Northern Sonoma County, CA
1/24/05
INDEX
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Protest Fueling Rules as Unfair to Rumford First, see A New Round of Comparative Fireplace Emissions Testing - 1999-2000. Then, within that context, I wrote to George about what I consider to be a fueling protocol unfair to Rumfords:
George Erdman has been developing a fireplace emissions standard since at least 1992. Last week (August 14, 1999) he told me it would be "several more months". He is busy and doesn't have adequate funding to do what he wants to do. George relies heavily on Paul Reitz in San Luis Obisbo in technical matters and, like Paul, does not think fireplace emissions should be evaluated on the basis of an "emissions factor" (expressed as grams of particulate per kilogram of fuel burned). Rather, they both feel that an emission "rate" is more appropriate. A "rate" favors small appliances even if they are not very clean. Our big 48" Rumford, which can burn four times as much wood as a typical stove, has to be four times as clean as a stove to pass the "rate" standard. A "rate" also favors light weight metal stoves which are fired continuously. Masonry fireplaces (and especially masonry heaters) are one-burn-rate appliances and are fired intermittently or periodically, relying on their thermal mass to keep on heating between cycles or even after the fire is out. The EPA stove testing protocol and "rate" standard is not a very good prediction of what goes on in the real world. It serves mostly to compare one stove to other very similar stoves. For a fireplace testing protocol and standard to be "equivalent" to the EPA stove standard some consideration must be made about how the different appliances transmit heat and how they are fired or used. A fair comparison might be made on emissions per BTU of heat output, which can be reduced to emissions per kilogram of fuel burned factored by the efficiency of the appliance. But that would be an "emission factor" and George doesn't buy it. The Northern Sonoma County standard is expressed as a "rate" and when we translate our Washington emission factor to a rate we average the emissions out over the duration of the test, roughly equivalent to the heating cycle of the fireplace (4.42 hours for the 30" Rumford), and George thinks that's too long. He'd like to cut the test off after one and a half or two hours. I don't care. Draw a line in the sand. But until George or Paul or someone else actually develops an alternative fireplace testing protocol and standard, I think Northern Sonoma County should accept the Washington standard. It's the best one we have. - Jim Buckley 8/19/99
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Meeting with Barbara Lee and George Erdman on July 30, 2002
Date: August 8, 2002
Barbara Lee
Barbara & George,
Michael Gersick and I enjoyed meeting with you on July 30. We appreciate the time you set aside to meet with us. I think we may all be a little frustrated with endless meetings that seem to go nowhere so I welcome your invitation to submit a couple of proposals. Hopefully they will help us get down to specifics and off dead center. The proposals we discussed are:
1) A general proposal to express the Northern Sonoma County Fireplace Standard as an emissions factor expressed in grams of PM10 per kilogram of fuel burned, rather than as a rate of grams/hour, and
2) A specific application for approval of a Rumford fireplace with test results expressed as an emission factor showing, by the above equivalency, the Rumford to meet the EPA stove standard of 7.5 gr/hr.
During the meeting on July 30 you both indicated that you were familiar with the comparative testing OMNI did in 1999 and 2000 which resulted in the Report entitled "Evaluation of The Northern Sonoma County Wood-Burning Fireplace and Masonry Heater Emissions Testing Protocols" by Paul Tiegs, PE and James Houck, PhD, November 30, 2000 which is on line at http://www.omni-test.com/Publications.htm as a PDF file.
Yet when you encouraged us to submit the above proposals you added the phrase "supported by data we can believe." To me that implies that you don't agree with at least some of the conclusions expressed in the OMNI Report. Perhaps you already have, but I would appreciate it if you would evaluate or critique the OMNI Report point for point in a systematic way so I may know what parts you agree with or disagree with.
The OMNI Report is pretty complicated but Paul Tiegs wrote a "Summary" that was presented in Portland, OR on June 9, 2000. It's short so I have reprinted it below. If you could identify for me the points made in the Summary with which you disagree. Then we can go to the full Report (or do more testing) to resolve those questions without having to wade through the sections of the Report that are irrelevant or upon which we do agree. To me the Summary hits the high points and may be the best way to get started.
One note I would make at the start: Tiegs backs off the g/kg equivalency to avoid argument, but his conclusion is basically that 27.7 g/hr = 7.5 g/hr which isn't intuitive - you have to follow the argument. I think the g/kg equivalency is far less subject to manipulation. With a g/kg standard, for example, the start, end and overall length of the test don't matter, and at least one "factor" to adjust for the fireplace cold start can be eliminated. We can live with an adjusted g/hr standard but I think a g/kg standard is more straight forward and less subject to abuse. The arguments Tiegs makes below would apply to a fireplace standard expressed as either an adjusted g/hr rate or as a gr/kg standard.
I look forward to hearing from you and will submit our proposals soon after hearing from you.
Best Regards,
Since it has been very difficult to get a general understanding amongst regulators of the issues between using the grams-per-hour (the reporting unit used for woodstove emissions) and the grams-per kilogram of fuel burned reporting unit most appropriate for fireplaces, I will keep the discussion in g/hr.
The U.S. EPA's 7.5 grams per hour (g/hr) emission limit for woodstoves is actually a calculated weighted average of four different tested burn rates (measured at four different times during a full burn cycle). Those measured rates may range from 1 kilogram per hour (kg/hr) to the maximum rate a stove will burn.
In addition to the g/hr limit, the EPA also stipulates a single, maximum burn rate test limit of 18 g/hr (Federal Register Volume 53, Number 38, page 5860, February 26, 1988), which applies to woodstove tests that produce single-measure readings of more than 1.5 kg/hr.
Fireplaces do not have burn rate control mechanisms, as do woodstoves. It is impossible, therefore, to "choke down" a fireplace to reach the lowest burn rate achievable by a woodstove. Therefore, when establishing a "fireplace equivalent" of the EPA woodstove test, it is reasonable to apply the EPA burn rate test limit cap of 18 g/hr.
The second conversion that is required when establishing a "fireplace equivalent" relates to the test methods used for measuring woodstove emissions and fireplace emissions, respectively.
One of the primary differences between the approved woodstove test methodology and the approved fireplace test methodology is fuel loading. When fueling a woodstove test, the prescribed test-fuel load (cite authority for fuel quantity/quality) is placed on top of a hot, burning coal bed. When fueling a fireplace test, the prescribed test-fuel load is placed in a cold fireplace and ignited.
Another significant difference relates to the timing of sample-capturing. For example, fireplace test sampling is begun immediately upon lighting the test-fuel load from a cold start. Woodstove test sampling does not begin with a cold start, but only after a hot burning coal bed is under the test-fuel load to be measured.
These differences, if not corrected, produce patently incomparable results. Well-accepted research by Shelton Research Laboratories (Santa Fe, New Mexico) has demonstrated 33% of total fuel-load emissions is produced during the kindling phase of the combustion cycle. In order to derive data that is useful and comparable, therefore, a "fireplace equivalent" of the EPA woodstove certification test must include a factor to neutralize the differences in the state of combustion at which sampling is initiated. Since the Northern Sonoma County Air Pollution Control District's protocols (which the BAAQMD approves unconditionally) prescribe a single test with three serial fuel loadings only the first of which are started with kindling, the adjustment factor proposed by OMNI is 11% (i.e., 1/3 of the 33% emission factor which has been attributed to the kindling phase), or 1.11 times the EPA 18 g/hr. cap.
Finally, there must be an adjustment to compensate for the differences in the way exhaust air samples from the respective woodburning devices are captured and measured. EPA woodstove certification tests use EPA's Method 5H (Title 40 CFR, Part 60. [Appendix A]) which is fashioned after EPA's standard Method 5 for measuring particulate emissions from industrial sources. Fireplaces are sampled using a high-efficiency sampling system (ESS) favored by the Northern Sonoma County Air Pollution Control District and endorsed by the Bay Area Air Quality Management District. In addition to capturing all the emissions captured by EPA's Method 5H, the ESS captures the semi-volatiles produced by woodburning, in an absorbent resin trap (designated as XAD-2). The effect of requiring this much more effective sampling technology -- designed specifically for maximum efficiency with woodsmoke sampling -- is that the captured-emissions readings are higher than they would be if EPA's Method 5H were used.
Thus, after adopting the EPA burn rate test cap of 18 g/hr, a truly transparent "fireplace equivalent" to the EPA woodstove certification test must include adjustment factors to neutralize significant disparities in both kindling phase sampling methods and emissions-capture efficiencies.
OMNI Test Laboratories proposes the following formulation:
18 g/hr x 1.11 (kindling phase factor) x 1.385 (capture efficiency factor) = 27.7 g/hr Emissions Cap for Fireplaces as measured by the Northern Sonoma Fireplace Testing Protocols.
OMNI is one of four national laboratories licensed by the EPA to perform the EPA woodstove certification test and site of recent comparative analyses sponsored, in part, by the BAAQMD and the Northern Sonoma Air Pollution Control District.
--
Jim Buckley
And a follow-up note...
To: nsc@sonic.net
Barbara Lee
Barbara & George,
Anticipating our application for approval of a Rumford fireplace in Northern Sonoma County once we establish the rules, I remembered you being concerned that there was not enough "spread" in the OMNI comparative test results and that all the fireplaces looked about the same. Let me draw your attention to the chart in the OMNI report on line at http://www.rumford.com/emissions/images/report17.gif This chart is complicated by the consideration of efficiency but it is sort of the "bottom line" of the Report and shows, after all the adjustments are made, which appliances passed and which failed. Those below the slanted line passed while those above the line failed.
The chart shows a pretty clear separation between clean-burning fireplaces and regular fireplaces. I know the letter designations are supposed to mask the identity of the fireplaces but I think it would be helpful to unmask them. The metal "zero clearance" fireplace (ZC), way up in the top left corner did not come close to passing. Neither did the Standard masonry fireplace designed by the Brick Industry Association (MF B). The Rumford with the NSC fueling load, which was not appropriate for the fireplace shape (MF C), also did not pass.
The fireplaces that did pass were all "new technology" fireplaces in one way or another. Fireplace MF C is, of course, the Rumford which passed in the closed door configuration and also in the open configuration with an appropriate fuel load. Fireplace MF D was the Rosin which tested very clean but, of course, it was the smallest fireplace with an insulated firebox, a tuned air system and the smallest flue. Fireplace A was a conventional "Western" masonry fireplace but it was not conventional in that it also had an insulated firebox and tuned air system.
So we had three sort of conventional fireplaces and three sort of "new technology" fireplaces and only the "new technology" fireplaces passed. Isn't that what we want - a technology driving standard? At our meeting we touched on the Maximum Achievable Control Technology (MACT) concept and you mentioned that you wished the test results separated the good from the bad a little more clearly. I would submit that they did. Only the "new technology" fireplaces passed while the metal zero clearance fireplaces and the standard masonry fireplaces, which represent way over 90% of the market, failed pretty decisively.
Best,
No answer as of 9/10/02 so I re-sent the August 8 Letter to Barbara Lee and George Erdman with the following note:
Barbara & George,
Please acknowledge that you have received this message. I have not heard from you since I emailed you the message below on August 13, 2002 and now I learn from John Crouch that you have a new "Final Draft" out. Perhaps I have an incorrect email address for you or somehow your return has gotten lost.
Best regards,
Jim Buckley
Meanwhile, John Crouch reports on....
From: "John Crouch"
John,
Barbara Lee of the Northern Sonoma Air Pollution Control District has
released what they call the "Final Draft" of their test protocol.
It is far less than any of us had ever hoped for.
Clearly, if we want anything more out of this jurisdiction, we will
need to take our story to her board.
John Crouch
Attachment: Final Draft - 8-09-02Rev.doc
Thanks Jerry. I had already gotten the "Final Draft" from John Crouch.
I called John yesterday and he told me Moberg may be planning to go to Barbara Lee's board. Maybe we should do the same - not with Moberg, hopefully - but separately to put pressure on Barbara and George Erdman to come up with a realistic standard someone can pass. Seems to me that a standard no-one can pass is really a ban.
Michael Gersick (California Hearths and Homes) and I met with George and Barbara last July and I've got some follow-up letters and notes on line at http://www.rumford.com/emissions/NSonoma.html
John told me another surprising thing. He said that all the big metal fireplace manufacturers were likely to endorse an EPA recognized "consensus standard" - maybe one developed by ASTM E-6. When we went to that meeting in Santa Barbara it was clear to me that all the big manufacturers wanted no part of a fireplace standard. Why have they switched? John says because, with the new pressure of PM 2.5, regulation is going East anyway. I don't know if I am convinced but John is in a good position to know. The big guys may just be playing along, knowing the ASTM process will be slow. On the other hand I guess that's another reason I should get on the E-6 committee.
Best,
Date: Thu, 23 Oct 2003
Jim: I am offering my encouragement. We do 5-6 med - high end homes a year at Sea Ranch and other parts of the N. Cal coast. Very few of my clients want tin boxes to be the focal point - they want something solid and rich, as only a masonry fireplace can be. And the Rumford is pretty much admired by all when they see one.
So anything you could do to persevere would be rewarded by some small amount of sales of your products. I know how intractable NCPAD can be. The fact that they implement this rule on the coast where there are no valleys in which inversions might occur and insufficient population to generate smoke that degrades the air quality is of no interest to them. I strenuously argued the point when they held the implementation hearings, but to no avail.
Meantime we are going to try the gas log approach.
Anything I can do to help, please let me know.
DAN
6/4/04
Andrew,
"NSCAPCD" stands for "Northern Sonoma County APCD" I think. Is Sebastopol in Northern Sonoma County as opposed to Sonoma County? If so, maybe there is a wasp's nest waiting for you. We've had a confusing and sometimes contentious relationship with George Erdman, the head air quality official in Northern Sonoma County. See the details at http://www.rumford.com/emissions/NSonoma.html
Ironically, the last testing we did was according to the "rules" that George Erdman suggested. See http://www.rumford.com/emissions/testing.html and the results are the ones we report in the tests dated in 2000 at http://www.rumford.com/testRumfordresults.html Yet, to my knowledge, Northern Sonoma County has never approved a masonry fireplace. In fact I would suggest that the phrase you quote from them, "Masonry fireplaces do not comply with the emission standards of the NSCAPCD." implies that the district has a policy that no masonry fireplace will ever comply no matter how clean it is. I'd love to appeal a case and go above George to his Board, but when I tried to make general application for approval back in 2002, he never answered my letters. Maybe he'd have to if you appealed his disapproval of your proposal to build a Rumford.
But that's my fight, not yours. My best advice to you is to ask the building official on your project up front before you are too committed. Ask if the Rumford will be approved. If not, ask if a) you can build a Rumford with gas logs installed as shown at http://www.rumford.com/store/gaslogs.html and b) what are the procedures for an appeal. Then make your decision. Maybe, if you are allowed to build the Rumford with gas logs, you can delay any appeal to burn wood until the house is finished and your customer has moved in.
If you choose to appeal, I will do all that I can to assist, including coming to any commission or board meetings and preparing testimony and probably paying for the Director of our test lab to come to give expert testimony. I also promise you that it will all be very professional and civil. I may not make a better friend of George Erdman but often I've found that appealing a code or emissions rule ends up being a positive experience with the officials becoming better educated and more supportive.
Best,
Mr. Buckley:
I'm an architect in San Francisco, designing a house in Sonoma County CA,
near Sebastopol. The project is going in to the County for permitting soon
(within the next few weeks).
I have designed a Rumford fireplace for the house, based on the 'Certified'
drawings and information on your website. Very recently, however, I have
come across a document from the County, 'Residential Construction in Sonoma
County', that states "Masonry fireplaces do not comply with the emission
standards" of the NSCAPCD.
I understand from your website that there has been some controversy about
these emission standards. If I go forward with the Rumford design, am I
stepping into a wasp's nest? Or do you have documentation that will resolve
the issue with the County?
If there is some documentation, what should I state on my drawings? Is there
some test or standard number (similar to a UL listing)? You show the
emissions rating on the drawing called ' 48" Certified Rumford Fireplace ',
but I am not sure how to relate that to the NSCAPCD standard (which is
unknown to me at this time, although I am going to look it up on the web).
Any help you can give me would be much appreciated.
Best Regards,
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