Homemakers know all about spring cleaning – time to sweep out the cobwebs and give lie to the statement that dust is just a country accent. “Clean” is a different animal for wood burners. All wood-fueled systems should be cleaned out regularly, both to ensure efficient operation and to keep the air clean. And the government goes beyond that.
With the Environmental Protection Agency’s (EPA) final ruling of the new source performance standards (NSPS) for residential wood heaters, the job has become doubly difficult. The EPA’s ruling regulates the emissions allowances for wood stoves, pellet stoves, hydronic heaters and forced air furnaces. The first round of NSPS went into effect on May 15, 2015. Phase 2 looms over stove makers with a 2020 deadline.
The NSPS finalized amendments to the 1988 Standards of Performance for New Residential Wood Heaters (40 CFR part 60, subpart AAA). A petition to reconsider the action was rejected in October 2016.
The EPA implemented a two-step compliance regimen. Some felt there would be little problem for most manufacturers to comply with the first step. Under the ruling, the EPA said manufacturers were to be given added time for R&D and the testing. Testing would comply with both with the U.S. standard and Canada’s Standard CSA B415.1-10 test for large wood furnaces. But most industry sources believe the Phase 2 regulations and the 2020 deadline are a nightmare.
“The cost incurred by the consumer is going to be outrageous,” said Lisa Johnson, purchasing agent for Alpha American Company, maker of Yukon Furnaces, Palisade, Minnesota. She said that paying the cost for added R&D will extend the time it takes for a farmer to see a return on investment. On top of that, choices will be limited.
Note that the updated standards apply only to new wood heaters and will not affect wood heaters already in use in homes or farms. The Wood Stove Organization estimated that, with an EPA-certified wood stove, a farmer can expect to use up to one-third less firewood than when using an older, less efficient stove.
The smoke one sees coming out of the chimney is really lost energy. In an EPA-certified stove, most of the smoke is burned, resulting in more heat for the building from the same amount of wood. It also saves time because users need to haul less wood.
“I’ve talked to a lot of people in the industry. We all feel that [the] EPA would like hot air furnaces and boilers to disappear,” said Daryl Lamppa, Lamppa Manufacturing, Tower, Minnesota. “Otherwise, why drop the standard by 84 percent by 2020?”
Indeed, the burn requirement drops from 0.93 pounds per million BTUs today to 0.15 pounds per million BTUs in four years. “[The] EPA is right about needing clean air. I’m in favor of regulations to burn clean,” Daryl Lamppa said. “But they went overboard.”
Daryl and his son Garrett produce the Lamppa line, which was started by Daryl’s dad, Herbert. A math teacher, Herbert was a numbers guy and foresaw the need to meet standards. Their design on the Vapor Fire 100 already has passed the 2020 standards, but Daryl frets about the hurdles they had to cross.
“There was so much involved,” he said. He figures they invested about $100,000 to get that single stove approved. The smaller Vapor Fire 200 is still pending approval. “Only one model – and look at the money I’ve spent.”
Daryl started testing for NSPS in 2009. They passed the 2020 test at all four burn levels (high, low and two in between).
Hardy Heater, located in Philadelphia, Mississippi, is working to get a unit that will meet the Step 2 2020 standards. TJ Madison, distributor for Hardy, agreed that it is an expensive proposition. “You have to pay about $25,000 for the four tests,” he said.
Turn back the clock?
There is near-unanimous agreement among vendors that more time is needed to meet Phase 2. Madison has hope that the industry will get some relief from the new administration in Washington, D.C. “At this point, it is in litigation,” he said of the 2020 NSPS. “I think we are making some progress with the new administration.”
The Hearth, Patio and Barbecue Association (HPBA) based in Arlington, Virginia, has the leadership role in the move to challenge the 2020 standards. Meanwhile, operations in states like New York and Pennsylvania have regulations requiring stove companies to meet standards equal to the basic EPA rules but still must meet the 2020 thresholds.
HPBA said it supports reasonable standards for wood appliances to burn more efficiently. The EPA updated its NSPS in February 2015. Since then, HPBA has led the hearth industry in attempts to negotiate change to the Step 2 standards.
HPBA supports the “Relief from New Source Performance Standards Act of 2017,” part of House of Representatives bill HR-453. HR-453 would extend the effective date of EPA’s Step 2 regulation for new biomass-fueled stoves and central heaters from May 15, 2020, to May 15, 2023. The association notes that, while much of the Step 1 requirements that were effective as of May 15, 2015, were achievable, there are outstanding issues with Step 2 of the rule.
HPBA argues that an extra three years would provide enough time for everyone in the industry to have equal opportunity and access to test labs, skilled lab engineers and to develop the future of clean wood heating.
“This isn’t a matter of manufacturers not wanting to comply with the rule,” HPBA said. They object to the lack of time and capacity to complete this effort industry-wide within the time allotted by the EPA. Additional time also provides market stability for manufacturers and retailers alike who are concerned with which products may or may not be sold after the Step 2 effective date, the trade group said.
Lots of stoves out there
“There are well over 50,000 Yukon multi-fuel furnaces installed and in use in the U.S. and Canada, Johnson said. Its website promised that they would take “considerable measures in R&D to account for replacement of the Yukon Husky and Polar furnaces to retrofit seamlessly now and in the future.” It turns out the EPA regulations simply do not afford enough time to do the job correctly.
Johnson, who has 40 years of experience, fears that all manufacturing, advertising, selling and shipping of Yukon Furnaces will be halted.
“Forced-air manufacturers, in general, got two years to get into compliance, add technology and change the flow rates,” Johnson said. That may have been doable, but there was almost no time left to check the new designs for safety. Unlike the one-week test run in the lab, Johnson knows that farmers use their furnaces for months at a time, year after year.
Yukon Furnaces have a UL stamp certification. However, with the required modifications to the fire box, they were unable to get the consistency to do the same thing in the lab as in the field to obtain the EPA’s approval.
Cleaning A Boiler
An annual cleaning of a wood boiler should be part of any maintenance program. “It’s pretty simple,” said Dale Furman of Econoburn.
The first step is to remove the outer jacket and insulation. “You don’t have to remove the whole jacket — just the rear left and right plates,” Furman explained. There are several 9/16 bolts around the stack plate and that opens the unit up.
Of course, it is vital to establish exactly where the controller wires run. Keep in mind that they run loose on top of the insulation and must not be cut.
Use care when taking off the top plate. First, be sure the fiberglass gasket is not attached and is not coming along with it. The back plate is a bit easier since it has no gasket. Feel free to grab-and-go here.
Once the plates are off, Furman recommends a 2-inch brush for cleaning. With a two-stage gasifier, there should be no creosote in the system, only fly ash. “The secondary chamber reignites the material,” Furman said. That ensures a complete burn.
“I do mine every year,” Furman said. It is both an important and a big job for a farmer who is doing it for the first time. However, once you’ve gone through the process a couple of times, it’s pretty straightforward. Furman can clean his boiler in 15 minutes.
“Remember, everything stays cleaner the hotter you burn,” he said. As for any job that promises to be dusty, dress for success. That means having a light breathing mask handy when it comes time to remove fly ash.
If you burned well-seasoned wood through the cold season, there should be no creosote in the tubes. At this point, the job involves a simple brushing out of the loose ash buildup. Replace those bolts and you are good to go for another season.
The EPA’s take
The EPA acknowledged that the industry is comprised of more than 90 percent small businesses. The agency said that was a concern and it took steps to minimize impacts as much as possible while still achieving emission reductions. Part of that process was setting phased emission limit standards.
In moving to revise NSPS, the EPA said residential wood smoke can contribute to unhealthy levels of particulate matter in many neighborhoods nationwide, including in minority and low-income neighborhoods, and can impact people in their homes.
“To the extent that children and other sensitive populations are particularly susceptible to asthma and that minority populations and low-income populations are more vulnerable to the effects of air pollution, this rule will significantly reduce the pollutants that adversely affect their health,” EPA standards noted.
The EPA said populations that are 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. “Each year, smoke from wood heaters produces hundreds of thousands of tons of fine particles throughout the country – mostly during the winter months,” according to the EPA. The health benefits of the new regulations, the EPA said, “are substantially greater than the cost to manufacture cleaner, lower-emitting appliances.” They put the cost-benefit ratio at over 100 times the cost.
Nationally, the EPA said residential wood combustion accounts for 44 percent of total stationary and mobile polycyclic organic matter (POM) emissions, which account for nearly 25 percent of all area source air toxic cancer risks and 15 percent of non-cancer respiratory effects.
“If you burn hot and hard, there is little or no residual material,” said Dale Furman, plant manager at Econoburn, which makes boilers, not hot air furnaces. As such, they easily met the compliance deadline of January 1, 2015.
Still, he recommends an annual cleaning of the boilers (see sidebar).
But if everyone were running wood pellets, the standards might be met. Of course, pellets are dried to the 10 percent range where even dry woodlot cordwood typically contains much more moisture – in the 20 percent to 28 percent range even if considered “dry.”
Then there are the isolated cases where a person tampers with the emissions system. The EPA is concerned about stoves with catalytic converters. Converters need maintenance and can plug up. Sometimes, users bypass the converter. “Then, it becomes like an old-fashioned barrel stove,” Lamppa said.
Madison stated that current law requires a manufacturer to void the warranty on any stove that is modified and creates more pollution.
“Not only does it void the warranty but it is illegal,” Madison warned.
Lamppa said it is easier for boilers to pass the EPA standards since they can store heat. “With hot air, you can’t store heat unless you have some sort of magic,” he said.
Lamppa agreed that not all stoves are models of environmental purity. Some produce as much as 30 grams of emissions per hour – versus less than a gram for his. Note that the standard is based on the 0.93 pounds per million BTUs and not on the number of grams from the whole burn. However it is measured, a visit to towns like Fairbanks, Alaska – where smoke hovers over the landscape much of the winter – underscores the EPA’s concerns.
What may happen later
As it stands today, the second, stricter phase of the EPA regulations for hot air furnaces will go into effect in 2020. Those regulations will present yet another hurdle to the many small manufacturers of wood burners.
“We are a small company,” Johnson said. She points out that most of their customers are rural or farm people. “Those regulations are a huge burden on us and any other small company,” she said.
Industry sources estimate the new, higher-priced replacement models to cost at least 20 percent more than those that have been sold in the past.
The EPA, however, feels it has economics on its side. “On an economic basis, the public benefits of this rule vastly outweigh the costs, with every dollar in additional cost producing more than $100 in public benefit,” according to EPA analysts.
The EPA’s action does not include any requirements for heaters solely fired by gas, oil or coal. Note that it does not include any new requirements associated with appliances that are already in use – so a farm’s existing wood burner is grandfathered in. However, the EPA said it will continue to strongly encourage “state, local, tribal, industry and consumer efforts to change out or replace older heaters with newer, cleaner, more efficient heaters.
Others in the business suggest to move the deadline to a later year. Not only will it give manufacturers time to do the R&D to design more efficient stoves, but it would give the labs time to schedule the requisite performance testing.
Farmers in the market for a new stove should keep in mind that EPA-certified wood stoves will have a label or model plate indicating EPA certification.
Certified stoves are available from distributors or at many stores ranging from Tractor Supply, Northern Tool, L&M Fleet and Rural King to big-box stores like Home Depot and Lowe’s.