1 NSPS - REVIEW WESTAR-EPA-HPBA MEETING November 17 -19, 2009.

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NSPS - REVIEWNSPS - REVIEW

WESTAR-EPA-HPBA MEETINGWESTAR-EPA-HPBA MEETINGNovember 17 -19, 2009November 17 -19, 2009

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• ““Residential Wood Heaters” listed in Residential Wood Heaters” listed in 1988 [CAA §111(b)(1)(A)]1988 [CAA §111(b)(1)(A)]

– Covered:Covered:•Wood Stoves and Pellet StovesWood Stoves and Pellet Stoves

•Other Heating DevicesOther Heating Devices– Hydronic Heaters, Furnaces, Masonry HeatersHydronic Heaters, Furnaces, Masonry Heaters

– Excluded:Excluded:•FireplacesFireplaces

LISTED SOURCE CATEGORY

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Affected Facilities DefinitionAffected Facilities Definition

• Solid Fuel Heaters that meet the Solid Fuel Heaters that meet the following criteria:following criteria:

1.1. An air-to-fuel ratio averaging < 35-to-1, An air-to-fuel ratio averaging < 35-to-1,

2.2. A usable firebox volume < 20 cubic feet,A usable firebox volume < 20 cubic feet,

3.3. A minimum burn rate < 5 kg/hour, and;A minimum burn rate < 5 kg/hour, and;

4.4. A maximum weight < 800 kg (appliance A maximum weight < 800 kg (appliance only). only). 

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• Included:Included:– Wood Stoves & Fireplace InsertsWood Stoves & Fireplace Inserts– Pellet Stoves and Inserts if:Pellet Stoves and Inserts if:

•Air-to-fuel ratio <35:1Air-to-fuel ratio <35:1

– Factory-Built Fireplaces if:Factory-Built Fireplaces if:•Air-to-fuel ratio <35:1 and,Air-to-fuel ratio <35:1 and,

•minimum burn rate < 5 kg/hourminimum burn rate < 5 kg/hour

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• Exempted:Exempted:– FurnacesFurnaces– Boilers & Hydronic HeatersBoilers & Hydronic Heaters– Cookstoves meeting specific requirementsCookstoves meeting specific requirements– Open Site-Built Masonry FireplacesOpen Site-Built Masonry Fireplaces– Masonry HeatersMasonry Heaters– Coal-Only HeatersCoal-Only Heaters– Pellet Stoves and Inserts if:Pellet Stoves and Inserts if:

•Air-to-fuel ratio >35:1Air-to-fuel ratio >35:1

– Factory-Built Fireplaces if:Factory-Built Fireplaces if:•Air-to-fuel ratio >35:1 or,Air-to-fuel ratio >35:1 or,•minimum burn rate > 5 kg/hourminimum burn rate > 5 kg/hour

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• HPBA POSITIONHPBA POSITION– ALL HEATERS SHOULD BE INCLUDEDALL HEATERS SHOULD BE INCLUDED

– FIREPLACES ARE NOT HEATERS AND FIREPLACES ARE NOT HEATERS AND SHOULD NOT BE INCLUDEDSHOULD NOT BE INCLUDED• Fireplaces would first have to be listed as an additional Fireplaces would first have to be listed as an additional

source category under CAA Section 111(b)source category under CAA Section 111(b)..– Would require a finding that new fireplaces "cause of Would require a finding that new fireplaces "cause of

contribute contribute significantly significantly to air pollution that may to air pollution that may reasonably be anticipated to endanger public health and reasonably be anticipated to endanger public health and welfare"welfare"

– Low frequency of use, low contribution to ambient levels, Low frequency of use, low contribution to ambient levels, adequacy of current control measures (e.g., bans, adequacy of current control measures (e.g., bans, voluntary program) for impacted areas, and the fact that voluntary program) for impacted areas, and the fact that efforts to develop cost reasonable fireplace controls are efforts to develop cost reasonable fireplace controls are in their infancy all argue against listing. in their infancy all argue against listing.

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HEATING DEVICES VS. NON-HEATING DEVICES VS. NON-HEATING DEVICESHEATING DEVICES

• Does the line distinguishing heaters Does the line distinguishing heaters from non-heaters need to be from non-heaters need to be reconsidered?reconsidered?– Air Fuel Ratio?Air Fuel Ratio?– Minimum Burn Rate?Minimum Burn Rate?– Other Design Features?Other Design Features?– Safety Listing?Safety Listing?

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Format of StandardsFormat of Standards

• Grams per Hour (g/hr)Grams per Hour (g/hr)– Used in the current NSPSUsed in the current NSPS

• Grams per Kilogram (g/kg)Grams per Kilogram (g/kg)

• Grams per Megajoule (g/MJ)Grams per Megajoule (g/MJ)

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•HPBA POSITIONS ON FORMATHPBA POSITIONS ON FORMAT

•NO “ONE SIZE FITS ALL”NO “ONE SIZE FITS ALL”– WOOD HEATERS AND PELLET HEATERS:WOOD HEATERS AND PELLET HEATERS:

G/HRG/HRSEPARATE EFFICIENCY RATING – NO SEPARATE EFFICIENCY RATING – NO

PASSING GRADE FOR EFFICIENCYPASSING GRADE FOR EFFICIENCY

– CENTRAL HEATING SYSTEMS:CENTRAL HEATING SYSTEMS:G/MJG/MJ

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Test MethodsTest Methods• How to operate the appliance?How to operate the appliance?

• How the measurements are made?How the measurements are made?

• How is the data used to rank How is the data used to rank performance?performance?– Weighting Factors?Weighting Factors?

• Current NSPSCurrent NSPS– OperationOperation

• EPA Methods 28 and 28AEPA Methods 28 and 28A

– Emission MeasurementEmission Measurement• EPA Methods 5G and 5HEPA Methods 5G and 5H

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• HPBA POSITIONS ON TEST METHODSHPBA POSITIONS ON TEST METHODS

– USE CONSENSUS TEST METHODS WHEN USE CONSENSUS TEST METHODS WHEN AVAILABLEAVAILABLE

– ASTM MethodsASTM Methods• E2515 – Particulate MeasurementE2515 – Particulate Measurement

• E2618 – Hydronic HeatersE2618 – Hydronic Heaters

• CSA B415.1 - EfficiencyCSA B415.1 - Efficiency

• E06.54.01 Task Group has been activated to address E06.54.01 Task Group has been activated to address other solid-fuel fired appliancesother solid-fuel fired appliances

– Two Working GroupsTwo Working Groups Wood HeatersWood Heaters Pellet HeatersPellet Heaters

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– CONSIDER ADJUSTING THE BURN RATE CONSIDER ADJUSTING THE BURN RATE CATEGORIES FROM FIXED KG/HR RANGES TO CATEGORIES FROM FIXED KG/HR RANGES TO PERCENTAGES OF THE MAXIMUM BURN RATE.PERCENTAGES OF THE MAXIMUM BURN RATE.

– ADJUST THE MINIMUM BURN RATE RANGE ADJUST THE MINIMUM BURN RATE RANGE UPWARD SOMEWHAT TO CORRECT FOR FLAW UPWARD SOMEWHAT TO CORRECT FOR FLAW IN CURRENT NSPS.IN CURRENT NSPS.

– INCREASE THE “5-MINUTE” START-UP TIME IN INCREASE THE “5-MINUTE” START-UP TIME IN

THE FUELING AND OPERATING TEST METHOD.THE FUELING AND OPERATING TEST METHOD.

– EFFICIENCY TESTING SHOULD BE REQUIRED EFFICIENCY TESTING SHOULD BE REQUIRED FOR ALL HEATERS FOR WHICH EMISSION FOR ALL HEATERS FOR WHICH EMISSION TESTING IS REQUIRED.TESTING IS REQUIRED.

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Determination of BDTDetermination of BDT

• HPBA POSITIONS ON BDT: HPBA POSITIONS ON BDT: – BDT NEEDS TO BE RIGOROUSLY DETERMINED BDT NEEDS TO BE RIGOROUSLY DETERMINED

BASED ON AVAILABLE DATA.BASED ON AVAILABLE DATA.

– NO “ONE SIZE FITS ALL”.NO “ONE SIZE FITS ALL”.

– DESIGN STANDARDS SHOULD BE CONSIDERED DESIGN STANDARDS SHOULD BE CONSIDERED FOR SOME PRODUCT TYPES:FOR SOME PRODUCT TYPES:• Pellet HeatersPellet Heaters

• Masonry HeatersMasonry Heaters

• CookstovesCookstoves

• Coal-Only HeatersCoal-Only Heaters

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– BDT is used to set the passing gradeBDT is used to set the passing grade•THE PASSING GRADE SHOULD BE BASED ON THE PASSING GRADE SHOULD BE BASED ON

BDT USING THE METHOD 5G/ASTM E2515 BDT USING THE METHOD 5G/ASTM E2515 DATA WITHOUT A “CORRECTION FACTOR”.DATA WITHOUT A “CORRECTION FACTOR”.

•THE PASSING GRADE MUST INCLUDE A THE PASSING GRADE MUST INCLUDE A COMPLIANCE MARGIN TO ACCOUNT FOR COMPLIANCE MARGIN TO ACCOUNT FOR VARIABILITY IN THE TEST METHODS.VARIABILITY IN THE TEST METHODS.

•SEPARATE PASSING GRADES FOR CATALYTIC SEPARATE PASSING GRADES FOR CATALYTIC AND NON-CAT TECHNOLOGIES? AND NON-CAT TECHNOLOGIES?

•NO PASSING GRADE FOR EFFICIENCY.NO PASSING GRADE FOR EFFICIENCY.

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Certification Procedures and Certification Procedures and Laboratory AccreditationLaboratory Accreditation

• The current NSPS:The current NSPS:– Model Line CertificationModel Line Certification

•A representative sample is tested at an EPA A representative sample is tested at an EPA accredited laboratory using EPA test methods.accredited laboratory using EPA test methods.

•The model line is certified upon approval of The model line is certified upon approval of certification application and issuance of certification application and issuance of certificate of compliance by EPA.certificate of compliance by EPA.

•Manufacturers must conduct on-going QA/QC Manufacturers must conduct on-going QA/QC program with random EPA audits/oversight.program with random EPA audits/oversight.

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Current NSPS QA/QC Current NSPS QA/QC

• Manufacturers perform regular “k-list” Manufacturers perform regular “k-list” parameter inspections and maintain parameter inspections and maintain records.records.

• Emission audit tests required based on Emission audit tests required based on model line production quantities and model line production quantities and proximity to passing grade.proximity to passing grade.

• Random Compliance Audits (RCA)Random Compliance Audits (RCA)– RCA surcharge added to certification test costs RCA surcharge added to certification test costs

to fund program.to fund program.

• Selective Enforcement Audits (SEA)Selective Enforcement Audits (SEA)

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• HPBA POSITIONHPBA POSITION– A REPRESENTATIVE SAMPLE IS TESTED AT A A REPRESENTATIVE SAMPLE IS TESTED AT A

NATIONALLY ACCREDITED THIRD PARTY NATIONALLY ACCREDITED THIRD PARTY LABORATORY.LABORATORY.

– ASTM, CSA OR OTHER CONSENSUS-BASED ASTM, CSA OR OTHER CONSENSUS-BASED TEST METHODS ARE USED WHEN AVAILABLE. TEST METHODS ARE USED WHEN AVAILABLE.

– CERTIFICATION BY NATIONALLY ACCREDITED CERTIFICATION BY NATIONALLY ACCREDITED THIRD PARTY PRODUCT CERTIFICATION THIRD PARTY PRODUCT CERTIFICATION AGENCIES/BODIES ISOAGENCIES/BODIES ISO• Guide 65 Guide 65 Third Party Product CertificationThird Party Product Certification

– EPA PROVIDES AN OVERSIGHT ROLE ONLY.EPA PROVIDES AN OVERSIGHT ROLE ONLY.

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Third Party Certification Third Party Certification QA/QCQA/QC

• Periodic Periodic UNANNOUNCEDUNANNOUNCED inspections (for inspections (for example, at manufacturer or importer facilities).example, at manufacturer or importer facilities).

• Verification that products being “Marked” as Verification that products being “Marked” as certified comply with design, process and QA certified comply with design, process and QA requirements.requirements.

• Documentation of results and reporting of any Documentation of results and reporting of any deficiencies or deviations.deficiencies or deviations.

• No product modifications allowed without review No product modifications allowed without review and verification of compliance with certification and verification of compliance with certification requirements.requirements.

• Certification Body must investigate and Certification Body must investigate and determine scope/severity of non-compliance.determine scope/severity of non-compliance.

• Determine appropriate remedial actions.Determine appropriate remedial actions.• If warranted, suspension or revocation of If warranted, suspension or revocation of

authorization to apply certification mark.authorization to apply certification mark.

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Compliance DateCompliance Date

• Current NSPSCurrent NSPS– Two tiers of the passing gradeTwo tiers of the passing grade

– Two tiers of deadlines for ManufacturersTwo tiers of deadlines for Manufacturers

– Additional deadlines for Distributor and Additional deadlines for Distributor and Retailer Sell ThroughRetailer Sell Through

2020

• HPBA POSITION ON COMPLIANCE HPBA POSITION ON COMPLIANCE DATEDATE– COMPLIANCE DATE PHASING COMPLIANCE DATE PHASING

NECESSARYNECESSARY•THE COMPLIANCE DATE STRUCTURE MUST THE COMPLIANCE DATE STRUCTURE MUST

CONSIDER DEVELOPMENT, TESTING CONSIDER DEVELOPMENT, TESTING CERTIFICATION AND MANUFACTURING LEAD CERTIFICATION AND MANUFACTURING LEAD TIMES. TIMES.

– New product types will be regulated.New product types will be regulated.– Existing NSPS products may require redesign and Existing NSPS products may require redesign and

recertification.recertification.– Safety listings may be impacted.Safety listings may be impacted.

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Labeling and Consumer Labeling and Consumer InformationInformation

• Current NSPSCurrent NSPS– Permanent LabelingPermanent Labeling

• Information about manufacturer, model and Information about manufacturer, model and certification status.certification status.

– Temporary Labeling (Hang Tag)Temporary Labeling (Hang Tag)• Contains information targeted at helping the Contains information targeted at helping the

consumer make an informed purchase.consumer make an informed purchase.– Performance informationPerformance information

– Owner’s ManualOwner’s Manual• Requires information to help the user to achieve the Requires information to help the user to achieve the

best appliance emission performance.best appliance emission performance.

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• HPBA POSITIONS HPBA POSITIONS – NO MAJOR CHANGES IN THE LABEL OR NO MAJOR CHANGES IN THE LABEL OR

OWNER’S MANUAL CONTENT OWNER’S MANUAL CONTENT REQUIREMENTS ARE NEEDED EXCEPT:REQUIREMENTS ARE NEEDED EXCEPT:•Measured efficiency values provided on Measured efficiency values provided on

temporary labeling where efficiency rating is temporary labeling where efficiency rating is required or available.required or available.