# NSPS Revision Recommendations

• Test Methods



## • Product Types



## • Efficiency



## • Emissions Units



## • Certification



## • Fueling Procedure



## • Other Issues

Rick Curkeet, PE Chief Engineer

# Test Methods

• Replace EPA Methods with Consensus Standards

– Emissions Measurement

– ASTM E2515

– Outdoor Hydronic Heaters

– ASTM E2618

– Fireplaces

– ASTM E2558

– Wood/Pellet Stoves

– CSA B415.1 (New version) or ASTM if Available.

– Forced Air Furnaces

– CSA B415.1 (New Version)


## • Advantage

– Consensus Standards are Preferred.

– OMB Circular A119

– Consensus Standards are updated and revised on a regular basis to improve and keep pace with new technologies.

# Product Types

• Coverage should be expanded to cover all common types of bio

- mass fueled appliances.

– Furnaces

– Boilers/Hydronic Heaters

– Pellet/Corn/Grain burning heaters

– Cook Stoves

– Masonry Heaters



## • Not being included in regulatory system leads to being excluded from some important markets.

# Efficiency

• All heating appliances should be tested and rated for heating efficiency.



## • CSA B415.1 will include an updated and reliable “Stack Loss Method” for direct heating appliances such as wood stoves and pellet type appliances.



## • Furnaces and Boilers should be rated for delivered efficiency based on direct measurement of heat output.


## • Critical to have recognized test methods to support US tax credit incentives. Heat Input Comb 

## . Loss Heat Transfer Loss

Delivered Heat

# Emissions Units

• All Heating Appliances should be rated and regulated for emissions on a particulate mass per unit of heat output basis.

– Grams/Mega Joule (g/MJ)

– Lbs/Million BTU (lb/MMBTU)


## • Provides a fair approach for consistent requirement for different types of solid fuel heating appliances.



## • Automatically incorporates incentives to improve efficiency.



## • Non

- Heating Appliances (e.g. Fireplaces) should be rated and regulated based on mass per unit of fuel burned

– e.g. grams/kilogram (g/kg).

# Emissions Units

• Existing EPA “emissions adjustment factor” to convert EPA method 5G to Method 5H equivalent (E adj 

### = 1.82 x E Meas 0.83 

### ) should be dropped and limit stated in un

adjusted 5G (ASTM E2515) values.



## • This would change nothing in terms of the result necessary to meet a specified limit and would remove a very dubious issue from the process. The size of the correction gets larger as emissions decrease which is not correct (see next slide).



## • Example

– If the current method’s limit where set at 4.5 grams/hour, the unadjusted 5G result would need to be 3.0 grams/hour. This would equate to 0.2 g/MJ or 0.46 lb/MMBTU based on the current non

- catalytic woodstove default efficiency of 63%.

# Eliminate 5G to 5H “Correction”.

EPA Method 5G to 5H Correction Factor

0.0 0.5 1.0 1.5 2.0 2.5 3.0

0 1 2 3 4 5 6 7 8 Measured Emissions Rate (g/hr)Corection Factor

0 1 2 3 4 5 6 7 8 9 10Corrected Emissions (g/hr)

Correction Factor "Corrected" Emissions

# Certification

• Emissions and Efficiency Certification should be handled through “Third

- Party Certification” per ISO/IEC Guide 65.


## • This process is already in use for “Safety Certification” of nearly all the appliances involved.


## • It includes a robust and reliable follow

- up inspection process that assures on - going conformance of individual production units.


## • Much more efficient and reliable than the NSPS Random Compliance Audit program that has never been implemented. Particulate Emissions and Heating Efficiency Certified per ASTM E2618
- 08

Manufacturer: ODHH Inc. Model: 150 Clean Heat Serial #: 123456 Particulate Emissions Rate: 0.13 lb/mmBtu Output Use: Heating Season Only. Delivered Heating Efficiency: 76% Maximum Heat Output: 128,000 Btu/hr w/ reload at 2.5 hr. intervals. 8

- Hour reload output: 85,000 Btu/hr. Fuel: Seasoned Cordwood only.
Particulate Emissions

0 lb/mmBtu Output 0.60 Better Worse This Model 0.13

Delivered Heating Efficiency

0 Percent 100 Worse Better This Model 76%

IMPORTANT: THIS APPLIANCE IS INTENDED TO BURN SEASONED CORDWOOD FUEL ONLY. OPERATE IN ACCORDANCE WITH MANUFACTURER'S OPERATING INSTRUCTIONS ONLY. FAILURE TO OPERATE THIS APPLIANCE AS DIRECTED MAY RESULT IN VIOLATION OF AIR QUALITY REGULATIONS AND SUBJECT THE OPERATOR TO ENFORCEMENT ACTIONS INCLUDING FINES AND/OR REMOVAL ORDERS.

# Certification

• Involves no cost to regulatory agencies and minimal cost to manufacturers or consumers as the process is already required and functioning for product safety certification.



## • Third

- Party Agencies already available and active in this area.



## • Process is based on internationally recognized standards.

# Fueling Procedure

• All solid fuel burning appliances should be rated for emissions and efficiency performance with the fuel that they are intended to burn.



## • Arguments for the use of cribs have not been supported by data available.

– Cribs do not provide significantly better reproducibility than cordwood.

– Cribs do not provide a reliable indication of real world performance.

– Cordwood can be specified in a manner that provides a good representation of typical real world operation.


## • Pellet Burners are tested with pellets, corn burners with corn, etc.

# Other Issues

• Burn Rates

– The requirement for wood stoves to operate at under 1 kg/hr burn rate should be dropped in favor of the minimum being a percentage of the maximum.

– This requirement has been unnecessarily design restrictive.

– The CSA B415.1 burn rates

- <35%, 35

- <53%, 53

- <76% and 100% should be considered. The average low burn rate for all EPA certified woodstoves and pellet burners is 28% of the maximum.

– Consider going to 3 burn rates rather than 4.



### • Fuel Species

– Fuel should be specified based on density range rather than species. Data indicates that fuel density is a more significant contributor to variability in results than species. Changing this requirement would make it easier for labs and manufacturers to obtain specified fuel locally.

– This approach would be consistent with long standing practice in Europe. EPA Certified Stoves

0 50 100 150 200

10% 15% 20% 25% 30% 35% 40% 45% 50% 55% 60% Minimum Burn Rate % of MaximumNumber of Models

# Other Issues

• Eliminate “Gram per Hour Caps” in regulatory requirements.

– A gram per hour emissions cap serves to limit the output rate of affected appliances which actually burn very cleanly.

– For example, a cap of 18 grams/hour limits the output of an appliance that would meet a 0.2 g/MJ (0.46 lb/MMBTU) limit operating at 80% efficiency to a burn rate of 5.7 kg/hour and a maximum output of 86,000 BTU/hr.

– Where heating applications require larger heat demands, caps could result in users being forced to buy fossil fueled appliances rather than using renewable bio

- mass fueled equipment. Alternatively users might buy multiple smaller units to meet a larger heating demand application to work around the cap issue. Maximim Heat Output Rating All EPA Certified Stoves

0 20 40 60 80 100 120 140 160 180

10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 Max Output (1000 Btu/hr)Number of Units

# Other Issues

• Consider revision to the “5

- minute start

- up” requirement for manually controlled appliances.

– It is well known that start

- up with a fresh fuel load can be critical in obtaining good combustion performance.

– The 5

- minute limit seems arbitrary and over

- rides reasonable manufacturer’s operating instructions.

– Many of the so

- called “outliers” in EPA woodstove test programs are simply the result of failure to operate at a high burn setting for long enough to establish and sustain secondary combustion.

– Real world performance would benefit from more specific instructions to the user on how to assure good start

- ups when reloading. Laboratory testing should include following such instructions provided they are clear and reasonable.