Alameda Rules
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From: "John Shouldice" Sent: Wednesday, April 23, 2008 Subject: Wood Burning Fireplace Cc: "Steve Forster" Mr. Buckley: My name is John Shouldice and I'm a plan checker with Alameda County Bldg. Inspection Dept (Bay Area, California). Mr. Steve Forster (project architect) has submitted a building permit application to install a Rumford Masonry Fireplace and he has submitted the attached documentation/information. I have also attached a copy of our present county ordinance for wood burning fireplaces and such exempts fireplace that emit no more than 7.5 g/hr. particulate. The information submitted by Mr. Forster indicates that the Rumford Fireplace meets this requirement and that such has been tested by Omni Environmental Services. We would appreciate if you could review the attached documentation from Mr. Forster and confirm that the fireplace indicated is, in fact, the model that is indicated in the attached Omni report. In addition, we would appreciate if you could provide us with an e-mail address and tel # for Mr. Paul Tiegs (Omni Representative). We would appreciate hearing from you at your earliest convenience. You will note that I have copied Mr. Forster with this correspondence. Sincerely:
John Shouldice
802.5.5.5 Wood-burning Appliances [CDA]. {Added} A wood-burning appliance installed in a building or structure shall be an approved wood-burning appliance as defined in this section.
1. Existing buildings undergoing remodel or renovation when the total cumulative costs of the planned work and of all improvements over the 5 years prior to the application date is estimated by the building official to be less than $50,000. 2. Existing wood-burning appliances being reconstructed, repaired, or modified when the cost of the said work is estimated by the building official to be less than $4000. 3. Historical buildings or structures, as defined in CBC. 4. Gas-only fireplaces that do not burn wood are exempt from the provisions of this Section. Gas fireplaces that are converted to burn wood are not exempt from the provisions of this Section.
2. Any wood heater that meets the standards in Title 40, Part 60, Subpart AAA, Code of Federal Regulations as in effect at the time of heater installation and that is certified and labeled pursuant to those regulations. 3. A wood heater insert meeting the same standards as in 2. above. 4. A permanently-installed masonry or factory-built fireplace, as defined in Section 3102 of the CBC, that is designed to be used with an air-to-fuel ratio greater than or equal to 35 to 1 and that has been certified by a testing laboratory, approved (certified) by the Environment Protection Agency (EPA), as emitting no more than 7.5 grams particulate per hour when tested using an EPA-approved protocol.
Note: We hope that in a few months after the ASTM E2558 Standard has been recognized by EPA that last line in #4 will read: "... 5.1 grams particulate per kilogram of fuel burned when tested using the EPA-approved ASTM E2558 protocol." - Jim Buckley
From: "Paul Tiegs"
Mr. Shouldice,
As you have requested, I've attached a copy of OMNI's U.S. EPA accreditation certificate. We have been accredited for performing wood heater emissions testing by EPA since 1986, and the States of Oregon, Washington, and Colorado since 1984. We are also accredited/approved by the California Air Resources Board for performing source emissions testing since about 1988.
OMNI measured the emissions from the 30-, 36-, and 48-inch Buckley Rumford fireplaces with all of the results at less than the U.S. EPA woodstove limit of 7.5 grams per hour (40CFR60 SubPart AAA): the 30-inch produced 4.8 g/hour, the 36-inch produced 6.0 g/hour, and the 48-inch produced 3.2 g/hour when tested to the Washington State fireplace emissions testing protocols (Washington Administrative Code CHAPTER 51-50). The Washington State protocols were and still are the only appropriate protocols in effect at the time the Buckley Rumford fireplaces were tested. When the Washington State protocols went into effect, they were considered equivalent to the stringency of EPAÕs wood heater regulation.
The EPA wood heater protocols (40CFR60 Appendix A Method 28) are not appropriate and were never intended to be appropriate for testing fireplaces. The primary problem with trying to use EPAÕs Method 28 is that it requires 4 separate test runs be performed each at a different burn rate including one at a burn rate of less than 1 kg/hour. Besides having to have a fireplace on a scale to measure the fuel consumption rate, it is virtually impossible for any and all fireplaces to burn wood at less than 1 kg/hour.
Let me know if you need any additional information,
Paul Tiegs
OMNI-Test Laboratories, Inc.
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Fireplace Emissions
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