# Residential Wood Heaters New Source Performance Standards (NSPS)

Proposal EP A A ir To xics Risk Assessors Call February 13, 2014 This presentation is a good faith effort to represent the proposal as signed 1/3/14. An y differences are unintentional and do not supersede the official 2/3/14 FR proposal. Please email comments on the proposal to the official docket at: a - and - r - docket@epa.gov

, Attention Docket ID No. EP A - HQ- OAR - 2009 - 0734

# Current Schedule ► Proposal was signed by EP A Administrator on January 3, 2014 ► The full proposal and fact sheets are available on - line at http://w ww2.epa.gov/residential - wood - heaters ► The proposal wa s published in Federal Register on February 3. http://w ww.gpo.gov/fdsys/pkg/FR - 2014 - 02 - 03/pdf/2014 - 00409.pdf ► There is a 90 - day public comment period until May 5 ► Opportunity to submit comments and data for EP A to consider ► Information on how to comment is on the website ► A public hearing w ill be held in Boston on February 26, 2014. ► Information on how to register is on the website. ► Wew ill 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 r ule

– Outdoor and indoor hydronic heaters

– Forced - air furnaces ► Subpart RRRR new

r ule

– Masonry Heaters

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# 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

a n EP A- accredited lab, and attach EP A label after EP

A approval. ► The proposal will update the 1988 NSPS to reflect today ’s b est systems of emission reduction, considering costs. These systems are ~80% cleaner and more ef ficient. ► The rule will af

fect 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. ► Te st 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 ef ficiency and carbon monoxide. ► The projected monetized health benefits are far greater than the costs (>100:1).

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# 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 -wo od materials) ► Proposal by itself would not ban certified devices or restrict hours of use. ► New i ndoor fireplaces ► Not ef fective heaters (this NSPS is for "residential wo od heaters ”) ► However, EP

A is taking comment ► Fireplaces are included in an EP A voluntary program that encourages manufacturers to make cleaner- burning fireplaces and retrofits available for consumers. 1 Werefer to “Strategies for Reducing Residential Wo od Smoke” on EP A’ s Burn Wise website and note that it includes ideas for local regulations, voluntary programs, funding mechanisms and best burn practices - all of wh ich can help reduce particle pollution from existing wo od - 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 P anel 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 wh ile still meeting the legal requirements in the Clean Air Act.
► We w ill continue to work to address environmental and small business potential impacts throughout the process to get to the final rule.

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# 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 - ye ar period • Step 1 – similar to Washington State’s 1995 limit for non - catalytic stoves (most adjustable rate EP

A- certified stoves already meet today)

– EP A- 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) ► Wo uld have to meet the same emission limits as adjustable burn - rate stoves ► Pellet stoves ► Wo uld 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. ► Wo uld have to meet same emission limits as adjustable burn rate heaters 7

# Room Heaters -- Proposed Emission Limits

8 Manufacturers must use 3rd - party, independent, ISO - accredited and EP A- approved test laboratories and certifying entities to demonstrate compliance with a representative appliance for a model line. **Subpart AAA** 

**A ppliances**  **Phases / Steps PM Emission Limits**  Heaters with current EP A 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

# Central Heaters (Subpart QQQQ Proposal ) ► Wo uld af

fect hydronic heaters and forced - air furnaces ► Not subject to 1988 NSPS ► Hydronic heaters are also know n as indoor and outdoor wood boilers

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# Hydronic Heaters (in Subpart QQQQ) ► In January 2007, EP A 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 w hite 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 EP

A voluntary “Hydronic Heater Program” ► Step 2: meet strengthened limits (see table) 5 years after effectiv e date ► Te sting and certification process similar to revised subpart AAA

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# Hydronic Heater – Proposed Emission Limits

11 EP A 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

# Forced -Air Furnaces (in Subpart QQQQ)
► Step 1 is based on the Canadian consensus standard. ► Step 1 is higher than HH because most F AF have not progressed as quickly, but all should catch up by Step 2

12 EP A 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

# Masonry Heaters (in Subpart RRRR) ► Currently not regulated ► Wo uld 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 dif ficult. ► Compliance deadlines based on production level ► Most companies make less than 15 heaters per year

13 **Annual Pr** **oduction 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

# Te st Methods ► **Peak, shorter -** **term particulate emissions**  ► Weadd multiple 1 - hour filters for each test run to gather data regarding start - up and anticipated peaks. ► For Step 2, we 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** ► Weadd testing w ith cordwood to encourage best real -wo rld performance. For Step 1, the manufacturer would submit 2 test reports, 1 w ith cribs (dimensional lumber) and 1 w ith cordwood and choose w hich results to use for certification. Step 2 tests would all be w ith cordwood. ► Wew ill continue to work wi th states, labs and industry on the details. ► **Precision** ► Wepropose improvements to the test methods to improve precision.
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# Ef ficiency and Carbon Monoxide ► 

### Ef ficiency ► Werequire testing and reporting but not a minimum ef ficiency 

### ► 

### Carbon Monoxide ► Werequire 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 EP A ► 

### Model lines also subject to audit testing • Sealed/stored units used for original performance test 

### • Original draw ings compared to actual unit

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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 2015 - 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. ► We expect costs would be ~$16 million per year.

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# Comments
► 

### We encourage email comments to the of ficial docket at: ► 

### a - and - r- docket@epa.gov, ► 

### Attention Docket ID No. EP A- HQ - OAR - 2009 - 0734 ► 

### Gil Wood ► 

### wood.gil@epa.gov ► 

### 919 - 541 - 5272

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