Rumford Technical Discussion
Workaround in New York
August 3, 2010
Rumford Fireplace
Attn: Jim Buckley

Dear Jim,

We built a Rumford style fireplace I had designed around the Supeior Clay products. The local Building Dept., Mr. Frank Lisi, required that I install glass doors at the unit. I attempted to explain why that really made little sense.

Mr. Lisi said that he would accept a variance letter from the DOE in Albany. I contacted Joseph Hill who I had heard at an energy seminar. He said that he would be willing to write a variance for that but asked for a letter from Rumford. I saw on your website a similar letter you prepared in the State of Washington.

Is there anything available for New York. I will forward you some of the various communications and photos and details if desired.

Sincerely,
jw

**************

From: Jim Buckley
Sent: Aug 3, 2010
To: jw
Subject: Rumford door Variance

Jeff,

That's great news. And good for the NY regulators - both Messrs. Lisi and Hill. Most building officials stick strictly to the letter of the code.

I will work on a letter for Mr. Hill as you suggest. Let me send you a draft today or tomorrow.

Warm regards,
Jim Buckley

And then (a couple of days late) I did draft such a letter. See letter. Now we are waiting to see if we get the variance. We'll let you know. - Jim

The fireplace was approved without doors and then a week or so later we heard that another customer was able to avoid installing doors on a Rumford just by presenting the my letter. - Jim ********

8/25/13 Now another similar situation with a different inspector - below is my letter.

    Dear Mr. Morehouse,

    Ms. Paplin has forwarded to me your letter (below) requesting documentation concerning our gasketed damper specified for a Rumford fireplace and depicted at http://www.rumford.com/store/dampers.html. I'll do my best.

    We appreciate the implication (by your asking about our gasketed damper) that you would consider a gasketed or tight-fitting damper as an alternative to the NYS 2010 Energy Code on Fireplaces requirement for "tight-fitting noncombustible fireplace doors".

    As you may know, this is a hot topic at the ICC code hearings. At the IRC and IEC Committee hearings in Dallas last April there were several proposals to require either gasketed or tight-fitting doors on fireplaces. There are no gasketed or tight-fitting doors because the manufacturers fear that not letting the radiant heat escape and without adequate cooling ventilation tight fitting fireplace doors would create a fire hazard. So the Hearth Patio and Barbecue Association (HPBA), the Masonry Alliance for Codes and Standards (MACS), the Clay Flue Lining Institute (CFLI) and Underwriters Laboratories (UL) all got together and worked out a compromise with the proponents. The compromise, which still needs to be approved at the ICC Annual Conference in Atlantic City in October, would read ...

      Modification: R402.4.2 (N1102.4.2) Fireplaces. New wood-burning fireplaces shall have tight fitting flue dampers or doors, and outdoor combustion air. When using tight-fitting doors on factory-built UL 127 fireplaces listed and labeled in accordance with UL 127, the doors shall be tested and listed for the fireplace. When using tight-fitting doors on masonry fireplaces, the doors shall be listed and labeled in accordance with UL 907.

    In other words the code would allow, just as you imply, that either "tight fitting flue dampers or doors" would be allowed. And, in the case of masonry fireplaces which are not UL tested and listed, it would mean that tight fitting flue dampers would always be the option since there are no tight fitting doors "listed and labeled in accordance with UL 907".

    We agree with that compromise. We think it avoids the fire hazard that tight fitting doors would create and we think it is far easier and more effective to seal off the damper with relatively less perimeter than it would be to seal off fireplace doors.

    The next problem with your request is that there is no definition of "tight-fitting" and no standard or test to determine how much if any air can be passed through the closed damper under what pressure differential. We think our gasketed dampers, depicted at http://www.rumford.com/store/dampers.html are pretty tight fitting but they have not been tested nor would we know what the test should be. Perhaps, with the damper closed, the whole house should pass whatever blower door test you require to minimize leaks.

    Finally you admonish Ms. Paplin to "provide documentation that a source of combustion air has been provided". We agree with you and always advise our customers to provide exterior air as required by R1006.1 of the IRC. We are not fond of providing the exterior air directly in the firebox as it is never adequate and it often comes with the bad side effects of bad smells, blowing ash and sometimes a fire hazard if it can flow backward. We far prefer complying with R1006.1 by insuring that the room is "mechanically ventilated and controlled so that the indoor pressure is neutral or positive" as is allowed in the first paragraph of R1006.1. Alternatively we prefer locating the outlet, not in the firebox, but within 24" of the firebox as allowed in R1006.5.

    We would welcome your comments and suggestions as we all struggle to make the codes safer and more consistent. In the meantime we hope that you will allow Ms. Paplin to specify our gasketed Rumford damper in lieu of "tight-fitting doors" and combustion (or exterior) air as required by code.

    Respectfully yours,
    Jim Buckley

    On Tue, Aug 20, 2013 at 3:32 PM, Catherine Paplin wrote: -------- Original Message --------
    Subject: Energy Variance 2013-0258 West Hurley
    Date: Mon, 8 Jul 2013 14:42:25 -0400
    From: Morehouse, George (DOS)
    To: cpaplin@cpaplinarch.com
    CC: Hill, Joseph (DOS)

    Ms. Paplin;

    On the Variance application Part 3 you refer to Code section 102.5.1. I assume you are using Code section 303.1.5 Fireplaces for your relief request, if so, please update this Part and forward to me.

    The letter dated March 29, 2011 from Mr. Buckley states that this fireplace features dampers with gaskets. Please forward any listed information or air infiltration (leakage) charts that have been documented for this product.

    Most importantly, please provide documentation that a source of combustion air has been provided, as this is a requirement.

    Thank you;

    George W. Morehouse
    NYS Dept. of State, Codes Division
    Code Compliance Specialist 1
    99 Washington Ave.
    Albany N.Y. 12231
    (518) 474-4073

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