MRR-13-2008	 14:04 EPR 5411039 P. 02 'J J{t-iL- ( I~

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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 Test Protocol 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, Subpart AAA 

FROM:	 Michael S. Alushin, Director ~.1. pt/ Compliance Assessment and MedIa Programs Division 

Office of Compliance . 

TO:	 Conniesue Oldham, Group Leader 

Measurement Tecl:mology Group 

Office of Air 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 Performance 

Standard (NSPS) for Residential Wood Heaters at 40 CFR Part 60, Subpart AAA. This request 

is made on behalf of the United States Environmental Protection Agency (EPA) .accredited 

laboratories that perform wood stove certification testing and manufacturers of wood 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 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 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
 

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MRR-13-2008 14:04 EPR 5411039 P.03

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

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

that closely resembles the CSA B415.1 test protocor~. Both methods are stack loss base~,

procedurally similar and produce similar results. 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 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 

B4l5.1 be accepted as an alternative method for determining thenna! 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 of an approved test method. A good 

example would be the approval of a modified version of Reference Method 26 as an alternative 

means of determining 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 it is often used in lieu of approved opacity measurement 

methods for compliance and enforcement purposes. . 

Use ofthe CSA B41S.1 as an alternative method will fulfill the original intent ofthe rule 

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 percent4 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 

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 Oregon AdminIStrative 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 ofSolid Fuel-Burning Healing Applulnces. Canadian Standards 

Association. December 2000. ' 

3 Toney, M, Reilly Industries Request/or A.lternative Te51 Meth()d Determination/or Hydrogen Cyanide. 

December 29,2005. 

4 Houck. J.E., Tiegs, P,E., Air Emissions/rom Residential Wood Heating: The Wood Heating Option Put 

into Environmental Perspective. l{eport prepared for EPA by OMNI Environmental Services, Incorporated, 

Beavenon, Oregon. 2001 
MJ=lR-13-212J12J8 14:1214 EPJ=l 541112139 P.12J4 

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This proposal enj oys 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 staff is ready to provide any administrative assistance 

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 of the CSA B415 as an alternative test method. 

,// If you have any questions regarding this request, please contact John DuPree of my staffat 

./ (202) 564-5950. . 

/ 

\ 

cc; Robin Segall, OAQPS 

MiJce Toney, OAQPS 

Michael S. Alushin, CAMPD 

Mamie R. Miller, CAMPD, ACB 

John DuPree, CAMPD, ACB 

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TOTJ=lL P.12J4 
MAR-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 SfANOAFlD8
 

MEMORANDUM 

SUBJECT:	 Request to use ¢e CSA B415.l Test Protocol 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 of Compliance. 

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

Environmental Protection Agency (EPA) accredited laboratories that perform woodstove 

certification testing and manufacturers of woodstoves, 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), 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 of Environmental 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 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. 

Intemet AddrBS8 (URL) • http://www.epa.gov 

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MAR-13-2008 14:07 EPA 5411039 P.03 

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

B415.1 for many years. Based on similarity ofthe CSA B415.1 protocol to the Oregon DEQ 

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

protocol for detennining an actual thennal energy efficiency rating for wood stoves affected 

under the NSPS for Residential Wood Heaters in 40 CFR Part 60~ Subpart AM is an acceptable 

alternative to the use ofthe default values. 

If'you have additional q'i1estions~ please call Mkhttel Toney ar(919) 541~S247.

TOTAL P.03