# Residential Wood Heaters New Source Performance Standards (NSPS)

Draft Proposal Update for April 24, 2013 EJ Communities Call 4/15/13 W orking DRAFT– Subject to change. Does NO T re pr esent final EP A decisions.

# EP A Point of Contact

Gil W ood, Project Lead 919 - 541 - 5272 wo od.gil@epa.gov

# Current Schedule ► Draft * NSPS proposal package being reviewed internally ► Draft should be ready to start normal 90 - day review b y other federal agencies by June 2013 ► Anticipated schedule: ► Summer 2013 – Proposed rule to be signed by EP A A dministrator and published in Federal Register and on - line ► 90 - day public comment period – Opportunity for people to submit information for EP

A to consider as we develop the final rule. Information on how

t o comment w ill be on the website wh en we propose the rule. ► If requested, a public hearing wi ll be held during the comment period ► Summer 2014 – Final rule to be signed by EP A A dministrator and published in Federal Register and on - line ***** Proposal is still draft and subject to change pending EP A Administrator ’s review and signature on rulemaking proposal in Federal Register for public comment
3 4/15/13 W orking DRAFT – Subject to change

# To day’ s Update ► Key Changes from 2 - 9 - 12 Update ► Wo od Stoves (and single - burn - rate stoves and pellet stoves) ► Hydronic Heaters (aka indoor and outdoor wood boilers) ► Forced - air Furnaces ► Masonry Heaters ► Te st methods ► Peak, Shorter- term Emissions ► Cordwood Te st Method ► Ef ficiency and Carbon Monoxide ► Projected Impacts ► Questions ► Appendix - Historical Overview
4 4/15/13 W orking DRAFT – Subject to change

# Key Changes ► **Tw o**  **- Step**  **Ap proach**  **Preferred for Proposal** ► The states and environmental communities feel strongly about the need for stringent stepped standards as soon as possible. ► We would propose to require compliance with Step 1 emission limits immediately and Step 2 tighter emission limits in 5 years. ► Three - Step Approach for Comment ► We would ask for comments and environmental and economic data for potential justification of a Three - Step Approach that would require Phase 1 immediately, an interim Step 2 in 3 years, and a final Step 3 in 8 years. The emission limits would be identical for Step 2 in the T wo - Step Approach and Step 3 in the Three - Step approach. ► EP A’ s current preference is for the T wo - Step Approach but we will consider the information submitted during the public comment period and the final rule will include the appropriate approach. We do not expect the final rule to allow individual manufacturers to choose between approaches. 5 4/15/13 W orking DRAFT – Subject to change

# Wo od Stoves **Preferred T**

**wo -**  **Step Ap**  **proach for W** **ood Stov** **e NSPS Proposal**  ► **Step 1: W**

**ashington State noncat**  **emission lev el**  **upon promulgation**  

### • Over 85% of sales of EP A - certified wood stoves are models that already meet this level. ► **Step 2: “Best Systems” emission lev** **el fiv** **e years**  **after promulgation** ► We would combine catalytic and non - catalytic units under one emission limit. ► We would include single - burn - rate stoves and pellet stoves. ► We would prefer to establish an emission limit for cordwood (rather than cribs) for 2019, if possible. W e appreciate the testing that labs are conducting now t o help inform us of w hat is possible.
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# Hydronic Heaters **Preferred T**

**wo -**  **Step Ap**  **proach for Hydronic Heater**  **NSPS Proposal** ► **Step 1: Partnership Program Phase 2 lev el**  **upon promulgation** 

– 36 hydronic heater models (27 cordwood and 9 pellet models) built by 17 U.S. manufacturers have already been qualified at this level. ► **Step 2** : **“Best Systems” fiv** **e years**  **after promulgation**

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# Forced - air Furnaces **Preferred T**

**wo -**  **Step Ap**  **proach for Forced**  **- air Furnaces NSPS Proposal**  ► **Step 1: CSA** 

**B 415 lev** **el upon**  **promulgation**

– The two primary U .S. manufactur er s of for ced - air furnaces both have models that can meet St ep 1 alr eady. Other manufactur er s ar e conducting te sts now . ► **Step 2: “Best Systems”**  **fiv e**  **years after promulgation** 

8 4/15/13 W orking DRAFT – Subject to change

# Masonry Heaters **Preferred Compliance Requirements for Masonry Heater NSPS Proposal**  : ► **Lev el**  **Equiv alent**  **to HH upon promulgation except for small v olume**  **manufacturers.**

– Based on dat a submit te d by the Masonry Heat er Association, over 10 models alr eady achieve this level.

– Man y other models ar e e xpect ed to use a comput er simulation to show that their design would be expect ed to achieve the NSPS level without conducting further t es ting. ► **For small v olume**  **manufacturers (less then 15 total units per year), compliance deadline w**  **ould be 5 years**  **after promulgation**

– Most masonry heat er manufactur er s ar e very small businesses that pr oduce less than 12 heat er s per y ear . 9 4/15/13 W orking DRAFT – Subject to change

# Scope of the Rules

► We feel strongly about the need to minimize potential loopholes. ► We are considering proposing three subparts as follows:


### • Subpart AAA, aka “room heaters”

– Adjustable burn rate stoves, single - burn rate stoves, and pellet stoves



### • Subpart QQQQ, aka “central heaters”

– Outdoor and indoor hydronic heaters

– Forced - air furnaces



### • Subpart RRRR

– Masonry Heaters

10 4/15/13 W orking DRAFT – Subject to change

# Te st Methods
► **Peak, shorter -** **term emissions**  ► We would add multiple 1 - hour filters for each test run to gather data regarding start - up and anticipated peaks. ► For Step 2, we wo uld require compliance wi th 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. ► **Cordw ood**  **test method** ► We would add testing w ith cordwood to encourage best real - wo rld performance. For Step 1, the manufacturer would submit 2 test reports, 1 wi th cribs and 1 w ith cordwood and choose w hich results to use for certification. For Step 2, the tests would all be w ith cordwood. ► We are working wi th states and labs and industry on the details. ► **Precision** ► We would propose improvements to the test methods to improve precision. 11 4/15/13 W orking DRAFT – Subject to change

# Ef ficiency and Carbon Monoxide
► **Efficiency** ► We would require testing and reporting but not a minimum ef ficiency.

► **Carbon Monoxide** ► We would require testing and reporting of CO but not an emission limit.

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# Projected Impacts

► We expect the rule would reduce fine particle pollution from new heaters by ~4,800 tons per year over the 2014 - 2022 timeframe; many reductions would be in areas w ith significant particle pollution problems. ► We expect monetized health benefits would be >$4 billion per year and lives would be saved. ► We expect costs would be ~$16 million per year.

13 4/15/13 W orking DRAFT – Subject to change

# Questions?

14

# Appendix - Rulemaking Overview ► On February 26, 1988, EP A published the original NSPS for residential wood heaters. ► In 1995, Washington State tightened the emission limits in W A. Almost all manufacturers chose to meet the W A limits for all U.S. models. To day, over 85% of EP A - certified models meet the W A emission levels. ► In November 2009, EP A released a draft review document with preliminary draft conclusions. ► EP A conducted numerous stakeholder outreach activities and prepared the technical and economic information necessary for a draft proposal. However, the February 2012 draft proposal did not have great support and EP A began to consider other options. ► In November 2012, State and local air pollution control agencies hosted a national forum for a broad range of stakeholders (including EP A, manufacturers, health organizations, and environmental groups) to discuss the issues and potential options. ► EP A has prepared new options for the draft proposal after consideration of the information and recommendations discussed in November and in numerous follow - up discussions. ► The new options would better reflect current best systems of emission reduction and add emission limits for new appliances that were not regulated in 1988, such as indoor and outdoor wood boilers, forced - air furnaces, and single - burn - rate stoves. They would also include improvements of the repeatability of the test methods and add testing requirements to address short - term emission peaks and testing with cordwood to better represent real - world conditions. ► The monetized health benefits far exceed the costs for all options considered. 15 4/15/13 W orking DRAFT – Subject to change