# An O WB Pr ogr am Experience in Linn Coun ty

, Iow a Nov ember 8, 2012

## December 21, 2010 “T he [Wood - fir ed boiler s] came under Linn Coun ty Public Health scrutin y over the pas t year after a handful of neighbor s complained about smoke blowing into their y ar ds .” “Hodina worked for months on an or dinance that would bring the boiler s into compliance without for cing owner s to abandon what was in some cases a $10,000 in ve st men t .” “T he super visor s disr eg ar ded the r ec ommendation and vote d 4 - 1 on Aug. 27 to e xe mpt existing boiler s. The emissions rules would apply to new units, but complaints ag ains t e xis ting ones would be handled case - by - case using nuisance laws.”

# Gr ound Z er o

# Loc al SIP - Appr ov ed Rules **10.5 P ermit R**  **equired Ex** **emptions** Fuel - burning equipment for indir ect hea ting and r e - hea ting furnaces or cooling units using natur al or liquefied petr oleum g as e xc lusiv ely , with a capacity of less than 10 million B TU per hour input per combustion unit. **10.7 Visible Emissions** No person shall allow

, cause, or permit the emission of visible air contaminants of a density or shade equal to or darker than that designated 20 per cent opacity **10.8 Emissions Fr** **om Fuel**  **- Burning**  **Eq uipmen**  **t** Applies to installations in which fuel is burned for the primary purpose of producing ste am, hot w ater , hot air or other liquids, g ases or solids and in the course of doing so , the products of combus tion do not come into direct contact with pr ocess materials. Fo r heat inputs less than 10 million B TU , 0.6 lb/million B TU shall apply . DS1**Slide 4**

**DS1** I would consider adding LCCO 10.7 [Visible Emissions]. The 20% opacity limit can be very effective in regulating dirty

units if the owners fail to properly operate and maintain the OWB. Dodge, Shane, 11/2/2012

# Appr oach t o Rule Modific at ion

• Understa nd who has O WBs in Linn Coun ty and how they ar e used. • Who is selling O WBs in Linn Coun ty and how ar e they marketing these units. • Es ta blish oper ating conditions fo r e xis ting units to oper ate without violating NAA QS. • Pr opose rules t o:

– Grandfather ex is ting units

– Re quir e new units to meet SIP limit

# Input fr om Iow a DNR **April 22, 2009** “ Or dinances adopted by Linn County that ar e less s tring en t than the applicable s tate sta ndar d will not super sede the applicable s tate sta ndar d unless they ar e incorpor ate d by EP A in to Iowa's SIP

. EP A may incorporate less stringent ordinances into the SIP on a case - by- case basis provided that a demons tration is made that the relaxation in the emission sta ndard will not result in an adverse impact on air quality . The DNR and EP

A ma y both enfor ce the mor e s tring en t state emission s ta ndar d if the less s tring en t s ta ndar d in the Linn Coun ty or dinance is not made feder ally enfor ceable thr ough incorpor ation into the SIP .”

# Modeling Demons tr at ion Es ta blish siting and oper ating co nditions for ex is ting units to oper ate w ithout violating NAA QS c onsidering the following v ariables:

– St ack heigh ts

– Setback dis ta nces

– R esiden tial v ersus agricultur al heat demand

– Seasonal va riability

# Annual Hea t Degr ee Da ys

**Month Heat Degree Day** **s Annual Percentage**  Jan 1341 21% Feb 1269 20% Mar 872 14% Apr 384 6% May 132 2% Jun 0 0% Jul 0 0% Aug 0 0% Sep 44 1% Oct 315 5% Nov 685 11 % Dec 1345 21%

# Modeling Assumptions

• Used PM 2.5 

### backgr ound as Design Value of 28 g/ m 3 

### and 10.2 g/ m 3 

### • In addition to PM 2.5 

### , ev aluated CO , SO 2 

### , and NO 2 

### . • Emission fa ct or for uncertified boiler of 12.2 g/ kg (1.44 lb/MMBtu) of wood burned. • Wo od firing rates based on heat demand wer e calculated in range of 51 to 153 MMBtu/yr

– 15 and 25 cor ds per year fo r agricultur al setting

– 5.0 and 7.5 cor ds per year fo r r esiden tial setting**5 Cords/Y ear**  Oct Nov Dec Jan Feb Mar Apr lb/season 7.44 16.19 31.78 31.69 29.99 20.61 9.07 lb/day 0.2401 0.54 1.03 1.02 1.07 0.66 0.30 lb/hour 0.0100 0.02 0.04 0.04 0.04 0.03 0.01 gm/hr 4.5382 10.20 19.38 19.32 20.24 12.56 5.72 **15 Cords/ Y**

**ear** Oct Nov Dec Jan Feb Mar Apr lb/season 22.33 48.56 95.35 95.07 89.96 61.82 27.22 lb/day 0.720 1.62 3.08 3.07 3.21 1.99 0.91 lb/hour 0.030 0.07 0.13 0.13 0.13 0.08 0.04 gm/hr 13.62 30.59 58.13 57.96 60.72 37.69 17.15 

# Seasonal Va riability of Hea t Demand & PM Emission Ra te s“T he Iowa Department of Natur al R esour ces swooped in and put the br akes on Linn Coun ty ’splans to e xe mpt ex is ting wood fir ed boiler s fr om a new or dinance r egulating the units . If the super visor s e xe mpt the boiler s, Fitzsimmons said, her ag ency would r eview Linn Coun ty ’sair quality division and perhaps withdr aw the state’ s stamp of appr ova l. The super visor s r esponded Monda y by pos tponing the second r eading of the or dinance un til Sept. 9, time enough to decide whether it ’spossible to e xe mpt existing boiler s without losing funding for local air quality.” 

## December 21, 2010

# Final Pr oposal

• All Boilers

– Re gis tration permit fo r e xis ting and new units

– Es ta blished “Nuisance Conditions” fo r all O WBs

– All new boilers mus t meet 0.6 lb / mmBtu fo r PM 2.5 

## • Exis ting Boilers

– Agricultural Use • St ack heigh t of 15ft another re sidence within 500ft • F uel usag e limit re st rict ed to 15 cords/year DS3**Slide 12**

**DS3** The final proposal slides are a little confusing. All units must be registered - new and existing. Also, the set backs, stack

heights and usage limits only apply to existing units that are not Phase 1 compliant. Phase 1 units, regardless of installation date are not subject to 10.8(3). Dodge, Shane, 11/2/2012

# Final Pr oposal (c on tinued)

• Exis ting Boilers (continued)

– Re siden tial Use • Sit ed no closer than 200 ft of the near es t pr operty or • Ha ve a s ta ck heigh t two feet higher than the peak of an y r oof structur e that is located within 300ft. • Fuel usag e limit is re st rict ed to 5 cords annually • Cannot oper ate fr om Ma y 15 to September 15.

# Iow a Atto rney General Following a meeting with the Assis tant Atto rney General, letters were sent out to 21 outdoor wo od boiler manufactur ers who sell their pr oducts in Iowa, which s tated: “O ur primary concerns r elate to the ability of Iow a consumers to lawfully use your compan y's out door w ood boiler pr oducts. As we understa nd it, the cos t to a consumer of an outdoor wo od boiler , on a ve ra ge, is in the ra nge of $10,000 with cos ts of up to $50,000 fo r hea vier users. Ther efore, the consumer's ability to use the pr oduct lawfully is a material fa ct that ma y not be misr epr esented to consumers or concealed from them pursuant to the Iow a Consumer Fr aud Act, Iow a Code section 714.16. The Consumer Fr aud Act is Iow a's civil consumer fr aud law and is enfor ced by this office. In addition, as of July 1, 2009, Iowa consumers now also ha ve priv ate re medies fo r consumer fr aud pursuant to a new law , House File 712.”**To day** 

• LCPH has had significant reduction in complaints. • Some municipalities adopting more stringent requirements than county, wi th bans in residential neighborhoods • Also very few

n ew u nits being registered. • 83 Registered Outdoor Wo od Boilers: • Built and installed 2006 and later • Rated heat input of • 125,000 – 500,000 Btu/hr • Over 20 dif

ferent manufactures each wi th dif ferent models **Linn County** 

**, Iow a** 

# Con ta ct Informa tion

James Hodina En vir onmen ta l Manager Air P ollution Con tr ol Of

ficer Linn Coun ty Public Health 501 13 th 

## Str eet NW Cedar Rapids, Iow a 52404 j ames.hodina@linncoun ty.org 319 - 892 - 6010 www.linncleanair

.org