By Norbert Senf,
Chair of Masonry Heater Association Technical Committee,
Chair of Masonry Heater Association Technical Committee,
and member of the Board of Advisors of the Alliance for Green Heat
EPA has
released the long awaited new version of their “New Source Performance
Standard”, which now includes masonry heaters in the section “RRRR”. In
the last edition of this Standard, released in 1988, masonry heaters were
exempted as “inherently clean burning”.
Norbert Senf lives in Quebec and has built masonry heaters for more than 30 years. |
The Masonry
Heater Association (MHA) technical committee has worked very hard to produce
written comments and recommendations to the Proposed Standard (P.S.).
The draft NSPS
proposes an emissions limit of 0.32 lb/MMBtu for particulates for masonry
heaters. HPBA is opposed to a lb/MMBtu limit, and is advocating for g/kg. In
g/kg terms, that would be about 1.8 g/kg, assuming 70% efficiency. HPBA
cites the fact that lb/MMBtu requires an efficiency number, and that there is
no EPA recognized efficiency test method for masonry heaters.
The MHA tech
committee feels that lb/MMBtu will eventually be a better way to compare
heating appliances, since it takes efficiency into account and avoids having to
make the distinction between g/kg for heat storing appliances and g/hr for
continuous burn stoves. To that end, MHA is conducting testing to see if the
CSA B-415 efficiency method can be adapted to masonry heaters. However at this
point we will support the HPBA position.
Two tech
committee members are currently conducting testing on the Austrian Eco- firebox
air design, which was presented at the MHA annual meeting in 2013. We are
measuring repeatable particulate (PM) numbers substantially below 1 g/kg,
roughly a 50% reduction from existing designs. More information on the testing
can be found here.
The fueling
method proposed is ASTM E2817, which defaults to "manufacturer’s
instructions", the method used in Europe. There are annexes for
alternative crib and cordwood fueling methods. In-house testing at MHA is
showing good repeatability with "manufacturer’s instructions" and
cribs. Crib emissions appear to be roughly 50% higher than "manufacturer’s
instructions" with cordwood.
Perhaps the
biggest challenges presented by the practical aspects of the proposed standards
lie with the fact that EPA doesn’t understand the unique operating
characteristics of the masonry heater industry. For lack of adequate funding in
addressing this tiny portion of the wood burning industry, regulators ended up
copying much of the language from “AAA”, the wood stove portion of the
P.S.
For example,
the P.S. refers to masonry heater Certified Model Lines, and includes a
Licensing Restriction and a Storage Requirement.
The “model line” issue would require every heater built to be tested
for emissions at an EPA certified lab. The “licensing” restriction
prevents MHA from certifying a heater and selling the plans for it. The
storage requirement would require a heater builder to keep a copy of every
different heater built in a sealed container. MHA is protesting all of
these issues as unacceptable, since masonry heaters are typically very heavy,
site built one-of appliances - similar to a masonry fireplace, except with
dramatic performance improvements. Many heater masons have met the substantial
requirements of the MHA Heater Mason Certification Program, and discussions
need to take place with EPA on more feasible regulation compliance mechanisms
for masonry heaters.
On a more
hopeful note, as an alternative to certification testing, RRRR would permit a
“validated computer model simulation program”. A limited version of
this is already used in Europe. It could provide a good way to certify a
“family of units” defined as units with the same firebox dimensions and also
gain acceptance of “substantially similar” heaters. The technical
committee has a project under way to design and verify a calculator to meet
compliance under this clause. This could be a key way to continue to
offer custom designs to clients.
Anyone
building fewer than 15 masonry heaters per year would be granted a 5-year
extension for compliance with the emissions limit. It is a delay of
standards that will be imposed for larger manufacturers when NSPS becomes law,
likely in 2015.
(The views
expressed here do not necessarily reflect the views of the Alliance for Green
Heat. We have asked Norbert Senf and others to assist the Alliance in
developing our comments to the EPA on masonry heaters.)
No comments:
Post a Comment