From: Knoxstoveworks@aol.com

To: Lucinda Power/DC/USEPA/US@EPA, Gil Wood/RTP/USEPA/US@EPA

Date: 09/12/2010 08:57 PM Subject: SBREFA Panel

- Cook Stove Caucus

Lucinda,

I have attached the Cook Stove Caucus' position paper for your records. Thank you for your help during this process.

Warmest Regards,

Joe NSPS Review Paper

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- 10.docx

# NSPS Review Paper

The Wood Cook Stove Caucus would like to present some of our concerns over the proposed

NSPS regulations and the effect on our segment of the hearth industry. Throughout the period of the EPA Phase 1 and 2 regulations (1988

- 1992), the consensus among those studying the issue of the wood cook stove and regulatory compliance was both the lack of workable technology and relatively small sales numbers for wood cook stoves. The existing and proposed NSPS test methods were based upon a wood room heater. The test data used is weighted based upon expected burn rates. There was

, and is

, no relevance to a wood cook stove in this data due to the cook stove's use for cooking versus wood heater's use for generating heat.

No data has ever been gathered for normal use of a wood cook stove, as well as, no standard being established to test a cook stove. The crux of our dilemma is no best demonstrated technology (BDT) exists that would enable the cook stove to meet current or proposed standards.

As you have seen from the CBI’s, the sales total for all of these five producing companies is le ss than one thousand units per year. Further, the majority of those sales are located in the five

Midwestern states of Illinois, Indiana, Michigan, Ohio, and Pennsylvania. There is truly no national significance from the sale of wood cook stoves.

From a technological standpoint, one hurdle the wood cook stove faces is the need for extremely low operational temperatures in food simmering applications. Allen Carroll of Appl ied

Ceramics stated the minimum operational temperature for a catalyst is approxima tely three hundred degrees Fahrenheit. In Applied Ceramics tests with both Hydronic Stoves and wood cook stoves, they found numerous burn tests resulting in temperatures below this minimum. The result is a malfunctioning of the catalyst rendering it use less. Temperature variation is also a result of firebox water coils, which allow the consumer to heat water for household use. This uses a tremendous amount of the firebox BTU’s and is an option unique to the wood cook stove. With the current technology of secondary burn devices, dedicated temperature control is not possible. The ensuing variations would render reliable oven temperature control impossible.

An integral feature of any wood cook stove is the reliable control of the temperature in the ove n. The use of both a pre

- fire intake damper, as well as an oven bypass damper achieves this.

W e, as manufacturers, have not been sitting idly by. Airtight firebox technology along with a tightening of the tolerances between the cooking surface parts are just two of the improvements

introduced since 1988.

One of the concerns which have been expressed to us is the hijacking of the term “Wood Cook Stove” by some manufacturers in an attempt to avoid regulation. This is a valid concern and one

which w e have addressed. We propose adding two new items and eliminating one to the definition of a wood cook stove which would eliminate the use of the term on anything other

than a true wood cook stove.The complete definition, including our additions and subtraction of the shaker grate requirement

is listed below.

(1) An oven, with a volume of 0.028 cubic meters (1 cubic foot) or greater, and an oven rack, (2) A device for measuring oven temperatures, (3) A flame path that is routed around the o ven, (4) An ash pan, (5) An ash clean

- out door below the oven, and (6) The absence of a fan or heat channels to dissipate heat from the appliance.

Additions:

(7) A Cook Stove will have a cooking surface measured in square inches or square feet which is 1.5 times greater than the firebox which is measured in cubic inches or cubic feet. Example: A firebox of 2 cubic feet would require a cooking surface of 3 square feet.

(8) A portion of at least four sides of the oven will be exposed to the fl ame path during the heating cycle of the oven while a flue gas bypass will be permitted for temperature control.

The need for wood cook stoves in rural homes that either do not have grid access or suffer frequent winter power outages is also of vital importance. During a period of electrical power failure, the wood cook stove becomes the most important appliance in the home

.

An interesting aspect unique to the wood cook stove is the use by religious groups, including the Amish, Mennonites, and others, as an integral part of their religious heritage. An important tenet of their religious practice precludes the use of outsid e electrical or gas supplies. For this reason they are limited to the use of the wood cook stove to prepare their meals and heat their water. This religious practice is one they have followed for two hundred years.

If the wood cook stove is not grante d exemption from the proposed NSPS regulations it will effectively end the wood cook stove industry in America. This action will cause undue hardship on people in rural areas who rely on it to cook their food and heat their water. Non

- exemption

would als o force change upon the religious communities who have used it since its inception as not only a way of life, but an integral part of their religious practices.

Today, neither the hearth industry nor government agencies have been able to provide a BDT

whi ch would allow a wood cook stove to operate in the same manner as a wood room heater. No wood cook stove specific data has been gathered nor have any testing standards ever been established to give us a baseline from which to start.By tightening the d efinition of a wood cook stove, we believe we have eliminated the possibility of companies using the term, “wood cook stove”, as a method to usurp regulation. As we are a de minimis segment of the hearth industry, we respectfully request a continuation of exempt

status for the true North American Wood Cook Stove.

Warmest Regards,

Cook Stove Caucus

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