# E C 

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R Incorporated Providing Environmental Technical Support Since 1989

MEMORANDUM TO: Docket EPA

- HQ

- OAR

- 2009

- 0734 FROM: Jill Mozier, EC/R Inc.
DATE: F ebruary 20 , 2014 SUBJECT: Notes from NSPS Wood Heater Webinar requested and hosted by the Biomass Thermal Energy Council on January 29, 2014, with Gil Wood as presenter

The Biomass Thermal Energy Council (BTEC) hosted a webinar for its members entitled “NSPS Review with EPA’s Gil Wood” led by Joseph Seymour, the executive director of BTEC. Gil began the slide presentation (attached) by emphasizing that it was “ a good faith effort to represent the proposal as signed on January 3, 2014 ” and that “a ny differences are unintentional and do not supersede the official proposal. ” Gil also asked that comments be e

- mailed to the official docket at: a - and

- r - docket@epa.gov , Attention Docket ID No. EPA

- HQ

- OAR

- 2009

- 0734

. After the slide presentation, during the Q & A portion of the webinar, Gil answered the following questions as follows. (Note: these Q & A’s are paraphrased.)

• Question : At w hat point during the one

- year draft working comment period will Hydronic Heater (HH) manufacturers know what test methods are available to them (i.e., allowed for certification testing) ? Answer : Unfortunately, I can’t give a definitive date now because we’re still in the comment period of the proposal . I hope we could tell manufacturers within a reasonable time period , but the rule is not final until the administrator signs it and prior to that there is the potential for change . We will certainly put out the information as early as possible, but that is one of the historical problems with the NSPS

– there is uncertainty between proposal and final rule.

• Question : What is cut

- off date for what qualifies as a new appliance? Answer : The effective date of fi nal rule , which is 60 days after final rule is published

.

• Question : What is the rationale for eliminating the consumer hangtag? How will a consumer know [the information that’s currently reported on those hangtags]? Answer : A ll information will be availa ble on EPA’s website instead of on the hangtags , including test values, heat outputs, efficiencies, CO . The website will be in a user 501 Eastowne Dr., Suite 250  Chapel Hill, North Carolina 27514 Telephone: (919) 484

- 0222  Fax: (919) 484

- 0122friendly format so consumer s can readily search for i nformation and pick and choose items to research. Follow

- up Question : So is the rationale th at the hangtag doesn’t have enough room , or that the web interface will be easier for consumers? Answer : Both

– the hangtag s are not large enough to contain all of the information of interest to consumers, plus the website will be more user - friendly and w ill contain more information than the hangtag can. Also, the retailer can choose to have this EPA website up and available to prospective customers in their showrooms.

• Question : P lease discuss the requirement in the proposed NSPS that the Pellet Fuel Institute (PFI) needs to certify the pellets as fuel. Answer : EPA has had many conversations over the years with the Hearth, Patio and Barbecue Association (HPBA) and with PFI regarding this issue. O ne alternative idea was the possibility for an EPA pellet certification program , but due to EPA budget cons ideration s and the fact that an industry alternative existed in PFI, EPA decided the industry solution was the best and most feasible. A fter discussions with PFI, EPA determined that PFI’s suggested criteri a were good, that PFI’s certification/licensing efforts would help ensure pellet quality, and that PFI’s efforts with the American Lumber Standard Committee w ere also helpful and critical. EPA concluded that PFI’s suggestions were a cost effective method o f ensuring pellet quality. However, in the proposal we are asking for comments regarding other programs out there that might be as good as PFI (EPA is not aware of any to

- date)

. In general, the requirement to use certified or licensed pellets goes back to conversations with heater manufacturers that the pellet quality make s a significant difference in the operating and emissions performance of the heater. Consequently EPA determined that certifying/licensing the quality of the pellet is a win

win situation for the environment, the manufacturers and the consumers. Thus EPA has proposed to include the requirement in the heater’s warranty that consumers use certified/licensed pellets, and that us ing non - certified /non

- licensed pellets would void the warranty

.

• Question : How many [current] models of wood pellet boilers are able to achieve Step 2 in 5 years? Answer : I don’ t have the precise number off the top of my head . In the voluntary program , which includes both cordwood and pellet models , there are about 40 models that meet Step 1 , and there might be about 10 that meet Step 2 , but I will need to confirm that number with a follow

- up e - mail . Counting models participating in the voluntary program plus models not participating, including models sold outside t he US (e.g., in Europe), we believe there are over 50 models that can meet Step 2 . T here are admittedly

2some test method issues

– differences between European and US test methods [making a simple tally difficult]. I will send a follow

- up e - mail with more precise numbers

. Note : Follow

- up e - mail is attached to this memorandum.

• Question : What is current plan for the HH voluntary program? Will you consider adding another voluntary program for multi

- fuel s ? Answer : Greg Green (EPA) can better answer that question, but my guess is that such a decision would be based on need, value , and available resources. The current voluntary program does encourage qualification for heaters that burn other biomass ; it is not limited to wood, but to

- date no units have requested qualification for biomass other than wood as f uel.

• Question : How w ere the 4,800 tons [per year in reduced fine particle pollution over the 2015 to 2022 timeframe] calculated? What was that number reduced from? And how did you come up with health benefits? Answer : The answer is too complicated to fu lly explain now , in the allotted time, but the Regulatory Impact Analysis ( RIA ) report

– available with the proposal

– details how we did the impact analysis including estimating emissions, baseline levels, S tep 1 levels, Step 2 levels, plus the cost infor mation to achieve those different levels. The sh ort answer is that we estimated pre

- NSPS emissions and then Step 1 and Step 2 emissions to determine emission reductions at each step. We also estimated the number of units at each of these steps and used projection of sales into the future

– all of which is detailed fully in the RIA

.

• Question : Please e xplain the testing protocol for single burn rate stoves

. Could this be an easier limit to meet than the weighted average of 4 burn rates? Answer : T he testing of single burn rate stoves should and would be at the rate that the se stoves normally operate . We are trying to test at real

- world situations . Manufacturers must be able to prove to EPA that not only does their single burn rate stove not operate at other burn rates in the lab setting, but also that it can’t be altered to operate at other burn rates in the field/home setting

– and the latter may be especially challenging . So we are asking for comments on how to best avoid someone circumventing the rule by for example putting a damper in the stack to adjust the burn rate (e.g., to make the stove burn slower overnight). We would like help with solving this problem. If this situation [of turning a single burn rate stove into an adjustable burn rate st ove] can be avoided, then the heater can be tested at just that [single] burn rate . But the fact is that consumers have put in dampers on many of these, so perhaps the best answer is to test these stoves with a damper set at the lowest burn rate . Again, we are seeking comment and help with this problem. 3• Question : What is likelihood that woodstoves meeting Step 2 wouldn’t be reliant on electricity (i.e., would be off

- the

- grid)? Answer : There is a ver y high probab ility that Step 2 certified stoves need not be reliant on electricity, since there are some very clean non

- cat alytic stoves being sold currently that already meet the Step 2 limit

.

• Question : What is your preferred mode of communication with industry during the comment period (between proposal and f inal rule)? Answer : My preference is for industry to comment to the docket officially, although copying me on those submissions is fine and appreciated, so I see the comment as soon as possible (although we’ll be checking the docket daily for comments). To reach me directly, e

- mailing is better than calling.

• Question : Would EPA allow an automated stove to be tested as a single burn rate stove (“a utomated ” meaning a stove that the consumer can’t change/ control the air intake )? Answer : I would have to re search what is meant by this more , but my first impression is no

– if a stove can be run at different burn rates then it should be tested accordingly. However, I am open to learning more about this and any of these topics

.

4From: Wood, Gil To: Joseph.Seymour@biomassthermal.org Subject: Follow-up to NSPS Presentation for 1/29/14 BTEC Webinar Date: Thursday, February 20, 2014 3:53:40 PM Hi Joe, During the webinar, I promised to give you more specific numbers on pellet boilers versus what I recalled off the top of my head. Below are the question and answer from 1/29/14 and then today’s additional information. Best regards, Gil

Question : How many [current] models of wood pellet boilers are able to achieve Step 2 in 5 years? Answer : I don’t have the precise number off the top of my head. In the voluntary program, which includes both cordwood and pellet models, there are about 40 models that meet Step 1, and there might be about 10 that meet Step 2, but I will need to confirm that number with a follow-up e-mail. Counting models participating in the voluntary program plus models not participating, including models sold outside the US (e.g., in Europe), we believe there are over 50 models that can meet Step 2. There are admittedly some test method issues

– differences between European and US test methods [making a simple tally difficult]. I will send a followup e-mail with more precise numbers.

Additional information provided on 2/20/14: There are 2 pellet HH built by U.S. manufacturers that have been qualified under the voluntary program at approximately the NSPS Step 2 level or better [1]

. We believe there are additional pellet HH models built by U.S. manufacturers that have not yet gone to the effort to become partners in the voluntary program and have their HH models tested by ISO-accredited laboratories, but rather are waiting to see what the NSPS final requirements will be. There are also over 50 European manufacturers with multiple models per test method EN 303-05. [2]

1 See list of cleaner hydronic heaters participating in EPA’s voluntary program at http://www.epa.gov/burnwise/owhhlist.html

. 2 European Wood-Heating Technology Survey: An Overview of Combustion Principles and the Energy and Emissions Performance Characteristics of Commercially Available Systems in Austria, Germany, Denmark, Norway, and Sweden; Final Report; Prepared for the New York State Energy Research and Development Authority; NYSERDA Report 10–01; April 2010.

# Residential Wood Heaters New Source Performance Standards (NSPS) Proposal Biomass Thermal Energy Council January 29, 2014

This presentation is a good faith effort to represent the proposal as signed on January 3, 2014. Any differences are unintentional and do not supersede the official proposal. Please email comments on the proposal to the official docket at: a - and

- r - docket@epa.gov , Attention Docket ID No. EPA

- HQ

- OAR

- 2009

- 0734

# Current Schedule

► 

## Proposal was signed by EPA Administrator on January 3, 2014 ► 

## The full proposal and fact sheets are available on

- line at http://www2.epa.gov/residential

- wood

- heaters ► 

## The proposal will be published in Federal Register ~January 31. ► 

## There will be a 90

- day public comment period
► 

## Opportunity to submit comments and data for EPA to consider
► 

## Information on how to comment is on the website ► 

## A public hearing will be held in Boston on February 26, 2014.
► 

## Information on how to register is on the website. ► 

## We intend to consider all comments and issue the final rule in 2015. ► 

## States and environmental groups have sued to put us on a schedule

• Negotiations are ongoing. Likely will be ~1yr from proposal to final.

2

# Scope of the Rules
We are proposing three subparts as follows:

► 

## Subpart AAA (for “room heaters”) revision

– Adjustable burn rate stoves

– Single

- burn rate stoves

– Pellet stoves

► 

## Subpart QQQQ (“central heaters”) new rule

– Outdoor and indoor hydronic heaters

– Forced

- air furnaces

► 

## Subpart RRRR new rule

– Masonry Heaters

3

# Summary of Proposal

► 

## The 1988 NSPS requires manufacturers to design new residential wood heaters to meet particulate emission (PM) limits, have representative heaters (per model line) tested by an EPA

- accredited lab, and attach EPA label after EPA approval. ► 

## The proposal will update the 1988 NSPS to reflect today’s best systems of emission reduction, considering costs. These systems are ~80% cleaner and more efficient. ► 

## The rule will affect models manufactured and sold after the rule is final. ► 

## The rule will also establish new emission limits for types of heaters that have become popular after the 1988 NSPS was issued ► 

## Step 1 emission limits will be required when the rule is final and tighter Step 2 limits will be required 5 years after the rule is final. ► 

## Test methods will be revised to improve precision and better reflect the real world, e.g., use cord wood and consider peak, shorter

- term emissions. ► 

## The rule will also require testing and reporting efficiency and carbon monoxide. ► 

## The projected monetized health benefits will be far greater than the costs (>100:1).

4

# Not Covered

► 

## Existing heaters currently in use in people’s homes 1 

## ► 

## Outdoor fireplaces, pizza ovens, barbecues, fire pits, chimineas , traditional Native American bake ovens, ceremonial fires ► 

## Heaters fueled solely by oil, gas or coal (or other non

- wood materials) ► 

## Proposal by itself would not ban certified devices or restrict hours of use. ► 

## New indoor fireplaces ► 

## Not effective heaters (this NSPS is for "residential wood heaters ”) ► 

## However, EPA is taking comment ► 

## Fireplaces are included in an EPA voluntary program that encourages manufacturers to make cleaner

- burning fireplaces and retrofits available for consumers.

1 

## We refer to “Strategies for Reducing Residential Wood Smoke” on EPA’s Burn Wise website and note that it includes ideas for local regulations, voluntary programs, funding mechanisms and best burn practices

- all of which can help reduce particle pollution from existing wood

- burning appliances.

5

# Outreach

► 

## We conducted extensive outreach as we developed the proposal, seeking input from numerous wood heater manufacturers, state, local and tribal governments, regional air quality agencies, and citizen and environmental groups.

► 

## We also participated in a Small Business Advocacy Review Panel to seek input and advice. The preamble discusses the changes made to the proposal in response to the panel’s recommendations to reduce small business impacts as much possible while still meeting the legal requirements in the Clean Air Act.

► 

## We will continue to work to address environmental and small business potential impacts throughout the process to get to the final rule.

6

# Room Heaters (Subpart AAA Proposed Revisions)

► 

## Adjustable burn

- rate wood stoves (focus of 1988 NSPS) ► 

## Proposal would strengthen existing emission limits in two steps over a five

- year period



## • Step 1

– similar to Washington State’s 1995 limit for non

- catalytic stoves (most adjustable rate EPA

- certified stoves already meet today)

– EPA

- certified stoves can continue manufacturing/sales until current certification expires, up to a maximum of five years



## • Step 2

– meet strengthened limits (see table)

► 

## Single burn

- rate wood stoves (NOT covered by 1988 NSPS) ► 

## Would have to meet the same emission limits as adjustable burn

- rate stoves

► 

## Pellet stoves ► 

## Would be explicitly included



## • Pellet stoves are inadvertently exempted from 1988 NSPS if their air

- to
- fuel ratio is >35:1. Exemption was intended only for typical open fireplaces with high excess combustion air. ► 

## Would have to meet same emission limits as adjustable burn rate heaters

7

# Room Heaters

-- Proposed Emission Limits

Manufacturers must use 3rd

- party, independent, ISO

- accredited and EPA

- approved test laboratories and certifying entities to demonstrate compliance with a representative appliance for a model line. 

## Subpart AAA Appliances Phases / Steps PM Emission Limits Heaters with current EPA certification issued prior to the effective date of the Final Rule Transition period from 1988 rule through the later of the effective date of the final revised rule or expiration of current certification (maximum of 5 years certification and no renewal) 4.1 g/hr for catalytic heaters/stoves and 7.5 g/hr for noncatalytic heaters/stoves (1988 NSPS limits)

All other heaters (includes currently certified heaters after the certification expires) Step 1: upon the effective date of final rule (60 days after publication)

Step 2: 5 years after the effective date of the final rule 4.5 g/hr (weighted average)

1.3 g/hr for each burn rate

8

# Central Heaters (Subpart QQQQ Proposal )

► 

## Would affect hydronic heaters and forced

- air furnaces

► 

## Not subject to 1988 NSPS

► 

## Hydronic heaters are also known as indoor and outdoor wood boilers

9

# Hydronic Heaters (in Subpart QQQQ)

► 

## In January 2007, EPA instituted a voluntary program and NESCAUM developed a model rule that several states subsequently used as a starting point for state regulations.

► 

## Some manufacturers redesigned their models to be Phase 2 white tag “qualified” models >80% cleaner (in lab tests) than unqualified ones

► 

## > 40 current qualified Phase 2 models ► 

## > 30 manufacturers are signatory partners in the voluntary program

► 

## 2

- Step phase

- in ► 

## Step 1: test and certify to meet level similar to current Phase 2 white tag qualifying level for EPA voluntary “Hydronic Heater Program” ► 

## Step 2: meet strengthened limits (see table) 5 years after effectiv 

## e date

► 

## Testing and certification process similar to revised subpart AAA

10

# Hydronic Heater

– Proposed Emission Limits

EPA also is seeking comment on a 3

- Step approach over an 8

- year period. This approach would include an interim limit of 0.15 pounds per million Btu heat output 3 years after the rule is published in the Federal Register.



## Step PM Emission Limit Compliance Date Step 1 0.32 pounds per million BTU heat output (weighted average) and a cap of 7.5 g/hr for any individual test run 60 days after publication of final rule

Step 2 0.06 pounds per million BTU heat output for each burn rate 5 years after publication of final rule

11

# Forced

- Air Furnaces (in Subpart QQQQ)

► 

## Step 1 is higher than HH because most FAF have not progressed as quickly, but all should catch up to HH by Step 2

EPA also is seeking comment on phasing in the limits in 3 steps over an 8

- year period. This approach would include an interim emissions limit of 0.15 pounds per million Btu heat output 3 years after the rule is published in the Federal Register (the same interim limit as for hydronic heaters). 

## Step PM Emission Limit Compliance Date Step 1 0.93 pounds per million BTU heat output (weighted average) and a cap of 7.5 g/hr for any individual test run 60 days after publication of final rule

Step 2 0.06 pounds per million BTU heat output for each run 5 years after publication of final rule

12

# Masonry Heaters (in Subpart RRRR)

► 

## Currently not regulated ► 

## Would require certification process similar to revised Subpart AAA ► 

## Limit based on test data for typical masonry heaters that perform well. ► 

## Asking for comments on alternatives to testing. Most heaters are custom built on - site, so testing each custom model could be difficult. ► 

## Compliance deadlines based on production level ► 

## Most companies make less than 15 heaters per year



## Annual Production Level PM Emission Limit Compliance Deadline 15 heaters or more 0.32 pounds per million BTU heat output 60 days after final rule is published
Fewer than 15 heaters 0.32 pounds per million BTU heat output 5 years after final rule is published

13

# Test Methods

► 

## Peak, shorter - term particulate emissions ► 

## We add multiple 1

- hour filters for each test run to gather data regarding start
- up and anticipated peaks. ► 

## For Step 2, we require compliance with emission limits at the lowest burn rate (“Category 1”) and the maximum burn rate (“Category 4”) rather than the weighted average of the four burn rates in the current NSPS.

► 

## Cordwood test method ► 

## We add testing with cordwood to encourage best real

- world performance. For Step 1, the manufacturer would submit 2 test reports, 1 with cribs (dimensional lumber) and 1 with cordwood and choose which results to use for certification. Step 2 tests would all be with cordwood. ► 

## We will continue to work with states, labs and industry on the details.

► 

## Precision ► 

## We propose improvements to the test methods to improve precision.

14

# Efficiency and Carbon Monoxide

► 

# Efficiency ► 

## We require testing and reporting but not a minimum efficiency



# ► 

# Carbon Monoxide ► 

## We require testing and reporting of CO but not an emission limit



# ► 

# Information would guide consumers’ decisions ► 

# Model line performance testing by 3 rd



# - party

• ISO

- accredited labs and certifying bodies ► 

# Reviewed/approved by EPA ► 

# Model lines also subject to audit testing

• Sealed/stored units used for original performance test



# • Original drawings compared to actual unit

15

# Projected Impacts

► 

## We expect the rule would reduce fine particle pollution from new heaters by ~4,800 tons per year over the 2015

- 2022 timeframe; many reductions would be in areas with significant particle pollution problems.

► 

## We expect monetized health benefits would be >$4 billion per year.

► 

## We expect costs would be ~$16 million per year.

16

# Comments

► 

# We encourage email comments to the official docket at: ► 

# a - and

- r - docket@epa.gov , ► 

# Attention Docket ID No. EPA

- HQ

- OAR

- 2009

- 0734

► 

# Gil Wood ► 

# wood.gil@epa.gov ► 

# 919

- 541

- 5272

17