UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 

WASHINGTON, D.C. 20460
 

OFFlCE OF 

ENFORCEMENT AND 

COMPLIANCE ASSuFlANCe 

MEMORANDUM 

SUBJECT:	 Request to Use the CSA B41S.1 Test Protocol as an Alternative Test Method 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, Subpart AAA 

FROM: Michael S. Alushin, Director tffI:.1. Compliance Assessment and Media Programs Division 

Office of Compliance . 

C 

TO: Conniesue Oldham, Group Leader 

Measurement Teclmology Group 

Office ofAir Quality and Planning Standards 

The purpose of this 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 at 40 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 of wood 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 a wood stove either by using a default 

number (63 percent for noncatalytic wood stoves, 72 percent for catalytic wood stoves, and 

78 percent for pellet stoves), or by using of a measured efficiency protocol. Since a method 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 a negative 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 Paper 
2 

The default values used in the rule were calculated using an energy efficiency 

measurement procedure developed by the Oregon Department of Environmental Quality (DEQt 

that closely resembles the CSA B415.1 test protocofz

• Both methods are stack loss base~,

procedurally similar and produce similar results. In fact, the majority of wood stove 

manufacturers and EPA accredited labomtories currently utilize the CSA B41S, 1efficiency 

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 of default efficiency ratings prescribed under the NSPS is not an actual 

test method, there have been 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 of a modified version ofReference Method 26 as an alternative 

means of determining 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 of approved opacity measurement 

methods for compliance and enforcement purposes. . 

Use ofthe eSA B41S.l as an alternative method will fulfill the original intent ofthe role 

to provide affected sources the option of using a measured energy efficiency protocol to generate 

thennal efficiency ratings for the wood stoves offered for sale in the United States. Only 

11 percent' of wood stoves installed in residential 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 of accurate 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 easief for domestically manufactured wood heating appliances to 

be exported ifthey have an actual measured efficiency rating. 

I Oregon AdmlntStrattve Rules, Chapter 340, Division 21, pages 100 through 190, Oregon Deparnnent of 

Environmental Quality. Portland, Orogon 97204. November 1984. 

2 8415.1-00, Performance Testing 01SolJd Fuel-Burning Healing Appliances. CWlwHan Stlllldards
 

Association. December 2000. '
 

3 Toney, M, Reilly IndustrkJ Requesljor A.lternative Test Meth()d Determlnationfor Hydrogen Cyanide. 

December 29.2005. 

4 Houck. J.E., Tiegs, P,E., Air Emis$ionsfrom Resid~ialWood Heating: The Wood HeaJing Option Put 

Into E"v/ronmenlllJ Perspective. 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 Act have increased the 

demand for energy efficient heating 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 of the 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 B41 j as an alternative test method. 

Ifyou have any questions regarding this request, please contact John DuPree ofmy staff at 

(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.04
 
UNITED 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 eSA B41S.l Test Protocol 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 of Compliance.
 

I am writing in response to your February 6,2007, memorandum requesting, on behalf of
 

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 in the 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, 1 method 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 J is used as an optional
 

procedure in establishing the overall thennal efficiency of wood heaters." However, an
 

efficiency test method was never developed.
 

Internet A<ldfllSll (URL.) • http://www.epa.gov 

AICY~llIdIfl8l:Yl:Ia!)f ••Pr!nled wllt1 V8Q&IatJ.. 01 8aaaQ IllI<a on Aecycled PIpOf' (Minimum 25% Poslconaumtlrj 
--

We are aware that EPA accredited laboratories are using and have been using CSA 

B415.1 for many years. Based on similarity ofthe eSA B415.1 protocol t~ the Oregon DEQ 

method used to determine the allowed default values, we agree that use ofthe CSA 8415,1 test 

protocol for determiDing an actual thenna! energy efficiency rating for wood stoves affected 

under the NSPS for Residential Wood Heaters in 40 CFR Part 601 Subpart AAA is an acceptable 

alternative to the use ofthe default values. 

If'you ltave additioaal questions-, pleas~ call Mithael Toney ar(919) 541~5247.

. , 

TOTAL P.12I3 

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