EPA finds lapses in cord wood certification test reports

A Regency stove being tested at RFS labs
for 2020 compliance using the Alternative
ASTM E3053 cordwood method. (NOTE: The
3 photos used in this story are NOT connected
to the EPA memo.  They are just random 
cordwood certification test.)

The EPA recently sent a memo to wood heater test labs and third party certifies about significant lapses in documenting certification tests using the cord wood test method and potentially significant lapses in cord wood testing.  We reproduce the memo below.  

[For the more recent blog on lab testing, 30-day notices and non-CBI reports, click here.]

The memo does not specify which labs and which manufacturers are involved and the EPA is not making that public as of now.  The manufacturers involved are being contacted to have labs submit paperwork to the EPA, via third party certifies, who also could have caught the lapses before forwarding documentation to the EPA.  Some stoves may have to do the cord wood emissions tests again.

A Kuma stove using the ASTM
test method at Omni labs

AGH supports a transition to cordwood testing under the assumption that stoves tested with cordwood are more likely to burn more cleanly in the hands of consumers. But cordwood testing of stoves in the United States is still in its infancy and so far there is only the ASTM E3053 test method.  There are still many, many questions about whether the ASTM method can help achieve the emergence of a class of wood stoves that truly operate better in peoples' homes.

AGH asked the EPA to provide us with the memo to test labs when we heard about it.  The EPA promptly sent it to AGH but more often than not, we do not know about memos that go to labs, HPBA and manufactures.  EPA rarely shares many

A Travis stove using the ASTM cordwood
method at Omni lab.

such memos with the wider stakeholder community, that also includes stove retailers, state air quality agencies and others.  We believe documents such as this should be made routinely available by EPA without anyone having to file a freedom on information act request.   

Documentation from test labs to show stoves meet certification requirements go to Rafael Sanchez at the EPA Office of Enforcement and Compliance at EPA's headquarters in Washington DC.  This memo came from a review done by Steffan Johnson, based in Research Triangle in North Carolina.  Mr. Johnson is the Group Leader for the Measurement Technology Group at EPA's Office of Air Quality Planning and Standards,  the Measurement Technology Group provides national leadership in furthering the science of characterizing and measuring air pollutant emissions from industrial sources and is the EPA's focal point for producing validated emissions test methodology.  The Group also provides expert technical assistance for EPA, State, and local enforcement officials and industrial representatives involved in emissions testing.

(March 2021 update: Alaska sought and received approval from the EPA for an IDC cordwood stove test method to be "broadly applicable" which means any manufacturer can choose to use it in a stove's certification test.  It was partially sought because of weaknesses in the ASTM cordwood method and it also sets the stage for Alaska to potentially require that test for stoves sold in Fairbanks.)

From: "Johnson, Steffan", EPA
Date: 6/13/19 4:18 pm

To: all EPA Approved Wood Heater Test Laboratories and Third Party Certifiers,

In reviewing some recent test reports that have been submitted to EPA with the intent to certify a wood heater to the Subpart AAA cordwood emissions standard, there are some discrepancies and concerns that we are observing, and we will be asking some manufacturers to revise and resubmit a corrected compliance test report.  At least one of these concerns (noted below) is critical and may require re-testing.  All of these items are important enough to request a corrected report, and we wanted to let all of you know just why you may be contacted by your client(s) with such a request.

1. We have seen a number of test reports using the Alternate Test Method and ASTM E-3025 that do not identify the species of cordwood used for the com pliance testing.  While it is true that the ASTM method allows selection from a wide list of wood species, the test report must identify the species of fuel used.  This is specified not in the test method but in the General Provisions to EPA 40, Part 60.8 (f)(2) which governs content that must be included in the test report. Paragraph (iii) of this section reads:  “(iii) Description of the emission unit tested including fuel burned, control devices, and vent characteristics; the appropriate source classification code (SCC); the permitted maximum process rate (where applicable); and the sampling location.”

We are asking that test reports that did not identify the wood fuel species burned during a compliance test submit an amended test report to this Agency.  If you are a third party reviewer and have certified such a test report, we request that you include this item, along with other items listed in the General Provisions, in your review checklist. 

2. We have seen some test reports that reference “manufacturer’s instructions” for conducting the certification test, yet those instructions were not included in the test report.  The requirement to submit this information is to comply with the General Provisions of 60.8(b) and (c).  The guiding principle here is that ONLY the EPA Administrator has the ability to modify a test method for any reason, and these manufacturers instructions do NOT supersede the test method.  Also, the National Stack Test Guidance Document (available here:  https://www.epa.gov/compliance/clean-air-act-national-stack-testing-guidance) clearly states that the emissions test report “must demonstrate all information from the test lab such that it is a stand-alone document capable of reproducing the entirety of the test results”.  As such, all information pertinent to the operation of the appliance during the testing must be included in the test report (per 40 CFR 60.534). Also, as such instructions are relevant to how the testing was conducted, this documentation is not Confidential Business Information (CBI). 

We are asking manufacturers that have issued test reports where the manufacturers provided instructions to the test lab regarding appliance operation during the test, and that documentation was NOT included in the emissions test report available to the public, to take corrective action and submit an amended test report to this Agency.  If you are a third party reviewer and have certified such a test report, we request that you now include this item, along with other items listed in the General Provisions, in your review checklist.

3. We have seen some test reports that contain manufacturer’s instructions that may run contrary to the test method and rule requirements.  Specifically, we have seen instances where manufacturers have directed laboratories to conduct low load testing with air inlet damper settings at “specified distances from fully closed”, meaning that the unit may not be getting tested at the lowest operating rate that a homeowner will have access to during the course of normal daily operation.  Testing at the lowest setting a consumer will be able to operate the appliance in their home is specifically required in 40 CFR 60.534.

Test labs and third party certifiers who are conducting /observing testing where manufacturers provided such instructions AND where you have knowledge that such devices are capable of combustion with air inlet dampers more fully closed than those setpoints specified by the manufacturer review the rule requirements with their client(s) and either select the lowest available setpoint or modify that stove model to fix the lowest available air inflow setting at that specified point, to remain fixed thereafter.  Furthermore, we insist that laboratories and third party certifiers add the requirement(s) of 60.534 to their checklists and take necessary steps to not look past this requirement in the future.  Appliance models found to have been tested in this manner and subsequently certified, will need to be reviewed by EPA on a case-by-case basis.  As a reminder, third-party certification is an attestation that all testing was conducted as specified in the regulation; certification of testing that does not meet the regulatory requirements may result in loss of EPA Approval status.  

4. We have seen some test reports where cordwood fuel is used to demonstrate compliance, and the dimensions of the “cordwood” very closely match the dimensions of crib fuel.  While we recognize that it may happen that occasionally a wood splitter would produce a piece where the minor cross section is nearly equal to the major cross section of the fuel piece, we expect that this happens infrequently and is not normal for every piece in a fuel load. 

We ask that labs and third party certifiers use pieces that approximate hand-split fuel and not something that seems to be far more selective.  While fuel pieces are ‘selected’ for the test based on size and weight and, to some extent, dimension, we expect to see fuel loads that are more random (in terms of piece-to-piece comparisons) than not.

As always, thank you for continuing to support the EPA Wood Burning Appliance Certification Program.  Please do not hesitate to reach out to us and ask questions, any time, with respect to any certification testing you are undertaking; we are happy to offer our technical direction to help you, and your clients, meet the subpart AAA and QQQQ regulatory requirements.

My best regards,

Stef Johnson

Steffan M Johnson | Leader – Measurement Technology Group | US EPA Office of Air Quality Planning and Standards | Air Quality Assessment Division | 109 T.W. Alexander Drive, RTP, NC  27710 | Mail Drop: E-143-02 | Phone: (919) 541-4790  | Cell: (919) 698-5096

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