UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

DEC 16 2011 OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

Voluntary Consensus Standard Results for Standards of Performance for New Residential 

Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces, and New 

Residential Masonry Heaters 40 CFR Pat1 60, Subparts AAA, QQQQ, and RRRR 

Conniesue B. Oldham, Group Leader ~ tJ.~ Measurement Technology Group (E 143-02) 

Chebryll Edwards, Group Leader 

Regulatory Development and Policy Group (C404-05) 

At your request, the Measurement Technology Group (MTG) of the Office of Air Quality Planning and 

Standards (OAQPS) conducted searches and reviews to address the National Technology Transfer and 

Advancement Act (NTTAA) requirements on the use of voluntary consensus standards (VCS). The 

NIT AA directs EPA to use VCS in regulatory and procurement activities unless doing so would be 

inconsistent with applicable law or otherwise impracticable. This memorandum documents the results of 

the MTG searches and reviews to determine ifVCS are available and practical for use in lieu of stationary 

source methods cited in the Results for Standards of Performance for New Residential Wood Heaters, New 

Residential Hydronic Heaters and Forced-Air Furnaces, and New Residential Masonry Heaters 40 CFR 

Part 60, Subparts AAA, QQQQ, and RRRR 

In 1998, OAQPS began implementing the requirements of the NTT AA by conducting searches to identify 

VCS. Searches continue to be performed to meet the requirements ofthe NTTAA. While we have made a 

reasonable effort to identify and evaluate potentially practical VCS, our findings do not necessarily 

represent all potential alternative standards which may exist. 

The MTG participates in the American Society for Testing and Materials (ASTM), which is one of the 

most active VCS organizations on emissions testing, and has been invited to pat1icipate in the USA 

Technical Advisory Group for International Organization for Standardization (ISO) relating to emissions 

monitoring. We expect these additional effot1s will help us to support a periodic review of all EPA 

reference methods and performance standards for possible incorporation by reference (IBR) ofVCS in lieu 

of or as alternatives to EPA procedures. We anticipate that these activities will provide an opportunity for 

further review, consideration and possible IBR ofVCS overlooked in the National Standards Service 

Network (NSSN) searches or finalized after Federal agency review in the EPA rulemaking process. 

We conducted searches for Standards of Performance for New Residential Wood Heaters, New Residential 

Hydronic Heaters and Forced-Air Furnaces, and New Residential Masonry Heaters 40 CFR Part 60, 

Subparts AAA, QQQQ, and RRRR through the Enhanced NSSN Database managed by the American 

Internet Address (URL) • http://www.epa.gov 

Recycled/Recyclable • Printed wnh Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer) 
2 

National Standards Institute (ANSI). We also contacted VCS organizations, and accessed and searched 

their databases. 

Searches were conducted for EPA Methods 50, 5H, 22, 28, 28A, 28R (proposal), 28 WHH (proposal) of 

40 CFR Part 60, Appendix A. No applicable voluntary consensus standards were identified for EPA 

Methods 50 and 22. The EPA has also decided to use ASTM E2515-l 0, E2618-09, E2779-l 0, E2780-l 0, 

E2817-ll, WK26558, CSA B415.1-l 0 and EN303-5 in this rule. 

Three voluntary consensus standards were identified as acceptable alternatives to the EPA test methods for 

the purpose of this rule. The voluntary consensus standard ASTM E871-82 (2006), "Standard Test Method 

for Moisture Analysis of Particulate Wood Fuels" is acceptable as an alternative to Methods 5H and 28. 

The voluntary consensus standard ASTM E2515-l 0, "Standard Test Method for Determination of 

Particulate Matter Emissions Collected by a Dilution Tunnel" is acceptable as an alternative for pattieulate 

measurement portion of Methods 28R (proposal) and 28 WHH (proposal). The voluntary consensus 

standard ASTM E2780-l 0, "Standard Test Method for Determining Patticulate Matter Emissions from 

Wood Heaters is acceptable as an alternative to Method 28R (proposal) with the following conditions: 

1.0 Scope and Application 

1.1 This test method applies to certification and auditing of wood-fired room heaters and fireplace 

inserts. 

1.2 The test method covers the fueling and operating protocol for measuring particulate emissions, 

as well as determining burn rates, heat output and efficiency. 

1.3 Particulate emissions are measured by the dilution tunnel method as specified in ASTM E2515 

Standard Test Method for Determination of Particulate Matter Emissions Collected in a Dilution 

Tunnel. 

2.0 Procedures 

2.1 This method incorporates the provisions of ASTM E2780-l 0 except as follows: 

2.1.1 The burn rate categories, low burn rate requirement, and weightings in Method 28 shall be 

used. 

2.1.2 The startup procedures shall be the same as in Method 28. 

2.1.3 The equation for converting the emission test values between the EPA Reference Method 50 

"Determination of Particulate Emissions From Wood Heaters From a Dilution Tunnel Sampling 

Location" and EPA Reference Method 5H "Determination of Particulate Emissions From Wood 
3 

From Wood Heaters From a Stack Location" shall be the same as in Method 28. 

2.1.4 Manufacturers shall not specify a smaller volume of the firebox for testing than the full 

usable firebox. 

2. I .5 The test fuel moisture content, fuel load, and coal bed depth shall be as follows: 

2. I .5 (a) The fuel load dry-basis moisture content shall be within a range of 22.5 percent+/- I 

percent 

2.1.5 9b) The fuel load weight shall be 7 lb/ft3 +/- I percent (or 7 lb +/-0.07 lb) of the fuel load 

weight, calculated in accordance with Method 28. 

2.1.6 (c) The range for the test-initiation coal-bed weight shall be 22 percent+/- 1 percent of the 

fuel load weight. 

During the search, if the title or abstract (if provided) of the VCS described technical sampling and 

analytical procedures that are similar to EPA's reference method, the MTG considered it as a potential 

equivalent method. All potential standards were reviewed to determine the practicality of the VCS for this 

rule. This review requires significant method validation data which meets the requirements of EPA 

Method 30 I for accepting alternative methods or scientific, engineering and policy equivalence to 

procedures in EPA reference methods. The MTG may reconsider determinations of impracticality when 

additional information is available for particular VCS. 

The search identified five other VCS that were potentially applicable for this rule in lieu of EPA reference 

methods. After reviewing the available standards, EPA determined that five candidate VCS (ASTM 

El358-97 (2006), ASTM E872-82 (2006), ASTM E1534-93 (2006), ASTM E319-85 (2008), ASTM PTC 

19.5. I (I 964)) identified for measuring emissions of pollutants or their surrogates subject to emission 

standards in the rule would not be practical due to lack of equivalency, documentation, validation data 

and other important technical and policy considerations. These five methods are listed in Attachment I, 

along with the EPA review comments. 

I hope our research into this matter has been useful and timely to your Groups efforts in this rulemaking. 

Please contact me at (9I9) 54I-7774 with any further questions in this matter. 

Attachments 

cc: Rima Howell, EPNAQAD (EI43-02) 

Michael Toney, EPNAQAD (EI43-02) 

Gil Wood, EPNSPPD (C404-05) 
Voluntary Consensus Standards Not Applicable for Standards of Performance for New Residential Wood Heaters, 

sidential Hydrouic Heaters aud Forced-Air Furnaces, aud New Residential Masonry Heaters 40 CFR Part 60, 

ts AAA, QQQQ, aud RRRR. 

VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

STANDARD 

ASTM E1358-97 (1997)- Standard Test Method for ASTM recommends that this standard be used for spot 1 

Determination of Moisture Content of Particulate checks only. Therefore, it is likely to be not as accurate as a 

Wood Fuels Using a Microwave Oven moisture meter used in EPA Methods 5H and 28. 

ASTM E872-82 (2006) - Standard Test Method of Good method, but not applicable to any part of these EPA 

Volatile Matter in the Analysis of Particulate Wood methods, since the EPA methods assume a constant for 

Fuels wood hydrocarbon content. Could be useful to the EPA in 

future method revisions or for special wood-type situations. 

ASTM El534-93(1998)- Standard Test Method for Good method, but not applicable to any part of these EPA 

Determination of Ash Content of Particulate Wood methods, since the EPA methods assume a constant for 

Fuels wood carbon content. Could be useful to the EPA in future 

method revisions or for special wood-type situations. 

ASTM E319-85 ( 1997) - Standard Practice for the This standard is not a complete weighing procedure as is 

Evaluation of Single-Pan Mechanical Balances EPA Method 28 because the standard lacks a pretest 

procedure. 

ASMEPTC 19.5.1 (1964)-PowerTestCodes, This standard is not a complete weighing procedure as is 

Supplement On Instruments and Apparatus, Part 5, EPA Method 28, for the standard neither specifies the exact 

Measurement of Quantity of Materials, Chapter I, number of initial calibration weights to be used nor include a 

Weighing Scales specific pretest weight procedure.