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ELECTRONICS SAMSUNG ElECTRONICS AMERICA, INC, 

OA lab America 

January 23, 201 2 

Dr. Henry Ke ll y 

18600 Broadwick Street 

Rancho Dominguez, CA 90220 

TEL 310 900 5230 FAX 310 537 5500 

Energy Efficiency and Renewable Energy 

Departme nt of Energy 

1000 Independence Avenue, SW. 

Washington, DC 20585 

Re: Samsung's Petition for Waiver and Application for Interim Waive.', Clothes Washe.'s 

Dea r Assistant Secretary Kelly : 

Samsung Electronics America, on behalf of Samsung Electronics Co. (Samsung), respectfull y 

submits this petition for Interim Waiver and Application for Waiver to the Department of Energy 

(DOE) [or its manufactured clothes washers. Samsung manufactures for its own brand and for OEM 

brand, Kenmore. 

The 10 CFR 43 1.401(a)(1) allows a person to submit a petition to waive for a parti cul ar basic model 

any requirements of §430.23 upon the grounds that the basic model contai ns one or more design 

characteristics which either prevent testing of the basic model according to the prescribed test 

procedures, o r the prescribed test procedures may evaluate the basic model in a manne r so 

unrepresentative of its true energy consumption c haracteristics as to provide materially inaccurate 

comparat ive data. Additionally, 10 CFR Part 430.27(b)(2) allows an app li cant to request an In terim 

Waive r if economi c hards hip and/or competitive disadvantage is likely to result absent a favorable 

determin ation o n the Application for Inte rim Waiver. 

Reasoning 

In order to mee t current market demands, Samsung designed and will be marketing clothes washers 

with capaciti es greater than 3.8 cubi c feet. Samsung expects th at the majority of Samsung clothes 

was he rs will be g rea te r th an 3 .8 cubic feet in capacity. The current test procedure, Appendi x 11 to 

Subpart B of Part 430, Tabl e 5. 1, does not contain load sizes for capacities grea ter than 3.8 cubi c 

fee t, preve nting Samsung from appropriately testing clothes washer models with ca pacity grea ter 

th an 3.8 cubi c feet. The Department recognized this test method deficiency in the Interim Wai vers 

granted to Electrolux (76 FR 11440), LG (76 FR 11 233), Whirlpool (75 FR 69653), General 

Electric (75 FR 76968), and Samsung (76 FR 21881). 
Conclusion 

amsung respectfull y requests that DOE gra nt Samsung a Waiver and Inte rim Waiver, allowing 

Samsung to use the alternate expanded Table 5.1 of Appendix] 1 that appears in DOE's clothes 

was her test procedure NOPR (75 FR 57556, September 21,2010). 

In summary, this reque t for Waiver and Interim Wa iver approvals is for mode ls noted below and is 

based upo n the grounds that: 

1. Current test method for clothes washe rs do not allow testing of clothes washers w ith greater 

than 3.8 cubi c feet capacity. 

2. DOE has already granted Samsung an Interim Waiver in 75 FR 57937, pe r the altern ate 

Table 5.1, for simil ar mode ls. 

Brand Model Name 

Samsung WA456D *HD ** 

Samsung WA422P*HD** 

Samsung WA400P*HD** 

Samsung WF457A*GS** 

Samsung WF455A *GS** 

Samsung WF405A* PA ** 

Kenmore 592-4919* 

Kenmore 592-4900* 

Affected Persons 

Primaril y affected perso ns in the clothes washers category include Alli ance Laundry Systems, LLC, 

Arce lik A.S., ASLP Appli ances, Inc., BSH Home Appliances Corp., Electrolux Home Products, 

Fagor America, Fisher & Paykel Appliances, Inc., GE Appliances, Haier America Trading, LLC. , 

Indesit, LG Electronics USA, Inc., Mi ele Appliances, Inc., Panaso ni c Corporatio n, and Whirlpool 

Corporation. Samsung will notify all these entiti es as req uired by the Department's rul e and provide 

them w ith a version of this Petition. A copy was also provided to the Association of Home 

Appli ance Manu facturers (AHAM). 

Pl ease fee l free to contact me if you have any questions regarding this Petition for Waiver and 

Appli cation for In terim Waiver. I will be happy to discuss should any questions arise. 

Sincerely, 

Michael Moss 

Director of Corporate Environmental Affairs 

Samsung Electroni cs America , Inc. 

18600 Broadwick Street 

Rancho Dominguez, CA 90220 

(310) 900 - 5245 

mikem@sea.samsung.com