EPA Report on Residential Wood Heaters (Wood Stoves, Hydronic Heaters and Forced-Air Furnaces) WESTAR Fall Meeting September 19, 2018
Overview • Regulatory Activities o 1988 and 2015 NSPS Rulemakings o 2018 Notice of Proposed Rulemaking o 2018 Advance Notice of Proposed Rulemaking • Cordwood Test Method Development o ASTM o Integrated Duty Cycle • EPA Assistance to States 2
Air Agency Concerns Wood smoke is a major contributor to areas exceeding or close to exceeding NAAQS for fine particles (PM 2.5 measured over 24 hour period): • Fairbanks, AK • Greater Salt Lake, UT area • West Silver Valley, ID • Plumas County, CA State/local air agencies (and EPA) regularly receive nuisance complaints from citizens concerned about excessive smoke from neighbor’s wood - burning devices. In absence of an effective national standard, individual state actions will result in a regulatory patchwork – tighter, disparate emission standards and burn bans. 3
1988 and 2015 NSPS • The original New Source Performance Standards (NSPS), issued in 1988, covered only new adjustable burn-rate woodstoves and fireplace inserts. • The 2015 NSPS, published on March 16, 2015 • Regulates new residential wood heaters • Covers adjustable and single burn-rate woodstoves, pellet stoves, hydronic heaters, forced air furnaces, and fireplace inserts • Does NOT regulate existing heating devices currently in use, masonry heaters, fireplaces, pizza ovens, barbecues, chimeneas, fire pits, or heaters fueled solely by oil, gas, coal 4
Overview of 2015 NSPS Because 90% of wood heater manufacturers are small businesses, a number of accommodations in the 2015 final rule included: • Phased compliance approach: Step 1 in May 2015 and Step 2 in May 2020 • 8-month sell-through period for existing non-Step 1 compliant appliances • Automatic Step 1 certification: • for the 85% of wood heaters previously certified under the 1988 NSPS • for 70 hydronic heater models qualified under EPA’s Voluntary Program, plus an additional 20 models approved under New York hydronic heater programs • for forced-air furnaces that have test reports that are independently certified (not self-tested) 5
2015 NSPS Health Benefits and Costs • Reduces emissions of about 8,300 tons of fine particles • Reduces emissions of about 9,300 tons of VOCs • Reduces emissions of about 46,100 tons of CO • Benefits of $3.4 billion to $7.6 billion annually at 3% discount rate and $ 2013 ◦ Range reflects number of avoided deaths estimated using two long-term cohort studies (Krewski et al. 2009 and Lepeule et al. 2012); unable to monetize benefits from VOC and CO reductions • Costs of $46 million annually (in $2013) • $74 to $165 in health benefits for every dollar spent • Benefits and costs are an average of annual impacts between 2015 and 2020 inclusive. • Benefits and costs reflect implementation of both Steps 1 and 2, with Step 2 implementation dominating the impacts by 2020 6
Ongoing Engagement • Implementation of 2015 NSPS ◦ Appliances compliant with Step 2 emission limits as of Spring 2018: ◦ Wood & pellet stoves – 77 models ◦ Hydronic heaters – 9 models ◦ Forced-air furnaces – 1 model, plus another currently being reviewed by EPA ◦ Encouraging States to take delegation of rule ◦ Developing Electronic Reporting Tool (ERT) and cordwood test method ◦ Supporting wood stove change-out programs and Burn Wise education program • Non-Rulemaking Changes ◦ Collaborating with masonry heater industry to collect preliminary data ◦ Cordwood test method development is ongoing, but industry can request it as an alternative test method now. Cordwood methods for HHs and FAFs were allowed in the 2015 NSPS. ◦ ERT should be available in 2019 7
Plan for Revising the Woodheater NSPS • Summer/Fall 2018 • Propose changes to 2015 rule via a Notice of Proposed Rulemaking (NPRM), proposing a 2-year sell-through provision and soliciting comment on pellet fuel requirements • Currently under OMB review (accepted August 3) • Solicit ideas about other issues via an Advanced Notice of Proposed Rulemaking (ANPRM). These other issues may include Step 2 compliance date, emission limits, and audit testing. • Currently under OMB review (accepted August 10) • Fall/Winter 2018: Publish final rule regarding sell-through and pellet fuel requirements and a proposal on other issues based on responses to ANPRM. • Mid-2019: Issue a Final Rule addressing the Step 2 compliance date, emissions limits, audit testing, and/or other issues, as appropriate. • Next several years: work with stakeholders to develop a cordwood test method and fueling protocol, collect sufficient test data with this method/protocol, revisit BSER, and if necessary, revise NSPS. 8
Development of Cordwood Test Method • Test Methods in 2015 Rule AAA QQQQ QQQQ Woodstoves Hydronic Heaters Forced Air Furnaces PM Method ASTM E2515 (crib) Operating Protocol EPA 28 R (crib) No Thermal Storage CSA 415.1-10 EPA 28 WHH, ASTM E2618 ASTM E3053 (cord) - Partial Thermal Storage approved alternative EPA 28 WHH-PTS, ASTM E2618 Annex 1 Full Thermal Storage ASTM E2618 Annex 2 • Cordwood Test Method Collaborative Process (Fall 2015 – Spring 2018) ◦ NESCAUM/WESTAR will facilitate the process, EPA will participate in an advisory role and communicate EPA information requirements ◦ Steering Committee and Technical Workgroups (PM Measurement and Fueling/operational Protocols) ◦ EPA Discussion Paper: “Process for Developing Improved Cordwood Test Methods for Wood Heaters” (March 2016) • Status • Recently met with HPBA to discuss ASTM E3053 and Integrated Duty Cycle – see https://www.regulations.gov/docket?D=EPA-HQ-OAR-2016-0130. • Upcoming state meetings • Will also be soliciting stakeholder input via ANPRM 9
EPA Assistance to States • Voluntary Programs • Burnwise • PM Advance • Grant Programs • Targeted Airshed Grants • Community-Scale Air Toxics Monitoring Grants 10
What Burn Wise Materials are Available? Posters Brochures Tear Pads Tip Sheet Wood Shed Construction Plans Videos Note: free hard copies are currently available for most tools 11
Partnerships Examples: Washington State’s Northwest Clean Air Agency “Learn Before You Burn” Poster Alaska Department of Environmental Conservation: “Burn Wise, Breathe Easy” Makah Tribe’s Modular Wood Shed Design Retailers and Chimney Sweeps 12
Washington - NW Clean Air Agency: “Learn Before You Burn” Poster modified to include local air quality district’s logo 13
Alaska DEC: Burn Wise, Breathe Easy 14
Build a Firewood Storage Shed – Adapted from the Makah Tribe’s Modular Wood Shed Design 15
Targeted Airshed Grants • Competitive grant program for state/local/tribal air agencies authorized by Congress under appropriations in 2010 and 2015-2018. • 2010: $10M • 2015: $10M • 2016: $20M • 2017: $30M • 2018: $40M • 2019: $55M (House markup) • Area must be one of the five most polluted areas for ozone, PM2.5- annual, or PM2.5-daily • Wood stove changeouts received about $26M – San Joaquin Valley, CA; Portola, CA; Salt Lake City, UT; Logan, UT; Provo, UT; West Silver Valley, ID; Fairbanks, AK 16
Appendix 17
2015 NSPS – Summary of Standards Wood-Fired Heating Device Step Effective Date Particulate Matter Emission Test Fuel *after F.R. Notice Standard Wood stoves & Pellet Stoves Cribwood 60 days (both adjustable and single 1 4.5 grams/hour (g/hr) or (May 15, 2015) Cordwood burn rate) (both catalytic & non-catalytic) 2.0 g/hr Cribwood 5 years 2 (May 15, 2020) 2.5 g/hr Cordwood Hydronic Heaters - all wood 0.32 pounds (lbs)/million British Thermal Units (Mbtu) weighted fuels Cribwood 60 days average AND 1 or (May 15, 2015) 18.0 g/hr individual test run cap Cordwood OR EPA “Phase 2” Qualified 0.10 lbs/MBtu for each burn rate Cribwood 5 years 2 (May 15,2020) 0.15 lbs/MBtu for each burn rate Cordwood Forced Air Furnaces – all New work practice and operational wood fuels 60 days standards, including providing N/A (May 15, 2015) information on best operating practices in owner’s manuals Small: 1 year (May 16, 2016) 1 0.93 lbs/MBtu weighted average Cordwood Large: 2 years (May 15, 2017) 2 All: 5 years (May 15, 2020) 0.15 lbs/MBtu for each burn rate Cordwood 18
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