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Buckley Rumford Fireplaces Recommended Application Procedures San Jose, CA 1/2/08
"Michael Andersson"
Mike,
Nice to hear from you again. And this sounds like a good job for us.
As for certification, we have tested the 48" Rumford in a test lab and it is "certified" which is recognized in many areas, including Mammoth (I think). San Jose is a special case since in 2001 we sued San Jose and Palo Alto since they were the first cities to adopt the Bay Area Air Quality Management model rules which we thought unfairly held fireplaces to a non-existent EPA standard.
In the last couple of years, and in the hope of leaving all this politics behind us, we have joined with other metal and masonry fireplace manufacturers to develop a new ASTM fireplace emissions standard that EPA would recognize. The standard has just been passed - not even published yet - and we will begin to test to it this week. Once we have test results to the new ASTM standard - or if San Jose would recognize the test results we already have based on the Colorado and Washington standards - you can build a "certified" Rumford using the correct components and to the exacting dimensions specified in our "Certified Manual" at http://www.rumford.com/manual.html and we will issue you a certification label. So, no, you don't have to test in the field. We will build and test in a test lab and then you can build one just like the one we tested.
Since we are in a bit of a transition, here are my recommendations:
1) Apply to San Jose for permits to build all the Rumfords attaching our California Manual at http://www.rumford.com/manualca.html or at least the test results and cover letter from our EPA certified test lab at http://www.rumford.com/testRumfordresults.html to your application. San Jose may just approve all the Rumfords, not for any rational reason, but just because they have already demonstrated that they don't think fireplace emissions are a big problem and they don't want to waste administration and attorney time on the issue. They might at least approve the 48" Rumfords which we actually tested. If they can just say "no" they probably will but, if you look serious and might appeal, they may come up with a different answer.
2) If San Jose won't approve, ask if you can build the Rumfords with gas logs installed. This is tricky because the National Fuel Gas Code and the gas log manufacturer both require that gas logs be installed only in code compliant solid fuel-burning fireplaces. Sometimes building officials think you will just remove the gas logs as soon as they leave so may not approve gas logs or, worse, will try to make you use a small B-Vent so you can't use the fireplace to burn wood - and that would be dangerous and against code. You've got to convince them that your customer is law-abiding, pays taxes, is willing to accept gas logs as an alternative and wouldn't think of taking the gas logs out illegally - although they might appeal the decision later.
3) And that's my final recommendation - build the fireplaces as if they might be tested and certified to the new ASTM standard in a year or two and consider getting them certified and approved for wood-burning after the fact. In order to anticipate approval, build the 48" Rumfords as specified in the current certified Manual at http://www.rumford.com/manualca.html and build the 60" Rumfords the same way, including the wolf head air system, and with openings exactly 60" wide by 54" tall as shown in the plan at http://www.rumford.com/R6054plan.gif because that will be the size we test once we get the bugs worked out of the new ASTM standard. If our 60" Rumford becomes certified and your's are built to the same specifications I will issue you a label after the fact.
I know you don't have time to deal with all this bureaucracy during the construction process. The gas log gambit, it think, will get you a permit and preserve the option for you or your customer to appeal the wood-burning issue later. But, you must convince the building officials, who also think they are too busy to deal with this issue, that you have all the time in the world and this is an important issue that you plan to appeal if necessary.
Keep in touch and let me know how it works.
Best,
BTW you have helped me out in the past on a project I designed in Mammoth Lakes for Eric Fishburn. I saw the response you wrote to James Dixon at Eric Fishburn's with suggestions and how you were already working with Mammoth Lakes on the emissions issue. I was curious as to the outcome... I had moved on to other projects before any decisions were made.
Respectfully,
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