### Presentation for NSPS Consideration:

Oversizing Hydronic Heaters :

1. Oversizing Outdoor Hydronic Heaters (OHH) for residential use immediately invalidates the EPA’s stamp of approval of cleaner technology

, yet consumers more often than not purchase oversized units for the following reasons:

a. Larger firebox which increases time between loadings. b. To heat additional out

- building such as garages and pole barns.

c. To prepare for future out

- buildings

. d. To heat pool s, Jacuzzis, melting ice on drive ways etc.

e. Dealers convince buyers t o purchase l arger units. f. Consumers believe their units are not oversized based on the EPAs whitetag.



### Examples as to why oversized units create nuisance conditions:

a) Most operators o f OHH dislike getting up late into the night to reload fuel. By purchasing an oversized unit, the firebox is larger and the unit stays in Category 1 mode for long periods thereby preserving the fuel and increasing the time between loadings.

b) Purchasing a la r ger OHH to simultaneously heat a home and outbuildings may operate more efficiently when both are calling for heat, but during those instances when the owner does not occupy the outbuilding(s) the second zone may be turned off to save fuel creating an oversized condition for the home.

c) Many home owners purchase oversized units based on the possibility of constructing
additional out

- buildings in the future. During the time the building(s) are on the wish list
the oversized unit creates nuisance condit ions for neighbors.

d) Pools, Jacuzzis, driveway heating etc., are all temporary with respect to being part of the heating load. When an OHH is purchased to accommodate these conveniences, along with heating a home, an oversized condition exits when there is no longer a requirement to provide heat to the secondary needs.



### Cycling Technology:

Cycling technology employed in Outdoor Hydronic Heaters (OHH) is an inefficient method of regulating heat demand of a building. Compared to other heating systems such as natural gas, hydronic heaters employing cycling technology do not simply turn off when there is no longer acall for heat. Instead , they idle in Category 1 mode

, setting the co nditions for heavy smoke and

pollution during the next call for heat cycle. Oversized units exacerbate this condition.



### Research:

The significance of oversizing and its effect on efficiency and emissions is not a recent subject. NESCAUM and NYSERDA warned the EPA about the dangers associated with improper sizing in past reports. In the following passage NYSERDA not only outlines the hazards of oversizing but also implies that the current testing methodology is lacking when considering climates (design day) not represented in the test procedures.

“ As the units are increasingly oversized, the amount of time spent in the lower load s increases and performance at these loads is typically lowest. As efficiency decreases, PM emissions increase greatly, often in an exponential manner below 25% load. The Syracuse model shows that for a reasonably harsh climate, the average output of a Whi te Tag unit provides a sizing factor of three, which yields about 90% of the operation at a load of 25% or less. It is also important to consider that these units are installed nationwide where milder winters such as in the South could yield sizing factors much larger than three, hence pushing the hydronic heater into even lower load operation

. As the heater’s nominal output increases beyond the design day heat load, the time spent operating at lower loads increases. The average output of the White Tag unit s when using the load side data is 175 kBtu/hr. This leads to significant oversizing ranging from 2.7

— 8.8 times the design load depending on the climate. (Review of EPA Method 28 OWHH Test Results, NYSERDA, Page 11

- 13 )”



### Conclusion:

It goes without saying that government testing programs do not rely strictly on science to arrive at final testing protocols. But the issue here is not a few miles per gallon from what the sticker reads on a new car, it represents significant nuisance con ditions that drives people from their homes and harms health. After receiving complaints for years from states’ and citizens’ affected by hydronic heaters , the EPA must not squander this opportunity to finally get it right. Human health should not be a ne gotiable. NSPS should require that certification testing be based on
three climates

– very cold, cold, and mild winters. If the manufacturer elects to sell its product in any of the three climates then testing should be adapted to represent that climate. Based on the EPA sponsored NYSERDA report, the average whitetag unit tested is already oversized by a factor of three if sold in a cold climate. This simply does not pass the common sense test when considering the requirements of the Clean Air A ct and is one of the main reasons Phase II models continue to create nuisance conditions. Simply stated

, cycling technology in its present form cannot operate safely even with a whitetag attached.

Because there have been countless Phase II oversized units sold m any families are now enduing a living hell with very unattractive options to remedy the created health hazard. State DEQ’s andlocal government who bought into the voluntary program now have their hands tied because

Phase II units have been touted as safe and 90 percent cleaner yet most of the mod els bearing the whitetag earned the label as a result of the technology driving the test instead of the test driving technology. We ask that this significant flaw in testing be remedied to ensure that sizing factors are accounted for based on the projecte d climate the model will be sold while also considering how out

- buildings and other secondary variables affect initial load calculation s

. We also ask that strong enforceable language be added to NSPS not allowing oversized units to be sold in any climate where the “design day” variable is exceeded to a point where a health hazard
could be created. Finally, we ask for strong mandatorily enforceable nuisance protections to counter the damage already inflicted on families as a result of flawed testing during the voluntary p rogram and that this program be immediately discontinued.



### Proposed Language f or NSPS :

The EPA cannot guarantee that a certified Outdoor Hydronic Heater will not create a nuisance
condition if the unit installed is oversized

. Addition ally, outb uil ding or other secondary structures included in the initial residential load calculation (Manual J) can also cause nuisance smoke and odor if these secondary loads are switched off by either low temperature settings or the zone is made inoperable when the HH is operational. State and local authorities should also consider not allowing oversized in stallation s of Hydronic Heaters for anticipated out

- buildings or secondary uses unti l the additional heat loads are operational and analyzed by cert ified personnel.



### Manufacturers:

Hydronic Heater Manufactures are always quick to point out that it’s not their product that

creates nuisance conditions but how the unit is operated. The aforementioned suggestions will assist in proper operation.

Thank you for the opportunity,

Roger Soldano