Friday, November 20, 2020

Alaska releases deficiency details on wood and pellet stove test reports

Bryce Ward, Mayor of Fairbanks
North Star Borough.
Alaska posted summary review sheets of nearly every certified wood and pellet stove, exposing issues in a certification system that has been running for decades with little oversight. Of the 131 wood stove models, 130 had major problems in their testing report based on the Alaska classification system.

ADEC is pursuing EPA approval of s smoke reduction plan similar to one in Montana. They said, “Missoula City-County Montana regulations allows installation permits only for pellet stoves emitting no more than 1.0 gm/hr.  Alaska embarked on the certification test review and the establishment of a 1-hr filter pull standard as an alternative to a pellet only program for the nonattainment area as DEC feels this approach meets the communities desire for more device options and is at least equal to the Missoula requirement."  Click here for the full email.)

Alaska also sought and received approval from the EPA for an IDC cordwood stove test method to be "broadly applicable" which means any manufacturer can choose to use it in a stove's certification test. It also sets the stage for Alaska to potentially require that test for stoves sold in Fairbanks.

Alaska is undertaking this unprecedented review in an effort to find the stoves that they can be assured are the cleanest and meet all the requirements in EPA regulations under the Clean Air Act. AGH first covered this in a October 22 blog. In addition to checking that stoves meet the extremely detailed level of documentation based on emission testing, Alaska has imposed even stricter emission requirements, which do not apply anywhere other than Fairbanks. The primary stricter standard is that stoves cannot emit more than 6 grams an hour of particulates during the first hour of a multi hour test. Ultimately, when averaging the PM of the entire test, stoves must emit no more than 2 grams an hour to meet the Fairbanks standard, even though the federal standard allows up to 2.5 grams of PM if a stove is tested with cordwood.

Part of ADECs summary sheet showing
 the preliminary and initial final
determination and the reasons.
The initiative is being undertaken by the Alaska Department of Environmental Conservation (ADEC). It only impacts which stoves and boilers can be installed in a relatively small area around the city of Fairbanks that currently fails federal air quality limits. That is a very small market for the wood stove industry but the initiative may end up having far reaching implications for the EPA, the stove industry and how stoves are tested in the future.

 

One reason why so many stove models are flagged with multiple deficiencies is simply because ADEC officials missed data in the test reports or the manufacturer of the model has not yet provided it. Of the 130 stoves with major problems, many will likely meet Alaska’s review in the coming months. Manufacturers who have requested an extension from the State have until April 1 to work with Alaska to provide details, and only after that can the model not be sold in the Fairbanks non-attainment area. In the meantime, the review appears to shpow that only one wood stove model – MF Fire’s Nova tested by ClearStak lab – could be on the market. The data sheets on all stove models can be found here and will be updated at least monthly.

A Step 1 Jotul stove being tested by
Dirigo labs, taken over by PFS-Teco.
The data on pellet stoves is far better in some respects. Rarely do pellet stoves emit more than 6 grams during the first hour of a test like many wood stoves do. Of the 97 certified pellet stoves, only 3, or about 3%, are disqualified for this reason, compared to 31% of wood stoves. However, like wood stoves, the vast majority of pellet stove test reports had missing data. Only 7 had minor issues. As with wood stoves, over the ensuing months, scores more will likely be approved after missing information is found or provided by the manufacturer. Eleven of the test reports could not be found by ADEC. Sometimes links to these reports are hard to find, sometimes the link is broken, and sometimes the report doesn’t appear to be posted.

ADEC has not yet determined which missing items on test lab reports disqualify a stove. Some of the issues ADEC is flagging have to do more with paperwork requirements than the potential cleanliness of the stove. They are engaging in a series of meetings with EPA personnel from both enforcement (OECA) and air quality (OAQPS) offices to determine what is actually required by the NSPS, what isn’t required, and what should be considered significant. One long time technician at an EPA approved lab said that “based upon ADEC’s interpretation of the language in parts of the Federal Register, they have come up with several new requirements” which never existed before.

A 2019 pie chart made by AGH
showing an approximate percent
of stoves tested by each lab based 
on one data set.

For manufacturers, a key distinction is also data that was collected and exists, but was never calculated or reported properly, compared to data that was mistakenly not collected and could only be obtained by retesting the unit. It’s unclear if any of the test reports are so deficient that the EPA would ever considering revoking a certificate.

The scrutiny of certification paperwork by labs by Alaska also comes on the heels of years of effort by the stove industry to prevent stricter emission standards and the possibility of stricter audits. States have become increasingly frustrated that the EPA is not enforcing their regulations governing wood stoves and boilers. While enforcement was explicitly curtailed under the Trump administration, under Obama and previous administrations, enforcement has been regarded as lax or sporadic. In particular, the EPA has never initiated an audit of a wood stove or boiler to determine if it can achieve the emission levels that it got on its initial certification test. There is also no documentation of the EPA denying certification of a stove or boiler based on inadequate lab reports. In addition, there are only a handful of documented cases when a stove or boiler has failed emission tests in a lab even though industry cites very high rates of variability in emissions during testing.

Some of these issues emerged in 2019 when the EPA released hundreds of documents that NESCAUM had requested in a Freedom of Information Act request. But very little has ever been written about the many complex and opaque issues in test labs other than a blog AGH posted in August 2019: Records reveal successes and challenges in laboratory wood heater testing. That article explored issues of conflicts of interest, compliance with testing regulations and suspension of certification tests, all of which are receiving are receiving more scrutiny by ADEC officials and their partner agencies.

 

An ASTM 3053 test at Omni lab in
May 2020 on a GHP Group stove. GHP
is a company that has not 
requested that ADEC review its stoves.

ADEC’s initiative is also intertwined with concerns about the ASTM E3053 cordwood method and lab tests that showed the method was lax and may have helped some stoves to achieve certification to the EPA’s stricter 2020 standards with few or no modifications to their design. A meeting between EPA and state officials and industry representatives in January of 2020 explored these concerns and ADEC presented their strategy at that time.

ADECs efforts to improve air quality in the Fairbanks non-attainment area go back at least 10 years, starting with traditional stove and boiler change-out programs and a variety of restrictions. But the tenacity of excessive wood smoke in America’s coldest city has frustrated residents and officials alike, leading to this latest effort to understand which stoves are actually cleaner than others. Fairbanks is also spearheading solutions for the other most obvious culprit: unseasoned wood. As of October 1, 2021, only seasoned firewood can be sold in the non-attainment area.

Registration for firewood retailers is
compulsory in Fairbanks and voluntary
in the rest of the state.

It is still too early to tell how much this latest initiative will lead to cleaner air in Fairbanks. There is little doubt that it will bring a new level of scrutiny and integrity to test reports submitted to the EPA, and help the EPA and state agencies better understand how to craft a federal reference method for testing stoves with cordwood.

Postscript: In March 2021, NESCAUM released a report that was largely based off of the reviews of certification reports done jointly by ADEC and NESCAUM.  The scathing report concluded that the EPA process of certifying stoves is "dysfunctional" and recommended a series of aggressive measures.  AGH's initial response that report can be found here.

Monday, November 16, 2020

Alliance for Green Heat calls on President-elect Biden to support and help transform wood and pellet heating

Press release
Contact: John Ackerly
202-365-4765

Nov. 16, 2020 - The Alliance for Green Heat congratulates President-elect Joe Biden and Kamala Harris on their 2020 presidential victory and welcome their commitment to scale up renewable energy and energy efficiency.

This change of administration offers the United States a historic opportunity to reduce fossil fuels through a range of renewable heating solutions and energy efficiency measures. We have already begun to decarbonize our electric grid, and now it’s time to also focus on our heating sector which can reduce heating costs for families across the country, buoy economic recovery and create good-paying jobs.

The Alliance for Green Heat’s supports all renewable heating options as well as strategic pairing of heat pumps, geothermal, solar thermal and solar PV with wood and pellet heat technologies (our specialty). The role of decentralized renewable thermal technologies, including wood, solar thermal and geothermal is essential along with the electrification of heat as our electric grids slowly become more renewable. The electrification of transportation is creating massive demands for new generation and distribution. This combined with very high peak demands in the cold, short daylength northern tier of the country calls for strategic deployment and use of non-electric heating technologies. Rural areas need special attention given the cost of new infrastructure.

Executive Branch


The Biden Administration, through executive action, can immediately begin to drive markets toward beneficial forms of advanced wood heating. It is essential that Biden’s administration analyzes small-scale wood heating as having unequivocal carbon benefits. This includes:
  • Ensuring there is an in-depth, science-based analysis to account for carbon content of wood used for residential and small-scale institutional heating that is separate and distinct from the analysis used for larger scale biomass to electric pathways.
  • Use the power of procurement, as outlined by the Climate 21 initiative, to “bolster markets for climate friendly products such as … heating systems that use wood pellets” in federal buildings, starting with more rural buildings in colder climates.
  • Directing the GSA to require rural federal buildings to consider heating with wood, chips or pellets where it is economically feasible.
  • Prioritize an interagency working group on bioenergy to focus on small scale thermal wood.
  • Include environmental justice considerations in bioenergy projects and expanding employment opportunities for Native Americans and low-income populations in rural areas.

Agencies

EPA: 

We urge the EPA, under new leadership to give more priority to one of the most popular and commonplace renewable energy solutions in the country. To this end, we encourage the EPA to

  • Invest in the expeditious development and adoption of test protocols that resemble how homeowners use wood heaters (we use the term “wood heater” to include wood and pellet stoves, boilers and furnaces).
  • Prepare the groundwork for a national wood stove exchange program to replace old wood heaters with cleaner alternatives.
  • Put resources into the offices that certify wood heaters so that the process is expedited and includes a full review of all testing requirements
  • Ensure the EPA’s Science Advisory Board (SAB) evaluates the carbon benefits of residential and small-scale institutional wood and pellet heating based on studies of how that wood is gathered and obtained by households and small institutions.
DOE:
  • Issue a Statement on Scientific Integrity that reaffirms DOE’s commitment to renewable energy pathways that can be deployed in the short term, including wood heating.
  • Expand the focus of the Bioenergy Technologies Office beyond liquid fuels to include biothermal and provide additional grants for automated, next generation wood heating technology.
  • Develop strategies that utilize wood heating as an integrated approach to mitigate grid-load growth risks caused by rapid electrification in the country’s northern tier.
USDA:
  • Prioritize the utilization of wood thinnings removed from high-hazard forests to be used for local heating of homes and institutions in those areas.
  • Ensure Rural Development Housing programs allow for and encourage the installation of modern, automated wood heating.
  • Increase funding to the Community Wood Energy program.
Congress:

We urge the Biden administration to work together with a closely divided Congress to:
  • Incorporate the BTU Act into any renewable energy or tax legislation to ensure that the most carbon beneficial pathway for low-grade, bi products of sustainably harvested wood is included.
  • Expand tax credits for energy efficient appliances including the cleanest and most efficient wood and pellet heaters,
  • Expand funding for the DOE to continue the R&D program to modernize residential wood and pellet heating technology
  • Establish a national program to retire older wood heaters in exchange for heat pumps, pellet heaters, and in some cases, new wood heaters.
  • Ensure that weatherizing programs inspect wood and pellet stoves just as they do with gas and oil furnaces for both safety and efficiency and provide avenues for repair or replacement, if needed.

The Alliance for Green Heat promotes wood and pellet heat as a low-carbon, sustainable and affordable residential energy solution. The Alliance works to advance cleaner and more efficient wood heating appliances, particularly for low and middle-income families.  The Alliance runs the semi-annual Wood Stove Design Challenge to encourage innovation and automation in wood stoves. Founded in 2009, the Alliance is a 510c3 non-profit organization based in Maryland.  

Friday, November 6, 2020

Safety recalls of wood and pellet stoves

Updated: July 2022 - There have been at least seven recalls of wood and pellet burning products since 1979 and one certification revocation.  Four of those were in 2015-2016.  While there are few reports of any injuries, recalls are expensive and time consuming for stove manufacturers.

(In addition to stove recalls, the Consumer Product Safety Commission recalled a camping tent sold by Cabellas in July 2022 because the "stove jack ring" where the stove pipe exits the tent, can deteriorate.)

Almost all recalls are voluntary, which is usually to the benefit of the company.  A successful recall effort often reaches about 65% of consumers, and it the case of wood or pellet stoves, it may depend on who sold them and how much effort the company actually made.  Its easier for some stove manufacturers to track down who purchased a particular stove if it was purchased through a specialty retailer compared to stoves purchased through hardware chains.  For the following seven recalls of wood and pellet stoves, there is no data about how effective each recall was.

The dangers posed by some of the stoves subjected to recalls are significant but may pale in comparison to the ongoing dangers of self-installed stoves that never get inspected.  The Consumer Product Safety Commission (CPSC)'s 1982 survey of more than 2,000 households indicates that 70% of stoves in use were installed by the consumer, and half of these "do-it-yourself" installations were never inspected by a building or fire inspector.  A very high percentage of self-installed stoves remains a high probability in the US, in part because of the increasingly high volumes of stoves sold through hardware chains and on-line.  The percentage of self-installed stoves purchased on the second-hand market could be even greater than the 70% figure found in 1982.  In addition to dangerous self-installation practices, the other main cause of stove-related house fires is excessive creosote build-up in chimneys that are not regularly cleaned.

 

The highest volume recalls have been pellet stoves, which pose less of a fire risk when self-installed, or from lack of chimney cleaning.

 


1. The recall impacting the most devices was the 2015 recall of the US Stove HomComfort pellet stove that could be mounted in a window or wall.  This recall involved 4,400 units, which provides one of the few insights into volumes of particular units.  The Chinese-made stove was sold at Northern Tool, Rural King, Home Depot and Lowes from 2010 to 2012.  There were 16 reports of fires and property damage, but the recall did not happen until three years after the product run.  US Stove offered $868 cash or $1,200 credit towards the purchase of another US Stove product. Those amounts are still available from US Stove.  An updated version of the stove is 2020 certified but only supposed to be mounted in walls, not windows.

 

2. The next largest recall was England Stove Works pellet Smartstove.  The US-made unit was only sold for a few months in the fall of 2015. After the company received four reports of incidents and one minor injury, it initiated recall the following year.  Englander sent consumers a free repair kit to remedy the issue.  An updated version of the stove is 2020 compliant and on the market.

 

3.The next largest recall was for 2,000 Mt. Vernon pellet stoves made in the US by Quadrafire, a subsidiary of Hearth & Home Technologies.  The $4,000 stove was sold for almost a year between 2014 and 2015.  There were eight reports of glass breaking after excessive pressure built up in the firebox but no reports of injuries.  The company remedied the issue by offering to arrange for free installation of an enhanced control board. The firm's dealers contacted known purchasers.  An updated version of the Mt. Vernon is also 2020 compliant and on the market.

 

 

4. The following year saw a much smaller recall of a Quadrafire device. This time it was a wood stove, the Explorer III, and involved 650 units.  The US-made unit was sold for about a year and a half for $3,000.  The danger was that the handle of the top lid could disengage and the lid could fall.  There were five reports of incidents, two of which involved minor injuries to fingers. The company offered to fix the problem through its dealer network. The Explorer is off the market.

 

 

 

5. A small recall of 200 Scan Andersen wood stoves made by Jotul occurred back in 2010.  A faulty door hinge led to the door falling off, and of the three reported incidents, one consumer received a bruised foot.  The stove was made in Norway and the fix was a free hinge repair.


6. Going back a bit further in time, there was a recall of 1,300 EPA certified, catalytic Vermont Castings Sequoia wood fireplaces in 2006.  At the time, Vermont Castings was owned by the CFM corporation and the units were made in Canada and the US.  They sold from 2003 to 2006 for about $2,200.  This was a more serious recall, as it involved insufficient insulation or a missing weld, and could cause these fireplaces to pose a fire hazard, though no incidents were reported.  Consumers were advised to stop using the product immediately, and it is not clear if the company offered any remedy after 2008 when they went bankrupt. 


 

 

7. The final recall listed on the CSPC database dates back to 1979, and involved glass for stove doors that posed a breaking hazard. The glass doors were in “Hearth-Glo” wood burning circulators made by the Jackes Evans Manufacturing Company. These sold in 1977 and 1978, right before the EPA began requiring wood stoves to be certified. One thousand stoves were involved and customers could get free replacement doors.


8.  While not yet a formal recall, the EPA is taking an unprecedented step of revoking the certification of a wood stove because the lab did not do the test correctly and the EPA certified the stove because it did not carefully read the lab test report.  The stove in question is the England Stove Works Model 50-T tested by Intertek, and the wood they used was too dry. It appears that Englander tried to test it again but couldn't get it under 2 grams an hour. Englander had requested a hearing, but they pulled out of the hearing process and the EPA is finalizing revocation of the model line in April 2022, which apparently will mean those models will have to be recalled from retailers.