10/27/2012

1

# Hydronic Heater NSPSIndustry Perspective

1 

## Presented by the Hearth, Patio & Barbecue Association 

# Hydronic Heater Terminology

2

• Outdoor Furnaces/Outdoor Wood Furnaces (OWF) • Outdoor Wood Boilers (OWB) • Outdoor Wood Hydronic Heaters (OWHH) • Wood Hydronic Heaters (WHH) includes Indoor Hydronic Heaters Hydronic Heaters • Hydronic Heaters are appliances that burn wood or pellets and produce hot water. • They can be pressurized but are most North American Hydronic Heaters are unpressurized. • Warm air furnaces are a totally different product category. • They produce heated air not heated water.10/27/2012

2 

# Hydronic Heaters - Background Timeline • 2004 – ASTM test method development begins. • Essential first step – can’t have emission limits with out a test method. 

### • 2006 – EPA, NESCAUM, NESCAUM States and HPBA Outdoor Hydronic Heater Caucus hold stakeholder meetings for NESCAUM Model Rule and EPA Voluntary Program. 

### • 2007 – January: EPA Voluntary Program for OWHH is launched. • Phase 1 PM limits of 0.60 lb/mmBtu Input . • Phase 2 PM limits of 0.32 lb/mmBtu Output (90% PM Control). – NESCAUM Model Rule has EPA Phase 2 limit. • EPA test method (EPA M28 OWHH) based on very early ASTM draft. 3 

### • 2008 – July: ASTM Hydronic Heater Test Method (ASTM E2618) Published. 

### • 2010 – March: EPA Voluntary Program Phase 1 Ends. 

### • 2011 – April: EPA commences stakeholder process to modify EPA M28 OWHH to address output and efficiency determination issues. – October: EPA M28 WHH adopted. 410/27/2012

3 

### Summary • Tremendous progress has been made in a very short period. – 12 models qualified under EPA Voluntary Program Phase 1. • Average PM – 0.84 lb/mmBtu Output • 26 cordwood models qualified under Voluntary Program Phase 2. – 13 Manufacturers in the program. • Stakeholders recognized that the “fast start” for the program implicated unforeseen problems and agreed to cooperatively work and in good faith to resolve them. – EPA M28 OWHH test method issues were resolved in this manner. 5

• The EPA Hydronic Heater Voluntary Program should been seen by all as a huge success. – Problems that have been encountered have been cooperatively resolved. – The significance of those problems has been disproportionally emphasized by some stakeholders. 610/27/2012

4 

## Co-Proposal (0.15 lb/mmBtu Output) for

Hydronic Heaters • EPA cannot support a finding that 0.15 lb/mmBtu Output is achievable by “demonstrated” technology. – Only two cycling models have been qualified below this level under the Voluntary Program, using EPA Method 28 WHH. • One of these is at 0.14 lb/mmBTU –barely under the lim it. • Two other models have been qualified below this leve l using EPA Method 28 OWHH making these data suspect for BDT consideration. – Test Method Precision needs to be taken into account in standard-setting. • No rigorous precision analysis is yet possible for M28WHH. – Precision is likely to be similar to the precision for t he Wood Stove test methods. 7 • “European Technology” employing “Partial Thermal Storage” won’t support the co-proposal. – The emissions data for PTS appliances are from the EN testmethod, which doesn’t provide a “reasonable worst case” emissionprofile. – This creates an “apples and oranges” problem: • The EN data cannot be adjusted to M28 WHH equivalents . 1 • The test method differences (EN303-5 v. EPA M28WHH or AST M E2618) make comparison of corresponding test results impossible. – An ASTM test method that specifically addresses PTS applian ces is still under development. • Good progress is being made by the ASTM task group whi ch includes participation by representatives from EPA, Brook Haven National Laboratories (NYSERDA Contractor) and Vermont and is being monitored by a num ber of other interested parties. 1 **North American and European Wood-Fired Boiler Testing Comparison**, Rick Curkeet, PE, Chief Engineer – Hearth Products, Intertek Testing Services, Inc., September 28, 2010 810/27/2012

5 

# ASTM PTS Test Method • Key Elements of the Draft Test Procedure include:

– “Cold” starts from empty fireboxes for the two lowest heat output categories (Categories 1 & 2). – “Hot” starts on coal beds for the medium and maximum he at output test runs (Categories 3 & 4). – The option for a partial fuel load in the Category 1 (Lowest Heat Output) test run to prevent an appliance-forced shutdown that would otherwise void the test run. – A procedure for determining that combustion has comp letely ceased before the full test fuel load is consumed. – Inclusion of the manufacturer’s recommended minimum storage volume as part of the test apparatus. – A requirement that the Category 2 test run consume the full test fuel load. 9 

## • Limited data indicates that crib fuel is very problematic for PTS appliances. • Available test data (all with cordwood) generated during PTS test method development are indicating that heaters that employ PTS could have weighted average PM emissions (lb/mmBtu Output) in the same range as Phase 2 cycling models. – The cold starts for the low heat output categories are contributing significantly to total PM. • The low heat output categories are heavily weighted in the average emission ratings. 1010/27/2012

6 

## • In consequence, setting the standard at 0.15 lb/mmBtu Output can be expected to disqualify many PTS models when they are tested with the new PTS test method.

11 

# Cost Effectiveness • We have very serious doubts that the coproposal is cost effective, since 0.32 lb/mmBtu Output already represents 90% particulate emission control. – Industry is developing a rigorous cost effectivenes s analysis. 1210/27/2012

7 

### • EPA must stick with 0.32 lb/mmBtu output. – 90% particulate emissions reduction is a remarkable level of improvement for batch-fired, consumer-operated combustion devices. – EPA has qualified 26 cordwood-fired models to this limit under the Voluntary Program. – HH manufacturers have accomplished this in record time and at considerable cost . BUT: » These models are produced by only 13 manufacturers – less than half of the total North American HH manufacturers. » Many additional models need to be developed and qualified to meet marketplace demands. • The 26 models are only a fraction of all models producedby the 13 Voluntary Program manufacturers. 13 

## Conclusions Regarding the Co-Proposal

• 0.32 lb/mmBtu is NOT a “low bar.” – While 26 models have been qualified, an unknown but significant number were sent to the lab with confidence they would pass, and actually failed. – The precision of EPA Method 28 WHH has not been determined. • Due to the random nature of burning wood, it is unlikely to be better than the precision of the woodstove test methods. • Lowering standards without taking the precision of the compliance methods into account is inappropriate and arbitrary. 1410/27/2012

8 

# EPA’s Proposal to Add an Efficiency Standard for Hydronic Heaters • There are major problems with the proposed efficiency standards: – EPA has discredited the efficiency data database. – The precision of the efficiency determination has not been determined. 

### • The format of the standard (lb/mmBtu Output) already indirectly regulates efficiency by making manufacturers accountable for heat output. • Instead of efficiency standards, we support the previous EPA position: a requirement to report efficiency values for consumer use. 15