### Appendix A. Andrea Wieland - E-mails with Gil Wood, EPA, about Phase 2 Hydronic Heater

Smoke. March-April 2012

From: Gil Wood [mailto:Wood.Gil@epamail.epa.gov]

Sent: Monday, April 30, 2012 10:51 AM

To: Andrea Wieland Subject: RE: Question about smoke from neighbor's OWB [Andr ea Wieland, Spring Valley, Wisconsin - 3/5/12, 3/21/12, 4/3/12, 4/15/12, 4/29/12]

**Hello Ms. Wieland,**

**As I indicated in my email to you on April 9, I do not know the answer.** 

**Also, I have contracted the Wisconsin DNR and EPA's Region 5 office and the manufacturer and they all**  **are aware of your question but no one knows the ans wer at this time for that particular OWB.** 

**Gil**

**"Andrea Wieland" ---04/29/2012 10:57:26 PM---Hello Mr. Wood –** 

**From: "Andrea Wieland"** 

**To: Gil Wood/RTP/USEPA/US@EPA** 

**Date: 04/29/2012 10:57 PM**  **Subject: RE: Question about smoke from neighbor's OWB [Andre**  **a Wieland, Spring Valley, Wisconsin - 4/3/12]**

Hello Mr. Wood –

I haven’t yet heard back from you since I responded to your e-mail on April 15. I’d like to confirm th at you received

this e-mail.

Please let me know if you need more information to respond to my initial question about why a Phase II -qualified OWB would smoke, as shown in the attached photos.

Thank you very much for your time and consideration

.

Andrea Wieland Pierce County Wisconsin svrosesbirds@gmail.com

715-778-4481

From: Andrea Wieland [mailto:svrosesbirds@gmail.com ]

Sent: Sunday, April 15, 2012 7:14 PM

To: 'Gil Wood'

Cc: 'Amanda Aldridge'; 'Chebryll Edwards'; 'Debbie Sta ckhouse'; 'Gregory Green'; 'Pat Finch'; 'Joseph.Hoch@wisconsin.gov'; 'Bart.Sponseller@wisco nsin.gov'; 'Bruce.Rodger@wisconsin.gov';'thomas.woletz@wisconsin.gov'; 'robert.thiboldeaux@ dhs.wisconsin.gov'

Subject: RE: Question about smoke from neighbor's OWB [Andr ea Wieland, Spring Valley, Wisconsin - 4/3/12]

Mr . Wood –

Thank for your response to my e-mail and for the su ggestions that you provided.

As is common for people like myself who are exposed to OWB smoke for many years, I have done all of th e suggestions that you listed, plus many more for the past seven years in the ongoing struggle to protec t my health from the hazards of breathing OWB smoke on my prope rty and in my home.

Here is a basic summary to respond to your question s. 1. I have discussed the ongoing OWB problem with bo th the Wisconsin Department of Natural Resources (WI DNR), the Wisconsin Department of Health (WI DH S), my county (Pierce) and my township (Gilman). 2. The WI DHS did air monitoring on my property and found that the PM2.5 exceeded the NAAQS for multiple contiguous days, which correlated with atm ospheric/climatic conditions for wind direction and inversions. WI DHS was prepared to declare a human health hazard but requested more air monitoring from the WI DNR, which was denied. 3. The WI DHS and Central Boiler have visited my ne ighbors to review the OWB installation and operatio n and to provide best burn practices information for reducing the smoke. This included burning only dry, seasoned wood and raising the stack above the roofl ine (the stack was never raised above the roofline) . I am not certain if the dealer was present during the site visit or if my neighbor has consulted with or complained to the dealer. I don't know of any stack emission tests of the unit. 4. There are no nearby OWBs that contribute additio nal smoke. I see the smoke coming from the Phase II EPA qualified OWB and then smell the smoke on my pr operty and in my home.

Here are details to provide information for the abo ve responses to help answer your questions:

In 2006 after two neighbors installed OWBs (Central Boiler HF60 and Central Boiler CL6048) that produc ed smoke that impacted my property and home, I contacted bot h the Wisconsin Department of Natural Resources (WI DNR), and the Wisconsin Department of Health (WI DHS) for assistance. The WI DHS worked with my county (Pier ce) and monitored the air at my home for two weeks in Novem ber 2006. The results are attached and show that th e PM2.5 exceeded the allowable NAAQS levels for multi ple contiguous days. At that time, there were no ot her OWBs nearby and the high levels directly correlated with wind and atmospheric conditions that directed smok e toward my property, including inversions. Note that the WI DHS incorrectly guessed the distance from the OWB to my property line at 1,000 feet. But, the closest OWB i s 250-feet from my property line.

I requested help at many of my county's Health Comm ittee meetings and asked WI DHS staff to give a pre sentation on OWB health impacts. WI DHS encouraged my county to adopt a model ordinance for OWBs, but it lacked political support among county board members. The W I DHS advised my county to declare a health hazard at my home due to the OWB smoke. But on March 7, 2007, th e county attorney, Lynn Lahti, decided not to pursu e legal action because of concern for "not being able to me et the burden of proof required to successfully lit igate this

matter."

In March 2007, I contacted the WI DNR for assistanc e (Tom Woletz, Eau Claire Regional Air Administrato r). Mr.

Woletz told me that OWBs violate numerous air rules and it is easy to find an OWB in violation of the visible

emission law. He sent me a NOV for an OWB that viola ted WI visible emission law in 2001. But now the DN R doesn't have the resources to enforce these laws ag ainst OWBs due to litigation time and expense. On M arch 27, 2007, Mr. Woletz wrote this summary of the problem: "We are not unsympathetic to your problems and it is difficult to answer your request by a simple statem ent that it’s a matter of setting priorities with l imited resources; however, that’s the reality of it.” And on April 24 , 2007, Mr. Woletz wrote: “...the initial readings do cumenting avisible emission violation would be the least time consuming effort for us. Visible emission readings o nly take a half

hour or so. It's the follow up meetings, putting to gether the enforcement package, staff review, and l awyer and prosecuting attorney time that are really our main concern as far as resources.”

Mr. Woletz also sent letters on March 27, 2007, to my two neighbors advising them of a neighbor’s comp laint about their smoke and providing guidance on best bu rn practices.

In October 2007, WI DHS requested air monitoring eq uipment from the WI DNR to do additional monitoring of outdoor wood-fired boiler emissions at my home. Bil l Otto of WI DHS wrote, "We have a site in Pierce C ounty where we really could use a PM2.5 monitor for acqui ring air data. We would need it for about 2 weeks. We are working towards declaring a human health hazard for a resident affected by emissions from an OWB. It s eems pretty obvious that the home is impacted by OWB emi ssions but we really need to shore up our air monit oring

data."

On November 2007, WI DNR (Bruce Roger) responded to WI DHS stating that they didn't have any spare mon itors to loan to WI DHS (email attached). Neither WI DHS or WI DNR shared this information with me until I s ent an open records request. I continued asking WI DHS for assistance to reduce the hazardous smoke exposure and to protect my health.

On December 12, 2007, a WI DHS e-mail from Mr. Otto to his staff stated that air monitoring "is not th e strongest part of the case" in determining a health hazard fr om an OWB. He wrote, "in order of importance, I'd s uggest reports of irritant/respiratory symptoms of the com plainants, location of the OWB relative to the reco mmendation of the HPBA, and visible smoke plume all would be g ood evidence of potential for a human health hazard being present."

On May 15, 2008, WI DHS visited the property of one neighbor with the closest OWB to observe the OWB i n use and provide suggestions for reducing smoke. Also in attendance were the second neighbors with an OWB, the Gilman Township Chair, and two representatives from Central Boiler: Rodney Tollefson and David McDonal d. During this site visit, both neighbors said that th ey followed best-burn practices and used only seaso ned, dried wood. Because my neighbors are approximately 25-fee t lower in elevation than my home, we are typically directly in the smoke plume. Central Boiler and WI DHS sugge sted that my neighbors raise their stack to above t heir roof line. This change never occurred.

WI DHS incorrectly guessed the distance of the OWB from my property line in their follow-up letter as 1,000 feet.

The distance is 250-feet. Please note that DHS used this erroneous distance as an excuse in its letter for not enforcing existing public health laws against nuisa nce smoke and denying me equal protection under the law. WI DHS also said they would follow up with my neighbor s, but when I inquired about the dates of the follo w-up, WI DHS said they did not follow-up with my neighbors t o ensure that the smoke hazard had been mitigated. And they never did a surveyed distance of the OWB to my prop erty line. Under false information (unverified, fal se distance), they denied me protection of my health under state law, but gave this protection to at least seven oth er individuals impacted by OWBs during the same time ( found through open records request).

In September 2008, the WI DHS issued the following guidance to County Health officials about OWBs: "Th e Wisconsin Department of Health Services (DHFS) has accumulated historical air monitoring data for smok e particulates (PM2.5) related to OWB emissions. In e ach case, when a visible smoke plume impacts on a neighboring house/property, US Environmental Protec tion Agency (EPA) PM 2.5 health standards have been exceeded. Strong smoke odors along with the visible plume indicate the presence of a variety of irrita ting chemicals normally found in wood smoke. Typically, there are one or more individuals experiencing adve rse health effects, i.e., respiratory irritation, sinus issues , headaches, etc. DHFS believes that a "cause and e ffect" relationship

has been established between OWB emissions and adve rse health effects for downwind neighbors, and that air monitoring is not essential to establish exposure a nd health impact. If there are visible emissions and odors at a neighboring residence(s), there is a completed expo sure pathway and the potential for adverse health e ffects ."I wrote letters and called all my elected state and federal representatives repeatedly and asked them to require

that EPA update the wood stove New Source Performan ce Standards (NSPS) and regulate OWBs, as requested by numerous state attorneys general in 2005. I asked m y representatives to support state regulation of OW Bs. To date, no regulations exist at the state or federal level. The political will does not exist to regulat e residential

sources of wood smoke.

After being denied protection under existing public health and environmental laws by my local, state a nd federal government, I had no choice but to attempt civil li tigation against my neighbors. My neighbor's receiv ed technical assistance from Central Boiler and their litigation costs were paid by their insurance companies, in s pite of a pollution exclusion clause in one policy. I paid fo r the litigation costs myself. After two years, we were outspent by the insurance companies and forced to settle in Jan uary 2010, and agreed to allow my neighbors to inst all EPA qualified Phase II OWBs under the condition that th e neighbors install and operate the OWBs according to

manufacturer's instructions. This includes followin g EPA Burn Wise guidance and Wisconsin laws for OWB installation (under Commerce Department law).

I agreed to this settlement because I could no long er afford continued litigation and I had to trust that EPA had done its job and had solid science on emission test ing and manufacturing design controls, to ensure th at the Phase II qualified OWBs sanctioned through the EPA OWHH Vo luntary Program truly would be 90% efficient (as EP A continues to claim) and not smoke.

However, that is not the case. One neighbor install ed a Central Boiler E-Classic 2400 OWB that produce s as much visible and choking smoke as the previous nonqualif ied Central Boiler CL6048 model. I see the smoke an d smell it on my property regularly. I continue to be adversel y impacted by the acrid smoke. As the WI DHS 2008 O WB guidance to health professionals advises, " If there are visible emissions and odors at a neigh boring residence(s), there is a completed exposure pathway and the poten tial for adverse health effects ."

As noted previously, I am higher in elevation than my neighbors, so I am directly in the visible smoke plume generated by the Phase II OWB. As shown in the phot os below, the plume rises about 20 feet and spreads out. In addition, we are in a valley, with hills on three s ides of the OWB (south, west and east) that funnels the smoke plume directly onto our property and into our home.

We are located northwest of the OWB. Smoke emitted from this OWB stays in a low-hanging plume as shown in the photos below. Because we are in a higher elevat ion than the OWB, we are in that plume.

Central Boiler warns owners of its Phase II Qualifi ed OWBs that terrain can cause nuisance conditions. This language shows that Central Boiler knows that even when properly operated, their Phase II Qualified OW Bs will

smoke and cause a nuisance condition.

Here is the warning/disclaimer language on the firs t page of Central Boiler’s owner’s manual for the E -Classic 2400: “Improper use or failure to maintain the hydronic h eater may cause nuisance conditions. The person(s) operating a hydronic heater is/are responsible for operation in a manner that does not create a public or private nuisance condition. Meeting the distance and stack height recommendatio ns from the manufacturer and requirements in applicable State a nd local regulations may not always be adequate to prevent nuisance conditions in some areas due to terrain or other factors.”

Below are photos of smoke from the new EPA Qualified Phase II Central Boiler E-Classic 2400 OWB . Note that this unit regularly smokes for two or more continuous ho urs each morning, then on and off all day, and agai n for a long period in the evening after being fueled for the ni ght:For comparison purposes, here is a picture of smoke from the previous Central Boiler CL6048 nonqualifi ed OWB.

As you can see, there isn't any visible different i n opacity or volume between the two units. And the choking, acrid

smell is the same from both units:

As stated earlier, I see the smoke coming from my n eighbor's Phase II qualified OWB and I smell it whe n the wind is from the southeast or during calm conditions. Th ere are no other nearby OWBs that blow or drift smo ke onto my property during those same conditions or duratio ns. From my two years of experience with breathing Phase II EPA qualified OWB smoke, I agree with the WI DHS st atement that, " If there are visible emissions and odors at a neighboring residence(s), there is a completed expo sure pathway and the potential for adverse health e ffects ."

Mr. Wood, this e-mail correspondence started with a basic question in response to your statement in th e February

NSPS Webinar that Phase II OWBs would not smoke.

Now that you have the information requested, I woul d appreciate your answer to my question as to why t his Phase II OWB smokes and why it smokes continuously for hours.

And please explain why Central Boiler would include the disclaimer in the owner’s manual that their Ph ase II EPQ qualified OWBs can cause nuisance conditions.Thank you for your time and consideration.

Andrea Wieland Pierce County Wisconsin svrosesbirds@gmail.com

715-778-4481

From: Gil Wood [ mailto:Wood.Gil@epamail.epa.gov ]

Sent: Monday, April 09, 2012 2:41 PM

To: Andrea Wieland

Cc: Amanda Aldridge; Chebryll Edwards; Debbie Stackhou se; Gregory Green; Pat Finch Subject: RE: Question about smoke from neighbor's OWB [Andr ea Wieland, Spring Valley, Wisconsin - 4/3/12]

**Ms. Wieland,**

**I am not aware of any good reason why your neighbor 's E-Classic 2400 should be smoking for 2 hours**  **each morning if your neighbor is actually following the manufacturer's recommendations, including prop**  **er loading of the right quantity of clean dry wood [an**  **d nothing else] for the time of season and proper i gnition**  **procedures. I still wonder if your neighbor is actu ally following the best practices recommendations,**  **despite the court order.**

**I have previously discussed the performance of Cent ral Boiler E-Classic 2400's and 3200's with the**  **manufacturer and they indicated that these models h ave a good track record in the field. They do note**  **that some dealers do a better job than others in in stalling the units properly and ensuring that the o**  **wner understands best practices. Has your neighbor asked**  **the dealer or manufacturer to trouble-shoot this particular unit? The dealers have responsibility to**  **follow-up on owner complaints in the warranty peri od.** 

**Have you discussed this situation with the Wisconsi n Department of Natural Resources? Have they**  **talked to your neighbor? Do they agree that your ne ighbor is using best practices? Have they conducted**  **particulate matter (PM) stack emission tests of the unit itself or conducted ambient air quality monit**  **oring**

**of PM at the fenceline?**

**A thought: Are there any other OWB nearby that may be contributing to the smoke/odor that is coming to**  **you?**

**Gil**

**"Andrea Wieland" ---04/05/2012 05:33:40 PM---Mr. Wo od:** 

**From: "Andrea Wieland" <svrosesbirds@gmail.com**  **> To:**  **Gil Wood/RTP/USEPA/US@EPA**

**Cc: Amanda Aldridge/RTP/USEPA/US@EPA, Chebryll Edwards/**  **RTP/USEPA/US@EPA, Debbie Stackhouse/RTP/USEPA/US@EP A,**  **Gregory Green/RTP/USEPA/US@EPA, Pat Finch/RTP/USEPA /US@EPA** 

**Date: 04/05/2012 05:33 PM**  **Subject: RE: Question about smoke from neighbor's OWB [Andre**  **a Wieland, Spring Valley, Wisconsin - 4/3/12]**Mr. Wood:

Thanks for your response.

To answer your question, I know that my neighbor fo llows the instructions in the Central Boiler E clas sic 2400

owner’s manual and Burnwise Best Practices because: 1. Our proximity to the OWB and the covered wood pi le allows us to see that the wood is seasoned, stacked, split and protected from rain and snow. Wh en the device is in use, the odor emitted is of str ong wood smoke typical of OWBs (anyone who lives near a n OWB knows this odor very well). 2. My neighbor is required by court order to operat e the OWB according to manufacturer’s instructions.

Central Boiler’s owner’s manual and instructions in clude following EPA’s Burnwise Best Practices, as n oted

on its Web site: http://www.outdoorfurnacefacts.com/wood-corn-heatin g-best-practices/best-burnpractices/index.html

I’m still awaiting your response to my questions ab out why my neighbor’s Phase II qualified OWB smokes for hours after loading, as noted in the attached e-mails.

Thank you.

Andrea Wieland svrosesbirds@gmail.com

715-778-4481

From: Gil Wood [ mailto:Wood.Gil@epamail.epa.gov ]

Sent: Wednesday, April 04, 2012 2:09 PM

To: Andrea Wieland

Cc: Amanda Aldridge; Chebryll Edwards; Debbie Stackhou se; Gregory Green; Pat Finch Subject: RE: Question about smoke from neighbor's OWB [Andr ea Wieland, Spring Valley, Wisconsin - 4/3/12]

**Dear Ms. Wieland,**

**You're welcome.**

**We're curious: How do you know that your neighbor a ctually follows the burnwise best practices and the** 

**owner's manual?**

**Thanks,**

**Gil**

**"Andrea Wieland" ---04/03/2012 05:26:15 PM---Dear M r. Wood –** 

**From: "Andrea Wieland" <svrosesbirds@gmail.com**  **> To:**  **Gil Wood/RTP/USEPA/US@EPA**

**Cc: Chebryll Edwards/RTP/USEPA/US@EPA, Gregory Green/RT**  **P/USEPA/US@EPA, Pat Finch/RTP/USEPA/US@EPA, Amanda Aldridge/RTP/USEPA/US@EPA, Debbie Stackhouse/RTP/US**  **EPA/US@EPA**

**Date: 04/03/2012 05:26 PM**  **Subject: RE: Question about February 9, 2012 EPA Webinar on**  **draft NSPS [Andrea Wieland]**Dear Mr. Wood –

Thank you very much for responding to my e-mails. I appreciate your time and consideration of my reque st and question.

Here is the additional information you requested ab out my neighbor’s Phase II OWB to help you determin e why it produces smoke for more than 2 hours each morning. Please note that it also emits smoke on and off all day after the initial 2-hour contiguous smoke emissions: - Model/Make: Central Boiler E Classic 2400, Phase II Qualified

- Manufactured date: 2010 - Installation Date: September 2010 - Operated according to manufacturer’s instructions detailed in owner’s manual. - Fuel source: hardwood (primarily oak), dried, spl it and stored under shelter (3-sided metal pole bui lding located next to OWB). - Fuel wood loaded in the morning and again in the late evening. - OWB provides heat and hot water to a house and a pole shed. Pole shed is approximately 15 feet from OWB and house is approximately 30 feet from OWB. - Owner follows EPA’s best burn practices, as instr ucted in owner’s manual and on EPA’s Web site (Best Burn).

If you need additional information about this OWB t o determine why it smokes more than you state that it should, please let me know.

Thank you very much for your time and assistance.

Andrea Wieland svrosesbirds@gmail.com

715-778-4481

From: Gil Wood [ mailto:Wood.Gil@epamail.epa.gov ]

Sent: Tuesday, April 03, 2012 2:58 PM

To: Andrea Wieland

Cc: Chebryll Edwards; Gregory Green; Pat Finch; Amanda Aldridge; stackhouse.debbie@epa.gov Subject: Re: Question about February 9, 2012 EPA Webinar on draft NSPS [Andrea Wieland]

**Dear Ms. Wieland,**

**I'm sorry that I was unable to respond directly to you sooner. You do have my correct email address fo**  **r sending me comments and questions and I appreciate**  **your input.**

**Please remember that official comments on the offic ial proposal will need to be sent to the EPA docket**  **office after**

**the official rule proposal in the Federal Register this summer. In the meantime, we will**  **consider all comments and questions but we may not able to send individual acknowledgements or**  **responses to each email... Please do not think that we are ignoring your comments just because we may**  **have not responded to you in individual personalize d emails to each of your emails.** **Also, please do not think that there is a "table" f or negotiations and that you are a not a party. EPA**  **is not negotiating this standard at all but rather we are**  **fully considering all available information and pro posing**  **data-based standards accordingly. From the beginnin g of this effort, we have been inviting and**  **welcoming input not only from "some" states but eve ry state and tribe and community and from all of th**  **e public. The February 9, 2012 webinar was just the m**  **ost recent event...**

**In regard to my thoughts on why there is smoke from your neighbor's unit, I can not answer without** 

**additional information. We have coordinated with th e state authorities to learn what they know and can**  **do and have done. In general, I continue to believe th**  **at Phase 2 qualified OWB that are built, installed, and**  **operated properly should not smoke for 2 hours ever y morning but I do not have details for the particu**  **lar unit near you.** 

**Yes, inclusion in the owner's manual of info on pro per operation is required via the partnership**  **agreement. See pages 45-47.**

**Sincerely yours,**

**Gil Wood**

**"Andrea Wieland" ---04/03/2012 10:01:50 AM---Mr. Fi nch -** 

**From: "Andrea Wieland" <svrosesbirds@gmail.com**  **> To:**  **Pat Finch/RTP/USEPA/US@EPA**

**Cc: Chebryll Edwards/RTP/USEPA/US@EPA, Gregory Green/RT**  **P/USEPA/US@EPA, Gil Wood/RTP/USEPA/US@EPA**

**Date: 04/03/2012 10:01 AM**  **Subject: Question about February 9, 2012 EPA Webinar on draf**  **t NSPS**

Mr. Finch –

I saw that you were the coordinator for the Februar y 9, 2012, EPA Webinar on the draft NSPS for Reside ntial Wood

Heaters.

I’ve sent Gil Wood, the presenter of that Webinar, two e-mails with questions from the seminar present ation and he has not replied. These e-mails are attached. The e-mail address that I’ve sent to was listed in the Webinar presentation ( http://www.epa.gov/burnwise/pdfs/20120209NSPSpresen tation.pdf ).

Mr. Wood also stated that we could send him comment s on the draft NSPS. However, I’m concerned about sending comments to him if there is a problem with his e-mail address or if he is not responding to pu blic questions or comments.

Please let me know if you can assist me in contacti ng Mr. Wood to both ask him questions about the dra ft NSPS

and to send him comments.

The February 9, 2012, Webinar was the only time the public has had a seat at the table to learn and co mment on the draft NSPS. To date, only industry and some sta te government has been allowed to participate in th is important rule revision. But, the public is directl y impacted daily by smoke emitted by unregulated ou tdoor woodboilers (OWB). It could be argued that the economic impact on public health far surpasses the impact o n a handful

of OWB manufacturers and, therefore, would justify a greater public involvement in the rule-making pro cess.

I certainly hope that EPA has not intentionally dec ided to ignore e-mails from the public with questio ns and

comments about the draft NSPS.

Thank you for your assistance.

Andrea Wieland svrosesbirds@gmail.com

715-778-4481 Spring Valley, WI **----- Message from "Andrea Wieland" < svrosesbirds@gmail.com**  **> on Wed, 21 Mar 2012 09:37:45 -0500 -**

**----** 

### To: < wood.gil@epa.gov >

Subject: Question about your NSPS Webinar Presentation

in February

Hi Mr. Wood –

I listened to your February 9, 20120 Webinar presen tation on EPA's Draft Proposed Rule NSPS for New Re sidential Wood Heaters. Thank you for presenting this informa tion to the general public.

During the Webinar you said a few times that a Phas e II qualified OWB should not smoke when operated p roperly according to manufacturer's instructions, except br iefly during initial startup.

My question is if a Phase II qualified OWB produces smoke for longer than the initial 15-minute startu p, is it because it is being improperly operated (not follow ing manufacturer’s instructions)?

I looked through the OWHH voluntary agreement and d idn’t find specific requirements for manufacturers on the definition of proper operations of an OWB that woul d in the user manual?

Thank you for any information or explanation you ca n provide about this question.

Andrea Wieland svrosesbirds@gmail.com

715-778-4481 **----- Message from "Andrea Wieland" < svrosesbirds@gmail.com**  **> on Mon, 5 Mar 2012 22:10:52 -0500 ---**

**--**



### To: < wood.gil@epa.gov >

Subject: Question about Information from your NSPS Webinar

Presentation

Hello Mr. Wood –

Thank you for your February 9, 2012, Webinar presen tation on EPA's Draft Proposed Rule NSPS for New

Residential Wood Heaters. It was interesting and helpful to hear your explana tion of the NSPS highlights and your answers to the questions submitted by Webinar participants.

You had requested that we send you questions and co mments on the draft NSPS. I will be sending mine to yousoon, but have a question about your reference to p roper operation of an Outdoor Wood Boiler (OWB).

During the Webinar you said a few times that a Phas e II qualified OWB should not smoke (except briefly during initial startup) when operated properly according t o manufacturer's instructions.

My question about this reference is from first-hand experience. My neighbor installed a Central Boiler E-Classic 2400 Phase II-qualified OWB. This replaced a non-qu alified OWB. My neighbor follows the manufacturer's instructions and EPA’s Best Burn Practices by burni ng only seasoned, dried hardwood that is stored und er a shelter. But, this EPA-qualified Phase II OWB produ ces enormous amounts of smoke continuously for two- hours every morning after startup.

Here is my question: Why would this Phase II-qualif ied OWB smoke so much if it is operated according t o manufacturer's instructions and EPA's Best Burn Pra ctices? Is it because he is not operating the OWB a ccording to manufacturer's instructions, or is this particular Phase II-qualified OWB defective in some way?

Here are photos to show the typical smoke produced from this OWB over the last year:As these photos show, this Phase II- qualified OWB produces alot of smoke, which is produced continuou sly for at

least two hours after startup. So, I would apprecia te your opinion about whether or not this Phase II- qualified OWB is being operated according to manufacturer's instr uctions. This is in reference to your statement tha t these devices should not produce smoke when operated prop erly according to manufacturer's instructions.

Thank you for your work in trying to develop cleane r-burning OWBs. And thank you for your time and consideration of my question.

Andrea Wieland svrosesbirds@gmail.com

715-778-4481 Spring Valley, WI