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- 0222  Fax: (919) 484

- 0122 MEMORANDUM TO: Gil Wood, USEPA

David Cole, USEPA FROM: Jill Mozier, EC/R Inc. DATE: December 9 , 2013 SUBJECT: Notes from 9/30/2013 presentation of citizens group to OMB regarding hydronic

heater concerns and Wood Heater NSPS Proposal The Office of Management and Budget ’s Office of Information and Regulatory Affairs ( OMB /OIRA ) , the Council on Environmental Quality (CEQ), the Office of Science and Technology Policy (OSTP), the Council of Economic Advisers (CEA), the Small Business Administration (SBA), and the EPA were on the call. Primary presenters were AndreaWieland, Nancy Alderman, Patric e Lee, Bonnie Lichak, and Sylv ia Schultz, a group either personally affected or representing other citizens affected by hydronic heater emissions
. Below are brief notes from the presentation , followed by one attachment . The additional numerous documents and videos submitted to OMB by the presenters will be attached to this memo in the docket.

 Andrea Wieland , currently living in Wisconsin , was present to represent citizens personally affected by indoor and outdoor wood boilers, or hydronic heaters (HH). She noted that these citizens have paid the cost of EPA not yet updating the NSPS, and that those impacted strongly support updating the NSPS. However, they oppose allowing HH at even Phase II levels, as they smoke excessively and negatively impact health and property values. Ms. Wieland li sted the known health effects of wood smoke and made the following points:
o The state of Alaska has measured 1,000 μg/m 3 particulate, which is twice the highest air quality level EPA measures. o The standard should include a g/hr never to exceed cap “ like the Washington standard ”
. o The standard should state a CO limit
. o HH are based on a flawed engineering design, as they are designed to cycle and smolder and smoke. o The proposed NSPS is not based on best available technology, as there are cleaner units (e.g. , 6 units that emit lower than proposed standards). o The argument that manufacturers can’t afford to design and sell cleaner units just shifts the cost to neighbors of HH owners. o This group urges OMB to reject the HH portion of the proposed NSPS.2

 Nancy Alderman, the president of Environmental and Human Health, Inc, (EHHI) a group of physicians and public health professionals “dedicated to protecting human health from environmental harm through research, education and promotion of sound public policy” (see http://www.ehhi.org/ ) , noted that the states rely on EPA’s expertise
. EHHI conducted a study (docketed and available on above EHHI website ) in which the indoor air of homes near and not

- so - near OWBs was sampled for particulate levels. A ho me a s far away as 850 feet from the OWB had PM 2.5 levels 6 times that of background houses, and 4 times higher than the EPA standards. These levels are unsafe to live in and the seriousness of this cannot be overstated, according to Ms. Alderman. The exposure is similar to people exposed to cigarette smoke 24/7. The impacts to affected neighbors are truly sad because they include economic impacts (e.g., can’t abandon homes and purchase others, can’t sell homes because they’re encased in smoke) and health impact s (e.g., neighbors are getting sick continuously, their children have lung impairments the rest of their lives). So these impacted neighbors are stuck in homes that are sickening them. The EHHI website receives 90,000 hits per year related to OWB wood smok e concerns. In conclusion, there are only 3 outcomes open to neighbors impacted by OWB wood smoke: (1) R emain and get sick; (2) Abandon a home that they can’t sell; (3) Pay a lawyer $150 to $450 per hour to represent them (while the people owning the OMB e mitting the smoke will pay nothing for defending their position

– there is no cost to them).

 Patrice Lee, a math and science teacher from Fairbanks, Alaska read from a handout regarding the significant health impacts to students and faculty of a Fairbanks school from two nearby EPA Phase II heaters, which is included as an attachment to this memo
. She concluded by urging OMB to reject EPA ’s NSPS proposal to cer tify Phase II (hydronic) heaters.

 Sylvia Schultz, a resident from Fairbanks, Alaska, read from a handout which is included as an attachment to this memo
. She noted EPA’s misleading basis for certifying Phase II OWB and concluded that “EPA must take a closer look at the true costs of approving a certified wood heater standard for hydronic heaters, especially the cost to public health.”

 Bonnie Lichak from New York noted the economic costs to families and further noted that concerned citizens can’t get New York to pass pr otective standards like in the state of Washington. She urged OMB to please reject EPA’s proposal to regulate HH at Phase II levels.Attachment

(Note that additional submissions to OMB from these presenters are docketed as attachments to this memo in Docket EPA HQ-OAR-2009-0734. )TO:

FROM: DATE: RE: Mabel Echols, OMB < Mabel_E._Echols@omb.eop.gov >

Sylvia Schultz Patrice Lee Sep t 29 , 2013 Septemb er 30 , 2013 meeting on th e residential wood heater NSPS and Phas e 2 Please find 21 attachments submitted in two emails. The presentations by Patrice Lee and Sylvia Schultz are included in Attachment (01). Technical support for our recommendation to OMB is provided in Attachment (02). Thank you. Attachments Submitted by Email: ( 01 ) NSPS residential wood heaters and Phase 2, Fairbanks Presentations 2013 -9- 29 .pdf (02) CAF Recommendation Opposing Hydronic Heater Standard NSPS 2013-9- 28 .pdf (0 3) 2009-1-10 FNSB photo 58 Trinidad.jpg (04) 2009-1-10 FNSB data.pdf (05) 2009-1-10 FNSB notes.pdf (06) FNSB map Woodriver bulls-eye 2011- 01
- 24 .jpg (07) Alaska v Straughn affidavits 2013-1- 31 .pdf (08 ) FNSB 190 Woodriver area AQ complaints 2008-2013.pdf (09) ADEC records re AQ in Woodriver neighborhood 2009-2010.pdf (10) Preliminary injunction Straughn 2013-2-4.pdf (11) Straughn receipt two Central Boiler 2300s 2008-4- 30 .pdf (12) Straughn FNSB application with color photos 2013-6-7.pdf (13) CAF Firewood Prices 2013.pdf (14) Alaska Resource Agency Leg Request 2011.pdf (15) Email Seth Beausang, Alaska AG Office 2013-7- 29 .pdf (16) Alaska v Straughn Settlement 2013-7- 22 .pdf (17) Alaska Resource Agency 2012-3- 29 .pdf ( 18 ) Straughn FNSB acceptance OHH replacement 2013-7- 18 .pdf (19) Gullett EPA 2012 Executive Summary 12- 15 Wood-Fired HH.pdf (20) Sidhu, Gullett 2011Toxic Air Emissions, webinar.pdf (21) Murphy, LA Times Fairbanks area chokes on wood stove pollution 2013 -2- 16 .pdfNSPS residential wood heaters and Phase 2 , Fairbanks Presentations 2013
- 9
- 30 , page 2 of 7

Fairbanks N SPS Hydronic Heater P resentations: 

### Patrice Lee

 I am Patrice Lee. I am a retired teacher, now su bstituting throughout the school district in the Fairbanks North Star Borough , Alaska
.  I would like to brief you about the harm to public health caused by smoke from two EPA Phase 2 heaters near a public school in Fairbanks . The owner installed the heaters for two rental properties in 2008.
 The Borough recorded PM 2.5 peaks up to 1,088.3 μg/m 3

. 1 , 2 , 3

 The Borough mapped the h ot zone of air pollution from these heaters surrounded by clean air
. 4

 358 public record complaints were filed regarding smoke in the neighborhood; 43 percent identified the two boilers
. 5 , 6

 Smoke was “ almost constant ” an d so thick teachers thought there was a fire in the school
. 7

 The s chool nurse identified smoke as the cause of a t least six asthma attacks in children , 4 in one day
. 8 A t least one child was hospitalized
. 9

 A teacher was hospitalized for a blood clot in her lung , missed five weeks of work , and is still receiving invasive treatment out - of

- state . Doctors attribute her symptoms to wood smoke 58 Trinidad Drive Fairbanks, Alaska EPA Phase 2: Central Boiler E - Classic 2300

5055 Palo Verde Avenue Fairbanks, Alaska Photos Prior to DestructionNSPS residential wood heaters and Phase 2 , Fairbanks Presentations 2013
- 9
- 30 , page 3 of 7

exposure . 10 S truggling to breathe, she consulted the school nurse who responded, “ Oh dear , you ’ ll just have to get an inhal er like the rest of us. ”
 Another s chool employee , athletic and a nonsmoker, required two sinus surgeries and was diagnosed with the blood oxygen levels of a smoker
. 11

 Years went by. Coughs and infections escalated into chronic conditions
. Prescriptions for s chool employees included antibiotics ; steroids pills, eye drops, and inhalers; and painful anti
- allergy shots
. 12

 Neighbors were harmed as well . One n eighbor was reduced to 20 percent lung function
. 13

 Recess was canceled repeatedly
. 14 T eachers were unable to work
. 15

 The state inspector gave the owner clean
- burning pamphlets including “EPA Hydronic Heaters Best Burning Practices.” 16

 According to the affidavit from the s tate inspector: “ It appeared from his description that he was operating them correctly. ” 17

 Thes e two Phase 2 heaters, even when apparently operated correctly , caused severe injuries to nearby residents and to teachers and children at the school.
 The smoke continued to 2013 until the state of Alaska took the owner to court. Judge Robert Downes found that the operation of the two boilers had “proven to be a public nuisance ” and , without a hearing, ordered burning to cease
. 18

 I witnessed and endured the ordeal of smoke inside and outside the school
. After burning ceased, the air in the playground and sch ool was clean
.  In regards to certifying Phase 2, we are not aware that EPA has considered public records regarding these two Phase 2 heaters in Fairbanks, Alaska.
 EPA’s 2012 study tested this make and model and found it has a low, 30 percent average therma l efficiency. 19 , 20

 Yet, EPA has hidden this vital information needed to assess Phase 2 heaters at the same time as EPA is recommend ing certification of these devices. 21 Having the data in hand, I can finally understand why these two hydronic heaters produced such vast amounts of smoke.
 EPA has also misled purchasers. EPA’s 2012 study compares the 30 percent efficiency of the tested model with the 75 percent “ nameplate efficienc y” (also called “rated efficiency”). 22 EPA verified that manufacturers were promoting efficiency numbers with little bearing on reality , but has kept the public in the dark
.NSPS residential wood heaters and Phase 2 , Fairbanks Presentations 2013
- 9
- 30 , page 4 of 7

 Based on the record of harm from two EPA Phase 2 Central Boiler E

- Classic 2300 heaters and EPA’s intentional concealment of relevant test data in federal rulemaking , O MB must reject EPA’s New Source Performance Standards proposal to certify Phase 2 heaters. 

### Sylvia Schultz

 I am Sylvia Schultz. For 22 years, I lived in Fairbanks. My husband was a 33
- year resident.
 Phase 2 heaters are not cheap to buy or install
. If wood is purchased, savings are n egligible over the cost of fuel oil.
 EPA’s proposal to certify Phase 2 ignores the true costs as well as the dangers of these devices
.  OMB must reject EPA’s improper, misleading proposal to certify Phase 2 heaters
. 23 Costs to the Owner – for Two Phase 2 Hydronic Heaters ( Central Boiler E - Classic 2300 ) :
 Over $ 23, 000 to purchase two Phase 2 heater s . 24 Costs of i nstallation not included
.  $ 8,500 per year for split firewoo d. The o wner reports burning 14 cords in one heater and 20 cords i n the other
. 25 The price of firewood is conservatively estimated at $250/cord
. 26

 $600 for t aller chimneys . A pprox . $100 per 4

- foot section , 27 3 sections each , 2009
.  Conventional oil
- fired boilers were installed when the properties were constructed in 2005, ma king th e Phase 2 heaters redundant systems . 28

 T he owner agreed to pay the state $12,000 per the court settlement agreement. 29 Externalized Costs – for Healthcare and Attempts to M itigate:
 $96,000 for at least three sinus surger ies , $32,000 each
. 30 , 31

 $160,000 for allergy treatment shots . F our years at $40,000/yr
. 32

 Over $100,000 paid by state health insurance to treat my husband, no preexisting conditions, for persistent atrial fibrillation ; diagnosed January 2012 after exposure to smoke from these heaters. 33 O ur copay was $4,000
.  $67,500 for installation of an air f iltration system in the school
. 34

 Neighbors installed HEPA air filtration systems, approx. $1,000 each ; filters $50/each ; filters replaced every three months
. 35

 $19,200 for two pairs of retrofit afterbur ner catalysts (ClearStak CS

- 100), $4,800 each
. 36

 $20,000 to be paid to the owner for removing the heaters , $10,000 each
. 37NSPS residential wood heaters and Phase 2 , Fairbanks Presentations 2013
- 9
- 30 , page 5 of 7

 Significant costs of agency monitoring, enforcement, and prosecution
.  In July 2012, we m oved with our two young children to Washington S tate where outdoor boilers are prohibited
. Our Fairbanks home of 26 years sold for $170,000 less than our Washington ho me . Moving expenses were significant.
 For comparison, we paid $4,000 per year to heat our 2,800 square foot home using fuel oil , typical for a similar, properly insulated home in Fairbanks
. Conclusions:
 Ex haustive, costly efforts to mitigate were unable to “fix” these two Phase 2 heaters
.  The substantial harm to public health from misuse of hydronic heaters 38 is avoided by continuous
- feed w ood pellet models. “ I f it fits, it burns” has led some in Fairbanks to heat with garbage, creosote
- treated poles, manure, carpet, and tires. Dr. Jim Conner , the Borough’s air quality program director has said, “ You would not believe what they burn. ” 39

 C onsi dering all costs , Phase 2 boilers may easily be the most costly heating system you can buy
.  Phase 2 heaters , such as the Central Boiler E
- Classic 2300, may benefit their owners, but this benefit fails to offset the significant cost s of healthcare and mitig ation
.  EPA must take a closer look at the true costs of approving a certified wood heater standard for hydronic heaters, especially the cost to public health.

1 2009/1/10 FNSB photo
. 2 2009
- 1
- 10 FNSB data
. 3 2009
- 1
- 10 FNSB notes
. 4 FNSB map Woodriver bulls
- eye 2011
- 01
- 24
. 5 Alaska v. Straughn affidavits, pp 7

- 8, 14
. 6 FNSB 190 Woodriver area AQ complaints 2008
- 2013
. 7 Alaska v. Straughn a ffidavits, p 25
. 8 ADEC records re AQ in Woodriver neighborhood 2009
- 2010, pp 3 and 19
. 9 Alaska v. Straughn affidavits, p 23
. 10 Alaska v. Straughn affidavits, pp 33

- 34
.NSPS residential wood heaters and Phase 2 , Fairbanks Presentations 2013
- 9
- 30 , page 6 of 7 11 Alaska v. Straughn affidavits, p 27
. 12 Alaska v. Straughn a ffidavits, pp 2 7, 30, 34, 35, 37
. 13 Alaska v. Straughn a ffidavits, p 52
. 14 Alaska v. Straughn affidavits, pp 22, 46
. 15 FNSB 190 Woodriver area AQ complaints 2008
- 2013, pp 1, 8
. 16 ADEC records re AQ in Woodriver neighborhood 2009
- 2010, p 7
. 17 Alaska v. Straughn affidavits , p 11 . 18 Preliminary injunction Straughn 2013
- 2
- 4 . 19 Brian Gullett, Gil Wood, et al, June 2012, Environmental, Energy Market, and Health Characterization of Wood

Fired Hydronic Heater Technologies, Report 12
- 15, Executive Summary, US EPA, Office of Resear ch and Development and Office of Air Quality Planning and Standards for NYSERDA, p 32
. 20 Sukh Sidhu, Brian Gullett, et al, March 2011, Toxic Air Emissions from Burning Wood and Agricultural Plastics
– A Cone Calorimeter Study, Great Lakes Commission webinar presentation, p 17.
21 CAF Recommendation Opposing Hydronic Heater Standard NSPS 2013
- 9
- 28
. 22 Brian Gullett, Gil Wood, et al, June 2012, Environmental, Energy Market, and Health Characterization of Wood

Fired Hydronic Heater Technologies, Report 12
- 15, Exec utive Summary, US EPA, Office of Research and Development and Office of Air Quality Planning and Standards for NYSERDA, p 28.
23 CAF Recommendation Opposing Hydronic Heater Standard NSPS 2013
- 9
- 28
. 24 Straughn receipt two Central Boiler 2300s 2008
- 4
- 30
. 25 St raughn FNSB application with color photos 2013
- 6
- 7 . 26 CAF Firewood Prices 2013
. 27 Alaska Resource Agency Leg Request 2011, p 13
. 28 Email Seth Beausang, Alaska AG Office 2013

- 7
- 29
. 29 Alaska v Straughn Settlement 2013
- 7
- 22, p 4
. 30 Woodriver Elementary area A Q complaints 2008
- 2013, p 18
. 31 Alaska v. Straughn a ffidavits, p 27
. 32 Alaska v. Straughn a ffidavits, p 30
. 33 Alaska v. Straughn a ffidavits, pp 61

- 63
.NSPS residential wood heaters and Phase 2 , Fairbanks Presentations 2013
- 9
- 30 , page 7 of 7 34 Alaska v. Straughn a ffidavits, p 16
. 35 Alaska v. Straughn a ffidavits, p 57 . 36 Alaska Resource Agency 20 12
- 3
- 29, p 1
. 37 Straughn FNSB acceptance OHH replacement 2013
- 7
- 18
. 38 Sukh Sidhu, Brian Gullett, et al, March 2011, Toxic Air Emissions from Burning Wood and Agricultural Plastics
– A Cone Calorimeter Study, Great Lakes Commission webinar presentation, p 17.
39 Murphy, LA Times Fairbanks area chokes on wood stove pollution 2013
- 2
- 16 , p 2.