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MEMORANDUM
SUBJECT:
Appropriate calculation of Medium Burn Rate Category in ASTM E-2779 Testing
FROM:
Steffan Johnson
Group Leader
Measurement Technology Group
Air Quality Assessment Division
TO:
Robert Scinta, P.E.
Chief, Air Branch
Monitoring, Assistance, and Media Programs Division
Office of Compliance, Office of Enforcement and Compliance Assurance
During a recent review of pellet heater compliance test reports, the Measurement Technology
Group has uncovered an error in determining the appropriate Medium Burn Rate Category when
using ASTM E-2779 for compliance pursuant to 40 CFR 60, subpart AAA. Specifically, the
method requirements in section 9.4.1.2 and Table 1 of that test method incorrectly require that
the Medium Burn Rate Category must fall below 50% of the maximum burn rate. This is not
correct as this requirement assumes then that zero is the other bound for determining half of the
maximum.
02/02/2022
Digitally signed by
STEFFAN
STEFFAN JOHNSON
Date: 2022.02.02
JOHNSON
08:28:07 -05'00'
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