[Federal Register Volume 60, Number 140 (Friday, July 21, 1995)]
[Proposed Rules]
[Pages 37603-37606]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-18037]
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Proposed Rules
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.
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Federal Register / Vol. 60, No. 140 / Friday, July 21, 1995 /
Proposed Rules
[[Page 37603]]
DEPARTMENT OF ENERGY
Office of Energy Efficiency and Renewable Energy
10 CFR Part 430
Energy Conservation Program for Consumer Products: Department of
Energy Refrigerator and Refrigerator-Freezer Test Procedure
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of inquiry.
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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;
[[Page 37604]]
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
[[Page 37605]]
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
[[Page 37606]]
[GRAPHIC] [TIFF OMITTED] TP21JY95.005
[FR Doc. 95-18037 Filed 7-20-95; 8:45 am]
BILLING CODE 6450-01-C
