icemaking cyc

used for the energy use calculation.

– Stability: compartment temperatures for any one compre

or icemaking cycle within 3  ̊F of test period average.
33

Icemaking Test Procedure

DOE proposes evaluation of two icemaking test period

products that cycle their compressors during icemakin

Test Period 2 (whole number of icemaking cy

Test Period 3 (whole number of compresso

within Test Period 2)

Energy per ice mass = 

=
34

Icemaking Test Procedure

The dual test period approach reduces measurement v

0.000.050.100.150.200.25

0 10 20 30 

Icemaking Energy per Mass

(kWh/kg)

Number of Icemaking Cycles

Single Test Period CalculationDual Test Period Calculation
35

Issue 2.m: Test Periods for Icemaking Part of Test

With respect to refrigeration products that cycle their compresso

icemaking, DOE requests comments on its proposal to (1) estab

periods for the icemaking part of the test based both on icemaker 

on compressor cycles and (2) require that energy use be calculated 

of these test periods and applying them to the same period of ice

order to provide a more accurate calculation of icemaking ener

Likewise, DOE requests comment on its proposal to allow use of o

period based on icemaker cycles for refrigeration products that do 

their compressors during icemaking.

Icemaking Test Procedure

Issue 2.l: Test Period for Baseline Part of Test

DOE requests comments on its proposal to adopt a test period for t

part of the test that is equivalent to its existing test period for prod

manual defrost, i.e. consisting of a period of time at least three 

duration and, if the product’s compressor cycles, comprising at l

complete compressor cycles. DOE further requests comment on th

to allow overlap of the stabilization period and the test period for th

part of the test as long as the stabilization period ends no later tha

period for the baseline part of the test.
36

Issue 2.o: Icemaking Test Period Duration

DOE seeks comment on its proposal to adopt a minimum te

duration of 24 hours for the icemaking portion of the test, if 

prior to a defrost cycle occurrence or filling of the ice storage 

also seeks comment on its proposal to require icemaking to 

shortly after the start of compressor operation following a de

Icemaking Test Procedure

Issue 2.n: Icemaking Test Period Stability Toleran

DOE requests comment on its proposal to include a temp

stability requirement in the icemaking test procedure that wo

the temperature in the freezer compartment, measured f

compressor cycle (if the refrigeration product cycles its com

during icemaking) or any icemaker cycle (if the refrigeration 

does not cycle its compressor during icemaking) within the t

to be within 3  ̊F of the compartment’s temperature average 

test period.
37

Issue 2.p: Ice Mass

DOE requests comment on its proposed method of measu

mass.

Icemaking Test Procedure

The DOE proposal provides instructions to ensure corre

the measured ice mass with the icemaking cycles used 

energy use measurement.

• Measure total ice mass produced.

• Determine total number of icemaking cycles.

• Calculate ice mass per cycle.

• Determine number of icemaking cycles in Icemakin

Period 2.

• Calculate ice mass for Icemaking Test Period 2.
38

Icemaking Test Procedure

For products with multiple icemakers, the DOE propos

measurement of icemaking energy for the icemaker se

through‐the‐door ice feature.

Issue 2.q: Multiple Icemakers

DOE requests comment on its approach for testing these pr

i.e. measuring the icemaking energy only for the icemaker p

through the door service. DOE also requests comment on w

products with multiple icemakers using other configurations e

their design details are, whether DOE should consider modi

proposed test procedure to address these products, and h

proposed test procedure should be modified to address t
39

Icemaking Test Procedure

DOE would not require measurement of icemaking en

until the compliance date of future efficiency standard

• This allows careful evaluation of the test procedure changes on 

measurement of overall energy use of products with icemakers

• The next energy conservation standards would most likely be in

EPCA’s 6‐year look‐back provision.

• The test procedure and the energy conservation standards wou

to use the 84 kWh fixed placeholder until those standards take 

• DOE’s testing suggests that 84 kWh is an appropriate energy use 

for icemaking using the proposed test procedure but requests d

confirmation.

Issue 2.s: Measurements of Energy Use Associated with 

DOE seeks icemaking energy use data for typical products 

automatic icemakers, using the test procedure proposed in this 

seeks these data in order to improve confidence in the under

typical icemaking energy use per pound of ice of residential r

products.
40

Issue 2.t: Impact on Energy Use Measurement

DOE requests comments on the impacts on energy use meas

of the proposed icemaking test procedure. DOE further re

comments and data supporting any claimed change in 

measurement.

DOE further requests comment on the proposed delay of ad

the laboratory measurement until a future energy conserv

standards rulemaking takes effect.

Icemaking Test Procedure
41

Multiple Compressor Test Procedure

DOE proposes to adopt a modified version of the mult

compressor test procedures prescribed in recent waive

• The current test procedure requires that products with “dual

compressors” or separate compressor systems be tested with system metered individually.

– This approach can be burdensome and does not address products whos

systems have shared components (e.g. controls, condenser fans).

• The test procedure prescribed in the waivers addresses these 

while minimizing truncation error through use of 24‐hour test 

• The DOE proposal would adopt the waiver procedure with so

changes that are not expected to alter the measured energy u
42

Multiple Compressor Test Procedure

Proposal would adopt the test procedure from recent 

for products with multiple compressors, with the follo

differences:

• Defining “multiple compressor”

• Allowing temperature cycles (as an

alternative to compressor cycles) to

define test periods.

• Prescribing a stabilization period

consistent with the existing test

procedure.

• Allowing a single‐part test for products

with single defrosts that are not long‐

time or variable.

• Reducing the required test period

duration for multiple compressor

products with a single or no cycling

compressor.

• Identifying freezer comp

primary compressor systtest periods.

• Requiring 24 hours of co

operation pending no de

part of the test with 18 h

defrost interrupts stable 

• Removing the 24‐hour re

the second part of the te

• Criteria for evaluation of 

operation more consiste

current Appendix A: maper hour variation.
43

Issue 3.a: Multiple Compressor Definition

DOE requests comment on its proposed definition of m

compressor refrigerator-freezers and refrigerators

Multiple Compressor Test Procedure

DOE proposes to define a “multiple compressor” prod

having more than one compressor.

• Compressor cycle described as extending from either a comp

to a compressor start, or from a stop to a stop.

• Temperature cycle defined as extending from a minimum to a 

minimum within 0.5  ̊F of the initial minimum, or similarly fro

maximum to a maximum.

DOE proposes to allow test periods to be defined by

temperature cycles as an alternative to compressor cyc

Issue 3.b: Temperature Cycles

DOE requests comment on its proposal to allow use of tem

cycles as alternative indicators for start and stop times for 

compressor test periods.
44

Issue 3.c: Data Collection Rate

DOE requests comments on the proposed one-minute maxi

collection interval for the proposed multiple compresso

Multiple Compressor Test Procedure

DOE proposes to require data collection at least once p

minute when testing multiple compressor products to 

the potential truncation error.

DOE proposes to require the existing stabilization requ

in Appendix A rather than a fixed 24‐hour period.

Issue 3.d: Multiple Compressor Stabilization Perio

DOE requests comment on its proposal to apply the cu

stabilization requirement of Appendix A, section 2.9 to m

compressor products and also on its proposal to allow evalu

temperatures based either on temperature cycles or compres

when evaluating stabilization.
45

Issue 3.e: One-Part Multiple Compressor Test

DOE requests comments on its proposal to allow a one-par

multiple compressor products where only one compressor sy

a defrost cycle (but this system’s defrost control is neither lon

variable).

Multiple Compressor Test Procedure

DOE proposes test period simplifications, where appro

• Use of the one‐part test for products with a single automatic 

that is neither long‐time nor variable.
46

Multiple Compressor Test Procedure

DOE proposes test period simplifications, where appro

• For products with one or no cycling compressors, use of a tes

that is eat least three hours long comprising at least two cycle

cycling compressor system.

Issue 3.f: Test Periods for Products with One or No C

Compressors

DOE requests comment on its proposal allowing simplified te

for both the first and second parts of the test (consistent wit

periods used for products with single compressors) when 

multiple-compressor products in which one or no compress

during a test.
47

Multiple Compressor Test Procedure

• The proposal requires that:

– the “primary” compressor determines the test period duration 

“primary” compressor be the freezer compressor if possible.

– the first part of the test be comprised of whole primary compre

• The proposal would not permit multiple individual

segments of stable operation to be combined to sat

24‐hour requirement.

• Alternatively, the proposal would also allow a short

duration of 18 hours if defrost operation interrupts state operation.

DOE proposes a 24‐hour test (first part) for models wit

two cycling compressors.
48

Issue 3.g: Duration of the First Part of the Test

DOE seeks comment on its proposal to require the first part o

to be a single continuous period lasting at least 24 hours, a

reduction to 18 hours long if it is interrupted by a defro

DOE also seeks comment on its proposal that the test period 

a whole number of cycles of a “primary” compressor, and t

“primary” compressor be the freezer compressor, if it cycles d

test.

Multiple Compressor Test Procedure
49

Multiple Compressor Test Procedure

DOE’s proposes that stabilization for the first part of t

evaluated based on compartment temperature rate o

less than 0.042  ̊F per hour.

Issue 3.h: Stabilization for the First Part of the Te

DOE requests comment on its proposal to require that the fir

the test consist of a period of stable operation. 

DOE also seeks comment on its proposed definition for s

operation, which would require compartment temperature c

during the period to not exceed 0.042  ̊F per hour.
50

Multiple Compressor Test Procedure

• Second part would be conducted for each compres

system that undergoes defrost.

• Test period would extend from one period of stable

operation before the defrost to another period of s

operation after the defrost.

• 0.5  ̊F compartment temperature tolerance for star

end of test period, consistent with current Appendi

procedure for the second part of the test.

• Evaluation of test data shows that extending the te

of this part of the test to 24 hours does not reduce

truncation error.

DOE’s proposal does not require a 24‐hour test period 

second part of the test.
51

Issue 3.i: Second Part of the Test

DOE requests comment on its proposal to have the second part of the start and end points during stable operation while surrounding the defromeasured. Further, DOE requests comment on its proposal that any of would be allowed to indicate start and end of the test period:a) when the primary compressor on-cycle starts; b) when the primary compressor on-cycle stops; c) when the compartment temperature associated with the primary c

a maximum; or 

d) when the compartment temperature associated with the primary c

a minimum. 

Finally, DOE requests comment on its proposal to allow start and end ttest period for products with non-cycling compressors to occur when thtemperatures are within 0.5  ̊F of their averages for the first part of the 

Multiple Compressor Test Procedure
52

Issue 3.j: Measurement Changes for Multiple Compresso

DOE requests information regarding any refrigeration products 

compressors (other than those already covered by test procedu

DOE also requests comment on whether the proposed test proc

alter the measurement of energy use of any multiple compresso

so, DOE requests supporting information: how large is the cha

aspects of the proposed test would be most responsible for th

Multiple Compressor Test Procedure

DOE expects no change in measured energy use for its 

as compared to the test procedure prescribed in the w
53

Issue 3.k: Multiple Compressor Products with Manual 

DOE requests comment on whether any multiple compressor 

products with manual defrost exist and whether the test proced

should address such products.

Multiple Compressor Test Procedure

DOE is not aware of any multiple compressor products 

manual defrost.
54

Triangulation Test Procedure

• Appendix A currently requires linear interpolation o

use from two tests, based separately on the fresh fo

freezer temperatures, and selecting the higher of th

calculated energy use values.

DOE proposes to allow triangular energy interpolation f

products with both fresh food and freezer compartmen

Energy Use (kWh)

Fresh Food Temperature Freezer Temper

Test 1

Test 2

Test 1

Standardized

(39  ̊F)

Standardized

(0 ̊F or 15 ̊F)

Test Energy 
55

Triangulation Test Procedure

Triangular interpolation conducts a single two‐paramet

interpolation based on three tests.

Energy (kWh)

Test 1

Test 2

Test 3

Energy Measured

in 3 Tests

Temperatures

Measured in 3 Tes

Test Result

Standardized

Temperatures
56

Triangulation Test Procedure

• DOE proposes to allow triangulation as an optional certific

method in Appendix A.

– Incorporation by reference of Australian/New Zealand (AS/NZS) St

44474.1:2007

– Energy use Ex would be calculated as discussed in the AS/NZS 444

Appendix M, with target temperatures txA and txB representing the

standardized temperatures specified in DOE’s Appendix A.

– The first two of the three tests would comply with the requiremen

DOE two‐test method as described in Appendix A.

• Proposed triangulation certification requirements:

– Manufacturers must report if triangulation is used for certification

– All units within a given model must be tested using the same test 

• DOE proposes to use triangulation for enforcement and

assessment purposes if either:

– Triangulation was used for certification, or

– The results of the first two tests differ by more than 5%.

Implementation of Triangulation:
57

Issue 4: Triangulation ApproachDOE seeks comment on its proposal to include the triangulatiapproach as an optional interpolation method, including the papproach for implementing this method in the test procedure proposed requirement to indicate in certification reports that triangulation has been used for certification. DOE also seeks on its proposal to use triangulation for assessment and enforctesting if: (a) the product was certified using this method, or (b) the measurement results calculated based on the first two 

differ by more than five percent using the two different compartment temperatures for the interpolations.

Triangulation Approach
58

Anti‐Circumvention Language

DOE proposes to modify the anti‐circumvention language based 

stakeholder comments submitted during the previous test proce

rulemaking.

Issue 5.a: Modification to Anti-Circumvention Langu

DOE invites stakeholder comment on its proposal to modify 

circumvention language.

• Proposal is identical to the anti‐circumvention provisions in H

rearranged slightly for clarity and consistency with the CFR st

(proposed text is at page 41663)

• The same revisions would be adopted in 10 CFR 430.23(a)(10

refrigerators and refrigerator‐freezers and 430.23(b)(7) for fre
59

Anti‐Circumvention Language

Issue 5.b: Components that Operate Differently During 

DOE seeks comment on potential revisions to the anti-circu

language that would, in limited circumstances, permit the use 

algorithms that may cause a system to operate differently dur

from how it would operate in the field.

• DOE’s adoption of the modified version of the AHAM anti‐circ

language aimed to prevent manufacturers from sensing enerconditions to obtain favorable, but unrepresentative measure

energy use.

• Manufacturers have requested clarification on the need for w

petitions for its models that run condenser fans at different sdepending on ambient temperature.

DOE may consider additional modifications to the anti

circumvention language to account for components thoperate differently during testing.
60

• The current 24‐hour test period for incomplete cycling pro

result in significant truncation error.

• In order to limit test burden, DOE proposes allowing singl

compressor‐cycle test periods if compressor cycles are mo

hours long.

• DOE also proposes to align test periods for measuring ene

with those used for compartment temperature measurem

– Same test periods for temperature and energy use measure

manual defrost products.

– Temperature measurement based on the entire test period 

part of the test for long‐time or variable defrost products.

– For products with automatic defrost that is neither long‐tim

variable, temperature measurement for a period of stable o

that includes no events associated with defrost, is at least t

long, and includes at least two compressor or temperature 

DOE proposes use of test periods that align with comp

cycles for incomplete cycling products.

Incomplete Cycling
61

Issue 6: Incomplete Cycling

DOE seeks comment on its proposed amendment to the inc

cycling definition and the associated modification of the test 

such products from 24 hours to one whole compressor c

DOE also seeks comment on its proposal to alter the test 

requirements of Appendices A and B to assure that warm-up 

defrost cycle is not part of the temperature measureme

Incomplete Cycling
62

Issue 7: Mechanical Control Settings

DOE invites stakeholder comment on its proposal to modify 

procedures to clarify the setting of mechanical controls durin

Mechanical Control Settings

• Two potential applications of the current Appendix 

requirements:

– Align control indicator with the most extreme numeral or symb

– Position the control as far as it will physically move.

• DOE proposes to clarify that the coldest or warmes

should have the control indicator aligned with the l

first numeral or symbol that indicates a temperatur

DOE proposes to specify the meaning of the “warmest

“coldest” temperature control setting for mechanical c
63

Issue 8: Ambient Temperature Conditions

DOE requests comment on its proposed changes to am

temperature and ambient temperature gradient requirement

proposed approach to implementing these changes

Ambient Temperature Conditions

DOE proposes to clarify the requirements for measurinambient temperature and for demonstrating that the

temperature gradient is maintained during tests.

• Shielding is allowed, but not relocation of sensors.

• Test procedure language addresses heat from adjacent te

• Temperature gradient must be verified during testing bas

sensors on both sides of the test unit at 2” and 36” above 

and 12” above the unit.
64

Definitions Associated with Defrost Cycles

DOE proposes to adopt definitions to clarify terminoloassociated with defrost.

• “Stable operation” defined to exclude any events associated with defr

and otherwise to be consistent with the requirements for evaluating s

prior to testing (e.g. Appendix A section 2.9)

• “Stable period of compressor operation” means a period of stable ope

a refrigeration system that has a compressor.

• “Precooling” means operating a refrigeration system before initiation 

cycle to reduce one or more compartment temperatures significantly 

0.5  ̊F) below its minimum during stable operation between defrosts.

• “Recovery” means operating a refrigeration system after the conclusio

defrost cycle to reduce the temperature of one or more compartment

temperature range that the compartment(s) exhibited during stable o

between defrosts.

Issue 9: Definitions Associated with Defrost Cycle

DOE welcomes comment on the proposed definitions for “pre

“recovery”, “stable operation”, and “stable period of comp

operation.”
65

Issue 12: Package Loading

DOE requests comment on whether its proposed clarificatio

method for achieving 75% package loading for freezers is co

with the sections of HRF-1-1979 and HRF-1-2008 reference

test procedures.

Package Loading

• The compartment would first be filled to capacity with p

• Subsequently, 75% of the packages would be used to fil

compartment for the energy test.

DOE proposes to clarify requirements for loading of pa

freezer compartments.
66

Issue A: Minimum Compressor Run-Time Between De

DOE seeks comment on the proposed use of observed comp

times between defrost, if shorter than specified for the alg

Minimum Compressor Run‐Time Between Def• CTL is the shortest compressor run time between defrosts (greater or 

hours but less than or equal to 12 hours).

• Products operating with shorter CTL values would be expected to have 

frequent defrosts and thus consume more energy.

DOE proposes to use observed CTL values less than 6 h

the energy use equation for products with variable de
67

Issue B: “Connected” Refrigerators

DOE seeks comment on the proposed clarifications for tes

connected products.

Treatment of “Connected” Refrigeration Produ• Connected refrigeration products have or are designed to work with

communication modules for remote monitoring and/or control purpo

• The test procedure would clarify that such modules must be installed, 

and connected to a communications network, but that no active com

would be ongoing during testing.

DOE proposes clarifications for testing of “connected”

refrigeration products.
68

Issue 13: Product Clearance to the Wall During Tes

DOE requests comment on its proposed revisions to the 

Appendices A and B to address product clearance to the w

testing.

Product Clearance to the Wall During Testing

DOE proposes refinements to requirements for rear wspacing

• Rear clearance based on lowest edge of the “rear p

• The “rear plane” defined as largest flat surface at t

the cabinet.

• Exclusion of features that protrude beyond the larg

surface, including brackets, the compressor, or rear

mounted condensers.
69

Issue 14: Relocating of Shelving

DOE requests comments on its proposal to require that shelv

other components whose position is adjustable by consum

relocated to assure that temperature sensors maintain the 

clearance from hardware, while indicating that the shelving b

as evenly as possible if relocation for temperature sensors is 

Relocating of Shelving

DOE proposes to prioritize temperature sensor placem

even spacing of user‐adjustable shelving.

• DOE would add language indicating that consumer

adjustable shelves should be relocated to maintain

temperature sensor clearance requirements.

• However, shelf position would adhere as closely as 

to setup instructions, e.g. for even shelf spacing.
70

Corrections

DOE proposes corrections to recently‐identified issues 

test procedure.

• Corrections to Temperature Setting Logic Tables.

• Consistent reference to “E”, average per‐cycle ener

section 6 of Appendices A and B.

• Clarification that the 7.75 cu. ft. cutoff for compact

refrigeration products refers to total refrigerated vo

• Revising the definition of “defrost cycle type” to cla

off‐cycle defrost is a form of automatic defrost.
71

Issue 10: Elimination of Product Height Reportin

DOE invites comment on its proposal to eliminate the certi

requirement for reporting product height starting September 

Elimination of Product Height Reporting

• The September 2011 Energy Conservation Standard eliminate

inch maximum for compact class categorization (compact sta

established by refrigerated volume alone).

DOE proposes to eliminate the requirement to report 

height in certification reports.
72

Issue 11: Measurement of Product Volume

DOE seeks comment on its proposals for volume calculations• Permitting use of CAD models to measure product volume• The proposed 2 percent (or 0.5/0.2 cubic foot) allowance w

respect to differences between the certified and measured 

• The requirements for retention of CAD-generated volume 

calculations as part of certification test reports. 

DOE also requests information on the documentation kept by manufacturers of CAD modeling used for volume calculations whether it could be in a format allowing DOE review.

Measurement of Product Volume

DOE proposes to allow calculation of volume based on

computer aided design (CAD) models.

• The proposal also includes requirements for retention of documentatio

support the calculations and an approach to resolve discrepancies betw

measurements and calculations arising in third party testing.
73

Measurement of Product Volume

DOE has received questions about treatment of certai

features for the purposes of refrigerated volume calcu

• AHAM HRF‐1‐2008, which is incorporated by reference by the D

procedure, indicates that the volume of air ducts is deducted fr

measurement of total refrigerated volume—AHAM asked how 

apply this provision.

• DOE has also been asked whether the volume of water tanks us

chilling of water prior to dispensing should be deducted for the 

volume measurement.

• DOE proposes adding the following text to section 5.3 of Appen

B ‐‐ “The measured volume shall include all spaces within the in

volume of each compartment except for the volumes that must deducted in accordance with section 4.2.2 of HRF–1–2008.”

• DOE has also proposed a definition for “through‐the‐door ice/w

dispenser.” This definition would not specify that water tanks us

chilling of water are part of the dispenser.
74

Issue 16: Measurement of Product Volume

DOE requests comment on its interpretations of the vol

measurement provisions of AHAM HRF-1-2008 pertaining to 

and water chilling tanks, and its proposed revisions to section 

test procedures in Appendices A and B addressing volu

measurement.

Measurement of Product Volume
75

Changes to Confidentiality of Certification Dat

DOE proposes changes to confidentiality of certain cer

data.

• Data proposed to be public rather than confidential:

– Whether the product has variable defrost control.

– Whether the product has an anti‐sweat heater switch.

– Whether alternative temperature sensor locations were used during tes
76

Public Meeting Slides Topics

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Products Covered by the Test Procedure Changes

5 Proposed Test Procedure Amendments

6 Other Issues Under Consideration

7 Compliance with Other EPCA Requirements8 Closing Remarks
77

• Built‐in refrigerators are designed to be installed totally encased 

cabinetry, fastened to the adjoining cabinetry, walls, or floor.

• DOE investigated the impacts of testing built‐in products in an e

that simulates installation into kitchen cabinetry.

• DOE fabricated the enclosures consistent with installation instru

the products and the provisions in UL Standard 250, sections 8.

Built‐in Refrigerators

Sample

Number

Heat

Rejection

Location

Freestanding

Annual Energy

Consumption

(kWh/year)

Built‐In Annual

Energy Consumption

(kWh/year)

Percen

Be

Freest

Buil

1 Front 679 675 ‐2 Rear 576 607 3 Front 485 487 

DOE testing shows that testing built‐in products in a “b

condition may in some cases affect the energy use me
78

Issue 15: Built-in Refrigerators

DOE requests comment on whether testing in a built-in condi

generally be more representative of energy consumption in 

use and, if so, the extent to which testing in this condition w

expected to affect the measured energy use of these product

also interested in receiving comment on whether there wou

significant additional test burden resulting from a requirem

specifies these products be tested in a built-in conditio

Built‐in Refrigerators
79

Public Meeting Slides Topics

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Products Covered by the Test Procedure Changes

5 Proposed Test Procedure Amendments6 Other Issues Under Consideration

7 Compliance with Other EPCA Requirements

8 Closing Remarks
80

Other Issues

1. Test Burden

2. Changes in Measured Energy Use

3. Standby and Off Mode Energy Use
81

Issue 17: Test Burden

DOE seeks comment regarding its assessment of the test 

impacts of the test procedure amendments proposed in this 

Test Burden and Regulatory Flexibility Review

DOE tentatively concludes that, other than the icemak

none of the proposed changes have a significant impac

burden.

• Many of the proposed test procedure amendments are minor changes 

affect the equipment required for testing or the time required to cond

energy test.

• The new icemaking test procedure would increase the test burden, inc

– Installation of a water supply (Estimate of an additional $800 per testing facility)

– Additional instrumentation required for measurement of additional parameters (e.g. – Additional test time

• DOE estimates that most of the additional cost is associated with the a

test time and estimates the increase at $1,250 per test, or $3,750 per c

model (assuming test of three units).
82

Test Burden Regulatory Flexibility Review

DOE must determine whether the modification propos

rule would result in a significant impact on a substanti

of small entities.

• As indicated in the test burden section, the icemaking test proc

only modification that may be a significant test burden.

• The Small Business Administration small entity standard in the 

Refrigerator and Home Freezer Manufacturing industry is 1,000 

• DOE identified one small business that manufactures products 

automatic icemakers and would be subject to the additional tes

requirements proposed in today’s test procedure.
83

Test Burden Regulatory Flexibility Review

DOE determined the proposed test procedure would n

significant economic impact on a substantial number oentities.

• DOE estimates an average industry research and development ex

2.4% of revenues.

• DOE estimates that the proposed test procedures would have a o

impact of approximately 5% of the annual research and developm

of an average small business manufacturer of refrigeration produ

• Conclusions were based on available data. DOE seeks additional d

supplement its analysis.

Issue 20: Regulatory Flexibility

DOE requests comment the extent to which any small bu

manufacturers of refrigeration products that would be affecte

proposed changes in the test procedures for products with a

icemakers.
84

Issue 18: Changes in Measured Energy Use

DOE invites stakeholder comment regarding DOE’s assess

the potential changes in measured energy use associated 

proposed test procedure changes. DOE requests comment o

any of the proposed amendments to the test procedures co

energy use measurements, and, if so, DOE requests data sh

magnitude of the measurement changes.

Changes in Measured Energy Use

DOE concluded that changes in energy use measureme

associated with the proposed test procedure are minim

do not warrant change in the Energy Conservation Sta

• Other than the icemaking test, the proposal consists of a variety 

clarification improvements and offers manufacturers with an opt

method for measuring energy use.

• DOE is proposing to require use of the icemaking test procedure 

next round of energy conservation standards after 2014 take effe
85

Issue 19: Standby and Off/Mode Energy Use

DOE tentatively proposed that no separate changes are ne

account for standby and off mode energy consumption, sin

current (and as proposed) procedures already address e

consumed in standby and off modes. DOE requests commen

determination.

Standby and Off/Mode Energy Use

The test procedures for these products (current and as

proposed) would address standby/off mode energy us

additional provisions to address energy use of these m

not necessary.
86

Public Meeting Slides Topics

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Products Covered by the Test Procedure Changes

5 Proposed Test Procedure Amendments6 Other Issues Under Consideration

7 Compliance with Other EPCA Requirements

8 Closing Remarks
87

How to Submit Comments... Public Meeting – oral comments will be captured in the t

become part of the public record.

 Written comments – NOPR comment period closes Septe

2013 and may be submitted as shown below:

Reference docket #: EERE–2012–BT–TP–0016 and/or RIN 

AC76

Email: Res‐Refrig‐Freezer‐2012‐BT‐TP‐0016@ee.doe.gov

Mail: Mrs. Brenda Edwards

U.S. Department of Energy Building Technologies Program

1000 Independence Avenue, SW, Mailstop EE‐2J Washington, DC 20585‐0121

Courier: Mrs. Brenda Edwards

U.S. Department of Energy Building Technologies Program

950 L'Enfant Plaza, Suite 600Washington, DC 20024 Telephone: (202) 586‐2945
88

Contact Information• Questions about products can be sent to:

refrigerators_and_freezers@ee.doe.gov

• For additional information, use the following links:

– DOE Appliance and Equipment Standards Program (main si

http://www1.eere.energy.gov/buildings/appliance_standa

l

– Test Procedure Rulemaking for Refrigerators, Refrigerator‐F

Freezers:http://www1.eere.energy.gov/buildings/appliance_standa

g.aspx/ruleid/75

• Thank you for your participation.