John Crouch on BAAQMD Staff Report

HEARTH
PRODUCTS
ASSOCIATION
Sacramento Office: 7840 Madison Avenue, Suite 185, Fair Oaks, CA 95628
Ph: (916) 536-2390, Fax: (916) 536-2392 Email: crouchpa@ix,netcom.com
DATE: November 8, 1998
TO: CHAIRPERSON JOHNSON AND MEMBERS OF THE AD HOC COMMITTEE ON WOODSMOKE
FROM: JOHN CROUCH, HEARTH PRODUCTS ASSOCIATION
RE: 11/2 STAFF EVALUATION OF FIREPLACE "EQUIVALENCE"
I have three comments on the Findings of the memorandum and two comments on the recommendations.
1.) The district's staff has done an excellent job of providing the Ad Hoc Committee with the background to the EPA's NSPS for Residential Wood Heaters. In the past I have endeavored to elucidate the inherent difference between fireplaces and woodstoves, and the inappropriateness of attempting to apply the Wood Heater NSPS methodology to appliances for which it was not intended.
2.) The staff report also does a good job of identifying the essential variable in any fireplace emission testing, which is the bum rate. The table on page 5 leaves it to the reader to ask the essential question, " What is a reasonable amount of wood for the average Fireplace Fire?" Clearly the ARB test, which burned almost 35 lbs per hour is well beyond the normal fire. Even the most recent test, by Reitz, utilized a 17+ lb/ hour bum rate, which I believe is too high. From the survey work which the HIPA has done, and the small amount of in-home testing done by OMN? laboratories, that 7 to 8 lbs per hour over the course of an evening, is a realistic bum rate. Thus, while a research fire can bum any amont of wood, the 'real world' evenings fire is about what one person can carry in their arms, 28 to 36 lbs, of wood.
3.) The staff finds the Washington state test protocol "adequate", although they suggest that the method of defining the end of a test allows the test to go on after the fire may have gone out, which may be important for masonry units. I must point out that this does not have gm impact on an emission factor which is what Washington State uses. Indeed, the use of an emission factor, eliminates this issue entirely, whereas an emission rate, which would depend on the time interval of the test would be greatly impacted by this issue. Emission Factors are simply a better method of expressing the quality of the combustion which is why, as the staff point out, they are overwhelmingly common in air pollution control. The staff correctly points out that repeatability is important for test results although the lack of demonstrated repeatability did not delay the USEPA from first adopting the Woodheater test method, and only subsequently addressing repeatability.
With regards to the recommendations contained in this memorandum; I assume that members of the Committee have a better appreciation of why members of our industry interceded as the committee was about to pass a motion adding the Washington State 'Equivalency' to your Model Ordinance, as was then recommended by your staff. Even though we did not foist this concept upon the Washington State legislature, nor 'sell' it to working group which prepared the rules, we have since been accused of pulling a 'fast one' on Washington State. We were determined that this would not be the case with the BAAQMD.
The fact is that many people in Washington thought that Fireplaces and Woodstoves are just different types of the same appliance, and failed to sit down and do the analysis that Bill Guy and his team did. It is to this District's credit that they finally, when instructed by the Ad Hoc Committee, did this work.
Not withstanding this excellent work, the recommendations are not entirely supported by the analysis. The Ad-Hoc committee needs to critically review these recomendations before submiting this draft to the full board.
1) Simply because Fireplaces are not "Equivalent" to WoodHeaters does not mean that this District cannot create a technology forcing standard for fireplaces.
2) Simply because neither the EPA, or Washington state have done the analysis of emissions and available control technologies that the District's staff points out would be the normal approach, it is not appropriate to simply ban the product. The Washington method has been judged adequate, and this District could use it to set a technology forcing target for these products.
3) If the District fails to set a target for Fireplaces, utilizing data obtained by the Washington State protocol, every city or county which considers the adoption of this model ordinance will be faced with a problem. They will bear the burden of explaining to their consumers and home buyers why the District failed to leave any option for new fireplace technology, and that only Woodheaters are allowed. They may also have to explain that this ban was passed in the absence of any federal mandate for PM non-attainment, and will have no effect on existing homeowners or complaints about existing fireplaces.

Headquarters: 1601 North Kent Street, Suite I 001, Arlington, VA 22209 Ph: (703) 522-0086 Fax: (703) 522-0548
web site: www.hearthassoc.org - email: hpamail@hearthassoc.org

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