U.S. Departmentof Energy
Application for Interim Waiver and Petition forWaiver, 10CFR430, Subpart B, Appendix A1- UniformTest Methodfor Measuring the Energy Consumption of Refrigerator-freezers

Submitted by:
Earl F. Jones Senior Counsel GE Appliances Appliance Park 2-225 Louisville, KY 40225 earl.jones@ge.com 

### 502-452-3164 (voice) 502-452-0395 (fax) Case No. Non-Confidential Version



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## u.s. Department of Energy Application for Interim Waiver and Petition for Waiver, 10CFR430, Subpart B, Appendix A1--Uniform Test Method for Measuring Refrigerator-Freezers


### I. Introduction
GE Appliances, an operating division of General Electric Co., ("GE") is a leading manufacturer and marketer of household appliances, including, as relevant to this proceeding, refrigerators, files this Petition forWaiver and Application for Interim Waiver (collectively, "Petition")
. GE requests thatthe Assistant Secretary grant it awaiverfrom certain parts ofthe test procedure promulgated by the U.S. Department of Energy ("DOE" or "the Department")for determining refrigerator-freezer energy consumption and allow GE to test its new refrigerator-freezer model pursuant to the modified procedure submitted herewith. This request is filed pursuant to 10 C.F.R. §430.27. The Department's regulations provide that the Assistant Secretary will grant a Petition upon "determin[ation] that the basic model for which the waiver was requested contains a design characteristic which either prevents testing ofthe basic model according to the prescribed test procedures, orthe prescribed test procedures may evaluate the basic model in a manner so unrepresentative of its true energy consumption characteristics as to provide materially inaccurate comparative data." 10 C.F
.R. §430.27(1). GE requests that the Assistant Secretary grant this Petition on both grounds
. First,the refrigerator energytest procedure set forth in 10 CFR 430, Subpart B, Appendix A 1 does not allow the energy used by GE's new refrigeratorto be accurately calculated. The new refrigerator contains two compressors, each ofwhich contributes to the cooling ofthe separate fresh-food and freezer compartments
. Since the test procedure assumes that refrigerators have only one compressor it does not provide a method for calculating energy consumption of dual-compressor systems. Thus, GE's new model cannot be tested perthe procedure. Second, if GE were to test its new dual-compressor refrigerator perthe test procedure the results ofthe energy test so conducted would not accurately measure the energy used bythe new model.



### 2II. Background GE has designed and has plans to market a new refrigerator. In orderto be assured that it is correctly calculating the energy consumption ofthe product, thatthe product meets the minimum energy requirements for its product class and is properly labeled, GE seeks the Department's expeditious concurrence to its proposed amendment to the refrigeratortest procedure to provide fortesting ofdual compressor models. DOE granted Sub-Zero's waiver petition1for refrigerators equipped with dual compressors acknowledging thatthe existing test procedure cannot properly measure the energy usage of refrigerators with dual systems. Thereafter, the Department granted LG Electronics USA, Inc.'s interim waiver application for its dual-compressor product.2 III. GE's Proposed Test Procedure In light ofthe above and since GE proposes to test its product in accordance with the test procedure that DOE has already approved for use by Sub-Zero and LG, the Department should grant GE's Petition and permit itto use the Sub-Zero-approved test procedure, which is setforth in Attachment 1 hereto. The reasons DOE granted Sub-Zero's waiver request apply as well to GE's product: GE's refrigerator also has a shared compressor system with refrigerant-flow controlled by a 3-way valve. It does not have the independent, sealed systems assumed bythe DOE test procedure. As a result, it cannot be tested using the DOE test procedure. Moreover, using the test procedure would yield test results so unrepresentative as to provide materially inaccurate comparative data. The waiver should continue in effect until DOE amends the test procedure to accommodate such products. GE also requests that the Department grant an interim waiverto test and rate the models listed on Attachment 2. Wewould be pleased to discuss this request with DOE and provide further information as needed.

1Sub-Zero. 77 Fed. Reg. 5784. Feb. 6, 2012.
2 LG, 77 Fed. Reg. 44603, July 30, 2012 

### 3GE requests expedited treatment ofthe Petition and Application. I hereby certifythat all manufacturers ofdomestically marketed units ofthe same producttype have been notified ofthis Petition and Application, listofwhich is found in Attochment3, hereto.
Respectfully submitted,

Counsel and**~u:.esWtative** ofGE Appliances



### 4ATTACHMENT 1

Where:

- ET is the test cycle energy (kWh/day);

- 1440 = numberof minutes in a day

- EP1 is the dual compressor energy expended during the first part ofthe test (it is calculated for a whole number offreezer compressor cycles at least 24 hours in duration and may be the summation ofseveral running periods that do not include any precool, defrost, or recovery periods);

- T1 is the length oftime for EPI (minutes);

- D is the total numberofcompartments with distinct defrost systems; - i is the variable that can equal to 1,2 or more that identifies the compartment with distinct defrost system;

- EP2j is the total energy consumed during the second (defrost) part of the test being conducted for compartment i. (kWh);

- T2j is the length oftime (minutes) forthe second (defrost) part ofthe test being conducted for compartment i.

- 12 = conversion factor to adjust for a 50% run-time ofthe compressor in hours/day

- CTj is the compressor on time between defrosts for only compartment i. CTj for compartment i with long time automatic defrost system is calculated as per 10 CFR Part 430, Subpart S,Appendix A 1 clause 5.2.1
.2. CTj for compartment Iwith variable defrost system is calculated as per 10 CFR part 430 subpart S,Appendix A 1 clause 5,2.1.3. (hours rounded to the nearest tenth ofan 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 ofthe test period must be within 1.0 [degrees 1 F (0
.6 [degrees 1 

### C) ofthe test period temperature average for each compartment. Make this determination forthe fresh food compartmentforthe fresh food compressor cycles closest to the start


### 5and end ofthe test period. Ifmultiple segments are used fortest period 1, each segment must complywith above requirement. Steady Statefor EP2i: The second (defrost) part ofthe test must be preceded and followed by regular compressor cycles. The temperature average forthe first and last compressor cycle of the test period must be within 1.0 [degrees 1 F (0.6 [degrees 1 C) ofthe EPI test period temperature average for each compartment. Test Period for EP2j, T2j: EP2j includes precool, defrost, and recovery time for compartment i, as well as sufficient dual compressor steady state run cycles to allow T2j to be at least 24 hours. The test period shall start atthe end ofa regularfreezer compressoron-cycle afterthe previous defrost occurrence (refrigerator orfreezer). The test period also includes the target defrost and following regular freezer compressor cycles, ending atthe end ofa regular freezer compressor on-cycle before the next defrost occurrence (refrigerator orfreezer). Ifthe 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 EP2j. Test Measurement Frequency Measurements shall be taken at regular interval not exceeding 1 minute. ***



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### ATTACHMENT 2 ZIC30GNDII ZIK30GNDII



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