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NSPS Review  Revision Subpart AAA Residential Wood Heaters & Additional NSPS . WESTAR Meeting November 17-19, 2009. Primary Goals for Today. Present EPA’s preliminary thoughts Hear Individual Stakeholders’ Interests Concerns Recommendations Receive Data Today Near future.

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nsps review revision subpart aaa residential wood heaters additional nsps

NSPS ReviewRevisionSubpart AAAResidential Wood Heaters& Additional NSPS

WESTAR Meeting

November 17-19, 2009

primary goals for today
Primary Goals for Today
  • Present EPA’s preliminary thoughts
  • Hear Individual Stakeholders’
    • Interests
    • Concerns
    • Recommendations
  • Receive Data
    • Today
    • Near future
background
Background
  • Originally promulgated February 26, 1988
  • Proposal was first regulatory negotiation by EPA
  • Not been reviewed until now
  • December 2004, CAAAC requested review
  • EPA response was that we wanted to focus on wood stove change-outs that would obtain larger emission reductions versus tightening the wood stove NSPS to the Washington State emission levels that were already being achieved by over 85% of the new wood stoves [sales-weighted]
request for regulation of owb
Request for regulation of OWB
  • August 11, 2005 petition from 6 northeastern states plus Michigan and NESCAUM requesting EPA to develop an NSPS for OWB or revise the current wood stove NSPS to include OWB
    • We developed voluntary program and provided technical and financial support for NESCAUM model rule… Phase 1 rolled out January 29, 2007
    • 22 partners, 12 qualified models [70% reduction]
  • September 27, 2007 letter from HPBA OWHH Caucus expressing “unanimous support for EPA establishment of an NSPS for OWHH”
wood stove nsps review request
Wood Stove NSPS Review Request
  • April 29, 2008 WESTAR/NESCAUM joint letter to EPA requesting:
    • “review and revision of the current residential wood heater/ indoor wood stove NSPS to capture the broader suite of RWD (residential wood heating devices)”
    • “fireplaces, masonry heaters, pellet stoves, and indoor and outdoor wood boilers, furnaces, and heaters… we urge EPA to develop standards…”
  • October 15, 2008 signed Phase 2 Hydronic Heaters agreement
    • We tightened qualifying level [90% overall reduction], expanded to indoor units, other solid biomass
    • 10 Phase 2 models qualified, several in pipeline
  • February 19, 2009 Low-Mass Fireplace Voluntary Program
    • Phase 1 and Phase 2 simultaneously, review within year
  • July 4, 2009 expanded to Masonry Fireplaces
    • 3 models qualified at Phase 2 level [70% reduction], several in pipeline
westar nescaum
WESTAR / NESCAUM
  • WESTAR hosted March 17, 2009 meeting with HPBA [EPA attended to hear positions & concerns]
  • NESCAUM hosted series of webinars in June & July to hear EPA background on NSPS and to discuss individual states’ positions and concerns
  • NESCAUM Directors met on October 28 to fine-tune NESCAUM position; we are awaiting their letter.
  • WESTAR is hosting meeting with EPA, industry, and NESCAUM on November 17-19 to help them develop their potential recommendations for NSPS revisions
hpba recommendations our draft responses
HPBA Recommendations & Our Draft Responses

HPBA presented their recommendations to us on June 16, 2009…

We presented our draft responses to HPBA on September 24, 2009…

draft review document staff draft preliminary conclusions
Draft Review Document & Staff Draft Preliminary Conclusions
  • Draft Review Document prepared by EC/R
  • Staff Draft Preliminary Conclusions prepared by Gil Wood
  • Drafts released on November 4
key conclusions
Key conclusions
  • BDT has improved and emission limits should be tightened
  • Will close “loopholes”, eliminate exemptions [e.g., cook stoves]
  • Will add pellet stoves explicitly
  • Will add wood boilers [hydronic heaters] and furnaces
  • Will revise test methods as appropriate
  • Will streamline certification process & incorporate ISO process and compliance affirmation
  • Will improve compliance assurance & enforceability
  • Will regulate fireplaces
  • Will consider regulating other solid biomass devices, e.g., corn, switchgrass
  • Will consider regulating coal
we have not yet recommended specific emissions limits because we are still waiting for data
We have not yet recommended specific emissions limits because we are still waiting for data…
  • HPBA provided the Houck review of 1988 burn rate frequency data on 9/25/09.
  • Still waiting for HPBA to complete their review of emissions per burn rate for certified stoves and exempt pellet stoves [§114?].
  • Still waiting on HPBA market and economic data
  • Still waiting for Austrian Biomass Research Center to complete their review of advanced combustion technology performance in Europe
  • Still waiting for Catalytic Hearth Coalition to complete their review of catalytic performance versus time
  • Still waiting for ORD to complete test reports for their tests of hydronic heaters, including advanced European designs
we hpba are actively reviewing test methods
We & HPBA are actively reviewing test methods…
  • Mike Toney [AQAD] & HPBA are participating on numerous ASTM work groups
  • HPBA is participating on revision of Canadian method B415.1
  • NYSERDA is reviewing European test methods
  • Continuing concern of “real world” versus lab tests, cribs, etc.
  • Continuing discussions on emissions averaging [burn rate weightings], low burn rate, number of runs, time for hot start, caps, degradation, etc.
  • Efficiency test methods
  • Some states cannot participate because of ASTM’s intellectual property policy… [ASTM “ownership” rather than states or individuals]
scope applicability definitions
Scope & Applicability Definitions

Our goal is to be more inclusive…

  • Size
  • Air-fuel ratios
  • Weight
  • Eliminate exemptions (cook stoves, coal, boilers, furnaces)
pollutants
Pollutants

We expect regulation to focus on fine particles but we want to review available data for all pollutants…[to help further understanding]

  • PM2.5 [>85% of the PM]
  • Benzo(a)Pyrene?
  • Dioxin?
  • Mercury?
  • Black Carbon, CO, CO2, CH4, N2O?
health effects
Health effects

Although NSPS are BDT-based, we will note relevant information on health effects, such as:

  • EPA human exposure study [Chapel Hill lab]
  • Tony Ward indoor exposure study
  • ORIA indoor air specifications for wood smoke
  • Environmental justice considerations
  • Review/revision of PM 2.5 NAAQS [due 2011]
compliance enforcement aspects
Compliance & Enforcement Aspects

We intend to:

  • Streamline certification process--- develop electronic system for submittals and approvals
  • Improve compliance assurance --- inspections of labs and manufacturers, random audits, monitor websites and trade show, alert foreign companies
  • Make consumer-friendly --- website, spreadsheet of current certifications ranked by emissions, tested efficiency, output
  • Incentivize lab proficiency testing
  • Streamline recordkeeping and reporting of manufacturing tolerances and quality control
other devices
Other devices

Our goal is to eventually have NSPS[s] that include:

  • Other Room Heating Devices
    • Pellet stoves
    • Masonry Heaters
    • Other biomass (corn, switchgrass)
    • Low-mass fireplaces, masonry fireplaces
  • Other Residential Wood Heating Devices
    • Outdoor Hydronic Heaters
    • Indoor Hydronic Heaters
    • Furnaces
  • Cook stoves, pizza ovens, chimineas?
  • Coal?
nsps timeline
NSPS Timeline
  • Draft Review Document publicly available – November 4
  • Staff Draft Preliminary Recommendations -- November 4
  • NSPS Revision Proposal - September 2010
  • Revision Promulgation - September 2011
  • Many parties have noted that schedule is extremely tight, especially considering SBREFA Panel, EJ, GHG/Climate
contact
Contact:

Gil Wood

wood.gil@epa.gov

(919) 541-5272

appendix
Appendix
  • More detailed slides…
hpba recommendations our draft responses20
HPBA Recommendations & Our Draft Responses

HPBA presented their recommendations to us on June 16, 2009…

The next several slides are our draft responses to each recommendation…

We presented our draft responses to HPBA on September 24, 2009…

Some potential changes/updates underlined…

listed source category affected facility definitions
Listed Source Category & Affected Facility Definitions
  • HPBA Positions:
    • [1] all heaters should be included
    • [2] fireplaces are not heaters and should not be included (unless listing is changed)
    • [3] definitions need to be revisited? (air-fuel ratio? minimum burn rate? other design features? safety listing?)
  • EPA Draft Responses:
    • [1] yes
    • [2] will prepare new listing, pending resources
    • [3] yes, goal is to be as inclusive as possible, pending resources & schedule
format of standards
Format of Standards
  • HPBA Positions:
    • [1] “no one size fits all”
    • [2] wood heaters & pellet heaters
      • g/hr
      • separate efficiency rating with no passing grade
  • [3] central heating systems
    • g/MJ
  • EPA Draft Positions:
    • [1] TBD
    • [2] g/hr plus caps; efficiency standard depends on Congress’s GHG goals
    • [3] probably; plus g/hr cap?
test methods hpba positions
Test Methods (HPBA Positions)
  • [1] use consensus test methods when available
    • ASTM Methods
      • E2515 – particulate measurement
      • E2558 – fireplaces
      • E2618 – hydronic heaters
      • E06.54.01 task group efforts on wood heaters and pellet heaters
  • [2] consider adjusting burn rates to percentages
  • [3] adjust burn rate upward to help ensure more robust performance in “real world”
  • [4] increase “5-minute” start-up time
  • [5] efficiency testing should be required for all heaters for which emission testing is required
test methods epa draft positions
Test Methods (EPA Draft Positions)
  • [1] mostly yes
      • E2515 – particulate measurement [yes]
      • E2558 – fireplaces [yes]
      • E2618 – hydronic heaters [yes, except will still be cribs] [may use cribs for limit & cordwood for info]
      • E06.54.01 task group efforts on wood heaters and pellet heaters [TBD] [seems to be going well]
  • [2] probably
  • [3] maybe, States doubt that is “real world”, Houck paper supports increase
  • [4] maybe, States doubt that is “real world”
  • [5] yes

Note: we see need for durability testing & VE testing

bdt hpba positions
BDT (HPBA Positions)
  • [1] needs to be rigorously determined based on available data
  • [2] no one size fits all
  • [3] design standards should be considered for some product types:
    • pellet heaters
    • masonry heaters
    • cookstoves
    • coal-only heaters
  • [4] use data for Method 5G without correction factor
  • [5] passing grade must include compliance margin
  • [6] separate passing grades for catalytic and noncatalytic?
  • [7] no passing grade for efficiency
bdt epa draft positions
BDT (EPA Draft Positions)
  • [1] of course
  • [2] mostly
  • [3]
    • pellet heaters [no]
    • masonry heaters [TBD, consider economic impacts]
    • cookstoves [TBD, consider economic impacts]
    • coal-only heaters [no]
  • [4] probably [yes]
  • [5] of course
  • [6] TBD, concern about durability and maintenance by operator. Note: we also have concerns on noncats
  • [7] TBD, depends on Congress’s GHG goals/policy
certification procedures lab accreditation hpba positions
Certification Procedures & Lab Accreditation (HPBA Positions)
  • [1] A representative sample is tested at a nationally accredited 3rd party lab
  • [2] ASTM, CSA, or other consensus-based standards are used when available
  • [3] Certification by nationally accredited certifying bodies [ISO Guide 65]
  • [4] EPA provides “oversight only”
certification procedures lab accreditation epa draft positions
Certification Procedures & Lab Accreditation (EPA Draft Positions)
  • [1] Yes
  • [2] Mostly, see earlier slide on test methods
  • [3] Yes, plus…
  • [4] No to that wording. EPA cannot relinquish authority. Also, EPA must receive manufacturer’s affirmation (similar to Title V compliance certification) that the manufacturer is in compliance with all requirements and cannot disavow responsibility due to 3rd party errors
compliance dates
Compliance Dates
  • HPBA Positions:
    • [1] Phasing is necessary
      • [a] Must consider development, testing certification, and manufacturing lead times
  • EPA Draft Positions:
    • [1] Phasing is expected
      • [a] Of course
      • Note that ample notice of intent has been given already for most product types and others will have ample notice via Reg Agenda and FR proposal
      • Note Washington State compliance date of 1998
      • Note voluntary program dates and NESCAUM model rule dates
      • Expect Washington State levels and Voluntary Program Phase 2 levels immediately upon NSPS promulgation
      • Expect tighter levels at reasonable times thereafter (may differ per product type)
labeling and consumer information
Labeling and Consumer Information
  • HPBA Position:
    • no major changes except addition of efficiency value
  • EPA Draft Position:
    • agree with addition of efficiency
    • will make other changes to hang tag to make it more consumer-friendly
    • will require more consumer education info in owners manual to emphasize BurnWise
regulate fireplaces now not later
Regulate Fireplaces now, not later
  • Will need a new source category listing [low hurdle]
  • WESTAR & NESCAUM want NSPS now, not later
  • HPBA strongly opposed to “now” versus waiting till next review
  • NSPS potential PM2.5 emission reduction in 5th year of >11,800 tons per year
contact32
Contact:

Gil Wood

wood.gil@epa.gov

(919) 541-5272