NSPS - REVIEW

1. NSPS - REVIEW WESTAR-EPA-HPBA MEETING November 17 -19, 2009

2. LISTED SOURCE CATEGORY • “Residential Wood Heaters” listed in 1988 [CAA §111(b)(1)(A)] • Covered: • Wood Stoves and Pellet Stoves • Other Heating Devices • Hydronic Heaters, Furnaces, Masonry Heaters • Excluded: • Fireplaces

3. Affected Facilities Definition • Solid Fuel Heaters that meet the following criteria: • An air-to-fuel ratio averaging < 35-to-1, • A usable firebox volume < 20 cubic feet, • A minimum burn rate < 5 kg/hour, and; • A maximum weight < 800 kg (appliance only). 

4. Included: • Wood Stoves & Fireplace Inserts • Pellet Stoves and Inserts if: • Air-to-fuel ratio <35:1 • Factory-Built Fireplaces if: • Air-to-fuel ratio <35:1 and, • minimum burn rate < 5 kg/hour

5. Exempted: • Furnaces • Boilers & Hydronic Heaters • Cookstoves meeting specific requirements • Open Site-Built Masonry Fireplaces • Masonry Heaters • Coal-Only Heaters • Pellet Stoves and Inserts if: • Air-to-fuel ratio >35:1 • Factory-Built Fireplaces if: • Air-to-fuel ratio >35:1 or, • minimum burn rate > 5 kg/hour

6. HPBA POSITION • ALL HEATERS SHOULD BE INCLUDED • FIREPLACES ARE NOT HEATERS AND SHOULD NOT BE INCLUDED • Fireplaces would first have to be listed as an additional source category under CAA Section 111(b). • Would require a finding that new fireplaces "cause of contribute significantly to air pollution that may reasonably be anticipated to endanger public health and welfare" • Low frequency of use, low contribution to ambient levels, adequacy of current control measures (e.g., bans, voluntary program) for impacted areas, and the fact that efforts to develop cost reasonable fireplace controls are in their infancy all argue against listing.

7. HEATING DEVICES VS. NON-HEATING DEVICES • Does the line distinguishing heaters from non-heaters need to be reconsidered? • Air Fuel Ratio? • Minimum Burn Rate? • Other Design Features? • Safety Listing?

8. Format of Standards • Grams per Hour (g/hr) • Used in the current NSPS • Grams per Kilogram (g/kg) • Grams per Megajoule (g/MJ)

9. HPBA POSITIONS ON FORMAT • NO “ONE SIZE FITS ALL” • WOOD HEATERS AND PELLET HEATERS: • G/HR • SEPARATE EFFICIENCY RATING – NO PASSING GRADE FOR EFFICIENCY • CENTRAL HEATING SYSTEMS: • G/MJ

10. Test Methods • How to operate the appliance? • How the measurements are made? • How is the data used to rank performance? • Weighting Factors? • Current NSPS • Operation • EPA Methods 28 and 28A • Emission Measurement • EPA Methods 5G and 5H

11. HPBA POSITIONS ON TEST METHODS • USE CONSENSUS TEST METHODS WHEN AVAILABLE • ASTM Methods • E2515 – Particulate Measurement • E2618 – Hydronic Heaters • CSA B415.1 - Efficiency • E06.54.01 Task Group has been activated to address other solid-fuel fired appliances • Two Working Groups • Wood Heaters • Pellet Heaters

12. CONSIDER ADJUSTING THE BURN RATE CATEGORIES FROM FIXED KG/HR RANGES TO PERCENTAGES OF THE MAXIMUM BURN RATE. • ADJUST THE MINIMUM BURN RATE RANGE UPWARD SOMEWHAT TO CORRECT FOR FLAW IN CURRENT NSPS. • INCREASE THE “5-MINUTE” START-UP TIME IN THE FUELING AND OPERATING TEST METHOD. • EFFICIENCY TESTING SHOULD BE REQUIRED FOR ALL HEATERS FOR WHICH EMISSION TESTING IS REQUIRED.

13. Determination of BDT • HPBA POSITIONS ON BDT: • BDT NEEDS TO BE RIGOROUSLY DETERMINED BASED ON AVAILABLE DATA. • NO “ONE SIZE FITS ALL”. • DESIGN STANDARDS SHOULD BE CONSIDERED FOR SOME PRODUCT TYPES: • Pellet Heaters • Masonry Heaters • Cookstoves • Coal-Only Heaters

14. BDT is used to set the passing grade • THE PASSING GRADE SHOULD BE BASED ON BDT USING THE METHOD 5G/ASTM E2515 DATA WITHOUT A “CORRECTION FACTOR”. • THE PASSING GRADE MUST INCLUDE A COMPLIANCE MARGIN TO ACCOUNT FOR VARIABILITY IN THE TEST METHODS. • SEPARATE PASSING GRADES FOR CATALYTIC AND NON-CAT TECHNOLOGIES? • NO PASSING GRADE FOR EFFICIENCY.

15. Certification Procedures and Laboratory Accreditation • The current NSPS: • Model Line Certification • A representative sample is tested at an EPA accredited laboratory using EPA test methods. • The model line is certified upon approval of certification application and issuance of certificate of compliance by EPA. • Manufacturers must conduct on-going QA/QC program with random EPA audits/oversight.

16. Current NSPS QA/QC • Manufacturers perform regular “k-list” parameter inspections and maintain records. • Emission audit tests required based on model line production quantities and proximity to passing grade. • Random Compliance Audits (RCA) • RCA surcharge added to certification test costs to fund program. • Selective Enforcement Audits (SEA)

17. HPBA POSITION • A REPRESENTATIVE SAMPLE IS TESTED AT A NATIONALLY ACCREDITED THIRD PARTY LABORATORY. • ASTM, CSA OR OTHER CONSENSUS-BASED TEST METHODS ARE USED WHEN AVAILABLE. • CERTIFICATION BY NATIONALLY ACCREDITED THIRD PARTY PRODUCT CERTIFICATION AGENCIES/BODIES ISO • Guide 65 Third Party Product Certification • EPA PROVIDES AN OVERSIGHT ROLE ONLY.

18. Third Party Certification QA/QC • Periodic UNANNOUNCED inspections (for example, at manufacturer or importer facilities). • Verification that products being “Marked” as certified comply with design, process and QA requirements. • Documentation of results and reporting of any deficiencies or deviations. • No product modifications allowed without review and verification of compliance with certification requirements. • Certification Body must investigate and determine scope/severity of non-compliance. • Determine appropriate remedial actions. • If warranted, suspension or revocation of authorization to apply certification mark.

19. Compliance Date • Current NSPS • Two tiers of the passing grade • Two tiers of deadlines for Manufacturers • Additional deadlines for Distributor and Retailer Sell Through

20. HPBA POSITION ON COMPLIANCE DATE • COMPLIANCE DATE PHASING NECESSARY • THE COMPLIANCE DATE STRUCTURE MUST CONSIDER DEVELOPMENT, TESTING CERTIFICATION AND MANUFACTURING LEAD TIMES. • New product types will be regulated. • Existing NSPS products may require redesign and recertification. • Safety listings may be impacted.

21. Labeling and Consumer Information • Current NSPS • Permanent Labeling • Information about manufacturer, model and certification status. • Temporary Labeling (Hang Tag) • Contains information targeted at helping the consumer make an informed purchase. • Performance information • Owner’s Manual • Requires information to help the user to achieve the best appliance emission performance.

22. HPBA POSITIONS • NO MAJOR CHANGES IN THE LABEL OR OWNER’S MANUAL CONTENT REQUIREMENTS ARE NEEDED EXCEPT: • Measured efficiency values provided on temporary labeling where efficiency rating is required or available.