Energy Conservation Program for Consumer Products: Test Procedures for Refrigerators, Refrigerator-Freezers, and Freezers
Federal RegisterJul 10, 2013
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[Docket No. EERE-2012-BT-TP-0016]
RIN 1904-AC76
Energy Conservation Program for Consumer Products: Test Procedures for Refrigerators, Refrigerator-Freezers, and Freezers
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Notice of proposed rulemaking and public meeting.
SUMMARY:
The U.S. Department of Energy (DOE) today is issuing a notice of proposed rulemaking to amend the test procedures for refrigerators, refrigerator-freezers, and freezers that will be required for the testing of products starting September 15, 2014. DOE is proposing to amend the test procedure to address products with multiple compressors and to allow an alternative method for measuring and calculating energy consumption for refrigerator-freezers and refrigerators with freezer compartments. DOE is also proposing to amend certain aspects of the test procedure in order to ensure better test accuracy and repeatability. Additionally, DOE is soliciting comment on a potential test procedure to measure the energy use associated with making ice with an automatic icemaker. If adopted, that procedure would become effective in conjunction with any parallel energy conservation standards rulemaking that DOE would need to conduct pursuant to the six-year review process mandated under Federal law.
DATES:
DOE will hold a public meeting on July 25, 2013, from 9 a.m. to 4 p.m., in Washington, DC. The meeting will also be broadcast as a webinar. See section V, “Public Participation,” for webinar registration information, participant instructions, and information about the capabilities available to webinar participants. DOE will accept comments, data, and information regarding this notice of proposed rulemaking before and after the public meeting, but no later than September 23, 2013. See section V, “Public Participation,” for details.
ADDRESSES:
The public meeting will be held at the U.S. Department of Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue SW., Washington, DC 20585. To attend, please notify Ms. Brenda Edwards at (202) 586-2945. See section V, “Public Participation” for details.
Any comments submitted must identify the NOPR for Test Procedures for Refrigerators, Refrigerator-Freezers, and Freezers, and provide docket number EERE-2012-BT-TP-0016 and/or regulatory information number (RIN) number 1904-AC76. Comments may be submitted using any of the following methods:
1.
Federal eRulemaking Portal:
www.regulations.gov.
Follow the instructions for submitting comments.
2.
Email:
#Res-Refrig-Freezer-2012-BT-TP-0016@ee.doe.gov.
Include docket number EERE-2012-BT-TP-0016 and/or RIN 1904-AC76 in the subject line of the message.
3.
Mail:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, Mailstop EE-2J, 1000 Independence Avenue SW., Washington, DC 20585-0121. If possible, please submit all items on a CD. It is not necessary to include printed copies.
4.
Hand Delivery/Courier:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 950 L'Enfant Plaza SW., Suite 600, Washington, DC 20024. Telephone: (202) 586-2945. If possible, please submit all items on a CD. It is not necessary to include printed copies.
For detailed instructions on submitting comments and additional information on the rulemaking process, see section V, “Public Participation”.
The docket is available for review at regulations.gov, including
Federal Register
notices, public meeting attendee lists and transcripts, comments, and other supporting documents/materials. All documents in the docket are listed in the regulations.gov index. However, not all documents listed in the index may be publicly available, such as information that is exempt from public disclosure.
A link to the docket Web page can be found at:
http://www.regulations.gov/#!docketDetail;D=EERE-2012-BT-TP-0016.
This Web page will contain a link to the docket for this notice on the regulations.gov site. The regulations.gov Web page will contain simple instructions on how to access all documents, including public comments, in the docket.
For further information on how to submit a comment, review other public comments and the docket, or participate in the public meeting, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT:
Mr. Lucas Adin, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue SW., Washington, DC, 20585-0121, 202-287-1317, email:
refrigerators_and_freezers@ee.doe.gov
or Mr. Michael Kido, U.S. Department of Energy, Office of the General Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 586-8145. Email:
Michael.Kido@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Background and Authority
II. Summary of the Proposal
III. Discussion
A. Products Covered by the Proposed Rule
B. Proposed Dates for the Amended Test Procedures
C. Proposed Test Procedure Amendments
1. Icemaking Test Procedure
2. Multiple Compressor Test
3. Triangulation
4. Anti-Circumvention Language
5. Incomplete Cycling
6. Mechanical Temperature Controls
7. Ambient Temperature Gradient
8. Definitions Associated with Defrost Cycles
9. Elimination of Reporting of Product Height
10. Measurement of Product Volume
11. Corrections to Temperature Setting Logic Tables
12. Minimum Compressor Run-Time Between Defrosts for Variable Defrost Models
13. Treatment of “Connected” Products
14. Changes to Confidentiality of Certification Data
15. Package Loading
16. Product Clearance to the Wall During Testing
17. Other Minor Corrections
18. Relocation of Shelving for Temperature Sensors
D. Other Matters Related to the Test Procedure
1. Built-In Refrigerators
2. Specific Volume Measurement Issues
3. Treatment of Products That Are Operable As a Refrigerator or Freezer
4. Stabilization Period
E. Compliance With Other EPCA Requirements
1. Test Burden
2. Changes in Measured Energy Use
3. Standby and Off Mode Energy Use
IV. Procedural Requirements
A. Review Under Executive Order 12866
B. Review Under the Regulatory Flexibility Act
C. Review Under the Paperwork Reduction Act of 1995
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under Section 32 of the Federal Energy Administration Act of 1974
V. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Requests to Speak
C. Conduct of Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VI. Approval of the Office of the Secretary
I. Background and Authority
Title III of the Energy Policy and Conservation Act (42 U.S.C. 6291,
et seq.;
“EPCA” or “the Act”) sets forth a variety of provisions designed to improve energy efficiency. (All references to EPCA refer to the statute as amended through the Energy Independence and Security Act of 2007 (EISA 2007), Pub. L. 110-140 (Dec. 19, 2007).) Part B of title III (42 U.S.C. 6291-6309), which was subsequently designated as Part A for editorial reasons, establishes the “Energy Conservation Program for Consumer Products Other Than Automobiles.” Refrigerators, refrigerator-freezers, and freezers (collectively referred to below as “refrigeration products”) are all treated as “covered products” under this Part. (42 U.S.C. 6291(1)-(2) and 6292(a)(1)) Under the Act, this program consists essentially of three parts: (1) Testing, (2) labeling, and (3) Federal energy conservation standards. The testing requirements consist of test procedures that manufacturers of covered products must use (1) as the basis for certifying to DOE that their products comply with the applicable energy conservation standards adopted under EPCA, and (2) for making representations about the efficiency of those products. Similarly, DOE must use these test requirements to determine whether the products comply with any relevant standards promulgated under EPCA.
By way of background, the National Appliance Energy Conservation Act of 1987 (NAECA), Public Law 100-12, amended EPCA by including, among other things, performance standards for refrigeration products. (42 U.S.C. 6295(b)) On November 17, 1989, DOE amended these performance standards for products manufactured on or after January 1, 1993. 54 FR 47916. DOE subsequently published a correction to revise these new standards for three product classes. 55 FR 42845 (October 24, 1990). DOE again updated the performance standards for refrigeration products on April 28, 1997, for products manufactured starting on July 1, 2001. 62 FR 23102.
EISA 2007 amended EPCA by requiring DOE to publish a final rule determining whether to amend the energy conservation standards for refrigeration products manufactured starting in 2014. (42 U.S.C. 6295(b)(4)) Consistent with this requirement, DOE initiated an effort to consider amendments to the standards for refrigeration products. As part of this effort, DOE issued a framework document on September 18, 2008, that discussed the various issues involved with amending the standards and potential changes to the test procedure. 73 FR 54089. DOE later prepared preliminary analyses that examined in greater detail the impacts amended standards would be likely to have on a national basis. DOE published a notice of proposed meeting (NOPM) to initiate a discussion of these analyses, 74 FR 58915 (Nov. 16, 2009), and held a public meeting on December 10, 2009, to discuss its preliminary findings. At that meeting, and in submitted written comments, interested parties indicated that the energy conservation standards for refrigeration products should address the energy use associated with automatic icemakers. They added, however, that a test procedure to measure icemaking energy use had not yet been sufficiently developed to provide a basis for the standards. (Energy Conservation Standards for Refrigerators, Refrigerator-Freezers, and Freezers, Docket No. EERE-2008-BT-STD-0012; American Council for an Energy Efficient Economy (ACEEE), No. 46 at p. 1; California Investor Owned Utilities (IOUs), No. 39 at p. 2; LG, No. 44 at pp. 2-3; Natural Resources Defense Council (NRDC), No. 42 at p. 2; Northeast Energy Efficiency Partnership (NEEP), No. 41 at p. 1; Northwest Power and Conservation Council (NPCC), No. 36 at p. 1; Sub-Zero, No. 43 at pp. 2-3; Appliance Standards Awareness Project (ASAP), Public Meeting Transcript, No. 30 at pp. 28-29; Association of Home Appliance Manufacturers (AHAM), No. 37 at p. 2; General Electric, No. 40 at p. 1)
DOE also initiated a test procedure rulemaking to help address a variety of test procedure-related issues identified in the energy conservation standard rulemaking's framework document. Taking these issues into account, DOE published a notice of proposed rulemaking (NOPR) on May 27, 2010. 75 FR 29824 (hereafter referred to as “the May 2010 NOPR”). The May 2010 NOPR proposed to use a fixed value of 84 kWh per year to represent the icemaking energy use for those refrigeration products equipped with automatic icemakers. The NOPR also indicated that DOE would consider adopting an approach based on testing to determine icemaking energy use if a suitable test procedure could be developed. Id. at 29846-29847. A broad group of stakeholders
1
submitted a joint comment supporting DOE's proposal to use a temporary fixed placeholder value to represent the energy use of automatic icemakers. It also urged DOE to initiate a rulemaking no later than January 1, 2012, and publish a final rule no later than December 31, 2012, to amend the test procedures to incorporate a laboratory-based measurement of icemaking energy use. The joint comment further recommended that DOE publish a final rule by July 1, 2013, amending the energy conservation standards scheduled to take effect in 2014 to account for the differences in energy use of icemakers measured using the new test procedure as compared with the 84 kWh per year fixed placeholder value. (Test Procedure for Refrigerators, Refrigerator-Freezers, and Freezers, Docket Number EERE-2009-BT-TP-0003; Joint Comment, No. 20 at 5-6)
1
The signatories to these comments included the Association of Home Appliance Manufacturers, the American Council for an Energy-Efficient Economy, the Natural Resources Defense Council, the Alliance to Save Energy, the Alliance for Water Efficiency, the Appliance Standards Awareness Project, the Northwest Power and Conservation Council, the Northeast Energy Efficiency Partnerships, the Consumer Federation of America, the National Consumer Law Center, Earthjustice, and the California Energy Commission.
In keeping with the timeline suggested in the comment, AHAM provided DOE in early January 2012 with a draft test procedure that could be used to measure automatic icemaker energy usage. (AHAM Refrigerator, Refrigerator-Freezer and Freezer Ice Making Energy Test Procedure, Revision 1.0—12/14/11,
2
No. 4) Subsequently, consistent with the suggestions made by commenters and DOE's previously stated intentions, DOE initiated work to develop today's notice. On July 18, 2012, AHAM provided DOE with a revised test procedure. (AHAM Refrigerator, Refrigerator-Freezer and Freezer Ice Making Energy Test Procedure, Revision 2.0—7/10/12,
3
No. 5) Today's notice, which is based in part on the approach suggested by AHAM, is designed to help the agency improve the accuracy of certain aspects of the test procedure that it recently promulgated. To ensure that any potential technical issues are addressed, DOE is soliciting
comments from the public on the potential adoption of the icemaking energy use measurement test that is detailed in today's notice. The procedure would be added as a new and separate section to the test procedure. Based on the comments received, DOE may adopt this testing approach (along with any necessary modifications) as part of the overall procedure but would require its usage to occur in parallel with any energy conservation standards rulemaking that would result from the mandatory review required under EPCA. See 42 U.S.C. 6295(m).
2
Subsequently referred to as “AHAM Draft Test Procedure”
3
Subsequently referred to as “AHAM Revised Draft Test Procedure”
DOE does not anticipate, based on collected preliminary data that its proposed changes to the current procedure would be likely to require an adjustment to those standards that manufacturers must meet starting in 2014. Additional details regarding these adjustments are detailed below and explain why an adjustment to the 2014 standards will not be necessary.
General Test Procedure Rulemaking Process
Under 42 U.S.C. 6293, EPCA sets forth the criteria and procedures DOE must follow when prescribing or amending test procedures for covered products. EPCA provides in relevant part that “[a]ny test procedures prescribed or amended under this section shall be reasonably designed to produce test results which measure energy efficiency, energy use . . . or estimated annual operating cost of a covered product during a representative average use cycle or period of use, as determined by the Secretary [of Energy], and shall not be unduly burdensome to conduct.” (42 U.S.C. 6293(b)(3))
In cases where DOE is considering amending a test procedure (or adding a new one), DOE publishes a proposal and offers the public an opportunity to present oral and written comments. (42 U.S.C. 6293(b)(2)) When considering amending a test procedure, DOE must determine the extent to which, if any, the proposal would alter the measured energy use of a given product as determined under the existing procedure. (42 U.S.C. 6293(e)(1)) If DOE determines that the amended test procedure would alter the measured energy use of a covered product, DOE must also amend the applicable energy conservation standard accordingly. (42 U.S.C. 6293(e)(2))
Today's rulemaking addresses amendments that, if adopted, would apply to the test procedures that manufacturers must use to demonstrate compliance with the energy conservation standards starting on September 15, 2014 (
i.e.,
10 CFR part 430, subpart B, appendices A and B). DOE has determined that none of the amendments to the test procedures proposed in this notice would be likely to significantly change the measured energy use of refrigeration products. DOE's analyses demonstrate that the proposed amendments to Appendices A and B, along with the possible incorporation of an optional “triangulation” method, will not affect measured energy use to any significant extent that would necessitate a change to any of the energy conservation standards for the products that would be affected by today's proposal. (42 U.S.C. 6293(e)(2)) Further, the preliminary data indicate that if DOE were to adopt the icemaking energy measurement test procedure detailed in today's notice, an adjustment to the standards be unnecessary. To demonstrate the effects of these amendments under consideration, DOE has conducted a preliminary evaluation of the anticipated impacts presented by today's proposal. This evaluation is discussed in further detail in section D.II of this notice. DOE notes that the proposed icemaking energy measurement test procedure amendments, if adopted, would not be required for manufacturers to use unless DOE were to set new or amended standards for refrigeration products after September 2014. Until such standards are developed, manufacturers would continue following the method that is laid out in Appendices A and B.
Refrigerators and Refrigerator-Freezers
DOE's test procedures for refrigerators and refrigerator-freezers are found at 10 CFR part 430, subpart B, appendices A1 (currently in effect) and A (required for rating products starting September 15, 2014). DOE initially established its test procedures for refrigerators and refrigerator-freezers in a final rule published in the
Federal Register
on September 14, 1977. 42 FR 46140. Industry representatives viewed these test procedures as too complex and eventually developed alternative test procedures in conjunction with AHAM that were incorporated into the 1979 version of HRF-1, “Household Refrigerators, Combination Refrigerator-Freezers, and Household Freezers” (HRF-1-1979). Using this industry-created test procedure, DOE revised its test procedures on August 10, 1982. 47 FR 34517. On August 31, 1989, DOE published a final rule establishing test procedures for variable defrost control (a control type in which the time interval between successive defrost cycles is determined by operating conditions indicating the need for defrost rather than by compressor run time) refrigeration products, dual compressor refrigerator-freezers, and freezers equipped with “quick-freeze” (a manually-initiated feature that bypasses the thermostat and runs the compressor continuously until terminated). 54 FR 36238. DOE amended the test procedures again on March 7, 2003, by modifying the test period used for products equipped with long-time automatic defrost (a control type in which defrost cycles are separated by 14 hours or more of compressor run time) or variable defrost. 68 FR 10957. The test procedures include provisions for determining the annual energy use in kilowatt-hours (kWh) (54 FR 6062, Feb. 7, 1989) and the accompanying annual operating costs. 42 FR 46140 (Sept. 14, 1977).
DOE further amended the test procedures in a final rule published on December 16, 2010. 75 FR 78810. These amendments helped clarify how to test products for compliance with the applicable standards. The amendments clarified certain elements in Appendix A1 to ensure that regulated entities fully understand how to apply and implement the test procedure. These changes included clarifying how refrigeration products equipped with special compartments and/or more than one fresh food compartment or more than one freezer compartment should be tested. The amendments also accounted for the various waivers granted by DOE, specifically with regard to variable anti-sweat heater controls. The final rule also modified the regulatory definition of “electric refrigerator-freezer” by requiring the storage temperatures in the fresh food compartment of such a product to be at a level that would effectively exclude the coverage of combination wine storage-freezer products.
See
10 CFR 430.2. The definition for “electric refrigerator” had already been amended to clarify the characteristics that distinguish it from related products, such as wine storage products, as part of a final rule published on November 19, 2001. 66 FR 57845. However, the December 2010 final rule made additional refinements to the definition. 75 FR at 78817 (Dec. 16, 2010). DOE is considering further modifying its product definitions to cover wine storage products as part of a separate rulemaking.
See
77 FR 7547 (Feb. 13, 2012) (announcing the availability of DOE's framework document regarding wine chillers and other miscellaneous refrigeration products).
In the December 16, 2010 notice, DOE also established a new Appendix A, via an interim final rule. The new
Appendix A included a number of comprehensive changes to help improve the measurement of energy consumption of refrigerators and refrigerator-freezers. These changes included, among other things: (1) New compartment temperatures and volume adjustment factors, (2) new methods for measuring compartment volumes, (3) a modification of the long-time automatic defrost test procedure to ensure that the test procedure measures all energy use associated with the defrost function, and (4) test procedures for products with a single compressor and multiple evaporators with separate active defrost cycles. DOE noted that the compartment temperature changes introduced by Appendix A would significantly impact the measured energy use and affect the calculated adjusted volume and energy factor (
i.e.,
adjusted volume divided by energy use) values. Lastly, the interim final rule also addressed icemaking energy use by including a fixed value for manufacturers to add when calculating the energy consumption of those products equipped with an automatic icemaker. Using available data submitted by the industry, this value was set at 84 kWh per year. See 75 FR 78810, 78859 and 78871 (Dec. 16, 2010) (specifying daily value of 0.23 kWh for products equipped with an automatic icemaker).
4
In light of stakeholders' strong recommendations that the test procedure and energy conservation standards incorporate the energy use associated with icemaking, AHAM's development efforts, and additional work performed by NIST and DOE, DOE is soliciting the public for feedback on a possible replacement for the “fixed value” approach by detailing a test procedure based on these collective efforts that relies on laboratory measurements to determine the energy use of automatic icemakers. Based on the comments received, DOE may adopt this approach or consider other alternatives.
4
Multiplying 0.23 by 365 days per year yields 84 kWh.
Freezers
DOE's test procedures for freezers are found at 10 CFR part 430, subpart B, appendices B1 (currently in effect) and B (required for the rating of products starting in 2014). DOE established its test procedures for freezers in a final rule published in the
Federal Register
on September 14, 1977. 42 FR 46140. As with DOE's test procedures for refrigerators and refrigerator-freezers, industry representatives viewed the freezer test procedures as too complex and worked with AHAM to develop alternative test procedures, which were incorporated into the 1979 version of HRF-1. DOE revised its test procedures for freezers based on this AHAM standard on August 10, 1982. 47 FR 34517. The subsequent August 31, 1989 final rule established test procedures for freezers with variable defrost control and freezers with the quick-freeze feature. 54 FR 36238. A subsequent amendment occurred to correct that rule's effective date. 54 FR 38788 (Sept. 20, 1989). The current test procedures include provisions for determining the annual energy use in kWh and annual electrical operating costs for freezers.
As with refrigerators and refrigerator-freezers, the December 16, 2010 notice also clarified compliance testing requirements for freezers under Appendix B1 and created a new Appendix B, the latter of which manufacturers are required to use starting in 2014. That new test procedure changed a number of aspects of the procedure detailed in Appendix B1, including, among other things: (1) The freezer volume adjustment factor, (2) methods for measuring compartment volumes, and (3) the long-time automatic defrost test procedure. In addition, Appendix B also addresses icemaking energy use by implementing for freezers the same procedure adopted for refrigerator-freezers in which a fixed energy use value is applied when calculating the energy consumption of freezers with automatic icemakers. 75 FR 78810.
Finalization of the Test Procedure Rulemaking for Products Manufactured Starting in 2014
The December 2010 interim final rule established comprehensive changes to the manner in which refrigeration products are tested by creating new Appendices A and B. In addition to the changes discussed above, these new appendices also incorporate the modifications to Appendices A1 and B1 that were finalized and adopted on December 16, 2010.
DOE provided an initial comment period on the interim final rule, which ended on February 14, 2011, and subsequently reopened the comment period on September 15, 2011 (76 FR 57612) to allow for further public feedback in response to the promulgation of the final energy conservation standards that were published on the same day. 76 FR 57516. This re-opening permitted interested parties to comment on the interplay between the test procedure and the energy conservation standards, and provided DOE with additional information to consider before making any final changes to the test procedures of Appendices A and B prior to their use by manufacturers starting on September 15, 2014. 76 FR at 57612-57613. That comment period ended on October 17, 2011. DOE also considered comments related to a petition for a test procedure waiver that had a direct bearing on elements of the test procedures used in Appendix A.
See
76 FR 16760 (March 25, 2011) (petition no. RF-018, Samsung Electronics America, Inc. (Samsung)).
During the comment periods that DOE provided, interested parties raised a number of issues for DOE to consider with respect to the test procedure. The submitted comments included suggestions that DOE modify the test procedure for multiple compressor systems to reduce test burden, modify the test period for the second part of the test for products with long-time or variable defrost to assure proper accounting of all energy use associated with defrost, develop separate test procedures and standards for products combining wine storage with fresh food compartments, allow use of an alternative three-test interpolation approach as an option to potentially improve measurement accuracy at the cost of greater test burden for those manufacturers choosing to use it, adjust the test procedure's anti-circumvention provisions, and adjust the default values of CT
L
and CT
M
(the longest and shortest duration of compressor run time between defrosts) to be used in the energy use equations for products that do not have defined values for these parameters in their control algorithms. (Test Procedure for Refrigerators, Refrigerator-Freezers, and Freezers, Docket Number EERE-2009-BT-TP-0003; Sub-Zero, No. 42; AHAM, No. 43, Whirlpool, No. 44) Stakeholders recommended that all but the last of these changes be adopted in the current test procedures (Appendices A1 and B1) as well as the test procedures that will be required for certification of compliance with the new energy standards starting September 15, 2014 (Appendices A and B). The recommendation for changing the default values of CT
L
and CT
M
applied only to the latter set of test procedures.
On January 25, 2012, DOE published a final rule setting out the test procedures for refrigerators and refrigerator-freezers (Appendix A) and freezers (Appendix B) that manufacturers must use starting in 2014. 77 FR 3559. In finalizing the test procedures, DOE considered the changes recommended by stakeholders, including recommendations for certain amendments to be made to the current test procedures found in 10 CFR 430.23
and in Appendices A1 and B1. DOE declined to make the recommended amendments for these appendices because the supplementary comment period DOE provided had explicitly focused solely on issues related to Appendices A and B. Aspects of Appendices A1 and B1 had already been settled and finalized with the December 2010 final rule.
Id.
at 3568-3571. Additionally, DOE declined to adopt certain changes recommended for Appendices A and B. DOE declined to adopt these suggestions because the nature of those recommendations had not, in DOE's view, been presented in a manner that would have afforded the public with a sufficient opportunity to adequately comment on those issues.
Id.
Nevertheless, after finalizing the rule setting out Appendices A and B, DOE reviewed these various suggestions and weighed their possible inclusion as part of the test procedure framework for refrigeration products. As a result of this review, DOE has decided to propose the inclusion of some of these recommended amendments in today's NOPR, including modified test procedures for products with multiple compressor systems, use of an alternative method for measuring and calculating energy use consumption at standardized temperatures for refrigerator-freezers and refrigerators with freezer compartments, and the modification of the anti-circumvention language currently found in these appendices.
Waivers
DOE has granted a limited number of petitions for waiver from the test procedures for refrigeration products since the publication of the December 2010 final rule. On January 10, 2012, DOE published a decision and order (D&O) responding to two waiver petitions from Samsung addressing products with multiple defrost cycle types. 77 FR 1474. That notice prescribed a procedure to account for the energy use associated with the multiple defrost cycles of a single-compressor-based system. The approach is identical to the procedure established for Appendix A in the January 25, 2012, final rule that manufacturers will need to follow starting in 2014. 77 FR 3559. DOE also issued a Decision and Order (D&O) that granted a waiver to GE Appliances (GE) to use the same test procedure for similar products.
See
77 FR 75426 (Dec. 20, 2012) (GE waiver). In effect, these waivers permit these companies to address certain products that cannot be readily tested or that otherwise would produce unrepresentative energy consumption measurements under the currently required test in Appendix A1.
DOE also granted a waiver to Sub-Zero, Inc. (Sub-Zero) to address that company's multiple-compressor products.
See
77 FR 5784 (Feb. 6, 2012) (Sub-Zero waiver). That waiver permitted Sub-Zero to use the same test procedure that AHAM had recommended that DOE adopt for both Appendix A1 and Appendix A. (Test Procedure for Refrigerators, Refrigerator-Freezers, and Freezers, Docket Number EERE-2009-BT-TP-0003; AHAM, No. 43 at pp. 2-3) Today's NOPR proposes to add a test procedure for multiple compressor products that is based on the Sub-Zero waiver procedure.
Finally, on August 16, 2012, DOE granted a waiver to Sanyo E&E Corporation (Sanyo) to address a hybrid refrigeration product,
i.e.,
a product combining wine storage compartments in a refrigerator. See 77 FR 49443 (Decision and Order granting Sanyo's petition (Sanyo waiver)). The waiver cites a guidance document that DOE published in February 2011, which indicates that products combining a wine storage compartment and a fresh food compartment are considered refrigerators and should be tested as such.
5
The waiver further explains that the Sanyo hybrid product cannot be tested with its wine storage compartment at the standardized temperature required for testing refrigerators using Appendix A1 (
i.e.,
38 °F), and that doing so would result in a non-representative energy use measurement. Hence, DOE granted Sanyo's request that it be allowed to test the product using a standardized temperature of 55 °F for the wine storage compartment.
Id.
5
This guidance is posted in DOE's online Guidance and FAQ database, and is available for viewing at
http://www1.eere.energy.gov/guidance/default.aspx?pid=2&spid=1
After granting a waiver, DOE waiver provisions generally direct the agency to initiate a rulemaking to amend its regulations to eliminate the continued need for the waiver. 10 CFR 430.27(m). Today's notice addresses this requirement for the Sub-Zero waiver by proposing to amend Appendix A to include a test procedure for multiple compressor products that is based on the Sub-Zero waiver procedure. The Sub-Zero waiver would terminate on September 15, 2014, the same date that manufacturers must use the test procedures in Appendix A for testing. The Samsung and GE waivers have already been addressed by the January 2012 final rule for products manufactured starting September 15, 2014. DOE does not currently anticipate that additional products on the market with single-compressor-based systems using multiple defrost cycles will be introduced prior to 2014, since it is DOE's understanding that this is a system design unique to those manufacturers who are currently covered by these waivers. Hence, at this time, DOE does not believe amending Appendix A1 to include this particular alternative test procedure is necessary. As for hybrid products such as the one identified by Sanyo, DOE will consider developing appropriate test procedures for these and similar products in a separate rulemaking.
See
77 FR 7547 (Feb. 13, 2012).
II. Summary of the Proposal
DOE's December 2010 and January 2012 notices made a number of changes to the previous versions of the test procedures. These changes included modifying the current procedure and creating a substantially revised procedure that manufacturers must begin to use when certifying and rating refrigeration products starting in 2014. While the final rules made a number of significant improvements to the test procedures, there remained some pending issues that DOE was unable to address. Today's notice attempts to address those remaining issues.
Some of the improvements proposed in this notice could be considered for implementation in the current test procedures as well as the procedures that will be required for certification starting in 2014. However, the current test procedures will continue to be used only for a limited time. Hence, DOE is not proposing to make any substantive amendments to these test procedures, which are contained in Appendices A1 and B1. (The proposal does, however, include amendments that would correct certain cross-references in these appendices to sections of 10 CFR 429). DOE requests comments on its proposed amendments to Appendices A and B, along with its tentative decision to refrain from applying this approach to the currently required Appendices A1 and B1.
The proposed amendments and issues on which DOE seeks public comment are summarized below.
First, DOE is soliciting comment on its proposal to incorporate laboratory-based test procedures for measuring energy use associated with automatic icemaking to replace the standardized value used to represent icemaking energy use that DOE adopted as part of the December 2010 test procedure interim final rule. See 75 FR at 78859 (Appendix A, sec. 6.2.2.1.) and 78871
(Appendix B, sec. 6.2.1.1.). Responding to DOE's preliminary analysis in 2009, a broad group of stakeholders agreed that DOE should regulate icemaking energy use as part of the refrigeration product energy conservation standards. The commenters recognized, however, that suitable test procedures were not yet available to allow their introduction in time for use with the 2014 energy conservation standards. (See Energy Conservation Standards for Refrigerators, Refrigerator-Freezers, and Freezers, Docket No. EERE-2008-BT-STD-0012; ACEEE, No. 46 at p. 1; and AHAM, No. 37 at p. 2) With this understanding, many of these stakeholders collaborated to submit a joint comment recommending that DOE conduct a rulemaking in 2012 to amend its refrigeration product test procedures to incorporate icemaking energy use. (Test Procedure for Refrigerators, Refrigerator-Freezers, and Freezers, Docket Number EERE-2009-BT-TP-0003; Joint Comment, No. 20 at pp. 5-6) AHAM submitted to DOE a “draft” version of this test procedure in January 2012. Later, in July 2012, it submitted a revised version of this earlier draft and recommended that DOE adopt it. (AHAM Draft Test Procedure, No. 4; and AHAM Revised Draft Test Procedure, No. 5)
6
6
DOE's proposal is more consistent with the revised AHAM test procedure than with AHAM's initial draft. However, it is instructive to consider the contrast between the initial and revised AHAM test procedures, since justification for certain complications present in the DOE proposal for testing products that cycle compressors during icemaking are best explained through comparison with the simpler, but potentially less accurate, method of the initial AHAM draft.
Today's notice solicits comment on an approach that would measure the energy use of automatic icemaking. That approach is based in part on the suggested approach from AHAM. Depending on the nature of any submitted comments, DOE may modify this approach. At this time, DOE is proposing that manufacturers would not be required to use this procedure until DOE amends the energy conservation standards for refrigeration products as part of the mandatory review required under EPCA. By linking this new measurement method with a new standards rulemaking, DOE can better ensure that all of these new requirements are coordinated within the context of a standards rulemaking (which would include any potential impacts related to icemaking energy use) and avoid any potential labeling issues that may arise, particularly since the new standards that DOE promulgated in 2011 will not be required for compliance purposes until 2014. See 76 FR 57516.
Further, DOE notes that manufacturers must base their written representations of energy usage on a new test procedure within 180 days of when the final rule for that procedure is published. See 42 U.S.C. 6293(c)(2). Given the upcoming transition to the new standards for 2014, it is possible that this requirement, if adopted, could lead to confusion as consumers attempt to understand the meaning of the reported values, particularly if the reported values differ between two identical models that may have been tested under different provisions. Additionally, manufacturers would need to adjust their testing and labeling to account for the new icemaking energy measurement protocol. In light of these concerns, it is DOE's tentative view that linking the timing of when manufacturers should begin using the icemaking energy use test method with the agency's statutorily-mandated review of the 2014 standards would reduce consumer confusion and minimize the overall burdens faced by manufacturers while ensuring that a viable procedure is in place for measuring the energy use from icemaking. DOE notes that if it should adopt this measurement procedure, it would use that procedure in evaluating potential adjustments to the energy conservation standards as part of the mandatory review. This two-step approach should help ensure a smoother transition to a potential new set of standards based on any icemaking energy use test that DOE may adopt. DOE also notes that if this procedure were adopted in the manner described above, a manufacturer seeking to use the new procedure earlier than required would need to obtain a test procedure waiver from DOE in advance of doing so.
Second, today's notice proposes to add test procedures for products with multiple compressor systems. These proposed procedures are based on the waiver granted to Sub-Zero on February 6, 2012. 77 FR 5784. They are proposed for inclusion only in Appendix A (i.e. procedures for these products required starting in 2014). The approach is not applicable to freezers and, hence, is not proposed for inclusion in Appendix B.
Third, the proposal would address two issues raised by commenters during the previous refrigeration product test procedure rulemaking. The first would make modest changes to the “anti-circumvention” language of 10 CFR 430.23, which is found in paragraph (a)(10) for refrigerators and refrigerator-freezers, and paragraph (b)(7) for freezers. This proposed amendment would help clarify product design and control system issues to ensure that the measurements from testing are accurate and representative of expected consumer use. The second would allow the optional use of a new, alternative method for measuring and calculating the energy use of refrigerator-freezers and refrigerators with freezer compartments. This method, commonly known as “triangulation,” may, for some products, provide a more accurate measure of energy use—notably, for products with control systems that are not balanced to simultaneously match the standardized temperatures of both the freezer and fresh food compartments at the same positions of the temperature controls for these compartments. Triangulation involves the use of an additional test conducted using a third temperature control setting. (Under Appendix A, only two temperature control settings are used to calculate the energy usage of a given refrigeration product.) The proposal would allow manufacturers to use this test as an alternative for certification if a manufacturer believed that the more comprehensive triangulation test would provide a more accurate measurement of energy use than the simpler, “two temperature-control-setting” method already provided in DOE's regulations. The proposal would also require that certification reports indicate whether triangulation has been used for testing. The NOPR proposes that triangulation be adopted in Appendix A. This test method is not applicable to freezers and, hence, is not proposed for inclusion in Appendix B. Additionally, while manufacturers would have the option of using either the two-part or triangulation test, DOE is proposing that it would use the triangulation test for assessment and enforcement testing in some cases.
Today's proposal also includes amendments associated with certification of compliance. First, it includes a proposal to eliminate the current requirement to report the height of refrigeration products in certification reports starting September 15, 2014. This information will no longer be necessary to classify products after this date, because the compact product classes will no longer have a height limit. See 76 FR 57515, 57538 (Sept. 15, 2011) and DOE Guidance (Oct. 6, 2011) regarding compact products,
http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/refr-frz_faq_2011-10-06.pdf.
This change in the certification report requirements of 10 CFR 429.14(b)(2) would, in DOE's
view, reduce the overall reporting burden faced by manufacturers. The proposal would also move the requirement to report whether a product has variable defrost or variable anti-sweat heaters from section 429.14(b)(3) to section 429.14(b)(2) to reflect that DOE intends for this information to be publicly available.
As a measure intended to reduce testing burden and potentially improve the accuracy of reported data, today's proposal would permit the use of volume calculations derived using computer aided design (CAD) tools in lieu of physical measurements of each basic model. To enable manufacturers to use this option, DOE is proposing changes to the requirements of Appendices A and B for measuring volume, adding a new section 429.72 establishing requirements applicable to volume measurement, and adding a process in a new section 10 CFR 429.134 for verifying the rated volume of a product. Finally, the references in section 5.1 of Appendices A and B to certification test reports would be corrected, changing references from 10 CFR 429.14 to 10 CFR 429.71.
The proposal also includes several clarifying amendments. These include: (a) Clarifying the term “incomplete cycling” as it applies to tested products and also modifying the test period for these products to ensure more accurate energy use measurement, (b) more specific instructions for setting mechanical temperature controls at their warmest and coldest settings, (c) clarifying the requirements for measuring ambient temperature and for maintaining ambient temperature gradients during testing, (d) establishing definitions for several commonly understood (but undefined) terms used in the test procedures, (e) a correction to the definition of the term “E” as used in section 6.2.2.2 of Appendix A to reference the proper section of the procedure, (f) required conditions for “connected” products during testing, (g) more specific instructions regarding the required clearance to the rear wall during testing, and (h) more specific instructions for relocation of interior components, such as shelving, to allow placement of temperature sensors in the required locations. In DOE's view, adopting these proposed amendments would improve test accuracy and would help ensure consistency when tests are carried out by different testing laboratories. These proposals, which are not expected to lead to any changes in measured energy usage, would be adopted in Appendices A and B.
Today's proposal also includes corrections to the temperature setting tables—Tables 1 and 2 of Appendix A and Table 1 of Appendix B. These tables would be modified in the CFR to properly reflect the intended temperature-setting progression from the initial test through the final test. The proposal would eliminate some horizontal lines in these tables to clarify the temperature-setting logic.
Further, DOE is seeking comments on a specific aspect related to built-in products, namely, whether testing these products in their built-in conditions would provide more representative and accurate energy consumption measurements. Under the current procedures, manufacturers are not required to test these products in a built-in condition. However, data recently collected by DOE, described in section III.D.1, suggest that some built-in products may yield different energy use measurements depending on whether they are tested in a built-in condition.
Finally, DOE has proposed amendments to address issues that DOE has identified through product testing. The first involves products with variable defrost, which are tested using provisions in Appendices A and B that are designed to account for variation in compressor run time between defrost cycles. DOE has observed in some cases that the actual minimum time between defrosts during testing was less than the minimum value reported to DOE in the model's certification report. To ensure that measured values of energy use are representative of the actual operation of models with variable defrost, DOE proposes to require use of the minimum observed compressor run time between defrosts if it is less than the certified value. The second proposal is to include more specific instructions regarding loading of packages in freezers, as required by Appendix B, which DOE believes will result in more consistent performance of this aspect of the test procedure.
The proposed amendments discussed in this notice would, if adopted, take effect 30 days after issuance of the final rule. However, manufacturers would be required to use the modified versions of Appendices A and B for rating products starting on the compliance date for the 2014 standards, which is September 15, 2014. 76 FR 70865 (Nov. 16, 2011). With the exception of the proposed test method for icemaker energy use, which would be addressed separately from the other proposed amendments to Appendices A and B, these changes either involve clarifications or provide alternatives to those methods that manufacturers already must use—or otherwise permit manufacturers to use a procedure that the industry has already largely developed and vetted. None of these amendments would, to DOE's knowledge, alter the measured energy use to any significant extent, and DOE does not anticipate that manufacturers will need to make substantial efforts to adjust to any of these proposed changes. With respect to the adoption of the proposed icemaker-related amendments for Appendices A and B, none of these changes would be required until DOE prescribes new or amended standards for refrigeration products. Until that time, manufacturers would continue using the fixed value approach prescribed in the regulations to account for icemaking energy use. Should these proposed amendments be adopted, manufacturers seeking to use this procedure prior to DOE's promulgation of new or amended standards would need to obtain a test procedure waiver in advance of doing so.
III. Discussion
This notice contains a number of proposed modifications to the refrigerator, refrigerator-freezer, and freezer test procedures, and DOE encourages stakeholders to submit comments on any aspect of these proposals. Comments are especially encouraged if stakeholders wish to provide supporting data, propose alternate approaches, and express support for (or objections to) DOE's tentative views on the issues discussed in this notice.
The following section discusses in further detail the various issues addressed by today's notice. Table III-1 below lists the subsections of this section and indicates where the proposed amendments, along with the potential icemaking energy measurement test that DOE is considering, would appear in each appendix. Section A identifies the products covered by the proposal; section B specifies the compliance dates that would apply to the proposed amendments; section C discusses the test procedure amendments; section D discusses testing of built-in products and requests comment on the discussion without proposing a test procedure amendment; and section E discusses compliance of the proposal with other EPCA requirements.
Table III-1—Discussion Subsections
Section
Title
Affected appendices
A
B
III.A
Products Covered by the Proposed Rule
No proposed changes.
III.B
Proposed Dates for the Amended Test Procedures
X
X
1
Icemaking Test Procedure
X
X
2
Multiple Compressor Test
X
3
Triangulation
X
4
Anti-Circumvention Language
*
5
Incomplete Cycling
X
X
6
Mechanical Temperature Controls
X
X
7
Ambient Temperature Gradient
X
X
8
Definitions Associated with Defrost Cycles
X
X
9
Elimination of Reporting of Product Height
**
10
Measurement of Product Volume ***
X
X
11
Corrections to Temperature Setting Logic Tables
X
X
III.C.12
Default Minimum Compressor Run-Time Between Defrosts for Variable Defrost Models
X
X
III.C.13
Treatment of “Connected” Products
X
X
III.C.14
Changes to Confidentiality of Certification Data
***
III.C.15
Package Loading
X
III.C.16
Rear Clearance During Testing
X
X
III.C.17
Other Minor Corrections
†
X
X
III.C.18
Relocation of Shelving
X
X
III.D.1
Built-In Refrigerators
No proposed changes.
III.D.2
Products that are Operable as a Refrigerator or a Freezer
1
Test Burden
2
Changes in Measured Energy Use
3
Standby and Off Mode Energy Use
* This amendment would appear in 10 CFR 430.23, but would affect testing using all four appendices.
** This amendment would appear in 10 CFR 429.14, but would affect certification reporting for products tested using Appendices A and B.
*** This amendment includes proposed modifications to 10 CFR 429.14.
†
This section also proposes an amendment to 10 CFR 430.2.
A. Products Covered by the Proposed Rule
Today's amendments cover those products that meet the definitions for refrigerator, refrigerator-freezer, and freezer, as codified in 10 CFR 430.2. The definitions for refrigerator and refrigerator-freezer were amended in the December 16, 2010 final rule. 75 FR at 78817 and 78848.
B. Proposed Dates for the Amended Test Procedures
This notice proposes amendments that would be made in sections 429.14 and 430.23 and in Appendices A and B.
The proposed amendments to sections 429.14 and 430.23 would be effective 30 days after publication of a final rule. Manufacturers would not be required to use the amended test procedures to rate their products until 180 days after issuance of the final rule.
See
42 U.S.C. 6293(c)(2).
Some of the proposed amendments that aim to improve measurement accuracy by clarifying certain aspects of the test procedures or to reduce test burden could potentially be considered for adoption in the current test procedures (
i.e.,
Appendices A1 and B1). However, these appendices are scheduled to be obsolete after September 2014, so DOE is not proposing to amend them. DOE requests comments on this approach.
The proposed amendments that would apply to Appendices A and B would be effective 30 days after issuance of a final rule, but manufacturers would not be required to use this procedure prior to September 15, 2014. Once that date arrives, however, Appendices A and B will be mandatory for making representations regarding the energy use or operating costs of refrigeration products. Manufacturers would be permitted to use Appendices A and B before this 2014 date if they choose to do so, provided that they indicate in their certification submissions that their ratings are based on Appendix A or B and that the products satisfy the 2014 standards.
As discussed in section I, this NOPR addresses the joint comments of a broad group of stakeholders who urged DOE to initiate a rulemaking to amend the test procedures for refrigeration products to incorporate a laboratory-based measurement of icemaking energy use. The joint comment further recommended that DOE publish a final rule by July 1, 2013, and amend the energy conservation standards scheduled to take effect in 2014 to account for the differences in measured energy use of icemakers when using the new test procedure as compared with the 84 kWh per year fixed placeholder value. (Test Procedure for Refrigerators, Refrigerator-Freezers, and Freezers, Docket Number EERE-2009-BT-TP-0003; Joint Comment, No. 20 at 5-6) However, as discussed in section 1, DOE has tentatively determined that its proposal to address icemaking energy use would not affect measured energy use to any significant extent. Hence,
DOE believes at this time that adjusting the energy conservation standards as suggested would not be necessary. Section 1 discusses DOE's preliminary assessment of the likely impact of the icemaking test procedure detailed in today's notice on energy consumption measurements. Supporting data are provided to help illustrate this impact.
As pointed out earlier, the proposed icemaking test procedure would not be required until DOE prescribes new or amended standards for refrigeration products. Until that time, manufacturers would continue using the fixed value approach currently prescribed in DOE's regulations to account for icemaking energy use. Should these proposed amendments be adopted, manufacturers seeking to use this procedure prior to DOE's promulgation of new or amended standards would need to obtain a test procedure waiver in advance of doing so.
C. Proposed Test Procedure Amendments
The following discussion addresses aspects of DOE's proposal to amend 10 CFR 430.23 and Appendices A and B. DOE seeks comment on all aspects of its proposal as described below.
1. Icemaking Test Procedure
Nearly all refrigerator-freezers currently sold either have a factory-installed automatic icemaker or are “icemaker-kitable”—
i.e.,
they are manufactured with the necessary water tubing, valve(s), and icemaker mounting hardware to allow quick installation of an automatic icemaker at any time after the product leaves the factory. Ice production increases the energy use of a refrigerator-freezer in two ways: (1) Some icemaker components (
e.g.,
the mold heater and the gear motor) consume energy, and (2) additional refrigeration is required to cool and freeze incoming water and to remove the heat generated by icemaker components (
e.g.,
the mold heater).
The current test procedure for refrigerators and refrigerator-freezers does not measure the energy use associated with ice production. Specifically, HRF-1-1979, section 7.4.2 (which is incorporated by reference into the current test procedures of Appendix A1) states, “Automatic icemakers are to be inoperative during the test”.
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In the May 2010 NOPR, DOE indicated that energy use associated with automatic icemaking represents 10 percent to 15 percent of the rated energy use of typical refrigeration products.
See
75 FR at 29846-29847 (May 27, 2010). As discussed in section I of this notice, stakeholders commented in response to DOE's presentation of its preliminary analysis supporting the recently completed energy conservation standard rulemaking that the test procedures and energy conservation standards for refrigeration products should address icemaking energy use (see, for example, Energy Conservation Standards for Refrigerators, Refrigerator-Freezers, and Freezers, Docket No. EERE-2008-BT-STD-0012; ACEEE, No. 46 at p. 1).
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DOE has published guidance documents clarifying how to render icemakers “inoperative” during a test. See, for example, “Additional Guidance Regarding Application of Current Procedures for Testing Energy Consumption of Refrigerator-Freezers with Automatic Ice Makers”,
http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/rf_test_procedure_addl_guidance.pdf.
However, stakeholders also commented that a test procedure to measure icemaking energy use had not yet been sufficiently developed. (Energy Conservation Standards for Refrigerators, Refrigerator-Freezers, and Freezers, Docket No. EERE-2008-BT-STD-0012; AHAM, No. 37 at p. 2: General Electric, No.40 at p. 1) To avoid delaying the energy conservation standard rulemaking, DOE published the new Appendix A test procedure and related energy conservation standard with a fixed placeholder energy use value of 84 kWh/year for products with automatic icemakers, to represent the average amount of energy consumed in ice production. 75 FR at 78842-78843 (Dec. 10, 2010) and 76 FR at 57538 (Sept. 15, 2011). (The 84 kWh/year value is equivalent to the 0.23 kWh/day value found in Appendices A and B, Section 6.2.2.1. That 0.23 kWh/day value is multiplied by 365 (see, for example, 10 CFR 430.23(a)(1)), which yields an annual consumption of 84 kWh/year.)
As part of the 2010 industry and efficiency advocate consensus agreement, AHAM agreed to develop an icemaking test procedure before January 1, 2012. (Test Procedure for Residential Refrigerators, Refrigerator-Freezers, and Freezers, Docket No. EERE-2009-BT-TP-0003, Joint Comment, No. 20 at p. 5).
Summary of AHAM's Initial Draft and Revised Draft Icemaking Test Procedures
A key aspect to determining annual energy use associated with icemaking is the average daily ice production. AHAM presented some information to DOE in late 2009 regarding this value in a document summarizing the status of its test procedure development work, titled “AHAM Update to DOE on Status of Ice Maker Energy Test Procedure—November 19, 2009”.
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(AHAM Ice Making Test Update, AHAM, No. 7 at p. 5). That document also included data suggesting that using a daily production rate of 1.8 pounds of ice per refrigeration product would be appropriate. This value was based on a total “sample size” of 155. However, the document did not elaborate further on the sample size other than to indicate that it had been derived using the combined data from three consumer surveys and three separate field tests.
8
Subsequently referred to as “AHAM Ice Making Test Update”.
In early January 2012, AHAM provided DOE with a draft of its icemaking test procedure, “AHAM Refrigerator, Refrigerator-Freezer, and Freezer Ice Making Energy Test Procedure, Revision 1.0—12/14/11”. (AHAM Draft Test Procedure, No. 4) That draft indicated that it applies to refrigerators, refrigerator-freezers and freezers, as defined in 10 CFR 430.2, that were equipped with a single automatic icemaker (including non-icemaker-equipped models that could be readily retrofitted with an optional automatic icemaker).
In July 2012, AHAM provided DOE with a revision of its icemaking test procedure, “AHAM Refrigerator, Refrigerator-Freezer, and Freezer Ice Making Energy Test Procedure, Revision 2.0—07/10/12”. (AHAM Revised Draft Test Procedure, No. 5) The AHAM Revised Draft Test Procedure applies to products that have one or more automatic icemakers. In addition, it includes several revisions to the AHAM Draft Test Procedure. The paragraphs below summarize the AHAM Revised Draft Test Procedure and highlight provisions from the AHAM Draft Test Procedure relevant to the detailed procedure on which DOE seeks comment.
The AHAM Revised Draft Test Procedure does not address the average ice production rate and does not include a value to apply when converting the measured icemaking energy use into a value of energy use per daily cycle. In contrast, the earlier AHAM Draft Test Procedure retained the current assumed 1.8-pound daily ice production rate through the use of an annual ice consumption value set at 657 pounds. Dividing this value by 365 days yields an ice production rate of 1.8 pounds per day. (AHAM Draft Test Procedure, No. 4 at pp. 7-8)
The AHAM Revised Draft Test Procedure would require an ambient test room temperature of 90 °F, which is consistent with the DOE procedures (
see, e.g.,
Appendix A, section 2.1). It
would also require target compartment temperatures of 39 °F for fresh food compartments and 0 °F for freezer compartments. These temperatures match the standardized temperatures prescribed by the DOE energy tests (see Appendix A, section 3.2 for refrigerator-freezers and Appendix B, section 3.2 for freezers). While the AHAM revised draft test does not mention the freezer compartment standardized temperature for refrigerators, which the DOE test sets at 15 °F (see Appendix A, section 3.2), it does indicate that its scope would extend to refrigerators.
See
AHAM Revised Draft Test Procedure, section 2.1.
In view of the above, DOE requests comment on whether any refrigerators (
i.e.,
“electric refrigerator” as defined in 10 CFR 430.2, and not a refrigerator-freezer) are sold with automatic icemakers (including non-icemaker-equipped models that could be readily retrofitted with an optional automatic icemaker). (DOE's review found none.) If so, DOE also seeks comment on whether test procedures for automatic icemakers should cover these “electric refrigerators” and to what extent, if any, the test procedure would need to be modified to accommodate the testing of these products. DOE is seeking comment on this issue in part to ascertain whether this aspect of today's proposal should apply to refrigerators as opposed to only refrigerator-freezers. DOE is currently unaware of any refrigerator that is sold equipped with an automatic icemaker.
The AHAM Revised Draft Test Procedure also does not mention whether the test procedure would apply to refrigeration products with manual defrost. Such products are tested with frozen food packages in their freezer compartments (see, for example, Appendix B, section 2.2 and HRF-1-2008, sections 5.5.3 and 5.5.5.3). Any icemaking test procedure would likely require that such products be tested with the frozen food packages removed, since some of the test operations, such as removing ice from the ice bin, may be impossible if the freezer compartment is full of packages. DOE requests comment on whether any manual defrost refrigerator-freezers or freezers are sold with automatic icemakers and whether any test procedure modifications would be required to address such products.
The AHAM Revised Draft Test Procedure specifies the use of target compartment temperatures, equal to the standardized compartment temperatures already prescribed in Appendices A and B, for a baseline test involving no icemaking. However, rather than following the DOE procedure of requiring tests to measure icemaking energy use at the median and cold (or warm) settings of the temperature controls and calculating energy use as a weighted average of the measurements at the two selected settings (see Appendix A, section 3.2.1), the AHAM Revised Draft Test Procedure, if adopted, would require that a single test be conducted with the temperature controls adjusted to achieve a compartment temperature within 2 °F of the target temperature. The temperature controls would not be adjusted further during the phases of the test in which the product is producing ice.
The AHAM Revised Draft Test Procedure would also require that the test setup be in accordance with the setup already prescribed by the DOE test procedure (or “DOE energy test”). It also specifies that the supply water for the icemaker must have a temperature range of 90 +/− 2 °F and a pressure range of 60 ±15 pounds per square inch gauge pressure (psig).
9
No further setup requirements are provided.
9
Gauge pressure is absolute pressure minus barometric pressure,
i.e.,
the pressure that a pressure gauge connected to the water supply piping would indicate.
In calculating the energy use per pound of ice produced, the AHAM Revised Draft Test Procedure would require subtracting the average energy use per day (in kWh/day) measured during a baseline test (during which the product is not making ice) from the average energy use per day (in kWh/day) measured during an icemaking test, and dividing the difference between the results of the two tests by the average rate of ice production (pounds per hour) during the icemaking test. This calculation would yield a final value in kilowatt-hours per pound (kWh/lb). The energy use for both the baseline and icemaking tests would be measured under the proposed procedures during steady-state operation and not during a defrost.
The test period for the baseline test could consist of at least seven hours of operation equivalent to the procedure for confirming steady-state conditions during the DOE energy test (see Appendix A, section 2.9). For products with cycling compressors, this test period would include two periods of at least two hours each, both comprising a whole number of compressor cycles, separated by one period of at least three hours. Although this test period is used only to confirm steady-state conditions in the DOE test procedure, the AHAM Revised Draft Test Procedure would also use this period as the test period for measuring energy use when the product is not making ice.
According to the AHAM Revised Draft Test procedure, the icemaking part of the test for products that do not cycle their compressors during icemaking would require a test period of at least 24 hours and consist of multiple complete icemaker cycles. If the test is interrupted by a defrost or if the ice storage bin fills before 24 hours have elapsed, the test period would be the maximum time between defrost cycles or the maximum time before the ice bin is filled with ice.
The AHAM Revised Draft Test Procedure would calculate icemaking energy use in products that cycle their compressors during icemaking differently from the initial AHAM Draft Test Procedure. Specifically, the AHAM Revised Draft Test Procedure would use a measurement of average ice production per hour that would be adjusted to account for differences in compressor run time of a first test period based on compressor cycles (which would be used to determine average energy use during icemaking) and a second test period based on icemaker cycles (which would be used as the basis for measuring the energy use per icemaking cycle and the mass of harvested ice). (AHAM Revised Draft Test Procedure, No. 5 at p. 8). The adjustment would be based on the two measurements of energy use associated with the two test periods. In contrast, the AHAM Draft Test Procedure relied on energy use and harvested ice mass measured for a single test period based on icemaker cycles, irrespective of whether the compressor cycles during icemaking (AHAM Draft Test Procedure, No. 4 at p. 7). The contrast between these two approaches is highlighted because, as discussed in more detail below, the approach DOE is considering would include the more comprehensive approach of the AHAM Revised Draft Test Procedure.
Under the AHAM Revised Draft Test Procedure, the final calculated result would be the incremental icemaking energy use per mass of ice in kilowatt hours per pound of ice. There would be no further conversion of this value into energy use per daily cycle or per year. In contrast, the AHAM Draft Test Procedure included a conversion calculation to yield an annual ice production rate. (AHAM Draft Test Procedure, No. 4 at p. 7-8)
Potential Approach Under Consideration
The approach DOE is considering for measuring icemaking energy use is based on the AHAM Revised Draft Test Procedure. It differs from that draft in
that the DOE approach would include greater detail to improve clarity and testing consistency. If adopted, DOE would likely add this icemaking energy measurement procedure as a new section 8 for both Appendices A and B. While this discussion touches on a number of key aspects related to the potential approach, DOE encourages interested parties to review it carefully and to comment on all of its aspects.
The key modifications DOE is considering compared with the AHAM test procedure would attempt to:
(1) Establish a definition for “ice piece” in addition to the definitions suggested by the AHAM Revised Draft Test Procedure.
(2) Clarify that the anti-sweat heater must be turned off during the icemaking test period, and that the water filter must be installed.
(3) Require that measurements be recorded during testing at time intervals not exceeding one minute.
(4) Clarify the points at which an icemaker cycle begins and ends. Many icemakers have mold heaters that are energized with 100W or more power input for more than a minute. This temporary increase in power is easily recognizable when evaluating the wattage data for a refrigerator test. Icemakers without mold heaters do not provide such an indication that one icemaking cycle has ended and the next has started. These icemakers would require the use of an alternative method to identify the beginning and end of icemaker cycles. The proposal would specify three alternative options: measuring the icemaker mold temperature, measuring the water supply temperature, or monitoring the activation of the water supply solenoid valve.
(5) Require that each compartment's average temperature during the baseline part of the test be no more than 1 °F warmer than its standardized temperature
(6) Require that each compartment's average temperature during icemaking be no more than 1°F (0.6 °C) warmer than its temperature during the baseline test, and require adjustment of temperature control settings if necessary to meet this temperature requirement. Also, the proposed test procedure would require products with a feature that automatically reduces the freezer compartment temperature setpoint or maintains compressor operation at an elevated duty cycle or speed during icemaking to be tested with this feature enabled.
(7) Prescribe the use of a baseline test period consistent with the test period specified in the DOE test procedure in Appendix A, section 4.1, rather than using the stabilization test period as the test period for baseline energy use calculation.
(8) Prescribe the use of equations that are equivalent, but not identical to, those of the AHAM Revised Draft, making more direct use of values measured during the test and involving fewer intermediate calculations.
(9) Apply a temperature stability criterion to the icemaking test period.
(10) Specify that icemaking would be initiated earlier than specified in the AHAM Revised Draft after completion of defrost.
(11) Address refrigeration products with multiple icemakers by requiring that such units be tested with only one of these icemakers operating during the test, rather than all of them simultaneously. The approach DOE is considering would also specify which icemaker to operate.
(12) Specify a daily ice production rate of 1.8 pounds per day in order to allow calculation of the contribution of icemaking to annual energy use. DOE is also considering requiring that products that cycle their compressors during icemaking would have their energy use calculated in a manner similar to the AHAM Revised Draft Test Procedure (
i.e.,
calculate energy use both for test periods comprising a complete (whole) number of compressor cycles and for test periods comprising complete icemaker cycles). The two calculations would be performed using the data from the same single icemaking test, as recommended in the AHAM Revised Draft. Using this approach would, in DOE's view, help improve measurement accuracy for the reasons described below.
Potential Icemaking Section
As noted above, DOE is considering incorporating an icemaking test based on AHAM's Revised Draft Test Procedure into Appendices A and B (
i.e.
the test procedures manufacturers must use starting in September 2014) by adding a new Section 8 to both appendices. Separating this new method from the other sections would, in DOE's view, help reduce the risk of confusion and improve the overall clarity of the procedures.
Icemaking Definitions
To help ensure clarity during testing, DOE proposes to add four definitions to provide background for the terminology that would be used in conjunction with whatever potential icemaking test procedure DOE adopts. Two of these definitions are identical to those used in the AHAM Revised Draft Test Procedure and are commonly understood in the industry but are currently undefined:
“Harvest” means the process of freeing or removing ice pieces from an automatic icemaker.
“Ice Storage Bin” means a container in which ice can be stored.
In addition, DOE proposes to define “Ice Piece” as a piece of ice made by an automatic icemaker and that has not been reduced in size by crushing or other mechanical action. Although people often refer to ice pieces as ice “cubes”, DOE proposes to use “pieces” instead to (a) avoid the suggestion that ice pieces must have a specific shape, and (b) avoid confusion with DOE's energy conservation standards for automatic commercial ice makers, which include a definition for “cube type ice”. (
See
10 CFR 431.132) DOE also notes that the AHAM Revised Draft Test Procedure does not use the term “cube” and has established the precedent of using the term “ice piece”, as seen in the definition for “harvest” discussed above.
Finally, since neither the test procedures in Appendices A and B nor the HRF-1-2008 test procedure specifically define the term “through-the-door ice/water dispenser” and because this term or similar terms are used both in the sections addressing measurement of ice making energy use and in the volume calculation method, DOE proposes to incorporate a definition for this term in both Appendices A and B to read as follows: “Through-the-door ice/water dispenser” means a device incorporated within the cabinet, but outside the boundary of the refrigerated space, that delivers to the user on demand ice or water from within the refrigerated space without opening an exterior door. This definition includes dispensers that are capable of dispensing ice and water, ice only, or water only.
DOE requests comment on these proposed definitions.
Anti-Sweat Heater Operation
To minimize test variation and potential error, particularly for products with variable anti-sweat heater control, the proposed procedure would require all anti-sweat heater switches to be in the “off” position for the test. Variable anti-sweat heater control is a feature that energizes the anti-sweat heaters only as much as needed, depending on ambient humidity and other conditions, to prevent the condensation of water vapor on the door gaskets and cool surfaces near them.
This requirement is proposed for two reasons: (1) To avoid the random activation of variable anti-sweat heaters
during testing should the ambient humidity levels in the test room vary during the test and (2) to help clarify the power input measurement of the test by removing the power consumption associated directly with anti-sweat heaters. Because random activation of variable anti-sweat heaters could add extra power consumption to one part of the test and not the other, complete removal of anti-sweat heater power use from the measurement may ease the interpretation of power consumption signals measured during the test. Hence, DOE proposes that the heaters be turned off both to avoid change in anti-sweat heater energy between portions of the icemaking test and to allow for better evaluation of the power input measurements that will be used to define test periods and the number of icemaker cycles—these factors would improve the accuracy and repeatability of the test.
A potential issue with this proposal is that it may be susceptible to circumvention by products that have an anti-sweat heater switch if the icemaker's operation is modified once the switch is turned off. For example, a manufacturer may be able to reduce icemaking energy use at a lower ice production rate by reducing fan and/or compressor speed when the switch is turned off, which would violate the anti-circumvention provision. An alternative proposal to address the potentially random activation of variable anti-sweat heaters would be to require that icemaking tests be conducted with the anti-sweat heater switch turned on and the test chamber humidity level set sufficiently low to prevent heater activation—this proposed change would apply to products without anti-sweat heater switches, as described below. However, this approach would add more testing burden, since it would require that all refrigerators with variable anti-sweat heating be tested in this fashion, which requires using test facilities capable of reducing humidity levels as needed. Another approach would be to require that humidity levels in the test facility be maintained within a narrow range for which the variation in energy use of any variable anti-sweat heater would be insignificant. However, this could also add significantly to test burden, since many existing test facilities do not have the necessary equipment to control humidity levels. If it subsequently becomes clear that some manufacturers are exploiting this flexibility in a manner that would yield unrepresentative measurements of energy use, DOE may implement one of the alternative proposals in a future rulemaking.
For products with variable anti-sweat heater control but with no anti-sweat heater switch, the proposal would require that the test be performed in an ambient condition with humidity levels sufficiently low to prevent the anti-sweat heater from being energized. The proposal would not specify the humidity level required to assure that the heater is not energized, which DOE expects would maximize testing flexibility and minimize the burden associated with meeting this requirement since not all variable anti-sweat heater control systems will start to energize the heaters at the same humidity level. Data regarding the humidity levels at which variable anti-sweat heater systems energize are provided to DOE by manufacturers of products with this feature in certification reports. (
See
10 CFR 429.14(b)(3)) These data suggest that this threshold humidity level is close to 35 percent relative humidity. DOE may consider the possibility of specifying an ambient humidity level depending on the nature of the feedback it receives in comments to this proposal.
DOE is aware of potential issues with its proposal for products with variable anti-sweat heater control but without anti-sweat heater switches and may consider alternative options to ensure that the objectives of the proposal are met. One potential issue is that some test facilities may not have the capability to sufficiently control humidity levels to assure that variable anti-sweat heaters would not be energized during testing. Based on DOE's review of available refrigeration products, every product examined that is equipped with a variable anti-sweat heater control also uses an anti-sweat heater switch. As a result, it is DOE's belief that, in spite of the potential inability of some existing test facilities to reduce humidity sufficiently to avoid variable anti-sweat heater activation, all or nearly all variable anti-sweat heater products can be readily tested using the proposed procedure by turning off their anti-sweat heater switches, which would reduce or eliminate the need for upgrades to testing facilities. Accordingly, DOE does not anticipate any new burdens associated with its proposed humidity requirements.
DOE requests comments on whether there are other alternative approaches it should consider to help ensure that random activation of variable anti-sweat heaters will not affect the accuracy of the measurements. DOE also seeks comment on the testing approaches it has proposed in today's notice to address this issue.
Setup for Icemaking
The test procedures in Appendix A and Appendix B do not require water lines or water filters to be connected or installed; they do, however, require the ice storage bin to be empty of ice. To properly execute the icemaking test that DOE is considering, DOE would revise sections 2.6(a) and 2.6(g) of Appendix A and sections 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 required only when conducting the icemaking test described in section 8;
(g) Ice storage bins shall be emptied of ice, except as required for the icemaking test described in section 8.
These modifications would ensure that testing would be conducted consistent with current practice when measuring the energy use not associated with icemaking, but would clarify that these requirements would change when conducting the icemaking test. Also, the new section 8 would indicate that water lines and water filters must be installed for the icemaking test.
DOE seeks comments on this approach.
Ambient Temperature and Water Inlet Specifications
Currently, DOE is considering requiring that the icemaking test be conducted in a 90 °F ambient condition, identical to the condition required by the current test. While this temperature is not a typical household condition, it is intended to account for the energy use associated with door openings and other thermal loads (e.g., cooling down warm food) that would occur during usage in a typical household environment (with an ambient temperature of approximately 70 °F), and its use in the DOE tests has been reaffirmed through rulemakings several times since DOE initially adopted the Appendix A1 and Appendix B1 test procedures in a final rule published August 10, 1982. 47 FR 34517. DOE would apply this condition to the icemaking test to reduce the complexity that would be incurred by imposing a different ambient temperature requirement. Using the same temperature will allow all tests to be conducted sequentially without waiting for the test chamber to adjust and stabilize at a different temperature.
Water inlet temperature affects the thermal load (
i.e.,
heat) that refrigeration systems must remove from the cabinet to make ice, and water inlet pressure could potentially affect the water
quantity that flows into the icemaker mold during each icemaker cycle. For the reasons that follow below, adopting the same inlet conditions specified in the AHAM Revised Draft Test Procedure (
i.e.,
90±2 °F inlet water temperature and 60±15 psig inlet water pressure) is also under consideration.
DOE recognizes that the water inlet temperature noted above is not consistent with typical household water supply temperatures. However, due to the intermittent flow of water supplying an icemaker, and the relatively long periods between successive fillings of the icemaker mold with water, the temperature of water entering the refrigeration product's water supply system will always be very close to the ambient temperature since most of the supply line is located outside the refrigerated cabinet. For example, the ice production rate of automatic icemakers in refrigeration products tested by DOE ranged from 4 to 5.5 pounds per day, with icemaker cycle times of an hour or more. Unless there is significant use of water for features other than icemaking, such as the water dispenser of a product with through-the-door ice and water dispensing, the water that will be supplied to the cabinet at the start of each icemaker cycle will have been stagnant in the supply tube of the product for at least one hour. This is sufficient time for the temperature of the supply water to equilibrate (
i.e.,
achieve balance) with the ambient air temperature, and the same equilibration will occur during an icemaking test.
Supplying water to the cabinet at any temperature other than ambient would require using a water temperature conditioning system located adjacent to the cabinet, or a recirculating loop to ensure that the supply temperature at the cabinet water inlet remains at a specified temperature other than the ambient temperature. DOE believes that requiring such a system would represent an undue test burden because specifying an inlet water temperature equal to a typical household ambient condition rather than 90 °F would have a limited impact on the overall test result. The heat that must be removed from the water to make ice at 0 °F (i.e. “Q”) is equal to the sum of three separate components: (a) The heat capacity of water (1 Btu/lb−°F) multiplied by the temperature reduction from the supply temperature down to 32 °F, (b) the heat of fusion of water (144 Btu/lb), and (c) the heat capacity of ice (0.5 Btu/lb−°F) multiplied by the temperature reduction from 32 °F to 0 °F. This value equals 218 Btu/lb for testing with a water inlet temperature of 90 °F—see below.
EP10JY13.028
In contrast, requiring an inlet water temperature of 72 °F, which would occur in 72 °F ambient conditions more typical for a household, the heat removed during icemaking would be 200 Btu/lb, only 8 percent less. Because the impact of using a 90 °F water supply temperature is modest and because the test burden associated with attempting to simulate a more typical household water supply temperature would be significant, the DOE proposal retains the water inlet temperature requirement, 90±2 °F, as specified in the AHAM Revised Draft Test Procedure.
DOE also recognizes that the pressure range under consideration is broad. However, refrigeration products are designed to be used in settings that can have a wide range of water supply pressures. For example, the installation instructions for a typical refrigeration product indicate that it can be used with water supply pressures ranging from 20 to 125 psig. See Typical Water Line Installation Instructions, No. 3 at p. 1 (providing instructions for installing the water dispenser line for a typical refrigeration product, including indication of the acceptable water pressure range). The quantity of water supplied for each icemaker cycle is regulated by the product to be within a narrow range regardless of the water supply pressure. Because these products are designed to operate consistently with a relatively wide range of water supply pressures, and because allowing the proposed range will reduce the potential need for test facilities to boost or reduce the pressure of the supply water, DOE may adopt the same wide range of allowable pressures as suggested in the AHAM Revised Draft Test Procedure. Adopting this approach would minimize the testing burden faced by manufacturers when compared with an equally viable alternative that would require testing facilities to fine-tune water pressure during testing.
DOE seeks comment on the approach discussed above regarding water temperature and pressure conditions.
Frequency of Measurement
DOE is considering requiring that the temperature, input power, and energy use measurements needed to evaluate steady-state conditions and calculate energy use be recorded at intervals not exceeding one minute. DOE is aware that most test facilities record data for refrigeration product energy tests at a frequency of once per minute. The current DOE test procedures allow a recording interval of up to four minutes (see, for example, Appendix A1, section 5.1.1). Because the icemaking test involves multiple recurring events (
i.e.,
icemaker cycles and compressor cycles) that are not synchronized, a shorter recording interval would improve the accuracy of the measurements. Additionally, updating the requirements to reflect the increased accuracy of the equipment routinely employed by test facilities would ensure that the procedure adequately accounts for the improved technology already used in the field. DOE believes that the test burden associated with this requirement, if any, would be insignificant since most, if not all, test facilities already use one-minute recording intervals during testing.
DOE requests comment on the requirement for this proposed limit on the data acquisition time interval and its assumptions.
Icemaker Cycle Indication
Determining the start and end of icemaker cycles is essential for the icemaking test in order to properly correlate ice production with the energy used to produce the ice. Most automatic
icemakers used in refrigeration products have a mold heater (or harvest heater) that is used to release ice from the mold. The input power measurements for the cabinet can readily be used to determine when this heater is energized, thus allowing for easy identification of the start and end of icemaker cycles.
The AHAM Revised Draft Test Procedure indicates that the icemaker harvest cycle test period starts and ends upon the initiation of harvest. (AHAM Revised Draft Test Procedure, No. 5 at p. 7) In contrast, DOE would define the icemaking cycle as starting and ending when the icemaker mold heater shuts off. DOE is considering this delineation between icemaker cycles to ensure that both the energy used to freeze the ice (which occurs prior to the harvest) and to operate the harvest heater are associated with the harvested ice for purposes of calculating overall energy use. DOE requests comment on this specification for icemaker harvest cycles.
DOE notes that icemakers in some refrigeration products use harvesting methods that do not involve mold heaters. One example is the “twist tray” icemaker, which has a plastic ice mold and employs a motor that rotates one end of the ice mold at slow speed, turning the mold upside-down, and then twisting the mold as the rotation is stopped by a catch at the mold's other end, thus releasing ice into the ice storage bin. To address icemakers of this type, and future designs that may be able to harvest ice without mold heaters, DOE would require one of three alternative methods to be used to determine when ice is harvested, since the examination of the power input data may not reliably reveal the time of harvest.
The three alternative methods under consideration are: (1) measuring mold temperature, (2) measuring water supply temperature, or (3) detecting actuation events of the icemaker water supply solenoid valve. Each of these methods would provide an equally reliable and readily identifiable indication of when water for the next batch of ice flows into the mold. Hence, DOE would define icemaker cycles for these methods based on when the given method indicates that water starts flowing or has entered the mold.
In addition, each of these methods has certain practical advantages that readily lend themselves to being appropriate indicators of ice harvesting. The ice mold temperature can reliably indicate the occurrence of ice harvesting because it rapidly rises when the solenoid valve dispenses warm water into the ice mold. Similarly, the water supply temperature can reliably indicate ice harvesting because the solenoid valve must dispense water into the ice mold for every round of ice production. Although water supply temperatures must remain in the 90 ± 2 °F range at all times during the test, the temperature of water in the inlet tube typically may change slightly during the filling of the icemaker mold due to temperature gradients within the test laboratory. If this change in water supply temperature is large enough, for example greater than 0.5 °F, this temperature change could be used to indicate the start of an icemaker cycle. NIST test data show a shift in water inlet temperature of roughly 0.9°F (0.5 °C) when the solenoid valve opens during testing of a refrigerator that has an icemaker without a mold heater. (NIST Technical Note 1759, No. 6 at p. 22-23) Finally, monitoring of the solenoid valve input voltage, current, or power will indicate that a new harvest cycle has started because the solenoid valve must be energized to supply water to the icemaker mold. To accommodate differences in individual product design or laboratory instrumentation capabilities which may favor one method over another, and because DOE sees no apparent difference in precision among these three methods, DOE proposes to include these three approaches and require that one of them be used if the icemaker has no mold heater. Further, the approach would require that the test report state in these cases which of these methods is used.
DOE requests comment on the proposed requirement to monitor harvest cycles if the product does not have a mold heater, the details of the three proposed alternate methods to accomplish this monitoring, and the proposed requirement that the test report indicate which one of these three methods was used. DOE further requests comment on whether other alternative methods could be used and/or should be allowed in the test procedure, including details of these alternative methods. DOE also seeks comment on whether it should specifically identify when one of these three alternative approaches must be used.
DOE's method would also clearly specify the start and end points of icemaker cycles for icemakers without mold heaters. As mentioned above, under the proposal, these time periods would occur when the mold heater is de-energized for products with mold heaters. For products without mold heaters, the proposed test procedure would indicate that the start and end points would occur when frozen ice drops into the ice storage bin and/or at the initiation of water flow into the icemaker mold. DOE requests comment on this proposed specification.
Control Settings
DOE would adopt generally the AHAM Revised Draft Test Procedure's requirement to use a single compartment temperature setting for the baseline test and the icemaking test, rather than specifying separate tests at median and warm or cold settings. Following this approach would limit the overall test burden faced by manufacturers.
However, DOE is concerned that significant differences in compartment temperatures between the baseline and icemaking tests could result in unrealistic indications of icemaking energy use. In particular, if the temperature of either compartment rises significantly during the icemaking test, the portion of the measured energy use associated with maintaining compartment temperatures would decrease significantly, which could potentially result in a value of energy use associated with icemaking that is lower than the actual amount. The AHAM Revised Draft Test Procedure approach would treat any such deviation in temperature between baseline and icemaking operation for fixed positions of the temperature control settings as typical for operation in the field, since homeowners are not expected to adjust temperature control settings when the icemaker starts making ice. (AHAM Revised Draft Test Procedure, No. 5 at p. 5)
However, DOE notes that there are some distinct differences between icemaking in the laboratory and icemaking in the field that weigh in favor of making temperature adjustments in some circumstances. First, the icemaking test would be conducted with no load in either the freezer or fresh food compartment, while a refrigerator in the field would generally be stocked with food. This load in a typical refrigerator, acting as a thermal mass, significantly dampens variations in compartment temperatures during icemaking. In an icemaking test conducted in a refrigeration product without any loaded food products, the compartment temperature could respond much more rapidly to the added load associated with icemaking.
Second, the icemaking test would be conducted with the icemaker operating at full capacity, meaning that for the entire icemaking test period, it would continually produce successive batches of ice without stopping. In contrast, in the field, continuous icemaking would typically occur only for the initial filling of the bin, and successive icemaker
cycles would occur after a portion of ice has been withdrawn from the ice bin. The comparison of daily ice production with the ice production rate of tested refrigerators discussed in the following paragraph helps illustrate this point.
AHAM's ice production value of 1.8 pounds per day represents typical daily average ice production (AHAM Ice Making Test Update, No. 7 at p. 5). DOE compared this value to measured icemaking production rates when typical refrigerators operate continuously. The production rates measured by the National Institute of Standards and Technology (NIST) for four tested residential refrigerator-freezers ranged from 3.7 to 10.6 lb/day, at least double AHAM's average daily production rate. (NIST Technical Note 1697, No. 6). Hence, even the icemaker of this test with the lowest production rate would operate less than half a day to produce the amount of ice specified by the AHAM estimate (1.8 lb/day). This means that the product does not continually make ice and would have time to recover compartment temperatures between icemaker cycles. As a result, even if the compartment temperatures rise slightly during icemaking, they could recover to their “baseline” levels before the next icemaker cycle starts.
The tendency of the food product thermal mass to limit the compartment temperature rise that could occur during icemaking and the ability of the system to recover to steady state temperatures between icemaking cycles suggests that the average increase in cabinet temperatures during icemaking in the field may be significantly less than would occur for a laboratory test of continuous icemaking in an empty cabinet. This observation casts significant doubt on the premise of the AHAM position that the compartment temperature rise in the field would be comparable to that in the test, and likewise casts doubt on AHAM's suggestion that allowing the temperature to rise in this fashion during the test would lead to energy use measurements for icemaking that are representative of field operation. For these reasons, DOE believes that a laboratory-based icemaking energy use measurement for a product whose temperatures drift upwards during icemaking would be more representative of field energy use if an adjustment were made during the icemaking portion of the test to ensure that the compartment temperatures are no warmer than their temperatures measured during the baseline test, perhaps within a 1 °F allowance. Hence, DOE's approach would require controls to be adjusted to cooler settings during the icemaking portion of the test, if necessary, to ensure that the compartment temperatures are no warmer than 1 °F above their averages during the baseline test.
DOE selected this 1 °F maximum compartment temperature rise between the baseline and icemaking tests by considering the one percent maximum threshold for uncertainty discussed in the section above and reviewing the results of icemaking tests conducted by NIST (NIST Technical Note 1697, No. 6; NIST Technical Note 1759, No. 8). Test Samples 3 and 4 of NIST Technical Note 1697 and Test Samples 1 and 2 of NIST Technical Note 1759 were tested using an icemaking test procedure consistent with the approach under consideration but using three sets of temperature control settings for the baseline and for icemaking portions of the test rather than the single set being proposed. The results obtained using the three temperature control settings permit one to calculate the results that would be expected for any desired combination of compartment temperatures close to those measured during the tests—these results can be calculated using the triangulation approach. See section III.C.3. DOE used this approach to calculate total annual energy use, including the energy use associated with icemaking for the tested samples, for compartment temperature conditions matching the standardized temperatures (0 °F in the freezer and 39 °F in the fresh food compartment), and for conditions in which either the fresh food or freezer compartment temperature shifts 1 °F or 2 °F from its standardized temperature during the icemaking test. (Assessment of Icemaking Test Temperature Control Setting Tolerance, No. 9). The results of the calculations are summarized in Table III-2 below.
Table III-2—Impact on Energy Use of Shift in Compartment Temperature During Icemaking
Product class
Change in annual energy use
2011 Sample 3
5A
(percent)
2011 Sample 4
5A
(percent)
2012 Sample 1
5
(percent)
2012 Sample 2
5
(percent)
Fresh Food Compartment Temperature Change
−2 °F
+0.4
+0.3
+0.1
+13.5
−1 °F
+0.2
+0.1
+0.1
+6.6
+1 °F
−0.2
−0.1
−0.1
−6.3
+2 °F
−0.4
−0.3
−0.1
−12.3
Freezer Compartment Temperature Change
2 °F
+1.2
+3.5
+1.8
-1.5
−1 °F
+0.6
+1.7
+1.0
−0.8
+1 °F
−0.6
−1.5
−1.0
+0.9
+2 °F
−1.3
−2.9
−2.1
+1.8
“2011” samples are those discussed in NIST Technical Note 1697, while “2012” samples are those discussed in NIST Technical Note 1759.
The calculations reflected in the above table show that the 1 °F shift in compartment temperature during icemaking can change the annual energy use measurement by as much as 6.6 percent. However, this extreme case occurred for the one test sample among the group of four that is not typical of most products in the U.S. market. (NIST Technical Note 1759, No. 8 at p. 20) The calculated annual energy use results for the other three products showed little sensitivity to temperature shifts in the fresh food compartment during the icemaking test. One of the test samples
showed a calculated change in annual energy use as high as 1.7 percent when the freezer compartment temperature shifted 1 °F. This change would yield a variation of 11 kWh over an entire year—the annual energy use of this product was calculated to be 671 kWh assuming all compartment temperatures match their standardized temperatures during all tests. This analysis shows that even the 1 °F compartment temperature tolerance that DOE has considered for the icemaking test leads to overall measurement uncertainty larger than the desired one percent threshold discussed in the section above.
On the other hand, limiting compartment temperature variation to less than 1 °F between the baseline and icemaking tests could pose considerable test burdens because of the potential difficulty of achieving such tight control for both compartments of a refrigeration product. To mitigate these burdens, DOE would allow an increase in compartment temperatures of no more than 1 °F between the two tests, and would not impose a lower limit on the compartment temperatures for the icemaking test. In cases where the compartment temperature increases for the icemaking test, DOE would require adjustment of the temperature control to the warmest settings for which the compartment temperature is no more than 1 °F warmer than measured during the baseline test.
DOE's method would not allow disabling of “quick freeze” operation during icemaking for products that use this feature to accelerate icemaking. Quick freeze is an operating mode that, when selected by the user, runs the compressor without stopping for a specified interval in order to rapidly reduce the compartment temperature (see Appendix B1, section 1.9). DOE tested a product with a control system that automatically activated a “quick freeze” operation whenever the product was making ice. Such a product clearly would be incurring additional energy use associated with continuous compressor operation during icemaking in the field. Hence, DOE would require that such control features remain active (not disabled) during the icemaking test.
Additionally, the AHAM Revised Draft Test Procedure contained a requirement that compartment temperatures be within 2 °F of their standardized temperatures for the baseline test, and that if both the freezer and fresh food compartments cannot be maintained in this range, then the freezer compartment must be maintained in this range and the fresh food compartment must be maintained as close to this range as possible (AHAM Revised Draft Test Procedure, No. 5 at p. 5). DOE conducted an analysis using the NIST icemaking test data discussed above to determine the impact of deviation in compartment temperatures from their standardized temperatures for the baseline test. The analysis, summarized in Table III-3, shows that the 2 °F allowance can result in an increase in the total annual energy use measurement of 2 percent or more. (Assessment of Icemaking Test Temperature Control Setting Tolerance, No. 9) Hence, DOE considered proposing a tighter tolerance of 1 °F, which, for most products, would limit the variation on the total annual energy use measurement to roughly one percent. However, DOE recognizes that the precision with which compartment temperatures can be set during testing may be insufficient to use a 1 °F tolerance. In recognition of this limitation, DOE would require temperature controls to be set during baseline testing in the warmest settings for which the compartment temperatures are no more than 1 °F warmer than their standardized compartment temperatures. Using this approach would mean that the fresh food and freezer compartment temperatures would be no warmer than 40 °F and 1 °F, respectively, during the baseline test.
Table III-3—Impact on Energy Use of Deviation in Compartment Temperature from Standardized Temperatures
Product class
Change in annual energy use
2011 Sample 3
5A
(percent)
2011 Sample 4
5A
(percent)
2012 Sample 1
5
(percent)
2012 Sample 2
5
(percent)
Fresh Food Compartment Temperature Deviation from 39 °F
−2 °F
−0.1
−0.1
−0.4
+1.5
−1 °F
−0.1
0.0
−0.2
+0.7
+1 °F
+0.1
0.0
+0.2
−0.7
+2 °F
+0.1
+0.1
+0.4
−1.4
Freezer Compartment Temperature Deviation from 0 °F
2 °F
+0.7
+2.3
+0.4
−0.6
−1 °F
+0.4
+1.1
+0.2
−0.3
+1 °F
−0.4
−1.0
−0.2
+0.4
+2 °F
−0.7
−1.9
−0.5
+0.8
“2011” samples are those discussed in NIST Technical Note 1697, while “2012” samples are those discussed in NIST Technical Note 1759.
As discussed above, DOE is considering using the warmest temperature control settings that satisfy the compartment temperature requirements for the baseline and icemaking tests. By preventing the use of excessively cold settings, this approach would help to ensure consistency between tests conducted by different laboratories. For products with mechanical temperature controls, DOE proposes requiring that the temperature settings be those for which the temperature setting indicator aligns with a control symbol. This provision will prevent setting the indicator at undefined positions between the symbols and thus will also help to ensure consistency between tests conducted by different laboratories.
DOE requests comment on all aspects of its approach regarding temperature settings.
Test Periods
DOE is considering using an approach that would modify the test periods
suggested in AHAM's Draft Test Procedure in two key ways. The proposal would include: (a) A test period for the baseline test that is more consistent with the existing DOE test procedure and (b) an energy use calculation based upon two test periods for products that undergo compressor cycles during icemaking. The first of these proposed changes diverges also from the AHAM Revised Draft Test Procedure, while the latter one is consistent with the more recent AHAM approach.
Baseline Test Period
The AHAM Revised Draft Test Procedure would allow use of the stabilization test period for measuring baseline energy use. In contrast, DOE is proposing that the stabilization and energy measurement test periods be defined as they are in the DOE test procedure (see, for example, Appendix A, sections 2.9 and 4.1). However, in order to minimize testing burden, DOE is proposing to permit the overlap of these test periods in order to avoid the three or more hours of additional test time that would be required if no overlap were allowed. The proposal would permit this overlap only if the baseline test period ends no later than the stabilization test period ends.
Icemaking Test Period
For products that do not cycle their compressors during icemaking, there is no potential distinction between compressor cycles and icemaker cycles. For such products, DOE is considering adopting the same icemaking test period suggested in both the initial and revised AHAM Draft Test Procedures. This test period would incorporate a complete (whole) number of icemaker cycles, beginning when the first of these cycles starts and ending with the completion of the last cycle.
On the other hand, for products that cycle their compressors during icemaking, DOE considered whether energy use measurements should be based on compressor cycles or icemaker cycles. The initial AHAM Draft Test Procedure suggested a test period based on icemaker cycles for the icemaking portion of the test, but AHAM later altered this approach in its revised draft, suggesting instead that both compressor and icemaker cycles be part of the test period. NIST reviewed several icemaking test procedure approaches and concluded that average power input is a much stronger function of compressor cycles than icemaker cycles. (NIST Technical Note 1759, No. 8 at p. 48) Hence, when subtracting the average power of the baseline test from the average power of the icemaking test, as is done to determine the energy use associated with icemaking (AHAM Draft Test Procedure, No. 4 at p. 7), a much more stable and repeatable result is attained if the average power is calculated for a test period based on compressor cycles.
In contrast to the average power input during icemaking, the ice mass must be correlated with the icemaker cycles rather than with compressor cycles because ice production occurs in batches that are harvested at the end of icemaker cycles. Furthermore, the NIST work shows that, assuming the product is in stable operation during icemaking, the energy use per icemaker cycle stays relatively constant, even though the time between harvests may vary. NIST recommended an approach that calculates average power based on compressor cycles and average energy use per pound of ice produced using the same test data. Without increasing test time, the approach improves accuracy and repeatability in determining the energy use associated with ice production, as compared to the use of the same calculation based only on icemaker cycles. NIST's suggested calculation of energy use expended per pound of ice produced, abbreviated as EIM, in kilowatt-hours per pound, can be expressed as follows:
EP10JY13.029
Where:
PI3 is the icemaking test average power input in Watts, measured based on compressor cycles;
PI1 is the baseline test average power input in Watts;
EPI2 is the energy use in kilowatt-hours, measured based on icemaker cycles;
M
ICE_CYC
is the mass of ice in pounds produced per icemaker cycle; and
N
CYC
is the number of icemaker cycles in the test period associated with the energy measurement EPI2.
This equation uses the icemaking test average power based on compressor cycles (the more stable test period for measuring average power) when subtracting the average power of the baseline test. This approach of using the more stable power measurement based on compressor cycles in the calculation helps to minimize the potential error associated with the measurement, since any variation in the measurement of PI3 is amplified by subtracting the baseline test average power PI1. However, to maximize accuracy, the calculation must also use the measurement based on the icemaker cycles, since the energy use measurement based on compressor cycles is not correlated to the ice production. The improvement in accuracy afforded by this approach is illustrated in Table III-4 below, which shows test data for an icemaking test for a 22 cu. ft. refrigerator-freezer with a bottom-mounted freezer and no through-the-door ice service. The table compares successive icemaker cycles from results based on the AHAM Draft Test Procedure against those results obtained using the NIST-recommended approach of the AHAM Revised Draft Test Procedure. The data show that it takes more than roughly 15 icemaker cycles for the results of the two tests to be consistently close to each other.
The data also indicate that test results using the AHAM Draft Test Procedure fluctuate between icemaker cycles during testing, indicating that this test method's accuracy depends on whether the test period ends on a cycle that happens to experience no fluctuations—an extremely unlikely event based on the inherent variability built into the AHAM Draft Test Procedure. In cases where the test must terminate early due to the filling of the ice storage bin or initiation of a defrost, the test would end and the error would not be corrected by the additional icemaker cycles exhibited for this test. Because of its significantly improved accuracy over the AHAM Draft Test Procedure, and the absence of any increase in testing time, DOE is considering the approach recommended by NIST that the AHAM Revised Draft Test Procedure ultimately adopted for products with cycling compressors during icemaking.
Table III-4—Comparison of Draft AHAM and NIST Icemaking Test Results
Icemaker cycle No.
Cumulative energy use per ice produced
(kWh/lb)
AHAM Draft Test
NIST recommended test
(AHAM revised draft)
1
0.010
0.165
2
0.151
0.186
3
0.192
0.189
4
0.148
0.191
5
0.177
0.191
6
0.194
0.192
7
0.169
0.192
8
0.186
0.193
9
0.196
0.193
10
0.178
0.193
11
0.189
0.193
12
0.194
0.193
13
0.180
0.192
14
0.188
0.192
15
0.194
0.192
16
0.182
0.192
17
0.189
0.192
18
0.194
0.192
19
0.184
0.192
20
0.191
0.193
21
0.193
0.193
In light of these recorded data, DOE seeks comment on whether the NIST approach it is considering would be reasonably sufficient for purposes of assessing icemaking energy use.
Icemaking Test Stability
The AHAM Revised Draft Test Procedure does not require temperature stability during the icemaking portion of the test. DOE has tested a product that significantly reduces its freezer temperature during icemaking, from 0 °F to roughly −12 °F. This reduction in temperature requires three to four icemaker cycles to occur. During the initial reduction in freezer compartment temperature, the energy use per icemaker cycle was much higher than after the compartment temperature stabilized, starting at 0.28 kWh/lb and dropping to 0.20 kWh/lb. A test that included the initial icemaker cycles, during which the compartment temperature was dropping significantly, would have resulted in a significantly higher measurement of icemaking energy use. The data also showed that selecting a temperature stability threshold of 3 °F (i.e. the maximum allowable variation for the freezer compartment temperature from its average during the selected test period) is sufficient to reduce the potential error to less than one percent of the product's overall energy use. (Examination of Icemaking Test Period Stability, No. 10) These test data show that a stability requirement for the icemaking test is important in order to obtain repeatable results. Hence, DOE is weighing whether to include a requirement that the temperature for the freezer compartment remain within 3 °F of the compartment's temperature average for the full test period for the icemaking part of the test. For products with non-cycling compressors, the proposal would apply this requirement by comparing the freezer compartment temperatures for complete icemaker cycles. For products with cycling compressors, the requirement would be applied by comparing average temperatures for complete compressor cycles and would also be applied to the freezer compartment.
DOE seeks comment on this potential approach.
Duration of the Icemaking Test Period and Initiation of Icemaking
The AHAM Revised Draft Test Procedure would require test periods lasting 24 hours, if this is possible during steady icemaking operation between defrost cycles, and that the ice storage bin be able to hold 24 hours of ice production. The AHAM Revised Draft Test Procedure also specifies that if 24 hours of icemaking operation are not possible between two defrost cycles, the icemaker would be enabled after the product has recovered from a defrost. DOE would adopt nearly identical requirements for the test duration and initiation of test, except that the DOE approach would specify that icemaking should be initiated shortly after the start of compressor operation following a defrost cycle. The DOE approach would reduce the overall testing time compared to the AHAM Revised Draft Test Procedure approach because the AHAM approach may lead to the start of a second “recovery” period after the initiation of icemaking, since the cabinet temperatures may shift after icemaking starts. The shifting of these temperatures would require additional time for the unit under test to reach the new steady operating condition.
DOE seeks comment on these potential durations and initiation periods.
Ice Mass
Measuring the ice mass produced by a test sample is a necessary prerequisite to determine the energy use required per pound of ice produced. The AHAM Revised Draft Test Procedure requires that the amount of ice produced during the test be determined by weighing the ice storage bin with the ice in it and subtracting the weight of the empty ice storage bin. It would also provide that the weight measurement must not include the ice harvested prior to the test period or after the initiation of the
last harvest cycle. (AHAM Revised Draft Test Procedure, No. 5 at p. 8)
To properly correlate total ice production with the test period used for the energy use measurement, DOE's approach would require calculating the mass of ice produced per icemaker cycle in pounds. This value would be multiplied by the number of icemaker cycles within the test period in the equation used to calculate energy use per pound of ice produced (see the equation for EIM above). This approach would enhance test accuracy by explicitly assuring proper correlation of ice production with the test period used for measuring energy use.
DOE seeks comment on its potential approach.
Products with Multiple Icemakers
DOE is aware of very few refrigerator models with multiple icemakers. The only such products of which DOE is aware are French Door refrigerator-freezers with one icemaker serving a through-the-door ice dispenser and a second icemaker located in the bottom-mounted freezer compartment. The AHAM Draft Test Procedure did not address multiple icemaker products. (AHAM Draft Test Procedure, No. 4 at p. 4) However, the AHAM Revised Draft Test Procedure included methods for testing products with multiple icemakers. Specifically, the test would require that all icemakers make ice during the icemaking part of the test. (AHAM Revised Draft Test Procedure, No. 5 at p. 10) The icemaking test would continue for 24 hours, until interrupted by a defrost, or until all ice bins are full.
For products with one icemaker serving a through-the-door dispenser and another that does not, DOE is considering requiring that manufacturers account for icemaking energy use by measuring the energy consumption only for the icemaker serving the through-the-door dispenser. This approach would minimize the testing burden while providing a measurement of energy use that should be reasonably representative of actual usage since the icemaker serving the through-the-door dispenser would likely be more frequently used. This expectation of more frequent use of the through-the-door icemaker is based on the fact that this ice is much more convenient for consumers to access. Taking this approach would also make the test simpler to perform. As discussed above, one of the complications of measuring the energy use associated with icemaking is the lack of coordination between icemaker and compressor cycles. The test approach described above is a compromise that balances the need for accuracy and the need to limit test burden by using two test periods based on the same icemaking test. If two icemakers were operating, the test procedure would have to address the non-synchronized cycles of two icemakers and the compressor. The AHAM Revised Draft Test Procedure does not fully address how this issue should be handled other than indicating that icemaking for both icemakers would be initiated after recovery from defrost and that the test may continue until
both
ice bins are full. Because of these unresolved complications and DOE's expectation that most of the ice would be produced by the icemaker serving the through-the-door feature, DOE's approach would involve testing only this icemaker. DOE seeks comment on its tentative approach and expectations.
Additionally, DOE's approach would not address other configurations of products with multiple icemakers. As a result, DOE seeks comment on (a) whether any such products exist or are likely to exist, (b) what their configuration details might be, and (c) what test procedure modifications should be developed to address these products.
Ice Production Rate
DOE initially obtained ice production rate information from AHAM, based on available survey data it reviewed. That data indicated that 1.8 pounds per day would be a representative ice production rate. (AHAM Ice Making Test Update, No. 7 at p. 5). DOE used this production rate as the basis for the fixed icemaking energy use placeholder it adopted in the Appendix A and B test procedures. 75 FR at 78842-3 (Dec. 16, 2010).
Subsequently, NEEA sponsored a field study that monitored daily refrigerator energy use, kitchen ambient temperature, and the number of icemaking harvest cycles for refrigerators at 80 sites. (NEEA Icemaking Field Study Data Summary Spreadsheet, No. 11). The study showed that the average number of icemaking cycles per day for the field test sites was 3.3 cycles/day. The spreadsheet did not include data indicating the mass of ice produced per icemaking cycle for any of the test sites. Hence, calculating the average ice production per refrigerator per day requires applying a representative value of ice production per icemaking cycle to the NEEA data. Values of this parameter measured during tests conducted by DOE and NIST are summarized in Table III-5 below. The average of these measurements is 0.21 lb/cycle. Multiplying the 3.3 cycles/day of the NEEA study by this average gives an average daily ice production rate of 0.7 lb/day.
Table III-5—Ice Production per Icemaking Cycle
Data Source
Product class
Ice
production
(lb) per cycle
NIST 2011 Sample 1
3
0.31
NIST 2011 Sample 2
7
0.21
NIST 2011 Sample 3
5A
0.15
NIST 2011 Sample 4
5A
0.12
NIST 2012 Sample 1
5
0.2
NIST 2012 Sample 2
5
0.15
DOE Sample 1
7
0.19
DOE Sample 2
3
0.26
DOE Sample 3
5A
0.26
Average
0.21
“NIST 2011” samples are those discussed in NIST Technical Note 1697, “NIST 2012” samples are those discussed in NIST Technical Note 1759, and “DOE” samples are those tested by DOE.
The NEEA data suggest that daily ice consumption rate may be half of the 1.8 lb/day initially selected for the test procedure. However, the field study was limited to sites in the northwest region of the United States and its representativeness as a national average ice production rate is not certain. The 1.8 lb/day value was initially proposed by AHAM as a representative value based on its own testing, and DOE has insufficient information about the details of its development to question its validity. Hence, DOE is considering retaining the 1.8 lb/day production rate for use in the test procedure.
Impact of the Icemaking Test Procedure on Energy Consumption Measurement
DOE conducted testing to validate the feasibility of its potential icemaking test procedure. The test results can be examined to determine if they suggest that icemaking energy measurements using the proposed test procedure would differ significantly from the 84 kWh/year fixed value currently used in Appendices A and B. As noted above, this annual energy use is based on a daily production rate estimate of 1.8 lb/day (1.8 lb/day multiplied by 0.128 kWh per pound of ice multiplied by 365 days per year). The section above discusses the daily ice production rate. This section examines data currently available to DOE regarding icemaking energy use per pound of ice and
calculations of annual energy use based on these data.
Table III-6 summarizes the icemaking energy test results conducted by DOE and NIST. Measured icemaking energy consumption per pound values range from 0.092 kWh/lb to 0.192 kWh/lb, with an average of 0.139 kWh/lb. Note that this average includes the measurement for DOE test 3B but not 3A (see Table III-6, below), since these measurements were made for separate icemakers of a single product. In DOE's view, the product used in tests 3A and 3B is not sufficiently representative of icemaking in refrigeration products, in large part because it has two automatic icemakers, an uncommon feature currently. As a result, DOE sought to prevent double-counting (
i.e.,
results from both icemakers of this one unit which may not be representative of the market) when calculating the average energy usage measurements and, therefore, DOE included only one of its measurements in the average. Consistent with the approach contained in today's notice, DOE included only the measurement for the ice maker serving the through-the-door dispenser of this product to determine the average for the tested samples. DOE requests additional data indicating the energy use associated with icemaking, using test methods as nearly identical as possible to the test method detailed in today's notice.
Table III-6—Icemaking Test Results
ID No.
Product class
Through-the-door (TTD) ice delivery?
Ice mold
heater?
Icemaking
energy use
(kWh/lb)
Icemaking
energy use
(kWh/year)
NIST
2011-1
3
No
Yes
0.143
94
2011-2
7
No
Yes
0.150
99
2011-3
5A
TTD
Yes
0.170
112
2011-4
5A
TTD
Yes
0.113
74
2012-1
5
No
Yes
0.125
82
2012-2
5
No
No
0.092
60
DOE
1
7
TTD
Yes
0.134
88
2
3
No
Yes
0.134
88
3A
5A
No
No
0.169
111
3B
5A
TTD
Yes
0.192
126
Averages
0.139
92
Note:
The averages include data for DOE icemaker 3B but not icemaker 3A (both are part of the same test sample refrigerator-freezer).
The test data show that the initial icemaking energy use estimate of 0.128 kWh per pound of ice is a very good approximation, as is the 84 kWh annual energy use. The samples tested by NIST and by DOE were selected to provide a range of icemaker styles with which to evaluate the icemaking test procedure, rather than to provide the actual average of the icemaking performance of refrigeration products currently on the market. Hence, DOE does not consider the 8 kWh difference in annual energy use measurement (84 kWh as compared with 92 kWh) to be significant. Given the closeness of these values, DOE may also consider, as an alternative to the test procedure detailed in today's notice, retaining the 84 kWh/year value to denote the energy usage stemming from icemaking.
DOE requests comments and alternative data addressing the energy use expended for production of a pound of ice, and DOE's tentative conclusion that the impact of the proposed test procedure changes on energy use measurements is not significant.
2. Multiple Compressor Test
Refrigerator-freezers combine a fresh food compartment and a freezer compartment in a single cabinet. Most refrigerator-freezers use a single-compressor refrigeration system that directly cools the freezer compartment; cooling for the fresh food compartment is achieved by circulating air between the two compartments. This approach cools the fresh food compartment with cold freezer air and allows the freezer-located refrigeration system to remove heat gained by the fresh food compartment. However, some refrigerator-freezers have a separate refrigeration system serving each individual compartment. This approach has been adopted by some manufacturers to improve food preservation in the fresh food compartment. By preventing the introduction of dry freezer air into the fresh food compartment, its humidity can be maintained at higher levels, which can improve food preservation. (See, e.g., Sub-Zero Dual Refrigeration User Manual Excerpt, No. 2 at p. 1)
DOE first recognized that testing products with more than one compressor requires different test procedures from those that apply to single compressor system-based products as early as 1989.
See
54 FR 36238 (introducing a dual compressor system test procedure). The 1989 proposal introduced a two-part procedure that separately measures each compressor system's energy use. The first part measures the energy use during stable operation between defrosts, while the second, conducted separately for each defrost, measures the energy use contribution of the defrost cycle for each compressor system. This second part of the test, like the second part of the test for products with long-time or variable defrost, measures total energy use during the defrost cycle.
See
10 CFR part 430, subpart B, appendix A1, section 4.2.3.
In order to determine the amount of energy use associated with defrost using the measurements for the second part of the test, the test procedure requires that the average energy use for stable operation for a period of time exactly equal to the elapsed time of the second part of the test be subtracted from the total energy use measured for the second part of the test. This difference is then adjusted by the defrost frequency in order to calculate its contribution for each 24-hour daily cycle (see, e.g., Appendix A1, section 5.2.1.2).
However, when measuring the defrost energy use for one of the compressors of a dual-compressor system, the second compressor continues to operate. If its average energy use per unit of time during the second part of the test exactly matches its average energy use per unit of time expended during the
first part of the test, this compressor's energy use cancels out in the equation, and the calculation provides an accurate indication of the first compressor's defrost energy use. The timing of cycles of the two compressors generally is not synchronized. If the average duty cycle (i.e. the fraction of time the compressor runs) of the second compressor is different during the second part of the test than it was during the first part of the test, the equation does not properly cancel out its energy use, which would create an error in the calculated defrost energy use. As an example, the second compressor may have completed a whole number of compressor cycles during the first part of the test, but may have completed 4.5 compressor cycles during the second part of the test. The additional half compressor cycle may represent the time period when the second compressor is not running. Hence, the average duty cycle for the second part of the test would be less than for the first part of the test, and the defrost energy use for the first compressor would not be correctly calculated.
The same issue applies during the first part of the test. Each of the two compressors has an average duty cycle and a cycle time, which are not likely identical. In order to ensure that the single time period selected to measure the energy use of both compressors reflects the average duty cycle for both, this time period must be equal to a whole number of compressor cycles for both. However, this is not generally possible unless the cycle times of the two compressors are identical or are perfect multiples of each other. If they are not, a portion of one of the compressor's last cycles is cut from the test period, resulting in a “truncated” test period. If the average energy use of this compressor for this truncated time is different from its average duty cycle, the result is a truncation error. This error can either increase or decrease the energy use measurements of either part of the test.
By requiring the energy use of the two compressor systems to be separately measured, the current procedure eliminated the truncation error, since the measurements focus on each individual system rather than the combined unit. Because the energy use of each compressor is evaluated and calculated separately, different test periods equal to whole compressor cycles can be selected for each compressor system, thus avoiding truncation error.
As part of the most recent rulemaking to address the test procedures for refrigeration products, DOE amended the dual compressor system equation definitions.
See
75 FR at 78830. These amendments clarified two areas of the procedure. First, DOE modified the text in section 4.1.2.4 of Appendix A1 to explicitly include the compressor and defrost heater in the list of components associated with each system that must have their energy use separately measured. Second, DOE corrected errors in the energy use equation that addresses this class of products (section 5.2.1.4 of Appendices A1 and A).
Id.
AHAM had expressed concerns during that prior rulemaking about the continued test burden associated with separately measuring the energy used by the two systems, as well as the problem that some of the components of existing dual compressor products are shared by the two compressor systems. As a result of the shared nature of these components, their energy use cannot be readily assigned to one system or the other as required by the test. (See Test Procedure for Residential Refrigerators, Refrigerator-Freezers, and Freezers, Docket No. EERE-2009-BT-TP-0003; AHAM; No. 16 at p. 7; No. 43 at pp. 2-3) Sub-Zero, a manufacturer of dual-compressor products also expressed similar concerns and supported AHAM's views (Test Procedure for Residential Refrigerators, Refrigerator-Freezers, and Freezers, Docket No. EERE-2009-BT-TP-0003; Sub-Zero; No. 23 at p. 1; No. 42 at pp. 1-2).
On September 6, 2011, Sub-Zero filed a petition for waiver from the test procedures for its products that use more than one compressor. DOE published a decision and order granting this waiver request (the “Sub-Zero waiver”) on February 6, 2012. 77 FR 5784. The Sub-Zero waiver prescribed an alternative test procedure that does not require separate measurement of each system's components but includes specific provisions to minimize the measurement error associated with truncation. The test does this by requiring a duration of 24 hours for key parts of the test, including the stabilization period, along with the first and second parts of the test.
Id.
By increasing the test period to 24 hours, the total energy use measured during the test is much greater than the possible truncation error, thus reducing the error to an insignificant magnitude. This result is illustrated with test data in the discussion below.
The last set of comments AHAM submitted in response to the December 2010 interim final rule recommended that DOE replace the dual compressor system test procedure with one that is essentially identical to the Sub-Zero waiver test procedure. (Test Procedure for Residential Refrigerators, Refrigerator-Freezers, and Freezers, Docket No. EERE-2009-BT-TP-0003, AHAM, No. 43 at pp. 2-3)
DOE declined to adopt AHAM's proposed test procedure during the last round of rulemaking because stakeholders did not have an opportunity to comment on the AHAM procedure. Given the complexity of the proposed dual compressor test, and the extent to which it differed from the existing DOE test, DOE believed that, prior to modifying the test procedure in the manner suggested by AHAM, all interested parties should have an opportunity to fully vet and comment on that approach. DOE also noted the limitations of the existing dual compressor test procedure and indicated it would consider revising the procedure in a future rulemaking. 77 FR at 3570-1 (Jan. 25, 2012). Today's notice is addressing these issues.
Summary of AHAM's Proposed Multiple Compressor Test Procedure
The multiple compressor test procedure being proposed by DOE today is based in part on the multiple compressor test procedure previously suggested by AHAM—and that DOE ultimately permitted Sub-Zero to use in response to that company's waiver request. The proposed procedure would determine energy use based on a measurement of power input at the product's power cord rather than requiring a separate measurement of the power input of the two compressor systems. The energy use calculated for a multiple compressor product would include: (a) energy use measured during the first part of the test, which involves stable operation (excluding events associated with defrost), and (b) a defrost energy use contribution for each compressor that undergoes defrost cycles, based on measurements made during a second part of the test, which would be conducted for each of the defrosting compressor systems.
To ensure that the product has stabilized after adjusting the temperature controls, the AHAM procedure would require waiting 24 hours rather than evaluating steady-state conditions as currently prescribed in Appendix A1, section 2.9.
The revised draft AHAM procedure would require the first part of the test to be at least 24 hours long in order to minimize the truncation error (see the discussion above explaining truncation error). The test period would consist of a whole number of freezer compressor cycles. The procedure would allow this test period to be a summation of several running periods that do not include any
of the events associated with defrost cycles. To ensure stability during the first part of the test, the procedure would require that the compartment temperatures measured for the compressor cycle at the start and end of the test period (or of each individual running period comprising the test period, if there is more than one) be within 1.0 °F of the test period's temperature average, and that these measurements for fresh food temperature be based on the complete fresh food compressor cycles that are closest to the start and end of the test period.
The revised draft AHAM procedure would require the second part of the test for each measured defrost cycle to be at least 24 hours in duration, running from a time of stable compressor operation (normal compressor cycling) through all events associated with the measured defrost to a later time of stable compressor operation. The test procedure would allow additional non-continuous running periods of stable operation to be added to the test period if needed to achieve a total test duration of 24 hours. To ensure stability during the second part of the test, AHAM's revised procedure would require the compartment temperature averages for the first and last compressor cycle of this test period to be within 1.0 °F of their averages for the first part of the test. DOE notes that this approach is less stringent than the current Appendix A requirement for long-time or variable defrost systems. That provision requires that compartment temperature averages for compressor cycles just prior to and after the second part of the test be within 0.5 °F of their averages for the first part of the test (see Appendix A, section 4.2.1.1).
Proposed Amendment
DOE proposes to replace its dual compressor test procedure with a modified version of the test procedure recommended by AHAM. The key differences between the DOE proposal and the Sub-Zero/AHAM test procedure are:
(1) The proposal would define the term “multiple compressor” to help enhance the clarity of this term and to ensure that a uniform definition applies to this term. Adopting such a definition would lessen the risk of confusion.
(2) The proposal would allow an examination of temperature cycles as an alternative to an examination of compressor cycles as the basis for test period duration and for compartment temperature calculation. Also, a definition is proposed for the term “complete temperature cycle” to support this change.
(3) The proposal would use a stabilization period consistent with the existing test procedure rather than requiring 24 hours for stabilization.
(4) The proposal would allow a single-part test if only one compressor system has defrost and it is a timed defrost with less than 14 hours of compressor run time between defrosts.
(5) In cases where only one compressor in a multiple-compressor-based product cycles, the proposal would specify a test period consisting of a complete number of compressor or temperature cycles lasting at least three hours for the first part of the test, similar to single-compressor products. Similarly, if none of the compressors cycle, the procedure would allow a 3-hour test period for the first part of the test.
(6) Under the proposal, if at least one compressor cycles, the test periods would be based on temperature cycles or compressor cycles of a “primary” compressor system. This would be the freezer compressor system, if its compressor cycles.
(7) For the first part of the test, the proposal would require 24 hours of continuous stable operation if there is no defrost interruption. It would also require at least 18 hours of continuous stable operation if there is a defrost interruption, rather than allowing use of non-continuous running periods, as suggested by AHAM.
(8) For the second part of the test, the proposal would not require 24 hours of operation.
(9) The proposed test would require that, for both the first and the second parts of the test, the temperature averages for the first and last cycle of the test period (either compressor or temperature cycles) for each system must be within 0.5 °F of the temperature average for the first part of the test.
These modifications and other details of the implementation of the proposed procedure are discussed in more detail below. DOE seeks comment on this approach, including on the details that follow below.
Multiple Compressor Definition
The term “multiple compressor” is currently undefined. In light of this gap, and the accompanying need to ensure clarity for manufacturers, DOE is proposing to define this term. This term would be used in lieu of the term “dual-compressor” in order to provide general applicability to all refrigeration products that have more than one compressor. Although DOE is not aware of any current refrigeration products with more than two sealed compressor systems, taking this broader approach in defining this particular term would ensure that products using more than two sealed refrigeration systems that might be manufactured and sold in the future are addressed by DOE's regulations. The new definition in Appendix A, for example, would read as follows: “Multiple Compressor” refrigerator or refrigerator-freezer means a refrigerator or refrigerator-freezer with more than one compressor.
DOE requests comment on this proposed definition.
Temperature Cycles
DOE is proposing that test periods for multiple compressor refrigeration products be determined by either compressor operation or compartment temperatures. Reliably identifying individual compressor cycles from power data based on a single power measurement of all the energy use for multiple compressor refrigeration products may be difficult because identifying compressor cycle starts and stops may be challenging and it might not be obvious which events are associated with each compressor unless some means of differentiating these events applies. As an alternative, the proposed test procedure would allow the selection of test periods based on the cycles of the compartment temperatures associated with the multiple compressor systems. Complete temperature cycles are equivalent to complete compressor cycles because the starts and stops of each temperature cycle coincide nearly exactly with the starts and stops of the compressor cycles for the compressor associated with the considered compartment temperature. Since it is the operation of the compressor that causes the refrigeration system to reduce compartment temperatures, compressor and temperature cycles are inherently equivalent. This approach may be easier to apply to some multiple compressor products because the compartment temperature measurements of separate compressor systems are not combined like total product power inputs are. In general, these temperature cycles would coincide with their corresponding compressor cycles (i.e. the compartment temperature falls as the compressor operates and it rises when the compressor is not operating), but the use of temperature cycles may make identification of test periods easier.
DOE proposes to use a definition for “complete temperature cycle” that would refer to a cycle based on compartment temperature variations. To maintain flexibility, the proposal would allow the selection of both temperature
cycles that start when the temperature is at a maximum and those that start when the temperature is at a minimum—such temperature cycles would correspond to compressor cycles that start when the compressor starts or when it stops, respectively. Under the “maximum temperature” approach, the time period would be based on a starting point that coincides with the compartment temperature reaching its maximum temperature and would end once the compartment temperature returns to an equivalent maximum (within 0.5 °F of the starting temperature). During the course of the temperature cycle, the compartment temperature must have fallen to a minimum temperature for the period before rising again to reach the maximum temperature. Likewise, under the “minimum temperature” approach, the time period's starting point would occur once the compartment temperature reaches a minimum and ends when the compartment temperature returns to an equivalent minimum (within 0.5 °F of the starting temperature), having, in the interim, risen to a maximum and subsequently fallen again to reach the second minimum.
By defining the complete temperature cycle in this way, this proposed definition should resolve the potential difficulties in identifying test periods based on compressor cycles, because, as mentioned above, the compartment temperature measurements would be made separately for the different compressor systems, whereas the power input measurement combines all of the product's power input. DOE requests comment on this proposed definition that would define a “complete temperature cycle” in a manner that would permit the use of temperature cycles to identify test periods.
Measurement Frequency
The current test procedure allows temperature measurements to be taken at up to four-minute intervals (see Appendix A sections 2.9 and 5.1.1). This approach, however, carries with it an inability to further reduce the risk of truncation error beyond a certain degree. The Sub-Zero and revised draft AHAM procedures would further reduce this risk by requiring the measurement of multiple-compressor systems to be recorded at regular intervals not to exceed one minute (Test Procedure for Residential Refrigerators, Refrigerator-Freezers, and Freezers, Docket No. EERE-2009-BT-TP-0003, AHAM, No. 43 at p. 3).
In DOE's view, increasing the frequency of measurement periods would provide a more accurate picture regarding the energy usage of refrigeration products. DOE is aware that most test facilities record data for refrigeration product energy tests at a frequency of once per minute. DOE believes that there would be, at most, an insignificant test burden associated with this requirement since most test facilities already use one-minute recording intervals. Accordingly, DOE proposes to adopt a data collection interval that would not exceed one minute in length. DOE requests comment on the requirement for this proposed limit on the data acquisition time interval for test of multiple compressor products.
Stabilization Period
Instead of requiring a stabilization period of 24 hours as AHAM suggests, DOE is proposing to apply the existing stabilization requirements (see Appendix A, section 2.9). The DOE proposal would also permit the use of temperature cycles rather than compressor cycles to determine steady-state conditions. For example, while the current section 2.9 requires the comparison of temperature averages for two periods lasting at least two hours comprising complete compressor cycles, the proposal would allow this comparison to consider periods comprising complete temperature cycles or complete compressor cycles. As described above, it may be easier in certain cases to identify individual temperature cycles than individual compressor cycles for a multiple compressor system. DOE proposes to offer this alternative to reduce test burden for the majority of products, which achieve stabilization in less than 24 hours, and to ensure that the existing stabilization requirement is met for any product that requires more than 24 hours to achieve stabilization. DOE requests comments on this proposal.
One-Part Test Simplification
DOE proposes using a one-part test for multiple compressor products where (a) only one compressor system has automatic defrost and (b) the defrost is a “short-time” defrost (
i.e.,
not a “long-time defrost” with more than 14 hours of compressor operation between defrosts (see Appendix A, Section 1.12) or variable defrost). The proposed test period would start at a point during a defrost period and end at the same point during the subsequent defrost period, as does the existing test procedure for single-compressor products with automatic defrost that is neither long-time nor variable (see Appendix A, section 4.2). DOE proposes to allow use of the single test period to minimize the test burden for products with short-time automatic defrost for only one of the compressor systems.
Such a one-part test introduces the possibility of truncation error associated with the second compressor system. However, the clock time (as opposed to the compressor run time upon which CT values are based—see Appendix A section 5.2.1.2) between defrosts for short-time defrost systems is generally about 24 hours. (For example, one of the refrigerators tested and reverse-engineered as part of the September 2011 refrigeration product energy conservation standard rulemaking had a defrost timer with a 10.5-hour timer interval, and clock time between defrosts of 22 hours for a test with temperature controls in the median setting). (Refrigerator with Defrost Timer Example, No. 12) As described below in the discussion addressing truncation error associated with the first part of a two-part test, a test duration of 24 hours is sufficiently long to minimize the overall impact of this type of error.
DOE requests comments on its proposal to allow a one-part test for multiple compressor products in which only one compressor system has a defrost cycle that is neither long-time nor variable.
Test Simplifications for Tests With One or No Cycling Compressors
AHAM's Revised Draft Test Procedure does not consider potential test simplifications that could be implemented for multiple compressor refrigeration products for which one or more of the compressors does not cycle. The DOE proposal would address this possibility by providing details on how to determine test periods and the intervals over which compartment temperatures should be measured if the tested unit has one or no cycling compressors. Specifically, if only one of the compressors cycles, the test period for the first part of the test would be at least three hours long and comprise two or more complete cycles of the cycling compressor. Further, if none of the compressors cycle, the test period for the first part of the test would be three hours long. These test periods are nearly identical to the test periods for products with single compressors. (e.g. Appendix A, section 4.1) This approach, which would reduce manufacturer testing burdens, is justified because truncation error is essentially eliminated when only one compressor cycles or when no compressors cycle.
The proposed test procedure would use a similar simplification for the second part of the test for such products. For example, for a product
with one cycling compressor, it would require that the second part of the test start and stop when the single cycling compressor starts or stops. In addition, the criteria for compartment temperatures at the test period start and stop times would be based on temperature measurements made for full cycles of the single cycling compressor. Again, using this approach for the second part of the test is, in DOE's view, merited since truncation error is eliminated with one or no compressors cycling.
DOE requests comment on this proposed approach to help simplify the test periods for both the first and second parts of the test when less than two of the compressors of a multiple compressor product cycle during a test.
First Part of a Two-Part Test for a System With at Least Two Cycling Compressors
DOE's proposal would require that the first part of the test for multiple compressor products have a test duration of at least 24 hours if the test period is not interrupted by a defrost cycle. The proposal would require test periods to be selected based on the compressor or temperature cycles of a “primary” compressor. A primary compressor would normally be the freezer compressor, if it cycles. If the freezer compressor does not cycle, a fresh food compressor would be the primary compressor, and the test periods would be based upon the compressor or temperature cycles of this fresh food compressor. DOE proposes to require that the first part of the test would include a whole number of primary compressor cycles or temperature cycles. If a defrost cycle occurs prior to the completion of the 24-hour test period, the DOE proposal would allow a shorter test duration of 18 hours. This proposal contrasts with the AHAM test procedure proposal, which would permit multiple segments of running time that add up to at least 24 hours. DOE's reasoning for its approach is described below.
DOE is adopting this modified approach of AHAM's revised draft procedure because the accuracy of the test is not necessarily improved by allowing the use of multiple segments of running time to increase the total test period time to 24 hours. This is because each segment that is used to comprise the test period would introduce its own contribution to truncation error. Hence, the benefit to accuracy associated with adding additional time to the test period would be reduced or eliminated by the additional truncation error introduced by each additional segment of test period time. DOE recognizes that there may be situations in which it is difficult to obtain 24 hours of uninterrupted stable operation. Based on a review of the test data for tests of multiple compressor products described below, DOE has tentatively concluded that shortening the test period time to 18 hours is a reasonable compromise in such cases, but that further reductions may not be acceptable because of the potential for the truncation error to become unreasonably large.
At the same time, an 18-hour test period would be possible without combining non-continuous running periods, assuming that most multiple compressor products have variable defrost. Multiple compressor products are generally premium products with electronic control and variable defrost as standard convenience features. DOE is aware of products sold by Sub-Zero, Liebherr, Bosch, LG, and GE (under that company's Monogram line of appliances) that use multiple compressor systems. To the extent DOE could determine based upon the certification information in its product listing database, models of this type all have variable defrost systems. Occasionally, defrost cycles may occur with less than 18 hours of stable operation between them, but variable defrost products would increase the defrost time interval during testing. DOE expects that in all cases, the period of stable operation after the second defrost would extend to at least 18 hours. The DOE test would continue to be conducted with the product doors closed, creating little opportunity for moisture to enter the cabinet. Unde
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