The draft NSPS appears to treat all biomass stoves, pellet
or wood, catalytic or non-catalytic, the same and require that they emit no
more than 4.5 grams of fine particulate emissions (PM2.5) per hour, a standard
that has been in place in Washington State since 1995. The average pellet stove today emits about 2
grams per hour, already less than half of the proposed standards.
Hydronic heaters, commonly known as outdoor wood boilers,
would also be held to existing standards that were developed about 5 years ago. However, the new NSPS would regulate
sales and installations of these appliances across the entire country, instead
of just the approximately 10 states that have adopted the voluntary EPA
standard.
While the new NSPS may reflect the status quo in many states
in the near future, it could become far stricter for both stoves and
boilers. In 2019, the test method for measuring
stove emissions could change, for example, from averaging four burn rates to using
only the highest or lowest burn rate (depending on which one the stove has the
hardest time passing). Some in the
industry think this standard will be a death-blow for stove manufacturers. Other experts say it will be achievable, but the
stoves that will be made may not be as appealing to consumers.
The written document EPA released this month did not contain
any numerical limits that industry would have to meet in the future, but Gil
Wood, EPA’s lead official on this NSPS verbally shared numbers with roomful of
stove and boiler manufacturers who had gathered in Orlando Florida for the
annual HBPA Expo. The Alliance for
Green Heat requested a copy to make available to the public, which the EPA
provided.
The EPA has backed off of creating a required minimum
efficiency standard, which all other HVAC technology has, in favor of testing
and publicly reporting efficiency to the consumer. The industry position is that reporting
efficiency is sufficient and enables the consumer to decide if they want the
equivalent of a gas guzzler or a gas miser as their home heating appliance.
There is much speculation about how the new EPA
Administrator, Gina McCarthy, will impact the NSPS. Administrator McCarthy had been head of the
air quality division at EPA and has a good working knowledge of solid fuel
appliances. And, McCarthy has already
reportedly asked tough questions about why fireplaces are not covered in this
NSPS.
Many in industry are simply tired of an agency that appears
to keep changing its mind about how strictly wood heating appliances should be
regulated. As of last fall, EPA appeared
to have something close to a final draft of the new NSPS that was more
acceptable to industry but considered far too weak by many states.
States now appear to have strengthened their hand. By adopting a stepped approach, the new NSPS
may do little to make stoves or boilers any cleaner before 2019 in the Northeast
and Northwest, where states have already adopted standards that are as strict
as or even stricter than what the EPA is proposing.
The most immediate impact upon promulgation, which could be
in 2014, is that unregulated outdoor wood boilers would go off the market in
all states. But there is a growing
movement that feels even Test Method 28 WHH and standards for EPA qualified
outdoor boilers still are deeply flawed, even after Method 28 OHH was improved
to Method 28 WHH. It is still unclear how boilers will be tested for 2014
compliance and how existing voluntary tests will be validated.
Brookhaven National Laboratory recently completed a study
that resulted in a new test method being created for both outdoor
wood boilers and indoor boilers that have partial thermal storage. Funded mainly by NYSERDA with some support
from EPA, this method draws upon the
ASTM method and Method 28 WHH. It can be
used instead of Method 28 WHH for any boiler with partial thermal storage. New York State has already accepted the test
method which will help open up the state up to European and American boilers
with thermal storage.
The Brookhaven
Method is also similar to the ASTM Method 2618 and could replace that method as
well, but has it has not yet been introduced into the ASTM process. The test
method is more stringent than Method 28 and the European EN 303-5 but it may be
a quicker and cheaper test for manufacturers to undertake. It is still unclear if the Brookhaven method
could be part of this NSPS or not. That
will likely depend on how much the states push for it and whether industry pushes
back.
The EPA’s latest timetable suggests it will have a final
draft of the new NSPS ready for internal review in April and the agency will
publish the standard in the Federal Register this summer. Industry, states, non-profits and the public
will then have 90 days within which to submit comments. The final rule would be promulgated and go
into effect in the summer of 2014.
The EPA has yet to meet any of their timetables for this
NSPS. There is always the chance that
someone will sue the EPA simply to get a court-ordered timetable that it would
have to adhere to. And, lawsuits based
on substantive regulations are also possible, if not likely, from a variety of
fronts, if acceptable compromises cannot
be reached.
Gina McCarthy and Janet McCabe seem open for discussion about an NSPS for wood burning fireplaces. They have received letters requesting an NSPS from the American Lung Association, ECOS, NACAA, Westar, Nescaum and several major fireplace manufacturers.
ReplyDeleteWhy don't the government worry about more important things. There are way bigger issues than wood burning stoves that have been around for ever.
ReplyDeleteCompletely ridiculous what’s next regulating fireplaces in our houses?
ReplyDeleteAs usual EPA is still in bed w/industry. Gil Woods meets w/them and then does NSPS light. The regulations for wood boilers is a clear example of how EPA is not one bit concerned about the public's health when it comes to wood smoke. Why would boilers not be held to same standards as stoves? Same carcinogens as cigarettes, people's houses engulfed in smoke, exposure to VOCs, PM 2.5, and PAHs and Mr. Woods is busy showing off his NSPS light to the HPBA in Florida at their conference. People's lives have been ruined and people have suffered heart attacks, cancer, and asthma attacks and Mr. Woods is still glad handing the industry. No big surprise that industry was successful in getting Voluntary Program to be the proposed sanctioned. 95 g/hr vs. 4 g/hr in emissions. Corrupt. Mr. Woods is corrupt and cares not a bit about public health. Wood Boilers are inefficient and subject their owners and neighborhoods to horrendous pollution. Here's hoping Mr. Woods gets a dose of it some day since he obviously does not get it. Industry doing own testing. NYSERDA study showing EPA data 90% missing or incomplete for Voluntary Program on boilers. Bad data and now Mr. Woods wants to make this the regulation level. Corrupt is the only word for Mr. Woods. He should be fired and his pension taken away. Junket to Florida indeed. Disgusting.
ReplyDeleteHow can you even allow this ridiculous post to be approved by your site? Allowing someone to post completely false and defamatory information about an EPA official is scandalous! EPA - by law - is required to work with people/companies within the industries they are regulating and this EPA official delivers an EPA message to the industry and gets lambasted with false statement and information from some anti-wood burning activist and you post it. What a joke!
DeleteI totally agree, where is the balance, as it is the latest round of mandates will kill many manufactures who don't have the ability to meet the standard, Only a few companies will survive. Clean air is good for everyone, but so are American jobs.
DeleteMany Outdoor Boiler manufacturers will not be able to meet the latest round of EPA Regulations in 2014, they will be out of business just like hundreds of companies that went under after the EPA regulated woodstoves way back when. Today we have some very clean burning woodstoves and have made progress in cleaning them up. Other boiler manufactures like Econoburn and Woodmaster have worked very hard to meet them. Unfortunately the first two round of testing requirements was not fair as boilers and woodstoves are two different animals so the testing was flawed. There needs to be a better standard and the EPA has had a hard time figuring out what this is. They have a mandate to work together with manufactures to give them time to accomplish the EPAs goals, as well they should, it is only fair as jobs are at stake here. We all want cleaner burning products, however we need a standard testing procedures that yields the same results regardless if the boiler is tested at Omini, Interlake, or Brookhaven labs. NYSERDA has taken the lead on this and done a good job at sorting this mess out, hopefully we can soon have a standard we can all live by. Slandering Mr. Woods who has been handed a can of worms, or the EPA for that matter is childish in my humble opinion. How come no one here has the Kahunas to reveal themselves but prefers to remain "Anonymous" ? Maybe that gives them the right to spew forth garbage....I don't think so. Industries are at stake here as well as livelihoods, I applaud the EPA trying to work with these manufacturers, to come up with a workable standard, unfortunately it has not gone as planned. Manufactures have no control over clowns who think that burning tires in their OWBs is OK. Once again it is a few fools who make it tough on everyone else. Burning Biomass and wood is a renewable energy and good for the environment and the economy, lets not forget the facts for the sake of arguments.
DeleteI was at the meeting in Florida when Mr. Woods presented the NSPS update. Sorry Mr. Anonymous, Mr. Woods did not get a "Junket to Florida", he addressed the audience by conference call from his office at the EPA.
ReplyDeleteThe proposed limit to outdoor wood fired hydronic heaters is measured in pounds per million BTU. EPA has indicated a limit of 0.32 lbs./Million BTU for phase 1. The limit of 95 grams an hour posted above is incorrect and I would like to know where that number came from. The difference between units that are not qualified Vs. units that are is night and day. Many qualified units, when run properly by the users, emit less emissions than some wood stoves.
ReplyDelete