Buckley Rumford Fireplaces
Fireplace Emissions
6/30/09
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EPA's Low Mass Fireplace Program New Source Performance Standard |
New ASTM standard Currently met Standards Useful Links |
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EPA's Low Mass Wood-burning Fireplace Program 6/1/09 Currently the EPA's Low Mass Wood-burning Fireplace Program excludes masonry fireplaces even though the ASTM test standard does include masonry fireplaces. Read about the EPA's Low Mass Wood-burning Fireplace Program on the EPA website at http://www.epa.gov/air/fireplaces/program.html. The issue seems to be mostly the perceived difficulty in auditing - how to be sure a field constructed masonry fireplace is just like the one built and tested in a test lab. Stay tuned. Convincing the EPA to include masonry fireplaces in the Agreement is extremely important for those of us interested in masonry fireplaces.
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New Source Performance Standard for Wood Heaters (NSPS)
5/29/09 The Hearth Patio and Barbecue Association (HPBA) held a conference in Denver May 27-28, 2009 to prepare for the Environmental Protection Agency (EPA) review of the New Source Performance Standard for Wood Heaters (NSPS). The EPA is required by law to revise the NSPS every ten years and it has been twenty so they are under some threat of another suit by the Lung Association and various environmental groups. Fireplaces were not included in the conference because the EPA has just concluded a "Voluntary Agreement" (at least for "low mass" fireplaces) with the fireplace industry. This conference was about revision of the wood stove regulation. The EPA is ratcheting up the standards to maybe 4.5 g/hr for stoves, including efficiency requirements and broadening the net to include pellet stoves, outdoor hydronic heaters, furnaces, cook stoves, etc. The meeting included the owners or test lab directors of all the major stove, insert, outdoor hydronic heater, wood-burning furnace and pellet stove manufacturers in the US and Canada. Some are in a panic. The NSPS regulation by EPA carries the force of law including recall of all appliances sold if a surprise audit results in a test that shows that an appliance does not meet the standard - with a $32,000 per day fine until the recall is accomplished - to get their attention. This was all a blinding glimpse of the obvious for me. I never understood why the metal fireplace manufacturers decided to work so hard to develop a fireplace emissions testing protocol and standard. A few years ago I thought the fireplace industry was willing to write off fireplace (builder's box) sales in areas that regulated fireplace emissions rather than have a fireplace emissions standard that might lead to the regulation of fireplace emissions nationwide. Turns out the metal fireplace manufactures have negotiated a Faustian deal with EPA. Fireplaces, they argue, are "merely decorative appliances". They are not "heating appliances". As such, fireplaces are not used daily to heat but rather they are used rarely if at all - maybe only a couple of times a year or maybe in some cases on an evening or two per week and weekends. Having been convinced, the EPA developed the "Voluntary Program" we have been working on for five years. The fireplace manufacturers can use the "Voluntary Program" which includes testing to the new ASTM E2558 standard, to try to get approval in "non-attainment" areas - areas like the Bay Area and Denver where air quality does not meet federal standards. In the rest of the country they don't expect fireplaces to be regulated. That new insight for me makes some things clear and raises other questions: 1) I have objected to being just a "merely decorative appliance" but, if I win the argument that Rumfords are effective radiant heaters, I may have just signed up to be regulated nationally under the force of law as a "heating appliance", complete with all the audits, recalls and $32,000 a day fines. Maybe I could live with Rumfords being "merely decorative" in Denver and tout their heating qualities in Chicago. 2) Being a "merely decorative appliance", however, may still turn out to be a liability. With the rising consciousness about issues like global warming and being "green", will our neighbors and people in general come to feel that polluting, even just a little, just for fun, when there is little or no benefit, is immoral? Will using a fireplace come to seem like smoking cigarettes or driving a Hummer? 3) Are there any assurances that, even if we pass the emissions tests and get on the EPA approved list, that local air quality regulators will certify or approve us? It's a "voluntary" program after all. 4) Now that we have a fireplace emission standard, even if it is voluntary, how certain can we be that the rest of the country won't embrace and enforce it in future? The temporary conclusion I come to is that in the near future masonry fireplaces can survive nationally and the clean-burning ones will probably be approved in at least some of the non-attainment areas. In the long run we will have to accept the fact of fireplace emission regulation, which will probably spread, and we should promote the usefulness of fireplaces as supplemental and emergency heaters, short of getting them classified as "heating appliances". For those of us who are interested in developing a clean-burning masonry fireplace, the EPA still has not agreed to include masonry fireplaces in the "Voluntary Agreement" they have concluded with the "low mass" (metal) fireplace industry. The HPBA is working to persuade the EPA to include masonry fireplaces and have promised to press the issue at their meeting with the EPA about the NSPS on June 16, 2009. The Buckley Rumford Co.is and has been a member of HPBA. We recommend that other masonry industry companies also join the HPBA and support their efforts on our behalf. The HPBA has been in the business of dealing with EPA regulation for a long time and they are effective. ... Jim Buckley
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New ASTM Fireplace Emissions Standard 3/11/09 A new ASTM standard - E2558-08 - on fireplace emissions has been approved and published. Masonry fireplaces are included in an Annex to the standard which equates a 35% oxygen recovery to the fuel weights measured on a scale used to determine when to re-load and end the test. We are only waiting on the EPA to negotiate an Agreement with the fireplace industry, decide what the passing emissions "number" will be and announce E2558 as a "voluntary standard" that local and state regulators can use to regulate fireplace emissions if they so choose. We hope that the new standard and EPA's active involvement will result in better regulation with more science and less politics. We expect our clean-burning Rumford fireplaces will be able to meet the standard but we also expect that we will have to monitor and lobby for fair local rule-making for months if not years to come. ... Jim Buckley
ASTM E2558 - The EPA
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Useful Links EPA Certified Test Labs
Myren Consulting, Inc.
OMNI Test Labs Attorneys Skilled in Environmental Law
Arter & Hadden, LLP, Attorneys at Law
Ballard Spahr Andrews & Ingersoll
Gablehouse Calkins & Granberg, LLC
Heller Ehrman White & McAuliffe Attorneys |
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Fireplace Emissions
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