MRR-13-2008 14:04 EPR 5411039 P. 02 

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

OFFICE OF ENFORCEMENT AND COMPLIANce ASSUFlANce



### MEMORANDUM
SUBJECT: Request to Use the CSA B415.1 TestProtocol as an Altemative Test Method for Determining Thennal 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

# ~.1. 

# pt/ Compliance Assessment and MedIaPrograms Division Office ofCompliance

. TO: Conniesue Oldham, Group Leader Measurement Tecl:mology 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 efficiencyratings for wood stoves affected under the New Source Performance 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) .accredited laboratories that perform wood stove certification testing and manufacturers ofwood stoves affected under the NSPS.
As you are aware, the NSPS at 40 CPR Part 60, Section 60.534(d)(1) allows affected
sources to determine the thennal efficiency rating for a wood stove either 

### by using a default nwnber (63 percent for noncatalytic wood stoves, 72 percent fOf catalytic wood stoves, and 78 percent for pellet stoves), or by using ofa 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 undermines teclmical innovation in the wood stove industry and provides
erroneous technical infonnation to the public, Most important, it has a negative impact on the environment because it discourages conswners from replacing older, inefficient, high polluting wood stoves with efficient, clean burning EPA certified wood stoves.

Inlernel Address (Ufll.) • http://WllM'.upa.gQv AKyclecWlecyca.blu • Pnn\uc;! wi,

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.**~7** The default values used inthe rule were calculated using an energy efficiency ,-­ measurement procedure developedbythe Oregon Department ofEnvironmental Quality (DEQY that closely resembles the CSAB415.1 test**protocor~.** Bothmethods are stack loss**base~,** procedurally similar and produce similarresults. In fact, the majority ofwood stove manufactW'ers and EPA accredited laboratories 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 inthe Canadian marketplace and will be incorporated into Canada's future wood smoke regulations. Itis for these reasons that we feel itreasonable to request that the CSA B4l5.1 be accepted as an alternative method for determining thenna! efficiency ratings under the NSPS for Residential Wood Heaters.

. Although the use ofdefault efficiencyratings prescribed under the NSPS is not an actual test method, there havebeeninstances where the Office ofAir Quality and Planning Standards (OAQPS) has issued alternative test methods in the absence ofan approved testmethod. A good example would be the approval ofa modified version ofReference Method 26 as an alternative
means ofdetermining hydrogen cyanide under the Phannaceutical Maximum Achievable Control Technology (MACT? The visual method for detennining particulate emissions, Reference Method 9, is also not a test method, but itis often used in lieu ofapproved opacity measurement methods for compliance and enforcementpurposes.
. Use ofthe CSA B41S.1 as an alternative method will fulfill the original intent ofthe rule 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 4 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 replace these archaic, inefficient wood stoves with efficient, clean burning EPA certified wood stoves. In addition, it will be easier for domestically manufactured wood heating appliances to be exported ifthey have an actual measured efficiency rating.

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

2 8415.1-00, Performance Testing of SolidFuel-Burning HealingApplulnces. Canadian Standards Association. December 2000. '

3 Toney, M, ReillyIndustries Request/orA.lternative Te51 Meth()dDetermination/orHydrogen Cyanide. December 29,2005.

4 Houck. J.E., Tiegs, P,E., AirEmissions/romResidential Wood Heating: The WoodHeating Option Put into EnvironmentalPerspective. l{eport prepared for EPA by OMNI Environmental Services, Incorporated, Beavenon, Oregon. 2001MJ=lR-13-212J12J8 14:1214 EPJ=l 541112139 P.12J4



### 3 This proposal enjoys very 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

...**effj~i~n~y.i.l.lfQrmf!tiQn.Qn** 

### wQo9**~tove.la.bels** 

### will be,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 

### administrative assistance necessary to assure its implementation. This support could include: issuing a Federal Register notice; drafting 

### aresponse, comment on the document 

### as well 

### as any 

### other activities deemed necessary to finalize approval ofthe CSA B415 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 

### MiJce Toney, OAQPS Michael S. 

### Alushin, CAMPD 

### Mamie R. 

### Miller, CAMPD, ACB John 

### DuPree, CAMPD, ACB 

# ¥1**~'.U~**

# 0C!'~

TOTJ=lL P.12J4MAR-13-2008 14:07 EPA 5411039 P.02

UNITED STAmS ENVIRONMENTAL PROTECTION AGENCY AESEARCH TRIANGLE PARK, NC 2n11 

## JUN 01 

## 2D07

OFFICE OF AIR QLI.Al.ITY PLANNING ANO Sf ANOAFlD8 MEMORANDUM



### SUBJECT: Request to use 

### ¢eCSA B415.l TestProtocol as an Alternative Test Method for Determining Thermal Energy Efficiency Rating for Wood Stoves Affected under the New Source Penonnance Standard (NSPS) for Residential Wood Heaters at

FROM: 

### 40 CFR Part 

### 60, Subpart AAA
COIUliesue B. 

### Oldham, Ph.D., Group Leader' [). :.. 

# ef?

r-..

# L

-I1P Measurement Technology Group
TO: Michael S. Alushin, Director Compliance Assessment and Media Programs Division Office ofCompliance.

I am writing in response to your February 6,2007, 

### memorandum requesting, on behalfof Environmental Protection Agency (EPA) accredited laboratories that perform woodstove certification testing and manufacturers ofwoodstoves, approval of the Canadian Standards Administration (CSA) 8415.1 test protocol as an alternative test method for determining the thermal energy efficiency rating for wood stoves affected under the New Source Performance Standards (NSPS) for Residential Wood Heaters in 40 CPR 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 percent for noncatalytic wood stoves, 72 percent for catalytic wood stoves, and 78 percent for pellet stoves), orby measuring the actual efficiency.
The default values used in the rule were calculated using an energy efficiency measurementprocedure developed by the Oregon Department ofEnvironmental Quality (DEQ) that closely resembles the CSA B41S.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 atest 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 ofwood heaters." However, an efficiency test method was never developed.

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We are aware that EPA accredited laboratories are using and have been using CSA B415.1 for many years. Based on similarity ofthe CSAB415.1 protocol to the Oregon DEQ methodused to detennine the allowed default values, we agree that use ofthe CSA 8415, 1test protocol for detennining an actual thennal energy efficiency rating for wood stoves affected under the NSPS for Residential WoodHeaters in 40 CFR Part**60~** SubpartAMis an acceptable alternative to the use ofthe default values. If'youhave additional**q'i1estions~** pleasecallMkhttel Toney ar(919)**541~S247.**

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