UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

OFFlCE OF ENFORCEMENT AND COMPLIANCE ASSuFlANCe

MEMORANDUM 

### SUBJECT: Request to Use the CSA B41S.1 TestProtocol as an Alternative TestMethod for Determining Thermal Energy Efficiency Ratings for Wood Stoves Affected under the New Source Performance Standard (NSPS) for Residential Wood Heaters at 40 CFR Part 60, SubpartAAA
FROM: Michael S. Alushin, Director 

# tffI:.1. Compliance Assessment and Media Programs Division Office ofCompliance

. C

TO: 

### Conniesue Oldham, Group Leader Measurement Teclmology Group Office ofAir Quality 

### and Planning Standards

The purpose ofthis memQrandum is to request that the Canadian Standards Administration (CSA) B415.1 test protocol be approved as an alternative method for detennining thennal energy efficiency ratings for wood stoves affected under the New Source Perfonnance Standard (NSPS) for Residential Wood Heaters at40 CFR Part 60, Subpart AAA. This request is made on behalfofthe United States Environmental Protection Agency (EPA)**~redited** 

### laboratories that perform wood stove certification testing and manufacturers ofwood stoves affccted under the NSPS.
As you are aware, the NSPS at 40 CFR Part 60, Section 60.534(d)(1) allows affected sources to determine the thennaI efficiency rating for 

### awood stove either by using adefault number (63 percent for noncatalytic wood stoves, 72 percent for catalytic wood stoves, and 78 percent for pellet stoves), or by 

### using ofa measured efficiency protocol. Since amethod for measuring thennal efficiency was never approved by EPA, affected sources are limited to use of the default number option for compliance wIth the NSPS. Our failure to approve a measured efficiency methOd undennines technical innovation in 

### the wood stove industry and provides erroneous technical infonnation to the public, Most important, it

### has anegative impa.ct on the environment because it 

### discourages consumers from replacing older, inefficient, high 

### polluting wood stoves with efficient, clean burning EPA certified wood stoves.

Inllmel Address (URL> •**h~:II_.ePll.gov ~ecyclecUReGYclsble**  • Prin1ed wllh Vege1llble 011 Based Ink& on 1lXl'l'. Poetconsumer. Proces.s ChIOt1I'lG Free ReQ)'cled Paper2 The default values used inthe rule were calculated using an energy efficiency measurement procedure developed by the Oregon Department ofEnvironmental Quality (DEQt that closely resembles the CSA B415.1 test protocof z • Bothmethods are stack loss**base~,** procedurally similar and produce similarresults. In fact, the majority ofwood stove manufacturers and EPA accredited labomtories currently utilize the CSA 

### B41S, 1 efficiency method as·a research and development tool to design new wood stove model lines. The method is also popular in the Canadian marketplace and will be incorporated into Canada's future wood smoke regulations. It is for these reasons that we feel it reasonable to request that the CSA 

### B415.1 be accepted as an alternative method for detennining thermal efficiency ratings under the

. NSPS for Residential Wood Heaters.

. Although the use ofdefault efficiency ratings prescribed under the NSPS is not an actual test method, there havebeen instances where the Office ofAir Quality and Planning Standards (OAQPS) has issued alternative test methods in the absence ofan approved test method. A good example would be the approval ofa modified version ofReference Method 26 as an alternative means ofdetermining hydrogen cyanide under the Pharmaceutical Maximum Achievable Control Technology (MACT)3. The visual method for determining particulate emissions, Reference Method 9, is also not a test method, but it is often used in lieu ofapproved opacity measurement methods for compliance and enforcementpurposes.
. Use ofthe eSAB41S.l as an alternative method will fulfill the original intent ofthe role to provide affected sources the option ofusing a measured energy efficiency protocol to generate thennal efficiency ratings for the wood stoves offered for sale 

### inthe United States. Only 11 percent' ofwood stoves installed inresidential homes today are EPA certified wood stoves. The remaining 89 percent are pre-NSPS wood stoves that produce up to 75 percent more particulate emissions. Posting ofaccurate efficiency numbers 

### will encourage consumers to replaco these archaic, inefficient wood stoves with efficient, clean burning EPA certified wood stoves. In addition, it will be easieffor domestically manufactured wood heating appliances to be exported ifthey have an actual measured efficiency rating.

I Oregon AdmlntStrattveRules, Chapter 340, Division 21, pages 100 through 190, Oregon Deparnnent of Environmental Quality. Portland, Orogon 97204. November 1984.

2 8415.1-00, Performance Testing 01SolJdFuel-Burning HealingAppliances. CWlwHan Stlllldards Association. December 2000. '

3 Toney, M, ReillyIndustrkJ RequesljorA.lternative TestMeth()dDetermlnationforHydrogen Cyanide. December29.2005.

4 Houck. J.E., Tiegs, P,E.,AirEmis$ions from**Resid~ial** WoodHeating: The WoodHeaJing Option Put Into E"v/ronmenlllJPerspective. Report prepared for EPA by OMNI Environmental Services, Incorporated, Beaverton, Oregon. 200]3 This proposal enjoys vel')' strong support from the five 

### EPA accredited wood stove testing laboratories and has received favorable responses from the wood stove manufacturers we queried. The increase in energy prices and the recently enacted Energy Policy Acthave increased the demand for 

### energy efficientheating alternatives to gas and oil. As a result, the typical wood stove consumer is far more energy conscious than they were twenty years ago. Posting more accurate



### ...**effl~i~n~Y .hlfQrm~tiQn**  

### .Qn wQo4 ,&tove.labels 

### will he.

### a. great service to consumers 

### as well 

### as

to the environment.
In the event that OAQPS elects to incorporate 

### use ofthe CSA B415.1 as 

### an alternative test method, the Wood Heater

### Program staffis ready 

### to provide any adnrin.istrativeassistance necessary to assure its implementation. This support could include: issuing a Federal Register notice; drafting 

### a response, comment on

### the document 

### as well 

### as any other activities deemed necessary to finalize approval ofthe CSA B41j as an alternative test method. 

### Ifyou have any questions regarding this request, 

### please contact John DuPree

### ofmy staffat (202) 564-5950.

.

cc: Robin Segall, OAQPS 

### Mi.ke Toney, 

### OAQPS Michael S. Alushin, CAMPD Mamie 

### R. Miller, 

### CAMPD, ACB John DuPree, CAMPD, ACB

TOTAL P.04UNITED STAl'ESENVIRONMENTAL PROTECTION AGENCY I=tESEARCH TRIANGLE PARK, NC 2n11 

## JUN 01 

## 2007

OFFICE Of AlA QUAl.1TY pLANNING AND STANDARDS 

### MEMORANDUM

SUBJECT: Request to use $e eSAB41S.l TestProtocol as an Alternative Test Method for Detennining Thermal Energy Efficiency Rating for Wood Stoves Affected under the New Source Performance Standard (NSPS) for Residential Wood Heaters at 40 CFR Part 60, Subpart AAA

.

# FROM~ Conniesuc B. Oldham, Ph.D., Group Leader' 

# rr.,'"

r"-

# L

-110 

# Irr- cB1J Measurement Technology Group
TO: Michael S. Alushin, Director Compliance Assessment and Media Programs Division Office ofCompliance.



### I am writing inresponse to your 

### February 6,2007, memorandum requesting, on 

### behalfof Environmental Protection Agency (EPA) accredited laboratories that perfonn woodstove certification testing and manufacturers ofwoodstoves, approval of the Canadian Standards Administration (CSA) 

### B415.1 test protocol as an alternative test method for determining the thennal energy efficiency rating for wood stoves affected under the New Source Performance Standards (NSPS) for Residential Wood Heaters in 40 CFR Part 60, Subpart AAA. As you know, Subpart AAA in §60.536(i)(3) allows affected sources to determine the thennal efficiency rating for wood stoves either by using a default number (63 percep.t for noncatalytic wood stoves. 72 percent for catalytic wood stoves, and 78 percent for pellet stoves), or

### by measuring the actual efficiency.
The default values used 

### inthe rule were calculated using an energy efficiency

. measurement procedure developed by the Oregon Department ofEnvironmental Quality (DEQ)

that closely resembles the CSA 

### B41 5.1 test protocol: the methods are both stack 10'ss based methods, are procedurally similar, and produce similar results. The CSA B4'lS, 1method 

### will be incorporated in the Canadian wood smoke regulations.
It was the intent ofEPA to develop a test method for measuring the thermal efficiency of wood stoves and pellet stoves as indicated in §60.534(d); "Appendix Jis used as an optional procedure in establishing the overall thennal efficiency ofwood heaters." However, an efficiency test method was never developed.

Internet A<ldfllSll (URL.) • http://www.epa.gov**AICY~llIdIfl8l:Yl:Ia!)f** •• Pr!nledwllt1 V8Q&IatJ

.. 01 8aaaQ IllI<a on Aecycled PIpOf' (Minimum 25% Poslconaumtlrj-- We are aware that EPA accredited laboratories are using andhavebeen using CSA B415.1 for many years. Based on similarity ofthe eSA B415.1 protocol**t~** the Oregon DEQ methodused

### to determine

### the allowed default values, we agree thatuse ofthe CSA 8415,1 test protocol for determiDing an actual thenna! energy efficiency rating for wood stoves affected undertheNSPS for Residential Wood Heaters in 40 CFR Part 60 1 SubpartAAA is an acceptable alternative to the use ofthe default values. If'you ltave additioaal questions-,**pleas~** callMithael Toney ar(919)**541~5247.**



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