Veteran lab technician challenges Alaska's wood stove criteria

Ben Myren, left, with Larry Brockman
at the 2018 Stove Design Challenge
where the IDC was showcased.

Updated, April 2, 2021 - Ben Myren, one of the nation's most experienced wood stove test lab experts, is frustrated with the officials in Alaska that are trying to enact stricter wood stove standards.  Fairbanks has to design a State Implementation Plan (SIP), to clean up their air to meet federal air quality limits or face sanctions. 

Myren is not alone in his opposition to the way Alaska is seeking to crack down on more polluting stoves.  Nineteen entities responded to the EPA's public comment on the Alaska stove requirements and all 19 were very negative.  This is not entirely surprising considering all 19 comments came from the wood stove industry, mainly from manufacturers.  Their comments can be viewed here and Myren's comments are reproduced below.  Companies that commented against the ADEC proposal included HHT, US Stove, Jotul, Rais, Blaze King, Central Boiler and Woodstock Soapstone.

The Alaska Department of Environmental Conservation (ADEC) stove requirements resulted from  a novel and ambitious review of certification reports of all wood stoves. According to its reports, the agency found missing and flawed data in nearly every set of certification papers sent to the EPA by EPA approved testing labs. One of those labs, run by Ben Myren, provided scores of reports ADEC found to be deficient.

Following ADEC's review, the Northeast States for Coordinated Air Use Management (NESCAUM), a non-profit based in Boston, used that data in a scathing report that found the EPA's system of certifying wood and pellet stoves boilers and furnaces to be "dysfunctional." Currently, high level officials at the EPA are reviewing the NESCAUM report and the stove industry and states are waiting to see what parts of the report the EPA will address and how. In the meantime, the EPA has reportedly stopped processing certification paperwork.

The stove industry association, the Hearth, Patio & Barbecue Association (HPBA) dismissed the NESCAUM report in a blog by John Crouch, their Director of Public Affairs, saying they do not see "any indication that the regulatory process doesn't work." Instead, Crouch says that the report is the result of an "anti-woodstove agenda" and its authors are trying to "find a problem so that they can push for their desired outcome." The Alliance for Green Heat's response urged the EPA to "take the report seriously", and calls on the Biden Administration to provide more resources for implementation and enforcement. AGH was critical that the report failed to sufficiently distinguish the far more fair and reliable testing of pellet stoves and boilers, which could undermine important efforts of New England states to incentivize modern pellet heating as a means of reducing fossil fuel reliance.

Myren, and most of the manufacturers who commented objected to virtually all the keys ways Alaska is trying to require stricter standards in their effort to convince the EPA that they are addressing its air pollution non-attainment problem. The EPA accepted Missoula's strategy of simply banning new installations of wood stoves and limiting pellet stove installs to devices emitting 1.0 g/h or less. Missoula's 1.0 g/h limit was also enacted ex post facto, and did not give manufacturers the chance to meet the stricter local standard in advance. Myren notes that Alaska's requirement that stoves not emit more than 6 g/h during the first hour of a test to be sold in Fairbanks is unfair, including because some stoves test with a cold start and capture heavy start-up emissions while others test from a hot start. 

ADEC points out that the strong objections posed in all the industry comments may backfire, because if the EPA rejects ADEC's approach, the fallback may be simply ban the installation of new cord wood stoves, like Missoula did.  The EPA approved Missoula's strategy and ADEC is using that as a yardstick to craft something that may be equally effective at reducing wood smoke, but still allow Fairbanks residents to install more cordwood stoves. 

Myren also found that ADEC appears to be requiring more bark on the test loads of cordwood for the ASTM test than for the Integrated Duty Cycle (IDC) test it asked the EPA to approve. Thus, if a lab uses the IDC method to certify a stove, it may fail ADEC's criteria. If Fairbanks wants a test method that will help identify stoves that will perform well in that polar-like environment, Myren argues that the IDC fails on many counts. In fact, Fairbanks may do better to alter the IDC to test stoves for their ability to burn in sub-zero temperatures, which causes a much higher draft than used in the IDC.

 

MYREN CONSULTING, INC.

AIR PLAN APPROVAL; AK, FAIRBANKS NORTH STAR BOROUGH;

2006 24-HOUR PM_2.5 SERIOUS AREA PLAN

86 FED. REG. 10,511 (FEB.22, 2021)

 

     The US EPA is proposing to approve parts of the Alaska State Implementation Plan for the Fairbanks North Star Borough Area (NSSIP).  Part of the NSSIP includes revised emissions standards and, possibly new test methods, for wood stoves.  Myren Consulting, Inc. (MCI) would like to offer the following comments on these proposed actions.

 

     1. EPA’s initial choice of the 2.5 g/h particulate emissions (PM) standard for wood stoves tested with cord wood (the cord wood option, see Section 60.532(c) in the 2015 NSPS) was made without any supporting data that demonstrated that the 2.5 g/h standard related in any way to the crib fuel standard of 2.0 g/h.  (See Section 60.532(b) in the 2015 NSPS.)  In short, EPA never conducted any M301 Validation tests to compare the emissions from the 2 different test methods (EPA M28/ M28R and ASTM E3053) used to determine PM emissions from wood stoves.  Thus, any use of the 2.5 g/h standard in the deliberations that led to the content in the NSSIP is both arbitrary and capricious.

 

            2. The Alaska Department of Environmental Conservation’s (ADEC) choice of a 6.0 g/h PM emission limit has also been made without any similar supporting data.  Thus it is also arbitrary and capricious.  

 

3. The 6.0 g/h PM emission limit is also arbitrary and capricious because it does not differentiate between the two test methods, EPA M28/ M28R and ASTM E3053, presently being used to certify wood stoves.  The operating and fueling protocols in these two test methods are very, very different.  The EPA M28/ M28R requires hot to hot tests for all tests with the crib fuel loads made from dimensional lumber (2x4’s and 4X4’s) that uses a loading density of 7 lbs. ±10%.  ASTM E3053 requires a cold to hot start for the High burn, hot to hot starts for the Medium and Low burns.  The fuel used in ASTM E3053 is cord wood with a loading density of 10 lbs. ±5% for the High burn and 12 lbs. ±5% for the Medium and Low burns.  Just the difference in fuel type (crib fuel vs. cordwood) and loading densities (7 lbs. ±10% vs. 10 lbs. ±5%/ 12 lbs. ±5%) would suggest that the 6.0 g/h limit can not be applied evenly to these two methods. 

 

4. Given the way the stoves burn during these tests, especially for the ASTM E3053 cold start High burn, the 60 minute filter pull 

happens at very different times in terms of what is taking place in the firebox.  On smaller stoves being tested with ASTM E3053, it is very possible that the filter changed at 60 minutes will contain all of the emissions from the cold start (K/S) phase plus a portion, the dirtiest portion that includes coal bed leveling, loading and ignition of the High burn fuel load.  Here again, the failure to differentiate between what is happening in the firebox on stoves of different sizes renders the 6.0 g/h unfair and arbitrary and capricious.

 

5. The same is true for the larger fuel loads required in the ASTM E3053 tests, i.e., higher loading densities means larger/heavier fuel loads, which take longer to ignite, so the emissions will understandably be higher during the first 60 minutes.  Again no differentiation, which is unfair, arbitrary and capricious.

 

     6. The 6.0 g/h 60 minute PM emission limit is being applied in an ex post facto manner.  Had manufacturer’s known about this limit in advance, they would have had the opportunity to change their wood stove designs and bring their stoves into compliance.  However, that is not the case with the presently proposed rules because the 6.0 g/h rule is being applied to stoves already certified.  That, again, is grossly unfair, not to mention arbitrary and capricious.  

 

     7. The ADEC’s certification stove review process is horribly skewed, because it requires documents that were never previously required in the EPA certification process.  Here I am referring to the newly required documents titled “Document of Run Appropriateness”, “Document of Run Validity”, “Document of Run Anomalies” and “Document of Run Burn Rates”.  These documents are nothing more than “boilerplate” and do nothing to effect the actual test results.  Again, this is grossly unfair, not to mention arbitrary and capricious. 

 

8. In addition, the ADEC review criteria often establishes other new criteria that, in effect, establish new more stringent criteria that must be met before a stove can obtain ADEC approval.  One of these is the establishment of an undefined requirement for the medium dry burn rate for cord wood stoves.  The question asked in the ADEC’s Summary of Review” in the “Comments” section is essentially, “Why is this Medium primary air control setting representative of what is needed for a Medium burn?”  Yet the data presented show that the dry burn rate in the test report meets the requirement set forth in the test method.  Thus, the ADEC is revising test criteria after the fact.  Again this is grossly unfair, not to mention arbitrary and capricious. 

 

9. Similarly, the ADEC’s Summary of Review for wood stoves certified with cord wood using ASTM E3053 seems have a minimum requirement that at least 50% of one side of each fuel piece be covered with bark.  Yet that 50% requirement clearly contradicts what is found Section 3.29 in the recently approved Integrated Duty Cycle (IDC) test method (EPA Alternate Test Method ALT-140) which states in part:

 

“…Test fuel charge – the collection of test fuel pieces used in   each of the four phases of the test run.  L2, L3, and L4 require that at least 5% of the individual pieces with at least 80% bark on one side of the fuel piece…”  

 

 ASTM E3053 Section 8.4.2.1 states that

 

“…Only cordwood pieces that are free of decay, fungus and

loose bark shall be used…” 

 

Thus there is no “official” bark requirement in the ASTM standard.

 

However, in as much as the ADEC requested approval of the AK version of the IDC contains the above cited bark requirement, it seems hard to believe that the ADEC would require an even more stringent bark requirement for stoves tested with the ASTM test method than is required in the IDC test method the ADEC requested EPA approve.  Or is this, once again, just one more instance of an unfair, arbitrary and capricious decision making process.

 

10. The IDC test method as presently written (Version V7B_2.23.2021 AK IDC) and recently approved by EPA as ALT-140 can not be used as it is written.  Thus any mention of the above cited document in the entire NSSIP document as a means to improve air quality in the North Star Borough is unwarranted.  You can’t cite what you can’t use.  And any use of data generated via testing with the above version of the IDC, or any unapproved version of the IDC for that matter is also invalid, because the test method can’t be used as written.

 

11. Despite claims to the contrary, the IDC test method does not in any way reflect a real world operating scenario.  This is especially true of the Fairbanks North Borough where typical winter subzero temperatures would find homeowners operating their stove with the primary air control (PAC) wide open, not closed to the minimum primary air setting as is required for well over half of the IDC test, i.e., in the IDC test the PAC is set at wide open for the cold start portion of the test and the first 50% of the High burn fuel load weight.  After 50% of the High burn fuel load has been burnt, the PAC must be set to the minimum air setting for the rest of the High burn and all of the Maintenance fire phase, i.e., no additional air is allowed when the Maintenance fire fuel load is loaded into the stove.  The PAC stays at the minimum air setting until the start of the Overnight fire phase, when the PAC can be opened to the maximum setting for the first 10 minutes of a test and then the  PAC must be returned to the minimum air setting and must stay at that setting for the rest of the test.  Does that sound like a typical operating scenario for a stove in the North Star Borough when the outside temperature is less than 10-20 degrees F? 

 

10. If one looks at the entire US in terms of wood burning, Fairbanks is an “outlier” due to the extreme temperatures that occur there.  Thus, the solutions for resolving the air quality issues for Fairbanks may have little or no relevance to resolving air quality issues elsewhere in the US.  EPA needs to recognize this “outlier” status if it should chose to approve any of the suggested proposals to reduce the PM emissions form wood stoves in the Fairbanks area. 

 

11. And lastly, no matter which of the present test methods, i.e., EPA M28/ M28R, ASTM E3053 or the AK IDC, one would decide to use, the stoves certified via that test method will not work well in the field because of the difference in the draft (static pressure (pg)) generated by a freely communicated lab chimney versus the draft that is generated by a real world chimney that vents into the outside air.  Here research has shown that the draft generated by a 28 foot chimney vented into outside air that is 10F can double the dry burn rate of a stove.  Imagine what would happen to the dry burn rate and stove emissions when the outside temperature is -40F.  The Europeans have long recognized this problem and so have induced a draft (12-14 Pa) during their emission testing.  Now they are working on a new test method where the draft is varied over the course of a test run, with the variation in induced draft being determined by 4 different variables, chimney height, outside ambient temperature, flue gas temperature and flue gas static pressure.  Again, failure to recognize the problems with existing test methods and try to eliminate one or more in favor a perceived “better” method ignores reality.  Especially when no actual field testing ahs been done to validate these assumptions, which renders any preference for a particular test method arbitrary and capricious.  

 

In conclusion, many of the criteria the ADEC wished EPA to approve are not based upon scientific data and facts, but instead are simply an arbitrary and capricious choice. 

 

Thank you for the opportunity to present this testimony.

 

Ben Myren, President

Myren Consulting, Inc.

512 Williams Lake Road

Colville, WA 99114

email: <myren.ben@gmail.com>

Related stories

Alaska releases deficiency details on wood and pellet stove test reports (Nov. 2020)

AGH response to NESCAUM report on data from Alaska process (March 2021)

Alaska building list of cleaner, properly certified wood and pellet stoves (Oct. 2020)

Alaska building list of properly certified wood and pellet stoves

Lab certification test are designed to
burn as cleanly as possible and all
emission results must now be publicly
disclosed as of 2015.

Alaska Finds widespread deficiencies in EPA wood stove certification process 

Officials in Alaska are in the process of compiling lists of wood stoves and boilers that have met all the requirements of EPA certification and emit fewer particulates during the first hour of the test burn. Alaska regulations requires new wood heating appliances installed in the Fairbanks nonattainment area to meet additional regulatory requirements beyond obtaining a federal U.S. EPA certification. The regulations went into effect January 8, 2020 and Alaska has been working to implement those regulations since then.  The new regulatory requirements involve reviewing certification test reports for deficiencies and collected data regarding additional PM levels and then approve specific models of wood stoves and pellet stoves by updating their approved device list.

The Alaska Department of Environmental Conservation (ADEC) began this process as part of their efforts to address excess wood smoke pollution that contributed to Fairbanks becoming a non-attainment area.  The State’s Implementation Plan (SIP) to improve air quality began including measures years ago to crack down on dirtier wood burning appliances, such as outdoor wood boilers.

The current effort involves reviewing every stove’s certification paperwork to ensure that it includes all the elements that EPA regulations require, such as average CO, the manufacturer’s written instructions to the lab, firebox dimensions, efficiency calculations, burn rate calculations, raw data sheets, documentation of run anomalies, etc. etc. 

 

If you are not familiar with this brewing controversial initiative, you are not alone.  The first time most people outside a small group of manufacturers and regulators heard about this was a month ago, Sept. 18,  when a group of states weighed in on the litigation between HPBA and the EPA.  Their brief mentioned that the Alaska Department of Environmental Conservation was conducting a systematic review of wood-burning devices that have been certified to be compliant with EPA standards. The Department found that 59% of the certifications had inaccurate certification data, and that the EPA must have a way to check on manufacturers through audits. 

The start-up phase of a stove in the lab
should be consistent with how it is
described in the owner's manual.

The lists being developed by Alaska officials only pertain to what can and can’t be sold in the Fairbanks Nonattainment Area, a very small market.  But regulators, manufacturers and test labs we spoke to all say that this is having major repercussions.  For the EPA, it’s a wakeup call that they have not been sufficiently reviewing test lab reports before certifying stoves.  Test labs are under more scrutiny for various practices and are already  being asked by manufacturers to help ensure their tests come in under 6 grams during the first hour.  And scores of manufacturers are scurrying to provide additional information to Alaska and showing them the details that were in their test reports that Alaska officials missed.  

 

One of the main reasons that everyone is paying attention is that most of the people AGH spoke to agree that other states and change out programs could adopt the Alaska lists instead of using the full EPA list of certified heaters.  If more change-out programs, or even states adopt these stricter requirements, the efforts of a small city in Alaska will have greater national ramifications.  Some managers of change out programs that AGH spoke to say they interested to explore ways to identify cleaner cord wood stoves and are uncertain whether the EPA’s reduction from a de facto 4.5 to 2 grams an hour actually resulted in cleaner cord wood stoves. Incentive and change out programs often have adopted stricter efficiency and/or emission requirements and this may represent the next vehicle for those programs to guide how taxpayer dollars should best be used.

 

The last time state regulators made changes that went on to have national implications may have been in 1995 when Washington State adopted a 4.5 gram an hour state standard, when the EPA allowed up to 7.5 grams an hour.  The 4.5 gram an hour limit soon became a de facto national standard and 20 years later, HPBA insisted it was still the lowest that the EPA should go for the 2015 NSPS.  

Non-confidential portions of emission
test reports made the Alaska investigation
possible for the first time.

Aside from developing new lists of stoves that met all the requirements of the NSPS and emitted less than 6 grams for the first hour of all their certification test runs, Alaska is providing a wealth of information to the EPA, NESCAUM and others who are already in the process of developing a new federal reference test method for certifying wood stoves.  Some regulators the Alliance for Green Heat (AGH) spoke to now acknowledge that they see the current system as “broken” and that no one knew it was so broken.  On November 16, Alaska will be making its data public, showing which requirements in the stove certification process are most commonly ignored or overlooked and which ones are complied with.  

 

The data to be released on Nov. 16 includes a two-page data sheet on individual stoves, showing any deficiencies in their test lab reports.   Each manufacturer will have had up to 2 months to review their own sheets and provide corrections to ADEC prior to their public release.  The initial sheets prepared by ADEC have numerous mistakes according to several manufactures AGH spoke to and include many of the data points that ADEC initially said were not in their test report.  Test labs have been helping manufacturers find relevant data in their test reports, and ADEC will continue making corrections before and after Nov. 16.

 

It’s not yet clear if any test lab reports may be so deficient that the EPA could revoke their certification or require that the stove be tested again.  EPA officials are just beginning to grapple with how widespread the problems may be and what they can do moving forward to help fix problems that should have been in plain sight for so long. The EPA has identified and tried to correct some testing deficiencies in the past.  An AGH blog in July 2019 covered an EPA memo asking labs to correct lapses in reports on stoves tested with the ASTM E3053 test method.  This incident may have contributed to greater scrutiny by states including Alaska’s far more in-depth investigation.

An ADEC official taking
air quality readings on top
of a school.

The EPA certifies stoves based on the weighted average of the entire burn but requires labs to also report the amount of PM in the first hour.  Like efficiency, its data that must be collected and reported by the lab to the EPA, but there is no regulatory limit.  The Alaska initiative is making everyone ask whether the first hour of emissions may be an equally important indicator of a stoves cleanliness than the entire burn cycle.  

 

Currently, the way EPA approved test labs test stoves is by using the standard Method 28 or a variation of it. Lab technicians load stoves with an amount of wood based on the size of the firebox and let the fire go until all the wood is burned, which usually takes anywhere from 4 – 9 hours but can be longer.  During the last several hours of the burn, known as the “tail”, there is virtually no particulate matter being released, but those hours are still averaged into the overall calculation, with much be less than 2 grams an hour with cribs, or 2.5 grams an hour with cordwood. 

 

AGH reviewed scores of test reports and found that single PM reading from the first hour could be as high as 20 grams an hour and the average of all the first hour burns could be as high as 10 grams an hour, but it would be less than 2 grams when the cleaner parts of the burn and especially the tail end of the burn was included.  For Alaska, if any single run went over 6 grams, it was rejected.  Since start-up is the dirtiest part of the burn, identifying stoves that have cleaner start-up may help airsheds improve air quality.

 

Test labs that AGH spoke to noted that this will likely have the result of disqualifying a greater proportion of larger fireboxes.  The average firebox size is 2.2 cubic feet and an initial small sample of stoves with average first hour emissions over 6 grams was 3 grams an hour.  One test lab also said that this could disadvantage catalytic stoves that have no secondary combustion during start up prior to engaging the catalyst, which often occurs 20 – 30 minutes after lighting the fire.  Hybrid stoves, however, that use both air tubes and a catalyst are likely to have cleaner start-up, according to test labs.

 

Some manufacturers are angry that a state is using a brand-new emission metric – first hour emissions – that they could have designed for, if they knew it would be used in some markets to regulate stoves.  Now that it has been flagged, manufacturers certifying stoves going forward can try to meet that – or at least urge the lab to build  the type of start-up fire that will come in under 6 grams.  One of the primary goals of a lab is to familiarize themselves with the stove being tested so they can “optimize stove operations during certification testing.” Some regulators fear that this will just become another factor that manufacturers and labs will use to “game the system.”

 

The Alaska initiative will have a far greater impact on wood stoves than pellet stoves.  Extremely few pellet stoves emit more than 6 grams in their first hour and the testing regimen is more straightforward.  Ultimately, only a dozen or fewer pellet stoves may be disqualified by their review, out of the 98 models that are currently certified. Of the 144 currently certified wood stoves, up to a quarter to a third could be impacted.   New outdoor wood boilers are not allowed in Fairbanks already.  They will be reviewing pellet boilers for compliance.

An inversion in Fairbanks that traps
wood smoke close to the ground.,

Next steps

 

As of Nov. 16, Alaska will publish its review on virtually every EPA certified stoves.  On December 1, only those stoves that ADEC found had complete test reports will remain on the approved device list and be allowed to be sold in Fairbanks.  If a manufacturer needs more time to address potential report deficiencies, they can contact ADEC and if they commit to working to correct the deficiencies, their device may remain on the approved device list.  The first hour emission of 6 grams on each test run requirement, went into effect on September 1, 2020, and those devices have already been removed from the approved device list. 

 

Other jurisdictions, incentive and change-out programs will likely begin assessing whether the Alaska list represents better stoves for public funding.  Consumers who really care about a cleaner stove could also check that list before buying a stove.  For now, there are more questions than answers but the bottom line for everyone in the industry and the wider renewable heating community is that this is a story to watch.

Related stories

Veteran lab technician challenges Alaska's wood stove criteria (March 2021)

Alaska releases deficiency details on wood and pellet stove test reports (Nov. 2020)

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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