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EPA updating wood-burning stove standards

MARYLAND—The Environmental Protection Agency is updating its emission standards for wood-burning stoves with stricter manufacturing guidelines, which industry representatives say are too aggressive and  with un-vetted testing methods they said could result in an unnecessary decrease in products.
On Jan. 3 EPA Administrator, Gina McCarthy, signed a proposal to update air emissions standards for wood-burning stoves that have not been modified since 1988, according to Gregg Achman, vice president of product engineering and standards for Minnesota-based Hearth & Home Technologies Inc., which makes stoves that are sold and used here on the Lower Eastern Shore. Where they are the primary source of heat—low-income households or homes located “off the grid” in remote locations—there are few other options, industry proponents have argued.
He said the stove manufacturing industry is not opposing the overall goal of the proposed rules and wants to work with EPA officials. But regional industry groups are preparing responses to the proposed regulations to meet a May 5 deadline for submitting comments from the public because they are hoping to find a comprise position that will meet both the EPA’s standards objectives and industry’s realistic production feasibility goals.
According to Achman, wood-burning stoves would be the product most impacted if the proposed rule is implemented. A specific concern for manufacturers is the EPA’s requirement that crib wood be used for emissions testing purposes. They would prefer testing be conducted using cord wood instead, because it would better reflect the conditions of actual use.
According to the proposed rule, “‘Crib wood’ is a specified configuration and quality of dimensional lumber and spacers, which was intended to improve the repeatability of the test method in 1988. ‘Cord wood’ is a different specified configuration and quality of wood that more closely resembles what a typical homeowner would use.”
The last time the rules were updated was in 1988. With the new proposal, the EPA wants manufacturers to participate in a two-phased certification program that would test one sample heater in each model line, rather than requiring that each individual heater in the line be tested. “If the representative heater meets the applicable emission limits, the entire model line may be certified and the manufacturer would not be required to test every heater,” according to the proposal, although individual heaters within the model line would still be subject to labeling and other operational requirements.  Moreover, the EPA would continue to have the authority to conduct audits to ensure compliance, it said.
The proposed rule would phase in the new standards under a two-step procedure, which officials suggested would allow manufacturers lead time to develop, test, field evaluate and certify current technologies across their consumer product lines.
During the first phase, manufacturers would be required to conduct two separate smoke emissions tests, one burning crib wood and one with cord wood samples. While the results of both tests would need to be reported to the EPA, manufacturers would have the option of choosing which method to certify their products with, officials said. Five years later, according to the proposal, during the second phase manufacturers would be required to show compliance under cord wood tests and add filters to their products during the tests to gather data on the amount of emissions released during startup and anticipated peaks.
New compliance requirements during the second phase would also establish emissions limits at the lowest and the highest of four categories of burn rates, a shift from the current practice of using a weighted average of the four burn rate categories. There would also be a labeling requirement, the preamble to the rule said.
Manufacturers would not be the only entities affected by the proposed changes, according to officials. Laboratories that test wood heaters would be subject to quality assurance requirements; and burn practices that currently apply to how owners or operators use the appliances would continue. “In addition, new pellet heater/stove owners and operators would be required to use only the grade of licensed pellet fuels that are included in the heater/stove certification tests, or better,” it said.
Albeit significantly fewer Americans are heating their homes with wood-burning stoves and fireplaces these days, but the manufacturers of such appliances are still watching closely to see if the EPA will actually tighten air emissions standards that have existed for nearly two decades.
In the proposal, EPA officials said the updates would not apply to wood stoves that are already in use or for heaters that are solely fired by gas, oil or coal. But officials do want to reduce emissions limits for new residential wood heaters and other wood-burning appliances, and to eliminate certain exemptions that have remained in place for a broad suite of residential wood stoves.
EPA officials said the reason is because smoke from residential wood stoves contains fine particles and toxic air pollutants, like benzene and formaldehyde, and the hundreds of thousands of tons of fine particles the stoves release—mostly during the winter months—can cause immediate negative health effects, including burning eyes, runny nose and bronchitis. “Exposure to fine particles has been associated with a range of health effects, including aggravation of heart or respiratory problems (as indicated by increased hospital admissions and emergency department visits), changes in lung function and increased respiratory symptoms, as well as premature death,” a preamble of the proposed rule said.
In a number of communities, pollution from residential wood smoke either exceeds the EPA’s health-based national ambient air quality standards for fine particles or is on the cusp of exceeding those standards, according to the proposal. “Populations at greater risk for experiencing health effects related to fine particle exposures include older adults, children and individuals with pre-existing heart or lung disease,” it added.
But for manufacturers and retailers of the stoves, the proposed rule would apply a one-size-fits-all emissions restriction on all products nationwide. Doing so would encompass areas where smoke would be trapped over populations by geographic characteristics, such as the bowl-like landscapes in Libby, Mont. or Denver, Colo., but also areas with conditions that would easily disperse released smoke fumes, like the wind conditions generated on the Eastern Shore.
Susan Turner, manager of Survival Products in Salisbury, said during a Feb. 3 interview that only a small percentage of the population burns wood as their primary heating fuel source. She also said that modern wood stoves were already operating with an 80 percent efficiency rate.
The EPA’s proposal, she said, would call for adding new features, such as baffles to deflect the flow of smoke and manifolds to trap fumes, so the stoves will hold the heat generated within the firebox longer before the smoke is released. The idea for increasing the internal burning is to try to contain the fumes until “most of what is going up the chimney is water and carbon dioxide,” she explained.
However, according to Turner, for a wood stove to operate properly it needs a draft, to create the temperature differential that allows the exhaust fumes to move. A certain amount of air flow inefficiency is necessary to allow that to happen, she indicated. To make it completely draft-free would be like covering a candle with a metal lid, without the draft, the fire inside the stove will extinguish.
Turner said of the stoves her store sells, 50 percent are pellet-burning stoves, with the other half of sales evenly split between gas-burning stoves and wood-burning stoves.
Aware of the EPA proposal, Turner said agency officials want manufacturers to design stoves with a combustion zone (fire box) that will burn at a higher level of efficiency than they currently do, in order to meet a more restrictive air quality minimum standard. If it goes forward, and there is no guarantee that it will, she said the wood stove industry could be facing at a very “expensive battle.”
Calls for comment to the EPA analyst in charge of the air emissions standards for wood-burning stoves were not returned.