Paul Tiegs on BAAQMD Staff Report

From: "Paul Tiegs"
To: "Loel McPhee"
Date: Sat, 7 Nov 1998 14:49:41 -0800
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Loel,
Since I have not been able to get this letter through to Bill Guy, would you please make sure the points I make get to the Board of Directors? The email address I have for Bill is: bguy@baaqmd.gov. For my future reference if you find out the correct one, I would also appreciate it if you could get it to me.
Thanks,
Paul Tiegs

Dear Mr. Guy,
I just this morning got a chance to look at your "Fireplace Equivalence" writeup. You have done an excellent job. In fact, it is one of the most thorough analyses done by a regulator (or even non-regulator for that matter) that I've seen. And, as usual after the compliments, I've got some comments for you to consider.
1. First, I would like to add a qualification to your statement that "Equivalence between standards for fireplace and woodstoves is not possible". My suggested added qualification is: "unless 'utility' (ie, heating capacity) is taken into account." There can be equivalence if fireplace thermal efficiency is measured. That way fireplace emissions can be expressed as grams of emissions per million joules of useful heat delivered. This approach would view fireplaces as having utility instead of just being recreational or aesthetic devices. Since EPA has an official thermal efficiency for non-catalytic woodstoves of 63%, their 7.5 g/hour emissions rate at a 1.03 kg/hour burn rate converts to 0.62 grams/million-joules of useful heat output (this also assumes 8250 Btu/pound of dry fuel in the calculation). An engineering and science based "equivalent" emission rate would index or scale, on a linear adjustment basis, the allowed or regulatory fireplace emissions rate: IE, at a fireplace thermal efficiency of 63% (ie, equal to EPA's assumed woodstove efficiency), a wood-burning fireplace that demostrated an emissions rate of 0.62 grams/million-joules or less, would be allowed to be installed. On the other hand, at a fireplace thermal efficency of 0% (ie, all heat generated by the fire is lost up the chimney), a wood-burning fireplace would have to demonstrate 0.00 (zero) emissions before it could be installed for burning wood. And, in between, a wood-burning fireplace that was tested at an intermediate thermal efficiecy of 31.5% (ie, 50% of EPA's 63%) would have to demonstrate an emissions rate of 0.31 grams/million-joules of heat delivered (50% of EPA's woodstove NSPS emissions rate). A simple formula: ie, x/63 * 0.62 = allowed emissions rate, could be used to determine approval. (where x is the tested fireplace thermal efficiency)
2. Your statement that "The Washington State "equivalent" standard for fireplaces appears to favor small fireplaces over larger fireplaces but does not distinquish between cleaner fireplace technologies and dirtier fireplace technologies." also needs some clarification. Although it is true that the standard (or any concievable future standard for that matter) favors smaller over larger fireplaces is true but I must point out that the standard still can distinguish clean from dirty especially for fireplaces of the same or similar size. By measuring the amount of emissions generated per kg of fuel burned, the Washington State standard does provide a good measure of the quality of the combustion process taking place (ie, the thermal/chemical processes of combustion taking place). Also, by effectively reducing the size of fireplaces that can be approved in Washington, the regulation does reduce emissions to the airshed.
3. I would also like to clarify and amend another comment I made during the October 8 discussions with the BAAQMD staff regarding my knowledge of a "cleaner burning fireplace". Although it is true that I don't know of any passive fireplace design features that can reduce emissions by large amounts (eg, more than 70 or 80%) unless the non-passive and expensive afterburner or precipitator technologies are used, I do know of new technology devices that when installed into a fireplace, can reduce emissions significantly. There are reasonably priced devices available now, like the EcoFire Super-Grate from Andiron Technologies, that can reduce fireplace emissions by as much as 30%. The EcoFire Super-Grate is a device that provides additional heated air to the fireplace combustion zone which improves combustion processes in a fireplace and thereby reduces the air pollutant emissions generated by incomplete wood combustion. I want to make it very clear here that I believe there are existing technologies that appreciably reduce fireplace emissions and I believe that since research for developing more advanced and effective technologies is only now just in its infancy, there are more significant improvements to come.
My personal and strong recommendation to the BAAQMD Board of Directors is to adopt at least the Washington State standard for new fireplaces being sold and/or installed in the BAAQMD. To make the standard more effective for reducing emissions in the BAAQMD, I believe, as do most reasonable members of the Hearth Industry that I know, the BAAQMD should adopt a more stringent passing grade. A standard that is 1/2 of the Washington passing grade would definately eliminate the larger polluters and would provide a stimulus for industry research and development into even cleaner and more cost effective technologies.
By adopting the Washington State standard, and since the Washington State Department of Ecology only publishes a pass/no-pass list of fireplace models, the BAAQMD would have to process applications containing actual tested emissions data and publish a list of approved models. Because the Washington State standard also has the problem of allowing too many non-tested but "similar" fireplace models to be approved under a loosely defined set of similarity criteria, the BAAQMD should adopt a more stringent set of similarity criteria. (As a note: The original intention of the Washington standard was to allow approval of non-tested fireplace models that only differed from a tested and approved model by aesthetic appearance or facade design. However, since no definitive similarity criteria have been established by Washington, strict oversight for the non-tested approvals has not taken place.). A very defined and stringent set of similarity criteria has been developed and is now being considered for adoption by the Washington Department of Ecology. Testing, application preparation, and similarity determinations can all be performed by test laboratories accredited by both the U.S. EPA for testing woodstoves under 40CFR60 Subpart AAA and by a nationally recognized accrediting body (eg, the American National Standards Institute [ANSI] or the American Association for Laboratory Accreditation [A2LA]) to the International Standards Organization [ISO] Guides 25 and 65 for laboratory quality assurance requirements.
An additional option would be to have a phased fireplace emissions reduction ordinance: ie, start with using the Washington State standard with a more stringent passing grade for the first two years and then, after two years, require the use of the ordinance presently being developed by the Northern Sonoma County AQMD. In its present draft form, the Northern Sonoma "protocols" for testing and fireplace approval are based on measuring fireplace emissions and thermal efficiency thereby providing the means for basing a fireplace emissions ordinance on the amount of emissions allowed per million joules of useful heat generated by the fireplace. In case the Northern Sonoma County ordinance is not finished in two years, which is highly unlikely since they have a completed draft and are presently initiating a test verification project, the BAAQMD ordinance could be worded such that the it would only be implemented if the program is in place and operating.
Let me know if you want to get any additional information on this or other fireplace topics.
Paul Tiegs

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