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# Revision of Subpart AAA Residential Wood Heaters & Additional New Source Performance Standards (NSPS) Panel Outreach Meeting with Small Entity Representatives (SERs)

August 25, 20102 

# Reminder of Proposals under Consideration  Tighten emission limits to reflect today’s Best Demonstrated Technology (BDT)  Close “loopholes,” eliminate exemptions  Add pellet stoves explicitly  Add wood “boilers” (hydronic heaters) and furnaces  Revise test methods as appropriate  Streamline certification process & incorporate International Standards Organization (ISO) process plus compliance affirmation  Regulate fireplaces  Regulate devices fueled by other solid biomass, e.g., corn, various pelletized biomass  Regulate coal -fired heaters (in order to level the playing field)3 

# Costs and Economic Impacts Are Being Developed and Analyzed  Handout of cost impact analysis approach  Handout of industry profile  Handout of draft costs for pellet stoves  Handout of draft costs for wood stoves  Handout of preliminary cost information on hydronic heaters  Handout of preliminary cost information on fireplaces  Handout of questions to ask SERs  How a wood stove looks seems to be a more important factor in sales price than the stove’s emissions  There are large differences in base costs within most appliance categories, regardless of emission considerations

# Compliance Deadlines  

### Many SERs have requested more time for development of new model lines  

### 1988 NSPS allowed  

### 4 months for Phase I (equivalent to the most stringent State standard) and  

### 2 years for the Phase II requirements  

### SERs are concerned that their current low cash flow requires them to stretch their R&D over a longer time, such as 7 years  

### EPA will address this as we evaluate economic impacts.5 

# Emission Data Are Being Compiled and Analyzed  Handout of EPA summaries of emission data  See list of questions for SERs  HPBA noted that low burn rate measurements of pre- 1988 were somewhat lower than measurements by the current test method  HPBA noted that the equation for conversions between 5G & 5H is erroneous. HPBA, manufacturers, and labs have agreed to conduct additional tests.  Catalytic Hearth Coalition is conducting a review of catalytic performance versus time.  MHA has prepared a summary of masonry heater performance  EPA is working on comparisons of European and EPA test methods  HPBA and BIA have provided additional information on fireplace potential emission reductions. SBA intends to obtain additional information.6 

# Test Method Revisions Are Being Developed  EPA & HPBA are participating on numerous ASTM work groups  HPBA participated on revision of Canadian method B415.1  NYSERDA (New York State Energy Research and Development Authority) and EPA and others are reviewing European test methods  Continuing concern of “real world variability” vs. lab tests, cribs, manufacturer preferences, etc.  Continuing discussions on emissions averaging (burn rate weightings), low burn rate, number of runs, time for hot start, caps, degradation, etc.  Efficiency test methods (ASTM, CSA B415.1, etc.)7 

# Proceeding on More Inclusive Scope

 **Pellet stoves**   Emission data show excellent performance potential with premium pellets  Need to determine how to judge performance with different pellet quality  **Masonry**

**heaters**  Considering development of 2-prong NSPS (emission limit and design option)  Meeting with industry representatives on 8/18  **Cook stoves**  Received improved definition of “**traditional North A** **merican cook**  **stov es** ”; expect to exempt these <1000 units  Still waiting on definitions of “**traditional Nativ** **e Am** **erican bake**  **ov ens** ” and “**ceremonial fires** ” so that they may be excluded  **Hy dronic heaters**   Typical European levels appear much lower; need to compare test methods  Some new designs avoid operation at typically dirty low burn rates  Considering different test method for heat storage which greatly reduces emissions  **Furnaces** – asked for data, little received yet  **Fireplaces**  Considering development of 2-prong NSPS (emission limit and design option); meeting with masons on 8/18  Numerous air agencies want regulations but SERs have recommended that EPA allow the voluntary program to “mature” first  **Coal** – asked for data, may use transfer of technology, SERs question priority8 

# Compliance & Enforcement Aspects **We still intend to**  :  Streamline certification process --- develop electronic system for submittals and approvals  Make consumer-friendly --- Burn Wise website, spreadsheets of certifications ranked by emissions, tested efficiency, output  Streamline recordkeeping and reporting of manufacturing tolerances and quality control  Require compliance tests on “worst” grade of each type of pellet that manufacturer specifies/warrants for use  Require Federal rules on pellet quality if adequate industry standards are not in place in time (see next slide)9 

# Pellet Fuel Certification  

## PFI standards committee developed a draft certification program that includes adequate fuel characteristics and 3 rd -

## party audits  

## PFI Board gave unanimous support July18  

## On schedule for October 2010  

## EPA is hopeful that there will be no need for an EPA certification program for pellet fuels10 

# Wood Stove Example Options  

### 1988 NSPS:

 7.5 g/hr for non-catalytic  4.1 g/hr for catalytic 

###  

### 1998 Washington State limits

 4.5 g/hr for non-catalytic  2.5 g/hr for catalytic  On sales-weighted basis, over 85% meet today  Require at promulgation? 

###  

### New NSPS limits for 2014?

 3.0 g/hr for either? (~half of “WA stoves” meet today)  2.5 g/hr? (~1/4 of “WA stoves” meet today)  2.0 g/hr? (>12% of “WA stoves” meet today)11 

# Pellet Stove Example Options
 1988 NSPS:  7.5 g/hr for non-catalytic  4.1 g/hr for catalytic  However, most pellet stoves are exempt via the 35:1 air-to-fuel ratio exemption  1998 Washington State limits:  4.5 g/hr for non-catalytic  2.5 g/hr for catalytic  Oregon tax credit level: 2.5 g/hr  Require at promulgation?  Match Wood Stove NSPS 2014 (?) level: ~2.0 g/hr?  over 2/3 of pellet stoves meet today  Pellet Stove NSPS 2014 (?) level: 1.0 g/hr ?  over 1/3 of pellet stoves meet today12 

# Hydronic Heater Example Options

 Exempt from 1988 NSPS  Typical emissions: >4 lb /mmBTU heat output  EPA 2010 Phase 2 Voluntary Level:  0.32 lb / mmBTU heat output  >14 EPA-qualified models already  Require at NSPS promulgation?  Typical State 2010 regulatory level:  0.32 lb / mmBTU heat output  Many local jurisdictions ban HH  New NSPS limit for 2014?  0.20 lb / mmBTU heat output ?

 >7 EPA-qualified models already  0.15 lb/mmBTU heat output?

 >3 EPA-qualified models already  >100 models qualified by EN 303-05 are estimated to meet this level  Maine Voluntary Phase 3 level:  0.06 lb/mmBTU heat output

 Many models qualified by EN 303-05 models are estimated to meet this level13 

# Fireplace Example Options

 Most are exempt from 1988 NSPS via exemptions for >35:1 air-to-fuel ratio or “open masonry fireplace constructed on site”  Typical emissions: 12 g/kg where not regulated  1988 Washington State limit  7.3 g/kg of wood burned  EPA 2010 Phase 2 Voluntary Level:  5.1 g/kg  DRAFT EPA 2011 Phase 2 Voluntary Level  2.7 g/kg of wood burned  Typical California AQMD 2010 regulations:  Ban  NSPS 2014 (?) levels ?  Allow Open doors: 4.0 g/kg?

 6 models already meet this level  Require Closed doors: 1 g/kg?

 numerous models can meet this level with doors closed14 

# Masonry Heater Example Options  

### Exempt from 1988 NSPS via weight exemption (800 kg)  

### Colorado limit: 6 g/kg  

### MHA requested for EPA to initiate voluntary program:  0.13 g/MJ (0.32 lb/mmBTU heat output) 

###  

### NSPS 2014(?) level?  2.5 g/kg, 2.5 g/hr daily average, 0.32 lb /mmBTU heat output, plus 7.5 g/hr max while burning?15 

# Single-Burn-Rate Appliance Example Options  

### Exempt from 1988 NSPS  

### NSPS 2014(?) level?  “Camp stoves” must be for temporary use?  Same as wood stoves, except burn rates?16 

# Cook Stoves Example Options  

### Exempt from 1988 NSPS  

### NSPS 2014 levels?  Design requirements for “North American traditional cook stove”?
 Estimates of less than 1000 units per year  Some States, same as wood stoves  European BAT: 3.0 g/hr?17 

# Forced-Air Furnace Example Options  

### Exempt from 1988 NSPS  

### Canadian B415.1 level  0.60 lb/mmBTU heat output  Require at NSPS promulgation? 

###  

### NSPS 2014(?) level?  Same as hydronic heaters?
 To level the playing field  Allow longer time?18 

# Coal Stoves Example Options  

### Exempt from 1988 NSPS  

### NSPS 2014(?) level?  Same as wood stoves?
 To level the playing field  Allow longer time?19 

# Contacts: Gil Wood wood.gil@epa.gov (919) 541 -5272 David Cole cole.david@epa.gov (919) 541 -5565