United States Stove Company SP1000E, Manual

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Mr. John Steinert
Vice President
PFS TECO
11785 SE Hwy 212
Suite 305
Clackamas, OR 97015
Dear Mr. Steinert,
I am writing you in response to your correspondence dated February 3, 2022, in which you
request the use of an alternative testing procedure to demonstrate compliance with 40 CFR part
60, Subpart AAA – Standards of Performance for New Residential Wood Heaters (Subpart
AAA). The Office of Air Quality Planning and Standards, as the delegated authority, must make
the determination on any major alternatives to test methods and procedures required under 40
CFR parts 59, 60, 61, 63, and 65. Your proposed alternative test method and our approval
decisions are discussed below.
According to the information provided, you seek an alternative test method for use when
conducting testing on the United States Stove Company, Model KP5517 pellet heater. Currently,
as required by section 60.534(a)(l)(i) of Subpart AAA, a manufacturer has the option to test their
appliance in accordance with 40 CFR part 60, Appendix B, Method 28R for a crib fuel appliance
or ASTM E2779-10 “Standard Test Method for Determining Particulate Matter Emissions from
Pellet Heaters” (ASTM E2779-10) for a pellet fuel appliance. This request seeks an alternative to
section 9.4.1.2 of ASTM E2779-10 which specifies test conditions for pellet heaters including
the determination of the Medium Burn Rate Category and states that the medium burn rate must
be ≤ 50% of the maximum burn rate.
In your request, you state that the specification for determining the medium burn rate found in
ASTM E2779-10 is incorrect, and the Medium Burn Rate Category should be defined as less
than 50% of the midpoint point (this is defined in the attached Memo as 50% of the span
between the Maximum Burn Rate and the Low Burn Rate) between the high and low burn rates.
Furthermore, your request includes a memorandum dated February 2, 2022, titled “Appropriate
Calculation of Medium Burn Rate Category in ASTM E-2779 Testing” (attached) which was
sent to the EPA’s Office of Enforcement and Compliance Assurance. This memorandum states
that an error had been uncovered in determining the appropriate Medium Burn Rate Category in
ASTM E2779-10 for compliance pursuant to Subpart AAA. Specifically, section 9.4.1.2 of
ASTM E2779-10 states that “the pellet heater shall be operated with the control or controls set in
02/04/2022