EPA's cordwood test protocol for wood stoves moves forward

 AGH wrote to the EPA in June and again in early July, requesting public information about the stove testing that it is undertaking.  We had seen numerous references about the stove testing but could not find more details about it.  Rather than submitting a Freedom of Information request, which would likely provide a jumble of emails and miscellaneous documents, we urged the EPA to provide an overview.  Details about the EPA’s stove testing program are well known by HPBA insiders, and by staff at NESCAUM and NSERDA, yet we have consistently found that the EPA, nor those organizations, share information very well. This blog may be updated soon with rejoinders from experts who take issue with the EPA's narrative.  

This letter from the EPA partially explains how and why the EPA approved an IDC (ALT-140) test method without a full certification test report using that method.  NYSERDA and NESCAUM still have not produced certification level test data for their IDC method "although we [the EPA] understand that Alaska will be providing us with additional data demonstrating use of the ALT-140 for compliance testing."  

In the past 10 years, the EPA has rarely had any budget for lab testing, so its current budget of one million is significant.  AGH believes that its imperative for the EPA to develop its own data and not just rely either on industry or groups like NESCAUM and NYSERDA.  We reproduce below the email verbatim from Stef Johnson, leader of the EPA's Measurement Technology Group.  The photos were added by us.

July 20, 2021

Dear Mr. Ackerly: 

 

Thank you for the questions you forwarded in your July 9, 2021 email.  I appreciate the thoughtfulness of you questions and the opportunity to engage with you on this important topic.  In particular, I’d like to clarify the steps in EPA’s processes for: 

·         New Test Method Development and

·         Alternate Test Methods (ATM) 

 

New Test Method Development 

 

In the method development process, EPA creates new measurement methods for regulatory purposes.  In the case of EPA developing new test methods for wood heaters, EPA has embarked on a public process that engages stakeholders as we develop a new measurement method for this sector.  EPA’s Measurement Technology Group, the group I lead, began the process by convening a Roundtable consisting of manufacturers, Hearth Patio & Barbeque Association (HPBA) staff, state and local regulators, test lab technical staff, and multijurisdictional organization (MJO) representatives.  The Roundtable participants gathered to discuss the use and vetting of the Integrated Duty Cycle (IDC) method for certification of wood fired stoves and consider making that testing approach an EPA test method.   

 

After the January 2020 meeting where we discussed the IDC approach and the ASTM E3053 test approach, the agency determined that we would pursue development of the IDC as an EPA method.  We have been working in that direction ever since.  The process to conduct method precision testing of an IDC for wood heaters, one for hydronic heaters, one for forced-air furnaces, and one for pellet heaters is resource intensive and complex.   

 

EPA remains committed to transparency and open dialogue as we explore and develop new methods for compliance testing of wood heating appliances.  We have provided the Roundtable group information about our Quality Assurance Project Plan (QAPP), the IDC method for wood heaters -- the current subject of our trials, and the Tapered Element Oscillating Microbalance (TEOM) Standard Operating Procedures.  We have also shared supporting spreadsheets for using these methodologies.  We have posted this and other information in a public docket (EPA-HQ-OAR-2016-0130) and we have begun using this posted IDC, along with TEOM measurements in our contracted laboratory.     

 

The EPA is paying for 26 tests at PFS-
TECO testing in Portland, OR.

We are conducting 52 tests (26 paired tests) at a West Coast lab (PFS-TECO) and will be comparing those data to a duplicate effort that will be funded by NYSERDA and conducted at ClearStak laboratories in Connecticut.  Within each lab, we are doing paired testing to look at intra-laboratory variability -- known as repeatability testing.  We will be comparing the inter-lab variability (method reproducibility) between these bi-coastal sets of 26 test pairs.  This helps us understand the test method performance with respect to overall variability and informs our decisions as to the appropriateness of the test method for use with a given emissions standard.  EPA has committed nearly $1,000,000 to the West Coast portion of wood heater test method work, and to a study of TEOM precision to be done at EPA’s facility in Research Triangle Park, NC.  This type of data has never been collected for any wood burning appliance test method to date.   

 

All data we develop from our trials will be publicly available and placed into the same docket as the QAPP and IDC /TEOM methodologies.  We will convene the Roundtable after the wood heater precision testing is complete and we have data to discuss.  Certainly, there will be lessons learned along the way and improvements made.  As you may know, NYSERDA is also conducting wood heater precision testing, and we expect that they will make their data public.  East Coast testing will likely begin in mid-September.  We anticipate that a full data set will be available for discussion by in early 2022.  Again, this is for the development of a wood heater IDC compliance test method.  Finally, we will propose, take public comment, and finalize a new compliance test method.  All of this will be a public process, and all of the data will be available for review.   

NYSERDA is paying for 26 tests of
the same stoves at ClearStak in
Connecticut.  ClearStak offers
transparency in testing by video taping 
the tests but it is not known if these 
tests will be videotaped or if the tapes
will be released to the public.

 

Alternative Test Methods 

 

The Alternate Test Method (ATM) approval process is different than compliance test method development.   In the ATM process, the requestor is responsible for providing sufficient information to the agency to demonstrate that the proposed Alternate Test Method is appropriate for compliance testing purposes.   Requesting an ATM is an option available to any affected party. The proposed ATM must be deemed by the Measurement Technology Group to be appropriate with the final air pollution standard.  The entity requesting the ATM must demonstrate compliance with a Federal subpart regulated by 40 CFR Part 60, such as subparts AAA or QQQQ regulating wood burning residential heating appliances. 

 

EPA’s Measurement Technology Group receives requests for alternate means of compliance testing from affected source categories, from electric utilities to wood heater manufacturers and everything in between.  We are responsible for reviewing each request and make a technical determination about the appropriateness.  We either work in a direct back/forth manner with the requestor or we agree to the request with some stipulations. (You will note we listed several in our 2021 ALT-140 approval letter).  

 

In sum, the ATM approval process is a technical exchange with a requestor followed by a technical evaluation by my staff.  The goal is to approve compliance testing that meets a specific need and is appropriate for the compliance purpose as outlined in the rule.  While such evaluations may involve exchange of data between the requestor and EPA, each request is evaluated and assessed on a case-by-case basis.  

 

In situations where there is not any test method available, for example, EPA will evaluate the request differently than in situations where we have already approved an ATM.  With regard to ALT-140, we have had the opportunity to learn about the IDC development process through multi-party meetings from 2017 to 2020.  The information shared during this time about the IDC illustrated that this method provides a more rigorous test assessment of heater performance and therefore, provides a more conservative compliance demonstration approach.  Such conservative approaches (more difficult to pass the test) are nearly ideal for Alternate Test Method processes because one of our goals with the ATM process is to not relax the standard in any manner.   

 

That said, when EPA received Alaska’s request to approve an alternative test method for demonstrating compliance with the New Source Performance Standard Subpart AAA, Standards for New Residential Wood Heaters in December 2020, we were not aware of data that demonstrated that a wood heater could meet the emissions limit of the rule using the IDC.  Therefore, we asked Alaska to provide us with that information.  While what they provided to EPA is not an entire test report, it is credible enough for us to allow the use of the test method for compliance demonstration, where a compliance test must fully document all of the test method QA/QC details to satisfy EPA’s Office of Enforcement and Compliance Assurance (OECA)’s requirements.   

 

Finally, using an ATM itself is optional and my staff ensures that all alternative methods are equivalent or more stringent than the test method in the EPA regulation.  No one need ask to use one unless they decide that it is in their interest to do so.   In the case of the Alaska request, EPA’s approval of ALT-140 provides a cord wood compliance pathway for manufacturers wishing to sell in the Fairbanks-North Star area.  They are also free to conduct crib fuel tests and sell crib fuel tested units in that area.   

 

Finally, EPA has received 5 spreadsheets from NYSERDA/NESCAUM in support the Alaska ALT-140 request and they are available upon request.  To date, EPA has not received any other NYSERDA/NESCAUM test data used for their IDC method development purposes, although we understand that Alaska will be providing us with additional data demonstrating use of the ALT-140 for compliance testing.  

 

I hope this has been helpful for your understanding.   

 

Very sincerely, 

 

Steffan Johnson

Leader - Measurement Technology Group

US Environmental Protection Agency (EPA)

Related stories

Nine states urge the EPA to revoke the ASTM cordwood method (May 2021)

EPA announces overhaul of wood stove certification process (April 2021)

AGH response to NESCAUM report on wood stoves (March 2021)

EPA and states vigorously defend audits of wood stoves (Sept. 2020)

EPA finds lapses in cordwood certification testing (July 2019)

Stove manufacturer documents scores of errors in NESCAUM report

NESCAUM responds to Morrissey as he issues Part 2 of his review

Tom Morrissey, owner of Woodstock Soapstone, a wood stove manufacturer, has written a blistering critique of a report that claimed the EPA wood stove certification process is “dysfunctional.”  

Tom Morrissey at his factory 
in West Lebanon, NH

The review by this independent manufacturer further ratchets up a conflict that has engulfed a section of EPA’s Office of Air and Radiation.  The original report, “Assessment of EPA’s Residential Wood Heater Certification Program" by the Northeast States for Coordinated Air Use Management (NESCAUM), issued in March 2021, was based on a review of all test lab certification documents that had been sent to EPA to certify stoves to EPA’s regulatory standards.  The review was conducted jointly by the Alaska Department of Conservation (ADEC) and NESCAUM, with funding from the New York State Energy Research and Development Authority (NYSERDA). 

(June update: Tom Morrissey released part 2 of his review on June 15 and three days later, NESCAUM released their rebuttal to Morrissey's initial review.  NESCAUM appears to be standing behind its entire report and did not find any merit in Morrissey's critique.  On page 21, NESCAUM also addressed editorial comments in AGH's blog. Part 2 of Morrissey's critique mainly focuses on burn rate requirements adopted by ADEC as a deficiency, but not used by NYSERDA's IDC test method.  Morrissey also describes why the IDC will likely result in lower efficiencies because BTUs in the tail of the burn are not included and questions if the EPA should ever approve a test method where underlying calculations are not public.  AGH agrees with a substantial amount of the content in both the NESCAUM report and Morrissey's rejoinders and believe it's important for EPA officials, states and experts to consider both.)

NESCAUM and ADEC accused the EPA of running a dysfunctional certification program that “is easily manipulated by manufacturers and testing laboratories” and “EPA has done little to no oversight and enforcement.” Morrissey counters that NESCAUM and ADEC also have produced a dysfunctional assessment of the EPA program that is full of “error, bias and conflict of interest.”

We have excerpted key parts of Morrissey’s review below.  The full review, with scores of photos, can be downloaded here.  The Alliance for Green Heat believes it is important to consider both the NESCAUM report and rejoinders from Morrissey and another one from veteran lab technician Ben Myren together.  We believe there is substantial truth in all three of these documents.  Our initial response to the NESCAUM report was that it “overstated” its case, and AGH welcomes expert rejoinders that bring some balance to the conversation.  However, AGH still believes that EPA should take the NESCAUM report seriously because it is clear that the EPA certification and enforcement programs need significant improvement, and that these have been underfunded, understaffed and overlooked within the EPA.  

AGH also agrees that much of ADEC’s and NESCAUM’s review was hastily done without sufficient fact-checking.  The report carries an unfounded degree of authority that is now reverberating throughout the wood stove industry and its state and federal regulators, and the wider public is less likely to see these rejoinders.  NESCAUM and ADEC now have the opportunity to respond and explain some of the allegations in Morrissey's review or continue to stand behind that data that led to their conclusions. Numerous individuals have approached northeastern state government agencies who are members of NESCAUM, urging them to distance themselves from the report and not let their agency names be used on such reports in the future without more due diligence.

In early April, in response to the NESCAUM report, the EPA announced they were conducting an in-depth review of the certification process.  They placed most of the blame on the test labs and third party certifiers.  Morrissey’s review may cause the EPA to rethink its strategy and not put undue trust in the finding of the NESCAUM report.  Morrissey’s review is significant because he is not a member of the wood stove industry association and has often taken sides for and against industry interests – and the EPA’s. This is part 1 of his review and he expects to complete the second part in June.

AGH is concerned that the NESCAUM report, media coverage of it, and Morrissey and Myren’s rejoinder put so much focus on the inherent problems with wood stoves and the pollution they can cause, that the benefits of pellet stoves get overlooked.  Virtually nowhere is there recognition of the technology and reliability of pellet stoves and boilers as a far cleaner, renewable energy technology that can help households and businesses get off fossil heating fuel.  

Excerpts:

REVIEW (PART 1)

of

“ASSESSMENT OF EPA’s RESIDENTIAL WOOD HEATER CERTIFICATION PROGRAM” Written by NESCAUM, March 2021 

Page 1: In March 2021, the Northeast States for Coordinated Air Use Management (NESCAUM) published a document entitled “Assessment of EPA’s Residential Wood Heater Program (“Assessment”). The “Assessment” is the result of a review conducted by NESCAUM “in collaboration with the Alaska Department of Environmental Conservation” (ADEC). 

The “Assessment” is intended to influence “policymakers” by claiming 1) that the EPA Certification Program is dysfunctional and a systemic failure, 2) that there are a significant number of discrepancies and omissions in test reports submitted to EPA for approval, 3) that EPA has failed to conduct compliance audits, and 4) that the NESCAUM and ADEC could do a better job than EPA in, a) deter- mining which stoves are in fact the cleanest burning and, b) developing a test method for certifying wood burning appliances. NESCAUM has provided scant data to back up these major claims, and some of the data that it does present is riddled with discrepancies, omissions, bias errors, and conflict of interest, as detailed below. Bias is evident everywhere; in tone and use of language, in lack of transparency, in the selection of subjective criteria to attempt to discredit test methods and results, and in its attempt to advance NESCAUM’s own agenda4 with its “policy recommendations.” The bias is so pervasive that it undermines much of the “Assessment.” 

Page 3: In order to assess NESCAUM/ADEC’s data analysis and conclusions, we need to first look care- fully at its data collection methods and ask whether the underlying data is complete, credible, and unbiased. The main focus of this Part One of A Review of the “Assessment” is on how data was collected and tallied on “Summary Review Sheets” by ADEC. 

On the following pages I raise concerns about quality control, bias, and conflict of interest in NESCAUM/ADEC’s acquisition of data. It is clear that NESCAUM/ADEC reviewers lacked objectivity in assessing information, particularly with regards to the ASTM E-3053 method, and they reviewed individual test reports (knowingly or not) with the intent to discredit the ASTM E-3053 and advance their own interest in promoting the IDCTM method. 

Page 4: All ADEC data sheets that I have reviewed are undated and unsigned. Most have few, if any comments.  Many have unfilled spreadsheet boxes (data not collected). All of the ADEC reports of stoves made by Woodstock Soapstone Company have serious omissions, errors of fact, misreporting, and untrue statements. Of six Woodstock Soapstone Company models approved to the EPA 2020 Standards, two models were missing entirely, and one model was reviewed twice, on separate data sheets that were inconsistent and did not match (i.e., different reviewers looking at the same data, or the same reviewer on different dates looking at the same data). The fact that ADEC reviewed the same data twice, and the two completed spreadsheets are markedly different, speaks to the concern (also noted in footnote #2) about quality control. 

Page 5: On the pair of summary sheets where NESCAUM/ADEC inadvertently reviewed the same test report twice, there were 25 discrepancies between the two reports, including errors of transcription, op- posing claims that data was or was not reported, rounding errors, conflicting or inconsistent “flags” and numeric/arithmetic errors. This is not reassuring in terms of NESCAUM’s claimed consistency in generating the summary results, and raises the issue of whether NESCAUM’s own consistency and repeatability should be the subject of an audit. 

These two ADEC Summary Reports are reproduced on page 6, and an explanation of most of the errors on page 7. For simplicity sake, I refer to the report that is captioned Model 210a (but really Model 210) as Report A, and the Report that was (correctly) reviewing Model 210 as Report B. Both reports were posted and properly labeled on the Woodstock Soapstone website. But that’s not the point; these two reviews of the same report should produce similar, if not identical results, but they did not. 

These two Summary Sheets, which review the same test report,8 disclose obvious problems in the research and reporting methods employed by NESCAUM/ADEC, and the ability/willingness of NESCAUM/ADEC to impose meaningful quality controls on their inquiry. As noted early in this review (see footnote 2), there is little, if any, evidence of NESCAUM/ADEC cross-checking or vetting of the reviews or data in the “Assessment”. The task of auditing the “Assessment” and validating its so-called “data” and its various claims will now, probably, fall squarely on EPA. 

This is the central irony of this situation; NESCAUM’s own data and reporting is guilty of the same failures it attributes to EPA, namely failures in transparency, documentation, and auditing its own work product for consistency, impartiality, and accurateness. The EPA will now become responsible for cleaning up the NESCAUM mess. 

Page 8:  For the purpose of this initial review, I will focus mainly on stoves made by Woodstock Soap- stone Company. Next, I will examine the ADEC Summary Sheet for our Model 202/204. This is a “plain vanilla” Summary Sheet, compared to Model 210, on pages 6 and 7, above. 

ADEC encourages manufacturers to “review their certification test report summaries and submit corrections, and that any substantiated errors or corrections will be applied to the summary sheet.” So, I’ll just make the corrections here. On our Model 202/204, the initial ADEC summary sheet (see next page, LEFT COLUMN) makes the following errors (WHICH CUMULATIVELY TOTAL 13 FLAGS). I intend to address THREE ADDITIONAL RED FLAGS (related to Documentation of 1) run appropriateness, 2) run Validity, and 3) run anomalies on Part 2 of this Review. 

What is fascinating is that between early April 2021, when I downloaded the original Summary Review Sheet, and today (mid-May, 2021), ADEC performed an additional review and corrected some of its original errors, and made some new errors. Here are comments on the initial ADEC Summary Sheet. Comments on the revised Summary Sheet are on the next page. 

Page 10: According to the ADEC “PROCESS”, I am supposed to address all of these “issues” by

One of the many photos that
appear to provide evidence
contradicting ADEC "flags"

discussing them with ADEC, and maybe submitting modified or reformed test reports. Then ADEC will makes changes as it deems appropriate. Or not. 

Page 14: The “Assessment” claims that “90% of the stoves tested using ASTM E-3053 used debarked wood or failed to provide information about whether there was bark on the fuel.” (Assessment page 38) The “Assessment further claims that “61% of the stoves tested with ASTM E-3053 used squared wood for more than 50% of the pieces” (Assessment page 33), including the stove immediately above (Model 205) and the fuel for Model 202/204, pictured on pp 10-11. 

Based on my review, I cannot believe either of these claims. If the basic data underlying the “Assessment” is defective, then its claims of numerous deficiencies in testing and reporting, and its criticisms of ASTM E-3053 are suspect, because they are based on bad data. 

Page 19: I hope to have Part 2 in mid-June. There is a lot more to unpack in the “Assessment,” including: 

* The overall “Assessment” review strategy, and whether it is a credible basis for proceeding to the conclusions that the “Assessment” tries to come to. This strategy is basically to make a list of each and every requirement imposed by the NSPS, and then see if each and every item on the list can be identified in test reports, no matter how obscure or irrelevant the requirement might be. Otherwise, deficiencies are claimed by NESCAUM/ADEC without any apparent oversight or review, or any basis in fact. 

* The nexus of firebox size and calculation, loading direction, fuel length, and loading density. These are the second set of elements that the “Assessment” uses to criticize ASTM E-3053. 

* I’ll review this sentence, and how it has spawned innumerable “flags” (i.e., claims of violations of the NSPS) in the “Assessment’s flag-collection effort."

EPA announces extraordinary overhaul of wood stove certification program

Confidence in wood stove testing program shaken in wake of Alaska and NESCAUM exposé

Richard Wayland leads the nation’s
technical air quality management
programs

On Tuesday, April 5, the EPA published letters that they sent to wood stove testing labs, announcing they were embarking on a historic review of certification paperwork, similar to the examination that the state of Alaska is conducting.

 

The publication of the letters may have been prompted by a freedom of information request from a reporter, who got access to the letters hours before the EPA published them.

 

The overhaul could end up costing stove manufacturers large sums of money and the revocation of some models' certification.  This is sending reverberations throughout the manufacturing community of wood and pellet heating appliances, which has never faced such scrutiny and oversight since wood stoves were first required to be certified in 1988.

 

The EPA announcement is also derailing, at least temporarily, a move by members of Congress to refile legislation that would establish a national wood stove change out program heralded by industry as the best way to combat excessive wood smoke.  The EPA emphasized that local and state change out programs rely on EPA certification documents to help determine which stoves can achieve the best emission reductions. 

 

The immediate actions by the EPA include using a template similar to the one used by the state of Alaska to see if their review of deficiencies in paperwork matches the the state's review.  This indicates, as early reports confirm, that the EPA may not agree with some of the categories of deficiencies Alaska thought were significant.

 

The EPA is also announcing that starting immediately, they will be conducting far more intensive reviews of new certifications.  This is believed to also include the routine retesting waivers.  Under the current system, once a stove gets certified, it receives a 5-year certificate that can be renewed, without any additional testing, over and over.  While this benefits manufacturers who, prior to 2015, were still marketing stoves certified in the 1990s, it did not incentivize making even small improvements in the cleanliness or efficiency of the unit every 5 years.  

 

The letters to the EPA approved stove testing labs also put the labs under notice that they could lose their approved status if they do not improve their standard operating procedures. It is unclear why half of EPA approved labs and third-party certifiers appear to have expired approvals.  The newest third-party certifier, Guardian Fire Testing Laboratories, is based in New York, the state that has been providing most of the funding to NESCAUM through its energy department, NYSERDA.

List of EPA approved labs and 3rd
party certifiers who received letters

 

Although the letters the EPA sent to wood stove test labs dealt mostly with enforcement issues, they did not come from the EPA's Office of Enforcement, but rather from Richard Wayland, the Director of the Air Quality Assessment Division, which typically does not handle such measures.  Wayland’s Division is now under a new high profile political appointee, Joseph Goffman, who was one of Biden's top advisors during the presidential transition.  Under Goffman is Tomas Carbonell, the Deputy Assistant Administrator for Stationary Sources, another political appointee who worked on the 2015 wood heater NSPS during his tenure at the Environmental Defense Fund.  This may indicate a shifting and larger role for senior leadership at the Office of Air and Radiation, a potential sign that the Biden Administration is taking the NESCAUM report very seriously.

 

The EPA stopped short of implementing some of the recommendations in the NESCAUM report.  For instance, they have not yet indicated any interest in revoking an ASTM cordwood test method that NESCAUM and Alaska found to be flawed.  However, the agency did emphasize that the recently approved IDC cordwood test method could be used by any manufacturer and updated their approval of the method, possibly to correct an error found by veteran stove tester Ben Myren.  That error, which the Alliance for Green Heat highlighted in a recent blog, dealt with the amount of bark that must be left on logs during certification testing, and highlights the precarious role of the EPA in approving test methods where the underlying data has not been publicly released for experts to review.  It is unclear if EPA even had access to the IDC test method's underlying data which is owned by NYSERDA.  If the agency does have the data, it could make it available or it may have to disclose it through freedom of information requests.  

The EPA's announcement of this major overhaul comes just days after many top stove manufacturers and the main industry association, the Hearth, Patio & Barbecue Association,  filed comments vigorously opposing the results of the Alaska stove certification review. If the EPA does not approve Alaska's scheme of culling out stoves with too many deficiencies in their paperwork and which emit more than 6 grams an out during test runs, Alaska may be forced to only allow the new installation of pellet appliances in the Fairbanks area, that is fighting federal non-attainment status.

For many years, experts have known of the mounting complexities and loopholes in testing wood stoves. Then, by 2020, it became apparent that many stoves that were tested above 2 grams an hour were somehow able to test to below 2 grams an hour without being altered, calling into question whether the regulations led to a cleaner generation of wood stoves.  Pellet stoves and boilers however have genuinely become cleaner and more efficient from the tighter 2020 emission standards because of their automated functions and consistent fuel qualities. 

Related stories

EPA's cordwood test protocol moves forward (July 2021)

EPA and states vigorously defend stove audits (Sept. 2020)

Opinions of top stove industry insiders on controversial topics (Aug. 2017)

Study shows environmental advantages of pellet stoves and exaggerations by manufacturers (Oct. 2015)

 

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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