Energy Conservation Program for Consumer Products: Department of Energy Refrigerator and Refrigerator-Freezer Test Procedure

SUMMARY: Today's document publishes a letter from Edward Schulak

Equities, Inc. (ESE), requesting the Department of Energy (Department

or DOE) to modify the refrigerator and refrigerator-freezer test

procedure to allow testing the ``Energy Efficient Domestic

Refrigeration System'' patented by ESE. The Department is soliciting

comments, data, and information respecting the request.

DATES: The Department will accept comments, data, and information not

later than August 21, 1995.

ADDRESSES: Written comments and statements shall be sent to: Department

of Energy, Office of Energy Efficiency and Renewable Energy, Case No.

FRIG-001, Mail Stop EE-431, Room 1J-018, Forrestal Building, 1000

Independence Avenue, SW., Washington, DC 20585, (202) 586-7574.

FOR FURTHER INFORMATION CONTACT:

Michael G. Raymond, U.S. Department of Energy, Office of Energy

Efficiency and Renewable Energy, Mail Station EE-431, Forrestal

Building, 1000 Independence Avenue, SW., Washington, DC 20585, (202)

586-9611.

Eugene Margolis, Esq., U.S. Department of Energy, Office of General

Counsel, Mail Station GC-72, Forrestal Building, 1000 Independence

Avenue, SW., Washington, DC 20585, (202) 586-9507.

SUPPLEMENTARY INFORMATION: The Energy Conservation Program for Consumer

Products (other than automobiles) was established pursuant to the

Energy Policy and Conservation Act (EPCA), Public Law 94-163, 89 Stat.

917, as amended by the National Energy Conservation Policy Act (NECPA),

Public Law 95-619, 92 Stat. 3266, the National Appliance Energy

Conservation Act of 1987 (NICE), Public Law 100-12, the National

Appliance Energy Conservation Amendments of 1988 (NICE 1988), Public

Law 100-357, and the Energy Policy Act of 1992 (EPACT), Public Law 102-

486, 106 Stat. 2776, which requires the Department to prescribe

standardized test procedures to measure the energy consumption of

certain consumer products, including refrigerators and refrigerator-

freezers. The intent of the test procedures is to provide a comparable

measure of energy consumption that will assist consumers in making

purchasing decisions. The refrigerator and refrigerator-freezer test

procedures appear at 10 CFR Part 430, Subpart B, Appendix A1.

The Department amended the prescribed test procedures by adding 10

CFR 430.27 on September 26, 1980, creating the waiver process. 45 FR

64108. The waiver process allows the Assistant Secretary to temporarily

waive test procedures for a particular basic model when a petitioner

shows that the basic model contains one or more design characteristics

which prevent testing according to the prescribed test procedures, or

when the prescribed test procedures may evaluate the basic model in a

manner so unrepresentative of its true energy consumption as to provide

materially inaccurate comparative data.

On March 14, 1995, ESE submitted a letter regarding the

refrigerator test procedures. This letter was submitted as a ``Petition

for Waiver'', but also stated that ``ESE recognizes that the Waiver

process may not be the appropriate forum, and we would like this

request to be considered in whatever forum DOE would consider

appropriate * * *'' ESE has patented a device which operates by cooling

the ambient air around the condenser coil. The device is a box placed

around the coils, connected via small tubes to the outside of the

house. The system also includes a movable barrier for selectively

controlling the transfer of air to the box. The purpose of the

invention is to reduce the energy consumption of the refrigerator.

ESE's application seeks a ``waiver'' from the Department test

procedure, because the energy consumption of a refrigerator equipped to

allow the ingress of cool outside air over the condenser coils is not

addressed. ESE has not submitted a modified test procedure to be used

for rating its refrigerator modification. ESE states that the existing

Department test procedure needs to be modified to allow the

introduction of cool air to the refrigerator condenser coil. This

refrigerator modification (specifically, the addition of tubes

conveying outdoor air to the refrigerator) may cause increased

infiltration of outdoor air to the building, which would affect the

energy consumption of the building containing the refrigerator as well

as the refrigerator itself.

The Department agrees that the current test procedure does not

account for the total energy savings of the ESE refrigerator

modification. Clearly, this invention would require modification to the

test procedure, but, for two reasons, the ``Petition for Waiver''

process is not appropriate.

First, waivers to the test procedure are applicable when ``basic

models'' have design features that require exceptional treatment and

are applicable only to the model in question. No models are currently

manufactured incorporating this invention, nor is the invention being

produced for retrofitting on refrigerators.

Second, if the invention were put to use, the nature of the

invention might require a fundamental change to the refrigerator test

procedure because of the interaction of the invention with the building

energy consumption.

The Department is publishing the letter from ESE, and, to

facilitate understanding of the invention, a digest (Attachment A),

which the Department has extracted from the patent. The patent is

United States Patent Number 5,291,749, Energy Efficient Domestic

Refrigeration System, granted to Edward R. Schulak, 567 Aspen,

Birmingham, Michigan 48009, on March 8, 1994. The Department has

identified several issues where comments are specifically requested.

These issues are as follows, including, but not limited to:

The effects of the invention on building energy

consumption;

Manufacturability of the invention;

Retrofitting the invention into existing dwellings;

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Method of testing the invention to determine energy

savings.

The Department solicits comments, data, and information respecting

the letter.

By publishing this letter and requesting comments, the Department

is not expressing a view as to the technical feasibility or economic

justification of this mechanism as an energy saving device to be used

with refrigerators and refrigerator-freezers.

Issued in Washington, DC, on July 13, 1995.

Christine A. Ervin,

Assistant Secretary, Energy Efficiency and Renewable Energy.

Edward Schulak Equities, Inc.

Christine Ervin, Assistant Secretary for Energy Efficiency and

Renewable Energy.

March 14, 1995.

Mr. Michael J. McCabe, Director, Office of Codes and Standards, U.S.

Department of Energy, 1000 Independence Ave., SW., Washington, DC

20585.

Ladies and Gentlemen: 1. Petition for Waiver--In accordance with

10 CFR, Part 430.27 this is a Petition for Waiver from the test

procedure set forth in 10 CFR, Part 430, Subpart B, Appendix A-1,

adopted August 10, 1982 and revised January 1, 1993 and for the use

of an alternate test procedure described in paragraph 4 below.

(Edward Schulak Equities, Inc. ``ESE'' recognizes that the Waiver

process may not be the appropriate forum and we would like this

request to be considered in whatever forum the Department of Energy

``DOE'' would consider appropriate, such as a Petition for Rule

Making.) ESE has been granted U.S. Patent No. 5291749 which

documents a unique technological breakthrough for which the required

Appendix A-1 test procedure referenced above will not produce energy

consumption results which correctly represent the enhanced energy

savings possible and thereby the performance of this refrigerator.

2. Background Information--ESE was granted U.S. Patent No.

5291749 Titled: Energy Efficient Refrigeration System which

documents a method of saving energy through increased efficiency in

any commercially available refrigerator model. The company is

familiar with DOE test procedures (specifically 10 CFR Part 430) and

the FTC Energyguide labeling requirements. Further, the company

engaged ETL Testing Laboratories ``ETL'' to independently confirm

the validity of the energy savings possible with the above

referenced patent, and to confirm the ineffectiveness of the

existing DOE testing procedures to accurately produce energy

consumption results with the above referenced patent (a copy of the

ETL Reports No. 536692A, 538479B & 539826 are included as Exhibits

A, B & C). In our opinion, the applicable DOE test procedure, which

was designed for self contained units, has no provision to test a

unit which transfers energy from cool external air into the unit's

refrigeration cycle and thereby reducing the unit's overall energy

consumption. The introduction of external cool air blown across the

refrigerators condenser and compressor can be adapted to any rear or

bottom mounted condenser model and has demonstrated (as confirmed by

ETL) energy savings in excess of 25% of total power consumed by the

unit.

3. Specific Test Procedure Problems--With the test conditions

and procedures currently prescribed by DOE, energy consumption of a

refrigerator equipped to allow the ingress of cool air over the

condenser/compressor would not be addressed. The existing test

procedures were written strictly for self contained models. A test

procedure to standardize the energy savings achieved on models

equipped to receive external cool air is currently not allowed and

therefore the energy savings cannot be officially measured and

documented.

As a result the dollar savings achieved through this technology

can not be listed on the FTC Energyguide label and buyers can not be

informed of the savings possible by purchasing a refrigerator

engineered to utilize cool external air. It should be noted that

there is already different test procedures established for measuring

the energy consumption of unvented home heating equipment (Part 430,

Subpart B, Appendix G) from that of vented home heating equipment

(Part 430, Subpart B, Appendix O). With this new technological

breakthrough there is now reason to consider a similar vented and

unvented test procedure for refrigerators and freezers.

4. Alternate Test Procedures--At the present time ESE does not

have a proposed alternate test method for refrigerator/freezer

utilizing this technology. However, the work commissioned by ESE and

completed by ETL provides a basis for developing a simple test

procedure for refrigerator/freezers adapted to accept external cool

air as proposed by ESE. The trials at ETL suggest that no existing

DOE test conditions or procedures need be modified or deleted, but a

provision needs to be added to allow the introduction of external

air at specific temperature ( deg.f) and airspeed (cfm) across the

unit's condenser/compressor. The existing DOE test formulas and

procedures would be unaltered. While the cool air would be

introduced into and out of the unit, the unit is tested in full

accordance with the existing 10 CFR, Part 430. For clarity, no test

procedure need be altered or changed, but simply the conditions be

expanded to allow cool air to be introduced in a consistent,

repeatable manner to ensure that both the energy saved is measured

in a consistent manner and that the savings can correspondingly be

listed on the FTC Energyguide label.

5. Public Policy Considerations--Since innovation is an

essential part of the Congressionally mandated energy conservation

programs, it is in the public interest for DOE to facilitate

introduction of new product technology like alternative air ducting

which have the potential for saving energy by reducing the number of

compressor cycles needed to keep a refrigerator/freezer cool.

6. Manufacturers--No existing appliance manufacturer in the

United States market manufactures a model adapted to accept external

cool air. In the discussions we have had with manufacturers and

their consultants, they have clearly indicated that there is no

advantage for them to utilize energy saving technology if it does

qualify for the DOE Energuide Label. Manufacturers will not consider

incorporating this new technology because the associated energy

savings can not be quantified under the currently existing DOE Test

conditions and procedures. Without an appropriate alternate test

procedure, the savings can not be officially sanctioned and

therefore are not allowed to be listed on an FTC Energyguide label.

The adaptation that allows external cool air to flow over the

condenser and compressor could apply to any existing model sold

presently in the United States.

If additional information is required, please contact me at

(810) 644-1500.

Respectively,

Edward Schulak,

President.

Enclosures:

Exhibit A--ETL Report No. 536692A

Exhibit B--ETL Report No. 5291749

Exhibit C--ETL Report No. 538479B

Attachment A

``* * * the present invention provides an energy transfer system

for a household refrigeration appliance. The energy transfer system

includes a compartment for enclosing the condenser, which is

associated with the refrigerator, and a set of conduits for enabling

the transfer of outside air into, through, and out of the

compartment. The system also includes a movable barrier for

selectively controlling the transfer of air through the compartment.

In one form of the present invention, the system also includes a

thermostatically actuated fan for forcing outside air into, through,

and out of the compartment in response to a predetermined

temperature.

``The set of conduits preferably includes a first conduit for

enabling the transfer of outside air to the compartment, and a

second conduit for enabling the transfer of air from the compartment

to the outside environment. Each of these conduits are disposed such

that they extend through an external wall of said household. To

facilitate the convection flow of air, the outlet of one conduit is

connected to the compartment at a location which is lower than an

inlet connection of the other conduit.

``Referring to Figure 1, a perspective view of a household

refrigeration appliance (10), in accordance with the present

invention, is shown. More specifically, the household refrigeration

appliance depicted in Figure 1 is a domestic refrigerator which has

been retro-fitted with the energy transfer system (12), in

accordance with the present invention. However, it should be

understood that the principals [sic] of the present inventions are

equally applicable to a domestic refrigerator, which has been

constructed at the originating factory to include a built-in energy

transfer system.

``As shown in Figure 1, the refrigerator (10) generally includes

at least one door (14) across its front and a serpentine tube

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condenser (16) mounted across its back. As is well known in the

field, the condenser (16) is connected to the discharge end of a

pump to compress a refrigerant fluid , such as freon, from a gaseous

phase to a liquid phase. This process creates heat which must be

removed in order for the refrigeration cycle to work.

``With this household refrigerator arrangement, the heat

produced at the condenser (16) is simply released into the area of

the home which surrounds the refrigerator. However, in accordance

with the present invention, a compartment (24) is used to enclose

the condenser (16). As shown in Figure 1, the compartment (24) may

be comprised of a five-sided molded fiberglass shell, which is

mounted to the exterior side of the refrigerator (10) where the

condenser (16) is located. In this regard, the compartment (24)

includes a flange (26) which extends around its periphery to enable

the compartment to be secured to the refrigerator (10) over the

condenser (16), such as with a plurality of spaced screws. However,

it should be understood that the compartment may be comprised of

other suitable materials, and may take other suitable shapes in the

appropriate application. For example, with a factory built-in energy

transfer system, the compartment (24) may be formed integrally with

a side of the refrigerator (10), such that the consumer need not

discern that the compartment is included as part of the refrigerator

body. Additionally, the compartment (24) may be constructed such

that it includes an insulative layer in order to more fully control

the transfer of heat from the condenser (16).

``The energy transfer system (12) also includes one or more

passageways for enabling the transfer of heat out of the compartment

(24), and for selectively utilizing outside air in this process.

Thus, for example, as shown in Figures 1 and 2, the energy transfer

system (12) includes a first conduit (28), which enables cool air

from outside of the home to enter the compartment (24), and a second

conduit (30), which enables air from inside the compartment to be

released outside of the home. In this regard, both of these figures

show an exterior wall (32) of the household wall, and the conduits

(28) and (30), constructed such that they are able to extend through

this exterior wall. The conduits (28) and (30) may be made of any

suitable material which is appropriate for this purpose (e.g., sheet

metal or flexible insulated duct), and the conduits may be connected

to the compartment in a variety of ways.

``It should also be noted that the first conduit (28) is

connected to the compartment (24) at a location which is lower than

that where the second conduit (30) is connected to the compartment.

This arrangement is used to facilitate outside air from through the

first conduit (28) into the compartment, through the compartment,

and out of the second conduit (30), by heat convection. While the

conduits (28, 30) are shown to be relatively straight pipes or

tubes, it should be understood that other suitable shapes may be

employed, depending upon such considerations as the available space

and the distance between the refrigerator (10) and the exterior wall

(32).

``Figures 1 and 2 also show the provision of a fan (34), which

may be used to force the flow of outside air into, through, and out

of the compartment (24). While the fan (34) is shown to be connected

to the compartment (24) in a way which is separate from the

connection of the conduits (28, 30) to the compartment, it is

preferred that the fan be connected in-line with the conduit (28),

either within the conduit or adjacent to its outlet into the

compartment. Additionally, it is preferred that the fan (34) be a

thermostatically actuated fan, so that its use may be carefully

controlled to achieve the most energy efficient benefit.

``Additionally, as shown in Figures 1 and 2, the energy transfer

system (12) also includes a movable barrier or wall, in one or both

of the conduits (28, 30) to control the flow of air through the

compartment (24). In one form of the present invention, this movable

barrier is comprised of a butterfly valve (36), which may be used to

prevent or enable the flow of outside air into the compartment via a

butterfly valve disposed in one or both of the conduits (28, 30).

For example, in the case of butterfly valve (36) disposed in the

second conduit (30), the flow of outside air through the first

conduit (28) could provide sufficient force to open the butterfly

valve, and thereby, permit the escape of air from the compartment

(24) through the second conduit.

``From the above, it should be understood that the energy

transfer system (12) conveys energy in the form of cool outside air

to the condenser (16), in order to reduce the energy of the

refrigeration process.

``Thus, in accordance with the present invention, the fan (34)

may be actuated when the outside air temperature drops to a

predetermined threshold level (e.g., 37 deg.C), as the energy

efficiency achieved will be greater than the energy consumed by the

fan. Alternatively, it should be appreciated that the refrigerator

(10) may already include a fan which may be used to divert some air

flow into the compartment (24) from the outside. The energy transfer

system (12) may also include a thermostatically actuated valve, such

as the valve which would enable ambient air from inside the

household (e.g., 20 deg.C.) to enter the compartment (24) when the

outside air temperature is above a particular threshold level (e.g.,

37 deg.C). In this way, the compartment (24) will always be provided

with a sufficient supply of air flow to cool the condenser (16).''

BILLING CODE 6450-01-P

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[GRAPHIC] [TIFF OMITTED] TP21JY95.005

[FR Doc. 95-18037 Filed 7-20-95; 8:45 am]

BILLING CODE 6450-01-C