MEMORANDUM

TO: 		EPA Docket No. EPA-HQ-OAR-2018-0195

FROM: 	Nathan Topham, Environmental Engineer
      U.S. EPA/OAQPS/SPPD/MICG (D243-02)

DATE: 	July 10, 2020

SUBJECT: 	Summary of June 15, 2020 Meeting with PFI on April 2, 2020 Final Amendments to Residential Wood Heater New Source Performance Standards
												

Attendees
EPA's Office of Air Quality Planning and Standards (OAQPS) 
Pellet Fuels Institute (PFI)
American Lumber Standards Committee (ALSC)
Summary
Representatives for PFI and ALSC requested a meeting to discuss changes to regulatory language related to 3[rd] party certification of pellet fuel requirements and prohibited fuels that were finalized on April 2, 2020 (85 FR 18448).  
PFI stated that their accreditation and testing partners have expressed some concerns that under certain interpretations of the word `certification', satisfying the requirement may be difficult or commercially impracticable. 
PFI asked whether the word "certification" in the regulatory text was intended to mean that every bag of pellets or every individual pellet must be examined and tested for prohibited materials. PFI stated that such a requirement would be impractical and asked whether EPA meant for the language to be interpreted in this manner or whether a QA program to prevent systematic intentional introduction of prohibited materials was what EPA intended in the final rule. OAQPS staff informed PFI that sampling from every pellet was not the Agency's intention. EPA requested that PFI provide documentation in writing exactly what regulatory provisions PFI felt were unclear and any information available regarding the type of QA program that PFI thinks would be sufficient to certify pellets. PFI said they would provide the information requested by EPA. 
