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The correct application of this requirement would be to determine the Medium Burn Rate
Category at a level below 50% of the span between the Maximum Burn Rate and the Low Burn
Rate (a non-zero value). Ergo, the correct calculation for finding that midpoint of 50% is defined
as
.
For example, if the Maximum Burn rate of an appliance is 1.79 kg/hr and the minimum is 1.23
kg/hr, the method would currently place the 50% requirement at 0.895 kg/hr. This is
unachievable on this appliance and presents an impossible compliance requirement. Applying the
equation laid out above the value of 1.51 is derived and, therefore, presents an appropriate and
likely attainable emissions test requirement for the Medium Burn Rate Category.
During your reviews of such emissions tests, as reported to OECA and intended for compliance
certification purposes, MTG recommends applying the above procedure in order to ascertain if a
Medium Burn Rate was appropriately established during a compliance test.
CC:
Sarah Ayres - OECA
Angelina Brashear – OAQPS
Alice Edwards – Alaska DEC
Chuck French – OAQPS
Robert Lischinsky - OECA
Theresa Lowe - OAQPS
Rafael Sanchez – OECA
Robert Scinta - OECA
Mike Toney – OAQPS
Nathan Topham - OAQPS
Chet Wayland – OAQPS
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