U.S. Department of Energy 

Application for Interim Waiver and Petition for Waiver, 10CFR430, Subpart B, Appendix A1-

Uniform Test Method for 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 A 1--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 for Waiver and Application for Interim Waiver 

(collectively, "Petition"). GE requests that the Assistant Secretary grant it a waiver from 

certain parts of the 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 of the basic model according to the 

prescribed test procedures, or the 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 energy test procedure set forth in 10 CFR 430, Subpart B, 

Appendix A 1 does not allow the energy used by GE's new refrigerator to be accurately 

calculated. The new refrigerator contains two compressors, each of which contributes 

to the cooling of the 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 per the procedure. 

Second, if GE were to test its new dual-compressor refrigerator per the test procedure 

the results of the energy test so conducted would not accurately measure the energy 

used by the new model. 

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II. Background 

GE has designed and has plans to market a new refrigerator. In order to be assured 

that it is correctly calculating the energy consumption of the product, that the 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 

refrigerator test procedure to provide for testing of dual compressor models. 

DOE granted Sub-Zero's waiver petition 1 for refrigerators equipped with dual 

compressors acknowledging that the 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 of the 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 it to use the Sub-Zero-approved test 

procedure, which is set forth 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 by the 

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 

waiver to test and rate the models listed on Attachment 2. 

We would be pleased to discuss this request with DOE and provide further information 

as needed. 

1 Sub-Zero. 77 Fed. Reg. 5784. Feb. 6, 2012. 

2 LG, 77 Fed. Reg. 44603, July 30, 2012 

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GE requests expedited treatment of the Petition and Application. 

I hereby certify that all manufacturers of domestically marketed units of the same 

product type have been notified of this Petition and Application, list of which is found in 

Attochment 3, hereto. 

Respectfully submitted, 

Counsel and 

~u:.esWtative of GE Appliances 

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ATTACHMENT 1 

Where: 

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

- 1440 = number of minutes in a day 

- EP1 is the dual compressor energy expended during the first part of the test (it is 

calculated for a whole number of freezer compressor cycles at least 24 hours in 

duration and may be the summation of several running periods that do not include any 

precool, defrost, or recovery periods); 

- T1 is the length of time for EPI (minutes); 

- D is the total number of compartments 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 of time (minutes) for the second (defrost) part of the test being 

conducted for compartment i. 

- 12 = conversion factor to adjust for a 50% run-time of the 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 I with 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 of an hour). 

Stabilization: 

The test shall start after a minimum 24 hours stabilization run for each temperature 

control setting. Steady State for EP1 : The temperature average for the first and last 

compressor cycle of the test period must be within 1.0 [degrees 1 F (0.6 [degrees 1 C) 

of the test period temperature average for each compartment. Make this determination 

for the fresh food compartment for the fresh food compressor cycles closest to the start 

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and end of the test period. If multiple segments are used for test period 1, each 

segment must comply with above requirement. 

Steady State for EP2i: 

The second (defrost) part of the test must be preceded and followed by regular 

compressor cycles. The temperature average for the first and last compressor cycle of 

the test period must be within 1.0 [degrees 1 F (0.6 [degrees 1 C) of the 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 at the end of a regular freezer compressor on-cycle after the previous 

defrost occurrence (refrigerator or freezer). The test period also includes the target 

defrost and following regular freezer compressor cycles, ending at the end of a regular 

freezer compressor on-cycle before the next defrost occurrence (refrigerator or freezer). 

If the previous condition does not meet 24 hours time, additional EP1 steady state 

segment data could be included. Steady state run cycle data can be utilized in EP1 and 

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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