6/12/00The results of a new round of emissions testing comparing four masonry fireplaces, a metal "zero clearance" fireplace and an EPA-Certified stove simultaneously tested to three sets of two sampling methods were presented today. The objective stated in the report prepared by OMNI was to "Develop a Protocol Relating Particulate Emissions from Non-Certifiable Fireplaces and Masonry Heaters to EPA-Certified Woodstoves."
It's good science. Paul Tiegs and Jim Hauk have spent months compiling the results and they have done a good job. The direct comparative testing provides a clear and careful way to compare fireplace emissions with woodstove emissions. For the first time in recent times fireplace emissions and efficiency have been looked at objectively.
Ironically the science, good as it is, may be too late, too complicated and politically useless. To compare fireplaces and stoves - a classic example of apples and oranges - requires a lot of manipulation. Tiegs and Hauk show first that the two methods (5G and 5H) EPA uses to measure stove emissions are complicated and devoid of any real-world meaning and don't even correlate very well with each other. In particular the emission rate standard of 7.5 grams of PM10 per hour used to measure stove emissions is particularly meaningless and only useful in comparing one stove against another very similar stove. To try to adjust and manipulate these methods even further to show a correlation with the ESS method OMNI uses and come up with a meaningful standard for fireplaces expressed in grams per hour just seems to be tortured.
If anybody really cared about regulating fireplaces it would probably be better to give up trying to compare them with stoves and start over using the EPA "MACT" approach - "Maximum Acheivable Control Technique" by which the best 12% in any group are used to set a technology driving standard and get rid of the worst 88%.
But does anybody really care? The Bay Area Air Quality Management District (BAAQMD) is bent on simply banning fireplaces and masonry heaters even if they are cleaner than the stoves they do permit. They seem to have the power. They've been successful in three Bay Area cities in a row. Many in our own industry don't think it's a good idea to come up with a fireplace emsissions standard - especially an EPA fireplace standard - for fear that fireplaces might be more easily requlated in the rest of the country where there are now no regulations. Back in California we couldn't even persuade our own dealers, masons, builders and architects to show up for the city council meetings in the cities where they lived and worked to speak out against the fireplace bans. And, while we are planning a lawsuit agaist Palo Alto and San Jose, few people think the courts will require these cities to be fair. Apparantly they can be "arbitrary and capricious" if you don't have the political power.
For the immediate future, we will continue our political and legal battle in the Bay Area and work with Northern Sonoma County, officials, George Erdman and Barbara Lee to see if we can come up with some fireplace standard as a result of the OMNI testing. Even that simple strategy seems fraught with problems:
1) Northern Sonoma County told OMNI staff they have other proiorities and won't get around to fireplace standards for at least six months - this after seven years of delays and many past missed deadlines.
But back to the science. While I'm quite pessimisstic about the politics, the science is interesting.2) Even when and if they do get around to it, Barbara Lee is only reluctantly willing to go back to her board which she still reports as insisting on a g/hr standard in order to limit the size of fireplaces.
3) Dennis Jaasma, Walter Moberg and perhaps others want to make certain fueling protocol changes that would limit a manufacturer's options and in any case would re-open areas that Northen Sonoma has already agreed with and would likely delay the process and require more testing.
If nothing else, the round of comparative testing showed that fireplaces, in the words of Paul Tiegs, "are inherently cleaner than stoves". We should accept no more assumptions or claims based on faulty science about fireplaces being inefficient or even negatively efficient. Masonry fireplaces had efficincies between 20% and 50% and the range was so great that, with a little effort, efficiencies could be expected to go even higher - probably about the same as stoves which are all about 63% efficient.
OMNI plans to write a more comprehensive report to accompany the "Results" they presented and I have already hit the highlights. For now I want to make some observations about what it means for masonry fireplaces and in particular Rumford fireplaces, based on my involvement, with Jerry Frisch in building the masonry fireplaces and observing most of the tests.
EPA Methods 5G and 5H are shown to be highly manipulated test methods used narrowly to camprare stoves with each other that have little of no real world meaning. In other words, the results have to be adjusted and manipulated for any stove to meet the EPA emissions standard of 7.5 grams of PM10 per hour and in fact stoves burned like fireplaces with lots of excess air are allowed to emit 27.7 g/hr as measured by the ESS system used by OMNI. It takes many complicated scientific "adjustments" to do it. The study shows that:
1) Fireplaces are inherrently cleaner than stoves and masonry heaters are cleaner yet.
4) The results are interesting and satisfying but probably are too late, too complicated, and nobdy cares. Besides, we're still arguing over the details. 5) A couple of details that affect Rumford fireplace performance are a) the fueling rules that require the total amount of fuel to be determined by the hearth area and put the tall shallow Rumfords at a disadvantage, and b) the measure of efficiency may neglect the real effectiveness of radiant heat.2) Efficiency of masonry fireplaces is much higher than previously thought and is between 20% and 50% if measured the same way efficiency is measured in stoves.
3) Rumford fireplaces, Rosins and other "new technology" fireplaces that have the correct air/fuel ratios are cleaner that regular fireplaces and can probably be made even cleaner and more efficient.
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Background - Reason for tests
11/5/99
OMNI Environmental Services must pass an annual EPA certification test in which they run a 5G and 5H test on a known EPA stove. Paul Tiegs, OMNI Director, thought it would be a great opportunity to run a simultaneous test of the Northern Sonoma fireplace test protocol and include a couple of masonry fireplaces and throw in the Washington test protocol for good measure. That way we would have a direct comparison of two fireplace test protocols with each other and the EPA stove protocols and end up with a fireplace standard maybe everyone will accept.
The OMNI comparison tests on the EPA stove and metal fireplace are now finished and so far the testing shows a remarkable confirmation of the Northern Sonoma and Washington testing protocols.
We have also tested four masonry fireplaces: a typical western standard fireplace paid for by Western States Clay Products Association, a typical eastern standard fireplace paid for by the Brick Industry Association, a Rumford fireplace paid for by me (Jim Buckley) and a Rosin paid for by Jerry Frisch. Testing the masonry fireplaces began in January and was finished last week. Results will take a few weeks to tabulate and evaluate.
Besides the masonry industry associations mentioned above, Northern Sonoma County and the Hearth Products Association are helping to fund the testing. We are working to get broader support. BAAQMD support, for example, might be a good face-saving way for us to resolve our political differences and begin working together.
I expect that ordinary masonry fireplaces will turn out to be cleaner-burning than we have been led to believe by the advocates of various alternative gismos - probably as clean or cleaner than EPA certified wood stoves on a grams per kilogram basis, which is the only fair way to compare different appliances. We hope and expect, of course, that the Rumford and Rosin fireplaces will be even cleaner and more efficient. I think the comparative testing will give us an objective basis for evaluating masonry fireplaces in general and for measuring any improvements among the "new technology" fireplaces. Our main purpose is to establish a fireplace standard and method of testing fireplaces that everyone will accept.
A New Round of Comparative Fireplace Emissions Testing
WSCPA Fireplace being tested for emissions
BIA Fireplace being built
BIA Fireplace being tested
Rosin being tested
Rumford being built
Rumford being testedclearance to combustibles test
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