CEC Workshop - Appliance Efficiency Regulations 

Comments Submitted by the 

Association of Home Appliance Manufacturers 

October 19,2000 

AHAM appreciates the opportunity to offer comments on the initiative by the CEC to 

promulgate amendments and additions to the its appliance efficiency regulations, per 

AB-970 and the previously noticed Docket 98-A&B-1. AHAM submitted comments on docket 

98-A&B-I dated October 7,1999, and we respectfully ask the Commission to again review and 

consider those comments in full prior to issuing a Proposed Rule. For the benefit of 

Commissioner Rosenfeld and others who may not be aware of or remember AHAM's previous 

comments, I will reiterate just a few of our major concerns that are already on the docket. 

General: AHAM opposes any new requirements or exercise of authority which is different than 

federal requirements and burdens and undermines interstate commerce, which NAECA is 

designed in large part to protect. Federal law is clear that the center of appliance standard 

activities for NAECA covered products is federal. Issues of testing, reporting, or compliance of 

these products should be dealt with at DOE or FTC. Please refer to our October 7, 1999 

comments for the details of our concerns in these areas. 

Reporting Requirements: In general, we object to providing any information to California that 

is not required to be provided to DOE or FTC. However, we would be glad to discuss 

California's interest in specific data items on a case-by-case basis. For example, the latest 

preliminary draft that AHAM has of the proposed changes to the efficiency regulations, dated 

July 20, 2000, indicates that CEC will require manufacturers of refrigerator/freezers to submit 

outside dimensions of the cabinets. This is not required by federal reporting and would result in 

an added burden that we believe is not germane to the regulations. 

Furthermore, the latest preliminary draft we have also indicated that CEC would require 

reporting various data on kitchen ranges and ovens. DOE and FTC have decided that no 

standards, labeling or data reporting are required for ranges and ovens because they use little 

energy and there is no evidence that there is a great deal of spread in the energy use of these 

products in the marketplace. The proposal by CEC to require data is not only preempted, but 

would add significant burden to manufacturers for no benefit to anyone. 

Another area of reporting proposed in the latest preliminary draft was to require a "Water 

Factor" and other parameters on clothes washers. Again, we urge CEC to only require 

parameters that are required by federal law for the same reasons stated above. 

AHAM is interested in providing data to CEC on behalf of its members to assist the 

Commission, especially in areas where we already publish most of the required information in 

our industry certification program directories such as room air conditioners and refrigeratorfreezers. 

\ 
Residential Wine Chillers: Wine Chillers were discussed at some length during proceedings 

for docket 98-A&B-I, resulting in a CEC staff recommendation on the docket, dated Decembers 

13,1999 as follows: "In discussions following the workshop, staff concluded that there should 

be no perfonnance standard for wine chillers at this time." However, the July 20, 2000 

preliminary draft indicated that CEC had changed its mind, and intended to propose standards for 

wine chillers. There has been much confusion as to whether these products were covered by 

federal or state regulation. DOE has clarified that there is no federal regulation. 

AHAM agrees with staff's previous position that it is premature to establish any standards for 

residential wine chillers for the following reasons: 

1. There is no appropriate test procedure for rating residential wine chillers. 

2. There is insufficient data to establish an appropriate baseline standard. 

3. Relatively speaking, there are very few units being sold, therefore the potential 

energy savings is insignificant. 

4. Care must be taken to avoid restricting features and utilities that are essential to the 

proper storage of wine and the needs of consumers. 

Therefore, AHAM recommends that a test procedure be developed first, followed by data 

collection to then detennine whether a standard is warranted and what an appropriate level might 

be .. Attached to our comments are recommendations on the test procedure, along with 

infonnation on the market and energy use of these products. 

Turning now to issues on the list of items for today' s workshop, we offer the following 

comments: 

Coin-operated clothes washers: We believe more analysis should be done before establishing 

standards for these products. The use patterns are probably quite different than clothes washers 

used in the home, and therefore a special analysis is required to detennine cost effectiveness of 

any standards. Furthennore, the potential energy savings may not warrant the cost and hassle of 

establishing standards. 

Continuously Burning Pilot Lights: Any restrictions on energy use of NAECA covered 

products, such as gas ranges, is preempted by NAECA. DOE is currently considering the issue 

of pilot lights on ranges and CEC should wait for their detennination. 

Electricity Standby Losses: Standby losses should be looked at on a product-by-product basis, 

and any restrictions on NAECA covered products are preempted. 

Thank you for considering our comments. We look forward to an ongoing constructive dialogue. 

f-,e3Pectfully sUbm~tt~Y7¥: "C a.,w'\.t2.~ 1(1. 

Lawrence R. Wethje 

Vice President 

AHAM Engineering Services 
CEC Commissioner(s}/ Staff Meetings 10/18/00 & 

Workshop 10/19/00 Comments 

presented by: 

Paul Sikir; Director of Design Engineering 

Sub-Zero Freezer Co., Madison WI 

• Introduction 

• Are efficiency standards for wine chillers appropriate? 

• Reasons for No efficiency standards on wine chillers. 

• Status changes since 12/13/99 CEC summary report. 

• Proposed Next Steps 

': 
Introduction 

• Appreciate the opportunity to provide comments 

• Sub-Zero Freezer Company; Madison WI 

- Family owned company in business 56 years 

- Built-in home refrigeration produced for specialty niche markets 

- Sophisticated product with value added features/performance 

- California is an important market to us 
Introduction 

• Sub- Zero wine product line 

- Introduced to market in mid 1999; Developed based on need in 

marketplace for improved products 

- Provides cooling for optimum long term storage or serving 

temperatures 

- Provides flexibility to store varying quantities of wine at different 

temperatures 

- Flexibility and sophistication in bottle and display arrangements 

- Developed product with input from wine experts and product field 

tests throughout the US including California. (UC-Davis; several 

California vineyards) 

- This product line provides new and exciting innovations that 

provide value added features/performance for the consumer and 

the wine itself. 
Introduction 

• Wine manufacturers / Resources 

- Wine coolers built by other smaller niche manufacturers like us 

- Limited resources that would be further depleted to satisfy 

additional energy regulation 

- Currently devoting significant manpower and financial resources 

to meet NAECA efficiency standards for refrigerators and freezers 

for upcoming 2001 standard levels 

- Significant disadvantage as compared to major appliance 

manufacturers who can spread the costs of regulation over a larger 

number of units produced. 

Administrative burden that would be required to respond to 

individual states, in addition to US DOE, would clearly hurt our 

ability to compete in the marketplace. 

• Strongly urge you not to set energy 

standards for wine coolers 

· . 
Are efficiency standards for wine chillers 

appropriate, and if so what should they be? What 

reporting requirements are appropriate ? 

• A December 13, 1999 summary report of the October14, 1999 CEC 

workshop (held in San Francisco) presented a staff conclusion "that 

there should be no performance standard for wine chillers at this time" 

• The same report stated that "consensus was reached that mandatory 

reporting of performance of wine chillers should continue" 

• The December 13,1999 summary also stated consensus was reached 

that" a modified test method should be developed for wine chillers 

since their operating temperatures are different from those of 

conventional refrigerators" 

· . 
Reasons Presented for No efficiency 

standards on wine chillers 

• Small energy usage for wine products as a whole when compared 

to refrigerators/freezers. 

• No applicable test procedure exists at this time which properly 

represents the energy consumption of wine product whose 

application and use differs significantly from a refrigerator. 

• Refrigerator standard does not allow for features unique to wine 

product and restricts the development of innovative value added 

features/ product for consumers and the wine product itself. 

· . 
,.' , . - ... -.... "~-.-,.,,--

. SMALL ENERGY USA GE FOR WINE PRODUCTS 

PERCENTAGE OF REFRIGERATORS SOLD IN CALIFORNIA VERSUS TOTAL USA (AHAM FIGURES) 

1998 CA 0.95 MILLION REFRIGERATORS % SOLD IN CALIFORNIA 

1998 US 9.7 MILLION REFRIGERATORS EQUALS 9.79% 

APPROX.10% 

TOTAL WINE US MARKET IS APPROXIMATELY 40,000 UNITS ANNUALLY 

IF WE ASSUME CALIFORNIA IS A LARGER PERCENTAGE OF UNITS SOLD IN US 1HAN 1HE 10% REFRIGERATOR SALES 

LETS ASSUME DOUBLE OR 20% 

1HE NUMBER OF WINE UNITS 1HEN SOLD IN CALIFORNIA ANNUALLY IS 20% OF 40, 000 8000 UNITS 

1HE TOTAL ENERGY IMPACT OF 1HESE 8000 UNITS IS APPROXIMATELY BASED ON 1.5 KWH/DAY @$0.101 KWH 

EQUALS 8000 X 1.5 XO,10 = 12,000 KWH/DAY X$O, 101 KWH = $1,200 PER DAY 

OR 

4380000 KWH/DAY $438,000 PER YEAR 

1HIS REPRESENTS 1HE ENTIRE ENERGY CONSUMPTION FOR WINE 

1HE ENTIRE CONSUMPTION FOR REFRIGERATORS @1,5 KWH/DAY AND $, 10/KWH EQUALS 

950,000 X1.5 X 0,10 EQUALS $142,500 PER DAY 

OR 

$52,012,500 PER YEAR 

SO WINE REPRESENTS A PERCENTAGE OF ENERGY CONSUMPTION IN CALIFORNIA OF 

$1,200 0,84% LESS THAN 1% 

142,500 

THIS IS ALL ENERGY CONSUMPTION; IF REGULATED SAY YOU WOULD SAVE 10%OR LESS THAN $50,000 I YEAR 

IS THIS WORTH THE EXTRA COSTANO TIME FOR REGULATIONS ON SUCH A SMALL NUMBER/SAVINGS? 

, , 
ITESTSTANDARD /pRQCEDURE (CURRENTLY NO TEST PROCEDURE IS AVAILABL~I , 

THE DOE DOES NOT RECOGNIZE A WINE PRODUCT AS A REFRIGERA TOR OR DOES IT HAVE A STANDARD FOR THEM 

BASED ON IT NOT BEING A REFRIGERA TOR (DEFINITION BEING DEVELOPED AT THIS TIME) AND THE SMALL CONTRIBUTION 

THIS PRODUCT MAKES TO ENERGY AS JUST DESCRIBED. 

THE SUGGESTI:D STANDARD BY THE PROPOSED RULE MAKING FOR WINE UNITS SECTION 1604.2 (A) (1) 

IS BASED ON A DEVELOPEDI UNIQUE TO REFRIGERATOR PRODUCT USAGE STANDARD 

AMBIENT RAN AT 90F 

ELEVATI:D AMBIENT WAS INCORPORATI:D IN THE REFRIGERATOR CLOSED DOOR TI:STTO SIMULATI: 

HIGH NUMBER OF DOOR OPENINGS NOT ACCOUNTI:D FOR IN A CLOSED DOOR TI:ST 

WINE PRODUCT HAS A VERY LOW NUMBER OF DOOR OPENINGS AS COMPARED TO A REFRIGERATOR 

WINE DOOR OPENINGS SIMILAR TO A FREEZER (USES A .85 FACTOR TO ADJUST FOR THIS) 

38 DEGREE ENERGY RA TlNG POINT 

REFRIGERATOR TI:ST IS RATING ENERGY CONSUMPTION AT 38 DEGREES F 

WINE PRODUCT WILL ON AVERAGE BE RUNNING AT 55 DEGREES F FOR TYPICAL USER 

RANGE DOWN TO LOWER FOR SERVINGI DESERT WINE TI:MPERA TURES 

SLOPE OF THE LINE / PRODUCT CAPACITY 

REFRIGERATOR STANDARDS ARE BASED ON AN EQUATION THAT IS A BEST FIT LINE (SLOPE AND INTI:RCEPl) 

THAT WAS ESTABLISHED BY MAPPING ENERGY CONSUMPTION VERSUS PRODUCT VOLUME (CAPACITY) 

FOR SEVERAL MODELS OVER WIDE RANGE OF VOLUMES ENERGY= SLOPE 01) + INTI:RCEPT 

A ENERGY EQUATION FOR WINE PRODUCT WOULD ALSO NEED TO BE DEVELOPED. 

MODEL LINE UP IN VOLUMES IS BECOMING A WIDER RANGE (SMALL UNDERCOUNTI:R UNITS TO LARGE 

UPRIGHT UNITS) AND THE APPROPRIATI: SLOPE AND INTI:RCEPTWOULD BE REQUIRED; CANT JUST 

ASSUME THE EXISTING SLOPE OF THE REFRIGERATOR STANDARD 

NEED ONE THAT IS CORRECT I FAIR ACROSS WINE VOLUME LINE 

IS THIS WORTH THE EXTRA COST AND TIME FOR REGULA TlONS ON SUCH A SMALL NUMBER/SAVINGS? 

· . 
r-----<·~<~-· --.--.. ~.-< .. ~~----- .<~~ ... -.--------<.-.-.< --.. -.--.... ------<--.. ------... ------. 

i REFRIGERATOR STANDARD DOES NOT ALLOW FOR FEA TURES UNIQUE TO WINE PRODUCT 

i USE OF A GLASS DOOR . 

I 

M UL TIPLE TEM PERATURE ZONESIINDEPENDENT CONTROLS 

USE BY CONSUM ER OF ILLUM INA TION LIGHTING WHEN DOOR CLOSED (LIKE DISPLAY 

CASES) 

NEW INNOVATIONS ARE B8NG USED THAT ARE VALUE ADDED FEATURES TO THE CONSUMER 

AND THE WINE ITSB.F. 

THIS IS A DEVB.OPING PRODUCT AND THIS DEVB.OPMENT AND ASSOCIATED INNOVATIONS 

SHOULD NOT BE OVERLY RESTRICTED BY INAPPROPRIATE TEST I ENERGY STANDARDS 

TO PERFORM THIS WORK AFFECTS SMALLER NICHE COMPANIES LIKE US WHICH I CAN NOT 

STRESS ENOUGH ARE ALREADY DEDICATING MAJOR RESOURCES TO COM PLY WITH THE 

2001 REFRIGERATOR/FREEZER STANDARDS. 

.. 
• 

Status changes since 12/13/99 CEC summary report 

On September 6, Gray Davis, Governor of California, signed into law the California Energy 

Security and Reliability Act of 2000 (AB 970). Among other things, this Act gives sweeping 

direction to the California Energy Commission (CEC) to adopt both building and appliance 

energy efficiency standards. 

- Adopt and Implement updated and cost-effective standards ... to ensure the 

maximum feasible reduction in wasteful, uneconomic, inefficient, or unnecessary 

consumption of energy. 

• CEC staffhas now taken position that wine coolers are already California regulated. 

(using the federal refrigerator test procedure) 

• Wine cooler manufacturers and AHAM are now confused; Why this change in 

position by CEC staff from consensus we had at 10/14/99 workshop? 

- AHAM / Manufacturers have started discussions for development of a test 

procedure for appropriate performance data reporting on wine coolers to the CEC 

as was agreed to at workshop. 

• The small energy savings associated with any energy regulation on wine chillers does 

not seem to fit the criteria associated with the California Energy Security and Reliability 

Act of 2000 and the use of an inappropriate test procedure (Refrigerator) greatly 

impacts the development of innovative / value added wine products and mis-represents 

the energy consumption of wine products whose application and use differs significantly 

from a refrigerator. 

.. 
Proposed Next Steps 

• Continue to follow the previous consensus that had been reached 

between the manufacturers/ AHAM and CEC staff during 

10/14/99 workshop (12/13/99 Summary Report) 

Se - Continue the discussion and development of an appropriate modified 

A-~o.ch€.cI:::; test procedure with wine manufacturers that is in progress. 

- Performance data per this modified test procedure would be 

reported to CEC and tracked as the wine product/designs/technology 

mature with innovative and new product designs. 

- No energy performance standard equations/ levels should be 

established at this time. 

• Attend and participate in 10/19/00 workshop 

• Request and conduct additional meetings with commissioners 

and! or staff as required. 

• Thanks to everyone for your time and consideration. 
Section 1604. Test Methods for Specific Appliances. 

(a) Refrigerators, Refrigerator-Freezers, and Freezers. 

(1) The test methods for refrigerators, refrigerator-freezers, and freezers are shown in 

Table A-I. 

(2) When a refrigerator, refrigerator-freezer, or freezer can be operated using either alternating 

current electricity or one or more other sources of primary power, the test shall be performed 

using alternating current electricity only. 

Table A-I 

Refrigerator, Refrigerator-Freezer, and Freezer Test Methods 

~-

~ -71.ppliam:e -- . - -- - " "~ -" ""~----"~-TestM1!Ihod 

~" .. , .. " ~ 

Federally-regulated consumer products 10 CFR Sections 430.23(a) (2000) and 

430.23(b) (2000), as applicable 

Wine chillers that are consumer products 10 CFR Section 430.23(a) (2000) 

Freezers that are consumer products 10 CFR Section 430.23(b) (2000) 

Refrigerating bottled or canned beverage ANSIIASHRAE 32.1-1997 Vending machines 

Commercial refrigerators, commercial refrigerator- ANSIIASHRAE 117-1992, with the 

freezers, and commercial freezers controls adjusted to obtain the following 

product temperatures: 

Type Initial Product Maximum Product Temperature in of Temperature in OF 

Refrigerator compartment 38 ± 1 40 

Freezer compartment 0±1 2 

Wine chiller 45 ± 1 No requirement 

Ice cream cabinet -5 ± 1 0 

(b) Room Air Conditioners, Room Air Conditioning Heat Pumps, Packaged Terminal Air 

Conditioners, and Packaged Terminal Heat Pumps. The test methods for room air conditioners, 

room air conditioning heat pumps, packaged terminal air conditioners, and packaged terminal heat 

pumps are shown in Table B-1. 

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-
PI. 430, Subpl. B, App. A 1 

being tested is to be maintained during the 

test. Unless the area is obstructed by shields 

or baffles, the gradient is to be maintained 

from 2 inches (5.1 em) above the floor or supporting platform to a height one foot (30.S 

em) above the unit under test. Defrost controls are to be operative and the anti-sweat 

heater switch is to be "on" during one test 

and "off" during a second test. Other exceptions are noted in 2.3, 2.4, and 5.1 below. 

2.3 Conditions for automatic defrost re- frigerator-freezers. For automatic defrost refrigerator-freezers, the freezer compartments 

shall not be loaded with any frozen food 

packages. Cylindrical metallic masses of dimensions 1.12 ±O.2S inches (2.9±O.S em) in diameter and height shall be attached in good 

thermal contact with each temperature sen· 

sor within the refrigerated compartments. 

All temperature measuring sensor masses 

shall be supported by nonthermally conduc· 

tive supports in such a manner that there 

will be at least one inch (2.5 cm) of air space 

separating the thermal mass from contact 

with any surface. In case of interference with 

hardware at the sensor locations specified in 

section 5.1, the sensors shall be placed at the 

nearest adjacent location such that there 

will be a one inch air space separating the 

sensor mass from the hardware. 

2.4 Conditions for all.refrigerators. There 

shall be no load in the freezer compartment 

during the test. 

2.5 Steady State Condition. Steady state 

conditions exist if the temperature measure· 

ments in all measured compartments taken 

at four minute intervals or less during a sta· 

bilization period are not changing at a rate 

greater than 0.0420 F. (0.0230 C.) per hour as 

determined by the applicable condition of A 

or B. 

A. The average of the measurements dur· 

ing a two hour period if no cycling occurs or 

during a number of complete repetitive com· 

pressor cycles· through a period of no less 

than two hours is compare to the average 

over an equivalent time period with three 

hours elapsed between the two measurement 

periods. 

B. If A above cannot be used. the average 

of the measurements during a number of 

complete repetitive compressor cycles 

through a period of no less than two hours 

and including the last complete cycle prior 

to a defrost period, or if no cycling occurs, 

the average of the measurements during the 

last two hours prior to a defrost period; are 

compared to the same averaging period prior 

to the following defrost period. 

3. Test Control Settings 

3.1 Model with no user operable tempera· 

ture control. A test shall be performed dur· 

ing which the compartment temperatures 

and energy use shall be measured. A second 

test shall be performed with the temperature 

10 CFR Ch. II (1-1-97 Edition) 

control electrically short circuited to cause 

the compressor to run continuously. 

3.2 Model with user operable temperature ~ 

control. Testing shall be performed in ac· ... ~~_--­

cordance with one of the following sections 

using the standardized temperatures of: 

All-refrigerator: 380 F. (3.30 C.) fresh food 

compartment temperature 

Refrigerator: 150 F. (-9.40 C.) freezer com· 

partment temperature 

Refrigerator·freezer: 5° F. (- 15° C., freezer 

compartment temperature 

Variable defrost control models: 5°F 

(-15°C) freezer compartment temperature 

and 38±2°F fresh food compartment tempera· 

ture during steady·state conditions with no 

door·openings. If both settings cannot be ob· 

tained, then test with the fresh food com· 

partment temperature at 38±2"F and the 

freezer compartment as close to SOF as possible. 

3.2.1 A first test shall be performed with 

all compartment temperature controls set at 

their median position midway between their 

warmest and coldest settings. Knob detents 

shall be mechanically defeated if necessary 

to attain a median setting. A second test 

shall be performed with all controls set at ei· 

ther their warmest or their coldest setting 

(not electrically or mechanically bypassed). 

whichever is appropriate. to attempt to 

achieve compartment temperatures measured during the two tests which bound (i.e., 

one is above and one is below) the standard· 

ized temperature for the type of product 

being tested. If the compartment tempera· 

tures measured during these two tests bound 

the appropriate standardized temperature. 

then these test results shall be used to determine energy consumption. If the compart· 

ment temperature measured with all con· 

trois set at their coldest setting is above the 

standardized temperature, a third test shall 

be performed with all controls set at their 

warmest setting and the result of this test 

shall be used with the result of the test per· 

formed with all controls set at their coldest 

setting to detennine energy consumption. If 

the compartment temperature measured 

with all controls set at their warmest setting is below the standardized temperature: 

and the fresh food compartment temperature 

is below 450 F. (7.220 C.) in the case of are· 

frigerator or a refrigerator.freezer. excluding 

an aU-refrigerator, then the result of this 

test alone will be used to determine energy 

consumption. 

3.2.2 Alternatively. a first test may be 

performed with all temperature controls set 

at their warmest setting. If the compart· 

ment temperature is below the appropriate 

standardized temperature, and the fresh food 

compartment temperature is below 45" F. 

(7.22" C.) in the case of a refrigerator or are· 

frigerator·freezer, excluding an all·refrig· 

erator, then the result of this test alone will 

124 
OCT-19-1000 09:37AM FROM-SUB ZERO DESIGN ENG, 

Pt. 430, Subpt. B, App. B1 

being tested has a variable defrost control 

the previsions of 4.1.2.2. shall apply. 

4.1.2.1 Long-time Automatic: Defrost. If ~he model being teseed has a long-1:ime automat!.c elefrost system, 'the tese Ume period 

may consist of twO parts. A first part would 

be the same as the test for a unit having no 

def~r. provisions (section 4.1.1). The second 

part would sta..~ when a aefrost period is initiated during a compressor "on" cycle and 

terminate at the second curn "::m" of t..'1.e 

compressor motor or after tou!" hours, which· ever comes first. 

"'.1.2.2 Variable defrost controL If the 

model being tested has a variable defrost 

control system. the test shall consist of 

three parts. Two part.$ shall be the same as the test for long-time automatic aefrost in 

accordance with section 4.1.2.1 above. The 

third. part: is the optional teSt to d.etermine 

the time between defrosts (5.2.1.3). The iliird 

part is used by manufacwrers that choose 

not. to accept the default value of F of 0.20, ta calculate CT. 

4.1.2.3 Variable defrost: control optional 

test. .I\.fter steady~state conditions with no door-openings are achieved in accordance 

with seetion 3.3 above, the test is eontinued 

using the above datly door-opening sequence 

until stabilized operation is achieved. Stabilization is defined as a minimum of three 

consecutive defrost cycles with times between defrost that will allow the calculation 

of a Mean Time Between Defrosts (MTBDl) 

that satisfies the statistical relationship of 

90 percent conf1dence, The test is repeated on 

at least one more unit of the model and Wltil 

the Mean Time Between Defrosts for the 

multiple unit test (MTBD2) satisfies the statistical relationship. If the time becween defrosts 1$ greater than 96 hours (compressor 

"on" time) and this defrost period can be repeated on a second unit. the test may be terminated at SS hours (en and the absolute 

time value used for MTBD for each unit. 

5. Test Measunmencs. 

5.1 Temperature Measurements. Temperature measurements shall be made at the 10· 

cations prescribed. in Figure 1-2 of HRF -1-

1919 and shall be accurate to Within to,S'" F. 

(0.3'" C.) of true value. 

5.1.1 Measured Temperature. The meas.-

ured t.emperature is to be the average of all sensor temperature readings taken at a particular time. Measurements shall be taken at 

regular intervals not to exceed four minutes. 

5.1.2 Compartment Tempera~e_ The 

compartment temperature for each test period shall be an average of the measured 

tempe:-atures taken during a complete eycle or sever-al complete cycles of the compressor 

motor (one compressor cycle 15 one complete 

motor "on" and one comple:.e motor "off" 

period). For long-time automatiC defrost: 

models. compartment temperature shall be 

that: measured in the first part. of the test pe6082716464 T-442 P 002/003 

10 CfR Ch. II (1-1-97 Edition) 

::-lod specified 1n 4.1.1. For models equipped 

with variable defrost controls, compartment 

temperatures shall be those measured in the 

first part of the test period spec!.fled in 

4.1.2.2. 

5.1.2.1 The nt..:mber of complete compressor motor cycles over which the measured 

t.emperatures 1n a compartment are to be 

averaged to detennine compartment temperature shall be equal to the number of 

minutes between measured. temperature 

readings rounded up to the next whole 

minute or a number of complete cycles over 

a time period. exceeding one hour, One of the 

cycles shall be the last complete compressor 

motor cycles during the test period. 

5.1.2,2 If no compressor motor cyclIng oc- curs, the compartment temperature shall be 

the average of the measured temperawres 

taken during the last thirty-twa minutes af 

the test period. 

5.1.2.3 If incomplete cycling occurs (less 

than one cycle) the compartment umpera- cure shall be the average of all readings 

taken ciuring the last three hours of the last 

complete "on" partod, 

5.2 Energy Measurements: 

5.2.1 Per-day Energy Consumption. The 

energy consumption in kilowatt-hours per 

day for each test pertod shall be the energy 

expended. during the test period as specified 

in section 4,1 adju.seed. to a 24 hour period. 

The adjustment shall be determined as follows: 

5.2.1.1 Nonautomadc and automatic defrost models. The energy consumption in kilowatt-hours per day shall be calculated 

equivalent to: 

ET-{EPx!44OxK}!T where 

ET-test cycle energy expended in kllowa«-

hau ... s per day, 

EP_energy expended in k1lowatt-hours during the test period, 

T_length of time of the test period In minutes. 

1440-conversion factor to acuust "to a 24 hour 

period 1n minut.8s per day. and 

K .. correetion factor of 0.7 for chest freezers 

and 0;85 for upright freezers to adjust for 

average household usage, dimensionless. 

5.2.1.2 Long-time Automatic Defrost, If 

the twO oa.-c :est method is used, the energy 

consump-tiOn 1n kllowat"t-hours per day shall 

bl! calculated equivalent to: 

ET ... {l440xKx£PlITl) ... ((EP2 - (EPlxT2I 

Tl))xKx!21CT) 

where 

ET, 1440, and K are defined 1n 5.2.1.1 

EPl_energy expended Ln kilowat.t~hours during 1:he first parr: of me test. 

EP2=energy expended in kUOWatt-hours during the second part of the teSt. 

CT_Defrost timer run time in hours reqUired 

to cause it to go through a complete 

cycle, to the nearest tenth hour per 

cycle, 

130 

F-034