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HomeMy WebLinkAbout2011-03-23 Planning & Zoning Packet - Work SessionOutdoor Wood Burning Boilers (OWB's) Work Session March 23, 2011 6 p.m. Agenda Does the Commission want to recommend an Amendment to regulate OWBs? 1. Notes from February 23, 2010 Work Session 2. OWB's An Introduction (Johnson Issod) 3. Alaska Warm Wood a. Outdoor Wood Furnace Best Burn Practices (HPBA) 4. EPA Information a. Burn Wise Administration does not currently recommend regulation of OWBs. If the Commission decides to recommend an amendment to regulate OWBs, the following items are recommended for consideration: 1. Zoning recommend against high density zones (RS, RU). 2. Lot Size minimum of 20,000 sq. ft. 3. Units limit number of units per lot. 4. Setbacks from buildings and lot lines. 5. Require Building Permits. 6. OWB's must be UL Listed. 1 3 7 8 5. ADEC Information a. NESCAUM Model Regulation for Outdoor Hydronic Heaters 9 b. Outdoor Wood Boiler Fact Sheet 29 6. Email Response on regulation of OWBs a. City of Homer 34 b. City of Anchorage 35 7. Work Sheet 39 MEMO: TO: Planning Zoning Commission THRU: Marilyn Kebschull, Planning Administration FROM: Nancy Carver, Planning Assistant DATE February 25, 2011 Village e with a Past, Ci y with a Future' 210 Fidalgo Avenue, Kenai, Alaska 99611 -7794 Telephone: 907- 283 -75351 FAX: 907 283 -3014 11 r 1992 SUBJECT: Work Session Outdoor Woodburning Boilers (OWBs) On Wednesday, February 23, 2011, the Commission held a Work Session on Outdoor Woodburning Boilers (OWBs). Those in attendance were: Jon Karen Cress dba Alaska Warm Wood Heating, Carolyn Unger, Duane Bannock, Mark Schragg, and Mayor Porter. Mr. Cress gave a brief description of OWBs, how they work, and proper installation. New gasification type boilers are more efficient and produce the same particulates as newer wood stoves. Not recommended for small lots. Phase II boilers required for smaller lots, but not recommended due to cost of $500 $1,000 and would tend to defeat the purpose of having the economy of a wood burner. Request property owner contact insurance company to make sure there are no restrictions with installation of OWB. A minimum of 10 -feet from all structures on subject property. Typically 40', 70', or 100' from service buildings. Location should be with prevailing winds. Height and diameter (6" or 8 of chimney stack (see HPBA handout pg. 28 in packet). Recommend fuel be at least 20-30% seasonal firewood. Other concerns were: Ms. Unger stated her concerns from her original information provided at the 9/8/10 work session (Vermont WA handouts). 1 o Ms. Unger discussed a letter to the editor from a Kasilof OWB owner, and how he had to significantly modify the OWB to make it work efficiently. (Mr. Cress confirmed that it was in fact a home -made unit and not certified in any way). o Closeness to neighbor's property. o Setbacks. Proper Emissions for the Peninsula area. o Commissioner Knackstedt noted the EPA regulates these types of emissions and monitors air quality in areas such as Anchorage and Fairbanks. o Noted ADEC may have some good information to add, suggested staff contact someone from the EPA. o Phil North is the local representative, and is located at the River Center. o Does the EPA regulate particulate level in the Kenai area? Does Anchorage or Homer have OWB codes? o Commission requested copies of codes. Does DEC have any recommendations, requirements or information on OWBs? If the City does consider an ordinance, should if include a Federal rebate program, (Fairbanks North Star Borough)? Mr. Bannock's recommended the Commission consider the regulation of OWB's carefully. o What types of wood burning appliances would be regulated, fire places, wood stoves, etc? o Wood stoves also require proper installation to work correctly. Next meeting scheduled for Wednesday, March 23, 2011 2 Outdoor Wood Boilers OWB An Introduction Page 1 of 5 HEARTH.COM ARTICLES BACK TO MAIN ARTICLES AREA GO TO HEARTH.COM HOME #1 Outdoor Wood Furnace Eliminate High Heating Bills Heat Entire Home. FREE Brochure www.CentralBoiler.com Heat Exchanger Standard Custom Heat Exchangers. Online Calculator Available. www.ExergyLLC.com wood boilers indoor outdoor burning wood coal gasification furnaces www.newhorizoncorp.com ARTICLES Wood Outdoor Wood Boilers OWB An Introduction Written by Eric Johnson and Craig Issod Outdoor Wood Boilers, also called OWBs or Outdoor Wood Burners, consist of a firebox surrounded by a water jacket and a control system all housed in an insulated, steel -sided enclosure with a roof. Hot water is circulated through insulated, underground piping between the boiler and the house. OWBs have become very popular in many rural areas of the United States, with substantial sales in the Northeast and Midwest, where hardwood is plentiful and winters are long and cold. Ins l (surrounds Water Jacket) Cooled Water recyc e. rick to furnace) Forced Air Fumace (radiant floor, radiant baseboard or existing boiler may also be used for Internal heal distribution 1 Water Jacket surrounds Fire Box) Hot Water ircu to and m home) Fire Box 11 x! lid OWB Typical Setup Source: HPBA Ade by Coogle Although typically referred to as "boilers," OWBs are not boilers in the traditional sense. In a conventional indoor boiler (oil, gas, wood or coal hydronic heater), water is heated in a pressurized vessel and then circulated through the heating system. In an OWB, the water is open to the atmosphere and thus, not pressurized. This allows the OWB to be built to different standards than a traditional indoor boiler, and makes it exempt from some of the regulations that apply to pressurized heating appliances. There are pros and cons to consider when shopping for an OWB. One of the advantages of open systems is that they are safer than pressurized boilers. And because they're usually sited away from the house and other buildings on the property, they dont affect your homeowners insurance rates. All the creosote, smoke, ash, wood storage, etc. are outside of the house as well, which is appealing to many people familiar with wood stoves. And they can burn much bigger pieces of wood than a stove. 3 http:// www .hearth.com/econtentlindex.php /articles /owb 2/9/2011 Outdoor Wood Boilers OWB An Introduction improper burning in an OWB Page 2 of 5 On the clown side, open systems are prone to corrosion and the accumulation of debris in the system, which can be a maintenance concern. Overall system efficiency is a problem with OWBs as well, since it is virtually impossible to efficiently bum wood in a firebox surrounded by water. The result is smoke, which is basically unused potential heat going up the stack and polluting the air. Lower efficiency translates into more wood burned roughly twice as much as a modern wood gasification boiler. An OWB can be tied into either a hot water (hydronic) or hot air (furnace) system. This is done by piping the hot water from the OWB into the house and transferring the heat into the existing system using a heat exchanger. In a home with a hot water heating system, the heat exchanger is usually a stainless steel and copper device known as a flat plate heat exchanger. In the case of a hot air furnace, it is a copper coil located in the furnace bonnet through which the hot water circulates. The furnace fan then blows air across the coil, heating it and distributing it into the house. Most OWBs have very large fireboxes, often ten times larger (12 to 40 cubic feet) than the firebox found in a traditional wood stove. This makes them best suited for large heating loads or multiple buildings. However, using such a large firebox to heat most homes is overkill, since the boiler quickly satisfies the heat load and then spends the rest of the time idling. Idling results in lower efficiencies and the production of more smoke and pollutants than when the boiler is running under a load. Such large fireboxes, together with improper burning techniques, have resulted in numerous complaints about OWB smoke and smell. Some states and localities have either regulated or banned them, and many others are planning similar restrictions. It is important, therefore, for people considering an OWB to research existing and pending regulations in their area before buying one. Don't count on a dealer to give you accurate information about regulations- either current or proposed or you could wind up owning a boiler that is illegal to use. Beginning in 2007, some new OWBs were introduced with advanced combustion designs that pass a new voluntary EPA (Orange Tag) standard for outdoor units. If they perform as well in the field as they have in the testing labs, these new boilers will provide many benefits over the older technology, including more heat for less wood and less smoke and pollutants. In addition, the newer EPA compliant units are likely to be exempt from the state and local bans currently being implemented. 4 http: /www. hearth. com /econtent/index.php /articles /owb 2/9/2011 Outdoor Wood Boilers OWB An Introduction Greenwood Aspen EPA Approved OWB Note that there are also some "hybrid" gasification boilers entering the market now (2008) which are basically indoor boilers housed in a shed and adapted for outdoor use. These are typically pressurized units which have smaller (5 -10 cubic foot) fireboxes than traditional OWBs. If you decide to buy an OWB, it is important to follow common sense wood burning wisdom such as: Page 3 of 5 1. Burn seasoned wood only: Green and wet wood will give you MUCH less heat, regardless of what the salesman tells your 2. Do not burn trash, tires, plastics, etc. Doing so will not only pollute your neighborhood and the environment, but it may corrode the steel firebox of your boiler. 3. Raise the chimney for best operation: many OWBs allow for installation of a taller stack (chimney) than the short stub that comes from the factory. Extending the chimney will result in better operation and help dissipate any smoke. 4. Do not use year- round: Smoldering your wood in the spring and fall will cause excess smoke, low efficiency and may contribute to a shorter life of the steel in your boilers firebox. 5. Learn and follow both the manufacturers instructions and local codes pertaining to setback from pro perty lines, distance to house, chimney height and other criteria for proper installation. As with any wood burner, it is important to consider your wood supply before deciding on a particular appliance. An OWB with a large firebox will require copious amounts of firewood, often from 8 to 14 full cords per year, making them most suitable for folks with access to their own woodlots. There are many manufacturers of OWBs, including both regional and national brands. Be certain to research the makers of any OWBs you may be considering to determine their reputation as well as the longevity and durability of their products. An OWB is a substantial investment and your unit should be built to last for at least 15 -20 years. 5 http: /www. hearth. com /econtent/index.php /articles /owb 2/9/2011 Outdoor Wood Boilers OWB An Introduction Olin {a[c Y l tl.:l 4. 0 Allr IA. '.1; l.'a yl 1 "7, ,.1!. Ili '11; '1Y -4 l t Z:�'r# I znil:�i "t ill .i∎j' ',4 F 10 ro` r.lz- -x1 xS� ?��k Jr!' II OUTDOOR WOOtf- immp HEATERS SMOKE EMISSIONS• RANGE Lower Gmisstons Ni Emiaslons 0.1 2;0 0.6 0.6 EPA EMISSIONS LEVEL 'TN #MOTEL Outdoorwood,drod hoatorsvlth lower orrassloili prode..Tess sokeN4 on fndldt ed and opct IEd properly t y 1 (YA1; liil!.li S r 1.:;� 14 Ia EPA Hang Tag for OWB With the new breed of efficient OWBs entering the marketplace, this tried and true approach to heating with wood is sure to remain popular among farmers, large landowners and other rural residents. With proper design, installation, fueling and operation, the new EPA OWBs can provide a clean way of heating with locally harvested firewood. Links: http: /www.vtwoodsmoke.org/ State of VT Outdoor Wood Boiler ban info http: /www.epa.gov /owhh/ EPA site detailing voluntary clean burn information for OWBs Please rate this article by clicking once on the Like or Dislike box below: -click one Like Dislike 12 likes 2 dislikes Article Originally Posted By: Webmaster On 06/11/2008 at 09:21 PM Page 4 of 5 6 http: /www. hearth. com /econtent/index.php /articles /owb 2/9/2011 OUTDOOR WOOD FURNACE BEST BURN PRACTICES 1. Read and follow all operating instructions supplied by the manufacturer. 2. FUEL USED: Only those listed fuels recommended by the manufacturer of your unit. Never use the following: trash, plastics, gasoline, rubber, naphtha, household garbage, material treated with petroleum products (particle board, railroad ties and pressure treated wood), leaves, paper products, and cardboard. 3. LOADING FUEL: For a more efficient burn, pay careful attention to loading times and amounts. Follow the manufacturer's written instructions for recommended loading times and amounts. 4. STARTERS: Do not use lighter fluids, gasoline, or chemicals. 5. LOCATION: It is recommended that the unit be located with due consideration to the prevailing wind direction. Furnace should be located no less than 100 feet from any residence not served by the furnace. If located within 100 feet to 300 feet to any residence not served by the furnace, it is recommended that the stack be at least 2 feet higher than the peak of that residence. Chimney Height Installation Scenario 2 feet Chimney height should be 2 feet above roof line Residence not served by furnace lll1IIII III Residence served by furnace 6. Always remember to comply with all applicable state and local codes. Minimum of 100 feet pwi HeaHt,, PAilo a Barbwuo Aatocta1on OUTDOOR FURNACE MANUFACTURERS CAUCUS 7 .d you know that by changing the way you burn wood �'y you can Y save monn.ey, reduce air pollution and protect ::U �ur health? Clea ashes from your wood burning appliance Excess ashes can clog the air intak v nts r ducin fficlen Be s re to e e e e c u g Y dis o of (i es in a metal: container::awa F� y from the house or any flarimmable material to r e uce Elie r of fr d k Follow:: instructlons. Operate your wood burning appliance according to the manufacturer's instructions and follow all maintenance procedures: Upgrade to cleaner equipment. EPA- certified wood stoves and fireplace inserts burn cleaner and burn wood more ef ficiently emitting less particle pollution than older models. Here area few simple tip, to make your fire burn hotter, keep your wallet fatter and kee p your local an cleaner and healthier. Season all firewood. All firewood should be split securel: covered or stored, and aged Y aged g for at (east six months, .Seasoned wood burns hotter, cuts fuel consumptiori and reduces the amount Of smoke your appliance produces. Choose the right firewood; Hardwoods are the best. Never burn trash or treated wood which can emit toxic air pollutants. A Start it right. Use only clean newspaper or dry kindling to start a fire. Never use gasoline; kerosene, charcoal starter, or a propane torch: 4 Don't let the fire smolder. Many people think they should let a fire smolder overnight: But reducing the air supply does little for heating and increases air pollution Kee our;chimne. clean.: A clean: chimn.e provides good draft for your wood burning appliance and reduce the risk of a chimney tire: Have a certified professional inspect your c imney once a year, d Be a good neighbor: Follow best practices �5p .for burning :wood:: Always remember to comply with state and local codes and check your air: quality forecast: A Size matters. Choose the right-sized appliance for your needs. If your wood- burning appliance is too big for your room or house, the fuel will smolder and create more air pollution. EPA For more information on how to burn wise, go to www.epa.gov /burnwise EPA- 456/F -09 -004 Nancy Carver From: Heil, Cynthia L (DEC) [cindy.heii @alaska.gov] Sent: Friday, February 25, 2011 12:50 PM To: Nancy Carver Subject: FW: NESCAUM outdoor hydronic heater outdoor wood boiler information Attachments: NESCAUMowbfactsheet.pdf; NESCAUMModelRegOutdoorHydronicHeaters .pdf Nancy, here is some information for you to start looking at that I think you will find extremely helpful. This is a huge issue in the NorthEast and they have been at the forefront. There are also regulations in Washington State that currently pretty much make it impossible to have them. Fairbanks also has completely banned OWB new installation in some areas. From: Hardesty, Joan E (DEC) Sent: Fri 2/25/2011 12 :45 PM To: Heil, Cynthia L (DEC) Subject: NESCAUM outdoor hydronic heater outdoor wood boiler Information http: /www.nescaum.org /topics /outdoor- hydronic- heaters the NESCAUM site. This page has links to the Outdoor Hydronic Heater (outdoor wood boiler) model regulation, fact sheet, other state model regulations, etc. "NESCAUM" is the NorthEast States for Coordinated Air Use Management CT, ME, MA, NH, NJ, NY, RI, VT. I think NESCAUM has the best info available about OHH, they had the first model rule reg, and have links to other states on their site. Below are the model reg, and an informative fact sheet about OHH OWBs. «NESCAUMowbfactsheet.pdf» NESCAUMModelRegOutdoorHydronicHeaters .pdf» Joan 1 9 NESCAUM Model Regulation for Outdoor Hydronic Heaters 1 Outdoor Hydronic Heater Model Regulation January 29, 2007 This document contains a model rule to assist state and local agencies in adopting requirements that will reduce air pollution from outdoor hydronic heaters (e.g., outdoor wood-fired boilers). It was developed in cooperation with a number of states and the U.S. Environmental Protection Agency (EPA). The model regulation is intended to assist government agencies in enacting their own regulations, thus are advisory in nature. The purpose of the model rule is to promote cleaner outdoor units through common standards across the states that will protect air quality and public health while reducing the compliance burden on manufacturers, thus the emphasis on the critical elements listed below. By controlling air pollution from these currently unregulated sources, the model rule can also serve to level the playing field with previously regulated indoor residential wood burning devices. Since 1988, the federal government has applied emission standards to most wood -fired residential heating devices under its Residential Wood Heater New Source Performance Standards. Outdoor wood -fired hydronic heaters, however, are not included in this regulation and do not have to comply with other boiler emission requirements. Therefore, unlike other solid fuel devices, these pollution sources have no federal regulatory emission standards. With an increase in their use and potential health impacts from their emissions, next door neighbors, local communities, and air quality agencies have a heightened concern about the current and future impacts of these devices. The various provisions of this model rule are suggestions and examples. To ease the compliance burden on manufacturers, NESCAUM recommends that air quality agencies at a minimum adopt certain critical elements of the model rule. We highlight these elements in the model rule using italicized bold text. The critical elements include: o Critical definitions o Emission standards o Test method procedures o Certification process o Labeling requirements The model rule contains a single method for regulating new units with respect to the critical elements and contemplates that states may propose alternative approaches for other provisions.. It also provides alternatives for states to consider for regulating previously installed units. Items in regular font are recommendations that states should consider, however, given the wide variety of local concerns and varying statutory requirements, these sections should be tailored to meet individual states' needs. Format of this Document: All [bracketed bold] sections require filling in a name, address, governmental body, date, or other information. While "[state" is typically listed for filling in, this model rule can be adapted to local agencies that have authority to limit emissions from these sources. Italicized bold text identifies critical elements that are recommended for adoption by all regulatory agencies undertaking this effort. Footnotes contain explanations or identify issues associated with various aspects of the model rule. 10 NESCAUM Model Regulation for Outdoor Hydronic Heaters 2 1. Applicability 2. Definitions Model Regulation for Outdoor Hydronic Heaters A. This Regulation applies statewide. B. This Regulation applies, in its entirety, to any manufacturer, supplier, distributor or person intending to sell, lease, distribute, or market, an outdoor hydronic heater in [state] that meets the definition of an outdoor hydronic heater and to any person who installs, operates or owns an outdoor hydronic heater. A. At Retail "At Retail" means the sale by a commercial owner of an outdoor hydronic heater. B. Clean wood "Clean wood" means wood that has no paint, stains, or other types of coatings, and wood that has not been treated with, including but not limited to copper chromium arsenate, creosote, or pentachlorophenol. C. Commercial size heater "Commercial -size heater" means a heater with a rated thermal output greater than 350,000 Btu/hr as rated by the test method identified in Section 7C of this Regulation. D. Distribute or sell "Distribute or sell" means to distribute, sell, advertise for sale, offer for sale, lease, ship, deliver for shipment, release for shipment, or receive and (having so received) deliver or offer to deliver. This term does not include the distribution or sale by a manufacturer of an outdoor hydronic heater that is installed outside the State. E. Existing unit "Existing unit" means an outdoor hydronic heater that is available for sale (or is installed and/or operational at the intended location of use) at retail, wholesale or in the open market as of the promulgation date of this Regulation. F. Heater Efficiency "Heater efficiency" means the ratio of the delivered useful heat output measured by the test methods referenced in Section 7B of this Regulation to the calculated heat input of the heater. G. Installed Units "Installed units" means any unit sold (or is installed and/or operational at the intended location of use) prior to the promulgation of this Regulation, H. Manufactured "Manufactured" means built and operational, and subsequently ready for shipment (whether packaged or not). 11 NESCAUM Model Regulation for Outdoor Hydronic Heaters 3 I. Manufacturer "Manufacturer" means any person who constructs or imports into the United States an outdoor hydronic heater, J. Model line "Model line" means all outdoor hydronic heaters offered for distribution or sale by a single manufacturer that are substantially similar in design and make as determined by the Department. K. New model "New model" means an outdoor hydronic heater of a new design including a new thermal output rating that is not available for sale at retail as of the promulgation date. L. Nuisance "Nuisance" means [insert state definition of nuisance]. M. Opacity "Opacity" means the degree to which emissions other than water reduce the transmission of light and obscure the view of an object in the background. N. Outdoor hydronic heater' "Outdoor hydronic heater" means a fuel burning device designed to (1) burn wood or other approved solid fuels; (2) that the manufacturer specifies for outdoor installation or installation in structures not normally occupied by humans (e.g., garages); and (3) heats building space and /or water via the distribution, typically through pipes, of a fluid heated in the device, typically water or a water /antifreeze mixture. 0. Particulate matter or PM "Particulate matter or PM" means total particulate matter including PM10 and PM2.5 (condensable and non condensible fraction). P. Residential -size heater "Residential -size heater" means a heater with a rated thermal output of 350,000 Btu /hr or less as rated by the test method identified in Section 7C of this Regulation. Q. Sale "Sale" means the transfer of ownership or control. R. Similar in all material respects "Similar in all material respects" means that the construction materials, exhaust and inlet air system, and other design features are within the allowed tolerances for components identified in Section 6H of this Regulation. S. Startup period "Startup period" means the time period beginning with flame stability after first charge of wood fuel and is no longer than a two hour duration. This definition only includes initial startup where no previous coal bed exists. This does not include refueling. The critical element is the definition, not the term therefore states can choose which term they prefer but all should use the same definition, which is purposely broad in its scope. 12 NESCAUM Model Regulation for Outdoor Hydronic Heaters 4 3. Prohibitions A. Outdoor hydronic heaters that have not been certified, as set forth in Section 6, to meet the Phase 1 or Phase 11 emission standard, as set forth in Section 4 of this Regulation, and are purchased between the rule promulgation date and March 31, 2008 must be installed 500 feet or more from a property line and must have a permanent stack extending five feet higher than the peak of any roof structure located within 150 feet of the outdoor hydronic heater. B. Effective March 31, 2008 no person shall: 1. Import, supply, distribute or sell, install or allow the installation of any outdoor hydronic heater subject to this Regulation unless it has been certified as set forth in Section 6 to meet the applicable emission limit set forth in Section 4A(1) or 413(1) of this Regulation. 2. Outdoor hydronic heaters that meet the applicable 4A(1) or 4B(1) emissions standard but not the 4A(2) or 4B(2) requirements must also meet the following requirements: must be installed 500 feet or more from a property line and must have a permanent stack extending five feet higher than the peak of any roof structure located within 150 feet of the outdoor hydronic heater. C. Effective March 31, 2010 no person shall: 1. Import, supply, distribute or sell, install or allow the installation of any outdoor hydronic heater subject to this Regulation unless the outdoor hydronic heater has been certified, as outlined in Section 6, to meet the applicable emission limit set forth in Section 4A(2) or Section 4B(2) of this Regulation. 2. Siting requirements: a) Units that meet the emission standard defined in Section 4A(2): No setback or stack height requirement. b) Units that meet the emission standard defined in Section 4B(2): Outdoor hydronic heaters must be installed 300 feet or more from a property line and must have a permanent stack 2 Setback requirements are based on average background conditions of 15 ttg /m States may need to adjust setbacks accordingly, either greater or lesser, based upon a region's background conditions for fine particulate matter. States may choose to regulate setbacks based upon property lines or based upon the nearest building. A Setback and stack height requirements should also be codified in building codes. 5 Setback requirements are based on average background conditions of 15 1.1g /m states may need to adjust setbacks accordingly, either greater or lesser, based upon a region's background conditions for fine particulate matter. 13 NESCAUM Model Regulation for Outdoor Hydronic Heaters 5 extending five feet higher than the peak of any roof structure located within 150 feet of the outdoor hydronic heater. D. No person shall operate an outdoor hydronic heater from April 15 to September 30 unless the outdoor hydronic heater has been certified, as outlined in Section 6, to meet the emission limit set forth in Section 4A(2) or 4B(2) of this Regulation, E. Prohibited fuels. No person shall burn any of the following items in an outdoor hydronic heater: 1. Any wood that does not meet the definition of clean wood; 2. garbage; 3. tires; 4. lawn clippings or yard waste; 5. materials containing plastic; 6. materials containing rubber; 7. waste petroleum products; 8. paints and paint thinners; 9. chemicals; 10. coal; 11. glossy or colored papers; 12. construction and demolition debris; 13. plywood; 14. particleboard; 15. salt water driftwood; 16. manure; 17. animal carcasses; and 18. asphalt products. F. Outdoor hydronic heaters must comply with all applicable laws, including but not limited to local ordinances. G. No person shall operate an outdoor hydronic heater in such a manner as to create a public or private nuisance. Local Boards of Health may enforce this provision according to their general authority to enforce nuisance conditions within the State Air Quality Regulations. 4. Particulate Matter Emission Standard for New Units A. Residential Hydronic Heaters 6 Setback requirements are based on average background conditions of 15 }rg/m States may need to adjust setbacks accordingly, either greater or lesser, based upon a region's background conditions for fine particulate matter. 14 NESCAUM Model Regulation for Outdoor Hydronic Heaters 6 1. Phase I Emission Standard No person shall distribute or sell, lease, import, or install an outdoor hydronic heater after March 31, 2008 unless it has been certified to meet a particulate matter emission Iimit of 0.44 pounds per million British thermal units (1b/MMBtu) heat input In addition, units meeting the Phase I limit must be installed according to the setback and stack requirements, as defined in section 3B(2), and the seasonal operation limit, as defined in section 3D of this Regulation. Compliance with this particulate emission limit shall be determined in accordance with the test methods and procedures in Section 6 and 7 of this Regulation. 2. Phase II Emission Standard No person shall distribute or sell, lease, import, or install an outdoor hydronic heater after March 31, 2010 unless it has been certified to meet a particulate matter emission limit of 0.32 lb/MMBtu heat output. In addition, within each of the burn rate categories, no individual test run shall exceed 18 grams per hour. Compliance with this particulate emission limit shall be determined in accordance with the test method and procedures in Section 6 and 7 of this Regulation. B. Commercial -size Hydronic Heaters 1. Phase I Emission Standard No person shall distribute or sell, import, or install a commercially sized outdoor hydronic heater after March 31, 2008 that has not been tested to meet a particulate matter emission limit of 0.44 lb/MMBtu heat input In addition, units meeting the Phase I limit must be installed according to setback and stack requirement, as defined in section 3B(2), and the seasonal operation limit, as defined in section 3D of this Regulation. Compliance with this particulate emission limit shall be determined in accordance with the test methods and procedures in Section 6 and Section 7 of this Regulation. 2. Phase II Emission Standard No person shall distribute or sell, import, or install an outdoor hydronic heater after March 31, 2010 that has not been certified, as set forth in Section 6, to meet a particulate matter emission limit of 0.32 lb /MMBtu heat output. In addition, within each of the burn rate categories, no individual test run shall exceed 20 grams per hour. In addition, units meeting the commercial Phase II limit must be installed according to setback and stack requirements, as defined in section 3C(2). Compliance with this particulate emission limit shall be determined in accordance with the test method and procedures in Section 6 and 7 of this Regulation. 7 The Phase I emission rate is based upon a technology transfer analysis. NESCAUM believes that there are several units currently on the market that can meet this standard. 8 The Phase II emission rate is based upon a technology forcing and public health impact analysis. NESCAUM believes that there is one unit currently available that can meet this standard. 15 NESCA UM Model Regulation for Outdoor Hydronic Heaters 7 C. Visible Emission Standard 1. No person shall cause or allow the emission of a smoke plume from any outdoor hydronic heater to exceed an average of 20 percent opacity for six consecutive minutes in any one -hour period. 2, Exception. Visible emissions may not exceed 40 percent opacity for 20 consecutive minutes during the startup period of a new fire. This only includes initial firing of the unit where no coal bed exists. This exception does not apply to refueling. D. Installed Units 5. Fuel Requirements 1, Option A Time Limit Removal Program. All installed and existing outdoor hydronic heaters within the State that do not meet the applicable emission limits defined in Section 4A(2) or 4B(2) shall be removed from all properties by [date] or rendered permanently inoperable by [date]. It shall be a violation of this section for any person on or after [date] to possess or operate an outdoor hydronic heater within [state] unless it is certified to meet the Phase II emission limits as defined in Section 4 of this Regulation, unless it has been rendered permanently inoperable. 2, Option B Prior Sale or Transfer of Real Property. Prior to the completion or consummation of a sale or transfer of any real property on or after [date], all existing and/or installed outdoor hydronic heaters that do not meet the Phase II emission standard as defined in Section 4 of this Regulation shall be replaced, removed, or rendered permanently inoperable. 3. Option C Setback and Stack Height Requirement for Installed Units. All existing and installed outdoor hydronic heaters that do not meet the Phase II emission standard as defined in Section 4 if this Regulation within the State shall either meet the Phase I setback and stack height requirements, as defined in Section 4A of this regulation, or be removed from all properties by [date] or rendered permanently inoperable by [date]. The outdoor hydronic heater must be installed 500 feet or more from a property line. The outdoor hydronic heater must have a permanent stack extending five feet higher than the peak of any roof structure located within 150 feet of the outdoor hydronic heater. 9 The section for installed units is intended for states that wish to address units installed prior to rule promulgation. States may choose to implement one of the three options or combinations of options or defer to local governments to address existing outdoor hydronic heaters. 16 NESCAUM Model Regulation for Outdoor Hydronic Heaters 8 A. No person that operates an outdoor hydronic heater shall use a fuel other than the following: 1. Clean wood; 2. Wood pellets made from clean wood; 3. Home heating oil in compliance with the applicable sulfur content limit or natural gas may be used as starter fuels for dual -fired outdoor hydronic heaters; and 4. Other fuels as approved by the Department. 6. Certification' A. Certification Requirement 1. No person shall supply, distribute, sell, lease, offer for sale, or allow the installation of an outdoor hydronic heater in [state] unless the Department, or equivalent authority approved by [state], has issued a certification to the manufacturer that the outdoor hydronic heater, or model line to which it belongs, complies with the particulate matter standard in Section 4 of this Regulation. A certification shall be valid for a period of five years unless revoked by the Department. 2. Certifications for units that meet the Phase I emission limit but not the Phase II as defined in Section 4 of this Regulation will expire prior to the compliance date for Phase II as defined in Section 3C. B. Certification Procedure: For each model line, units must demonstrate compliance with the applicable emission standard, which may be determined based on testing of a representative number of units within a model line. In order for an outdoor hydronic heater or new model line to obtain a certification by the State, the manufacturer of any such heater shall conduct testing via EPA's Environmental Technology Verification Program and submit the results to the State for its review and approval, or via an alternative program approved by the State. C. Issuance of Certification: The Department shall issue a certificate of compliance for a model line if it determines, based on the information submitted by the applicant and any other relevant information available to them, that: 1. A valid certification test has demonstrated that a representative unit of a model line complies with the applicable particulate matter emission Iimit 10 States must adopt a certification program, however, states may revise this section as necessary. Appendix A contains a draft of a state certification program. 17 If certification test results were: If yearly production per model is: <500 total production =500 total production 70% or less of the PM emission standard When directed by the State not to exceed one of every 1,000 units Every 1,000 units or triennially (whichever is more frequent) 30% or less of the PM emission standard Every 2,000 units Every 2,000 units or annually (whichever is more frequent) NESCA UM Model Regulation for Outdoor Hydronic Heaters 9 as defined in Section 4 of this Regulation To be valid, a certification test must be: a) Announced in accordance with Section 7E of this Regulation; b) Conducted by an accredited testing facility in accordance with Section 6F of this Regulation; c) Conducted on a unit similar in all materials respects to other units of the model line to be certified; and d) Conducted in accordance with the test methods and procedures specified in Section 7B of this Regulation. 2. A statement shall be made by the manufacturer to the effect that any tolerances for materials or components listed in Section 6H of this Regulation that are different than those specified in the applicable model specifications may not reasonably be anticipated to cause units within the model line to exceed the applicable emission limit. D. Denial of Certification Upon denying a certification under this paragraph, the Department or its designee shall give written notice to the manufacturer setting forth the basis for its determination. E. Quality Assurance Program For each certified model line, the manufacturer or its designee shall conduct a quality assurance program that, at a minimum, includes the following requirements: 1. The manufacturer or authorized representative shall inspect one in every 150 units produced within a model line to determine that the units are within applicable tolerances for all components that affect emissions as listed in Section 6H of this Regulation. 2. The manufacturer or authorized representative shall conduct an emission test on a randomly selected unit produced within a model Iine on the following schedule: 18 NESCA UM Model Regulation for Outdoor Hydronic Heaters 10 3. The emission test shall be conducted in conformity with Section 7B of this Regulation. The manufacturer shall notify the State by US mail that an emissions test required pursuant to this paragraph will be conducted within one week of mailing the notification. 4, If the manufacturer uses a different material for the firebox, firebox component, or hydronic heating mechanism than the one used for certification testing, the first test shall be performed before 500 units are produced. The manufacturer shall submit a report of the results of this emission test to the State within 45 days of completion of testing. F. Approved Test Facilities An accredited laboratory shall conduct all of the testing, test reporting, and product inspection requirements of this Regulation. Emission testing for certification shall be conducted by an independent contractor who has no conflict of interest or financial gain in the outcome of the testing. G. Laboratory Accreditation Requirements In order to qualify for accreditation under this Regulation, a test laboratory shall first be accredited: 1. by the U.S. Environmental Protection Agency (EPA) for testing wood burning residential space heaters in accordance with 40 CFR Part 60, Subpart AAA, Section 60.535; 2. by the American National Standards Institute (ANSI) to the International Standards Organization (ISO) Standard ISO /IEC Guide 65 General Requirements for Bodies Operating Product Certification Systems; and 3. by a nationally recognized accreditation body to ISO /IEC 17025, General Requirements for the Competence of Testing and Calibration Laboratories. 4. The nationally recognized accrediting body itself shall be accredited to, and operate under ISO Guide 58 (Calibration and Testing Laboratory Accreditation Systems General Requirements for Operation and Recognition), and 5. by a nationally recognized accreditation body to the American Society for Testing and Materials (ASTM) Standard Practice D7036 -04; Competence of Air Emission Testing Bodies. H. Laboratory Audits Laboratory operations and recordkeeping audits by ANSI or another nationally recognized accrediting body shall be conducted at least annually and the audits shall be specific to the laboratory operations directly responsible for conducting the testing, certification, and inspection services 19 NESCAUM Model Regulation for Outdoor Hydronic Heaters 11 required by this Regulation. Results of the audit will be provided to [state] on March 1st of each year for its review, I. Re- certification The Department shall determine the frequencyof certification testing of an outdoor hydronic heater or model line, with a minimum frequency of at least once in every five years of the outdoor hydronic heater or model line made available at retail. J. Change in Design Parameter A model line must be re- certified whenever any change is made in the design that is presumed to affect the particulate emission rate for that model line. Changes that are presumed to affect particulate emission rates for model lines include: 1. Tolerance changes: any change in the indicated tolerances of any of the following components is presumed to affect particulate emission rates if that change exceeds ±0.64 cm 1 /4 inch) for any linear dimension and ±5 percent for any cross sectional area relating to air introduction systems and catalyst bypass gaps unless other dimensions and cross sectional areas are previously approved by the State; 2, Firebox: dimensions; 3. Air inductions systems: cross sectional area of restrictive air inlets, outlets and location, and method of control; 4. Baffles: dimensions and location; S. Refractory /insulation: dimensions and location; 6. Catalyst: dimensions and location; 7. Catalyst bypass mechanism: dimensions, cross sectional area, and location; 8. Flue gas exit: dimension and location; 9. Door and catalyst bypass gaskets: dimension and fit; 10. Outer shielding and coverings: dimension and location; 11. Fuel feed system; 12. Forced air combustion system: location and horsepower of blower motors and fan blade size. 20 NESCAUM Model Regulation for Outdoor Hydronic Heaters 12 K. Material changes Any change in the materials used for the following components is presumed to affect emissions: 1. refractory /insulation; 2. door and catalyst bypass gaskets; 3. for catalyst equipped units change in catalyst make, model or composition; 4. heat exchanger; 5. heating fluids. L. Revocation of certification Certification of an outdoor hydronic heater may be revoked by the Department based on any of the following: 7. Testing Requirements 1. The outdoor hydronic heater does not meet the applicable particulate emission limit in Section 4 of this Regulation based on test data from retesting of the original unit used for certification testing; 2. A finding that the certification test was not valid; 3. A finding that the unit does not comply with the labeling requirements detailed in Section 9 of this Regulation; 4. Failure to comply with recordkeeping and reporting requirements detailed in Section 8 of this Regulation; 5. Physical examination showing that more than twenty percent of production units inspected are not similar in all material respects to the model used for certification testing; 6. Failure of the manufacturer to conduct a quality assurance program as detailed in Section 6E of this Regulation. M. Outdoor hydronic heaters certified to meet the Phase 1 emission limit, as defined in Sections 4A(1) and 4B(1) of this Regulation, shall be automatically revoked effective March 31, 2010. A. Test Facility 21 NESCAUM Model Regulation for Outdoor Hydronic Heaters 13 1. All emissions testing shall be conducted by an accredited, qualified, and independent testing consultant as defined in Section 6E who has no conflict of interest or financi al gain in the outcome of the testing. 2. Manufacturers of the outdoor hydronic heaters shall not involve themselves in the conduct of any emissions testing under Section 7 of this Regulation nor the operation of the unit being tested, once actual sampling has begun. B. Test Method Emission tests shall be conducted using one of the following: 1. EPA Method 28 OWHH Test Method, or 2. An alternative method approved by the Department. C. Btu Rating Testing to determine MMBtu/hr shall be conducted according to the test method defined in Section 7B of this Regulation. This testing determines the categorization of an outdoor hydronic heater as a commercial or residential -sized unit, D. Notice to State The manufacturer of the outdoor hydronic heater shall provide notice to the Department at least 60 days prior to any emission test to allow the Department to have an opportunity to have an observer present during the conduction of the test. If requested by the State, the manufacturer shall pay all expenses to allow for the observation of the test by a State representative. E. Test Protocols If there is any deviation from the test method defined in Section 7B(I) of this Regulation, the manufacturer of the outdoor hydronic heater shall provide the Department with a test protocol for approval by the Department in accordance with the testing requirements in Section 7 of this Regulation 45 days prior to the emission testing for certification. S. Notification by Manufacturers A. By March 1st each year, and as outdoor hydronic heaters are certified, manufacturers shall provide the following information in writing to any person to whom the manufacturer has distributed or sold or intends to distribute or sell, or for installation: 1. A list of all models of outdoor hydronic heaters that it manufactures; and 2. A list of models that have received certification to meet the particulate matter emission standards and certification requirements set forth in Section 4A and 4B respectively. 22 NESCA UM Model Regulation for Outdoor Hydronic Heaters 14 B. By March 1st of each year, a copy of all written information necessary to demonstrate compliance of Section 4, Section 6, and Section 8 of this Regulation shall be submitted to the Department. C. Within one month of promulgation of this Regulation, manufacturers and distributors of outdoor hydronic heaters shall notify all persons who purchase or plan to purchase an outdoor hydronic heater of the requirements in Section 3, Section 4, and Section 5 of this Regulation. D. Manufacturers must notify owners of installed units of the requirements of this Regulation. 9. Labeling Requirements for Manufacturer A. Permanent label Within three months of promulgation of this Regulation, any outdoor hydronic heater introduced into commerce into [state] shall meet the following label requirements: 1. Have a permanent label that shall: a) Be permanently affixed in a readily visible or accessible location; b) Be at least 31/2 inches long by 3 inches wide; c) Be made of a material expected to last the lifetime of the unit; d) Present required information in a manner so that it is likely to remain legible for the lifetime of the unit; e) Be affixed in such a manner that it cannot be removed from the appliance without damage to the label. The permanent label may be combined with any other label, as long as the required information is displayed, and the integrity of the permanent label is not compromised. 2. The permanent label shall display the following information: a) Month and year of manufacture; b) Model number or name; c) Serial number; 23 NESCAUM Model Regulation for Outdoor Hydronic Heaters 15 d) Thermal output rating in MMBtu/hr; e) Date of certification; f) Results of emissions standard testing in grams per hour and lb/MMBtu input and output for respective Phase 1 and Phase II certification testing as defined in Section 4 of this Regulation. B. Required Labeling each unit shall prominently display the following language on the outdoor hydronic heater: 1. Language stating, "It is unlawful to burn garbage, treated or painted wood, coal, tires, plastic and plastic products, rubber products, yard waste, lawn clippings, glossy or colored papers, construction and demolitio n debris, plywood, particleboard, salt water driftwood, manure, animal carcasses, asphalt products, waste petroleum products, paints, chemicals or any substance that normally emits dense smoke or obnoxious odors." 2. For units equipped with catalytic combustors, the following statement shall appear on the permanent label: "This unit contains a catalytic combustor that needs periodic inspection and replacement for proper operation. Consult owner's manual for further information. It is against the law to operate this unit in a manner inconsistent with operating instructions in the owner's manual, or if the catalytic element is deactivated or removed." C. Temporary Labeling All units shall have attached to them a temporary label that shall contain the following. 1. A statement indicating the compliance status of the model; 2. A graphic representation of the composite particulate matter emission rate as determined in the certification test, or as determined by the State; 3. A graphic representation of the efficiency of the model; 4. A numerical expression of the heat output range in British thermal units per hour (Btu/hr) rounded to the nearest 100 Btu /hr; 5. Statements regarding the importance of proper operation and maintenance; 6. The manufacturer and identification of the model. 24 NESCAUM Model Regulation for Outdoor Hydronic Heaters 16 10. Notice to Buyers 7. The temporary label shall: a) Not be combined with any other label or information; b) Be attached to the unit in such a manner that it can be easily removed by the consumer. D. Owner's Manual Each outdoor hydronic heater offered for sale or lease must be accompanied by an owner's manual that shall contain all the information listed below: 1. Proper thermal output capacity for matching with the building's thermal demands; 2. Proper installation information; 3. Operation and maintenance information; 4. Wood loading procedures, recommendations on wood selection, and warnings on improper fuels; 5. Fire starting procedures; 6. Proper use of air flow devices, if applicable; 7. Ash removal procedures; 8. For catalytic models, information pertaining to maintaining catalyst performance, maintenance procedures, procedures for determining catalyst failure or deterioration, procedures replacement, and information on warranty rights. 9. Persons operating this hydronic heater are responsible for operation of the hydronic heater so as not to cause a nuisance condition. Manufacturer guarantees, however, that proper operation of the outdoor hydronic heater in accordance with manufacturer's operating and maintenance procedures will not create a nuisance condition. A. No outdoor hydronic heater subject to the requirements of this Regulation shall be offered, sold, offered for retail sale, or leased within the State unless prior to any sales or lease agreement, the seller or dealer provides the prospective buyer or lessee with a copy of the Department's Regulation and a written notice stating that: 25 NESCA UM Model Regulation for Outdoor Hydronic Heaters 17 11. Nuisance Conditions 1. It is unlawful to burn garbage, treated or painted wood, coal, plastic and plastic products, rubber products, yard waste, lawn clippings, glossy or colored papers, construction and demolition debris, plywood, particleboard, salt water driftwood, manure, animal carcasses, asphalt products, waste petroleum products, paints, chemicals or any substance that normally emits dense smoke or obnoxious odors; 2. Installation of an outdoor hydronic heater may be subject to other applicable State and local stack height and setback requirements; 3. Use of an outdoor hydronic heater that meets the distance and stack height requirements provided in Section 3 of this Regulation may not be adequate in some areas due to terrain that could render the operation of an outdoor hydronic heater to be a nuisance or public health hazard; and 4. Gives the specific results of the average and maximum emission rates of particulate matter for the outdoor hydronic heater in grams per hour per the testing conducted in Section 7 of this Regulation and the average delivered heating efficiency as found in the test reports that were used for certification of the units as detailed in Section 7 of this Regulation. B. The written notice specified above shall be signed by the buyer or lessee at the time of purchase or lease to indicate receipt of notification of the requirements of this Section. Within seven days of making delivery of the outdoor hydronic heater into the possession of the buyer or lessee, the seller or dealer shall mail or otherwise provide a copy of the signed notice specified above to the Department. Said notice shall contain the name; address; telephone number of both the seller or dealer and the buyer or lessee; the location where the outdoor hydronic heater will be installed; and the make and model of the outdoor hydronic heater. A. No person shall cause or allow emissions of air contaminants to the outdoor atmosphere of such quantity, characteristic or duration that are injurious to human, plant or animal life or to property, or that unreasonably interfere with the comfortable enjoyment of life or property, Notwithstanding the existence of specific air quality standards or emission Limits, this prohibition applies, but is not limited to, any particulate, fume, gas, mist, odor, smoke, vapor, toxic, or deleterious emission, either alone or in combination with others. 26 NESCAUM Model Regulation for Outdoor Hydronic Heaters 18 Appendix A State Certification Application information 1. State Certification Program: Manufacturers requesting certification shall submit an application to the State. An application shall consist of two complete copies of applications and attachments. The application must be signed by the manufacturer or an authorized representative, and shall contain the following: A. The model name and/or design number. B. Four color photographs of the tested unit, showing the front, back and both sides. C. Engineering drawings and specifications of components that may affect emissions, including specifications for each component listed in Section 6H of this Regulation Manufacturers may use complete assembly or design drawings that have been prepared for other purposes, but should designate on the drawings the dimensions of each component listed in Section 6H of this Regulation. Manufacturers shall identify tolerances of components of the tested unit listed in Section 6H of this Regulation that are different from those specified in that paragraph, and show that such tolerances may not reasonably be anticipated to cause outdoor hydronic heaters in the model line to exceed the applicable emission limit. D. A statement whether the firebox or any firebox component will be composed of material different from the material used for the emission certification testing and description of any such differences. E. For applications to certify a model line for use with catalytic devices, a statement describing the manufacturers program to ensure consistency in the size of any gap in the catalyst bypass mechanism. F. A written report of the results of such tests, including a detailed description of the operating conditions of the heater during the tests, for review and approval by the Department or its designee, which shall include all documentation pertaining to a valid certification test, including the complete test report and, for all test runs, raw data sheets, laboratory technician notes, calculations, and test results. Documentation shall include the items specified in the applicable test methods. G. For units using catalysts, a copy of the catalytic combustor warranty. H. A statement that the manufacturer will conduct a quality assurance program for the model line that satisfies the requirements of Section 6E of this Regulation. I. A statement describing how the tested unit was sealed by the laboratory after completion of the certification testing. 27 NESCAUMModel Regulation for Outdoor Hydronic Heaters 19 J. A statement that the manufacturer will notify the certified Iaboratory, if the application for certification is granted, within thirty days of notification from the State. K. Statements that the outdoor hydronic heater offered for sale or lease will be: 1. Similar in all material respects to the unit submitted for certification testing, and 2. Will be labeled as defined in Section 9 of this Regulation. L. A statement that the manufacturer will comply with the recordkeeping and reporting requirements detailed in Section 8 of this Regulation. M. A written statement estimating the numbers of outdoor hydronic heaters that the manufacturer will produce in the first three production years. N. A statement that the manufacturer has entered into a contract with an accredited laboratory as defined in Section 6F of this Regulation that will: 1. Conduct random compliance audit testing at no cost to the manufacturer, if the State selects that Iaboratory to conduct the test, or 2. Pay the manufacturer the reasonable cost of a random compliance audit test, if the State selects any other laboratory to conduct the test. O. At the beginning of each test run in a certification test series, four photographs of the fuel load: one before and one after it is placed in the unit. One of the photographs shall show the front view of the load and the other shall show the side view. 28 OUTDOOR WOOD BOILER FACT SHEET Why the concern about OWBs? With increases in the cost of oil and natural gas, many people are turning to wood -fired appliances to provide heat and hot water. The recent increase in the use of outdoor wood boilers (OWBs) is of particular concern to public health and environmental agencies because the cumulative stack emissions from these appliances are usually significantly higher than other EPA certified wood burning appliances and, unlike wood and pellet stoves, are currently unregulated. In general, OWBs in residential or small commercial situations emit hundreds or even thousands times more fine particulate matter (i.e., pollutants) than produced from the burning of oil or gas. Research has shown that the fine particulates contribute to human health problems including cardiovascular disease, chronic lung conditions, and premature death. The most recent research has demonstrated that the health impacts of fine particulates are worse than previously realized, prompting the U.S. EPA to adopt stricter standards in 2006. Because most existing OWBs employ poor combustion design, they emit more fine particulates per energy produced than newer well designed indoor woodstove or properly designed wood furnaces that typically emit one to four grams of particulate matter per hour. Wood smoke also contains organic pollutants associated with the incomplete combustion of the wood. The toxic air pollutants that can result from this include benzene, formaldehyde, dioxin, and polycyclic aromatic hydrocarbons, all of which can cause cancer. While wood is a renewable resource and can be global warming neutral if harvested in a sustainable manner, these attributes are negated if people use inefficient devices that emit high amounts of particulate matter and air toxics. The technologies to burn wood cleanly are available and in use.' The long term effects of large numbers of people using inefficient wood burning technologies, such as unregulated OWBs, will be increased pollution levels, increased health care costs, and unnecessary early deaths. To put OWB emissions into perspective, NESCAUM estimates that the current generation of OWBs emits at least twenty times more emissions than the current generation of EPA- certified woodstoves, and emits as much particulate matter as 50 to 500 diesel trucks (depending on the truck age and level of control). States are requiring a number of particulate matter sources, such as diesel trucks, to reduce their emissions. States believe that OWBs should also be included because of their size and amount of emissions, as well as to level the playing field with other wood burning devices that are already subject to emission limits. 1 Based upon discussions with combustion experts, NESCAUM believes that OWBs have a great deal of flexibility and capability to use a variety of emission reduction techniques, in addition to those employed by indoor woodstoves. 2 Estimates are based on an OWB field test. This test generated an emission rate of 161 grams per hour for a 250,000 Btu unit with approximately a 50 percent fuel charge. 3 NESCAUM estimates that model year 2001 trucks emit 3 g /hr when idling, and that current diesel engines equipped with diesel particulate filters emit 0.3 glhr when idling. 29 What are OWBs? OWBs are known by various names: outdoor wood furnaces, outdoor wood -fired hydronic heaters, or waterstoves. They are often used to heat homes and buildings, provide domestic hot water, heat swimming pools and hot tubs, and heat agricultural operations, such as greenhouses and dairies. What do they look like? Most look like small freestanding metal tool sheds with stacks, but some are rectangular boxes or are cylindrical in shape. How do they work? Surrounding the firebox is a water jacket that can be heated. The OWB cycles water through the jacket to deliver hot water to a home, building, or other use. Water pipes run underground to deliver the hot water. OWBs have a cyclical operating pattern to control the fire and, in turn, the water jacket temperature. When the water temperature in the water jacket reaches the desired temperature, an air damper closes off air to the unit until the temperature drops and the air damper opens, creating an on/off cycle. When the damper is closed, the fire smolders and cools until the temperature of the water drops to a lower set point and the damper opens. These on/off cycles may go on for eight to 24 hours or more between fuel loadings, depending on the demand for heat. What size building do they heat? OWBs heat buildings ranging in size from 1,800 square feet to 20,000 square feet. How big are they? OWBs vary in size ranging from 115,000 Btu /hr up to 3.2 million Btu/hr, although residential OWBs tend to be less than 1 million Btu /hr. Typically, the dimensions of an OWB are three to five feet wide, six to nine feet deep, and six to 12 feet tall, including the height of the chimney. How big is the firebox? Firebox sizes will vary with each unit but tend to range in size from 20 cubic feet up to 150 cubic feet. Issues unique to OWBs OWBs have been a controversial form of wood heating in the northeastern and mid western US and Canada for several years. The controversy is caused largely by the smoke and health impacts that the emissions from OWBs have on neighbors, but there has also been concern about the use of the units to illegally burn materials other than natural wood. Specifically, concerns unique to OWBs include: Year Round Operation OWBs are designed to provide heat and hot water year round. Owners often use them in the warmer months not only for domestic hot water but also to heat swimming pools and spas. Smoke Three design parameters in OWBs 1) a water jacket surrounding the firebox, 2) large fireboxes, and 3) cyclic operation create a unit that even when operated properly emits large amounts of smoke. These design parameters, unlike EPA certified woodstoves, create an environment conducive to increased toxic and particulate emissions. In some cases, neighbors' indoor smoke and carbon monoxide alarms have been activated by the smoke from OWBs. 2 30 Short Stack Heights Stacks from OWBs, as per manufacturer's installation instructions, are usually less than 12 feet from the ground, resulting in poor dispersion of smoke and are more likely to cause very smoky conditions within surrounding areas. Increasing the stack height may help with dispersing the smoke but will not decrease the overall impact of OWB emissions. Oversized Firebox An OWB's large firebox is built such that a user could burn a variety of inappropriate materials that could not be burned in wood stoves or fireplaces. Enforcement programs have discovered OWBs burning tires, Iarge bags of refuse, and railroad ties. What are the policy options available to state and local government to address new OW13 units? Do nothing Delay will result in additional uncontrolled units being put in place. These units have an estimated lifespan of twenty years so the uncontrolled units installed now will be in place for a long time, contributing particulate matter and other air toxics to the airshed and reducing air quality locally and regionally. In addition, some units may cause serious local nuisance conditions. Zoning requirements This strategy would establish property line setbacks for OWBs to protect neighboring properties from nuisance smoke and odors. Preliminary modeling indicates that setbacks should be at least 500 feet away from neighbors, if the area does not have elevated particulate matter levels and the stack height is raised above the roofline of nearby buildings. In valley conditions, areas prone to thermal inversions or low wind speeds, these setbacks still may not be adequate to protect neighbors. Experience has shown that zoning requirements do not eliminate the problem and can be difficult to enforce. If jurisdictions adopt setback and stack height limits, efforts should be made to incorporate them into the building code. Emission standards This strategy would require the development of an emission limit for OWBs and prohibit the sale or installation of any unit that did not meet the standard. There are three potential approaches to creating a standard for OWBs: a simple particulate matter (PM) mass emission rate limit (grams /hour) regardless of an OWB 's rated output or actual thermal output; an emission rate limit that is tied to an OWB's rated output or actual average thermal output (pounds of PM /Btu or mg PM /megajoule); and a limit on the concentration of the PM in an OWB's the stack (grams /cubic meter or grains /cubic foot of exhaust gas). Although all three of these approaches could reduce particulate emissions from OWBs, only the first approach (grams /hour) specifically addresses both the regional and local aspect of OWB smoke. Bans This strategy would ban entirely the sales of all OWBs. Currently, only a limited of number of units have been tested that emit particulate matter at lower levels than the 3 31 units commonly sold on the market today. This strategy would reduce emissions from the older, dirtier OWBs and significantly reduce particulate emissions from these devices. EPA's Voluntary Program EPA has developed a voluntary program that encourages manufacturers of outdoor wood -fired heaters to make cleaner models available to consumers beginning in the spring of 2007. Under this agreement, the new models must emit no more than 0.6 pounds of particulate matter per million BTUs of heat input (i.e., wood burned). The models must be tested by an accredited third -party laboratory to verify that they meet these levels. The agreement requires participating manufacturers to make at least one model that meets the emission criteria. Initial estimates indicate that residential OWBs in this program could meet the emissions criteria with an overall emission rate of 95 grains per hour, more than twelve times higher than the emissions rate allowed for indoor wood stoves. Model Rule For agencies that wish only to allow the sale of cleaner units in their jurisdictions, NESCAUM, in conjunction with EPA and member states, developed a model rule to promote common standards across the states with additional provisions that can be tailored to address specific local situations. The model rule establishes emission limits and labeling requirements for new units and contains the following components for both new and existing outdoor wood -fired heaters. Specifically, the model rule: o Recommends a Phase I emission limit of 0.44 lb /mmBtu (heat input) effective 3/31/2008. o Recommends a Phase II emission limit of 0.32 lb /mmBtu (heat output) with no test run to exceed 18 g /hr for residential units and 20 g /hr for commercial units effective 3/31/2010. o Recommends setback requirements 500 feet from property lines and requries stack heights five feet over the roofline of nearby structures and residences for units that do not meet the Phase II emission limit. o Recommends distributor and buyer notification requirements. o Recommends common requirements for unit testing, certification, and labeling. What are the options for existing OWBs? Limits on use The strategy restricts or limits the use of existing OWBs to certain periods of time, such as limiting use to the heating season only and /or limiting use based upon air quality conditions, such as when high ambient particulate pollution levels are likely to occur. This strategy would address high emission events but would not address the day -to -day contribution of pollution from OWBs to the ambient air or where an OWB causes nuisance conditions for neighbors. Zoning requirement This strategy would require that existing OWBs meet a setback requirement. If the OWB cannot meet the requirement, removal of the unit would be required. The same factors regarding stack height and enforcement as described above for new OWBs apply to this approach. Stack height requirements While increasing stack heights would not reduce the total amount of pollution emitted from an OW13, it may assist in dispersing smoke. 4 32 However, no testing has been done to determine how raising the stack height will affect stack emissions. Discussions with combustion experts indicate that a height change will likely affect air flow rates, which could increase overall emissions from the OWB. In addition, this strategy would not address broader regional pollution caused by OWBs. Ban on use of polluting units This strategy would ban the use all OWBs that do not meet an emission requirement by a certain date. Change -out upon transfer of property Another strategy would require a certification prior to the completion of a sale or transfer of any real property on or after a certain date that states all wood burning appliances not meeting an applicable emission requirement have been replaced, removed, or rendered permanently inoperable. 5 33 Nancy Carver From: Jo Johnson [JJohnson @ci.homer.ak.us] Sent: Monday, February 28, 2011 1:40 PM To: Nancy Carver Subject: RE: City of Horner Alaska Website submission: Contact the City Hi Nancy, In response to your inquiry on outdoor wood burning boilers, the City of Homer does not have such an ordinance. I hope you find better results in other locations. Jo Johnson City Clerk City of Homer Original Message From: infoOci,homer,ak,us [mailto:info(aci.homer.ak.usl Sent: Friday, February 25, 2011 11 :56 AM To: Jo Johnson Subject: City of Homer Alaska Website submission: Contact the City <p> You may view the completed form here: http: /www.cityofhomer- ak.gov /node /9717 /submission /43 Details: Topic: Outdoor Wood Burning Boilers Details: The City o Kenai is looking into drafting an Ordinance regulating Outdoor Woodburning Boilers (OWBs). Does the City of Homer have an Ordinance, or additional information concerning OWBs? Thanks Nancy Carver Contact Information- First Name: Nancy Last Name: Carver Email address: ncarverPci,kenai.ak.us Phone number: 907 283 -8237 /p> 1 34 Nancy Carver From: Bergstrom, Leigh W. BergstromLW @ci.anchorage.ak.us] Sent: Thursday, March 03, 2011 5:28 PM To: Nancy Carver Subject: FW: OUTDOOR WOOD BURNING BOILER From: Hile, Gary A. Sent: Thursday, March 03, 2011 11:13 AM To: Bergstrom, Leigh W.; Noffsinger, Ross D. Subject: RE: OUTDOOR WOOD BURNING BOILER It appears you have it pretty well covered. I know that our Health Dept. (Air Quality) was working on an Ordinance for these types of installations, but not certain if it was ever formally adopted. Gary Hile Chief of Building Inspections Municipality of Anchorage Development Services Department Phone (907)343 -8330 Fax (907)249 -7428 From: Bergstrom, Leigh W. Sent: Thursday, March 03, 2011 10 :03 AM To: Noffsinger, Ross D.; Hie, Gary A. Subject: OUTDOOR WOOD BURNING BOILER Nancy Carver with the City of Kenai called asking what permits we would require for an outdoor wood burning boiler. know it would at least trigger mechanical and electrical permits and require a properly listed appliance installed In accordance with the manufacturers recommended installation instructions. Also, it would need a structural permit with plans and calculations for the supporting base and attachments. Another requirement would be a plot plan showing the location of the boiler with distances from other buildings and property lines. Are there any other considerations that should be included that I may have overlooked? 1 Thanks, Leigh 35 Nancy Carver From: Bergstrom, Leigh W. BergstromLW @ci,anchorage.ak.us] Sent: Thursday, March 03, 2011 5:28 PM To: Nancy Carver Subject: FW: OUTDOOR WOOD BURNING BOILER From: Noffsinger, Ross D. Sent: Thursday, March 03, 2011 1:30 PM To: Bergstrom, Leigh W. Cc: Hile, Gary A. Subject: RE: OUTDOOR WOOD BURNING BOILER They also need approval from the health dept, air pollution control officer. See 15.35.105 on municode. http:lllibrarvl ,municode.com /default- nowlhome.htm ?Infobase= 12717 &doc action= whatsnew Ross Noffsinger, P.E. Engineering Services Manager Development Services Division Community Development Department Municipality of Anchorage (907) 343 -8309 From: Bergstrom, Leigh W. Sent: Thursday, March 03, 2011 10:03 AM To: Noffsinger, Ross D.; Hile, Gary A. Subject: OUTDOOR WOOD BURNING BOILER Nancy Carver with the City of Kenai called asking what permits we would require for an outdoor wood burning boiler. know it would at least trigger mechanical and electrical permits and require a properly listed appliance installed in accordance with the manufacturers recommended installation instructions. Also, it would need a structural permit with plans and calculations for the supporting base and attachments. Another requirement would be a plot plan showing the location of the boiler with distances from other buildings and property lines. Are there any other considerations that should be included that I may have overlooked? 1 36 Thanks, Leigh Chapter 15.35 SOUTH CENTRAL CLEAN AIR ORDINANCE REGULATIONS Page 1 of 1 15.35.105 Stationary source emissions -Wood fired boilers. A. Unless otherwise prohibited by law, within the boundaries of the municipality no person shall cause, suffer, permit or allow the operation of a wood -fired boiler except when fired by: 1. Clean wood, or 2. Wood pellets made from clean wood; or 3. Corn; or 4. Home heating oil and natural gas as a starter fuel or substitute fuel in dual -fired wood boilers. B. Within the boundaries of the municipality the burning of wood that has been treated, painted, or treated with preservatives or other coatings is prohibited. C. Within the boundaries of the municipality the burning of used oil, waste petroleum products and home heating oil not meeting applicable limits for sulfur content is prohibited. D. Within the boundaries of the municipality, no person shall install or allow the installation of a wood -fired boiler subject to the requirements of this section unless: 1. The wood -fired boiler is located more than 50 feet from an adjacent property line and 100 feet from any habitable structure that it is not serving at the time of installation, unless that property or habitable structure is under common ownership; and 2. The wood -fired boiler has an attached permanent stack extending higher than the peak of the roof of the structure(s) being served by the wood -fired boiler, and higher than the peak of the roof of any other habitable structure located within 150 feet of the wood -fired boiler; and 3. The wood -fired boiler is certified to meet the U.S. Environmental Protection Agency voluntary phase 2 emissions level for wood -fired boilers through testing by an accredited independent laboratory showing it emits no more than 0.32 pounds of particulate matter per million BTUs of heat output; and 4. The wood -fired boiler complies with all applicable laws, including but not limited to local ordinances, and its operation does not create a public nuisance; and 5. Scaled drawings, prepared by a registered professional engineer or registered professional land surveyor, are submitted and approved by the air pollution control officer showing the wood -fired boiler will meet the separation requirements to adjacent property lines and habitable structures established in this subsection and that the stack of the boiler will be higher than the roof peak of any habitable structure within 150 feet. 6. Installation, modification and repair of a wood -fired boiler shall comply with the provisions of the Anchorage Building Code,Title 23of the Anchorage Municipal Code. (AO No. 2009- 41(S), 3, 7 -1 -09) 37 http: /library 1.municode.com/ default- now/DocView /12717/1/240/245 3/8/2011 Outdoor Wood burning Boilers (OWB) Notes: 38 February 28, 2011 Spoke with Angela Chambers, Planning Supervisor, Municipality of Anchorage, 343 -7940, ChambersACeci.anchorage.ak.us Municipality has no Ordinance for OWBs Complaints are currently covered under o Title 15.05 Environmental Protection (Dept. of Human Services) Impacting the use to adjoining properties. o Title 21.40.030(e)(2) RA R1A SFD Districts: "Prohibited uses and structures. The following uses and structures and prohibited: Any use which causes or may reasonably be expected to cause excessive noise, vibration, odor, smoke, dust or other particulate matter, toxic or noxious matter, radiation, humidity, heat or glare at or beyond any lot line of the lot on which it Is located. Operation of particle accelerator systems, including cyclotrons, is prohibited. The term "excessive" is defined for the purpose of this subsection as to a degree exceeding that generated by uses permitted in the district in their customary manner of operation, or to a degree injurious to the public health, safety, welfare or convenience." o Left Message with Don Craft, Development Services (Building Dept.), 343 -8301 to see if permits are required, and if he's aware of any that have been permitted. Title 23 City of Homer has no Ordinance for OWBs Cynthia Heil, ADEC, cindv.heil@alaska.gov -269 -7579 o Providing information, someone will attend the 3/23/11 Work Session. Phil North, EPA, north.phil @epa.gov 714 -2483 o 3/2/11 Sent an email. Definition: Setbacks: Lot Size: OWB Regulation Work Sheet Stack Height: Distance from Lot: Building Permit: Fuel Burning Restrictions: Other: 39