United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/4-85-012
February 1986
Air
Technical Support
Document For
Residential Wood
Combustion
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EPA-450/4-85-012
Technical Support Document For
Residential Wood Combustion
By
Nero And Associates, Inc.
Portland, Oregon
Contract No. 68-03-3871
EPA Project Officer: Dallas W. Safriet
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office Of Air And Radiation
Office Of Air Quality Planning And Standards
Research Triangle Park, North Carolina 27711
February 1986
t!.$. Environmental Projection £g
-------
This report has been reviewed by the Office Of Air Quality And Standards, U.S. Environmental
Protection Agency, and approved for publication as received from the contractor. Approval does
not signify that the contents necessarily reflect the views and policies of the Agency, neither
does mention of trade names or commercial products constitute endorsement or recommendation
for use.
EPA-450/4-85-012
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ACKNOWLEDGEMENTS
This study was conducted by Nero and Associates, Inc. (NAI) of Portland,
Oregon. The Project Manager was Dr. Robert L. Gay. Other project team
members and principal analysts were Mr. William Greene and Dr. Jitendra Shah,
and Mr. John Core currently with the Oregon Department of Environmental
Quality (DEQ) in Portland, Oregon. Dr. Kish Sharma, President of NAI was the
corporate official responsible for this study. Secretarial, typing and other
administrative support was provided by Ms. KLmm Olin, Ms. Pamela Hascall and
Ms. Dorothy Bressler of NAI. The EPA Project Officer was Mr. Dallas Safriet
of Research Triangle Park, North Carolina. Ftts assistance and suggestions, as
well as the cooperation of the numerous state and local agency staff members
consulted during this study, are gratefully acknowledged and appreciated.
iii
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ABSTRACT
This Technical Support Document Is prepared to assist state and local air
pollution control agencies In assessing and controlling Residential Wood
Combustion (RWC) air pollution Impacts. It provides an overview, description
and leading references to many technical topics related to characterization of
wood usage, pollutant emissions and resulting ambient concentrations
attributable to RWC.
RWC emissions relative to other emissions sources, and various methods for
estimating RWC wood usage and resulting emissions are described and
quantified. Factors affecting the magnitude of RWC emissions from woodstoves
and fireplaces are analyzed. Past and future trends are examined.
The magnitude of RWC ambient Impacts Is summarized based on available data
from localities around the nation, for total and fine partlculates, carbon
monoxide and benzo(a)pyrene. Methods for measuring or estimating RWC air
quality Impacts are described, Including field monitoring, sample analyses,
source apportionment analysis, dispersion modeling, and other specialized
analysis. A stepwlse approach to estimating RWC ambient Impacts Is outlined,
with options based on available study resources.
Leading examples of RWC emissions control strategies are described, based on
programs Implemented In Oregon, Montana, Colorado, Alaska, and Nevada.
Example laws, regulations, local ordinances and Informational materials
related to these cases are Included In an Appendix. Methods for estimating
the potential effectiveness of RWC emission measures are described and
Illustrated, Including the use of receptor and dispersion models.
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TABLE OF CONTENTS
I. Introduction. 1-1
A. Background/Introduction to Residential Wood 1-1
Combustion
B. Purposes and Limitations of This Document 1-2
II. Overview of Document Contents II-l
A. RWC Emissions Characterization II-l
B. Characterizing RWC Ambient Impacts II-2
C. RWC Control Strategies II-3
III. RWC Emissions Characterization III-l
A. Emissions from RWC vs Other Wood-Burning Sources III-l
1. Total Emission Estimates III-l
2. Nature of Emissions from Various Wood Burning III-5
Sources
B. Factors Influencing RWC Emissions III-8
1. Burning Rate Effects on Emissions II1-8
a. Influence of Burn Rate on Emission Factors 111-13
(k/kg)
b. Influence of Burn Rate on Emission Factors 111-16
(g/hr)
2. Emissions Effects of Appliance Design 111-18
a. EPA Emission Factors III-18
b. Design Factors Which Can Minimize Emissions 111-19
c. Emissions Performance For Different Stove 111-21
Designs
IV. Characterizing RWC Ambienjt Impacts IV-1
A. Summary of Ambient Impacts IV-1
1. Introduction IV-1
2. National Summary IV-2
3. Caveats and Conclusions 17-10
B. Field Monitoring for RWC Impact Estimation IV-16
1. Introduction IV-16
2. Network Design Considerations IV-18
a. Monitor Siting IV-18
b. Sampling Locations and Periods IV-18
c. Supportive Monitoring Data IV-21
3. Air Monitoring Instrumentation IV-22
4. Specialized Sampling Techniques IV-23
5. Sample Analysis IV-24
- v
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C. Receptor Modeling Assessment of RWC Impacts IV-24
1. Introduction IV-24
2. Introduction to Receptor Modeling IV-26
a. Chemical Mass Balance (CMS) IV-28
b. Multivariate Techniques IV-28
c. Enrichment Factor Models IV-29
d. Pattern Recognition IV-29
3. Model Input Requirements IV-30
a. Development of CMS Source Profiles and a
Source Matrix IV-32
4. Receptor Model Applications IV-40
a. Quantitative Methods of RWC Impact Assessment IV-41
Radiocarbon Techniques
b. Semi-Quantitative Methods - Enrichment IV-44
Factor Models
c. Qualitative Methods IV-47
5. Joint Application of Dispersion and Receptor Models IV-51
6. Modeling RWC Visibility Impacts IV-53
7. Estimating RWC Impacts Through Atmospheric IV-49
Tracer Studies
a. Overview
b. Tracer Studies
c. Strengths and Limitations of Tracer Studies IV-56
d. Example Tracer Study IV-58
D. Dispersion Modeling IV-59
1. Overview of Dispersion Modeling IV-59
a. Introduction to Dispersion Modeling IV-59
b. Considerations in RWC Applications IV-61
2. Applicable Dispersion Models IV-61
a. EPA UNAMAP Models IV-62
b. GRID Model IV-66
c. Screening Models IV-68
d. Areas Model IV-71
3. Dispersion Modeling Analysis IV-72
a. Input Information IV-72
b. Model Comparisons with Measured RWC Impacts IV-73
c. Analysis of Background Concentration IV-78
d. Model Evaluation IV-80
e. Analysis of Results IV-80
f. Modeling Carbon Monoxide Concentrations IV-81
g. Other Airshed Applications IV-81
h. Use of Dispersion Modeling to Evaluate RWC IV-82
Control Measures
E. Stepwise Approach to Characterizing RWC IV-82
Ambient Impacts
1. Level 1: Semi-quantitative Study Design IV-85
2. Level II: Quantitative Study Design IV-88
3. Level III: Optimum Program Design IV-90
VI
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V. Residential Wood Combustion Control Strategies V-l
A. Introduction V-l
B. Potential RWC Control Strategies V-2
C. leading Examples of RWC Control Strategies Adopted or V-19
Proposed
1. Oregon V-19
2. Montana V-43
a. Missoula V-43
3. Colorado V-48
a. Colorado Ski Communities V-48
b. State Level RWC Control Measures V-52
4. Alaska V-54
5. Reno, Nevada V-58
D. Approaches to Evaluation of the Potential V-62
Effectiveness of RWC Emissions Control Measures
1. Overview of RWC Control Measure Evaluation V-62
2. Use of Dispersion and Receptor Models to V-68
Evaluate RWC Control Measures
3. Evaluating Potential Emissions Reductions V-72
from RWC Control Measures
a. Emissions Standards for New Woodstoves V-72
b. Home Weatherization V-74
c. Wood Moisture Controls V-76
d. Episode Controls V-78
e. Public Education „ V-81
4. The Importance of Citizens Advisory Process V-82
VI. Bibliography VI-1
Appendix A - Information on RWC Household Surveys
Appendix B - Example Laws, Regulations and Ordinances
vn
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LIST OF TABLES
Table III-l
Table III-2
Table III-3
Table III-4
Table III-5
Table III-6
Table III-7
Table III-8
Table III-9
Table 111-10
Table III-ll
Table 111-12
Table 111-13
Table 111-14
Table 111-15
Table 111-16
Table IV-1
Table IV-2
Table IV-3
Table IV-4
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
IV-5
IV-6
IV-7
IV-8
IV-9
IV-10
IV-11
IV-12
IV-13
IV-14
IV-15
Table IV-16
Table IV-17
Table V-l
Table V-2
Table V-3
Table V-4
Table V-5
1981 Total U.S. Emissions Estimates for Wood Burning and
Other Sources from EPA's National Emissions Data System
(NEDS)
Emissions of Various Pollutants In 1981 from Wood Burning
Source Categories
Characterization of Bnlssions from Various Wood Burning
Sources
Summary of How Various Factors Can Influence RWC Emissions
EPA Emission Factors for stoves and Fireplaces
Summary of Woodstove Test Results
Effect of Log Size on Particulate Emission Factor
Annual and Cumulative U.S. Sales of Residential Wood
Burning Devices (1972-82)
Trends In Residential Wood Usage
Statewide RWC Wood Use Estimates from U.S. DOE and the USDA
Forest Service (cords/year; 1980-81)
RWC Wood Usage Estimates for Twenty Local ties
Wood Density and Heating Values for Selected Species
Cord Weights Used in Studies in Various Localities
Comparison of EPA Emission Factors with Range of literature
Values
Summary of Short Term Trend Estimates
Best Estimate Projections of Residential Wood Fuel Use for
Portland, Seattle and Spokane and Corresponding Particulate
Emissions
Summary of RWC Impact on Fine Particulates for Selected
Locations
Summary of RWC CO levels for Selected Locations
Summary of RWC Benzo(a)pyrene Levels for Selected Locations
Summary of RWC Impact on Fine Mass and Measured
Benzo(a)pyrene Levels
Air Quality Measurement Methods for RWC Assessment
Analytical Methods for RWC Studies
Receptor Model Input Requirements
Example from EPA Source Library of Wood Stove Source Profile
Example from EPA Source library of Wood Stove Source Profile
Example from EPA Source Library of Fireplace Source Profile
Example from EPA Source Library of Fireplace Source Profile
Source Matrix - Generic Example
Dispersion Model Characteristics
Model Intercomparison Summary
Dispersion Model Advantages and Disadvantages for
Applications to RWC
Approximate Program Costs
Air Sampling Equipment Requirements
Criteria and Weight Factors Used in Keppner-Tregoe Analysis
Generic Approaches to Reducing RWC Particulate Emissions
Comparison of Estimated Particulate Emissions Reductions
Achievable by Generic RWC Control Strategy Approaches
Final Fifteen RWC Control Strategies Evaluated
Description of Most Effective Control Strategies
viii
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Table V-6 Summary for Fifteen Final RWC Control Strategies of the
Keppner-Tregoe Ranking vs WANT Criteria and Major Strategy
Costs and Benefits
Table V-7 Oregon Woodstove Publications
Table V-8 Medford Residential Wood Burning Control Measures
Effectiveness
Table V-9 Particulate Hnission Reductions per Household
Table V-10 Potential Emission Reductions per Household
Table V-ll Energy and Economic Impacts of Medford Control Measures
Table V-12 Oregon's Woodstove Particulate Emissions Standards
Table V-13 Useful Parameters for Characterizing RWC Conditions
Table V-14 Impact of Moisture on Relative Heat Content of Firewood
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LIST OF FIGURES
Figure III-l Variation of 00 Emissions Factors with Firing Rate for a
Catalyst-Equipped Horizontal Baffle Stove
Figure III-2 Particulate Emission Rate vs. Heat Output for Catalytic
Woods toves
Figure III-3 Particulate Emissions from a Conventional Woodstove with
Catalytic Add-On Devices
Figure III-4 Particulate Emissions as a Function of Fuel Moisture
Figure III-5 Effect of Wood Moisture Content on Fireplace Combustion
Efficiency
Figure III-6 Emission Factor as a Function of m/q
Figure III-7 Annual and Cumulative U.S. Sales of Residential Wood
Burning Devices, 1972-82
Figure III-8 Distribution of Pennsylvania Anthracite
Figure III-9 Flow Diagram for Residential Fuelwood Consumption Model
Figure 111-10 Industrial and Residential Particulate Emissions, Portland,
Oregon
Figure IV-1 RWC Emission Profile Variability
Figure IV-2 Radiocarbon CO Sampling Train
Figure IV-3 Carbon Thermograms of Source and Ambient Aerosols
Figure IV-4 Seasonal and Diurnal Variations in RWC Pollutants
Figure IV-5 Diurnal Variations in CO and B-scat at Residential and CBD
Monitoring Sites
Figure IV-6 Modeled vs Estimated Atmospheric Carbon, Medford, Oregon
(1979-80)
Figure IV-7 Measured vs ISCST-Estimated RWC Impacts
Figure IV-8 Measured vs ISCST-Estimated RWC Impacts
Figure V-l Effects of Potential Programs to Promote Cleaner Burning
Woodstoves
Figure V-2 Woodstove Lables to be used by Oregon Certification Program
Figure V-3 Schematic Illustration: RWC Control Measures Can Alter RWC
Baseline Conditions in Several Ways
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EXECUTIVE SUMMARY
Characterizing RWC Emissions
Residential Wood Combustion (RWC) accounts for only 3% of Total Suspended
Particulate (TSP) emissions, and about 7% of Carbon Monoxide (CO) emissions
nationally. However, emissions of these pollutants are dominated by
transportation sources, such as resuspended road dust and vehicle exhaust.
Among all wood burning sources including industrial, agricultural, forest
management, forest wildfires, and residential open (backyard) burning, RWC
accounts for almost half of all TSP, Inhalable Particulate (IP), and CO
emissions.
The significance of RWC particulate emissions is substantially enhanced for
the following reasons. Virtually all of the RWC emission is inhalable
particulate. RWC emissions occur predominately in residential areas. Poor
meteorological conditions for dispersion (winter/evening), coupled with low
plume rise, tend to increase human exposure. RWC is the single largest source
in the nation of emissions of benzo(a)pyrene B(a)P - a proven carcinogen, and
prime example of the important class of toxic air contaminants referred to as
Polycyclic Organic Material (POM).
The large and steady decline in RWC since the 1940's, when eight million
households used wood as their primary heating fuel, was reversed in 1973-74 as
prices for oil, natural gas and electricity began to increase sharply. The
strong resurgence in RWC has continued for the last decade, with about 10
million new residential burning devices sold in the U.S. during that period.
Where wood is reasonably available, it is not unusual to find half or more of
all households using wood as a primary or secondary heating fuel, or for
aesthetic burning.
During this resurgence of RWC, its air pollution impacts have been exacerbated
by several factors. The woodstoves and fireplaces have generally not been
developed and engineered to minimize emissions. Their combustion efficiencies
are further reduced (and emission increased) when they are operated in a
starved air ("airtight") mode, to prolong fuel burning time. A shift from
ES-l
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fireplace to woodstove use, Which generally increases emissions per unit of
wood burned, is also common, because woods toves heat houses much more
efficiently. Eighty percent of all RWC emissions in! the U.S. are from
woods toves, including fireplace inserts.
Rising concerns about the air pollution effects of RWC have prompted study of
factors which influence the magnitude of RWC emissions from stoves and
fireplaces. The following factors are examined in this report: a) burn rate;
b) appliance size; c) wood moisture content; d) wood charge size; e) appliance
size; f) fuel type, and; g) wood piece size. Efforts to design and engineer
cleaner burning woodstoves have also increased dramatically in recent years,
including applications of catalyst technology. Based on the research
reviewed, the following general conclusions are offered.
In general, higher woodstove burning rates (kg/hr) result in lower emissions
factors (grams of pollutant per kg. of wood burned) for TSP, CO, hydrocarbons
(HC), and POMs. The same is probably true for fireplaces, although little
data on this exists.
Conventional woodstoves tend to have higher emission factors (g/kg) than
fireplaces for TSP, CO, and HC. More complete combustion with lower resultant
emission factors can be achieved by catalyst stoves, catalyst add-on devices,
and an increasing array of improved design, non-catalyst combustion stoves.
Although ranges can overlap, in general, catalyst equipped stoves result in
lowest emissions, conventional airtight stoves produce the highest emissions,
and improved design non-catalyst stoves perform in between.
Wood with moisture content in the range of 201 to 26% (wet basis) seems to
produce the lowest particulate emission factors in stoves. Wood moisture
contents above and below this range resulted in higher emission factors in
limited testing. For fireplaces, a more linear relationship seems to exist,
with higher wood moisture content generally resulting in higher emissions
factors.
Larger "charge size" in stoves generally results in higher emission factors
for TSP, CO and HC. However, charging larger pieces of wood in stoves
generally results in lower emission factors for these pollutants.
ES-2
-------
Larger firebox size in stoves generally results in higher particulate emission
factors. Information' is inconclusive regarding whether hard or softwoods
produce higher emissions, although softwoods have a higher content of
volatiles.
The best, most direct method for quantifying RWC emissions in a local area is
through household surveys conducted by telephone or mall. Wood supplier
information, census data and related information are likely to be too
incomplete or too indirect. They do not afford enough Information on the
number of households using wood, the amounts used per household, the mix of
wood burning appliances in an area, household burning practices and other
household characteristics. Such information is critical in understanding the
dynamics of RWC for a given community, and thus In designing effective RWC
control measures. Information on RWC household surveys is included in
Appendix A.
One of the major sources of uncertainty In estimating RWC emissions for a
local area involves selection of appropriate emission factors for woodstoves
and fireplaces. Scarcity of emissions test data, lack of standardized test
conditions, and lack of testing under "typical" household wood burning
conditions, have all contributed to a wide range of RWC emissions factors In
the current literature. Table ES-1 summarizes this variability, and compares
it to EPA's current woodstove and fireplace emission factors for TSP and CO.
More and better woodstove emissions testing, in conjunction with ongoing
efforts at the federal and several state levels should improve estimation and
selection of RWC emissions factors.
One of the best, most direct methods for quantifying RWC ambient impacts is
Chemical Mass Balance (CMB) receptor modeling source apportionment analysis.
Using detailed chemical composition of particulate emissions from various
airshed sources, CMB determines the relative contributions of individual
sources which best explains both the mass and chemical composition of
particulate samples collected at monitoring sites (receptors). CMB methods
thus directly attribute a specific amount of measured ambient particulate
concentrations to RWC, and to any other sources for which emissions chemical
composition can be established.
ES-3
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ES-4
-------
The strength of (MB source apportionment analysis is its ability to determine
relative source contributions from a single monitoring sample - e.g., one
collected under worst case meteorological conditions. A principal drawback is
the inability to distinquish impacts from chemically similar sources - e.g.,
woodstoves, fireplaces and forest burning. Other receptor modeling
techniques, such as multivariate analyses, require many more samples to obtain
statistically valid results.
Field monitoring and sample analysis are discussed in this report, primarily
in terms of supporting receptor modeling studies. A stepwise approach to
estimating RWC ambient impacts is outlined, with options based on available
study resources.
A recent national RWC assessment document (Nero and Associates, Inc., 1984)
compiled the best available data on RWC ambient impacts for twenty localities
around the country (Table ES-2). Fine particulate masss ( < 2.5 un)
3
attributable to RWC (mostly using CMS methods) ranged from: a) 6 to 93 ug/m
3
as a study period or seasonal average, and; b) 24 to 234 ug/m as a 24-hour
maximum average. The small size of this data base, and other limitations
discussed in this report, provide only a preliminary view of the potential
significance of RWC ambient impacts. It seems clear, however, that RWC could
be a very significant fine particulate source, relative to EPA's proposed
national dM-0) standard, for any locality with substantial wood burning and
restrictive wintertime meteorology.
Dispersion modeling is also useful in estimating RWC impacts - especially: a)
in areas where no monitoring sites exist; b) for future years, using
projections of future RWC emissions; and, c) to compare potential air quality
improvements from alternative RWC emission control strategies. Various
dispersion models developed by EPA and others, which are applicable to RWC
analysis, are reviewed in this report. The use of receptor modeling to
calibrate dispersion models for RWC applications is also discussed.
Other special methods to RWC impact assessment, discussed in this document,
include: a) radiocarbon analysis (carbon-14) of particulate and carbon
monoxide field samples, b) modeling RWC contributios to visibility impairment;
and c) monitoring for CH-Cl as an RWC tracer.
ES-5
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TABLE ES-2.
Summary of RWC Impact on Fine Mass and
Measured Benzo(a)pyrene Levels at
Selected Locations
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Location
Waterbury, VT
Western MA
Nashville, TN
Peter sville, AL
Albuquerque, NM
Missoula, MT
Denver, CO
Telluride, CO
Reno, NV
Las Vegas, NV
Boise, ID
Portland, OR
Medford, OR
Yakima, WA
Spokane, WA
Seattle, WA
Tacoma, WA
Longview, WA
Anchorage, AK
Juneau, AK
Study
Year
81-82
81-82
83
81
82-83
83
78
80
83-84
83
80-81
77-78
79-80
80-81
80-81
81
81
80-81
81-84
81-82
RWC Impact on
Fine Mass
lie An3
J?o. qf
Samples
33
13
24
8
56
12
16
13
8
4
9
32
40
4
15
9
4
4
8
11
Avg.
19
15
9-20
33
25
37
6-18
10-303
13a
--
85b
e
4-10
9-30e
50
17-45
29
35
42
18a
48-93S
Max.
30
25
51
65
59
48
29
59a
23a
41
128b
50
126d
. 55
68
49
44
26
45a
234a
Measured
Benzo(a)pyrene
ng/m3
NO. or
Samples
16
—
21
4
—
—
—
13
—
—
2
3
2
—
3
3
—
—
—
1
Avg.
0.8a
—
2.3a
41C
—
—
—
7.4a
—
—
1.5
3.2
8.4
—
6.1
2.1
—
—
—
—
Max.
2.4a
—
11. 4a
110.0°
—
—
—
14. 83
—
—
2.3
5.4
8.5
—
11.0
4.2
—
—
—
11.0
ABBREVIATIONS:
RWC - Residential Wood Combustion
Fine Mass - <2.5>an unless otherwise specified
ug/m3 - micro gram per cubic meter
ng/m3 - nanogram per cubic meter
Avg. - 24-hour average for the study period at one or more sites
Max. - 24-hour maximum for the study period
or PMi5 - Particulate matter <10 or <15 jm.
FOOTNOTES :
a - Analysis of TSP samples
b - Analysis of PM^g or PM]^ samples
c - Gaseous and particulate benzo(a)pyrene - 4-hour sample
d - 8-hour or 12-hour maximum
e - Annual average
ES-6
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RWC Control Measures
Leading examples of RWC particulates emission control measures are described
for the following states and localities: a) Medford, Oregon; b) Oregon's
statewide woodstove certification program; c) several Colorado ski
communities, including Aspen (Pitken County), Vale, Beavercreek and Telluride;
d) Colorado's statewide woodstove and fireplace control program; e) Missoula,
Montana; f) Juneau, Alaska; and, g) Reno, Nevada. Illustrative laws,
regulations, ordinances, and information materials developed in these programs
are included in Appendix B.
The major types of RWC emission control measures discussed in the document
include: a) emission standards for new woodstoves; b) home weatherization; c)
wood moisture controls; d) episode controls, and, e) public education. The
most effective of these measures for reducing RWC emissions appears clearly to
be woodstove emission standards for woodstoves. . However, its full benefits
take many years to accrue, as cleaner burning devices replace existing
stoves. For example, the Oregon Department of Environmental Quality
attributes an estimated 75% reduction in existing RWC emissions over a 10-20
year period to its new mandatory woodstove certification program.
Key elements of RWC emission control strategies are discussed for all of the
states and localities listed above. However, the only State Implementation
Plans (SIPs) to date which have addressed RWC comprehensively are for
particulates for three Oregon airsheds (Medford, Portland and Eugene). A
package of RWC control measures implemented for the Medford area is the best
documented example of applying all types of RWC control measures mentioned
above In a local area.
In Medford, an ambitious home weatherization program was predicted to reduce
RWC particulate emissions by up to 30-502 over a 3-10 year period. Wood
moisture controls (improved firewood seasoning) were estimated to achieve
about a 10% reduction. Episode controls (curtailment of burning during
certain air stagnations) were estimated to afford a 6-7% reduction. Public
education was not assigned an emission reduction benefit, but was deemed
essential to the success of the other measures. Overall, including statewide
ES-7
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mandatory woodstove certification, an 80-95% reduction In RWC particulate
emissions was predicted from the combined control measures, but fully
realizable only in 10-20 years.
Both generic and site-specific methods are discussed for estimating the
potential effectiveness of RWC control measures, Including the use of receptor
and dispersion modeling. Major uncertainties and assumptions are identified
and discussed. The important role of a citizens advisory process in
developing and selecting control measures is stressed.
ES-8
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I. INTRODUCTION
A. Background/Introduction to Residential Wood Combustion
In response to sharply increasing energy prices (since the early 1970s),
many households have turned to woodburnlng as a primary or supplementary
source of space heating. This led to sharp Increases in the sales of wood
stoves and fireplace inserts (as described in Section III. C), which were
more efficient for space heating purposes than fireplaces. Another factor
contributing to increased fuelwood usage was governmental promotion of
renewable energy resources to reduce dependence on fossil fuels,
exemplified by programs to encourage biomass utilization sponsored by the
U.S. Department of Biergy (Pacific, 1984).
The air pollution impacts associated with Residential Wood Combustion
(RWC) can be significant. They also represent an impediment to desirable
exploitation of wood as a renewable energy resource. Various studies have
shown that RWC can be one of the largest sources of emissions of fine
particulate and Total Suspended Particulate (TSP), in an airshed (Cooper
and Watson, 1979). RWC can contribute significantly to exceedances of
national ambient air quality standards for both TSP and Carbon Monoxide
(CO), especially in residential neighborhoods (Nero and Associates, Inc.
1984).
Among the most troubling characteristics of RWC particulate emissions are
their small particle size (respirability) (Rau and Huntzicker, 1984), and
potential toxlcity (Alfhelm et al, 1983; Hytonen et al, 1983). Toxlcity
concerns are based on their relatively high mutagenie activity, and
relative abundance of Polycyclic Organic Matter (POM), including known
carcinogens such as benzo(a)pyrene (B(a)P) (Cannon, 1984). RWC has been
identified as the largest single source nationally of emissions of POMs,
which are one of the toxic air pollutants of most concern to the
Bivironmental Protection Agency (EPA) (Radian, 1983).
FWC has also been shown to be a major contributor to visibility Impairment
and urban haze, due to its aerosol character and light scattering
capability (Wolff et al, 1980; Dennis, 1983).
1-1
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For air pollution, control agencies seeking to attain and maintain ambient
air quality standards, RWC is a prime example of the growing importance of
areawide emissions sources in airshed management. As stationary, largely
Industrial point sources have been controlled, residual exceedances of
ambient standards are Increasingly due to areawide sources, such as RWC,
road dust, and vehicle exhaust. These numerous, small, people-oriented
emissions sources present special challenges In pollution assessment and
control strategy development.
B. Purposes and limitations of This Document
The primary purpose of this document is to provide Information which can
help state and local air pollution control agencies in their efforts to
assess and control emissions from Residential Wood Combustion (RWC). This
goal is approached through discussions of RWC emissions (Section III),
description of leadlag methods for characterizing ambient impacts
attributable to RWC (Section IV), and a. review of RWC control measures
(Section V).
In general, the technical discussions herein provide an overview of the
topics addressed, and leading references to more detailed studies.
Illustrative examples are Included to help clarify or demonstrate
technical points. More extensive technical details - e.g., to help plan
quantitative studies of RWC emissions or ambient impacts - may be found In
the leading example studies referenced.
Approaches and methods for characterizing ambient particulate
concentrations directly attributable to RWC are addressed In Section IV.
Primary emphasis is given to Chemical Mass Balance (Q4B) receptor modeling
and source apportionment analysis, but dispersion modeling and other
approaches are also discussed. CMS analysis Is one of the most direct and
accurate method for quantifying RWC ambient impacts. Field monitoring
requirements to support CMS analysis, and the use of receptor modeling in
conjunction with dispersion modeling to estimate RWC Impacts, are also
discussed.
1-2
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RWC control strategies are discussed first in general terms in Section V.
Then leading examples of actual control measures adopted or proposed by
state or local agencies are described. Available approaches for
projecting RWC control strategy effectiveness, including using receptor
and dispersion modeling and other analyses, are also discussed.
Recommendations or preferences among various RWC control measures are not
presented, although their relative ability to reduce RWC particulate
emissions is discussed briefly.
While the information presented herein is intended to help state and local
agencies assess and control RWC impacts, it is not referenced in terms of
State Implementation Plan (SIP) requirements or procedures. Detailed SIP
requirements and procedures are described in other EPA documents and
regulations.
Also, estimates of RWC wood usage, emissions and ambient impacts reported
herein for specific localities, should not be extrapolated to other
localities without considerable caution. RWC characteristics and impacts
can vary widely from one locality to another. A better .use of this
document is to review and select appropriate methods for analyzing local
RWC parameters.
1-3
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II. OVERVIEW OF DOCUMENT CONTENTS
This section provides an overview of the contents of this document, in terms
of the primary topics covered in each of the remaining sections.
A. Residential Wood Combustion (RWC) Emissions Characterization
RWC 'emissions are characterized in Section III. A in terms of their nature
and magnitude relative to all other emissions sources. Particular
emphasis is placed on other wood combustion sources, such as industrial
wood boilers, agricultural and forest managed burning, forest wildfires,
and residential open ("backyard") burning.
Pollutant emissions addressed include the following criteria pollutants:
Total Suspended Particulate (TSP), Carbon Monoxide (CO), Nitrogen Oxides
(NO ), Sulfur Oxides (SO ), and Volatile Organic Compounds (VOC).
Total and Inhalable Particulate, CO, and Polycyclic Organic Matter (POM)
emissions from RWC and other wood combustion sources are also summarized
on a national basis. The nature of emissions from the various wood
burning sources is compared In terms of particle size, carbon content,
plume rise, and the predominant locations and timing of their emissions.
Factors which influence the magnitude of RWC emissions are described and
discussed In Section III.B, including the effects of: a) appliance type
(woodstoves vs fireplaces); b) appliance size and design (existing vs
emerging or advanced technology); c) firing practices - e.g., burn rate,
wood charge size, and piece ssize; and, d) fuel type and condition - e.g.,
moisture content.
Trends in RWC appliance and fuel use are addressed in Section III. C,
including the residential use of wood and coal.
Section III. D reviews and discusses several aspects of estimating air
pollutant emissions from RWC. Approaches and methods for estimating RWC
wood usage, and translating this Into RWC emissions estimates are
discussed, including the use of household surveys, data available from
wood suppliers, and census and related information. Selection and use of
II-l
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appropriate RWC emission factors is discussed. Projection of RWC
emissions for future years is discussed, including trend factors and a
wood use forecasting model.
B. Characterizing RWC Ambient Impacts
A summary of documented ambient impacts attributable to RWC is presented
for fine particulate (< 2.5 um), based upon a recently completed national
assessment of RWC impacts (Nero and Associates, Inc., 1984.) The
representativeness and limitations of these field measurements of RWC
impacts is discussed.
The primary tools for assessing ambient particulate impacts attributable
to RWC - receptor modeling source apportionment analysis, and dispersion
modeling analysis - are both described and discussed in Section IV.
Chemical Mass Balance (CMS) receptor modeling is emphasized, because it is
the most direct and accurate method available for quantifying RWC ambient
impacts. The theoretical basis for receptor modeling is described in some
detail, because it is a relatively new approach - e.g., compared to
dispersion modeling with which users of this document will probably be
more familiar.
Field monitoring for RWC applications is discussed in Section IV. B in
terms of desirable features for network design, instrumentation, sampling
and analysis. Receptor modeling requirements are stressed, including
chemical and physical analyses required to establish source composition
profiles.
Receptor modeling input data requirements are described, including both
chemical composition information and measures of its uncertainties.
Various receptor modeling techniques applicable to RWC assessment are
described in Section IV.C, and categorized as to whether their results are
quantitative, semi-quantitative, or qualitative. Examples of quantitative
techniques include CMB analysis of RWC particulate impacts, and
radiocarbon (carbon-14) isotope analysis of particulate and/or carbon
monoxide impacts from RWC. Multivariate models are also discussed.
II-2
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Enrichment factor models are discussed as an example of a
semi-quantitative receptor modeling technique applicable to RWC
assessment. Qualitative approaches discussed include carbon thermograms,
and analysis of temporal patterns (diurnal and seasonal variations) of
light scattering (nephelometer) and chemical composition data.
Dispersion modeling as an RWC assessment tool is discussed In Section
IV.D, first in general terms, and then by reviewing the characteristics of
ten dispersion models applicable to RWC analysis. These include five
models from EPA's ONAMAP series (PAL, RAM, ISCST, ISCLT, and CDMQC).
Other models considered include: GRID; box model; proportional rollback;
Holzworth urban model; and AREAS.
Dispersion modeling applications to RWC assessment are discussed in terms
of: input data requirements; model selection and validation; data analysis
and interpretation; and Inter comparison of the advantages and
disadvantages of various dispersion models for RWC assessment.
The joint application of receptor and dispersion models is discussed,
because it offers particular strengths for RWC assessment and State
Implementation Plan (SIP) control strategy development. The use of models
to evaluate control strategies is further discussed in Section V.D.
Receptor modeling of visibility impacts is discussed, as is the use of
atmospheric tracers (e.g., SFg) to estimate RWC ambient impacts.
Section IV. E briefly describes three levels of field monitoring and sample
analysis that could be undertaken to quantify ambient impacts attributable
to RWC. Approximate costs for levels I, II, and III are estimated at
36,000, ^25,000 and $75,000 respectively, exclusive of equipment costs.
The intent is to illustrate the types of measurements and analyses that
could be conducted with very modest study resources (Level I), and the
additional information that could be obtained with additional funds.
C. RWC Control Strategies
A brief overview of several factors which can govern selection and design
of RWC control strategies is provided as introduction in Section V. A. The
II-3
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following five types of RWC control measures are then discussed and
illustrated: a) emissions standards for new woodstoves; b) weatherization
of houses; c) wood moisture controls; d) episode controls; and e) public
education. The important role of a citizen advisory process in developing
and selecting RWC control measures is then briefly discussed.
II-4
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III. RWC EMISSIONS CHARACTERIZATION
This chapter addresses four main topics: (a) how Residential Wood Combustion
(RWC) emissions compare in magnitude and nature to other wood-burning sources;
(b) seven different factors which can influence emission rates; (c) trends in
wood burning in terms of appliance sales and in the use of wood and coal as
residential fuels; and, d) approaches and methods for quantifying RWC
emissions.
A. Baissions from RWC vs Other Wood Burning Sources
Emissions of Total Suspended Particulates (TSP), inhalable particulates
(IP) and Carbon Monoxide (CO) from Residential Wood Combustion (RWC) in
the U.S. are large in magnitude compared to those from other wood burning
sources (Table III-l). When emissions of Polycyclic Organic Matter (POM)
are considered, the relative contribution from RWC is much larger. RWC
emissions account for about eight times as much POM emissions as all other
wood burning sources and about 58% of total U.S. emissions of POM (See
Table III-2). The relative magnitude of RWC emissions compared to other
wood burning sources is discussed first, followed by a discussion of the
nature of emissions from various wood burning sources.
1. Total Emission Estimates
One primary source of information which estimates air pollution
emissions for the entire U.S. for major pollutant categories is the
EPA's National Emission Data System (NEDS) (U.S. EPA, 1984a). Table
III-l shows the latest (1981) NEDS emission estimates for: a)
Residential Wood Combustion; b) industrial wood combustion; c) forest
managed burning; d) agricultural burning; e) residential open burning;
and, f) forest wildfires. To provide perspective, information is also
presented on point sources vs area sources and transportation vs
non-transportation sources. Pollutants addressed by NEDS include:
Total Suspended Particulates (TSP), Carbon Monoxide (CO), Sulfur
Oxides (SO ), Nitrogen Oxides (NO ) and Volatile Organic Compounds
(VOC).
III-l
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TABLE III-l.
1981 Total U.S. Emissions Estimates for Wood Burning
Sources and Other Sources From EPA's National Emissions
Data System (NEDS)a
Thousand Tons Per Year
TSP
CO
NO,
Burning
Agricultural
Burning
Residential
Open Burning
Forest Wildfires
Total of "Wood
Burning" Sources
All "Transportation'
All "Non-Transpor-
tation
All "Area Sources"
All "Point Sources"
All Sources
34,7546 77,832 9,518
7,353 23,616 14,994
37,270 93,115 12,898
4,837 8,333 11,614
42,107 101,448 24,512
VOC
Source - Category
Residential Wood
Combustion b»c
- Stoves
- Fireplaces
Industrial Wood
Combus tion
Forest Managed
722
191
76
431
4,471 49 7
1,160 23 3
121 88 14
2,412 86 3
1,718
174
71
308
72
239
483
2,214
476
1,022
3,982
13,644
10
61
114
432
0
9
4
40
66
322
546
3,206
927 8,146
26,586 13,514
2,246 16,896
25,267 4,764
27,514 21,661
a. (US EPA, 1984a)
b. These NEDS values should be Increased by 25% as shown in Table III-2 and
explained in the Table III-2 footnote.
c. NEDS data actually shows stoves and fireplaces combined. Data was
disaggregated to show the greater contribution by stoves. NEDS assumes
71.6% of wood consumption In each state was in stoves; 28.4% in fireplaces.
NEDS uses emission factors for TSP, CO, NOX, SOX, and VOC of 21, 130,
1.4, .2, and 51 g/kg for stoves and 14, 85, 1.7, .2, and 13 g/kg for
fireplaces (U.S.EPA, 1983b). Split was back-calculated using these values.
d. TSP emissions of 34,753,991 T/yr includes 28,225,321 T/yr from unpaved
road dust which thus accounts for 67% of total TSP emissions from
transportation related sources.
III-2
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TABLE III-2. Emissions of Various Pollutants in 1981 from
Wood Burning Source Categories
(Thousand tons/Year)
Total
Suspended
Particulates
(TSP)h
Source
Category
Residential
Wood
Combustiona
- Stoves 903
- Fireplaces 239
Ind. Wood Com. 76
Forest Managed
Burning 431
Agricultural
Burning 72
Res. Open
Burning 239
Forest
Wildfires 438
Total of
"Wood-Burning"
Sources 2,442
Transportation 34,754J
Inhalable
Particulates
( 10 urn)
(IP)
812b
215b
53c
4lOd
68e
215f
459d
2,232
N/A
Carbon
Monoxide
(C0)h
5,589
1,450
121
2,412
476
1,022
3,982
15,052
77,832
Polycyclic
Organic
Matter
(POM)1
9.655
0.690
0.066
0.330
N/A
N/A
0.906
11.647
7.04
Total of
Inventoried
Sources
42,3358
N/A
102,8568
19.8178
a. Residential wood combustion emissions estimates have been increased by 25%
over the NEDS values used in Table III-l, as explained in the text.
b. Inhalable particulate fraction estimated at 90% of TSP based on Rau, 1984.
c. Inhalable particulate fraction estimated at 70% of TSP based on PEDCo,
1984.
d. Inhalable particulate fraction estimated at 95% of TSP based on data by
Sandberg and Martin, 1975 which found 92% of slash burning emissions mass
to be associated with particles of 5 urn diameter and smaller.
e. Sandberg and Martin data (1975) assumed to apply (see d. above).
f. Rau (1984) data assumed to apply (see b. above).
g. Totals include RWC emissions correct as explained in a. above.
h. Data from NEDS (U.S. EPA, 1984a).
i. Data is for 1980 and from Radian (1983).
j. Includes 28,225,321 T/yr from unpaved road dust.
III-3
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The NEDS estimates indicate that for these wood-burning sources about
41% of the TSP and CO is contributed by Residential Wood Combustion.
The NEDS data shows that woodstoves alone are estimated to account for
over 80% of the TSP and CO emissions from RWC, and about 32% of the
emissions from all the wood burning sources shown in Table III-l.
Table III-2 compares the relative emissions from various wood burning
sources of Total Suspended Particulates (TSP), Inhalable Particulates
(IP), Carbon Monoxide (CO) and Polycyclic Organic Matter (POM).
A recent study concluded that all of the RWC emissions estimates from
NEDS were approximately 25% low because underlying wood usage
estimates were calculated in dry tons (Nero and Associates, Inc.,
I984b). These had not been increased to account for normal firewood
moisture contents, which typically range from 20%-30% by weight.
Uacorrected NEDS estimates are shown in Table III-l, with corrected
estimates used in Table III-2.
Any estimate of wood burning emissions must rely on some method of
averaging or selecting from the wide range of reported emission factor
data. Thus, the values shown in Table III-2 should be considered as
best estimates. The uncertainty in the emission estimates in Table
IH-2 is probably the highest for POM's, and for the outdoor burning
sources. For example, available POM emission factors can vary by
several orders of magnitude (Harkov, 1984). Estimates of the emission
factors for open burning, wild fires, managed forest burning, and
agricultural burning are more uncertain, because it is more difficult
to measure both the amount of material burned and the total emissions
produced.
A review of Table IH-2 shows that wood-related sources in 1981
accounted for 5.8% of all inventoried TSP source emissions and 14.6%
of all inventoried CO source emissions. However, the total TSP
emissions are dominated by the transportation categories (82% of the
total). For example, the source category unpaved road dust, accounts
for 67% of the total estimated TSP source emissions. Transportation
emissions also account for about 76% total U.S. CO emissions. On the
order of 90% of the transportation TSP emissions are from unpaved and
III-4
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paved road dust. When the transportation category emissions are
excluded, wood-related TSP emissions accounted for 2.44 million tons
per year or 32% of the non-transportation TSP emissions of 7.6 million
tons per year.
A comparison of emissions in Table III-2 from wood burning sources
shows their relative magnitude. For each of the pollutants TSP, IP,
and CO, Residential Wood Combustion in stoves and fireplaces
contributes about 37% and 10%, respectively, to the totals from all
wood-burning sources. Forest managed burning contributes about 16% to
18% of total wood-burning emissions for TSP, IP, and CO, and forest
wild fires contribute about 20%-27% of the total for those three
pollutants. The contribution from industrial wood combustion and
agricultural burning is much smaller, with each at about 3% or less
for those three pollutants. Residential open burning is estimated to
contribute about 10% of the TSP and IP and about 7% of the CO. It is
noteworthy that the emissions from agricultural and forestry burning
are released, on average, much further from populated areas than the
other sources. Thus, while these source categories contribute about
40% of the TSP, IP, and CO emissions from wood-burning sources, their
percentage contribution to measured air quality impacts is on average
much lower in populated areas.
The relative contribution by various wood-related sources to POM
emissions is much different. However, results should be viewed in the
context that POM emission estimates for some of the source categories
shown in Table III-2 are not available. The others have relatively
high uncertainty due to the uncertainty in POM emission factors
(Harkov, 1984). POM emissions from stove wood burning and fireplace
wood burning account for 83% and 6%, of the total POM emissions from
the wood burning sources shown in Table III-2. This is consistent
with a recent study for EPA (Radian, 1983) which estimated that RWC
was the single largest source nationally of POM emissions.
2. Nature of Emissions From Various Wood Burning Sources
Emissions from various wood burning sources can be characterized in
III-5
-------
terms of the size of the particulates, the particulate carbon content,
the plume rise, where the emissions are emitted, and when they are
emitted, as summarized in Table III-3.
The nature of the particulate emissions from these various sources is
generally similar with the exception of industrial wood burning. For
most of the source categories, 90% to 95% of the emissions are
expected to be in the inhalable size range ( < 10 urn). Carbon
dominates the particulate mass emissions for all the sources except
industrial wood combustion. The difference is primarily associated
with the degree to which complete combustion is achieved. For all
these sources except stove wood burning and Industrial wood burning,
combustion conditions are not controlled. The highest degree of
complete combustion is generally achieved in industrial wood burning,
due to more expensive equipment and greater operator attention to
achieving complete combustion. In contrast, poor combustion
conditions are sometimes selected for woodstoves in order to lengthen
the time between stove reloadings.
RWC emissions have an enhanced ambient air quality impact, because the
emissions are released in residential areas with minimum plume rise.
Agricultural burning emissions occur in more rural areas and forest
burning emissions tend to be released even further from populated
areas. Such release conditions do not, of course, preclude impact on
populated areas. Industrial wood burning emissions are released in
industrial rather than residential areas, generally in hot buoyant
plumes with relatively high plume rise.
RWC emissions tend to be released at times which can produce
relatively greater impacts than comparable amounts of emissions from
other wood burning sources. RWC emissions are concentrated during the
winter evening hours when atmospheric mixing height can be limited
(due to residual solar heating effects and associated inversions).
RWC emissions are also concentrated during the winter months. For
many parts of the U.S., worst ventilation conditions occur during the
winter period.
III-6
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TABLE III-3. Characterization of Emissions from Various
Wood Burning Sources
Fraction of
Particulate
Mass In
Inhalable
Size Range
(< 10 urn)
Fraction
Carbon Plume
Content Rise
Where
Emitted
When
Emitted
Residential Wood
Combustion
- Stoves 0.9a
-Fireplaces 0.9a
Industrial Wood 0.7b
Combustion
.7*
.7*
Lowest Neighborhoods Winters:
above homes concentrated
in evenings
Low
,2-.558 High
Neighborhoods Winters:
above homes Almost
exclusively
in evening
Industrial Year Round:
land use throughout
day
Forest Burning
Emissions
Agricultural
Burning
0.95C
0.95d
.98
.78
Low
to
high
Generally
in remote
areas
Spring and
Fall: Most
during
daytime
hours
Low
to
high
More rural
farming
areas
Summer and
Fall: Most
during
daytime hours
Residential Open
Burning
0.9e
NA Low Neighborhoods Year round;
more in
Spring
and Fall;
daytime hours
a. Inhalable particulate fraction estimated at 90% of TSP (Rau and Huntzicker
1985).
b. Inhalable particulate fraction estimated at 70% of TSP based on PEDCo,
(1984).
c. Inhalable particulate fraction estimated at 95% of TSP based on data by
Sandberg and Martin, 1975 which found 92% of slash burning emissions mass
to be associated with particles of 5 urn diameter and smaller.
d. Sandberg and Martin data (1975) assumed to apply (see c. above).
e. Rau and Huntzicker (1985) data assumed to apply (see a. above).
f. Rau and Huntzicker (1985).
g. Nero and Associates, Inc., (1984).
III-7
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B. Factors Influencing RWC Emissions
The amount of emissions produced by households burning the same amount of
wood can vary significantly. Knowledge of how RWC emissions can change
with different factors is essential both to estimate the amount of
emissions, and to develop successful RWC control strategies. This section
focuses on the following seven factors that influence RWC emissions:
• burning rate
• appliance design
• wood moisture content
• wood charge size
• appliance size
• fuel type
• wood piece size
Table III-4 summarizes the effects of these factors on RWC emissions.
Detailed discussion is presented in the text below. In this discussion a
greater emphasis is placed on stoves than fireplaces, and on particulate
emissions. This is because stoves often account for more RWC particulate
and CO emissions than fireplaces, and because there is more research
information on stove particulate emissions.
1. Burning Rate Effects on Emissions
Wood burning rates can affect both the amount of wood burned, and the
TSP, HC, and CO emission factors (g/kg) for that wood burning. Burn
rate effects are discussed in this section both on a grams per
kilogram basis and a grams per hour basis.
The traditional way to express emissions effects is in grams of
pollutant emitted per kilogram of fuel(wood) burned, or g/kg. This is
how RWC emission factors are expressed in EPA's compilation of
emissions factors, referred to as "AP-42" (U.S. EPA, 1983b). Woodstove
and fireplace emission factors from AP-42 are summarized in Table
III-5. However, expression of RWC emissions in grams of emissions per
hour (g/hr) has also become useful - e.g., in identifying burn rate
effects and in comparing different RWC appliances.
III-8
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Table III-4. Summary of How Various Factors Can Influence RWC Emissions
Factor Effects References
Burning Rate • Higher burning Hayden and
rates result Braaten, 1982;
generally in Allen et al, 1981;
lower emission Hubble et al,1981;
factors (g/kg) Butcher and
for TSP, CO, HC Sorenson, 1979;
and POM. Knight and Graham,
1982; U.S. EPA
1984b/gh
Appliance Design • Conventional wood stoves U.S. EPA, 1983
have higher emission (AP-42)
factors than fireplaces,
for CO, TSP, and HC.
• Among stoves, more complete Tiegs et al, 1984;
combustion with lower Allen and Cooke,
resultant emission 1983; Hayden and
factors can be achieved Braaten, 1982
by catalyst stoves,
catalyst add-on devices,
and improved design non-
catalyst combustion units.
• Although ranges can over- Tiegs et al, 1984
lap, in general, catalyst
stoves result in lowest
emissions, conventional
airtight stoves produce the
greatest emissions, and
improved design non-catalyst
stoves perform in between.
Wood Moisture Content • For stoves, the wood mols- U.S. EPA,
ture content which produces 1984 b/gh
the lowest particulate
emission factors is 20% to
26% (wet basis). Wood
moisture contents above
and below this range result in
higher emission factors.
• For fireplaces, higher wood Shelton, 1981.
moisture content levels
result in higher amounts of
unburned material. Specific
effects on CO, HC, or TSP
cannot be generalized from
literature to date.
III-9
-------
Table III-4 Continued (Page 2)
Factor Effects References
Wood Charge Size • Larger "charge size" Butcher and
in stoves generally results Sorenson, 1979
in higher emission factors
for TSP, CO, and HC.
Appliance Size • Larger fireboxes in stoves Burnet and Tiegs,
generally result in higher 1984
particulate emission factors.
Fuel Type • Softwoods have a higher DeAngelis et al,
volatile content. Information 1980.
is inconclusive regarding
whether hard or softwoods produce
more emissions.
Wood Piece Size • For stoves, larger wood Barnett and Shea,
pieces generally result in 1981; Allen and
lower emission factors Cooke, 1981.
for CO, HC and TSP.
111-10
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TABLE III-5. EPA Emission Factors For Stoves And Fireplaces'
Pollutant
Stove Emission Factor
(g/kg)
Particulate 21
Sulfur Oxides 0.2
Nitrogen Oxides 1.4
Carbon Monoxide 130
Volatile Organic
Compounds
- Methane 0.5
- Non-methane 51
(Ib/ton)
Fireplace Emission Factor
(g/kg) (Ib/ton)
42
0.4
2.8
260
14
0.2
1.7
85
28
0.4
3.4
170
1.0
100
13
26
Source: U.S. EPA (1983b)
III-ll
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As the following general relationships illustrate, the total RWC emissions
released are a function of both the amount of wood burned (kg), and the
associated pollutant emission factor (g/kg) achieved under the combustion
conditions at which the wood is burned.
Total Emissions
Released (g)
Burn
Time
(hr)
Emission
Rate (g/hr)
Amount of Wood
Burned (kg)
Burn
Time
(hr)
Burn Rate
(kg/hr)
Pollutant Emission
Factor (g/kg)
Pollutant Emission
Factor (g/kg)
\
Wood Heat
Value (Btu/kg)
\
Heat Output
(Btu/hr)
Burn rate changes can simultaneously affect both the amount of wood
burned and the associated emission factor.' Thus pollutant emission
factors should be referenced to the burn rates at which they were
determined, for they may not be as representative of RWC emissions at
higher or lower burn rates. In AP-42, EPA notes that its current
woodstove emission factors were based on tests conducted at burn rates
of 3 kg/hr or less (U.S. EPA, 1983b).
When estimating RWC emissions for an airshed, multiplying the amount
of wood burned by a pollutant emission factor (g/kg) which is
representative of areawide average or predominant burning practices is
the typical approach. AP-42 emission factors are commonly used,
unless better local estimates are available.
However, in testing woodstove emissions, it is desirable to test over
a full range of heat outputs (Btu/hr), which is also a function of
III-12
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KPANY, INC.
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bum rate, as illustrated above. Since pollutant emission factors
(g/kg) will also be varying over this range of burn rates, it is more
meaningful to express stove emissions test results as an emission rate
(g/hr) over the entire range of heat outputs tested. This accounts
for burn rate effects on emissions performance in a more accurate way
than could be done using a single or average emission factor. This
also allows the stove's emission performance over its heat output
range to be simply and clearly represented in a label (e.g. see Figure
V-2).
The emissions rate (g/hr) parameter thus enables appliances operating
over a range of heat outputs to be compared on a consistent basis.
The Oregon wood stove certification program describes stove emissions
performance on a grams per hour basis, based on a series of tests
conducted over the stove's entire heat output range.
Thus, emission factors (g/kg) and emission rates (g/hr) are useful in
different ways In analyzing and expressing RWC emissions J The
Influence of burn rate on both emission factors and emission rates is
further discussed in the next two sections.
a. Influence of Burn Rate on Emission Factors (g/kg).
For the pollutants TSP, CO, and HC, a decrease in wood stove
burning rate generally results in an emission factor (g/kg)
increase. This has been confirmed by many researchers In recent
years, Including: Butcher and Sorenson (1979); Allen and Cooke
(1981); Hubble et al, (1981); Knight and Graham (1982); Hayden and
Braaten (1982), and; Del Green Associates (U.S. EPA, 1984b/g).
Although the burning conditions and other parameters have often
been different, the general shape of the burn rate vs emission
factor curve has been consistent. For example, Figure III-l shows
CO emission factors vs wood burning rate for a conventional stove
(with and without catalyst) is measured by Hayden and Braaten
(1981). This example is illustrative of similarly shaped emission
factor vs burn rate curves identified by the researchers cited
above.
III-l3
-------
w
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W
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fi
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Q
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X
i
200
150
100
50
i S3
without catalyst
with catalyst
'SJ SI
1234
FIRING RATE, kg/hr
Source: Hayden, 1982
Figure III-l.. Variation_of CO Emissions Factor with Firing Rate for
A Catalyst-Equipped Horizontal Baffle Stove3
111-14
-------
The emission factor (g/kg) vs burn rate relationship is important
because of the potential emission reduction strategies which it
suggests. For example, if heat storage capacity could be added to
stoves, then higher burn rates can be used for intermittent
burning periods, with the appliance heat output distributed
smoothly over time via the heat storage mechanism. These higher
burn rates would yield lower emission factors. Even without heat
storage capacity, stove operators could burn the same amount of
wood at a higher burn rate, with non-burning periods
interspersed. This results in less net emissions due to lower
emission factors, but has the disadvantage of providing a
fluctuating stove heat output.
The relationship that lower burning rates result In higher
emission factors can also be important on an airshed scale. Two
areas may burn the same amount of wood but produce different
amounts of emissions because the wood is burned at a different
average burn rate. For example, stoves used in areas with colder
climates may be operated at higher average burn rates because the
housing structures require more heat per hour to maintain
comfortable temperatures.
For FOM's, the relationship between emission factors and burn rate
identified above appears to apply to conventional stoves but may
not apply to catalytic stoves. Hayden and Braaten (1982) report
that total POM emissions vs conventional stove burn rate vary in a
manner (and curve) similar to the relationship shown in Figure
IH-1. They found higher POM emission factors as burning rate
decreased. However, two other Investigators testing catalyst unit
performance have measured lower emission factors for various POM
compounds at lower burn rates. Kaight and Riight (1983) tested a
catalytic unit and found lowest emission factors for PAH
(polycyclic aromatic hydrocarbons) and benzo(a)pyrene (with
benzo(e)pyrene Included) at the lowest burn rates tested.
Similarly, DeAngelis et al, (1980) reported several catalyst stove
111-15
-------
tests In which the lowest emission, factors for naphthalene and
phenanthrene were measured at the lowest burn rate tested. This
phenomenon is not completely understood.
Regarding fireplaces, Muhlbaier (1981) reported that as fireplace
burn rate decreases partlculate emissions tend to increase. An
inverse relationship between burn rates and emissions (correlation
coefficient of -. 44) was identified. However, the degree to which
burn rate determines fireplace emissions factors cannot be
determined due to various limitations of Muhlbaier*s research.
For example, the reported correlation was for burn rate vs
particulate emissions rather than particulate emission factors
(g/kg). Also, most of the tests involved burning of kindling size
wood (100 gram pieces) which were placed on hot coals, which is
not typical of normal fireplace burning practices.
b. Influence of Burn Rate on Emission Rates (g/hr)
For catalyst stoves, lower burn rates generally result in a lower
gram per hour (g/hr) particulate emission rate. Figure III-2
shows the findings of Tiegs et al, (1984), which illustrate this
relationship. Although the data are presented on a heat output
basis, the curve would be very similarly shaped if converted to a
wood burning rate basis, because those researchers found overall
catalyst appliance efficiency to vary by less than 10% over the
range in wood burn rates tested..
The ability of catalytic stoves to emit at lower rates (g/hr) at
lower burn rates (kg/hr) is apparently attributable to more
complete combustion efficiency. This occurs because the exhaust
gas flow rate is lower and exhaust gas "residence time" near the
catalyst is increased. In low burn rate situations where
combustion of exhaust gases is no longer occurlng in the catalyst
region, emission factors could be expected to be somewhat higher.
This situation could occur either because of poor design, or at
low burn rates where the exhaust gas temperatures were too low to
111-16
-------
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NOTE1 EACH SYMBOL REPRESENTS
DIFFERENT WOOOSTOVE.
••TREND
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I
I
9 IO 19 2O 29 50
(L9) (U) (441 (53) (7.3) (86)
HEAT OUTPUT, 10^ BTU/hr (Kilowotl*}
Source: Tiegs et al, 1984
Figure III-2. Particulate Emission Rate vs Heat Output for
Catalytic Woodstoves
111-17
-------
allow combustion even in the presence of a catalyst. Allen et al,
(1983) have reported that secondary combustion of wood combustion
products begins to occur at temperatures above 260 C (500 F).
Regarding conventional stoves, available data show that burn rate
increases can result in an increase or_ a decrease In particulate
emission rates (g/hr) depending on the appliances and burn rates
compared. Data illustrating how emissions in g/hr vary with burn
rates show differing behavior for different conventional stoves.
Such behavior is demonstrated by Tiegs et al, (1984) in reports
for the Oregon Department of Environmental Quality (1983).
Accordingly, no general conclusions can be drawn regarding how
emissions in g/hr for non-catalyst appliances tend to vary with
burn rates. Further research may result in the detection of some
consistent relationship.
2. Emissions Effects of Appliance Design
A wide range of emissions findings have been reported for various
designs of wood burning appliances by numerous investigators.
Findings discussed in this section include the following:
• EPA emission factors (g/kg) for stoves vs fireplaces;
• Design factors which can minimize emissions; and,
• Emission performance of different stove designs.
a. EPA Emission Factors
EPA emission factors are shown in Table III-5 for residential
stoves and fireplaces. Emission factors presented for both CO and
TSP are about 50Z higher for stoves than fireplaces.
EPA revised its emission factors to the levels shown in Table
III-5 in 1983. The wood stove emission factors may be
conservative, since some investigators have conducted their stove
emissions testing at burn rates higher than typical. As discussed
above, testing at a higher burn rate often yields a lower emission
111-18
-------
factor (g/kg). For example, EPA based its estimates of stove
emission factors on various stove tests in which wood was burned
at a rate of 3 kg/hour or less. However, Hayden (1981), the
Oregon DEQ (1984), and Barnett (1981) have reported average stove
burn rates for Ottawa, Canada, Oregon, and northern New York to be
3, 3.7, and 3.5 pounds per hour (1.36, 1,68, and 1.59 kg/hour).
b. Design Factors Which Can Minimize Emissions
Aside from add-on pollution control equipment where emissions
would be filtered or otherwise "captured", the reduction in
emissions of pollutants such as carbon monoxide, unburned
hydrocarbons, tars and other carbonaceous particulate matter
hinges on the achievement of more complete combustion. Various
woodburning appliance designs can be selected, but any design
approach must optimize the following three factors in order to
approach complete combustion:
• Time; There must be sufficient residence time in the area
where combustion occurs for unburned hydrocarbons and
carbonaceous material to be combusted.
• Temperature; Sufficiently high temperatures must be
maintained in the combustion zone(s) to support combustion.
• Oxygen Availability; Oxygen must be available in the
combustion zone(s) in sufficient quantity and distribution to
enable combustion of previously unburned materials.
EPA has previously commissioned research which reported on design
factors which can reduce RWC emissions by achieving more complete
combustion. Research by Allen and Cooke (1981) constitutes one of
the best summaries of such design considerations. The design
considerations presented below, are from Allen and Cooke (1981),
unless otherwise noted:
111-19
-------
• Designs which limit the amount of wood exposed to heat (but
not yet burning) can avoid excessive pre-burnlng pyrolysis.
This can help avoid situations where insufficient combustion
air is available to allow complete combustion.
• Smaller firebox sizes tend to result in hotter burning and
therefore more complete combustion (Burnett and Tiegs, 1984).
• Primary air Inlets can be oriented to better channel
combustion air so as to optimize combustion conditions.
• Turbulent air Introduction can promote better air-fuel mixing
and thereby more complete combustion.
• Higher combustion zone temperatures result In more complete
combustion. Insulation of the combustion zone can promote
such higher temperatures.
• Thermostatic control devices used should not allow such severe
air-supply cycling that sufficient oxygen is often
unavailable.
• Channeling of gaseous pyrolysis products to a well-controlled
combustion zone can result in more complete combustion,
• A secondary combustion zone can be provided. To enable
secondary combustion to occur, air pre-heating and other
measures to Increase temperatures in that zone can help.
• An auxilliary ignition source can be used to combust exhaust
products more completely.
• Catalytic afterburners can be used to achieve more complete
combustion.
111-20
-------
• Heat storage capacity can enable burning to occur at a faster
rate (lower emission factors) while still maintaining a
relatively uniform rate of heat output.
Any of the above design considerations can be used to achieve more
complete combustion. Different options can be selected to achieve
the same result. For example, if an effective secondary
combustion chamber or catalyst is integrated into a 'design, the
completeness of combustion in the primary burning chamber is less
critical. Regardless of design, in order to achieve complete
combustion in the unit as a whole, the elements of residence-time,
temperature, and oxygen availability must be optimized in one of
the primary, secondary or after burning combustion areas.
Bnlsslons Performance For Different Stove Designs
Although there is much emissions testing information available for
different stove designs, one major obstacle to comparing the
emissions performance of different stove designs is that different
test methods and burning conditions have often been used. This
section reports on emissions testing work by several leading test
facilities (Tiegs et al, 1984; TVA, 1983; NYSERDA, 1984).
The largest available data base on emissions from different stoves
(at consistent burn rates) is the testing work which has been
reported by Tiegs et al, (1984). Reports on that work enable the
comparison of the emissions performance for conventional wood
stoves, catalytic wood stoves, catalytic add-on devices and "new
technology" woodstoves. Little or no data are available in the
literature on how emissions vary with different fireplace designs.
Table III-6 shows the range in emission rates (g/hr) identified
for these appliance classes. The data presented represent about
one-hundred tests of thirty different models. This testing showed
that catalytic woodstoves generally operated at the lowest
emission rates, with new-technology non-catalytic devices higher,
111-21
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and conventional devices having the highest emission rates. In
this research effort, two baffled airtight stoves, considered
typical of the majority of wood stoves on the market, were
selected to represent conventional wood stoves. Five "new
technology, non-catalytic" wood stoves were selected to represent
this category. These devices employed design modifications such
as secondary combustion chambers, preheated secondary air, and/or
distribution optimizers.
While the catalytic woodstoves generally had the lowest emission
rates, and conventional stoves generally had the highest emission
rates, the range of performance does overlap to a certain extent.
Thus, catalytic stoves produced more emissions than conventional
or new technology non-catalytic stoves in some of the tests
reported by Tiegs et al, (1984).
The catalytic add-on devices tested were inserted on top of a
conventional wood stove, between the flue collar and stove pipe.
This arrangement reduced the particulate emission rate from
fourteen to forty-four percent, over the range of heat output
conditions tested, according to Tiegs et al (1984). The authors
noted: "the add-on catalysts displayed erratic characteristics in
ignition temperatures, making performance inconsistent and
unpredictable". At least one of the add-on devices worked more
efficiently on a different airtight stove than on the stove used
most for these tests. This indicates that performance of add-on
devices can vary significantly for different stoves. The add-on
catalytic devices tested do not represent the maximum reductions
achievable by this technology. They only represent three units
out of the population developed to date.
Figure III-3 shows the difference in particulate emission rates
achieved by the three catalytic add-on devices tested. Add-on
unit 1 was most effective at lower heat output rates. Add-on unit
2 most effective at higher heat output rates. Add-on unit 3
performed worst, at both low and high heat output rates, and
achieved no emission reduction at all during the low heat output
111-23
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NOTE: Each bar represents the average of two tests.
Figure III-3.
Particulate Emissions From a Conventional Woodstove
with Catalytic Add-on Devices
Source: Tiegs et al, (1984).
111-24
-------
test. This further illustrates that catalyst add-ons can vary
substantially In their effectiveness, depending upon operating
conditions.
The Tennessee Valley Authority has conducted 132 woodstove
appliance tests addressing emissions and efficiency (TVA, 1983).
An evaluation of this work Illustrates the difficulty which is
often encountered in applying the findings from emissions testing
research to evaluate the emissions performance of household wood
burning appliances as they are commonly used.
Out of the total of 132 tests, none of the tests represent common
household burning conditions. Twenty-nine (29) of the tests used
"brands" (small pieces of wood comparable to garden stakes) which
are "not typical of the fuel used by the average homeowner" (TVA,
1983).
Of the 103 tests which used oak cordwood as fuel, the moisture
content of the wood used was atypically low (10.4X), achieved by
oven drying of the wood. Available sources indicate that
residential cordwood typically has a moisture content of more than
20% (Tombleson, 1984). This discrepancy means that the TVA data
base has limited value for characterizing typical household wood
burning emissions.
For example, research reported in EPA (I984b/h), which is shown
graphically in Figure III-4, indicates that emission testing with
102 moisture content wood can produce emissions at a substantially
higher rate (factor of 3 or more) than when normal moisture
content wood Is used.
The New York State Biergy Research and Development Authority also
conducted emissions and efficiency testing of eight different
stoves (NYSSU5A, 1984). That study examined particulate emissions
from several types of new technology stoves including! a)
catalyst-equipped stoves; b) a secondary-combustion stove, and; c)
conventional stoves with add-on catalytic inserts. All exhibited
111-25
-------
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particulate emission rates where were 50% to 80% lower than those
of conventional airtight stove. Carbon monoxide rates were also
generally reduced, although to a lesser extent.
3. Emissions Effects from Wood Moisture Content
The most comprehensive treatment of the issue of how stove emission
factors vary with wood moisture content is reported in research in EPA
(I984b), which is the basis for the conclusions presented below.
Other research which reports some emission factor information for wood
at different moisture contents (Barnett and Shea, 1981; Rudling et
al, 1981) offers too few data points, or involves testing at different
burn rates, so that general conclusions are difficult. Information is
available from Shelton (1981) on how combustion efficiency varies with
wood moisture content, but it is not possible to determine from those
results how specific emission factors (e.g., for TSP, or CO, or HC)
vary with wood moisture content.
Figure III-4 shows the Del Green Associates findings (U.S. EPA, 1984b;
Task 5) on how particulate emission factors vary with wood moisture
content. Data are shown for wood moisture content on both a wet and
4
dry basis. Emission factors are shown in units of g/kg and g/10
Btu. The data have also been "normalized" in an attempt to factor out
the differences in emission factors associated with burn rate
differences rather than wood moisture content. Based on this data,
and data from Shelton on how combustion efficiency varies with wood
moisture content, Del Green Associates concluded that lowest
particulate emission factors probably occur in the 25% to 35% moisture
content range on a "dry basis" (which is 20% to 26% on a "wet basis").
M
Del Green Associates also measured how carbon monoxide, hydrocarbons,
and creosote emissions varied with different moisture contents.
Interestingly, their results for CO and HC showed that emission
factors for those pollutants were lowest for the highest moisture
content wood tested. Thus, woodstove emission factors for carbon
monoxide and hydocarbons appear to have a different relationship to
moisture content than that discussed above for particulates.
111-27
-------
Regarding how fireplace emission factors (g/kg) vary with wood
moisture content, the data are even more limited than for stoves.
Rudling and Ahling (1981) report four test results, but the reported
units (ppm CO, and ppm HC) do not enable conversion to g/kg figures.
Shelton (1981) reported combustion efficiency research which provides
some insight on how much "unturned material" is emitted for wood
burned in fireplaces at different moisture contents. Based on
Shelton's combustion efficiency vs wood moisture content relationship
(Figure III-5), it is apparent that the total amount of unburned
material (predominately HC, CO, TSP, and deposited creosote) increases
with increasing wood moisture content. However, no direct conclusions
can be drawn regarding how fireplace emission factors in (g/kg) for
specific pollutants (I.e. TSP or CO or HC) would vary with moisture
content.
In sunmary, particulate emissions factors for stoves vary with wood
moisture content. Lowest emission factors appear to occur in or near
the 20% to 26% moisture content range, on a wet basis. Higher
particulate emission factors appear to result when wood with moisture
content above or below that range is burned. However, since data on
this subject are limited, the moisture content range which produces
lowest emissions may lie slightly above or below the 20%-26% range
cited.
4. Effects Of The Amount of Wood "Charged"
Butcher and Sorenson (1979) postulated and demonstrated a positive
relationship between the amount of wood charged in a stove and the
resulting particulate emission factors. Allen and Cooke (1981) found
that stove CO and HC emission factors (g/kg) increase with Increasing
charge size. No Information is available from the literature which
determines whether or to what extent this relationship applies to
fireplace combustion.
111-28
-------
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MOISTURE CONTENTS
Figure III-5. Effect of Wood Moisture Content on
Fireplace Combustion Efficiency
Source: Shelton (1981).
111-29
-------
The Butcher and Sorenson (1979) research indicated that stove
particulate emission factor is directly proportional to the amount of
wood charged and inversely proportional to the wood burning rate. The
equation developed by them to describe this relationship is shown
below:
y - 10.34 m/q - 1.18
where:
y • emission factor in g/kg
m " fuel charge in kg of wood
q " combustion rate in 10,000 Btu's output/hour
and:
" [17>970-(203 * p)]
10,000 * h
where:
p " percentage of wood moisture content (wet basis)
h - length of burn in hours
Figure III-6 shows a plot of the data collected in the Butcher and
Sorenson (1979) research, and a superimposed line calculated using
this data and his equation above.
The physical explanation which underlies the identified relationship
appears to be related to the intensity of the fire. Intensity of a
fire can be thought of as the heat release rate from ongoing
combustion divided by the amount of wood charged. For the same wood
charge ("m"), burning with a greater heat release results in a more
intense fire and less emissions. For the same heat release rate
("q"), a smaller wood charge ("m") results in a more intense fire and
less emissions.
111-30
-------
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Figure III-6. Emission Factor as a Function of m/q
Source: Butcher (1979)
III-31
-------
Testing conducted by Allen and Cooke (1981), which focused on carbon
monoxide and hydrocarbons, also found that larger charge sizes produce
higher emission factors. Their explanation of the underlying physical
phenomenon was as follows:
"The amount of wood loaded into the stove will have a large
Influence on the amount of pyrolysis products leaving the stove.
The emissions Increase with the increase in wood inventory at the
same burning rate, due to the Increased quantity of wood exposed
to heat and thereby subject to preburning pyrolysis."
No information was identified which addresses whether this
relationship applies for fireplaces.
5. Emission Effects From Burning Unit Size
Research by Burnet and Tiegs (1984) Indicates that particulate
emission factors Increase with increasing firebox size. They
evaluated five different conventional stoves with different firebox
sizes. The particulate emission factors (gAcg) was found to decrease
with decreasing firebox size for comparable burn rates. They
explained this phenomena as follows: "temperatures will generally be
higher, and combustion more Intense, if a smaller firebox stove is
used than a larger firebox stove, burn rates being equal".
Research by Butcher and Sorenson (1979), discussed in the previous
section indicated that stove particulate emission factors are
proportional to the amount of wood charged. This also supports the
hypothesis that smaller sized stoves will tend to produce emissions at
a lower emission factor (g/kg), since charge size should typically be
smaller In a smaller stove.
Burnett and Tiegs (1984) addressed firebox size, but did not address
how charge size varied as they tested stoves with different
fireboxes. Butcher and Sorenson (1979) addressed charge size but did
111-32
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not address firebox size. Thus, It Is not possible to demonstrate
from the work by these researchers how these two obviously related
factors interact in influencing emissions. No information was
identified which addresses whether this relationship applies to
fireplace size.
f
6. Effects of Fuel Type
The available data are too limited to draw general conclusions about
emission factor differences for different types of wood. Although
emissions have been measured when many different types of wood were
burned, too few of the tests were conducted under comparable
operating conditions. Among emissions investigators such as Allen and
Cooke, DeAn gelis, Knight, Butcher, Tiegs, Del Green Associates, and
Barnett, none have reported to date that soft or hard wood generally
produces greater or lesser emissions.
DeAngelis et al, (1980) noted that yellow pine In the "green state"
did produce higher emission factors (g/kg) than green oak, seasoned
oak, or seasoned pine, but such a finding does not provide a basis for
generalization. The researchers postulated that the emissions
differences might have been, associated with the characteristics of the
volatile carbon portion of the green pine wood. They reported that
softwoods contain 0.8% to 25% resinous material while hardwoods
contain only 0.7% to 3% (Wise and Jabn, 1974) and concluded that the
higher resin content of the green pine could have been responsible for
the higher emission factor produced. Leading experts on RWC at the
Oregon Department of Eavironmental Quality (Tombleson, 1984) agree
that no firm conclusions can be drawn from current data regarding
whether softwoods or hardwoods have higher emission factors.
7. Emission Effects of Wood Piece Size
Both Barnett and Shea (1981) and Allen and Cooke (1981) have noted
that smaller sized logs burn with higher emission rates than larger
logs when burn rates are held constant. Results of Allen and Cooke
111-33
-------
are based on CO and total hydrocarbon emissions. Both of these
research teams concluded that small wood pieces can result in the
generation of more pyrolyzed wood gases than sufficient oxygen is
available to combust:
"The size of wood has a large effect on the rate of pyrolysis.
The smaller pieces of wood result in a shorter distance for the
pyrolysis products to diffuse, a larger surface area to loss
ratio, and a reduction in time required to heat the entire piece
of wood" (Allen and Cooke, 1981).
Barnett and Shea (1981) similarly postulated that the "surface area to
wood volume" is the key parameter:
"... results indicate that log diameter has a large effect on
emissions. Uadoubtedly, the surface area to wood volume
relationship is a key factor. Thin logs have a large surface area
to volume ratio. Therefore, these logs heat up relatively fast
and then release their volatiles at a fast rate. This process is
further aided by the large surface area of the logs through which
volatiles are released."
Barnett and Shea (1981) developed a best fit equation for a
thin-walled convective heater operated with a stove surface
temperature of 500° F:
y - 11.3 - 9.9 [log (log size)]
where:
y • TSP emissions factor In grams per pound
log size - log diameter in laches
If the emission factor (y) is expressed in g/kg, the equation
converts to:
y - 24.9 - 21.8 [log (log size)l
111-34
-------
Table III-7 shows (Column 2) how emission factors vary with log
diameters ranging from 1/2 to 6 Inches. Column 4 shows the % emission
factor reduction which results from increasing log diameter in several
2 inch increments, based on the equation above. As can be seen, each
increase in log size by 2" is predicted to decrease the emission
factor by about 33%, within a range of common log sizes.
Such a relationship holds promise as a simple and unrestrictive
control strategy. People could be encouraged to burn larger wood
pieces in stoves. Since less wood splitting work would be involved,
this idea might be readily accepted and adopted.
Available information on how wood piece size affects fireplace
emission factors is limited. Although Muhlbaier (1981) reported
fireplace testing results in which larger wood pieces produced a
higher particulate emission factor, several factors preclude
generalizing her findings to the population of fireplaces. For
example, her tests involved atypically small wood charges (most less
than 2.1 kilograms). Also, the large pieces stopped burning, and thus
burned in the smoldering phase for at least some time period. lastly,
since the large pieces were not completely burned, their emission
factors do not include the cleaner burning charcoal phase of
combustion. Thus no conclusions can be drawn at this time regarding
how wood piece size effects fireplace particulate emission factors.
C. Trends In Wood Burning Appliance and Wood Fuel Use
The most readily available information on trends In the U.S. on wood
burning appliances is U.S data on sales of Residential Wood Burning
devices. This information, for 1972 to 1982, is presented in Table III-8
and plotted in Figure III-7. Figure III-7 shows annual sales and
cumulative sales for the 1972 to 1982 period.
The annual sales graph illustrates the "boom" in wood stove sales spawned
by the increase in conventional energy prices subsequent to the Arab Oil
Embargo of 1973. Stove sales apparently peaked in 1979. Despite this
"peaking", a plot of cumulative sales between 1972 and 1982 suggests that
111-35
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TABLE III-7. Effect of Log Size on Barticulate Emission Factora
Log Size Predicted
(inches) Emission Factor3
(g/kg)
Example Log Size
Change From
Resultant %
Emission Factor
Decrease*5
0.5 31.5
1 24.9
2 18.3
3 14.5
4 11.7
5 9.7
6 7.9
2" to 4" 36%
3" to 5" 33%
4" to 6" 32%
A. From an equation reported by Barnett and Shea, 1981.
b. Based on estimated emission factors in Column 2.
111-36
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111-37
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the number of units In operation has continued to increase, at least
through the period for which data are available. Figure III-7 shows both
annual sales and cumulative sales for the 1972 to 1982 period.
Strictly speaking, sales of replacement units should be subtracted from
cumulative sales to estimate total additional units operating. However,
assuming a 10-15 year stove life, this correction should not be large,
over the decade shown in Figure III-7.
The total number of wood burning units in operation is a major determinant
of total national KWC emissions. This has dramatically Increased in the
last decade, and is probably still increasing (depending upon the rate of
retirement and/or replacement of burning units).
Accompanying the growth in RWC in the last decade has been a shift from
fireplace to woods tove use in some areas (Nero and Associates, Inc.,
1984). This is probably because stoves are generally more efficient for
space heating. However, more pollutant emissions generally result from
this shift, especially where stoves are operated in an airtight mode.
Typical stoves produce about 50% more TSP and 00 emissions per unit of
wood burned than fireplaces (Table III-5), so a shift in woodburning
activity from fireplaces to stoves results in an emissions increase
greater than that from the growth in wood usage alone. For example, based
on current EPA emission factors (see Table III-5; U.S. EPA, 1983b), if an
area burns 70% of its wood in stoves instead of in fireplaces, the
resultant TSP and CO emissions are about 17% higher.
Several other sources of information provide insight into residential wood
usage trends. U.S. Census data (DeAngells et al, 1980; Skog and
Watterson, 1983) on the number of U.S. households which use wood as their
"primary heating fuel" show that this number decreased from about
8,000,000 households in 1940 to about 660,000 households in 1974.
Households using wood as the primary heat source began to increase at that
point, rising to an estimate 2,600,000 households in 1980. This
information is shown in Table III-9.
111-38
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TABLE III-9. Trends in Residential Wood Usage
Year
1940
1950
1960
1970
1974
1976
1980
1981
Number of
U.S. Households
Using Wood As
Their Primary
Heat Source
8,000,000a
4,200,000a
2,100,000*
800,000*
660,000*
912,000*
2,600,000b
NA
Annual U.S.
Residential
Wood Usage
(Dry Tons/Yr)
NA
NA
36.432.000C
23,301,OOOC
21.567.000c
28,002,000c
47,543,OOOC
48,215,OOOC
a HeAngelis et al, 1980.
b Skog and Watterson, 1983.
c U.S. Doe /EIA, 1982b.
NA-Not available
111-39
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Another study, commmissioned by the U.S. Department of Biergy (U.S.
DOE/EIA, 1982), estimated that total annual U.S. residential wood usage
dropped from 36.4 million tons (dry basis) in 1961 to 20.6 million dry
tons in 1974, and rose thereafter to 48.2 million dry tons in 1981.
Residential Coal Usage Trends
Residential coal usage accounted for less than 3% of all U.S. coal usage
and less than 1% of all residential energy usage in 1980 (U.S. EPA,
1984b). No historical data base was identified in this study which
estimated annual residential coal usage over the last 20 years. A 1980
U.S. Department of Energy Survey (U.S. D.O.E., 1982) estimated that total
1980 U.S. residential coal usage was about 4.5 million tons, which
compares to the 47.5 million dry tons of wood burned in the U.S. In 1980
(U.S. DOE/EIA, 1982).
Appliance sales data from the U.S. Department of Census (see Table III-8)
also indicated that residential coal usage is small compared to
residential wood usage. For the year 1980, the only year in which
separate estimates are available for coal vs wood stove appliance sales,
coal burning appliance sales only amounted to about 5% of woodburning
stove sales.
Although there is no direct measure available of historical residential
coal usage by year, some trend information is available on shipments of
Pennsylvania anthracite between 1955 and 1980. While these estimates
include anthracite used in sectors other than the residential sector, they
do include the type and size of coal most commonly used for residential
heating. This data are shown in Figure III-8. This information shows
that annual anthracite shipments decreased until 1975, then stayed about
the same through 1978 and began to increase thereafter.
Since Information on past trends in residential coal usage Is limited,
studies which project future usage of coal can be used as an indication of
whether residential coal usage is likely to increase substantially. Three
such studies reported by EPA (1984b) do not project major expansion in
residential coal usage. The first, a U.S. DOE report entitled Energy
Projections to the Year 2000, projected residential coal usage to remain
111-40
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constant between 1980 and 2000 at about 4.5 million tons per year. A
second U.S. DOE report, 1981 Annual Report to Congress, projected
residential coal usage to decrease by about 30% between 1980 and 2000.
The third study by the Office of Technology Assessment (1980) projected
residential coal usage to double between 1985 and 2000.
D. Approaches and Methods for Estimating RWC Emissions
The following aspects of estimating air pollutant emissions from
Residential Wood Combustion (RWC) discussed in this section are:
• Approaches available for quantifying RWC wood usage, based on
household surveys, wood supplier data, and census and related
information;
• Translation of RWC wood usage estimates into emissions estimates,
including selection and use of RWC emission factors, and discussion of
the wide range of such factors In the current literature; and,
• Projection of future RWC emission levels, including discussion of
various trend factors and a model to project wood usage.
1. Quantifying RWC Wood Usage
The strengths and limitations of three approaches to quantify RWC wood
usage discussed here are: a) direct surveys of households; b) wood
supplier Information, from commercial and other wood supply sources;
and, c) use of census data and related information about the use of
wood for space heat in residences, and about the prevalence of wood
burning heating equipment in houses.
a. Household Surveys
Traditionally, survey methods are used to measure any phenomena or
attitudes within an areawide population. Carefully designed
questionnaires are typically administered to a judiciously
selected, random sample of the population. Sample size and degree
of randomness determine the accuracy and representativeness of
survey results.
111-43
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RWC emission sources axe households scattered throughout an area.
The density and distribution of RWC households can vary widely,
both within a particular local area and among different
localities. Wood usage per household, areawide RWC appliance mix,
/
and other factors can also vary considerably among different
localities (Nero and Associates, Inc., 1984). This indicates the
risk of assuming that: a) RWC wood usage estimates from one
locality will be representative of another locality, even within
the same state or region; and, b) that neighborhood scale survey
results are representative of the larger metropolitan area. RWC
wood use surveys are only representative of the population sampled.
RWC household survey questionnaires should be designed to
determine as many of the following types of Information as
practicable:
• The fraction of area households which burn wood, preferably
categorized by type - e.g., single family, owner vs renter
occupied etc.;
• /mount of wood used per household during a heating season
(cords), for major types of RWC appliance - e.g., fireplaces,
woodstove, fireplace insert, furnace, etc.;
• Number and type of RWC appliances in use;
• Type and source of wood used;
• Wood storage method, and time seasoned before use;
• Degree of home weatherization;
• Whether RWC is a primary or secondary means of space heating,
or only used for aesthetic purposes, and whether such usage
patterns will continue or change;
111-44
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• Burning practices - e.g., time of day when wood burning
occurs, typical wood charge size and/ or piece size, and
whether airtight operation occurs and when; and,
• Demographic information (optional) - e.g., household size,
income level, age, location, etc.
The first three items above provide the main information needed to
quantify RWC wood usage. Characterizing the amounts of wood
burned for major RWC appliance categories, and types of RWC
appliances in use, is important, because some appliances burn wood
more cleanly.
The next two items (source and storage of wood) provide valuable
indicators of wood moisture content, and the origins and costs of
wood fuel relative to other heating fuels. The next two items
help characterize whether RWC Is a primary or supplemental heating
fuel, and how its use varies with home weather ization.
Characterization of the degree to which local homes are already
weatherized, local firewood moisture content, and primary wood
supply sources, not only helps understand local RWC, but also may
help design RWC emission control strategies.
The Information on burning practices can indicate how RWC emission
densities are likely to vary during a day or week. It can also
afford useful information on other factors which influence
emissions - e.g., wood charge size and piece size, and how often
burning devices are operated in a damped down or "airtight" mode.
Such information is useful in many ways, including: a) selection
of appropriate emission factors; b) identification of practices
that could be targeted for attention in emission control
strategies; and, c) identification of "typical" burning practices
to be simulated in laboratory emissions testing of RWC appliances.
111-45
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Determining whether RWC is a major household heating method or an
aesthetic amenity, and whether households anticipate Increased or
decreased RWC activity, also helps understand present KWC impacts
and future trends. Cross tabulation of survey responses with
demographic information can indicate whether RWC activity is
concentrated In particular population groups. This can help
understand local wood burning activity, and target public
information efforts and emission control strategies.
Household RWC surveys have been conducted by telephone, by mail,
door-to-door, and using combinations of these methods. In
general, telephone or other "in-person" approaches allow better
probing for desired Information, better control over sample
selection (randomness), and better determination of respondent
characteristics. Random sampling of the population being surveyed
Is important to assure that survey results are representative of
that population as a whole.
Mallback questionnaires are significantly less costly, but the
sample size and randomness Is a function of who chooses to
respond. Telephone follow-up to mailed questionnaires can improve
sample size and probably randomness as well. To obtain optimal
sample randomness requires telephone interviews, in order to
assure that completed surveys represent a stratified random sample
- i.e., that respondents exhibit the same basic characteristics
(age, sex, income, etc.) as the population being sampled. Other
useful quality controls Include: provisions to assure access to
unlisted phone numbers in the sample called, and the ability to
determine the geographic distribution of respondents, e.g. through
zip codes or other means.
Surveys are best conducted in the spring, when wood usage for the
recent heating season Is better known. In-person Interviews
should be done when heads of households are home — i.e., mostly
In the evenings. Training and supervision of Interviewers is
important to assure consistency of approach, deal with problems as
111-46
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they arise, and determine invalid responses. Pretesting of survey
questionnaires on a small sample, say 50 respondents, is the best
way to identify and correct awkward survey questions or unforeseen
problems, and to complete interviewer training.
Standard statistical or polling procedures can be used to
preselect a sample size that is affordable and meets desired
accuracy criteria. As a first approximation, a random sample of
400 valid responses should provide survey results at a 95%
confidence level (See Appendix A). This size sample is a good
goal, regardless of local population size, or survey method unless
budget constraints dictate a smaller effort. In very small
communities, a substantial fraction of the entire local population
could be surveyed, if resources permit.
Analysis of survey results should provide at least the first three
of the following types of wood usage estimates:
• Number of wood burning households;
• Cords used per household - e.g., per "average" household,
and/or per wood burning household, or for any other household
category (e.g., single vs multiple family dwellings) desired
to help characterize aggregate areawide wood usage;
• Cords used per type of RWC appliance — I.e., fireplaces,
Inserts, woodstoves, etc. — Including separate categories for
advanced design units, or certified units in communities which
require certification of wood burning devices;
• Cords obtained from each major supply source — e.g.,
self-cut, commercial purchase, mill residues, etc; and,
• Cords of each predominant firewood species used.
111-47
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This quantitative survey information on RWC wood usage provides a
comprehensive basis for estimating RWC emissions, as discussed in
subsection two of this section.
Household RWC surveys have been conducted since the mid to late
1970s in several Oregon communities and in Missoula, Montana.
Recent surveys have also - been conducted by the State of Colorado
for seven communities (T8.C, 1985), and by the State of Idaho for
Boise (Edmundson, 1985). Appendix A contains Information
developed by the State of Oregon on: household survey design and
cost; the use of household surveys to develop RWC wood usage
estimates and emissions inventories; an example questionnaire and
cover letter; information on sample size calculation and sampling
error for mail back questionnaires; and, sample calculations of RWC
wood usage and emissions from survey findings.
b. Firewood Supply Data
Common sources of household firewood Include: self-cut wood from
public or private lands; purchases from commercial suppliers; and,
wood waste from wood processing facilities or construction sites.
Information may exist to estimate the amounts of household
firewood usage originating from one or more of these supply routes
for a given locality. However, comprehensive estimation of total
RWC wood usage from firewood supply data is usually not possible,
due to difficulty and/or lack of various data in identifying all
suppliers.
The percentage of firewood which is self-cut in an area is usually
significant. Much of the self-cut wood usage may be estimated
based on firewood cutting permit records from nearby public
forests. However, such permits are usually not closely
monitored. The best Information available may be the number of
permits issued, and a rough estimate by forest staff of the
average number of cords removed per permit.
111-48
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Commercial firewood sales from wood lots, or log truck loads
purchased from truck owners, are typically not a matter of
record. Private timber companies may also allow cutting on their
land by permit, or be a source of wood wastes eventually burned in
homes. Even wood theft from public or private forest land can be
a significant, unquantified source of firewood.
In general, estimation of RWC wood usage from firewood supplier
information is likely to be time consuming and would represent
only an unknown fraction of areawide total usage. Where a few
large suppliers account for most of the firewood usage in an area,
and can provide data, such analysis could serve as a useful check
on RWC wood usage estimates derived by using other methods.
c. Census and Related Data Sources
The U.S. Department of Commerce, Bureau of the Census, in its
decennial national census estimates: a) how many housing units
use wood as their primary house heating fuel; and, b) how many
housing units use "fireplaces, stoves, or portable room heaters"
as their primary house heating equipment (U.S. Department of
Commerce, 1983). Another bureau of Census report cross-tabulates
this Information with other census Information on housing
characteristics, including: location of such housing units inside
vs outside of central cities and standard metropolitan statistical
areas (SMSAs); the number of housing units in a structure, and
rooms per housing unit; household income, market value of housing
units, rental payments, year built, and heating fuel costs (U.S.
Department of Commerce, 1983).
Information is also available from several federal agencies which
describes the number of fireplaces in new housing built during a
given year or period (U.S. Department of Commerce and U.S.
Department of Housing and Urban Development, 1981; U.S. Department
of labor, 1958). Annual shipments by manufacturers of various
types of domestic heating stoves are also published by the Bureau
of the Census (U.S. Department of Commerce, 1982). Sales and
marketing data on residential wood burning devices may also be
111-49
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available for an area of interest (e.g., U.S. Department of
Energy, 1982a). A 1982 review of studies to estimate residential
wood energy consumption discusses both direct survey information
and indirect sources of information, such as the census reports
mentioned above (U.S. Department of Biergy, 1982b).
The use of census and other indirect information to estimate RWC
wood use has several advantages and some distinct disadvantages.
The major advantages are that the census and related Information
already exists, and is collected systematically, providing an
inexpensive representative data base, often available on national,
regional, state and local level. The major disadvantages are:
such data bases do not include estimates of the amount of wood
consumed; wood usage is not apportioned among categories or types
of wood burning appliances (e.g., stoves, fireplaces, inserts,
etc.); wood usage as a secondary or supplemental heating fuel is
not addressed at all; and no information Is provided on wood type,
seasoning or other wood fuel characteristics.
Lack of information on actual wood consumption in census data is a
major barrier to its use to estimate RWC wood usage, necessitating
development of estimation models based on other parameters which
can serve as proxies for wood usage. One of the leading examples
of this approach is the U.S. Department of Energy (DOE) study
referred to above (U.S. DOE, 1982b). Figure III-9 shows a
schematic representation of the model developed in the DOE study
to estimate RWC wood usage. It used existing census and other
information to estimate household heating requirements (in Btus),
and then how much firewood must be burned (in various RWC
appliances) to satisfy these requirements. This model involved
many steps and assumptions as it estimated internally such basic
parameters as: the number of woodstoves in operation;
distribution of woodstoves between primary and secondary use
categories; and, the average wood consumption per stove.
111-50
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Alternative approaches or models for estimating RWC wood usage can
be conceptualized to try to take advantage of the information base
provided by census and other data sources. However, all would
have to overcome key gaps in this information base with basic
assumptions which answer the following types of questions:
• How many operating wood stoves and fireplaces exist in the
study area?
• How many are actually used for primary heating, for secondary
heating, and for aesthetics only?
• What is the average wood consumption for each of the above use
categories and appliance types?
Estimating such basic parameters rather than directly measuring
them using survey methods runs the risk of introducing potentially
large uncertainties which can propagate throughout the analysis.
d. Comparison of RWC Wood Usage Estimation Approaches
The current state-of-the-art approach to estimating RWC wood usage
is to conduct a telephone survey of a random sample of all
households In the study area of interest. Surveys are the only
direct measure of total RWC wood usage, since wood supplier data
are likely to provide an incomplete picture. The major drawback
to surveys are their potential costs. These can be mitigated
somewhat through use of mailback questionnaires (instead of
telephoning), although the accuracy of results may suffer. Where
possible, readily available wood supplier data should also be
compiled, to check the reasonableness of survey results.
The use of census and similar information sources to estimate RWC
wood usage should be approached cautiously, unless or until some
of the fundamental gaps in this data base are addressed. For
example, census questions can be expanded to directly determine
wood usage by type of wood burning device.
111-52
-------
The uncertainties inherent in estimating RWC wood usage using
census and other data bases may be less troublesome for larger
(e.g., national or regional) study areas—e.g., if overestimates
and underestimates for various sub areas compensate each other.
Table III-10 compares two leading examples of national studies
which estimated RWC wood usage at the state level. The study by
the USDA Forest Service used telphone surveys (Skog and Watterson,
1983). The other study is the 1982 U.S. DOE Study referred to
above, which used a model (Figure III-9) based on census and other
data.
The latter study estimated RWC wood usage in dry tons. These are
shown in the table and converted to cords of seasoned wood, by
assuming 15% average moisture content and a cord weight of 2850
Ibs. In both studies, statewide wood use estimates are divided by
state total households (wood burning and non-woodbuming
households), to afford a RWC wood usage per "average" household
(HH), in cords per HH. Both studies refer to 1980-81 RWC wood
usage.
Among the more pertinent observations from Table 111-10 are the
following:
• After correction for moisture content, the national total RWC
wood use estimates by U.S. DOE, and by the Forest Service are
almost identical: 36.1 million and 36.3 million cords per
year, respectively, for the 37 states for which both studies
made estimates.
• Total estimated RWC wood usage, averaged over all households
in the nation, is about one-half cord per year from both the
U.S. DOE and Forest Service estimates.
111-53
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TABLE 111-10. Statewide RWC Wood Use Estimates from U.S. DOE
and the USDA Forest Service (cords/year; 1980-81)
State
1. Alabama
2. Alaska
3 . Arizona
4. Arkansas
5. California
6 . Colorado
7. Connecticut t
8. Delaware
9. Washington, D.C.
10. Florida
11. Georgia
12. Idaho
13. Illinois
14. Indiana
15. Iowa
16. Kansas
17. Kentucky
18. Louisiana
19. Maine
20. Maryland
21. Massachusetts
22. Michigan
23. Minnesota
24. Mississippi
25. Missouri
26. Montana
27. Nebraska
28. Nevada
29. New Hampshire
30. New Jersey
31. New Mexico
32. New York
33. North Carolina
34. North Dakota
35. Ohio
36. Oklahoma
37. Oregon
38. Pennsylvania
39. Rhode Island
40. South Carolina
41. South Dakota
42. Tennessee
43. Texas
44. Utah
45. Vermont
46. Virginia
47. Washington
48. West Virginia
49. Wisconsin
50. Wyoming
TOTALS
U.S. Department of Energy8
Dry
Tons
0.712
0.189
0.272
0.566
2.473
0.569
0.792
0.168
0.015
0.795
0.991
0.399
1.830
1.615
0.171
0.154
1.473
0.382
0.752
1.090
1.085
2.191
1.447
0.625
1.777
0.401
0.091
0.125
0.430
1.112
0.473
2.693
2.819
0.034
2.536
0.874
0.947
3.054
0.141
0.626
0.059
2.089
0.582
0.237
0.347
2.298
1.088
0.958
1.509
0.149
Million
Cordsc
0.59
0.156
0.225
0.47
2.04
0.47
0.65
0.139
0.012
0.66
0.82
0.33
1.51
1.33
0.141
0.127
1.216
0.315
0.63
0.90
0.90
1.81
1.19
0.516
1.47
0.33
0.075
0.103
0.36
0.92
0.39
2.22
2.33
0.03
2.09
0.72
0.78
2.52
0.116
0.52
0.05
1.72
0.48
0.196
0.29
1.90
0.90
0.79
1.25
0.12
39.818
Cords Per
HH4
0.45
1.19
0.23
0.57
0.24
0.44
0.59
0.67
0.05
0.18
0.44
1.02
0.37
0.69
0.13
0.15
0.96
0.22
1.59
0.61
0.44
0.57
0.83
0.62
0.82
1.15
0.13
0.34
1.11
0.36
0.88
0.35
1.14
0.13
0.54
0.65
0.79
0.60
0.34
0.50
0.20
1.065
0.097
0.44
1.63
1.02
0.58
1.15
0.76
0.72
STSOd
USDA Forest
Million
Cords
0.76
—
—
0.85
1.84
0.39
0.44
—
—
0.62
0.73
0.39
1.58
0.86
—
— .
—
—
0.84
0.49
1.07
1.79
0.96
—
1.23
0.26
—
—
0.46
0.41
0.23
2.12
1.92
0.14
2.09
0.57
1.55
2.20
—
0.61
0.22
1.47
1.32
—
0.41
1.76
1.67
0.64
1.28
0.14
36.3T"
Service
Cords Per
HHd
0.56
—
—
1.03
0.21
0.37
0.40
—
—
0.17
0.39
1.21
0.39
0.44
—
—
—
—
2.13
0.33
0.52
0.56
0.67
—
0.69
0.91
—
—
1.42
0.16
0.51
0.33
0.94
0.61
0.54
0.51
1.56
0.52
—
0.59
0.90
0.91
0.27
—
2.28
0.94
1.09
0.94
0.77
0.87
075ld
Source: Nero and Associates, Inc. (1974)
a. From U.S. DOE 1982b
b. Prom Skog and Waterson, (1983)
c. From dry tons, assuming 15% moisture content, and 2,850 Ibs. per cord
d. Total cords, divided by state total households
III-5A
-------
• However, for individual states, U.S. DOE estimates of total
cords range from up to a factor of two or more higher than
Forest Service estimates (New Jersey, Maryland, New Mexico),
to a factor of three or more lower than Forest Service
estimates (Oregon, Texas, Washington, and North and South
Dakota).
• The magnitude and distribution of RWC wood use estimates is
noticeably different between the U.S. DOE and the Forest
Service surveys; for example:
- In the higher usage states - e.g., in northernmost New
England and Pacific Northwest - U.S. DOE estimates are
consistently lower than those of the Forest Service.
- However, in most of the Appalachian and Southeastern states
which have relatively high usage - e.g., West Virginia,
Virginia, North Carolina and Tennessee - U.S. DOE estimates
are higher than those by the Forest Service.
- Overall, U.S. DOE estimates, corrected for moisture
content, in Table 111-10 are generally "flatter" than those
of the Forest Service - i.e., U.S. DOE estimates are lower
for states where the Forest Service estimates were high and
vice versa.
The Forest Service estimates are probably better, because they are
direct estimates, based on a careful random sample telephone
survey of actual wood usage by households. The U.S. DOE wood use
estimates are derived indirectly from a variety of data and
assumptions about how household heating requirements may be met
with wood fuel. Assuming the survey results are more accurate,
Table 111-10 illustrates how indirect methods based on census and
other data can produce estimates which are both significantly
higher and/or lower than survey results, due to unintended bias or
errors in the use of such indirect data bases.
111-55
-------
localities which cannot afford the cost of doing household surveys
may have to use indirect information sources to estimate RWC wood
usage. If so, every effort should be made to check resulting
estimates against other pertinent information, including household
survey results from other similar localities. A recent national
study of RWC wood usage, emissions and ambient impacts
investigated the extent of RWC information in all 50 states and
profiled 20 localities in more depth (Nero and Associates, Inc.,
1984). Table III-11 summarizes wood usage estimates from these
twenty localities.
As explained in that report, RWC wood usage estimates, for some of
these twenty localities, were considerably more uncertain than for
others. Among the twelve best estimates, RWC wood usage ranged
from 0.37 to 1.9 cords per "average" household. However, these
per household wood usage estimates appear to be rather sensitive
to the total number of households in the study areas, which ranged
from small mountain communities to large cities, as well as to
geographic and/ or climatological factors. Thus, assuming that
site-specific estimates could be representative of other
localities should be done with great caution.
Accordingly, there is no substitute for local household
(preferably telephone) surveys to determine actual local wood use,
mix and distribution of wood burning devices, burning practices,
and local trends. Such information is the best basis for
developing reliable local RWC emission inventories, as discussed
in the next section. These In turn are prerequisites for
assessing RWC ambient Impacts through receptor or dispersion
modeling as discussed in Section IV of this document.
2. Translating Wood Usage Estimates into RWC Emissions Estimates
Translation of RWC wood usage estimates into corresponding estimates
of air pollutant emissions is most commonly done as illustrated in the
following equation.
111-56
-------
TABLE 111-11, RWC Wood Usage Estimates for Twenty Localities
Locality, State
1. Waterbury, VT4
2. Western, MA
3. Nashville, TN4
4. Petersville, AL
5. Minneapolis, MN*1
6. Albuquerque, NM
7. Missoula, MT*
8. Denver, CO4
9. Tellurlde, CO*
10. Reno, NY4
11. Las Vegas, NV
12. Fresno, CAd
13. Boise, ID
14. Portland, ORd
15. Medford, ORd
16. Eugene, ORd
17. Yakima, WN
18. Spokane, WN
19. Anchorage, AK
20. Juneau, AK^
Year or
Heating
Season
80/81
78/79d
83/84
81/82
80/81
79/80
1980
76/77
79/80
82/83
83/84
83/84
83/84
83/84
81/82
83/84
78/79
1980
1981
1982
1983
78/79
1981
1982
1983
78/79
81/82
82/83
80/81
82/83
83/84
Total
HHs
1000s
' 0.647
283
281
178
1.2
721
151
21.3
22
23
567
0.671
67.5
103
96
60
_
383
387
390
386
42.7
42.1
42.1
42
66.4
70
21.4
70.9
55.2
2.93
Annual
Total
Cords
1000s
0.929
164.4
60
73.6
1.45
265
104.3
15
32
16-33
347.5
.96
38.6
5.8
42.5
N/A
198.6
262.1
272.7
307
280.2
42.7
62.7
59.6
54.8
56.5
77.1
21.4
1.5
12.1
5.57
RWC Wood Usage
Cords Per
"Average"
HHa
1.44
.58
.21
.41
1.21
.37
.69
.70
1.45
.71-1.43
.61
1.43
.57
.06
.44
N/A
.46
.68
.72
.79
.73
1.0
1.49
1.42
1.31
.85
1.10
1.0
1.58
.22
1.9
Stove
Usageb
(Z)
90(est)
65-70Z
N/A
71%
N/A
76Z
59t
N/A
60Z
83Z
30Z
94Z
49Z
few
2Z
N/A
N/A
40Z
62Z
63Z
63Z
N/A
71Z
78Z
78Z
20Z
68Z
N/A
23Z
N/A
63Z
Comments
door-to-door HHSs
Forest Service HHS
State Agency Estimate
Davidson County HHS
Visual and aerial surveys
From statewide HHS
Questionable survey
Phone and in-person HHS
Phone and in-person HHS
Telephone HHS
Mallback HHS
100Z HHS
Careful HHS
Visual survey; assumptions
Surveyed only SFDs
Still reviewing HHS data
Careful Phone HHS
Mailback HHS
RFP extrapolation
RFP extrapolation
RFP extrapolation
Careful phone HHS
Mailback HHS; RFP
RFP extrapolation
Mailback HHS; RFP
Careful phone HHS
Mailback HHS
Questionable HHS
1 mi.2 area HHS
Limited HHS (60 HHs)
Mendenhall Valley HHS
Source: Nero and Associates, Inc., 1984
a. Total cords divided by total households.
b. Percentage of total wood use in stoves, furnaces and inserts
c. Abbreviations: HHS = household survey by phone unless other stated
SFD = single family dwelling
RFP = reasonable further progress analysis
N/A = not available
d. Considered to be among the more reliable of the household surveys due to
sample size, randomness or coverage of a high percentage of all households,
etc.
111-57
-------
RWC Wood x Baisslon x Conversion • RWC Emissions
Usage Factor Factor
(kg/yr) (g/kg) (Tons/g) (Tbns/Yr)
Wood usage estimates are typically obtained in cords per year, or per
heating season. This estimate of the volume of firewood used is
converted to weight units (e.g., kg/yr) by multiplying by an assumed
cord weight. Cord weights are discussed below. Selection and use of
emission factors, usually expressed as grams of pollutant emitted per
kilogram of wood burned (g/kg) is also discussed below.
a. Cord Weight
3
A cord of wood measures A ft. X 4 ft. X 8 ft. « 128 ft. in
volume. The weight of a cord of wood primarily depends upon its
species (density), seasoning (weight of moisture and other
volatiles), and the fraction of cord volume assumed to be air space
vs wood. Table 111-12 shows how wood density can vary with species.
A recent study (Nero and Associates, Inc., 1984) of twenty selected
localities throughout the nation which had estimated RWC wood usage
and emissions, found that their assumed cord weights ranged from 955
to 1,815 kg/cord (Table 111-13). One of these local studies (for
Reno; Fitter et al, 1984) based its relatively low cord weight
assumption (1,011 kg/cord) on Its conclusion that 45% of local cord
stack volume was air space.
Selection of an appropriate areawide average cord weight assumption
for a given locality can be made by considering the following
factors:
• Areawide average mix of predominant firewood species used locally;
• Density of this mix (kg/ft ), using data such as in Table
111-12).
111-58
-------
TABLE 111-12. Wood Density and Heating Values for Selected Species
Species
Douglas-fir
Western hemlock
True firs
Western red cedar
Ponderosa pine
Lodge pole pine
Western larch
Spruces
Red alder
Bigleaf maple
Black cottonwood
Oregon white oak
Density
(dry weight)
(Pounds per
cubic foot)
28
26
23
19
24
24
30
22
23
27
19
37
Higher heating
values
(dry weight)
(Btu per pound)
9,050
8,260
9,700
9,100
8,730
8,000
8,000
8,510
8,170
Source: (Howard, 1981)
111-59
-------
TABLE 111-13. Cord Weights Used In RWC Studies In Various Localities
Locality/Region Cord Weight Assumed
. (kg/cord)
1. Waterbury, VT. • 1497
2. Western Massachusetts 955
3. Nashville, TN 1438
4. Petersville, AL 1438
5. Minneapolis, MN 1815
6. Albuquerque, NM 1100
7. Mlssoula, Ml 1489
8. Denver, CO 1100
9. Tellurlde, CO 1100
10. Reno, NV 1011
11. Las Vegas, NV 1100
12. Fresno, CA 1815
13. Boise, ID
14. Portland, OR 1588
15. Medford, OR 1588
16. Eugene, OR 1800
17. Yaklma, WA
18. Spokane, WA 1588
19. Anchorage, AK 1444
20. Juneau, AK 1466
Source: Nero and Associates, Inc., 1984
111-60
-------
• Volume of wood In a typical local cord (ft of wood per cord).
Alternatively, cord weights used by another similar locality can be
assumed to be applicable.
b. Selection and Use of RWC Mission Factors
Measurement and interpretation of emission factors for woodstoves
and fireplaces is undergoing development and change. Reasons for
this include: a) the relatively recent (last 5-10 years)
recognition of RWC as a potentially significant pollution source In
many localities (Nero and Associates, Inc., 1984); and, b)
subsequent efforts to develop new technology intended to reduce
emissions from RWC appliances - e.g., catalytic combustors, and
various advanced design woodstoves.
Table III-5 summarized woodstove and fireplace emission factors for
sir criteria pollutants, from EPA's Compilation of Air Pollutant
Bnlasion Factors (AP-42; U.S. EPA, 1983b). These were EPA's best
estimates, based on test results available several yeaxs ago. EPA
assigned these an emission factor rating of "C", Indicating that the
testing data base available was "average" at best, due to the
limited number of tests and source types tested. The woodstove
emission factors were father qualified in AP-42 as being based on
burn rates of 3 kg/hr or less. EPA noted that decreased emissions
could occur at higher burn rates. EPA also noted that the available
data referred to tests using primarily oak, fir and pine woods, with
moisture contents ranging from 151-35%.
The variety of conditions and emissions test procedures used in
studies to date has been a major factor contributing to the wide
range of woodstove and fireplace emission factors In the current
literature. For example, Table 111-14 compares current EPA
woodstove and fireplace emission factors for two pollutants -
particulates and carbon monoxide-wlth the range of comparable RWC
emission factors used or cited in recent RWC studies conducted by
twenty localities around the nation (Gay et al, 1985).
111-61
-------
TABLE II1-14. Comparison of EPA BalsaIon Factors
RWC Appliance,
Pollutant
Woods tove, TSP
Fireplace, TSP
Woods tove, CO
Fireplace, 00
With Range of
EPA
Emission
Factor*
(g/kg)
21
14
130
85
Literature Values
Range of
State/Local
Emission Factors
(g/kg)
5-62.5
2-25
50-180
9-150
i
a. AP-42 (U.S. EPA, 1983b)
Source: Gay et al, (1985)
111-62
-------
For the most part, the range of emissions factors shown reflect
substantial variation in published test results. This in turn
reflects the lack of standardization of RWC emissions testing
procedures. However, underlying uncertainty about "typical"
household wood usage and burning practices hinders design of RWC
emissions testing procedures which are representative of actual
household practices.
Conversely, the emissions testing conditions employed in laboratory
studies may or may not seem representative of actual household
practices to agencies who need to select RWC emission factors
appropriate for their locality. For example, in a study several
years ago, Montana scientific and regulatory personnel reviewed the
literature and selected TSP and CO emission factors for fireplaces,
woodstoves and residential furnaces which they believed were "more
generally representative of common burning practices in Missoula,
Montana" (Steffel, 1983). These were slightly to substantially
higher than the EPA emission factors in Table 111-14, including a
TSP emission factor of 62.5 g/kg for woodstoves operated in an
"airtight" mode.
Development of RWC emissions inventories using the general equation
above will become more complex, as the variety of RWC appliances in
use increases. The ongoing development and sales of advanced design
appliances should increase the difference in average emissions
performance between newer and older appliances. Accordingly, wood
usage estimates should be broken down by category of burning device,
In order to select appropriate emission factors for each category.
At a minimum, wood usage should be estimated separately for
fireplace and woodstove categories. These could then be multiplied
by EPA's fireplace and woodstove emission factors (Table III-5) to
afford a basic RWC emissions inventory. Fireplace inserts would
generally be Included in the woodstove category.
111-63
-------
As use of catalytic and advanced design non-catalytic RWC appliances
becomes significant, their wood usage and emissions should be
estimated separately, because their emissions factors will be
substantially lower than the current EPA factors in Table III-5.
Similarly, if stove wood usage in an "airtight" mode can be
separately quantified, higher emissions factors may be appropriate
for this category.
As indicated in the previous section, reliable estimation of local
RWC wood usage by type of burning device, generally calls for
household surveys in the community of interest. Today, such surveys
should include questions to determine both the present and possible
future mix of RWC appliances. This would help to determine the
number and type of wood usage categories for which separate RWC
emission factors are needed.
More test data and better RWC emissions factors should be available
in the near future, as EPA develops a New Source Performance
Standard (NSP3) for woodstoves, and updates its AP-42 RWC emission
factors, and states or localities Implement testing/certification
programs for RWC and applicances. Meanwhile, state or local
agencies may wish to better account for their changing RWC appliance
mix in estimating both present and future RWC emissions. They, may
be able to utilize the growing body of results from woods tove
testing and certification programs operated in such states as Oregon
or Colorado.
For example, Appendix B, Section Ib contains a summary sheet
describing the first nine woodstoves certified under Oregon's
program. However, Oregon's emissions testing results are expressed
in grams/hour, and are weighted averages of several tests conducted
over the full heat output range of each appliance, using Douglas Fir
as fuel. Other localities which use similar wood fuels may be able
to utilize some of the individual test results e.g., at heat outputs
111-64
-------
consistent with their climate and space heating demands. From these
results they could estimate RWC emission factors in grams/kilogram
of wood burned, for appliances of special interest in their areas.
This level of effort in estimating RWC emission factors for
different types of RWC devices is not warranted to obtain a first
approximation of RWC emissions. However, it may be useful in
projecting future RWC emissions levels, for areas in which a
significant transition to much cleaner burning appliances is
anticipated over time. Under such assumptions, AP-42 RWC emission
factors could substantially overpredict future RWC emissions. The
following section discusses projection of future RWC emissions in
more detail.
Another factor that may have to be considered In selecting
appropriate local RWC emission factors la altitude (elevation above
sea level). Recent preliminary findings (Shelton, 1985) have been
interpreted by others (Oregon DEQ, 1985) as indicating that
particulate and carbon monoxide emissions from both catalytic and
non-catalytic woodstoves tested in Sante Fe, New Mexico (elevation:
7,300 feet above sea level) average about twice
as high as emissions compared to the same wood stoves tested in
Portland, Oregon (elevation: 75-100 feet above sea level). If these
results are confirmed by more testing, they will represent a
significant consideration for higher altitude communities In
selecting appropriate RWC emission factors, as well as for EPA in
revising AP-42. This development is consistent with EPA's
development of different vehicle exhaust emission factors for use
in higher altitude states, principally in the Rocky Mountains.
3. Projecting Future RWC Emissions
Projecting future RWC emissions levels typically begins by
estimating RWC wood usage and corresponding emissions for some
appropriate baseline year, using approaches such as those described
in the previous two sections. Baseline emissions can now be
extrapolated Into the future using various trend factors - e.g.,
111-65
-------
anticipated growth (or decline) in the population or the number of
households in the area of interest. Alternatively, baseline RWC
wood usage can be extrapolated to future years and converted into
corresponding RWC emissions. Subsection (d) below describes a model
used for this purpose.
A common approach is to first estimate areawide total RWC emissions
in a baseline year, using the total number of occupied households
multiplied by the average RWC emissions per household. Then, local
planning agency projections of future changes in the number of
areawide households can be used as a trend factor to extrapolate
estimates of future RWC emissions, assuming that emissions per
average household will remain constant. Important factors to
consider in this basic approach include the following:
• If possible, the baseline year should be one for which RWC
emissions are measured directly using a household survey.
• Emissions estimates for all years should be normalized to account
for year-to-year changes in the severity of winter weather, using
local heating degree day data. Future projections should assume
a long term average weather severity, or heating demand.
Significant changes in household weatherization levels overtime
could also affect heating demand.
• Projected changes in the number of households should consider any
local trends in average household size (persons per household).
A decreasing trend in the number of persons per average household
will mean the total number of households will increase somewhat
faster than projected general population Increases.
• RWC emissions per average household will tend to decrease, due to
improvements in woodstove technology.
• RWC emissions per average household will increase if households
In an area shift from fireplace to woodstove usage for home
heating-e.g., through conversion of fireplaces with inserts.
111-66
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• Increases in RWC activity in a community will tend to level off as
the number of households willing to incur the inconvenience of
heating with wood is approached.
• Future changes in the relative prices of wood versus alternative
heating fuels (gas, oil, and electricity) should affect RWC wood
usage trends.
a. Normalization Based on Heating Demand
A reasonable assumption Is that the amount of wood burned for
household heating in an area will vary from year to year with how
cold the weather is, other tilings being equal. Seasonal total
heating degree days (HDDs) are a common measure of the relative
coldness of a heating season. HDDs are based on an assumption
that household heating demand beings when the mean daily outdoor
temperature drops below 65 degrees Fahrenheit. Thus, a day on
which the mean temperature was 50 degrees Fahrenheit would
contribute 15 degree days to the seasonal total.
The National Weather Service publishes Local Climatological Data
Summaries for many localities, which include heating degree days.
A long term (30-40 year) average of total annual heating degree
days should be used to represent an average or "normal" heating
season. RWC emissions estimates for the baseline year should be
normalized prior to extrapolation to future years. For example,
if the baseline year had 10% more heating degree days than the
long term annual average, its RWC emissions estimate would be
normalized by Increasing it by 10%.
b. Factors Affecting Average Wood Usage And Emissions Per Household
Table III-ll in Section D.l.d above summarized estimates of RWC
wood usage for twenty localities around the nation. Three of
these localities had conducted several household surveys over a.
period of years. These all indicated a shift from fireplace to
woodstove usage, with woodstoves eventually accounting for a large
majority of total areawide wood usage. This Is understandable,
since stoves are generally more effective than fireplaces for
111-67
-------
space heating. However, since wood stoves emit on average about
50% more particulates and carbon monoxide than fireplaces (per
unit of wood burned; Table 111-14), a shift from fireplace to
stove usage Increases total RWC emissions in an area, other
factors remaining constant. This also illustrates why RWC wood
usage and emissions should be estimated separately for woodstoves
and fireplaces first and then combined to estimate total RWC
emissions.
One factor that is changing, and which should decrease average RWC
wood usage and emissions per household, is Improvement in wood
burning appliance technology. Cleaner burning woodstoves or
fireplaces, which emit less pollutants per unit of wood burned,
generally also consume less fuel (i.e., are more fuel efficient
per unit of heat delivered. As discussed in Section III.B above,
emissions testing has demonstrated that most catalyst equipped
woodstoves, and some advanced design non-catalytic stoves, are
capable of emissions rates anywhere from two to ten times lower
than the average of stoves currently in use.
If and when the use of such cleaner burning RWC appliances becomes
more commonplace, the effects on areawide RWC emissions can be
estimated in several ways. If the changes over time in the
fraction of total wood usage in such advanced design appliances
can be estimated (e.g., based on household surveys, or
installation permit trends), their future emissions can be
separately projected, using appropriately lower emissions
factors. A cruder approach would be to simply reduce estimated
RWC emissions per household for future years, to represent
increasing usage of cleaner burning appliances.
c. RWC Trend Factors - Short Term
As Indicated in Section III. C, RWC wood usage on a national basis
decreased substantially between 1940 and the early 1970's, then
sharply increased as the oil prices escalated. It may be
gradually plateaulng in the 1980's as a national phenomenon,
although for particular communities, the trend may be different.
111-68
-------
Projecting future RWC emissions in view of changing RWC trends can
be difficult, and large errors can be costly - e.g., in terms of
inappropriately targeted emission control strategies. For
example, Figure 111-10 illustrates why RWC particulate emissions
projections helped change the particulate control strategy for
Portland, Oregon from primary emphasis on industrial sources to
increased emphasis on residential woodstoves. Further industrial
particulate controls were estimated to cost $10,000 per year per
ton, by the State of Oregon. This was determined to be a much
more costly and less effective means of attaining particulate
standards in Portland (Seton, Johnson and Odell, 1980).
The basic approach described at the beginning of this section
could utilize projected household or population growth as a trend
factor to estimate future RWC emissions. However, RWC trends may
not parallel population or household trends - especially if the
community anticipates expanding RWC activity due to other factors,
such as rising costs of competitive heating fuels. This calls for
other (than population based) trend factors capable of
representing whether the community is likely to experience
increasing, level or declining RWC wood usage in the future, or
possibly a combination of these phenomena.
A study conducted in 1981-82 for U.S. EPA, Region X, examined
various trend factors for projecting wood fuel use for three
cities in the Pacific Northwest - Portland, Oregon; Seattle and
Spokane, Washington (U.S. EPA, I984b, Task 3). Short-term
(through 1985) and long-term (through 2000) treads in RWC wood
usage were considered. Long-term trends were estimated using an
economic model discussed at the end of this section. Short-term
trend factors considered Included the following:
• Direct data on firewood use, including:
- Volumes of firewood removed from public and privatelands
under firewood cutting permits
- Household survey findings
111-69
-------
12 -I
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e
Ul
-------
• Indirect data on firewood use, including:
- Sales of wood burning appliances
Census data
• Direct measures of RWC ambient impacts, based on chemical
tracers for RWC contributions to particulate levels
• Indirect measures of RWC ambient impacts, based on other air
quality measurements including: nephelometer light scattering
coefficient (b ); coefficient of haze; soiling index;
SCclt
benzene soluble particulate extractions; organic and total
carbon measurements on particulate (HL-vol) samples.
Most of these factors were not used due to an inadequate database
- e.g., too few years of data for trend analysis, or data gaps-or
too indirect a linkage to RWC wood usage. The following two
short-term trend factors were used, primarily because there was
more data available on them.
• Volumes of firewood (cords/year) removed from the nearest
national forest(s); and
Average heating season nephelometer light scattering
coefficient (b ),
meteorological effects.
coefficient (b ), normalized for temperature and
Estimated volumes of firewood removed from the national forest(s)
nearest to each city were based on the number of firewood cutting
permits issued, and forest staff estimates of the average number
of cords of wood taken by each permittee. This represented only
an unknown fraction of the area's total RWC wood usage. However,
few databases suitable for trend analysis were available.
Accordingly, it was assumed that trends in this data would be
representative of areawide RWC wood usage trends.
Light scattering data were plentiful, but also had some drawbacks
as an RWC trend indicator. For example, while light scattering
111-71
-------
measurements are used In RWC analysis because they are sensitive
to fine particulate emissions, sources of fine particulate other
than RWC may often be present - e.g., other combustion sources
such as forest fires. To minimize such interference, only data
collected during the "heating season" (October-March) were used,
when RWC impacts would peak, and the influence of many potentially
interfering sources would be absent or minimal. Monthly average
b data were also normalized for year-to-year variations in
8 C£lt
temperature (using heating degree days) and wind speed, since
b levels can be influenced by such meteorological factors.
National Weather Service data were used to normalize b . data,
scat
as described previously.
Table 111-15 summarizes the short term trend estimates calculated
using the two trend factors. Overall, the recent annual average
rate of increase in both factors had been between 6% and 8%.
Accordingly, RWC wood usage was assumed to increase by 6-8% per
year, as a short term trend.
Neither of these trend factors was ideal for projecting RWC wood
usage. However, they illustrate how local data can be used to
help gauge short term RWC trends. The next section discusses
estimation of long term trends.
long Term RWC Trends
Long term trends analysis Is more uncertain than short-term
projections, because more unforeseen events can occur which
undermine key assumptions. For example, few could have predicted
the Arab Oil Embargo of 1973, which triggered rising energy prices
and associated increases in RWC wood use as an alternative means
of household heating.
The simplest approach to long-term projections is to use
anticipated population growth as the trend factor. This is not
necessarily the best trend factor for projecting RWC wood use or
emissions, as discussed above. However, it may be suitable for a
first approximation, and population growth forecasts are generally
more readily available than data for other RWC trend factors.
111-72
-------
TABLE 111-15. Summary of Short Term Trend Estimates
Short Term Heating Seasons
Trend Parameter; Trended Estimated Annual Aver.
City (No. of Seasons) Rate of Increase (%)
A. Firewood Volume Removed
from Nearest National
ForestCN.F.)
1. Seattle, Washington
Mt. Baker/Snoqualmle N.F.
1975-80 (5) 7.8-7.9
2. Portland, Oregon
Mt. Hood N.F. 1976-81 (6) 6.5
3. Spokane, Washington
Colvllle N.F. 1977-80 (4) 5.7
4. Spokane, Washington 1977-81 (5) 7.2-7.3
Idaho Panhandle N.F.
\
B. Heating Season Average
Light Scattering Coefficient
(Bscat)
1. Seattle, Washington 1978-81 (3) 7.9
2. Portland, Oregon
a. CAMS Site 1988-81 (3) 5.7
b. Cams Site 1978-81 (3) 5.6
Source: U.S. EPA (1984b; Task 3)
111-73
-------
Several published studies have projected long-term future RWC wood
use through the year 2000 or beyond (OTA, 1980; USFS, 1980; SERI,
1981; Booz, Alien and Hamilton, 1979; Bradburd et al, 1979;
Onisko, 1980; Marshall, 1981). Marshall's report includes a
review of the other studies listed here. Aaother report prepared
for the U.S. Department of Energy includes a literature review and
critique of a number of studies of historical RWC wood use (U.S.
DOE/ETA, 1982b). All of these studies estimated the amount of
fuelwood consumed as a product of a number of households burning
wood and the average fuelwood consumption per household.
A more sophisticated methodology is Marshall's development of a
systems dynamics model to forecast RWC wood usage (Marshall,
1981). This model projects wood usage based on estimated cost
differentials between heating with wood versus heating with
alternative fuels. Model input requirements include local price
forecasts for conventional fuels - usually from utilities
or regulatory bodies - and for wood. The latter were estimated by
extrapolating historical wood prices, in consultation with
knowledgeable wood suppliers.
Marshall's model also takes into account several important
factors, including: a) the effect of self-cut wood, and the
inconvenience of heating with wood, on peoples' perceptions of
their wood heating costs; b) the likelihood that, as market
penetration by wood for space heating increases, further market
penetration is more difficult, because the easiest wood
installations will occur first; and, c) the likelihood that wood
heating installation costs will increase, as the more convenient
installations are completed, or that air pollution from RWC will
result in new regulations which increase RWC costs. A shortcoming
of this model is that competing demands for firewood supplies are
not simulated - e.g., utilization of potential firewood supplies
in woodrfired power plants or co-generation facilities. This will
not be a problem unless firewood supplies are significantly
limited.
111-74
-------
Marshall's model was modified and used in the study referred to
above to forecast RWC wood usage in three Pacific Northwest cities
through the year 2000 (U.S. EPA, 1984b; Task 3). The model was
calibrated using available information about actual wood use from
household surveys, then used to predict future RWC wood usage at
(five) 5 year intervals. Table III-16 summarizes the resulting
wood usage estimates, and their conversion to corresponding
particulate emissions.
Increases in RWC wood usage were projected for all three cities.
Fireplace wood usage declined while stove wood usage essentially
doubled in all cases. Future wood usage in stoves substantially
exceeded fireplace usage in Portland, but fireplaces were
projected to use more wood than stoves in the other two cities.
However, this may have been due to the lack of areawide household
survey data on actual wood usage in the latter two cities. The
only survey in these cities at that time was of one residential
neighborhood area of one square mile.
As expected, estimates generated by this model were sensitive to
the changes in fuel price assumptions. The basic assumptions used
included an approximate doubling of the real cost of oil, gas and
electricity prices between 1980-2000. Based on utility forecasts,
about a 50% increase in real cost was predicted for wood fuel.
Changing the assumed wood price increase from 2% per year to 5%
per year resulted in a net decrease in projected RWC wood usage,
as expected.
Such a model was found to be the only tool currently available for
assessing the effects of future fuel price changes on RWC wood
usage and emissions. Calibrated models of this type could be used
to test some of the RWC control strategies discussed in section V
of this report; e.g., to estimate RWC wood use changes
attributable to weatherization of houses to lower their heating
requirements, or incentives for installing cleaner burning RWC
appliances which would lower RWC costs.
111-75
-------
TABLE 111-16. Best Estimate Projections of Residential Wood Fuel Use
(1Q3 cords/year) for Portland, Seattle and Spokane
(1980-2000) and Corresponding Particulate Emissions
(10-* tons TSP/yr)
Stove/Furnace Fireplace Total Total Particulate
Year Wood Usage Wood Usage Wood Usage Emissions
Portland Metropolitan Area
1980 150 190 340 9.3
1985 240 190 430 12.8
1990 240 170 410 12.5
1995 300 150 450 14.5
2000 340 140 480 15.9
City of Seattle
1930 45 110 155 3.7
1985 85 100 195 5.1
1990 85 100 195 5.1
1995 90 100 200 5.3
2000 85 100 195 5.1
Citv of Spokane
1980 28 93 121 2.7
1985 ' 42 84 126 3.1
1990 45 81 126 3.2
1995 51 78 129 3.4
2000 54 75 129 3.4
Source: U.S. EPA (1984b; Task 3)
111-76
-------
IV. CHARACTERIZING RWC AMBIENT IMPACTS
In this section, steps essential in characterizing Residential Wood Combustion
(RWC) ambient Impacts are described and discussed. The best available
quantitative estimates of fine particulate ( < 2.5 urn) matter ambient impacts
attributable to RWC for twenty locations around the nation, are summarized in
Section IV.A. The field monitoring considerations, necessary for evaluation
RWC ambient impacts, are discussed in Section IV.B. The two major approaches
to data interpretations, receptor modeling and dispersion modeling, are
discussed in Sections IV.C. and IV.D., respectively. Their theoretical basis
and example applications to RWC impact assessment are discussed briefly. For
further explanation of methodology and example applications, readers should
refer to references cited.
A. Summary of Ambient Impacts
1. Introduction
The use of wood for space heating has increased throughout the
nation. The corresponding ambient impact due to this increase in RWC
has been measured or estimated in a few metropolitan areas. This
section summarizes the available data on such RWC ambient impacts for
twenty localities.
Adverse air quality Impacts are one of the major deterrents to
expanding RWC as a biomass energy resource. RWC has been suspected of
contributing significantly to ambient levels of fine mass, Carbon
Monoxide (CO), and benzo(a)pyrene (B(a)P). Reasons for special
concern with RWC emissions are their: 1) location; 2) size of
particles being emitted; and, 3) chemical composition. Because RWC is
a localized area source, with a low plume rise, it exposes residential
populations to elevated concentrations of the above pollutants.
Because most of the RWC emissions are In the fine size fraction, RWC
also impairs visibility, is inhalable into the lungs (potentially
affecting health), and contributes to the proposed size specific
(PM.g) particulate standard (Federal Register, March 20, 1984). RWC
emissions are also rich in many gaseous and particulate organics, some
of which are known mutagens, carcinogens and irritants.
IV-1
-------
2. National Summary
Available information regarding RWC impact on air quality was gathered
from literature, researchers, and state, local and federal agency
personnel working in this field. The information was reviewed,
synthesized and tabulated for this document.
Localities included in this section were selected based on
availability of experimental quantitative ambient impact data.
Localities where RWC was suspected to have large ambient impact
without experimental data, are not included in this section. Table
IV-1 summarizes the RWC ambient impact on fine particulates
documentable for twenty localities. Tables IV-2 and IV-3 summarize
the carbon monoxide and benzo(a)pyrene levels measured during the
studies included in Table IV-1.
Detailed profiles of (17) of the localities included in Table IV-1,
are given in a report entitled "A National Assessment of Residential
Wood Combustion Air Quality Impacts", (Nero and Associates, Inc.,
1984), recently prepared for EPA's Office of Policy Analysis in
Washington, D.C. (EPA Contract No. 68-01-6543; Project Officer, Ms.
Sidney Worthington).
Headings in the summary Table IV-1 are self explanatory for the most
part. The second column lists the location of the air quality impact:
study while the third column includes both the number of field samples
and sampling period for the study. The sampling site, and the
surrounding land use classification are listed in column four. The
3
average RWC impact on fine mass in percent and ug/m is given in
columns 5 and 7, respectively. The average fine mass measured in
3
ug/m for the study period is given in column 6. The 24-hour
maximum RWC impact in ug/m is included in column 8. The
corresponding concentrations of particulates with 10 or 15 micron
diameter (PM,Q or PM,e), and total suspended particulates (TSP),
are given in columns 9 and 10, respectively. The references for the
study, from which the data were obtained are included in column 11.
IV-2
-------
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IV-7
-------
Critical comments regarding the data set referenced are included in
the last column. This column is especially important for
understanding the data limitations. Abbrevations and footnotes, also
essential in understanding values in the table, are given at the end
of the Table.
Based on the critical evaluation of available information, the best
available KWC ambient impact estimates on fine particulates and
corresponding measured benzo(a)pyrene (B(a)P) concentrations are
summarized in Table IV-4. This table shows a preliminary picture of
RWC impact for the various geographic locations studied. The RWC
impact on fine mass was calculated based on one of the many available
techniques discussed in Section IV.C. The measured B(a)P
concentration listed in Table IV-4 may not necessarily be from RWC
activities alone.
Unless otherwise noted, fine mass results refer to analysis of samples
of particulate smaller than 2.5 micro meters (urn) in diameter. Where
samples with other particle size ranges were analyzed (e.g., PMins
PM,e, or TSP), the mass fraction attributed to RWC was assumed to be
less than 2.5 urn in size. This assumption Is based on the Portland
Aerosol Characterization Study findings by Cooper and Watson (1979)
and similar findings from other studies (Muhlbaier, 1982; Rau and
Huntzicker 1985; and, Core et al, 1984) which indicate that most of
RWC emissions (over 801 to 90%) are less than 2.5 urn in size.
Benzo(a)pyrene (B(a)P) measurements were available for less than half
of the localities. No locality had collected carbon monoxide field
samples for direct analysis for RWC impact — e.g., using radiocarbon
measurements — although several were considering doing so. Several
localities had indirectly analyzed CO data for RWC impacts, as
discussed below.
IV-8
-------
TABLE IV-4.
of RWC Impact on Fine Mass and
Measured Benzo(a)pyrene Levels at
Selected Locations
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Location
Waterbury, VT
Western MA
Nashville, TN
Petersville, AL
Albuquerque, NM
Missoula, MT
Denver , CO
Telluride, CO
Reno, NV
Las Vegas, NV
Boise, ID
Portland, OR
Medford, OR
Yakima, WA
Spokane , WA
Seattle, WA
Tacoraa, WA
Longview, WA
Anchorage, AK
Juneau, AK
Study
Year
81-82
81-82
83
81
82-83
83
78
80
83-84
83
80-81
77-78
79-80
80-81
80-81
81
81
80-81
81-84
81-82
RWC Impact on
Fine Mass
ue An3
#0 . Of f
Sampl.es
33
13
24
8
56
12
16
13
8
4
9
32
40
4
15
9
4
4
8
11
Avg.
19
15
9-20
33
25
37
6-18
10-303
13a
—
85b
4-106
9-306
50
17-45
29
35
42
18a
48-93a
Max.
30
25
51
65
59
48
29
59a
23a
41
128b
50
126d
55
68
49
44
26
45a
234a
Measured
Benzo (a)pyrene
ng/m3
No. ot
Samples
16
—
21
4
—
—
—
13
—
—
2
3
2
—
3
3
—
—
—
1
Avg.
0.8a
—
2.3a
41°
—
—
—
7.4a
—
—
1.5
3.2
8.4
—
6.1
2.1
—
—
—
—
Max.
2.43
—
11. 4a
no. oc
—
—
—
14. 8S
—
—
2.3
5.4
8.5
—
11.0
4.2
—
—
—
11.0
ABBREVIATIONS :
RWC - Residential Wood Combustion
Fine Mass - <2.5ym unless otherwise specified
ug/m3 - microgram per cubic meter
ng/m3 - nanogram per cubic meter
Avg. - 24-hour average for the study period at one or more sites
Max. - 24-hour maximum for the study period
or PMi5 - Particulate matter <10 or <15 >m.
FOOTNOTES :
a - Analysis of TSP samples
b - Analysis of PM^g or PM^j samples
c - Gaseous and particulate benzo(a)pyrene - 4-hour sample
d - 8-hour or 12-hour maximum
e - Annual average
f - Samples were taken during heating season, unless indicated otherwise
IV-9
-------
Table IV-4 indicates the sampling year(s) for RWC impact estimates.
The number of samples analyzed (Column 4) and the resulting average
3
and maximum mass -values (ug/m ) shown la Columns 5 and 6, are for
24-hour averaging times unless otherwise indicated. The average
values shown represent averaging all of the field samples available
for a given site, during the study period. A range of average value
indicates sampling at more than one site. The measured 8(a)F
concentrations from all sources presented in Columns 7-9 were
developed in the same manner.
The seasonal or study period average RWC impact on fine particulate
3
matter was in the range of 6 to 93 ug/m . The 24-hour maximum RWC
3
impact varied from 24 to 234 ug/m . Not all the -values reported in
Tables IV-1 and IV-3 were measured on the fine mass fraction. However
since most of the RWC emissions is fine mass, the average and maximum
RWC in ug/m should remain relatively unchanged. The following
caveats are important for evaluating this national survey.
3. Caveats and Conclusions
The average RWC impact on fine partLculates are expressed as seasonal
or study period averages. In many cases the sampling is conducted on
adverse days or analysis is done on worst case days only. Thus the
average impact is biased high. The average values reported for
Portland and Medford in Tables IV-1 to IV-3, are the only stratified
annual averages reported. The extent of bias to the average RWC
impact cannot be determined, but the maximum and average RWC impacts
in the table can be concluded to be significant and demand further
investigation. This is partially expected because these studies were
carried out in areas where RWC was thought to contribute
significantly. Since most of the RWC impact is in the fine mass
fraction, RWC will contribute significantly (and in many cases be the
primary source of violations) to the proposed size specific
particulate standard. Limitations of the inventory presented here are
discussed below.
IV-10
-------
Many of the studies are seasonal and involve limited sampling over
short durations. Systematic long-term measurements are lacking in
general. Even though monitoring for particulate matter has been
carried out in most parts of the U.S., chemical analysis followed by
source apportionment has been done in a handful of locations only. In
many cases, RWC impact was projected by Nero and Associates, Inc.
based on limited data and involved many assumptions. The errors in
input data need to be propagated and evaluated to establish the upper
and lower limits to the RWC impacts. In some localities, the studies
were conducted many years ago and may no longer be applicable in view
of rapid changes observed in the RWC activities. Also some of the
studies were based on TSP samples. RWC impact measured on the TSF
samples should be viewed as upper limit.
The factors which would tend to make the RWC impacts reported in Table
IV-4 biased low are discussed below. In some cases, study results
date back five or more years, and cannot reflect the substantial
growth in RWC activity since then. Factors which may have resulted in
not measuring actual maximum impacts Include: limited sampling
especially in residential settings where maximum RWC impacts are not
likely; failure to sample under worst case meterological conditions,
and, "filter plugging" (causing loss) of some of the highest impact
samples. Agency staff from several localities thought the data in
Table IV-4 gave an unreal is tically low estimate of their average or
maximum RWC fine mass impact (e.g., Missoula; Portland) during the
heating season.
The B(a)P data base in Table T7-3 and IV-4 is very limited and subject
to the same caveats discussed above, plus others. The number of
samples analyzed for B(a)P is small in most cases. The three cases
with more than ten B(a)P estimates all involved TSP samples. B(a)P
may be contributed from a larger range of source. A final limitation
of the data is that many of the B(a)P measurements are based on B(a)P
extraction from particulate samples, whereas Imhoff (1982) has
reported significant B(a)P in the gaseous phase as well.
IV-11
-------
It is also important to note that the B(a)P ambient concentrations
shown in Table IV-3 and IV-4 cannot be directly attributed to RWC
emissions, in the same way that fine particulate contrations are
attributed to RWC in Tables IV-1 and IV-4. This is because the latter
are based on chemical tracers and mass balance analysis. However, RWC
has been shown in recent studies (Radian, 1984) to be the largest
national source of Polycyclic Organic Materials (POMs) such as B(a)P.
Thus, there is likely to be a strong association between the B(a)P
levels in Table IV-3 and IV-4 and RWC activities. B(a)P has commonly
been used as an indicator of POM levels. The fact that B(a)P was
found in significant ambient concentrations where RWC impacts were
also measured is consistent with previous studies which strongly link
RWC to POM emissions.
Preliminary indirect evidence shows that RWC contributes significantly
to carbon monoxide (CO) impacts, but no field monitoring study has
been completed to test the hypothesis. Several such studies are
14 12
planned, generally built around radiocarbon ( C/ C) analysis to
distinguish ambient CO from combustion of "contemporary" vs "fossil"
fuels. Preliminary evidence of RWC CO impacts include: (1) elevated
CO levels at residential monitoring sites which occur late at night on
cold winter evenings where RWC can be assumed to be the dominant CO
emissions source; and, (2) nephelotneter data from residential areas
which correlates better with ambient CO levels than it does with
traffic counts.
Concern about the RWC CO impacts has been slower to develop because
most CO monitoring is done at roadway oriented sites, where CO levels
are dominated by vehicle exhaust. Siting more CO and fine particulate
monitors in residential neighborhoods with RWC activity is needed to
help calculate RWC impacts not only for CO, but also for particulate
and B(a)P.
In Table IV-4 the highest RWC impacts measured are for localities
where meteorology and/or terrain features greatly restrict pollutant
dispersion, thereby encouraging higher ambient concentrations — e.g.s
IV-12
-------
Medford, Juneau (Mendenhall Valley), Tellurlde and Mlssoula. For
example, Table IV-4 indicates that Medford, Oregon had (annual)
average and maximum fine particulate impacts from RWC that were two or
three times higher than in Portland, Oregon — despite the fact that
total TSP emissions from RWC were four to five times higher in
Portland. This is attributable to Medford's valley location and
frequent inversions which trap pollutants. Medford's higher RWC TSP
emission per household (90 vs 47 Ib/HH/yr) may also indicate higher
RWC emission density than in Portland (Nero and Associates, Inc.,
1984).
Relatively high fine mass impacts are also noted in Table IV-4 for
localities where pollutant trapping by terrain and/or meteorology is
not a strong determinant of ambient concentrations — e.g.,
Albuquerque, Petersville, Spokane, Boise, Yakima, Nashville, and
Portland. The terrain and meteorological variables are significant in
any attempt to determine the extent to which the RWC impacts shown in
Table IV-4 may be representative of other localities throughout the
nation.
In at least one locality (Missoula) the average and maximum RWC
impacts were much lower than anticipated, based on its especially poor
dispersion characteristics (Holzworth, 1972), high per household wood
usage, and long standing concern about RWC impacts. Missoula agency
staff can qualitatively attribute TSP impacts to RWC that are much
higher than are shown in Table IV-4. On some worst case TSP days,
HiVol TSP sampling has measured concentrations in the hundreds of
3
ug/m , where RWC was thought to be the dominant source.
The main reason for this inability to document these higher levels is
that receptor modeling/source apportionment analysis for Missoula RWC
impacts is notably limited. The only completed study was conducted
during a limited period (February - March) when maximum RWC impacts
would not be likely (Cooper and DeCesar, 1983). Other Chemical Mass
Balance (CMB) analysis of Missoula fine particulate samples was "in
progress" and not available for inclusion in this report.
IV-13
-------
This is the most notable example of the following general conclusion.
Despite the fact that the data assembled on RWC ambient impacts in
this report addresses most of the major localities where RWC impacts
have been documented to date, it is notably limited in supporting
broad general conclusions about the national significance of RWC
ambient impacts. Nevertheless, the available data base has strong
features in terms of such a national assessment, which are:
• State-of-the-art (CMB) methods have documented significant RWC
fine particulate impacts in localities in many regions of the
country (albeit mostly in the western IB A).
• While the highest Impacts have predictably been found In
localities where meteorology and/or terrain features severely
restrict pollutant dispersion, other communities in which these
factors are not dominant also experience relatively high average
and maximum RWC impacts.
Limitations of the data base reported herein are:
• RWC impact data for localities are too limited in size and
consistency (of methods, sample years, etc.) to support broader or
more general conclusions about the geographic extent and severity
of RWC ambient impacts. The extent to which RWC impacts
documented to date, are or are not representative of RWC impacts
in other localities where RWC is a significant means of home
heating, is not clear.
• There is a lack of consistent methods of analysis in the present
data base — especially a lack of systematic application of CMB
receptor modeling methods, which have proven most specific and
defensible in quantifying RWC Impacts.
IV-14
-------
In summary, the present data base presents a preliminary picture of RWC
ambient impacts that suggests this source to be significant in localities
with high wood usage and restricted pollutant dispersion. At a minimum,
the data base also indicates that RWC impacts are potentially as
significant in any other locality with similar amounts of wood usage and
comparable meteorology and terrain features. Direct evidence of RWC
Impacts on fine particulate levels exists, from Chemical Mass Balance
(CMB) receptor modeling analysis of particulate samples. The evidence
linking RWC to carbon monoxide (CO) and benzo(a)pyrene (B(a)P) ambient
impacts is more indirect, albeit very suggestive.
The national assessment study (Nero & Associates, Inc., 1984) which
compiled the data discussed above also interviewed state and local air
pollution control agency staff in all fifty states. Their overall
perceptions of RWC impact in their jurisdictions, based on their
available RWC information base, their field observations, and their
best judgement were determined. Regarding the type, severity and
frequency of RWC impacts, a majority of all respondents indicated the
following:
• Severity! RWC impacts are definitely or potentially significant -
i.e., a high priority for investigation and/or control;
• Type; RWC contributes to visiblity impairment, and to increased
ambient concentrations of particulates or carbon monoxide. Thirty
percent (30%) believed RWC contributed to standard violations for
one or both of these pollutants; and,
• Frequency! RWC impacts occur on 4 to 25 days each heating season.
This study showed that most air pollution agencies do not have
adequate technical information on RWC impacts. Eighty percent of the
state agencies interviewed lacked quantitative estimates of wood
usage, emissions or ambient impacts specifically attributable to RWC.
Thirty eight percent had none of these.
IV-15
-------
There was a strong correlation between lack of such technical
information and respondent's who rated RWC impacts as "marginal" or
"insufficient" - including some states with relatively colder climates
and higher wood usage. Such areas may ha\e RWC impacts of greater
significance than they recognize.
B. Field Monitoring for RWC Impact Estimation
1. Introduction
This section discusses the measurement of Residential Wood Combustion
ambient air quality impacts through field measurements of particulate
concentrations. The monitoring methods, instrument siting
considerations and sample analysis techniques discussed in this
section are directed primarily toward the application of receptor
models as the principal tool in distinguishing RWC impacts from those
of other sources.
A receptor model is a mathematical method for identifying and
quantifying the sources of ambient air pollutants at a receptor,
primarily on the basis of the physical and chemical characteristics of
the aerosol. Because receptor model quantification of RWC impacts is
based on data sets developed through sophisticated chemical analysis
of ambient aerosols, it Is extremely important that the instrument
siting, monitoring methods and supporting measurements (i.e.,
meteorological, light scattering, gaseous pollutants, etc.) be
carefully coordinated. The overall design of the field study,
however, is largely dictated by the resources available and the level
of confidence that the analyst must have in the results. Receptor
modeling studies of particulate (Including RWC) impacts can be
designed and Implemented at various levels of effort, including
relatively simple and inexpensive studies (See section IV. E).
Receptor model estimation of RWC impacts has become the primary
technique used by regulatory agencies because of its unique ability to
quantify impacts during historical short-term periods (24 hour or
less) of adverse air quality. Although dispersion modeling and
emission inventory techniques have also been applied, receptor models
IV-16
-------
are unique in their ability to identify RWC impacts for any given
sampling period, independent of emission inventory and meteorological
assumptions. The complex terrain that typifies many of the airsheds
subject to woodanoka episodes further complicates dispersion modeling
studies. Given the extreme difficulty of recreating an emission
inventory that is representative of a specific day in history,
receptor models are the best available method for directly and
specifically measuring RWC ambient Impacts.
Receptor models are also subject to distinct limitations that must be
recognized and mitigated by the analyst during the experimental design
phase of the study. The principal limitation of receptor models is
the inability to identify specific sources of chemically and
physically similar aerosols. These methods are not able to quantify
impacts from specific sources within the same source group. This
includes emissions originating from wood stoves, fireplaces, open
burning of vegetative matter, smoke from prescribed burning of forest
residues, structural fires and land clearing open burning.
Fortunately, supplemental information on source emission activities
can often narrow the list of potential contributing sources.
Judicious placement of sampling sites with respect to the transport of
smoke from Interfering source locations can further minimize impacts
from other sources.
The second limitation of receptor models, as they are applied to RWC
impact assessment, centers on dependence of the method on a firm
knowledge of the chemical composition of woodanoke. Studies conducted
by Stiles (1983), DeCesar and Cooper (1981) and Dasch (1982) have
concluded that the composition of woodsnoke varies as a function of
wood species and combustion conditions, resulting in relative impact
estimates uncertainties that typically average + 30%. Tb minimize the
degree of uncertainty in the source assignments and maximize the
credibility of study conclusions, several independent forms of
receptor modeling are often applied. Since the greatest degree of
IV-17
-------
confidence in the program conclusions typically results from the
application of several complimentary methods, each RWC assessment
program should include two or more independent methods of impact
analysis.
2. Network Design Considerations
a. Monitor Siting
In designing a monitoring network to evaluate RWC Impacts, it is
important to first determine the objective of the study. For
purposes of this document, it will be assumed that the analyst is
interested in evaluating the maximum 24 hour, seasonal and annual
impact of RWC emissions within an airshed as well as the impact of
these emissions at a ISP nonattainment site. These objectives are
typical of most studies conducted within the past few years.
b. Sampling Locations and Periods
Most studies require at least three sampling sites - one site to
monitor "background" RWC emissions transported into the airshed,
one historical nonattainment site at which RWC impacts are of
interest, and a third maximum Impact (often residential) site.
All sites should conform to EPA siting criteria (40 CFR Part 58
Appendix E) to insure that the program results are representative
of the airshed. Neighborhood scale sites, representative of
conditions throughout a homogenous urban subregion of a few
kilometers in size, are usually selected for RWC monitoring. Such
sites provide data that are representative of similar
neighborhoods within the airshed and are suitable for determining
trends In RWC impacts, compliance with air quality standards and
population exposure.
Sampler inlet heights should vary from two meters above ground for
sites greater than 25 metera from major roadways (Average Daily
Traffic 3000) to 15 meters above ground for sites five meters from
the roadway. The site should not be unduly Impacted by any single
source and should be unobstructed by surrounding objects, i.e.,
two meters from the nearest wall and at least 20 meters from the
nearest tree. The distance between surrounding obstacles and the
IV-18
-------
sampler should be at least twice the height that the obstacle
protrudes above the sampler. The site should also have
unrestricted airflow in an arc of at least 270 degrees around the
sampler.
Maximum RWC impact sites are usually located in high density
residential areas that have been informally surveyed to Identify
the number of homes with winter wood supplies. local topography
that may restrict dispersion of emissions should be reviewed to
/
find high impact sites. In addition, dispersion modeling results
and winter wind direction frequency distributions (wind roses) for
the airshed should be reviewed as an aide in identifying potential
sampling locations.
Background sampling locations should be located in rural areas
upwind of the airshed during the winter heating season. Data from
such sites are Important in distinguishing "local" emission
impacts from those transported into the airshed. The impact of
these "local" emission forms the basis for developing RWC emission
control strategies for the airshed.
If the results of the program are to be used to evaluate the
performance of a dispersion model, sampling locations should be
selected based on a performance evaluation protocol designed in
accordance with EPA's Interim Procedures for Evaluating Air
Quality Models (Revised), (EPA-1984e). For example, at least one
site should be located in a residential area of average population
density and wood burning activity. A second site should be
located within an area of commercial or industrial land use.
Other choices include locations of modeled high concentrations.
The diverse locations of monitored and modeled RWC impacts
preclude setting a generalized minimum number of required samplers
that might be acceptable in a given model performance evaluation
study.
IV-19
-------
The ability of receptor models to isolate RWC impacts from other
airshed sources is dependent, in part, on the ability of the
analyst to minimize potential interfering sources within the same
source group (see abo-ve) while measuring representative RWC
emission impacts. Proper instrument siting, as mentioned above,
is means of accomplishing this objective.
A second approach is to insure that the ambient samples are taken
only during periods of maximum RWC emissions, i.e. during the
evening hours of the winter heating season. Three eight-hour
sampling periods (e.g. 6 pm to 2 am, 2 am to 10 am, and 10 am to 6
pm) can be used to isolate the peak emission period while
providing a means of estimating 24 hour maximum impacts. As a
less costly option, two 12 hour samples collected during the
daytime hours (6 am to 6 pm) and evenings (6 pm to 6 am) can be
taken. Under the latter option, however, care should be taken to
avoid splitting the periods of maximum emission strength (6 pm to
2 am and 6 am to 10 am) between the two sampling periods.
It is important to note that the plugging of filters during
periods of heavy RWC impacts is a common cause of sample loss.
Filter plugging, with resultant failure to maintain required
airflows, can thus void some of the most important ("worst case")
24-hour samples obtainable. This can generally be avoided by
dividing the 24-hour sampling into two or more shorter sampling
periods.
At a minimum, 24 hour samples should be taken each day. Daily,
consecutive samples should be included In the experimental design
to Insure that samples are taken during periods of adverse air
quality. Fine particle mass loading, the occurrence of cold
weather periods coupled with poor dispersion and/or high light
scattering can then be used as criteria for sample selection for
chemical analysis.
IV-20
-------
Estimates of RWC impacts during the space heating season are
usually obtained through receptor model analysis of samples
collected during periods of low, moderate and high fine particle
concentrations. An analysis of scattering coefficient
measurements (b ) obtained with an integrating nephelometer
scat
can be used to estimate fine particle mass concentrations. Space
heating degree day data can also be used as sample selection
criteria. Estimates of annual average impacts are best obtained,
resources permitting, through the analysis of samples taken
throughout the year. lower limit approximations, however, can be
obtained by assuming that RWC impacts are limited to the winter
months. Since the period of greatest concern relative to air
quality standard attainment is usually limited to short-term (24
hour) episodes, estimates of seasonal and annual impacts may not
be necessary.
c. Supportive Monitoring Data
In addition to fine particulate samples, several other supportive
measurements are useful in interpreting RWC impacts.
Meteorological measurements of wind speed, wind direction and
temperature are required to evaluate transport conditions, space
heating degree days, and dispersion characteristics of the
atmosphere. An integrating nephelometer measuring light
scattering in order to provide a continuous indication of fine
particle concentrations, can be extremely helpful in identifying
qualitative estimates of RWC impacts (see Section IV. C. 4.c).
Specialized sampling systems designed to measure woodsmoke organic
tracers such as methylchloride (Khalil et al, 1983) ha-ve also been
used as discussed below. Carbon monoxide (CO) measurements at
residential sites ha-ve also recently been used as another possible
indicator of woodsmoke concentrations within airsheds that have
traditionally experienced low CO concentrations outside of their
commercial/industrial landuse areas (Harris, 1982).
IV-21
-------
3. Mr Monitoring Instrumentation
Table IV-5 lists air quality measurements that are needed to determine
RWC impacts using receptor modeling methods. Two filter substrates
must be used to satisfy the trace element and carbon analysis
requirements. Two dichotomous (Olln, 1978) samplers or one fine
particle sequential sampler (Camp et al, 1978) is required to collect
concurrent samples on membrane and quartz filter substrates. The
sequential filter samplers commonly used have been designed to
simultaneously capture fine particle ( <2.5 urn) samples by using two
sampling ports within a sampling plenum. The ports are also
programmable to permit collection of 2,4,6,8 or 12 hour sample sets,
thereby minimizing servicing requirements. If manual dichotomous
samplers are used, one sampler is equipped with a membrane filter
substrate (typically Teflon) while quartz filters are used with the
second sampler. Data on mass concentrations, elemental and ionic
composition, and light absorption coefficient are obtained from the
membrane filters while organic and elemental carbon concentrtions are
obtained from the quartz filters.
High volume air samplers used to capture total suspended particulate,
and size selective inlet (SSI) samplers equipped with 10 or 15 urn
inlets and glass fiber filter, have been used in several studies where
fine particle samples have not been available. It is difficult to
obtain credible trace element concentration data from glass fiber
filters. It is also important to isolate the fine particle fraction as
the first level of RWC impact apportionment. Accordingly, results from
these programs have been considered preliminary pending completion of
studies using fine particulate samples designed as outlined above.
If agency resources clearly preclude fine particle sampling, or If
historical TSP or SSI samples must be used as a basis for RWC impact
assessment, semiquantitatlve Impact estimates can be obtained by using
atomic absorption measurements of a few key elements (Fe, Ca, K, Pb,
Ni, V, etc.). Carbon-14 and organic/elemental carbon measurements can
also be done, if the filter blank values are significantly lower than
measured values on the sample itself. Sample analysis methods are
discussed in Section IV. B.5.
IV-22
-------
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TWo additional instruments helpful In interpreting RWC impacts are
nephelometezs and GO monitors. Integrating nephelometers hare been
widely used to monitor hourly variations in light scattering, while
nondispersive infrared instruments are used to continuously monitor CO
concentrations.
4. Specialized Sampling Techniques
Recent research activities related to RWC impact assessment have
resulted in the development of several extremely useful techniques of
interest to regulatory agencies, since they provide additional
independent approaches to RWC apportionment. Khalil et al, (1983)
have recently described an RWC tracer method based on the measurement
of methylchloride (CHgCl), a low temperature pyrolysls product of
wood combustion. CH-C1 is typically not found in higher temperature
combustion processes - e.g., from wood-fired boilers and is thus a
potentially unique tracer for RWC. The method can measure short-term
variations in RWC concentrations based on the ratio of methylchloride
to fine particle mass emission rates. Uncertainties in determining
particulate mass concentrations by this method are largely due to the
variability of the natural background of methylchloride and the
emission zate ratio, limiting the accuracy of the method to about _+
30%. Sampling la conducted using evacuated cylinders into which air
samples can be drawn over time periods ranging from two to eight hours.
Currie (1982) and Klouda et al, (1982) have developed radiocarbon
analysis methods that can be used to distinguish fossil fuel carbon
from contemporary (e.g., wood) carbon by means of carbon-14
measurement. The method provides an estimate of the portion of
aerosol carbon associated with woodburning sources as distinguised
from oil, coal, dlesel and gasoline combustion. The method's ability
to distinguish RWC carbon from fossil carbon is based on the natural
decay rate of carbon-14 over time. If the ratio of carbon-14 ( C)
12
to carbon-12 ( C) is known for wood burned within the airshed, and
measurements of this ratio are made from fine particle aerosol
samples, the proportion of contemporary carbon can be determined.
Since the sample analysis method has commonly required at least 5 mg
IV-2 3
-------
of carbon, high volume particulate samplers equipped with multistage
cascade impactors have been used to insure that sufficient sample is
collected for analysis. More recent research indicates that
analytical sensitivity levels approaching 10 ug of carbon will soon be
possible, allowing the use of dichotomous fine particle filters and
radiocarbon analysis of smaller samples.
14
Both C and CH-C1 methods are being used by regulatory agencies
as independent methods to validate other receptor model estimates of
woodsmoke impacts. Section IV.C.A.a. further discusses the advantages
14
and limitations of C analyses, including its application to source
apportionment of ambient carbon monoxide levels.
5. Sample Analysis
The measurement of particulate mass and elemental concentrations
represents the minimum level of sample analysis required for receptor
modeling. Several additional measurements (see Table IV-5) should be
performed, especially organic and elemental carbon, since RWC
emissions are largely composed of these two components. While
scanning electron microscopy and X-ray diffraction analysis may be
helpful in identifying impacts from industrial sources and fugitive
dust, they are not useful in quantifying RWC impacts because of the
, carbonaceous nature of RWC particles. Optical microscopy can be used
effectively with TSP and SSI samples, however, to identify coarse
particles such as burned wood fibers that may indicate RWC impacts.
The final choice of analytical measurements should be based on the
resources available and, if historical TSP or SSI samples must be
used, on the nature of the samples available.
C. Receptor Modeling Assessment of RWC Impacts
1. Introduction
A discussion of field sampling and analytical methods that are used to
support receptor modeling of RWC impacts is presented in Section
IV.B. This section provides a brief review of the fundamentals of
IV-2 4
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IV-25
-------
receptor modeling and its application to RWC assessment. Receptor
model input requirements and sources of error are presented, as are
model validation methods. This section also discusses a number of
receptor model approaches that may be used by analysts.
2. Introduction to Receptor Modeling
Receptor models are mathematical and analytical techniques that
examine the ambient sample and conditions of its collection to infer
the types and relative mix of sources impacting a receptor. Receptor
models may be thought of as a set of mathematical equations which
relate one set of variables with unknown values to a set of variables
with known values. A set of known particle characteristics (elemental
composition, size, shape, crystalline pattern or isotope ratio)
measured in the source emissions is related to similar characteristics
measured for particulate samples collected at a receptor. The known
chemical composition of all major local emissions sources is referred
to as source chemical profiles, or as "finger prints" in vernacular
terms. The receptor model develops a "best fit" of source
contributions which best explains the chemical composition of
particulate samples collected at the receptor.
While dispersion models estimate source Impacts given known emission
rates and pollutant transport conditions, receptor models "decode" the
chemistry, variability and/or morphology of the particles to identify
their origins. Both types of models assume that the mass of particles
transported from the source are essentially unchanged, obeying the
following "Conservation of Mass" law that Is the foundation of both
dispersion and receptor models:
Conservation of Mass Equation
p
M - * Mj
IV-2 6
-------
Where:
3
M* Aerosol Mass (ug/m )
M.» Mass Impact of Source "j" (ug/m )
P* Number of Contributing Sources.
For example, if three sources contributed all of the mass measured at
the receptor (P*3), then the sum of the individual source impacts
(M.) would explain all of the measured mass. Receptor models expand
this concept to individual characteristics or features, of the aerosol:
- M C2)
Where:
3
Mj- Concentration of feature "i" at the receptor (ug/m )
P * Number of contributing sources
3
M.- Impact of feature "i" from source "j" emissions (ug/m )
In this example, M. could be the concentration of lead measured on
the filter. The concentration of lead at the receptor is then the sum
of lead from each of the individual contributing sources. This
relationship can be expressed in terms of the total source mass impact
by substituting the M. . term for the product of the source impact
(S.) and the fraction of feature "i" in the emissions from source
"j" (Fi-i)' If equation (2) is rewritten in this form, and the M£
and Mij terms are redefined as concentrations normalized to mass, we
obtain the receptor model equation commonly found in the literature:
Receptor Model Equation
IV-2 7
-------
Where:
C. • Concentration of feature "1" normalized to mass
P * Number of contributing sources
F." Fraction of feature "1" In source "j" emissions
S « Impact at the receptor of source "j" (ratio to mass)
A variety of receptor models have been applied to RWC Impact
assessment (Core et al, 1984; Watson et al, 1981; Gordon, 1980; Cooper
and Watson, 1980). EPA's technical series documents on receptor
models contain elaborate Information on various models. The most
useful of these methods are briefly described below.
a. Chemical Mass Balance (CMB)
This method compares the elemental composition of the particulate
matter collected by an ambient sampler with similar Information
collected from woodstove and fireplace emissions to estimate the
RWC contribution to the ambient partlculate mass. CMB attempts to
match the source "profile" or "fingerprint" to those measured at
the receptor. By superimposing the appropriate source profiles
one can generate a profile that resembles the ambient aerosol
fingerprint, identifying the relative mix of sources. The method
can be applied to a single sample collected over a 24 hour (or
less) time period thereby providing an excellent method of
assessing RWC impacts on actual worst case air pollution episodes.
b. MultIvarlate Techniques
These techniques Include factor analysis, regression methods,
cluster analysis and principal component analysis. The methods
are based on the common variability of chemical elements as
measured on a large number of ambient filters. The underlying
assumption Is that the temporal or spatial variability of the
chemical species at the receptor and attributable to specific
sources, will be similar. Source Identity Is determined by
comparing species of similar variability to the chemical emission
profile of the sources.
IV-2 8
-------
These methods can Include ambient measurements of parameters other
than elemental chemical composition in different size ranges.
Examples of other measurements that may be included in the
analysis include light scattering, carbon monoxide, and
meterological parameters. Additional parameters increase the
analyst's ability to resolve RWC impacts from other sources. At
least 30 and preferably 50-100 samples should be analyzed to
provide a sufficiently large database for multivariate analysis to
obtain statistically valid results. This is in contrast to CMS
analysis which achieves a separate, stand alone conclusion for
each filter or sample analyzed.
c. Birichment Factor Models
Earichment factor models can be used to calculate the impact of a
source based on the relati-ve enrichment of a tracer element in an
ambient sample. The method has been most widely used In RWC
studies assessment by assuming that fine particle potassium (K) is
solely associated with woodsmoke emissions. Iron (Fe) from soils
has been used to normalize the potassium (K) concentrations to a
crustal component. By examining the variations of the K/Fe ratio
during Impact peiods, a semi-quantitiati-ve estimate of RWC impact
can be made if the percent potassium (F..) in woodsmoke is
known. Organic carbon can be used in much the same manner.
d. Pattern Recognition
Integrating nephelometer measurements of light scattering
(b ) can also be used to obtain a qualitati-ve estimate of
SCo>t
woodsnoke Impacts. Because most of the wood an oka emissions are
less than 2.5 urn in size, they are effective light scattering
aerosols. By subtracting "background" scattering le-vels measured
during periods of minimal RWC emissions from those measured during
impact periods, an estimate of mass concentration impact (ug/m )
can be made given the knowledge of the b to fine particle
mass relationship.
IV-29
-------
3. Model Input Requirements
As noted above, many receptor models require a knowledge of the
chemical composition of both the source emissions and ambient aerosol,
and the number of sources impacting the receptor. Heally this calls
for chemical characterization of samples collected from source(s) as
well as similar characterization of ambient monitoring samples.
However, if source sampling and characterization cannot be done,
published data on source chemical profiles can be used to construct
the matrix of source composition information needed for CMB analysis,
as described in the next subsection below. In the case of the least
squares effective -variance Chemical Mass Balance Model, estimates of
the uncertainties associated with the source emission and ambient
aerosol components are also needed in order to estimate confidence
limits for resulting model estimates.
Although multi-variate methods do not require direct input of source
emission profile information, a knowledge of the likely emissions is
necessary to interpret and apply the model outputs and/or to select
the independent variables that are to be used as source tracers in the
regression analysis. Target transformation factor analysis (TTFA) may
be a potentially useful method of identifying the number and
approximate composition of source emissions likely to be impacting the
receptor (Hbpke et al, 1982). Where TTFA analysis is not available,
the number of sources impacting the sampler are commonly based on the
analyst's knowledge of the airshed.
Major Impacts from sources that may have been omitted from the
analysis are usually apparent by the inability of the CMB model to
account for all of the measured mass and aerosol components. For
example, failure to include an RWC source in the CMB analysis will
\
result in an inability to account for a major portion of the fine
particle potassium and organic carbon.
Table IV-7 lists the ambient and source measurements commonly required
for CMB and multi-variate model analysis of RWC Impacts.
IV-30
-------
TABLE IV-7. Receptor Model Input Requirements
Mass Cl Fe Pb
Na* K Ni S04
Mg* Ca Cu* N03
Al V Se* Organic Carbon
Si Cr* Br Elemental Carbon
S Mn Ba*
As* Sr* Cd*
Sn* Sb*
* Desirable but not mandatory measurements
IV-31
-------
Development of CMB Source Profiles and a Source Matrix
A critical element of Chemical Mass Balance (CMB) receptor
modeling is development of the source emission profile
matrix-i.e., the F,. values referred to in Equation 3 above for
all emission sources to be considered. Although it is always
preferable to develop source profiles for the specific airshed
under study, data sets published in the U.S. EPA Source Library
(U.S. EPA, I984c) can provide such information for many types of
emissions sources including RWC, based on previous studies. As
this library of source chemical profiles is periodically updated
using new research, it will become an essential reference document
for CMB analysis. This section discusses example source chemical
profiles from this library, and how such information is used to
develop the basic source matrix used in any CMB analysis.
Of special interest in RWC studies is the chemical composition of
woodstove and fireplace emissions. The current EPA Source Library
(U.S. EPA, 1984c) contains a number of RWC source profiles, four
of which are shown in Tables IV-8 through IV-11. Such profiles
were based on available source characterization data through
mid-1984. Recent increases in stove and fireplace testing,
associated with federal and state regulatory program development,
could expand the available source profile database significantly
in the near future, if chemical characterization of emissions test
samples is done.
Stiles (1983) has reported the results of an extensive study of
woodstove emissions composition. Rau and Huntizcker (1985) have
studied the size distribution and chemical composition of
emissions from woodstove and fireplaces as a function of burning
conditions and fuel type concluding that under hot burning
conditions (damper fully open), 60% of the carbon emissions are in
the form of elemental carbon while under cool burning (damper
fully closed) the carbon emissions are primarily in the form of
organic carbon. In both cases, 70 + 10% of the aerosol mass was
carbon. Muhlbaier (1981) has published results for fireplace
emissions from soft and hardwood fuels.
IV-32
-------
TABLE IV-8. Example from EPA Source Library of Wood Stove Source Profile
SPECIES
NUMBER
4
5
9
11
12
13
14
15
16
17
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
37
38
40
47
48
50
51
55
56
58
80
82
201
202
203
204
SUMC X )
NOTES:
SOURCE:
sec*
CONTROLS:
SPECIES
NAME
BE
B
F
NA
MG
AL
SI
P
S
CL
1C
CA
SC
TI
V
CR
MM
FE
CO
NI
CU
ZN
GA
GE
AS
SE
BR
RB
SR
ZR
AG
CD
SN
SB
cs
BA
CE
HG
PB
OC
EC
S04
N03
WOOD STOVES-PINE FUEL PROFILE: 42101
NOME RANKING: 3338
NONE RATING : A
*********
X BY WT
NA
NA
NA
NA
NA
NR
NR
NR
0.100
0.100
1.000
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
38.700
4.500
NA
NA
44.400
OC * ORGANIC CARBON
<2.5 UM ****** ********* <2.5 UM ****** ********* <2.5 UM ******
+ - UNC X BY WT +• UNC X BY WT +• UNC
+ - NR + • + •
* - NR + • + -
+ - NR + • + -
+ • NR + • + •
* - NR •»• • + -
+ • NR + • + •
+ • NR + • + -
+ - NR + • + •
+ - NR + • + •
+ • NR + - + -
+ • NR + • + -
+ - NR + - + -
* - NR + - * •
+ • NR + • + •
* - NR + - + -
+ - NR + - * -
* - NR + - + •
* - NR + • + -
+ • NR + • + -
+ • NR * - + -
+ • NR * - + -
+ • NR + • + -
+ • NR + • + -
+ • NR + - + -
+ • NR + • + •
+ • NR * • + •
+' • NR + • + -
+ - NR + - + •
+ • NR * - * •
+ • NR + • + •
+ • NR «• • + •
+ • NR * • + •
+ • NR * • + -
+ • NR + • + •
+ - NR + • + •
* • NR + - + -
+ • NR + • «• •
+ - NR + - + -
* - NR + - + -
+ - NR * • * •
+ • NR + • *• •
+ - NR + - + •
+ • NR + • + •
0.000 0.000
: EC * ELEMENTAL CARBON : NA - NOT ANALYZED : NR * NOT REPORTED
< * LESS THAN DETECTION LIMIT
OTHER NOTES : VALUES REPORTED ARE EMISSION WEIGHTED VALUES CALCULATED FROM EARLY, MIDDLE
AND LATE • STAGE EMISSION PROFILES. REF. 33.
Source: U.S. EPA, 1984c
IV-33
-------
TABLE IV-9. Example from EPA Source Library of Wood Stove Source Profile
SOURCE:
SCC:
CONTROLS:
SPECIES SPECIES
NUMBER NAME
4
5
9
11
12
13
14
15
16
17
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
37
38
40
47
48
50
51
55
56
58
80
82
201
202
203
204
SUMC X >
NOTES: OC
BE
B
F
NA
MG
AL
SI
P
S
CL
K
CA
SC
TI
V
CR
MN
FE
CO
N!
01
ZN
GA
GE
AS
SE
BR
RB
SR
ZR
AG
CD
SN
S3
CS
BA
CE
HG
PS
OC
EC
504
N03
WOOD STOVES-
NONE
NONE
OAK FUEL
PROFILE: 42103
RANKING: 3338
RATING : A
********* <2.5 UM ****** ********* <2.5 UM ****** ********* <2.5 UM ******
X BY UT * - UNC X BY UT +• UNC X BY UT '+• UNC
NA
NA
NA
NA
NA
NR
NR
NR
1.600
1.800
7.700
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
29.200
7.200
NA
NA
47.500
* ORGANIC CARBON :
+ - NR + -
+ • NR * •
* • NS + -
+ - NR + •
* • NR + •
* - NR + -
* - NR + -
* - NR + •
+ • NR + -
* • NR + -
+ • NR «• -
+ • NR + -
* • NR + -
* • NR + -
+ - NR + •
* - NR + •
+ • NR + -
+ • NR * •
* • NR * -
+ • NR «• -
+ - NR + •
* • NR * -
* - NR * -
* • NR * •
* - NR * -
+ - NR + •
* - NR * -
* - NR + •
+ • NR + •
+ • NR * •
+ • NR + -
+ - NR + •
* • NR * -
+ - NR + -
+ • NR + -
* - NR + •
* • NR + -
+ • NR + -
* - NR + -
+ • NR + •
*• • NR * -
* - NB + -
* • NR + •
0.000
EC « ELEMENTAL CARBON : NA * NOT ANALYZED :
+ -
•f -
+ -
+ -
+ -
+ -
* •
•f •
+ -
+ -
+ •
+ •
•» -
* -
+ -
* -
+ -
+ •
+ •
+ •
+ •
+ •
» •
+ -
* -
* -
* .
* -
* -
* -
+ -
+ -
+ -
+ .
+ -
+ -
* .
+ -
+ .
+ -
* -
* -
+ -
0.000
NR = NOT REPORTED
< » LESS THAN DETECTION LIMIT
OTHER NOTES : VALUES REPORTED ARE EMISSION WEIGHTED VALUES CALCULATED FROM EARLY, MIDDLE
AND LATE - STAGE EMISSION PROFILES. REF. 33.
Source: U.S. EPA, 1984c
IV-34
-------
TABLE IV-10. Example from EPA Source Library of Fireplace Source Profile
., SOURCE:
SCC:
CONTROLS:
SPECIES SPECIES
NUMBER NAME
4
5
9
11
12
13
14
15
16
17
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
37
38
40
47
48
50
51
55
56
58
80
82
201
202
203
204
SUM( X )
BE
B
F
NA
MG
AL
SI
P
S
CL
K
CA
SC
TI
V
CR
MN
FE
CO
NI
CU
ZN
GA
GE
AS
SE
BR
RB
SR
ZR
AG
CO
SN
SB
CS
BA
CE
HG
PB
OC
EC
S04
N03
FIREPLACES
NONE
NOME
*********
X BY UT
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.606
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
38.000
33.000
NA
NA
71.606
-SOFTWOODS
FINE
<2.5 UM ******
+ - UNC
+ • NR
+ • NR
«• • NR
+ - NR
+ - NR
+ - NR
+ - NR
+ - NR
* - NR
+ • NR
+ • NR
+ • NR
+ • NR
+ • NR
+ - NR
+ • NR
+ • NR
+ • NR
+ • NR
+ • NR
+ - NR
+ • NR
* - NR
+ - NR
+ • NR
t- • NR
+ • NR
+ - NR
+ • NR
+ - NR
+ - NR
+ • NR
+ - NR
+ • NR
* - NR
+ • NR
+ • NR
+ • NR
* • NR
+ • 6.000
+ • 13.00
+ • NR
* - NR
PROFILE: 42201
RANKING: 2224
RATING : C
COARSE
********* 2.5*10UM ******
X BY UT +• UNC
NA + •
NA + •
NA + •
NA + -
NA * -
NA + •
NA <• •
NA + •
NA + •
NA + •
0.606 + -
NA + •
NA * -
NA + •
NA + -
NA * -
NA + •
NA + •
NA + -
NA + •
NA * •
NA + •
NA + •
NA * -
NA + •
NA + -
NA + •
NA + •
NA + •
NA + •
NA * -
NA + •
NA * -
NA + -
NA + •
NA + -
NA + •
NA * •
NA + •
38.000 + -
33.000 + •
NA * •
NA + -
71.606
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
MR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
6.000
13.00
NR
NR
TSP
********* <3Q UM
X BY UT +•
NA + •
NA + -
NA + •
NA «• -
NA + -
NA + •
NA + •
NA + -
NA + -
NA + •
0.606 + -
NA + -
NA + -
NA * •
NA + •
NA + -
NA * -
NA <• •
NA * -
NA + •
NA + •
NA + -
NA + -
NA + -
NA + -
NA + -
NA + •
NA * -
NA + -
NA + •
NA ••• •
NA + -
NA •*• •
NA + •
NA + -
NA + •
NA + -
NA t- •
NA + -
38.000 + -
33.000 + -
NA + •
NA + -
71 .606
******
UNC
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
MR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
6.000
13.00
NR
NR
NOTES: OC * ORGANIC CARBON : EC - ELEMENTAL CARBON : NA = NOT ANALYZED : NR = NOT REPORTED
< > LESS THAN DETECTION LIMIT
OTHER NOTES : EC, OC MEAN AND STD. DEV. VALUES FROM 7 SOURCE TESTS.1C VALUES
AVERAGE OF 3 TESTS. PROFILES ALL ASSUMED SIMILAR BASED ON SIZE DISTRIBUTION. REF.
34
Source: U.S. EPA, 1984c
IV-35
-------
TABLE IV-11. Example from EPA Source Library of Fireplace Source Profile
SOURCE:
SCC:
CONTROLS:
SPECIES SPECIES
NUMBER NAME
4
5
9
11
12
13
14
15
16
17
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
37
38
40
47
48
50
51
55
56
58
80
82
201
202
203
204
SUM{ X >
BE
B
F
NA
MG
AL
SI
P
S
CL
1C
CA
SC
TI
V
CR
MN
FE
CO
NI
CU
ZN
GA
GE
AS
SE
BR
RB
SR
ZR
AC
CD
SN
SB
cs
BA
CE
HG
PB
OC
EC
S04
N03
FIREPLACES
NONE
NONE
««•«««»»*
X BY WT
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.030
NA
NA
MA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
46.000
8.000
NA
NA
55.030
- HARDWOODS
FINE
<2.5 UM ******
•f • UNC
+ • NR
+ - NR
+ - NR
+ - NR
+ - NR
* - NR
+ - NR
+ • NR
i- • NR
«• - NR
+ - NR
+ • NR
+ • NR
+ • NR
f - NR
+ • NR
+ • NR
+ - NR
+ • NR
* • NR
* • NR
+ - NR
+ • NR
+ - NR
+ - NR
+ • NR
+ • NR
+ - NR
+ - NR
+ • NR
+ • NR
* - NR
* - NR
+ - NR
+ - NR
+ - NR
+ • NR
+ • NR
+ • NR
+ • 7.000
+ • 7.000
«• • NR
+ - NR
PROFILE: 42202
RANKING: 2224
RATING : C
COARSE
********* 2.5-10UM ******
X BY WT '+• UNC
NA + -
NA + •
NA + •
NA + •
NA + •
NA + •
NA + •
NA + •
NA + •
NA + -
1.030 + •
NA + •
NA + •
NA * -
NA + •
NA + -
NA + -
NA + •
NA + •
NA + -
NA + •
NA + •
NA + •
NA + •
NA +' •
NA + •
NA + •
NA + •
NA + -
NA * -
NA + •
NA * -
NA + -
NA * -
NA * -
NA + -
NA + •
NA + •
NA + •
46.000 i- -
8.000 + •
NA * -
NA + •
55.030
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
7.000
7.000
NR
NR
TSP
********* <3Q UM
X BY WT +-
NA «• •
NA + -
NA + -
NA * -
NA + -
NA + •
NA + -
NA + -
NA + -
NA + -
1.030 + •
NA + •
NA + •
NA + -
NA + •
NA + -
NA + -
NA + •
NA * -
NA + -
NA * -
NA * -
NA * -
NA + -
NA + -
NA + •
NA + •
NA + •
NA + -
NA + •
NA + -
NA + •
NA + •
NA «• •
NA + •
NA + •
NA + •
NA + •
NA + -
46.000 + -
8.000 + -
NA + •
NA + -
55.030
******
UNC
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
7.000
7.000
NR
NR
NOTES: OC > ORGANIC CARBON : EC « ELEMENTAL CARBON : NA = NOT ANALYZED : NR = NOT REPORTED
< * LESS THAN DETECTION LIMIT
OTHER NOTES : EC AND OC VALUES AVERAGE AND STD. DEV. OF 14 TESTS. < VALUES MEAN OF THREE
TESTS. ALL PROFILES ASSUMED SIMILAR BASED ON SIZE DISTRIBUTION. REF. 34.
Source: U.S. EPA, 1984c
IV-36
-------
The RWC source profiles for woodstoves and fireplaces shown in
Tables IV-8 through IV-11 illustrate how key RWC tracers can vary
with operating parameters such as fuel type. For example,
woodstoves burning hardwoods such as oak fuel appear to emit
signficantly more fine particulate potassium (7.73JK) than when a
softwood fuel such as pine was used (1.0%K) - based on work by
Stiles (1983). The variations in organic and elemental carbon
shown in these four profiles - which could reflect differences in
operating parameters such as combustion, temperature, excess air,
etc. - further, illustrate the variability of wood smoke chemical
composition.
Figure IV-1 illustrates the variability in RWC emission profiles
by chemical species. The variability in the RWC emission profile
is the single most important factor contributing to the relative
uncertainties associated with RWC impact estimates obtained from
receptor models.
To help insure that the RWC profile for the study area is
representative of the actual mix of wood fuels and
woodstove/fireplace emissions, it is advisable to calculate an
emission inventory weighted composite for the airshed as explained
below. The calculations require information detailing actual
fireplace and woodstove emissions as well as the relative amounts
of soft and hardwoods used. This .information is often gathered
through household surveys of wood use patterns. RWC source
profiles (such as those in Tables IV-8 through IV-11, are then
weighted in proportion to the percent of RWC emissions in each
category (fireplace, hardwoods; fireplace, softwoods; stove,
hardwoods; stove, softwoods) and averaged to produce a single
composite profile to represent RWC in a CMB analysis.
Chemical composition profiles for all sources to be included in a
CMB analysis are then combined into a Source Matrix and input into
the CMB model to be used. Table IV-12 illustrates the type of
information included in the Source Matrix.
IV-3 7
-------
o
•H
+J
•H
10 >i
O -P
H -H
§ 01
U -H
0)
O
04
140
130
120
110
100
90
30
70
60
50
40
30
20
10
0
134% Var.
81% Var.
39%
16% Var.
0.5%
132% Var.
0.5%
115% Var.
\\
CL
Chemical Species
Figure IV-1. KWC Emission Profile Variability
IV-3 8
-------
01
ti
•O
03
O
O
+1
8
o
CM
+ 1
00
CM
+ 1
1-4
CM
!
0
•
+1
00
m
o
•
+ 1
0
•
1-1
o
+1
r-4
O
cn
4)
cn
t) «
I-J
& *3
Ct)
4
1 2
/K 55
i ^
* §
h -S?
«* Q)
s 5
..
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1 s
1
? 1
K t-i
a s
3 6
41
4J
3
•i-j
«
Pu
0)
5
(fe
d
1 1 1
J +1 | 4|
t-> \o >^
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•n
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Be
^
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00
00
«
4J
O
em
g +1 +1 +1
.0 O
Vi .
co ^r ^5 co
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O 1-4
•t* 1 1 ^1
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§
0
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i-i
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<-<
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VO !
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** C
oo o
CO 4J
rf! t-l 09
M cd 3
4J H •* £>
SCO 4J B
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1-1 o) e f-» o> cj
CO U
00 p
•H 9
^ o
W tn
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1-4 «r4 *-l ^
*»J .£ 00 O
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cn > e* S
•H +1
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i-l
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st
I
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•
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a\ CM
• •
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+ 1 +1
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cn
i-i .
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+ 1 +'
cn
m .
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^4
0
Pu
i-J
05
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t-l 01
*J O i-l CN
00 p >tfe "«=
3 3
B cn
M
IV-39
-------
Each source profile should also have an associated uncertainty
estimates. This Is used by the CMB model In estimating variance
for each source contribution. The analyst then operates the CMB
model to find the mix of source contributions which best
"explains" the total mass and chemical characteristics of an
ambient monitoring sample (s).
Enrichment factor and multlvarlate models require that a single
trace element (typically potassium) be Identified as a tracer
element for RWC emissions. While potassium may be a useful tracer
for RWC emissions In Isolated, rural areas, It Is most helpful to
assess the uniqueness of potassium (or other aerosol components)
to determine the validity of the tracer assumption. One of the
best means of evaluating this Is to calculate a chemical element
emission Inventory for the study area based on: (a) the TSP point
and area source emission Inventory; (b) a knowledge of the percent
of TSP emission < 2.5 urn in size; and, (c) the chemical profiles
for each of the area's fine partlculate emissions sources. From
this Information, the total number of tons per year of potassium
(or any other species Included In the source matrix) can be
estimated and the percent of potassium associated with RWC
emissions can be obtained. If RWC emissions can reasonably be
shown to contribute the majority of the potassium emissions during
the space heating season, then potassium can be used as a valid
tracer In enrichment factor and multlvarlate analysis.
4. Receptor Model Applications
The receptor model application described above can be catagorlzed as
quantitative, semi-quantitative or qualitative based on the method's
ability to resolve woodsmoke Impacts from other sources. Only the
quantitative methods provide a sufficient level of confidence to
support regulatory action. Semi-quantitative and qualitative
techniques, however, are highly useful In confirming the conclusions
reached through the more accurate methods. Their parallel use Is
therefore encouraged.
IV-40
-------
a. Quantitative Methods of RWC Impact Assessment
Radiocarbon Techniques
The measurement of RWC particulate impacts through radiocarbon
(carbon-14) isotope analysis pioneered by Currie (1982) can
provide an accurate direct assessment of RWC impacts if: (a) fine
particle samples are submitted for analysis; (b) it can be
reasonably shown that other sources of "modern carbon" (e.g.,
structural fires, forest fires, landclearing burning, industrial
combustion of woodfiber or other potential sources of vegetative
burning emissions) are of minor importance at the time of
14 12
sampling. Since the ratio of C/ C In the fuels burned in
the airshed is required as an input to the interpretation of the
data, radiocarbon measurements of sawdust obtained from cross
sections of fuel wood used within the airshed should be
concurrently analyzed with the ambient samples. If a mix of wood
species are burned, a weighted average sawdust composite sample
should be analyzed.
Since this method only provides an estimate of the percent of
"modern" carbon exclusive of the oxygen, hydrogen, nitrogen and
trace elements associated with RWC emissions, it is necessary to
correct the radiocarbon estimates to include these components.
Based on studies by Rau and Huntzicker (1985), 70 + 10% of RWC
emissions are carbon requiring that the "modern" carbon estimate
be scaled up by a factor of 1.42 (1/0.70).
Although radiocarbon methods have been applied to TSP and SSI
samples, results obtained from such samples should be considered
semi-quantitative. They provide an upper-limit estimate of
woodsmolce impacts, since Interferences from coarse particle
"modern" carbon sources (e.g., leaf fragments, insect parts,
pollen, sander dust, etc.) can be Incorrectly assigned to RWC
sour ces.
IV-41
-------
Duker et al, (1984) have recently applied radiocarbon methods to
the determination of ambient Carbon Monoxide (CO) Impacts
associated with wood burning sources. Figure IV-2 Illustrates the
14
CO sampling train. Integrated four to 16 hour samples can be
collected at flow rates of five liters per minute before the
substrates In the train need to be changed. Ambient air Is drawn
through a rotometer to a series of soda lime and Drier Ite
absorption columns to remove ambient carbon dioxide and water
vapor. Activated charcoal Is used to trap C, and higher
hydrocarbons. CO is then oxidized in a Hopcalite column and the
resultant CO- Is trapped on a carbonate-free, sodium hydroxide
impregnated firebrick substrate. The sealed CO- absorption
column can be stored Indefinitely prior to Tandem Accelerator Mass
Spectrometer analysis for radiocarbon isotopes. The C/ C
ratio measured in the desorbed CO- provides a direct measurement
of the percent of ambient CO which originated from woodburaing
sources.
Chemical Mass Balance
CMB-derived estimates of short term RWC Impacts offer the most
cost-effective means of obtaining quantitative data. The analyst
must be aware, however, that other emissions from vegetative
burning sources may not be distinguished by the model if the
source profiles of the two emissions sources are similar. An
analysis of source emission activities can often be used to
clarify such issues as described in the previous subsection. To
provide additional verification of CMB-estimated impacts, many
researchers have intercompared radiocarbon and CMB estimates.
Such comparisons have typically found that the impact estimates
from the two methods were comparable within the limits of
experimental error (+ 30%). Again, the CMB ambient aerosol data
sets must be obtained from fine particle samples to assure a high
degree of confidence in the results.
IV-42
-------
ea
o
m
c
•H
CD
h
H
00
8-
(0
(A
O
U
g
to
o
o
•H
•§
cs
00
•H
fa
CO
CT>
t-l
N^
rH
(0
4J
0)
M
0)
I
O
u
l-l
3
O
0-5
IV-43
-------
Multivarlate Models
Multiple regression analysis may be vised as a quantitative
analysis tool if the features (elements, ions or carbon species)
selected for analysis as independent variables are known to be
tracers for specific sources. The P.. values used In the
chemical emission inventory calculations may be utilized to
determine the species that can serve as source tracers. The
general multiple regression equation is shown in Equation 4.
Multiple Regression Equation
Y - a + b.X. + b_X.... + b X (4)
L L f. 2. n n
Where:
Y " Dependent Variable (fine particle mass)
a • Intercept (Background fine particle mass)
b - Partial Regression Coefficient, variable i
X * Independent Variable (tracer elements)
The Intercept represents the value of 7 when all of the
Independent variables are zero. The partial regression
coefficients are a measure of the change in the value of Y per
unit change in X when all other independent variables are held
constant. The value of the partial regression coefficients
determined by multiple regression analysis are the reciprocal of
F, . which the tracer represents . The product (bX) of the
partial regression coefficient and the concentration of the tracer
element is the Impact of the source which the tracer element
represents .
b. Semi-quantitative Methods
Enrichment Factor Models
As noted above, this method uses ambient aerosol elemental
composition data In association with a reference element to
IV- 44
-------
provide an estimate of the degree to which the "natural concentration"
of a given element has been "enriched" by a man-made emissions
source. The generalized equation for this application is shown In
Equation 5.
Enrichment Factor Equation
EFt m (Ci/Cr) aerosol (5)
(Ci/Cr) reference
Where:
EF - Enrichment factor or tracer element "I"
C. ~ Concentration of tracer element "I" in the ambient
aerosol
C « Concentration of reference element "I" in soils
The reference element is usually a crustal element, commonly iron,
aluminum, silicon, or calcium. Crustal elements are used because
of their abundance in ambient samples. By normalizing the source
tracer element to a crustal element, local meteorology that may
affect the elemental concentrations can be factored out.
Enrichment factors near 1.0 indicate that soil Is the likely
source of the tracer element. Values significantly greater than
1.0 Indicate that the ambient aerosol has been enriched by another
source. Potassium 00 is typically used as a tracer element for
RWC emissions, while Iron (Fe) has been widely used as a crustal
reference element. Variation in the K/Fe enrichment factor have
been found to closely correlate to known periods of RWC impact in
several studies (Lyons et al, 1979).
This concept can be extended to provide a semi-quantitative
estimate of woodsmoke impact, if the concentration of potassium in
RWC emissions is known:
IV-45
-------
RWC =
(C /C Impact) - (C./Cr No Impact)
Inpact)(F
* C.
(6)
Where:
Coacentratloa of RWC (ug/m )
Concentration of tracer element "1" (ug/m )
Concentration of reference element "r" (ug/m ;
Fraction of tracer element "I" In "source "j1
emissions (weight percent)
Mean concentration of the tracer element "I"
Used In this form, the enrichment factor model la a form of
Chemical Mass Balance in Which the tracer element (typically
potass lisa) is used to calculate woodsmoke impacts. For example,
assume the average K/Fe ratio during woodsmoke impact periods is
2.0, compared to an average K/Fe ratio of 0.6 during non-Impact
periods and that the average ambient concentration of potassium is
3 3
0.2 ug/m . Then an estimated average impact of 5.0 ug/m is
obtained, given an average content of 2.8% potassium in the
woodsmoke emissions:
RWC
* 0.2
(2.0) (0.028)
(7)
CRWC - 5.0 ug/nf
(8)
Such estimates are considered semi-quantitative because of their
sensitivity to the variability of potassium in the source
emissions (Figure IV-1). In addition, the model assumes that
potassium is uniquely emitted by RWC sources, an assumption that
may not be valid in some urban settings.
IV-46
-------
Qualitative Methods
Time series analysis of light scattering measurements, enrichment
factors and fine particle mass can be effectively compared to RWC
impacts estimated by (MB, radiocarbon and multivariate analysis
methods to evaluate the credibility of RWC impact estimates.
Temporal and spatial patterns of these parameters should be highly
intercorrelated if woodsmoke impacts are the principal source
impacting the receptor. These qualitative methods of RWC Impact
assessment are discussed below.
Carbon Thermograms
Stepwlse temperature programming combustion of aerosol samples
over a temperature range of 350 to 700 C can be used to
detect changes in the boiling point distribution of organic and
elemental carbon aerosols in the ambient air (Johnson and
Huntzicker, 1978). Thermograms of woods tove and fireplace
emissions, for example, are similar to ambient samples known to
have been highly impacted by RWC emissions. These patterns are
distinctly different from those obtained from other sources or
from ambient samples taken in the same airshed during summer
months in which little, if any RWC emissions are occur ing. Figure
IV-3 Illustrates the differences in these patterns.
Temporal Patterns
Diurnal and seasonal variations in light scattering measurements
made by integrating nephelometers can provide a qualitative
indication of woodsmoke concentrations. Figure IV-4, for example,
illustrates differences between typical hourly average scattering
coefficients measured during summer and winter months in an
airshed known to be impacted by woodsmoke. The winter pattern is
typified by a late evening peak in fine particle concentrations
that is not seen during the summer months. Diurnal patterns shown
in Figure IV-4 indicate a peak during the winter months that may
track the late evening peak in woodstove and fireplace use, which
typically occurs between 8 and 11 pm local time.
IV-47
-------
Oil-fired furnace
Automobile exhaust
<0
•o
•H
X
o
•H
O
I
h
cd
u
Natural gas-fired boiler
Wood-fired industrial boiler
Temperature
Figure IV-3. Carbon Thermograms of Source and Ambient Aerosols
Source: Kowalczyk and Greene (1982).
IV-48
-------
Fireplace
Wood Burning Stove
Medford Ambient
(Christmas Week)
-------
CD
Bend
Nephelometer Variation
Winter vs. Summer
=r--to ' AUG
12
Hour of Day
18
24
Medford
Nephelometer Variation
Suggesting RWC Impacts
3 3-
FEB. NEPH. —+> 39
WINTER CMB •*• 37 tg/m3
12
Suspected/
Wood /
Impact
5 Hour of Day
18
Figure IV-4. Seasonal and Diurnal Variations in RWC Pollutants
Source: Kowalczyk and Greene (1982).
IV- 50
-------
Since woodstoves emit, OQ the average 600 and 1,000 times more
carbon monoxide than oil furnaces and natural gas furnaces,
respectively, evening CO peaks in winter tine at residential sites
provide additional qualitative evidence linking RWC appliance use
to air quality impacts. The value of the analysis is further
enhanced if the CO diurnal variations at the residential site are
compared to that measured at a central business district (CBD)
monitoring site that is known to be principally impacted by
transportation sources. Studies by Harris (1983) indicate that,
while winter CO and scattering coefficient variations are highly
2
correlated at a residential site (R of 0.95), the correlation
between these two parameters at a CBD site during the same time
2
period were poor (R of 0.2). As illustrated in Figure IV-5,
the temporal variation patterns of CO and light scattering
(b ) at the two sites are strikingly dissimilar, indicating
s cat
the likely differences between the emission patterns of
transportation and RWC sources.
In addition to analysis of light scattering, CO and fine particle
mass variations, additional information can be gained by a diurnal
and seasonal analysis of the organic carbon and/or fine particle
potassium to mass ratios of the aerosol. Since RWC emissions are
highly rich in these species, a high degree of correlation between
these measurements would tend to provide confirming evidence that
RWC emissions are the common source of the pollutants. While it
is Important to note that a high degree of correlation does not
prove a causal relationship, the occurrence of the pollutant
variability patterns and correlation during the winter season
furthers the evidence that RWC emissions are likely sources
impacting the site.
5. Joint Application of Dispersion and Receptor Models
Several researchers have demonstrated the value of the joint use of
dispersion and receptor models in RWC impact studies. This approach
is especially useful when the emission inventory and/or other data
IV-51
-------
a18-
CO -
« 16-
00
M
J 2:
(0
o
CO
B-scat
«*
8-hr CO Max -11.9 mg/m"
6AM' ' ' ' 12 6PM'
Time of Day
- 18
- 16
- 14
- 12
- 10
- 8
- 6
- 4
- 2
CO
o
CO
e
0)
<4-4
ID
O
00
e
•H
CO
U
CO
4J
•a
' ' ' ' 6AM
4-l
- 10 §
o
- 8 g>
_ -H
- 6 ?.
- 4
H
to
oo
6AM
Figure IV-5. Diurnal Variations in CO and B-scat at Residential
and CBD Monitoring Sites
IV-5 2
-------
bases used In dispersion modeling are of marginal adequacy (Core et al,
1980). The results of the receptor modeling can be used to critically
evaluate the emission and meteorological assumptions used in dispersion
modeling to deduce whether the emission and dispersion characteristics
of the RWC sources have been adequately characterized. Inhoff et al,
(1983) for example, applied Chemical Mass Balance receptor modeling
results in an evaluation of the ability of several dispersion models to
reasonably simulate RWC area source impacts within the Petersville,
Alabama airshed. Core and Hanrahan (1983) were able to identify major
deficiencies in the Portland, Oregon RWC emission inventory based on an
inter comparison of woodsmoke impacts independently derived from each
modeling approach. Since dispersion models must be used to estimate
future source emission impacts, the validation of dispersion models
against receptor modeling estimates of source impacts is an extremely
useful tool for regulatory actions that must be based on future year
projections of air quality.
6. Modeling RWC Visibility Impacts
During the past decade, numerous studies have been conducted to
determine the relationship between urban haze and air pollution
sources. Extinction budget analysis has been conducted in many
airsheds including Denver (Dennis, 1983; Wolf et al, 1980), Detroit
(Sloane and Wolf, 1984),-IDS Angeles (Cass, 1979), Portland (Shah, 1981
and Shah et al, 1984), and Oakland (Barone et al, 1979). These studies
have clearly demonstrated the relationship between fine particle (<2.5
urn) size, mass and chemical composition and atmospheric light
extinction through empirical models based on statistical associations.
Empirical models fit the measured total light scattering and absorbance
of airborne aerosols to the concentrations of chemical species by
multivariate linear regression. Such models generally provide good
fits in that the correlation coefficient for the fitted and measured
light scattering measurements is usually high, providing valuable
insights into the relative importance of each aerosol species to
visibility impairment. Empirical regression models take the form of:
IV-53
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Bsp" IClMl+Babs
In this relationship: B represents the measured scattering
coefficient; C, is the partial regression coefficient which
physically represents the scattering efficiency of the individual
species; M. is the measured mass concentration of the chemical
species "1"; and B . is the light absorbance associated with the
elemental carbon component of the aerosol.
The aerosol sampling and analytical requirements of extinction budget
models are similar to those described for receptor modeling, but
require concurrent B data obtained from integrating nephelometer
measurements of light scattering. As a prerequisite to model
development, the analyst must select aerosol species that can serve as
unique tracers for airshed sources while attempting to explain, through
the multiple linear regression analysis, as much of the variability In
the B observations as possible. Chemical emission inventories,
sp ^ '
described in Section IV. C. 3, are extremely useful in Isolating those
aerosol species that are useful source tracers. Typical regression
models Include organic carbon or potassium mass concentrations as
tracers for RWC emissions, Pb as a trans portIon tracer and Si as a soil
dust tracer. Nitrate and Sulfate measurements are usually included to
account for scattering associated with secondary aerosol. The
reciprocal of the relative humidity may also be added to the list of
Independent variables, to account for humidity effects on aerosol size,
which effect the scattering efficiency of fine particles.
Once the regression models are developed, predicted changes In average
visibility conditions under altered emission scenarios can be made by
increasing or decreasing the M. concentrations of one species, while
holding the others constant. Future year concentrations of specific
aerosol species (M.) are obtained from proportional rollback modeling
of RWC emissions changes, given a knowledge of current RWC emissions
and ambient Impacts. As an alternative, future year M
concentrations can be obtained by dispersion modeling of likely
emission Increases and application of source profile Information. If,
for example, a 10 ug/m Increase In woodsmoke Impact Is predicted by
IV-5 4
-------
a proportional or dispersion modeling analysis, and RWC emissions are
assumed to contain about 36% organic carbon (see Tables IV-8 through
3
IV-11) then a 3.6 ug/m increase in organic carbon would be
predicted. Associated visibility impairment could be estimated using
the regression model already established for the airshed. The
validity of this approach, of course, Is dependent upon the stability
of the regression model. This can be tested by iterative modeling
using subsets of the ambient aerosol database.
7. Estimating RWC Impacts Through Atmospheric Tracer Studies
a. Overview
Chemical tracers (e.g., sulfur hexa f luor ide, SF,) can be
released in precise quantities and then measured through field
monitoring in order to determine the pollutant dispersion
characteristics for an area. The relationship between emissions
released and resultant measured concentrations can be used to
predict short term (e.g. peak 24 hr.) impacts, based on an
Inventory of RWC emissions.
This section addresses the use of tracers selected because they
are not normally found in ambient air in significant
concentrations. The use and applicability of other trace
chemicals or elements selected because they comprise a measurable
fraction of RWC emissions (e.g. methyl chloride, or carbon-14) are
addressed in Section IV. C.3 and IV. C. 4.
Tracer studies are discussed below in terms of: how they work;
strengths and limitations; and, an example RWC application.
b. How Tracer Studies Work
Pollutant emissions disperse and result in concentrations of
varying magnitude throughout an airshed. Certain "tracer"
chemicals exist which can facilitate the determination of this
relationship between emissions released and resultant
concentrations. Sulfur hexafluoride (SF,) is one of the most
o
IV-55
-------
commonly used- gaseous tracers. SFfi is non-toxic, detectable in
the parts-per-trillion range, not typically found in ambient air
at those concentrations, chemically stable, easily dispersed at a
measured rate, and has a fairly low molecular weight which results
in rapid mixing with the air (Collins et al, 1965). These
characteristics make it possible to use SF, to simulate
pollutant dispersion processes with precise measurement of release
rates and resultant concentrations. The results are valid only
for specific locations, and for the meteorological conditions
which exist during the test. The data can be used to verify and
modify a dispersion model for the study area.
Strengths and Limitations of Tracer Studies
Predicting the ambient air impact of a source is likely to be more
accurate with the use of a tracer study than using computer
modeling alone. This is because pollutant dispersion is a complex
physical process to simulate mathematically.
Most models require wind flow fields to be simulated, yet wind
speed and direction information are not always available. Due to
the response threshold of typical anemometers, wind speeds below
about two miles per hour are reported as calm. Thus during
periods of flow reversal, when winds are light and variable, the
available meteorological data may even be misleading (Wlllson et
al, 1983). Reviews of the accuracy of various dispersion models
in predicting concentrations for complex terrain commonly report
model prediction performances in the range of a factor of two or
worse (American Meteorological Society, 1984). If worst case
meteorology Is the period of Interest, and the tracer study is
conducted under poor dispersion conditions, the actual
relationship found between emissions released and resultant
concentrations can be used. The tracer study findings can also be
used to select and suggest modifications to an appropriate
dispersion model. When vehicle traverses are used to sample
SFg, with samples taken at Intervals one tenth of the mile
apart, a wealth of data are available for analysis. Having
IV-56
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measurements from hundreds of different locations can enable a
much better understanding and simulation of the mechanics of local
dispersion processes.
The ability to measure SF, at concentrations in the parts per
trillion range and the stability of SF, enable accurate
calculation of the relationship between emissions released and
resultant concentrations. The use of actual RWC tracers such as
potassium (K), methylchloride (CHgCl), or carbon, does not have
such a clear cut relationship, since the percentage of RWC
emissions which those compounds comprise can vary with wood type,
and other variables.
A tracer study can be uniquely beneficial when planners are
attempting to predict the air impact of a source before it is
constructed or in operation. In such a case, there is no way to
estimate impacts by receptor modeling since the emissions do not
yet exist. Such an example is discussed in the next subsection.
SF, tracer studies can be expensive, generally costing more than
$25,000. Actual costs depend on: 1) the number of tests, 2) use
of ground vehicle vs airplane traverses and; 3) complexity of data
interpretation, e.g. whether computerized dispersion modeling is
included.
Although the relationship between emissions released and resultant
concentrations can be quantified accurately, there are two key
obstacles to determining RWC impacts from such a tracer study.
First, predicting RWC impacts based on tracer study findings
requires the input of some assumed amount of RWC emissions. There
is always some error in estimating the emissions from a source,
and RWC emission factors often, have relatively high uncertainty.
This same obstacle is faced in computerized dispersion modeling.
IV-57
-------
Second, tracer studies are done during time periods with specific
meteorology. Field monitoring tracer studies without subsequent
computer modeling can only characterize dispersion conditions
present during the field tests. Some tracer study experiences
help minimize this concern. For example, when two tests were done
in Telluride, Colorado several days apart under conditions with
different meteorology, the ratios of emissions released to
resultant concentrations at the key site of interest were within
28% of each other (Wilson et al, 1983).
It is also difficult to duplicate with tracers the manner in which
emissions are released from area sources - e.g. RWC. For example,
area sources in a small confined area may be adequately
represented by a single release point, but multiple release points
would be necessary to simulate area source emissions for a
metropolitan area SF.. tracer study. It can also be difficult to
o
simulate the time variation of an emission source, such as RWC,
especially if there is limited information on emission rates vs.
time of day.
d. Example Tracer Study
An SF, tracer study was conducted in 1982 in Telluride, Colorado
o
with the goal of characterizing current and future potential RWC
air Impacts. The primary motivation for the study was the need of
a Colorado ski resort developer to determine likely air Impacts
from Residential Wood Combustion if a large ski area development
were constructed in this mountain resort area. Since dispersion
modeling alone was judged an inadequate prediction tool in such
complex terrain, the tracer study approach was selected.
Three different tracer release tests were conducted. Two tests
were set up with tracer releases from the proposed new development
area, and monitoring was conducted in the surrounding territory
via fixed sites and auto traverse sampling. The third test was
set up to simulate RWC emissions within the Town of Telluride, in
order to characterize the impact of existing sources at various
locations.
IV-58
-------
The tests Improved understanding of the dispersion mechanics in
and near the San Miguel Valley near Telluride. Actual results and
methods are discussed by Wilson et al, (1983). Anong the findings
was the conclusion that each ton of emissions released per day in
the Town of Telluride would tend to result in 24-hour particulate
3
impacts of 179 ug/m under the meteorological conditions which
prevailed at the time of the experiment.
D. Dispersion Modeling
1. Overview of Dispersion Modeling
The development of Residential Wood Combustion (R.WC) control
strategies requires the application of dispersion models capable of
accurately estimating RWC impacts under a variety of emission control
scenarios. This section discusses a variety of models, their data
base requirements, model validation and specific model applications in
actual airsheds. The following text is intended only to address the
application of dispersion models to RWC assessment. Readers
interested in more general applications of these models should also
refer to appropriate EPA dispersion modeling guidance, Including:
Guideline on Air Quality Models (U.S. EPA, 1978, 1984d); Interim
Procedures for Evaluating Air Quality Models (Revised) (U.S. EPA,
1984e, 1985); "Regional Workshops on Air Quality Modeling" (U.S. EPA,
1981c); and to users guides for specific dispersion models of interest
(e.g., U.S. EPA, 1973, 1977a, 1978a, 1979a, 1979b) on EPA's UNAMAP
system. The joint application of dispersion and receptor models was
discussed briefly In Section IV. C.5.
a. Introduction to Dispersion Modeling
Air Quality dispersion models are a set of mathematical equations
relating the release of air pollutants to resulting concentrations
of pollutants in the ambient atmosphere. Thus, they provide a
tool for predicting the consequences of changing pollutant
emission rates, or assessing the impact of an emission source(s)
on ambient air quality standards.
Dispersion models are useful in developing and evaluating RWC
control strategies designed to attain acceptable air quality, in
IV-59
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evaluating likely consequences of expanding emission growth, and
in projecting future air quality trends and patterns associated
with community growth.
In addition, dispersion model-derived estimates of RWC impacts are
highly useful for identifying areas of expected high impacts, and
providing insights on locating additional monitoring sites.
Effective use of dispersion models, however, requires the
collection and analysis of both meteorological and air quality
data to provide a basis for model evaluation and validation.
Monitoring of background pollutant concentrations associated with
distant, upwind RWC sources that are not included in the emission
inventory data base is also required.
Generally accepted practice is to complete a two level modeling
analysis. The first level provides a screening analysis of
potential RWC source impacts through the use of a simplified model
analysis designed to estimate RWC impact under worst case
meteorological situations. The second step, employing any one of
a number of more complex models, is initiated if potential
problems are identified during the screening analysis.
The second phase of modeling incorporates a more detailed
treatment of actual meteorological episodes, terrain influences
and dispersion characteristics of the emissions sources. Both
phases of modeling require data on source emissions, air quality
and meteorology, including wind direction, wind speed, atmospheric
stability and mixing height information.
The choice of a dispersion model to be applied during the refined
modeling analysis is primarily dependent on the level of detail
required to fulfill the objectives of the analysis, the
availability of input data and the physical nature of the
airshed. In RWC applications, the most critical factors in
selecting a model are its ability to accurately simulate area
source emissions for 24 hours, seasonal and annual time periods.
IV-60
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RWC emissions are relatively nonreactive during short transport
periods. RWC particulate matter emissions' are predominantly
within the fine particle size range, so complex particle
deposition, reactivity and secondary aerosol formation assessments
are not essential.
b. Considerations in RWC Applications
Dispersion modeling of RWC emissions presents several difficulties
not usually encountered with point source modeling. These include
the complexity of simulating the dispersion of low level, low
buoyancy area source plumes that are subject to plume downwash
around buildings.
Also airsheds adversely impacted by RWC emissions are often
located in mountainous areas typified by complex terrain, where
low wind speeds and stable atmospheric conditions can effectively
trap pollutants. The limited availability of onsite
meteorological data in rural areas, and/or difficulties in
preparing accurate emission inventories of RWC emissions can
further complicate dispersion model applications. Because of the
limited ability of dispersion models to address the extremely
complex nature of dispersion under such conditions, the analyst
must exercise caution in the application of dispersion models
within such airsheds. Comparisons with some form of
receptor-oriented RWC impact estimates is especially advisable in
such cases.
Applicable Dispersion Models
Although a number of dispersion models have potential application to
RWC impact assessment, relatively few papers have been published
documenting model applications and intercomparisons of modeling
results. The models described below, however, have been found to be
useful in RWC studies. This section lists the characteristics of
various models and their application to woodsmoke impact assessment.
IV-61
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This discussion includes some of the standard models from EPA's "Users
Network for Applied Modeling of Air Pollution", or UNAMAP system (U.S.
EPA, 1983e), as well as other specialized models that have been
applied to RWC analysis. Table IV-13 summarizes the characteristics
of those models which have been commonly used in RWC studies. Each of
these models are discussed in greater detail below.
a. EPA UNAMAP Models
A number UNAMAP models have been used in RWC studies, including
ISCLT, ISCST, CDMQC, RAM and PAL. Each of these models is
described below. Since the model's treatment of area source
emissions is especially critical in RWC studies, the description
focuses on this aspect of the model. More detailed descriptions
of each model can be found in the US EPA guidance documents and
users guides cited above. Several of these models require that
the analyst select either urban or rural dispersion coefficients
as inputs to the model. EPA guidance on this issue specifies that
the analyst determine the land use within a three km radius of the
source. If more than 50% of the land use is of an industrial,
commercial or multiple dwelling residential nature, urban
dispersion coefficients should be used (Auer, 1978). In addition,
the analyst can specify an effective stack height for area source
emissions. Work by Imhoff et al, (1984) suggests that a source
height of four meters is appropriate for RWC emissions based on
calculated building downwash effects which can occur even at low
wind speeds.
PAL Model
PAL is a point, area and line source model used to calculate
short-term concentrations of stable pollutants (U.S. EPA, 1978a).
The model can be used to estimate RWC impacts within portions of
an urban area at a maximum of 30 receptors. Calculations are
performed for each hour and require hourly meteorological data
(wind speed, wind direction, stability class and mixing height).
Level terrain, steady state conditions and Gaussian plume
dispersion are assumed. Area source emissions can be gridded for
modeling in either squares or rectangles. Emission rates can be
IV-6 2
-------
TABLE IV-13. Diaper a ion Model Characteristics
Averaging Period
Model Annual 24 Hour
PAL
RAM
ISC-ST
ISC-LT X
CDMQC X
GRID X
AREAS X
Box
Rollback X
Holzworth X
X
X
X
X*
X
X*
X
Plume
Dispersion
Gaussian
Gaussian
Gaussian
Guasslan
Gaussian
Eulerian
Gaussian
Advection
Implicit
Gaussian
Complex
Terrain
No
No
No
No
No
Yes
No
Yes
Met
Inputs
Hourly
Hourly
Hourly
STAR
STAR
Hourly
AIRDOS II
Hourly
None
Published
Gridded
Emissions
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
Requires statistical time average conversion. See Text.
IV-63
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varied hourly by specifying the fractional amount of emissions to
be applied, thereby enhancing the ability of the model to
accurately simulate diurnal variations in RWC emissions. Since
Gaussian models fall to account for the hour-to-hour buildup of
pollutants during low wind speed conditions 1 m/sec. is the
minimum wind speed sanction for use in PAL), worst case short-term
estimates may be under predicted. PAL is, however, especially
useful for carbon monoxide (00) RWC Impacts, because it Is able^to
simulate both the RWC area source and line source emissions of CO
from vehicle exhaust.
RAM Model
The RAM model Is useful for calculating short-term concentrations
during a one year period in flat urban areas with point and area
sources in multiple locations (U.S. EPA, 1979a). Like PAL, RAM is
a steady-state Gaussian model which employs a narrow plume
simplification to calculate area source concentrations. This
assumption is appropriate for cases in which area source emission
densities are relatively uniform. RAM can also accept diurnal
variations In RWC emissions. Locations, size, emission rates and
the effective plume height of the emissions are required for each
area source. Meteorological data are input to CRSMET or RAMMET,
two meteorological preprocessor programs which can be effectively
used to sequentially scan the data base for worst case, 24 hour
dispersion conditions.
IS GST Model
The ISC model (U.S. EPA, 1979b) is another steady-state Gaussian
model used to estimate pollutant concentrations from a variety of
point, area, line and volume sources for both short-term (BCST)
and long-term (ISCLT) periods. Both forms of ISC can account for
particle deposition. Point source building-induced plume downwash
is handled by the Huber-Snyder method. The area source treatment
is calculated as a finite crosswind line source, or as a volume
source in which the area source emissions within each grid are
mixed within their respective cells and then advected downwind.
The volume of the cell is determined by the dimensions of the grid
IV-64
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consistent with their climate and space heating demands. From
these results they could estimate RWC emission factors in grams/
kilogram of wood burned, for appliances of special interest in
their areas.
This level of effort in estimating RWC emission factors for
different types of RWC devices is not warranted to obtain a first
approximation of RWC emissions. However, it may be useful in
projecting future RWC emissions levels, for areas in which a
significant transition to much cleaner burning appliances is
anticipated over time. Under such assumptions, AP-42 RWC emission
factors could substantially overpredict future RWC emissions. The
following section discusses projection of future RWC emissions in
more detail.
Another factor that may have to be considered in selecting
appropriate local RWC emission factors is altitude (elevation
above sea level). Recent preliminary findings (She!ton, 1985)
have been interpreted by others (Oregon DEQ, 1985) as indicating
that particulate and carbon monoxide emissions from both catalytic
and non-catalytic woodstoves tested in Sante Fe, New Mexico
(elevation: 7,300 feet above sea level) average about twice as
high as emissions compared to the same woodstoves tested in
Portland, Oregon (elevation: 75-100 feet above sea level). If
these results are confirmed by more testing, they will represent
a significant consideration for higher altitude communities in
selecting appropriate RWC emission factors, as well as for EPA in
revising AP-42. This development is consistent with EPA's
development of different vehicle exhaust emission factors for use
in higher altitude states, principally in the Rocky Mountains.
3. Projecting Future RWC Emissions
Projecting future RWC emissions levels typically begins by
estimating RWC wood usage and corresponding emissions for some
appropriate baseline year, using approaches such as those described
in the previous two sections. Baseline emissions can now be
extrapolated into the future using various trend factors - e.g.
111-65
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A useful feature of this model is the ability to adjust predicted
concentrations based on a linear regression analysis against
measured RWC impacts. Meteorological inputs are similar to ISCLT,
in that STAR deck data are needed. CUM does not treat building
plume downwash, or particle settling/deposition, nor does it
calculate plume rise for area sources. Flat terrain is assumed.
b. GRID Model
One example of a model that may be considered on a case by case
basis, after a performance evaluation and approval by EPA, is the
GRID model.
GRID is a numerical conservation of mass, Eulerlan model
(Hanrahan 1981a) which has several major advantages over Gaussian
models in estimating RWC impacts. Principal among these is the
model's ability to use a unique wind speed, wind direction and
stability class for each grid cell for each hour. This is
supplied by key station meteorological data and coded inputs
describing airshed topography. The GRID model wind fields are
calculated using the WEST meteorological preprocessor (Hanrahan,
I981a).
GRID'S DTBASE emission inventory preprocessor (Hanrahan, 1981a)
produces separate point and area source emission files in an input
format suitable for GRID. It also apportions point and area
source emissions into day and night time periods, and provides
initial calculations of plume rise during stable and unstable
conditions.
The model's cell array accomodates a user-defined grid cell size
(e.g., two km), each of which may be divided into up to five
vertical cells of variable height. This vertical zoning provides
an important advantage in simulating low level RWC emissions,
while also accomodating the higher plume rise associated with
higher energy emissions from point sources.
IV-66
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A Brigg's (1975) plume rise algorithm is used for point sources.
Area source emissions are assigned to the lowest cell (50 meters)
existing above the topography. Because of the computational
requirements of the model, the airshed climatology is often
categorized in terms of discrete meteorological "regimes". Each
of these describes a wind field pattern and stability, with a
known seasonal frequency of occurrence. The model can, however,
use hourly data developed for specific days.
Simulations are then prepared for each regime, and the outputs
weighted based on regime frequency of occurrence, to arrive at an
annual or seasonal average pollutant concentration. Short-term
impacts may also be estimated on the basis of a worst case 24 hour
regime.
Once the model is validated using all airshed point and area
source emissions, impacts associated with specific sources can be
estimated, by limiting the emission database used to only the
source (s) of interest. Specific control strategies can be
simulated, using their estimated reduction in specific source
emissions.
The GRID model has been applied to RWC modeling in Portland,
Oregon. This experience demonstrated the importance of specifying
the distribution of emissions during the day, and the value of
comparison of the modeling results with those obtained from
receptor (e.g., (MB) models. For example, the initial GRID model
predictions underestimated CMB results by one-half (Hanrahan,
1981b).
This discrepancy led to a review of the EPA (AP-42) RWC emission
factor used, which at the time was 22 pounds per ton of wood
burned. This was based on the EPA Method 5 source testing method,
which excluded the condensible organic fraction of the RWC
emissions. Comparison of the Chemical Mass Balance/GRID impact
IV-67
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estimates, however, indicated that a 75% Increase in th». emission
factor to 38.5 pounds per ton would yield comparable impact
estimates.
Chemical Mass Balance/CDMQC results for the Medford, Oregon
airshed were similar, so the higher emission rate was also used in
the control strategy development modeling for this airshed.
Subsequent to this work, the AP-42 woodstove emission factor has
been changed to 40 pounds per ton of wood burned (U.S. EPA.,
1983b). Following corrections to the emission inventory, the GRID
model was used to predict future (1987) RWC impacts based on
estimated emission growth and assuming typical worst case winter
meteorological conditions. Results from the modeling with GRID in
Portland, Oregon indicated RWC impacts ranging from 6.9
3
(industrial receptor) to 37 ug/m (residential area), compared
3
to impacts of 6.2 to 7.4 ug/m for all point sources at the same
receptors (Core et al, 1980).
c. Screening Models
Box Models
The simplest and most appropriate screening analysis for
estimating worst case 24-hour impacts involves the use of the
basic box model. In this model, the change in pollutant
concentrations over time is directly proportional to the source
emission strength, mixing height and wind speed through the mixing
layer:
_ (1 _ e-nt)
tin
Where:
XQ= Ambient Concentration entering the box (ug/m^)
X " Ambient Concentration (ug/m )
Q • Emission Strength within the box (ug/sec/m2)
U • Average Mixing Layer Wind Speed (m/sec)
H - Mixing Ffeight (meters)
Loss
Time
n " Loss factor (sec )
IV-68
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When wind transport is the only loss mechanism and steady state
conditions are assumed, equation 9 can be simplified to:
Where: L^Box Width (meters)
This model assumes that pollutants are well mixed instantly after
release, and that the atmosphere is unstable, assuring good
vertical mixing. Values for L, the box model width, are
determined by the location of topographical features which limit
pollutant dispersion.
Rau has applied the box model to the Medford, Oregon airshed to
estimate RWC emission impacts over a series of 24 hour periods for
which fine particle (< 2.5 uo) carbon data were available (Rau,
1981). Earlier studies by DeCesar and Cooper have demonstrated
that 602 of the airshed's carbon emissions originated from RWC
sources (DeCesar and Cooper, 1981).
Comparisons of the variability of measured atmospheric fine carbon
concentrations and those predicted by the box model showed that
these were highly correlated (r*0.87). Figure IV-6 illustrates a
comparison of measured fine particle carbon concentrations versus
box model estimates.
Proportional Rollback Model
A rollback model is based on the simple assumption that source
impacts are directly proportional to emissions. A source's
contribution to measured ambient concentrations is calculated by
multiplying the measured concentrations by the ratio of that
source's emission rate to the total emissions rate of that
pollutant from all other sources in the airshed. Thus, absolute
pollutant concentrations are not predicted. Only the relative
contribution of the sources in the emission inventory and the
IV-69
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I
100
80
60
40
20
1979-1980 data
^Modeled
Apr Hay June July Aug Sept Oct Nov Dec Jan Feb Mar
MONTH OF SAMPLING PERIOD
Figure IV-6. Modeled vs Estimated Atmospheric Carbon
Medford. Oregon (1979-80)
Source: Rau (1981)
IV-70
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relative changes In concentrations over time are calculated. The
relative changes can be used In association with receptor modeling
results to estimate likely RWC Impacts In future years.
Holzworth Urban Model
Historical meteorology and urban size are used In the Holzworth
model to estimate the ratio of concentrations to emissions,
expressed as X/Q, where: X * ground level concentration of a
pollutant In air, and Q « the emissions rate of the pollutant from
a source(s). This rat^o can be used to calculate RWC Impacts by
multiplying the annual average normalized concentration (X/Q) by
the RWC emission rate (Holzworth, 1972). The principal
assumptions are that steady-state conditions prevail, emissions
occur at ground level and are uniformly distributed over the city,
emissions are non-reactive and emissions are uniformly distributed
within the mixing layer. Sources are treated as a continuous
series of Infinitely long cross-wind line sources. Values for
X/Q as a function of mixing height (H), wind speed (U) and
along-wlnd distance across the airshed (S) have been published by
Holzworth for cities 10 and 100 Km In size. Since the X/Q values
are presented In terms of frequency of occurrence, results
obtained with this model also represent the frequency of
occurrence with which the source Impacts can be expected to occur.
d. AREAS Model
AREAS Is an area source model which estimates annual average
pollutant concentrations at ground level In each of 400 grids
within a 20 by 20 grid area (Moore, 1978). Partlculate or carbon
monoxide emissions from low level dispersed sources can be modeled.
Input data Include the total emission rate within the study area
(mlcrograms per second), the fraction of the total emissions
within each of the 400 grids, and the grid size (meters). Two km
grid sizes are commonly used.
IV-71
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The model allows point source model to be used in an area source
mode. It does not employ meteorological data as inputs but
instead uses an array of 400 X/Q values (pollutant
concentration/emission rate from the source) to describe pollutant
behavior. These X/Q values may be derived from any point source
dispersion model to provide an output file (uu/m estimates) for
direct input to AREAS. For example, AIRDOS II - a Gaussian plume
model which estimates pollutant concentrations based on annual
average meteorological data has been used for this purpose (Moore,
1977).
Uniform annual-average meteorology across the grided area, and
uniformly distributed area source emissions of similar magnitude,
are assumed. Accordingly, results obtained from AREAS are only as
valid as these assumptions.
Dispersion Modeling Analysis
The extent to which a specific model may be suitable for RWC impact
assessment depends on the detail and accuracy of the database, the
meteorological and topographical complexity of the area to be studied,
the modeling resources available to the analyst, and the level of
confidence needed in modeling results. Generally, the greater the
degree of detail with which a model considers such factors as spatial
and temporal variability in emission and meteorological conditions,
the greater the ability of the model to evaluate source impacts under
a number of control strategy scenarios. A complete analysis may
require the application of a complex terrain model such as GRID.
However, the cost associated with the development of an appropriate
database may be difficult to justify, if a simple box model analysis
provides the level of confidence required by decision makers.
The principal steps in the dispersion modeling process are discussed
below:
a. Input Information
As a first step, the analyst should evaluate the availability,
quantity and quality of meteorological data, air quality data, and
emission inventory information within the airshed. If on-site
IV-7 2
-------
surface and upper air meteorological data are not available, an
evaluation of the applicability of data from the nearest National
Weather Service site should be made. The evaluation should
consider topographical features which may alter on-site wind
speeds and direction, the representativeness of upper level winds,
and potential differences in atmospheric stability. If possible,
a comparison of surface winds observed during a brief period in
the winter months at both sites should be completed.
Models such as GRID which require a large amount of detailed input
data cannot be applied to most airsheds without an intensive
period of database development. Assuming that the available data
are adequate to support models such as ISC, CDMQC, PAL or RAM, the
second step is to evaluate each model's treatment of area source
emissions, the importance of Including point and line sources in
the analysis, and the number of receptors to be modeled.
Consideration of each of these elements will be important in
selecting the appropriate model, should the screening model
analysis indicate a need for additional work.
b. Model Comparisons with Measured RWC Impacts
A limited number of studies have been published which compare
dispersion model predictions with direct measurements of RWC
impacts. This section reviews five such studies which compared
Chemical Mass Balance (CMB) measurements of RWC Impacts with
estimates from a variety of dispersion models, in locations In
Alabama, Tennessee and Oregon. Table IV-14 summarizes dispersion
model and CMB comparison data from these studies.
The Tennesee Valley Authority (TVA) conducted two studies of RWC
Impacts in Petersville, Alabama C&nboff et al, 1982, 1983) and one
In Nashville, Tennesee (Imhoff et al, 198A). The Petersville
studies both covered 10-day periods in February of 1981 and 1982,
respectively, and monitored at residential sites. CMB indicated
RWC accounted for most (80-90%) of the ambient fine particulate
levels, which TVA attributed mostly to woodstoves with only minor
contributions from fireplace emissions.
IV-7 3
-------
Airshed
Petersville, AL
Nashville, TN
Medford, OR
Portland, OR
Table Notes:
TABLE IV-14. Comparison of Dispersion Model and CMS
Estimates of RWC Impacts (ug/mj)
CMB (1) Rollback Holzworth
RWC Impacrt Model Model(2)
34.9 (3a)
65.1 (3b)
26.3 (4a)
117.0 (4b)
8.7 (5) 14.2 2.5
21.5 (6a)
5.8 (6b)
5.8 (7)
CDMQC
Model
7.8
19.4
6.5
ISCST
Model
23.7-28.9
65
5.5-7.7
GRID
Model
117
(1) Estimates of RWC impacts from chemical mass balance (CMB) analysis of fine
particulate (< 2.5-3.0 urn) samples;
(2) 50th percentile values
(3) From Imhoff et al (1982): a) 24 hour study period average, based on seven days
during February 2-14, 1981; b" highest 24 hour average RWC impact, February 6,
1981.
(4) From Imhoff et al (1983): a) 24 hour study period average during February 6-15,
1982, based on twenty consecutive 12 hour samples; b) maximum 12-hour average -
recorded 6 PM, February 13th to 6 AM, February 14, 1982.
(5) From Imhoff et al (1984); 24 hour study period average for the first quarter of
1982, also averaged over three monitoring sites, affording a generalized impact
for the metro area.
(6) From Core and Cox (1982) and Hanrahan 1981b); 24 hour average for winter
heating season (1979-80) at two Medford area sites: a) Medford Central Business
District; b) White City industrial area, eight miles from Medford.
(7) From Hanrahan (1981b); annual (1977) average RWC impacts at a residential site
(Flavel School). Range of values reflects the reported range of uncertainty in
CMB estimates. CMB versus GRID estimates at three other sites showed
comparable agreement.
IV-74
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The first Petersvllle study used several mobile vans to collect
air quality and meteorological data in and around a residential
area where RWC occurred. The study then compared CMB estimates to
PAL model estimates. PAL predicted higher 10-day average RWC
impacts, and maximum 24-hour average RWC impacts about 30-35%
higher than (CMB estimates (Table IV-14), and overpredicted total
fine particulate impacts by a factor of two.
The second Petersville study was conducted at two fixed sites
(residential neighborhood and rural background sites). This study
compared CMB estimates primarily to ISCST model estimates, with
comparison also to a PAL model estimate for the single 12-hour
period of maximum measured RWC impact. For wind speeds 1 m/sec,
10-day average RWC impacts estimated by ISCST were within 10% of
CMB estimates, although the model underpredicted the maximum
(12-hour) RWC impact measured by a factor of two (Table IV-14).
Despite close agreement between CMB and PAL estimates for the
maximum 12-hour RWC impact (Table IV-14), and greater ease in
using PAL versus ISCST, the authors concluded that the ISCST model
yielded more realistic X/Q values (concentration/emissions) than
PAL for area sources like RWC. This was because PAL estimated X/Q
values 2-3 times higher than did ISCST for stable, low wind speed
conditions considered more representative of maxlnmm RWC impact
situations, based on work by TVA and others. For example, TVA
cited a previous comparison of ISCST and PAL models, which found
that at a distance of 250 meters, PAL estimates were a factor of
three higher than ISCST estimates during D stability and 3.5
meter/second wind speed for surface emissions from an area source
50 meters on a side (Gschwandtner, et al, 1982).
Figures IV-7 and IV-8 illustrate CMB-estimates (o) versus maximum
and minimum ISCST-calculated RWC impacts for the following two
wind speed cases: a) measured wind speeds, except using 1
meter/second as a minimum wind speed value, consistent with user
guidelines (Figure IV-7), and; b) measured wind speeds, with a
0.34 meter/second minimum wind speed, which was the minimum
detectable by the meteorological equipment used. The modeled
*
concentrations increased significantly for calm nights, when RWC
IV-75
-------
00
a.
e
o
(U
u
o
o
3
U
1-1
to
oc
a.
u
I
200-
160--
120-.
80-
40-
0-
CMB Estimates
Max. ISCST
Min. ISCST
1
6 7 8 9 10 11 12 13 14 15 16 17
DATE (February)
Figure IV-7. CMB-Estimated vs ISCST-Estimated RWC
Imp acts (1 m/s Minimum Wind Speed)
200 -
160 - .
120 - .
80 -
40 - •
o - CMS Estimates
— - Max. ISCST
— - Min. ISCST
I -
6 7 8 9 10 11 12 13 14 15 16 17
DATE (February)
Figure IV-8. CMB-Estimated vs ISCST-Estimated RWC
Impacts (0.34 m/s Minimum Wind
Speed)
Source: Imhoff et al, 1983
IV-7 6
-------
impacts estimated by CMB were highest, resulting in ISCST
estimates consistently higher than CMB estimates (Figure IV-8).
TVA researchers noted that using Gaussian models with dispersion
coefficients based on Pasquill's experiments, it is difficult to
assess how representative calculated concentrations are at wind
speeds less than one meter/second. Unfortunately, these are
typically the conditions under which maximum CMB estimates of RWC
impacts are observed (Imhoff et al, 1983).
Another TVA study compared CMB estimates of RWC impacts in the
Nashville, Tenneseee metropolitan area during the first quarter of
1983 (Imhoff et al, 1984) with estimates from three dispersion
models - CDMQC, rollback and Holzworth. RWC was estimated to
account for 22-66% of fine particulate ( < 3um) levels and 15-281.
The maximum 24-hour RWC impact measured was 51 ug/m .
CDMQC season average estimates were quite consistent with CMB
3
estimates (7.8 versus 8.7 ug/m respectively; Table IV-12).
Rollback model estimates overestimated RWC impacts, while
Holzworth model estimates underestimated RWC impcts by a factor of
three to four. The latter are 50th percentile estimates, and
hence not strictly comparable to the others.
CDMQC estimates of RWC impacts averaged over an entire heating
season (1979-80) also agreed well with CMB estimates at several
sites in the Medford, Oregon area (Core and Cox, 1982; Hanrahan
(1981b). Annual (1977) average RWC impacts estimated by CMB
methods at four sites in Portland, Oregon also agreed well with
GRID-model estimates (Hanrahan, 1981b). In both Oregon studies
however, the CMB estimates and other information were used to
refine emission inventories for RWC and other particulate sources,
in order to achieve as close agreement as possible between the CMB
and dispersion modeling estimates. Accordingly, these comparisons
represent optimized cases of of dispersion model versus CMB
estimates of RWC impacts.
IV-7 7
-------
Overall, these studies suggest that dispersion modeling is capable
of estimating RWC impacts in good agreement with CMB estimates.
However, it is also clear that the selection of dispersion
model(s) to be used, and the model's capability to similute stable
meteorological conditions, can have a large effect on the RWC
impacts calculated.
The limited studies cited above indicate that ISCST and CDMQC,
GRID, and even PAL can estimate RWC impacts consistent with CMB
estimates. Other models not tested in these studies may also
yield close agreement for RWC analysis - e.g., RAM, box models,
and others. Table IV-15 summarizes some of the principal
advantages and disadvantages of several dispersion models that
have been or could be used in RWC assessment studies.
EPA must approve any dispersion modeling of RWC impacts undertaken
for regulatory application - e.g., SIP development. For models
not already recommended for particular applications in EPA
modeling guidance, this could require a site specific performance
evaluation in accordance with EPA dispersion model evaluation
procedures (U.S. EPA 1984e).
Analysis of Background Concentration
Development of RWC control strategies using dispersion models
requires that background concentrations of woodsmoke transported
into the airshed be considered. Such estimates are developed
through an analysis of ambient air quality data obtained from an
upwind remote (rural) site that is unaffected by emissions within
the study area. Winter season particulate data obtained from the
background site should be screened to identify days on which the
site was upwind of the study area, and the wind persistence (ratio
of vector averaged wind to average wind speed) was greater than
0.7 over a 24 hour period, corresponding to an hourly wind
direction deviation of 45 . CMB model-estimated RWC impact data
are preferred but fine particle mass data (< 2.5 urn) can also
IV-7 8
-------
TABLE IV-15.
Dispersion Model Advantages and Disadvantages
for Applications to RWC
RAM
ISCST
CDMQC
GRID
Box
Advantages
Treats point area and line
sources in same simulation
Relatively easy and
to run. Not for seasonal/annual
averages
Modeler can extract worst
case meteorology from
sequential data via RAMMET
Best area area source treatment
among Gaussian models. Area
source may be treated as
volume sources of specified
height
Variable area source size.
Worst case meteorology can be
extracted by modeler from
sequential data via CRSMET
Acceptable area source treatment
has been achieved for airshed
with heavy RWC impacts (Hanrahan,
198Ib)
STAR meteorological data
available for a wide number
of locations.
Best meteorological treatment
of area sources.
Wind flow fields can become
curvilinear near terrain.
Simple and inexpensive to use.
Adaptability to simulate
complex terrain may make
box models more practicable
for such cases than more complex
models
Disadvantages
Simulation area is
relatively small - e.g. a
portion of the metropolitan
area. Assumes flat terrain.
Tends to overpredict RWC
impacts under low wind
speed, stable conditions in
model intercomparison
analysis (Imhoff, 1983)
Assumes flat terrain
No terrain allowed which
is greater than stack weight
Cannot simulate volume
sources, assumes flat
terrain.
Requires statistical
inference to estimate worst
case 24-hour impacts ,which
is no longer recommended by
EPA for regulatory
applications.
Simulation costs are high
Large meteorological data
base input required.
Size of the box is often
difficult to determine and
a critical parameter in
Low level of credibility
IV-79
-------
be used. TSP mass concentrations should not be directly used.
However, a useful estimate of woodsmoke background concentrations
can be obtained from TSP filters, If they are analyzed for organic
(preferred) or total carbon.
d. Model Evaluation
Dispersion model evaluation studies, such as those described
above, can greatly Increase the analyst's level of confidence In
the model predictions. Model evaluation studies can be conducted
using fine particle mass concentration, ambient aerosol organic
carbon data, Chemical Mass Balance estimates or other Indicators
of RWC Impacts described In Section IV. C.
Anderson et al, (1984), Core and Cox (1982), and Hanrahan (1981b)
have each described similar protocols for evaluating dispersion
models using receptor model estimates of source Impacts. Briefly,
the process requires comparison of same-day receptor and
dispersion model RWC Impacts for the same sampling site. Also
required are Identification of discrepancies, Isolation of
assumptions or database errors causing the descrepancy, error
correction, and final modeling. The benefits derived from this
procedure, In terms of Increased confidence In the final RWC
Impact assessment, are Invaluable during development of control
strategy programs.
e. Analysis of Results
Upon completion of the model validation step, dispersion model
predictions of 24 hour, seasonal or annual concentration can be
conducted. Spatial distributions within the airshed can now be
predicted, by running model simulations for different locations.
Projection of future air quality Impacts of RWC emissions can be
simulated, and control strategy options can be evaluated, using
the model.
IV-80
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f. Modeling Carbon Monoxide Concentrations
Upon completion of the particulate model validation step, RWC CO,
B(a)P or oxides of nitrogen (NO ) emission inventories can also
be input to the model to estimate ambient impacts from these
pollutants. Optionally, a model postprocessor program can be used
to estimate contributions of these pollutants by multiplying the
concentrations of RWC particulate impacts by the CO or NO
relative emission strengths (e.g. CO/ PM) , assuming no
atmospheric transformation. This requires that the initial model
runs be made with unit emission rates. Since CO emissions may
principally be transportation oriented, development of a suitable
CO ambient air quality database for model validation may be
difficult. Accordingly, validation of the model using particulate
emission inventories is suggested as an initial step. ISCST
modeling of CO and NO concentrations in Petersville, Alabama
indicated that 3.6Z and 21% of the NO and CO ambient
x
concentrations were related to woodstove and fireplace emissions,
respectively (Imhoff et al, 1983).
g. Other Airshed Applications
In addition to the Nashville, Petersville, Medford and Portland
dispersion modeling studies noted above, CDMQC modeling of RWC
particulate and CO emissions are being conducted by the State of
Colorado for Denver, Fort Collins and Grand Junction. Simple Box
models have been applied in Bangor, Maine (Anderson et al, 1984)
and Vail, Colorado (Meyer, 1981).
The State of Vermont has used the Texas Climatological Model TACB
(1980) to predict seasonal average RWC impacts in Waterbury,
Vermont, using emission inventory data developed through household
surveys and local meteorological data. Modeling results were not
verified against ambient measurements. The relative results among
source groups, however, were consistent with the emission
inventory. They were not, however, considered conclusive because
IV-81
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of complex terrain and windfield limitations. Hourly impacts
predicted by the Texas Episodic Model TACB (1979) indicated RWC
impacts of 60-120 ug/m under one meter per second winds speeds
and 20 meter mixing heights that occur during calm, clear and cold
winter mornings.
h. Use of Dispersion Modeling To Evaluate RWC Control Measures
A major application of dispersion modeling to RWC analysis is in
simulation of the potential effectiveness of candidate RWC
emissions control measures in reducing ambient pollutant levels
attributable to RWC. This topic is discussed in section V.D.2 of
this document.
Stepwise Approach to Characterizing RWC Ambient Impacts
This section describes three different hypothetical levels of effort that
could be undertaken to estimate RWC ambient impacts, and their approximate
costs. This is intended to illustrate the types of measurements and
analyses that could be conducted with very modest study resources, and
additional information that could be obtained with additional funds. The
cost estimates are general approximations intended only as guidelines, to
assist localities in considering site specific studies. Localities
considering initiating a study to quantify RWC (or other particulate)
impacts, should also consider EPA guidance on modeling and monitoring
relative to national particulate standards, as well as the level of study
effort needed to answer local questions, and achievable with available
resources, as discussed in this section.
After EPA's proposed fine particulate (^1^) National Ambient Air
Quality Standard (U.S. EPA, 1984g) is promulgated in final form, the
resulting development of particulate State Implementation Plans (SIPs)
will provide an opportunity to use many of the monitoring and modeling
methods described in this document. EPA's proposed PM. SIP development
guidance (U.S. EPA, 1984f) discusses recommended modeling approaches for
demonstrating the adequacy of any control strategies proposed for
attainment and maintenance of PM,0 standards.
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This PM10 modeling guidance Indicates that model preferences depend upon
such factors as the type of monitoring data available (ISP versus fine
partlculate data), and the time scale (annual or 24 hour) of the
non-attainment problem. Both receptor and dispersion modeling are
discussed,' and their joint use Is recommended for both annual and 24 hour
PM.. source apportionment. Any RWC Impact assessment study which Is
Intended to support SI? development should be planned In light of the
appropriate SIP guidance, so that field monitoring and sample analysis can
support any subsequent modeling efforts cost-effectively. Also, since any
dispersion or receptor modeling used to demonstrate the attainment/
maintenance of ambient standards In SIPs must be approved by EPA., any
models used' for this purpose should either already be sanctioned by EPA In
Its SIP Guidance (e.g., see U.S. EPA, 1984f, for PM1Q modeling guidance),
or be evaluated In consultation with EPA using EPA's model evaluation
*
procedures (U.S. EPA, 1984e).
Study resources available must be matched with the program objectives and
the degree of confidence desired In the conclusions. In general, If a high
level of confidence Is required, more of the program resources must be
directed toward the completion of several Independent Impact assessment
methods, Instead of reliance on any single source apportionment method.
Regardless of the .specific modeling approach adopted, several of the
qualitative methods described above should be used and compared, to assure
the reasonableness of results.
The three levels of effort described below emphasize the Chemical Mass
Balance (CMB) receptor modeling approach for several reasons, but this does
not Imply that dispersion modeling Is not advisable especially If a
validated dispersion model is already available for the study area. CMB
receptor modeling Is emphasized here because of its strengths in diagnosing
RWC impacts specifically, using a limited number of field monitoring
samples, and especially In complex terrain situations where dispersion
modeling uncertainties are greatest.
IV-83
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CMB methods lead themselves well to preliminary screening assessments as
well as to sophisticated aerosol characterization studies. CMB findings
can be used to improve dispersion models - e.g., by detecting deficiencies
in their emissions data base for specific sources. Dispersion models may
then be preferred tools for assessing RWC impacts in locations which have
no monitoring data, or for estimating how emission control strategies
might reduce future ambient pollutant levels. However, the costs to
develop and apply dispersion models is not included in the three levels of
effort described below, because CMB approaches alone can generally
quantify RWC ambient impacts with less uncertainty and less initial cost
than dispersion modeling approaches.
Three levels of RWC impact assessment, at increasing levels of
sophistication, are proposed as follows:
• Level I; semiquantitative approach based on evaluation of existing
data and analysis of hi-vol (TSP) samples.
• Level II; quantitative program employing at least three monitoring
sites followed by data analysis.
• Level III; Intensive monitoring program involving at least five sites
utilizing several independent monitoring and analysis approaches to
RWC assessment.
Each level of analysis requires more resources than the preceeding one but
provides results of greater reliability. In the following discussion, a
four-month field program during the winter season is assumed in all
cases. Analysts interested in the Level II and III programs should first
complete an evaluation of existing air quality and emission inventory
data, as outlined in the Level I program.
A single program protocol and cost estimate for each level of effort
described here is not appropriate or possible. Analysts must use
judgement and make appropriate changes for their locations, meteorological
IV-84
-------
conditions, and study objectives using the following Information as
guidelines. General field monitoring and design considerations for source
apportionment studies are discussed In Section IV.B, Gordon et al, (1984),
and the EPA. Technical Series on Receptor Modeling Volumes I to V (EPA
198la, 198Ib, 1983a, 1983b, and 1984).
Table IV-16 summarizes the approximate resource requirements of each
program design level for labor, sample analysis, data analysis and
computer costs. The program cost estimates presented In this table assume
that air monitoring technician labor and air sampling equipment are
available during the field monitoring phase of the project. Estimates for
technician and analyst labor are estimated at 37 and $13 per hour
exclusive of overhead, administrative and profit costs. Adjustments to
the estimates shown should be made, If needed, to reflect other labor or
non-direct rates. If adequate monitoring equipment Is not available, It
can often be borrowed from other governmental agencies or leased from
private sources. Since capital costs for equipment are a major expense In
any field study — and considering the short term nature of most field
programs — purchase of the monitoring equipment Is often difficult to
justify unless a need for a continuous program can be argued.
Table IV-17 provides a listing of the air sampling equipment requirements
of the Level I, II and III programs. In light of EPA's current proposals
for a size specific partlculate standard, dlchotomus sampling with 2.5 and
10 micron (urn) cut points Is Included for Levels II and III. Hlvol TSP
sampling at one or more of the Level II or III sites may be Included If
the analyst wishes to evaluate the impact of RWC emission to TSP.
1. level I; Semi-quantitative Study Design
Level I analysis Is the first step towards estimating RWC ambient
Impact level for an airshed. It is recommended as a screening method
\*iere the extent of RWC impact is not known. The Level I program
requires minimum resources while providing a first-cut approximation
of RWC Impacts. It utilizes existing ambient air quality data, source
IV-85
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TABLE IV-16. Approximate Program Costa
Program
Level
Level I
Level II
Level III
Direct Labor
Analyst Technician
$ 1,800
$ 4,000
$10,000
a
$ 5
$10
200
,500
,000
Analytical Computer
Costs (a) Costs
$ 4,000
$15,000
$50,000
minimal
$1,500
$5,000
Total Program
Costs (b)
$ 6,000
$25,000
$75 ,000
(a) Unit costs noted in Table IV-6.
(b) Approximate costs in 1984 dollars, exclusive of air sampling instruments
and some specialty analyses, e.g. for certain toxic air contaminants such as
benzo(a)pyrene, B(a)P.
TABLE IV-17. Air Sampling Equipment Requirements
Program
Level
I
II
III
HiVol
TSP
1
none
none
Dichotomous
Sampler s (a)
none
6 (c)
5
Sequential
Sampler (b)
none
0 to 3
5
Int(d)
Neph.
1
1
1 (minimum)
Meter ological(e)
1
1
Other (f)
14C
"c
CH3C
1,
14C,
(a) Two samplers required per site; one with membrane and one with
quartz/glassifier filter.
(b) Equipped with 2.5 urn inlet; dual port configuration for simultaneous glass
fiber/Membrane filter substrates for XRF and carbon analysis.
(c) Only 3 samplers required (1 per site) if sequential samplers are also
used.
(d) Int. Neph - Integrating Nephlometer.
(e) temperature, wind speed; wind direction.
(f) Other sampling includes specialty sampling equipment discussed in Section
IV-B.
IV-86
-------
profile information, planned and/or historical TSP hi-vol samples, and
local emission inventory data. The design is based on samples taken
on a sixth day sampling schedule at one or more monitoring sites over
a four-month winter period. Samples selected for analysis should
include those most likely to contain maximum RWC impacts, including
samples from residential areas if possible. Archived filters from
previous winter periods may be used for this evaluation.
The twenty-four TSP samples collected during this period should be
analyzed by atomic absorption for Iron (Fe) and Potassium (K).
Elemental and organic carbon may also be completed to provide a data
set for enrichment factor analysis using Fe as a crustal reference
element. Time series and RWC impact analysis using organic carbon as
a tracer can also be completed (Section IV. C). To determine the
validity of organic carbon as an RWC tracer, optical microscopy
analysis of five selected worst case filters should be completed. The
microscopy data can be used to determine the extent of coarse mode
carbonaceous particles (leaf fragments, etc.) on the filters. The K
concentrations can be used to estimate RWC impact using a simple
linear regression model (Section IV.C).
If it can be shown through chemical emission inventory that RWC is the
predominant source of organic carbon (OC), an upper-limit estimate of
RWC impact can be obtained by subtracting from the measured OC the
amount of coarse mode carbonaceous particles identified by
microscopy. Radiocarbon analysis of the same five selected worst case
filters can also be used as an independent measure of RWC impact, if
non-RWC modern carbon sources are not present in the airshed (e.g.
field residue burning, forest fires, etc.)
Integrating nephelometer measurements can be and have been, used to
document RWC impacts. Since RWC emissions are primarily fine
partlculates, elevated nephelometer readings during typical heating
periods (especially in residential neighborhoods) can often be
attributed to RWC emissions for an RWC-dominated site. The organic
IV-87
-------
carbon to TSP ratio can be correlated with scattering coefficient
(bscat) measurements to evaluate common variablility. The organic
carbon measurements can be used to estimate the extent of RWC impact,
which can also be tracked with bscat measurements on a real time basis
(Harris 1983, Tombleson et al, 1983). Carbon thermogram analysis can
also provide another qualitative indicator of the presence of
woodsmoke aerosols. Example applications and explanations of these
methods are covered in Section IV. C. 4.
The principal limitation of the Level I approach is related to the use
of hi-vol TSP filters as the sample collection medium. If RWC impacts
are marginal, the organic carbon (OC) blank of the glass fiber filters
may be significant. In addition, the presence of coarse mode
carbonaceous particles from "modern carbon" sources (other than RWC)
can cause the radiocarbon RWC estimates to be incorrect,
overestimating woodsmoke impacts. As a result, the findings of a
Level I analysis should be considered tentative pending completion of
a field program in which fine particle samples can be obtained and a
detailed data analysis can be conducted. Results of Level I analysis
can be very useful In guiding level II and III program designs.
2. Level II; Quantitative Study Design
The Level II design incorporates three monitoring sites operated daily
(12 to 24 hour samples) over a four-month period. The analytical
costs noted in Table IV-16 include gravimetric analysis for about 700
fine ( <2.5 urn) and coarse mode ( < 10 urn) filters. From this set of
samples, 20 to 30 days are selected for analysis by X-Ray
fluroescence, and for elemental/organic carbon and ions. Resources
for radiocarbon analysis of three to five worst case filters, and
computer costs for completion of 60 Chemical Mass Balance (CMB)
calculations, are also included. Although the coarse mode samples are
not included in the analytical protocol, the gravimetric data from the
IV-88
-------
fine and coarse mode filters provide a basis for estimating RWC
impacts on PM10 levels. Direct labor costs include two months of
analyst time for data analysis and reporting tasks and over four
months of technician's time to service the sampling sites.
locations for sampling sites Include: one upwind (background) and two
downwind sites where maximum concentrations are anticipated on the
basis of preliminary screening, modeling, or monitoring sites
measuring TSP violations. Site location and field monitoring design
considerations are covered in Section IV. B. Dichotomous samplers are
recommended for Level II analysis to provide Improved source
resolution (EPA 198la) and to assertain RWC impact on M.Q. Shorter
sampling duration can provide better source resolution if adequate
sample size for analytical accuracy can be assured. Some of the
design parameters may be varied according to the results of Level I
efforts, project objectives and resources (Table 17-17).
The principal receptor modeling method used in the Level II analysis
is Chemical Mass Balance (CMB) or other multivariate analysis using
source profile Information from the literature. The CMB analysis can
be validated against radiocarbon analysis of 5 samples and correlated
to scattering coefficient measurements (for an RWC dominated site),
carbon thermogram patterns and chemical emission Inventory/enrichment
factor analysis (Section IV. C. 4) .
In contrast to the Level I analysis, the Level II effort should
provide a higher level of confidence in the conclusions, since state
of-the-art monitoring, analytical and modeling methods are used. In
addition, the measurements made at the background and downwind or
nonattainment sites provide useful Information for determining the
amount of "local" versus "transported" RWC emission impacts, as well
as a measure of the importance of RWC impacts to regulatory programs.
For example, if RWC aerosols are measured in substantial concentration
at the upwind site, they would need to be subtracted from the downwind
IV-89
-------
measurements to evaluate local RWC contribution. This background site
measurements are required to estimate the extent and nature of air
pollution transported into the airshed.
The principal limitation of level II analysis, however, is the use of
literature-derived source profile data sets. Inclusion of an
additional $3000-35000 in source testing and analytical testing would
correct this deficiency. This is done in Level III analysis, as
described below.
3. Level lilt Optimum Program Design
The Level III program incorporates daily eight to 24 hour sampling at
five monitoring sites with complete fine particle filter analysis
(XRF, carbon and ions) for 20 selected days. An intensive 12 day
sampling period in which short term samples are collected at each of
the five sites should be incorporated, if only 24 hour samples are
collected during the rest of the program. Since most of RWC
contribution is in the fine mass fraction, filter analysis is
generally restricted to this fraction. However, coarse particle mass
data is obtained to provide an estimate of RWC impacts on EM-.-
concentrations. Specialized sampling and/or analyses which are
described in Section IV. B and are recommended for Level III.
• Methyl chloride (CH,C1) measurements - Section IV.B. 4
• Particulate radiocarbon measurements - Section IV.B.4
• Radiocarbon measurements on CO to assess RWC CO impacts - Section
IV. B. 4
Inclusion of these special purpose sampling methods would provide
independent verification of RWC impact, and result in conclusions with
a higher level of confidence.
The source composition profile for RWC is obtained for the airshed by
stack sampling (preferably using dilution sampling methods). Dilution
IV-90
-------
sampling is source sampling with dilution air, to simulate the
atmospheric history stack samples would face prior to reaching
receptor sites and ambient sampling. This will assure a
representative source profile for the airshed. Dilution sampling is
recommended to simulate the real world situation and to collect
condensable species. The stack samples should be collected in size
fractions similar to those collected at ambient monitoring sites.
Further details on stack sampling methods are found in Harris, (1985)
and Gordon et al, (1984).
The importance of well thought out sampling procedures is shown by Rau
and Huntzicker (1985). Rau and Huntzicker showed that RWC profiles
are very dependent on the combustion temperature. A composite profile
for the complete burn cycle of RWC appliances tested should be
obtained for data analysis.
Radiocarbon analysis of five selected samples, 12 days of
methylchloride tracer sampling, and computer resources to complete 200
CMB calculations are included in the estimated Level III costs in
Table IV-16. The Level III direct labor estimate includes 230 hours
of analyst time and 800 hours of technician's time to complete the
project design, field sampling, quality assurance, sample selection,
data analysis, reporting and administrative tasks required. Analytical
costs include the development of RWC source profiles from woodstoves,
and fireplaces, as well as several other major sources in the
airshed. The data base developed by such a program can be used for
enrichment factor, CMB, multlvariate and time series analysis receptor
modeling as discussed in section IV. C.4 of this document.
A
Inclusion of C monitoring along with methylchloride to supplement
particulate measurements provides three Independent methods of RWC
Impact assessment. The principal disadvantage of level III analysis
is its cost. The availability of dichotomous (or sequential)
samplers, integrating nephlometer(s), a methylchloride sampling
train(s), and a radiocarbon sampling train(s) (Lavaggi et al, 1984)
IV-91
-------
may also pose problems. Depending on the Importance of RWC
contribution to ambient air quality and knowing the Importance of SIP
development process, the cost of level III analysis may be justified
In many airsheds. The importance of precise RWC estimates Is further
justified by the presence of potentially carcinogenic compounds in the
RWC emissions (Section IV.B.5.)
Since it is now recognized that RWC emissions are a major source of
polycyclic matter (Radian, 1983), and contain toxic compounds
including a variety of mutagenic compounds (Kamens et al, 1984;
Lewtas, 1982), an intensive study at Level III could Include:
measurements of B(a)P and possibly other specific POMs.
EPA's integrated Air Cancer Project has conducted several field
studies to evaluate the Importance of RWC contributions to the
mutagenic activity of particulate samples. The results of these
studies should be considered In Level III RWC study designs.
IV-92
-------
V. RESIDENTIAL WOOD COMBUSTION CONTROL STRATEGIES
A. Introduction
In this section, we discuss strategies for reducing pollutant emissions
from Residential Wood Combustion (RWC), in order to minimize its adverse
impact on ambient air quality.
This discussion, as has most research to date on RWC, primarily addresses
particulate impacts, and how these might be reduced by specific control
measures. Other RWC emissions of concern include Polycyclic Organic
Matter (POM), due to Its potential toxlcity, and Carbon Monoxide (CO). As
a first approximation, it can generally be assumed that RWC control
measures which reduce partlculate emissions will also reduce CO and POM
emissions, although not necessarily proportionately.
Section III.B of this report discussed factors which Influence the
magnitude of RWC emissions - e.g., burn rate, wood moisture content, and
appliance design, etc. Improving the control of one or more of these
types of factors Is usually the technical basis for RWC control
strategies. Another primary influence is public response. The degree of
public understanding of, and cooperation with, RWC control measures can
greatly Influence their effectiveness. Another determinant of RWC control
strategy design is the relative contribution of woodstoves vs fireplaces
to local air pollution problems. Fireplace controls have received much
less attention than stove measures, but fireplaces can account for a
majority of local RWC emissions (e.g., In Colorado; see Section V. C.3
below).
Section V. B discusses potential RWC control strategies which states and
localities could adopt. It does so In general terms, drawing upon
available generic analyses of the benefits and costs of different types of
approaches.
V-l
-------
Section V. C describes the leading examples of RWC control strategies
implemented or proposed to date. It focuses on the states and localities
listed below, because they have adopted or proposed the most unique RWC
control measures. They also have more information, on the effectiveness of
their RWC control measures, including air quality benefits in some cases:
• Oregon
- Medford
Statewide Woodstove Certification Program
• Montana
- Missoula
• Colorado
- Ski Communities
State Level RWC Control Measures
• Alaska (Juneau)
• Nevada (Reno)
Example regulations for each of these states and localities are included
in Appendix B.
B. Potential RWC Control Strategies
Possible RWC control measures, which state or local air pollution control
agencies could use to minimize RWC emissions, are reviewed and discussed
in this section. Strengths, weaknesses, costs and benefits, are discussed
for a variety of possible measures in general terms. This provides a
context for the subsequent discussion of actual control strategies adopted
or proposed by specific states or localities, in Section V.C.
While many reports and papers have mentioned or discussed RWC control
measures, few have focused primarily on this, and only one has attempted a
comprehensive and quantitative comparison of a full range of control
options. Greene and Tombleson (1981) reviewed potential approaches for
RWC control measures, and their strengths and weaknesses. Mors et al,
(1981) reviewed current federal laws to discuss legal bases (or lack
thereof) for controlling RWC emissions.
V-2
-------
Grotheer (1984) reviewed leading examples of actual RWC control measures
adopted or proposed, and discussed their projected benefits and costs. He
concluded that a variety of site-specific factors, including local public
acceptance, often determine the choice and ultimate effectiveness of RWC
control measures for any particular locality.
Only one published study to date has attempted a comprehensive and
quantitative evaluation and ranking of a full range of RWC control options
(U.S. EPA., 1984b, Task 6). The rest of this section draws primarily on
this study's findings and conclusions.
Seventy-five different RWC control strategy elements were Initially
evaluated in this study. These were based on a literature review of
control measures applied to RWC (or similar combustion sources) throughout
the world, and any other potentially feasible control actions. A
Keppner-Tregoe evaluation and ranking system was used to identify the most
promising RWC control measures (Keppner and Tregoe, 1965). It utilized
criteria designed to reflect attributes desired in an effective RWC
control strategy.
The criteria used in the Keppner-Tregoe analysis for scoring and ranking
strategy elements are summarized in Table V-l. Potential RWC control
measures which did not meet one of the "MUST criteria" were not considered
further. Those which passed this initial screening were scored from one
to ten, based on how well they satisfied each of the twelve "WANT
criteria". The twelve criteria were also weighted to indicate the
relative importance assigned to them in this study. The resulting overall
scores determined a ranking for all of the RWC controls initially
considered.
The weight factors used in this study reflected the perception of the
study authors about the relative effectiveness of actions or policies
related ta each criteria in reducing RWC particulate emissions. The
authors point out that the weights assigned do not reflect public policy
preferences of theirs or of any agency. They are an element called for In
the Keppner-Tregoe analysis. The weights assigned could be changed by
other analysts.
V-3
-------
TABLE V-l. Criteria and Weight Factors Used in Keppner-Tregoe Analysis
CRITERIA
MUST Criteria
1. Reduce air pollution impacts from RWC
2. Meet legal requirements
3. Widely applicable to RWC equipment or
operating practices
4. Must not increase safety hazard
5. Can be implemented within five years,
unless long-term benefits great
WEIGHT FACTOR*
Mandatory
Mandatory
Mandatory
Mandatory
Mandatory
WANT Criteria
1. Reduce average RWC emissions/household
2. Reduce number of RWC households
3. Widely applicable
4. Maximum public acceptance
5. Discourage worst appliances/practices
6. Minimum consumer cost
7. Uses proven technology
8. Minimum circumvention of control measure possible
9. Maximum agency administrative feasibility
10. Encourages innovative technology
11. Minimum free market Interference
12. Promotes conservation/use of renewable resources
(except wood)
13
13
10
9
9
6
5
4
3
2
2
1
* These weight factors were calculated using an analytic tool called "paired
comparison'
Source: U.S. EPA (1984b; Task 6)
V-4
-------
Based on this Initial evaluation, the most promising (highest ranked)
measures were categorized Into a list of generic approaches for reducing
RWC emissions, which Is shown In Table V-2. This list Is comprehensive In
several ways.
First, all of the major approaches available to reduce RWC emissions are
represented - I.e., reducing wood usage, or Improving new or existing wood
burning devices, or improving the way people operate such devices. Table
V-2 also covers the main types of RWC control measures actually adopted or
proposed to date by states or localities. It also includes leading
examples of the means by which RWC control strategies can be implemented -
i.e., by imposing regulatory requirements, by offering economic Incentives
or subsidies, and by public education or technology transfer. The RWC
control measures In Table V-2 cover both stoves and fireplaces. For each
of the generic approaches In Table V-2, the authors estimated the
potential reductions achievable (if any) in RWC partlculate emissions.
Their findings are summarized in Table V-3. To address strategies whose
benefits accumulate over a period of years - e.g., weatherIzation, or
woodstove testing/certification - emissions reductions estimates were
projected through the year 2000. The estimates In Table V-3 required many
assumptions and hypotheses, because sufficient experimental data or
knowledge did not exist for many key variables. Extensive literature
review and discussions with leading researchers were used to formulate
these assumptions, which were documented in detail. Nevertheless, the
emissions estimates in Table V-3 should be viewed as speculative.
For example, this study preceded the development of a statewide woodstove
testing and certification program in Oregon. Oregon subsequently
estimated that partlculate emissions reductions attributable to a
statewide, mandatory certification program would be 50-75% over a 10-20
year period (see section V. C.l.b), In contrast to the 30% shown In Table
V-3. This is neither surprising nor inconsistent, given the differences
in methods, assumptions and data available when each estimate was made.
The generic analysis described In this section (U.S. EPA, 1984b; Task 6)
rated woodstove certification as the most effective control measure In
reducing partlculate emissions, but only estimated a 30% reduction. This
V-5
-------
TABLE V-2. Generic Approaches to Reducing RWC Partlculate Emissions
A. Improving Burning Unit Design
1. Improved design of new stoves
a. Testing of woodstoves/furnaces, and certification of compliance
with an established emission limit, as a prerequisite for allowed
sales
b. Testing/certification as a prerequisite of stove furnaces sales,
plus a financial Incentive (33% tax credit) to buy the cleaner
(certified) stoves
c. Testing/certification as a basis for mandatory labelling of all
stoves/furnaces sold, which specifies their efficiency and
emissions performance
d. Testing/certification as a basis for mandatory labelling, plus the
33% tax credit for clean units
2. Modification of Installed stoves/furnaces, Including;
a. Air inlet modifications
b. Insertion of firebrick In stove box
c. Fans to improve heat transfer
d. Add-on particulate control devices:
1. Steel wool mesh filter
2. Catalytic afterburner
3. Improved design of add-on devices for fireplaces
a. Under fire air
b. Electrostatic precipltator
c. Glass doors
B. Reducing Wood Usage
1. Reducing home heating requirements
a. Weatherlzation
b. Reducing stove charge size
2. Improving wood fuel quality
a. Selection of wood with higher heating value
b. Moisture control (seasoning)
3. Direct restrictions of wood usage
a. Episode controls
b. Emission density zoning
C. Improving RWC Operating Practices
1. Initial selection of burning units - sizing
2. Operating technique modifications
a. Discouraging airtight stove operation
b. Charging larger pieces of wood
3. Periodic inspection of RWC equipment
Source: U.S. EPA (I984b; Task 6)
V-6
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was primarily because it assuaed higher average, emissions rates for
certified stoves, based on limited test data available at the time, than
the eventual Oregon standard. Oregon's subsequent estimates had much more
test data and other information to draw on, and hence should be much more
repesentative of Oregon's program potential.
The same general caveat applies to the emissions reduction potential
estimated for any of the other RWC control measures in Table V-3. Those
estimates involved assumptions deemed reasonable at the time, based on
limited test data, and discussions with experts. The main value of the
analysis as a whole lies in comparing a wide range of control measures in
a systematic fashion, and evaluating their relative strengths and
weaknesses.
The generic approaches estimated to achieve the greatest reductions in RWC
emissions included: a) all of the stove testing and certification
approaches intended to improve new stove designs; b) weatherization; c)
properly sizing stoves to the space to be heated; d) encouraging use of
larger pieces of firewood; and, e) wood moisture controls. Episode
controls were effective on worst case days, but their effect on seasonal
or annual average TSP levels were unknown.
Drawing upon the foregoing assessments, fifteen generic RWC control
strategies were selected (Table V-4) for evaluation and ranking, using the
Keppner-Tregoe process. These fifteen strategies included the highest
rated control measures from the preliminary analyses described above, as
well as leading examples of RWC controls actually implemented somewhere.
The intent was to systematically and quantitatively compare a
comprehensive group of the most practical and promising RWC control
measures which states and localities could implement.
Table V-5 summarizes the results of the Keppner-Tregoe analysis and
ranking of the fifteen strategies. It contains a brief description of
each strategy, its score/ranking, and notable major advantages and
disadvantages. Table V-6 shows the fifteen strategies in their final
V-9
-------
TABLE V-4.
Final Fifteen RWC Control Strategies Evaluated
Strategy #1
Strategy #2
Strategy #3
Strategy #4
Strategy #5
Strategy #6
Strategy #7
Strategy #8
Strategy #9
Strategy #10
Strategy #11
Strategy #12
Strategy #13
Strategy #14
Strategy #15
Testing/Certification as Prerequisite to Sales or Installation
of New Stoves/Furnaces
Strategy #1, with 33% Tax Credit ($400.00)
Testing as Basis for Mandatory Labeling of New Stoves/Furnaces
Prior to Sales; Label Specifies Emissions Performance and
Efficiency
Strategy #3, with 33% Tax Credit ($400.00)
Testing/Rating by RWC Industry Trade Association
Mandatory Weatherization of All Households
Mandatory Weatherization Only for Households Installing New
Stove/Furnace
Firewood Moisture Content Controls
Stove Sizing
Encourage Larger Firewood Piece Size
Require Underfire Air Source for New Fireplaces
Episode Controls
Research and Development of Improved RWC Appliances and/or
Practices
Encourage Alternative Fuels
Periodic Inspection of RWC Equipment
Source: U.S. EPA (1984b; Task 6)
V-10
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V-16
-------
ranked order, along with rough estimates of their Implementation costs and
benefits - the latter expressed mostly in terms of estimated particulate
reductions. The overall observations and conclusions from this analysis
are summarized below.
The two highest ranked strategies also provided the highest estimated
particulate emissions reductions, by the year 2000. Both involve
mandatory testing and certification of new stoves, and banning the sale of
stoves which cannot comply with an established emission standard
characteristic of clean burning operation. Their only difference was that
one strategy offers a financial Incentive (a 4400 tax credit) to help
purchase certified stoves, which were expected to cost more.
The emissions reductions from such certification approaches necessarily
take many years to be fully realized, but they reduce emissions from
existing as well as from new stoves. That is, when existing units are
eventually replaced, only certified cleaner units will be available. The
tax credit costs were shown to be reasonable, compared to industrial
pollution control tax credits which have been available for years from
states like Oregon.
Mandatory certification is effective because it limits consumer choice
dramatically. This could be a source of consumer backlash especially if
the only available (certified) appliances are much more costly. The
financial incentive could offset this, at significant cost to the
government. The other emissions testing/certification strategies
considered in this study relied upon labeling to Induce consumer purchase
of certified appliances. They ranked lower than the mandatory
certification approach, even with a financial Incentive added (tax
credit), because consumer choice was not limited enough to ensure how much
emissions reduction would result.
Several other strategies emerged from this analysis as low in cost,
convenient, and potentially capable of significant emissions reductions.
These Include: encouraging larger firewood piece size; moisture control
V-17
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(seasoning) measures; stove sizing, and; episode controls. All are based
on public education, and could be jointly implemented, with relatively
modest administrative costs.
However, there were two major uncertainties Inherent in these "least cost"
strategies. The most obvious was uncertainty in how much people would
respond to the public education and alter their wood burning practices in
the desired manner. The second uncertainty involved the very limited
research base upon which some of the projected RWC emissions reductions
were based. For example, the extent to which use of larger pieces of
firewood might reduce particulate emissions was very speculative.
Accordingly, agencies adopting these strategies would have little control
over, or ability to measure, the emission reductions.
The two strategies based on weatherization of households to reduce heating
demand did not rank very highly (9th and 12th out of 15). They produced
potentially good emissions reductions, but these were more uncertain
(e.g., than for a mandatory certification strategy). This was primarily
because the extent to which weatherization would alter household RWC
practiculate emission was not determinable. Public acceptance of
weatherization requirements was rated low, primarily due to its high
initial costs (despite eventual payback through fuel savings).
Strategies considered most acceptable to the public at large were those
involving the least inconvenience and/or costs to it - e.g.,
testing/certification and labeling, research and development, and the
least cost strategies mentioned above. Episode controls which rely on
voluntary compliance, also ranked high In public acceptance.
Mandatory episode controls, such as Mlssoula, Montana has adopted, or
restricting RWC via stove permits, such as Mlssoula has proposed (Section
V. C. 2), would have ranked relatively low in public acceptance if they had
been included In the group of fifteen strategies evaluated. Mandatory
episode controls were not included, because it had ranked 50th out of 75
possible approaches in the initial Keppner-Tregoe screening analysis. The
woodstove permit concept was not analyzed because of potential conflicts
V-18
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with state laws, many of which prohibit direct regulation of air pollution
sources at the household level. In retrospect, these are both viable
strategies which should be considered, If feasible, In any analysis of
potential approaches.
Overall, strategies most directly effective In reducing RWC emissions tend
to also reduce public convenience and choice, risking loss of public
acceptance. Accordingly, developing effective RWC control measures Is a
sensitive undertaking, and must be carefully tailored to each community's
characteristics.
C. leading Examples of RWC Control Strategies Adopted or Proposed
1. Oregon
The Oregon Department of Environmental Quality (DEQ) was the first
state agency to recognize and to document that RWC contributed
significantly to elevated ambient partlculate levels. The 1977-79
Portland Aerosol Characterization Study (PACS) (Watson, 1979)
estimated the relative contributions of RWC and other particulate
sources, in a landmark application of newly developed (Friedlander
1973) Chemical Mass Balance (CMB) techniques.
CMB „and other analyses in Medford, Eugene, and other localities
confirmed substantial RWC impacts from both wood stoves and fireplaces
(Nero and Associates, Inc. 1984). This was especially true in
Medford, where valley terrain and winter meteorology greatly
exacerabated ambient concentrations (DeCesar et al, 1981). Household
wood usage surveys and projections using dispersion models by DEQ, in
conjunction with CMB findings, provided the basis for partlculate
State Implementation Plans (SIPs) for Oregon's three non-attainment
areas (Portland, Eugene and Medford) In the early 1980's.
All three SIPs explicitly addressed RWC impacts and control
strategies, which were developed with extensive participation of local
citizen advisory committees. All of these SIP processes evaluated a
V-19
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range of RWC control strategies, to assess their potential air quality
benefits and implementation costs. Example strategies evaluated
included:
• weatherizing homes to reduce wood heat demand;
• promoting better seasoning of wood fuel to control moisture
content;
• public education to improve selection and operation of wood
burning appliances; and,
• measures to promote the development of cleaner burning stoves,
such as through stove testing and certification.
The most detailed and substantive local RWC control strategy
proposed/adopted was In Medford, where RWC impacts were higher than
anywhere else in Oregon, and where total part leu late levels exceeded
primary (health related) national ambient air quality standards.
In addition to developing TSP SIPs which addressed RWC control, DEQ
initially concentrated on public education. The agency prepared and
distributed a number of publications on wood heating, as summarized in
Table T^-7 (DEQ, 1979-81). Eventually, DEQ became convinced that
controlling increasing RWC impacts would require measures capable of
reducing baseline RWC emissions and improving existing air quality -
not just slowing projected Increases in RWC emissions. In 1983 DEQ
asked the Oregon Legislature for authority to establish a statewide
testing and certification program, as the most practical approach to
roll back RWC impacts.
Medford's RWC control measures, and Oregon's stove testing and
certification program are further described below.
a. Medford
In August, 1982, the Jackson County (Medford) Board of County
Commissioners adopted Ordinance Ifo. 82-6 which provided for the
following RWC control measures (Jackson County, 1982):
V-20
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TABLE V-7. Oregon Woodstove Publications3
Publication Distribution
Woodstoves: Energy Solution or Air Pollution? 18,000
Woodstove Bibliography 5,000
Interpretation of Woodstove Emission Testing Results 5,000
Oregon Woodheat Handbook 70,000
Bum Wood Better 20,000
DEQ Views on Woodheating 34,000
Source: Hough and Kowalczyk (1983).
a References: DEQ 1979-81; Hazen, 1980.
V-21
-------
• Mandatory weatherlzation for residences wishing to Install a
wood stove, fireplace, or any other form of solid fuel, space
heating device.
• The residence must meet cost-«ffective levels of
weatherlzation within 90 days of wood stove installation, and
have an alternative form of space heating other than solid
fuel burning for use during pollution episodes.
Cost-effective weatherlzation was to be based on the
recommendations from energy audits available free from local
utilities. Such audits were also required by this ordinance
as a condition of sale or rental, as part of Jackson County's
stated goal of helping all citizens weatherize to cost
effective levels by January I, 1987.
• All homes with wood heating systems must be weather!zed to
cost-effective levels at the time of sale or rental, _if_ the
primary particulate health standard is not attained by January
1984.
• Prohibition of RWC within the Air Quality Maintenance Area
whenever partlculate levels exceed, or are projected to
3
exceed, the primary particulate health standard (260 ug/m ,
24-hour average), except for residences with no other form of
space heating.
• If the primary particulate standard is not attained in the
AQ1A by July 1, 1984, RWC Is prohibited whenever DEQ Issues an
air stagnation advisory (occurs about 10-40 days per year).
The particulate standard was not attained by 1984, but the
ordinance described above was replaced by another in October,
1984, which changed some of its provisions, partly In response to
the efforts of local realtors (Jackson County, 1984). Major
changes include:
V-22
-------
• Establishing minimum weatherization standards, but with
options, instead of basing weatherization requirements
entirely on an energy audit.
- Installing weatherIzation measures proven cost-effective by
an authorized audit remains one way to satisfy minimum
weather ization standards.
- Mother option was insulation of 8.-30 in the ceiling, R-19
in the floor, and double glazed windows or storm windows.
- Another option is those weatherization alternatives
entirely authorized for installation through any federal,
state or utility company sponsored loan or grant program.
• Effective January 1, 1985, the owner of any residence (except
a mobile home) constructed before January 1, 1979, which does
not meet minimum weather ization standards, must provide an
energy audit to potential purchasers of such residence.
• Effective January 1, 1985: Prior to sale of the any residence
(other than a mobile home) constructed before January 1, 1979,
and which has a solid fuel heating device, the owner must
ensure that the home will meet minimum weather ization
standards by:
- Bringing the home up to those standards; or
- Filing a proposal with the Jackson County Department of
Planning and Development, signed by the new owner of the
residence, stating that the new owner will be responsible
for bringing the residence up to minimum weatherization
standards within 90 days of the sale.
• Mobile homes and homes outside the Jackson County Air Quality
Maintenance Area were exempted.
Sales within incorporated cities, including Medford, had been
exempted in the original ordinance. This exemption was
retained.
V-23
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The City of Medford adopted a very similar weather ization
ordinance (City of Medford, 1982) requiring cost-effective
weather ization of RWC homes at the time of sale or rental, If
primary particulate standards were not met by January, 1984. The
City repealed their ordinance in February, 1984, out of concern
for Its enforceabillty, and in response to concerns of local
realtors who felt that enforcement burdens fell on them. However,
the City will consider a revised ordinance for particulate
pollution control in the fall of 1985 (Eisenhard, 1985), which
would reestablish weather ization requirements for certain existing
RWC homes at the time of sale, and any residences Installing solid
fuel heating devices in the future. It would also ban RWC on any
days when the primary health standard is projected to be exceeded,
or when the National Weather Service issues a Air Stagnation
Advisory.
Appendix B contains copies of both Jackson county ordinances, as
well as summaries of ordinance provisions by the county and by a
representative of local realtors.
The technical basis for the Medford RWC control strategy was
described in "A Comprehensive Strategy to Reduce Residential Wood
Burning Impacts in. Small Urban. Communities" by Hough and Kbwalczyk.
(1983). This may be the most complete assessment published to
date of a range of proposed RWC control strategies for a specific
community. It includes estimates of expected reductions in wood
usage and emissions, ambient air quality benefits, and associated
costs for each control measure proposed. These findings and
conclusions are summarized briefly below.
Table V-8 summarizes nine RWC control measures recommended by the
Jackson County Air Quality Advisory Committee, to help comply with
the primary particulate standard by 1985. For five of these
measures, reductions in ambient total suspended particulate (TSP)
concentrations were estimated, based on technical analyses
prepared by DEQ staff.
V-24
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TABLE V-8. Medford Residential Wood Burning Control Measures Effectiveness
Control Measures
Projected Annual
TSP Reduction (ug/m3)
Woodstove Operation Education a
Weatherization Before New Woodstove Installation 3.2
Weatherization of Homes With Existing Stoves 5.5
Weatherization Assistance to Elderly/Low Income a
Stove Sizing Requirements a
Firewood Moisture Control 4.2
Woodstove Curtailment During Pollution Episodes 2.8
Alternative Heat Source for New Homes a
Solar Access and Orientation 0.3
Total 16-°
These measures are not assigned a direct benefit but are essential to the
success of other measures.
Source: Hough and Kowalczyk, 1983.
V-25
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The weatherizatIon and episode controls were Included in the
County Ordinance described above. Firewood moisture coatrol was
pursued separately through public education and cooperative
efforts with the U.S. Forest Service and Bureau of land
Management. Fuelwood moisture control was pursued by promoting
wood cutting in the spring, to allow more time for seasoning.
Stove certification and testing was not included in the Medford
recommendations, because It was a longer range strategy, and
enabling legislation had not yet been enacted. However, Hough and
Kowalczyk (1983) estimated that a woodstove certification program
3
would result in 10-15 ug/m lower TSP concentrations over a
10-20 year period - or, potentially as much as all of the other
control measures combined.
Table V-9 summarizes the potential reduction in particulate
emissions estimated by DEQ for the RWC control measures proposed
for Medford, as well as the time required to implement them, and
to fully realize their estimated emission reductions. Here stove
certification is listed for comparison. It reduces emissions by
almost as much as, or more than, the other control measures
combined, but requires much longer time.
Table V-10 shows DEQ's estimates of how these estimated emissions
reductions would affect RWC wood usage and associated emissions
for a typical Medford woodstove household. Household surveys had
shown that the average woodstove household in the Medford area
used 3.0 cords/year of wood In 1980-81. Implementation of the
strategies in Table V-8 were estimated to reduce per household
wood use and particulate emissions by slightly more than half.
Adding a woodstove certification program would further reduce wood
usage somewhat, but would further reduce emissions by a factor of
five (over 10-20 years), due to the gradual replacement of
existing woodstoves with more efficient and much cleaner burning
models.
V-26
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TABLE V-9. Particulate Emission Reduction Potential
Control Measure
Curtailment During
Pollution Episodes
Improved Operation
& Firewood Seasoning
Weatherization and
Proper Stove Sizing
Certification Program
(for high-efficiency/
low-emission designs) 3_
Overall 3
Time to
Implement
(yr)
1/2
Time to Achieve
Significant
Benefit (yr)
1-2
2-3
3-10
10-20
1-20
Particulate
Emission Reduction
Potential (%)
5-15
10-20
30-50
75-85
80-95
Source: Hough and Kowalczyk (1983).
V-27
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TABLE V-10. Potential Emission Reductions per Household
Control Measure
None (based on
typical Medford
woodstove house-
hold)
Add Curtaillment
During Pollution
Episodes
Add Improved
Operation & Fire-
wood Seasoning
Add Weatherization
& Proper Stove
Sizing
Replace Existing
Woodstove with
New Woodstove
Design
Overall
Emission
Reduction (%)
10
15
40
80
90
Resultant
Firewood Use
(cords/yr)
3.0
2.7
2.3
1.4
1.1
(-1.9)
Particulate
Emissions (Ib/yr)
210
190
160
100
20
(-190)
Source: Hough and Kowalczyk (1983).
V-28
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Overall, the RWC control strategies Identified for Medford were
estimated to reduce RWC partlculate emissions by 40% by 1985, and
by up to 90% by the year 2000, with a stove certification
program. This would be accompanied by an estimated 60% reduction
in firewood usage, and a 40% reduction in space heating
requirements.
The RWC control measures adopted for Medford were part of a larger
TSP SIP program which Included industrial controls. Table V-ll
compares the estimated energy and economic Impacts of both the
residential and industrial partlculate control measures. The
residential control measures were considerably more cost
effective, and often saved energy, while the more expensive
industrial controls also increased energy use.
Too little time has elapsed (two yeazs) since adoption of
Medford's RWC control strategy to attempt to estimate its actual
effectiveness. However, Oregon has recently Implemented a stove
testing and certification program, so all of the control measures
discussed above are now underway concurrently.
b. Mandatory Woodstove Certification Program
After years of special studies and SIP development work, DEQ
concluded that RWC emissions were a major and growing cause of
particulate standard non-attainment - especially in the Portland
and Medford airsheds. After evaluating the potential
effectiveness of many RWC control measures, DEQ also concluded
that to attain and maintain ambient air quality standards,
effective RWC control measures would have to promote the
development and use of new, cleaner burning appliances. These
would also eventually need to replace existing appliances, in
order to substantially reduce existing (baseline) RWC emissions
levels.
DEQ had concluded that virtually all existing wood stoves were
poorly engineered with respect to combusion efficiency
(emissions), and would emit relatively large amounts of pollutants
V-29
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TABLE V-ll. Energy and Economic Impacts of Medford Control Measures
Annual Cost Per TSP Reduction
Measure
Energy
Requirement
Per Ton Per ug/m3
RESIDENTIAL
Weatherlzation
Firewood Seasoning
Woodstove Curtailment
Woodstove Certification
Net Savings
Net Savings
No Change
Net Savings
Net Savings
Net Savings
$ 1,850
$ 350
Net Savings
Net Savings
$ 48,000
$ 18,000
INDUSTRIAL
Cyclone Controls
Veneer Dryer Controls
Small Boiler Controls
Large Boiler Controls
350 hp/ug/m3
450 hp/ug/m3
350 hp/ug/m3
No Change
i 1,000
$ 4,550
$17,000
$ 3,400
* 130,000
$ 500,000
$ 130,000
$ 120,000
Source: Hough and Kowalczyk (1983).
V-30
-------
no matter how carefully they were operated. Thus, RWC control
measures based on public education - e.g., about the benefits of
proper stove sizing and operation, firewood seasoning and
weatherlzatlon - could not achieve the Improvements In parttculate
levels needed for compliance with standards In places like Medford
and Portland.
Figure V-l Illustrates the relative magnitude and projected trends
of partlculate emissions from RWC and Industrial point sources.
It also shows the estimated reductions In projected RWC emissions
achievable with several control measures, for the Portland airshed
(Kowalczyk and Tombleson, 1982). During the last decade, growth
in RWC emissions had virtually negated Industrial partlculate
emissions reductions achieved through earlier SIP programs.
Continuing non-attainment threatened to stifle future industrial
and other economic development, unless sufficient particulate
emissions reductions could be achieved to attain standards and to
provide a growth margin of unused airshed capacity.
Figure V-l illustrates the emissions reductions projected for the
following types of RWC control measures, which were selected
because they would actually promote cleaner burning woodstoves: a)
voluntary or mandatory labeling of new stoves, to show consumers
their emissions performance; b) labeling combined with a financial
incentive (tax credit); and, c) mandatory testing and
certification of new woodstoves for compliance with an emission
standard, as a prerequisite of sale. The mandatory certification
was judged to be clearly the most effective at reducing both
existing and future emissions. DEQ estimated that a 68%-75%
reduction in RWC particulate emissions was achievable through
mandatory certification, and was needed to attain standards, as
explained below.
DEQ requested and obtained from the 1983 Oregon Legislature the
necessary authorization for a statewide certification program that
V-31
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V-32
-------
would regulate new woodstoves at the point of sale. Opposition
from the woodstove Industry was countered by support from a
coalition of other Interests, Including not only environmentalists
but also medical professionals and other Industrial groups. The
resulting enabling legislation (House Bill 2235, 1983) established
the basis for Oregon's woodstove certification program, which a
DEQ staff paper (Kbwalczyk and Tombleson, 1984) recently
summarized as follows:
"The first program In the United States to restrict the
sale of woods toves to only the cleaner burning models was
enacted by the 1983 Oregon legislature. Specific rules to
Implement the program were adopted In June 1984 to address
emissions and efficiency test procedures, laboratory
accreditation requirements, emissions and efficiency
labeling specifications, acceptable partlculate emission
levels and stove certification procedures. The rules were
developed with the aid of a broad-based advisory committee
and Input from national and International members of the
woodstove industry. An extensive woodstove emissions and
efficiency database was developed to assist In formulating
the rules. A two-stage emission standard was adopted,
which requires new stoves marketed In Oregon to achieve a
50 percent reduction In partlculate emissions by July 1986
and a 75 percent reduction by July 1988. The
certification program Is designed to bring all areas of
the state Into compliance with national ambient air
quality standards for partlculate matter by the year
2000. The program is expected to save owners of certified
woods toves up to 1/3 on firewood consumption because of
the inherently higher heating efficiency of lower
polluting stoves, as well as providing increased fire
safety because of reduced creosote formation and Increased
health benefits because of reduced polycycllc organic
matter emissions."
Oregon's certification program applies to woodstoves and stovelike
fireplace Inserts, but not to fireplaces. The program has five
major elements, Including:
• A testing procedure;
• An emission standard;
• A testing laboratory accreditation process;
V-33
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• labeling requirements; and,
• Certification procedures
Appendix B contains copies of Oregon's enabling legislation (HB
2235), and administrative rules adopted to implement the program,
including detailed specifications for measuring woodstove
emissions and efficiencies. Several fact sheets which describe
various aspects of Oregon's program and requirements are also
included in Appendix B. Highlights of the major program elements
are briefly discussed below.
Test Procedure
Oregon's enabling legislation requires new woodstoves to be tested
and permanently labeled both for emissions and heating
efficiency. Four tests are run on each stove - at low, medium,
high and maximum heat output levels, using a standardized fuel
charge (Douglas Fir). The results are averaged to determine
whether the stove meets the emission standard.
By testing over a full range of heat outputs, DEQ satisfies a wood
stove industry request to produce performance data which would be
usable in all areas of the country. In calculating the average of
the four emissions tests, weighting factors are used based on
Oregon climate and population distribution, as specified by rule
(Appendix B). Thus, a stove's performance is rated on how it
would perform under Oregon's heating demands.
Particulate sampling uses an EPA Method 5 apparatus, modified with
an extra impinger and filter to better collect condensible
particulates, which account for about 60% of a typical catch.
Either a Calorimeter Room method or a stackloss heating method may
be used to measure heating efficiency.
It should be noted that development by Oregon of a woodstove
certification program, with stipulated procedures for testing the
V-34
-------
emissions and heat transfer efficiencies of stoves, has stimulated
lively debate about a number of related issues and technical
questions. Inclusion of Oregon's "Standard Method of Measuring
the Emissions and Efficiencies of Woodstoves" in Appendix B does
not in any way constitute an EPA recommendation of these
procedures. EPA is currently developing a New Source Performance
Standard (NSP3) for woodstoves, during which the agency will
provide its own guidance on stove testing methods.
Several other professional and trade organizations have taken an
active role in the debate on woodstove standards and test methods
- especially, the Wood Heating Alliance (WHA) and the American
Society of Testing and Materials (ASTM). An ASTM subcommittee has
undertaken research on woodstove testing methods. A central focus
of this research is a dilution tunnel approach which might serve
as an alternative to Oregon's testing approach. This work is not
reported here, because the ASTM studies are not yet sufficiently
complete to allow definitive comparisons of alternative test
methods Oregon's test method description is included in Appendix
B, because it is the only such procedure completed and adopted to
date, and because it Is referenced by several of the other states
or localities whose RWC control measures are discussed in this
section. However, EPA stresses that it does not favor any
particular testing approach at this time.
Emission Standard
In selecting its emission standard, DEQ primarily considered three
items: a) airshed improvements (emission reductions) needed to
attain and maintain ambient air quality standards; b) the
emissions performance capability of available stove technology;
and, c) in the case of catalytic stoves, the deterioration with
age of catalytic combustera.
For both Portland and Medford DEQ estimated that a 72%-78%
reduction in RWC emissions was needed, in conjunction with control
V-35
-------
strategies for other sources, to fully meet all national ambient
standards for total suspended particulate. DEQ estimated the
average emissions from existing or baseline stoves at 30-34
grams/hour (20-21 grams/kilogram of wood burned times an. estimated
baseline burn, rate of 1.7 kilograms/hour (DEQ, 1984)). The
woodstove emission standards adopted to achieve the needed
reduction in this baseline emissions level are summarized in Table
V-12.
Tests showed catalyst-equipped stoves were cleaner burning, but
deteriorated in performance by an average factor of 2.5 over an
expected catalyst life of 6,000 to 12,000 hours of operation.
Accordingly, the standard for non-catalyst stoves was set to
result in equivalent performance with catalyst stoves over the
expected (two year minimum) life of the catalyst. That is,
catalyst stoves which initially emit six grams/hr are expected to
deteriorate to 15 grams/hour over the lifetime of the catalyst
component. Catalytic combusters are expected to have to be
replaced as often as every two years for frequently used
appliances. DEQ will require a two year replacement warranty on
the catalytic combuster elements of catalyst-equipped stoves as a
condition of certification. The 50% emission reduction is based
on DEQ's estimate that the average stove now on the market emits
more than 30 grams/hour, and certified stoves would emit no more
than 15 grams/hour on the average.
By mid-1988, the standard is tightened to nine grams/hour for
noncatalyst stoves and four grams/hour for stoves with catalytic
combusters. This would achieve a 702-75% reduction in current
baseline RWC emissions, over the 10-20 year period required for
Oregon's entire stove population to be replaced by cleaner burning
certified stoves. This would provide the overall RWC emissions
reduction DEQ estimates is needed for most areas in Oregon to
attain ambient standards, by the year 2000.
V-36
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TABLE V-12. Oregoa's Woodstove Particulate Emissions
Standards (grams/hour)
By July 1986 By July 1988
Catalytic 6 4
Non-Catalytic 15 9
Actual Emission
Reduction 50% 70%-74%
a Weighted average of four emissions tests, per Oregon procedures.
Source: Kowalczyk and Tbmbleson 1984.
V-37
-------
DEQ concluded that several different manufacturers of catalyst
equipped appliances had production model stoves which already met
the 1988 standard of four grams/hour. The testing to confirm this
used the Oregon procedures. This testing was done at a 13,000
Btu/hr reference heat output level, which corresponds to Oregon's
climate (heating demand), and estimated baseline burn rate of 1.7
kg/hour.
The nine grams/hour second stage (1988) standard for
noncatalyst-equipped stoves was based on equivalency with the four
grams/hour standard, taking Into account the catalyst
deterioration factor of 2.5. This standard Is not necessarily
achievable with present non-catalytic technology, as DEQ
acknowledges. However, this level of emissions reduction was
considered necessary to meet airshed requirements. DEQ hopes the
lead time available will result In sufficient advances In
non-catalyst technology, so that the standard does not become what
some of Its critics call a "catalytic mandate". However, If this
does not occur, Oregon Is prepared to rely solely on catalytic
technology to achieve Its airshed targets. DEQ cites the U.S.
auto Industry's experience In relying on catalyst technology as an
example of the workability of such a policy.
laboratory Accreditation
Most of the work In Oregon's certification program, once It Is
fully Implemented, will be done by private testing laboratories,
which must meet stringent Oregon accreditation requirements.
These Include demonstrating testing proficiency using an Oregon
supplied stove, standardized data calculations using Oregon
supplied software, audit provisions, and specific accreditation
enforcement procedures.
Labeling Requirements
Enabling legislation required that certified stoves be permanently
labeled to show both their tested emissions and efficiency.
Figure V-2 shows two labels, both of which will be used In
Oregon. The permanently attached label will show tested emissions
V-38
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Permanent Woods tove Label
(Example)
CERTIFIED TEST PERFORMANCE
20
T««ted by:
Data:
Procedure:
OS
D
O
I is|
W)
S
e1
o
01 0
O
5
Manufacturer:.
».«• !>.••• M.H* ».M*
HEAT OUTPUT • BTU/HOUR
- Model: _ ,
*:.
00
00
m
•n
2
O
m
Z
O
eo
BO
P»rformane» may vary from taat v>lu«» depending on actual horn* operating condition*
Removable Woodstove Label
(Example)
EMISSIONS AND EFFICIENCY PERFORMANCE
(non-catalytic stoves)
SBo11* _____ sr*«l/hour (DEQ Standard i 15 until 07/80)
9 after 07/88)
Efficiency % (NO DEQ Standard)
Manufactureri
HEAT 90TPPT RANGE
to
Modeli
Name
Name
BTC's/hour
_^ Design *t
Number
(Performance nay vary from test values depending on actual home
operating conditions)
.t this unit has been certified as
Pursuant to OAR _______^_
meeting Oregon Department of Environmental Quality emission
standards and has been approved for sale in the State of Oregon
until July 1, 1988.
Figure V-2. Woodstove Labels to be used by Oregon Certification
Program
V-39
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and efficiency performance over the whole range of heat output
levels. Its format was designed to provide useful data for all
areas of the country, allowing manufacturers to avoid additional
testing costs that might be imposed outside of Oregon. It will
also help consumers evaluate stove performance.
A second label, removable by the consumer, was also intended to
help the consumer compare appliances based on their average
efflciences and emissions levels. It also shows the rate of heat
output levels the stove can provide, for use in sizing stoves to
residences. Labels must be produced and affixed by manufacturers,
with DEQ approval, prior to stove certification.
Certification Program Timetable and Costs
Oregon's program is now underway, with the voluntary phase of its
testing and certification program. The first stage mandatory
standards are not in effect until July 1, 1986. One laboratory
had been accredited and nine stoves had been certified, as of
March 14, 1985 (See Appendix B for list of stoves). Other
applications are in process, or expected soon. The State of
Colorado has adopted, and Missoula, Montana is considering
adopting, certification programs similar to Oregon's as described
later in this section.
Estimated certification program costs have included the following:
• DEQ has estimated that increased costs to consumers of
certified stoves may range from $200-4500 on the average
(Kbwalczyk and Tombleson, 1984, and 1982).
• Testing costs to manufacturers were estimated by DEQ in 1981-82
at $1,500-42,000 per model tested. This is comparable to their
present costs for safety and efficiency testing (Kowalczyk and
Tombleson, 1982).
« Catalytic combuster replacement: $60 to $140 as often as every
two years (Kowalczyk and Tombleson, 1984).
V-40
-------
and efficiency performance over the whole range of heat output
levels. Its format was designed to provide useful data for all
areas of the country, allowing manufacturers to avoid additional
testing costs that might be imposed outside of Oregon. It will
also help consumers evaluate stove performance.
A second label, removable by the consumer, was also intended to
help the consumer compare appliances based on their average
efficiences and emissions levels. It also shows the rate of heat
output levels the stove can provide, for use In sizing stoves to
residences. Labels must be produced and affixed by manufacturers,
with DEQ approval, prior to stove certification.
Certification Program Timetable and Costs
Oregon's program is now underway, with the voluntary phase of its
testing and certification program. The first stage mandatory
standards are not In effect until July 1, 1986. One laboratory
had been accredited and nine stoves had been certified, as of
March 14, 1985 (See Appendix B for list of stoves). Other
applications are in process, or expected soon. The State of
Colorado has adopted, and Missoula, Montana is considering
adopting, certification programs similar to Oregon's as described
later in this section.
Estimated certification program costs have included the following:
• DEQ has estimated that increased costs to consumers of
certified stoves may range from $200-3500 on the average
(Kowalczyk and Tbmbleson, 1984, and 1982).
• Testing costs to manufacturers were estimated by DEQ in 1981-82
at $1,500-42,000 per model tested. This is comparable to their
present costs for safety and efficiency testing (Kowalczyk and
Tombleson, 1982).
• Catalytic combuster replacement: $60 to $140 as often as every
two years (Kowalczyk and Tombleson, 1984).
V-41
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• DEQ's administrative costs may not exceed one to two staff
persons, because so much of the program's cost and work will be
borne by the manufacturer and private testing labs.
• Potential loss in business (sales) to RWC manufacturers and
retailers due to higher appliance prices has been a concern,
but no quantitative estimates were available.
Benefits
DEQ has estimated the following benefits of their certification
program (Kowalczyk and Tombleson, 1984):
• Seventy-five percent reduction in particulate emissions by the
year 2000, including in TSP, fine particulate (PM1Q) and
polycyclic organic matter (POM).
• Proportional reductions in carbon monoxide from RWC, which
should aide in achieving attainment of CO standards too -
especially wherever these are exceeded in residential
neighborhoods.
• Higher woodstove heating efficiencies, which can save consumers
up to 33% in the amount of firewood needed, thereby reducing
costs associated with gathering firewood; and, conserving
renewable wood energy resources.
• Reduced fire hazards, because cleaner burning stoves will emit
up to 90% less creosote, thereby also reducing chimney cleaning
costs.
• Overall estimated savings of $10-20 per cord of wood burned,
available to offset higher purchase prices for certified stoves.
• Health benefits from the 75% reduction of respirable
particulate and POMs, the latter already identified as a major
air toxicant.
V-42
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2. Montana
The State of Montana Clean Air Act gives the Board of Health and
Environmental Sciences broad powers to regulate any source of air
pollutant emissions, Including residential sources since these are not
excluded. However, the Act prohibits entry and Inspection of private
residences for this purpose. This could limit the ability of agencies
to measure RWC emissions, or to enforce RWC control strategies, at the
household level.
The State of Montana Department of Health and Environmental Sciences
can Identify potentially significant RWC ambient Impacts In at least
ten western Montana communities, with observable Impacts In some
localities which occur as frequently as twenty-five times or more In a
heating season (Nero and Associates, Inc., 1984). The state agency
has concentrated on monitoring TSP problem areas, and has sponsored
RWC wood usage surveys In a number of cities (Erlckson et al, 1981).
The state approach Is to establish a strong data base, and to measure
the magnitude of RWC Impacts, before proposing any RWC control
measures, partly because regulation of RWC Is a controversial topic In
Montana.
The state Is closely watching developments In Oregon. As In Oregon,
state enabling legislation would be needed to regulate RWC appliances
at the point of sale. The only direct regulatory action related to
RWC In Montana has occurred In Mis sou la, but It has been a major
effort.
a. Mlssoula
Mlssoula has been a nonattalnment area for TSP (primary standard)
since monitoring began (1969), except for several years in the
mid-19701 s. Industrial controls and street paving achieved
attainment, but area source growth - suspected to be primarily
from RWC - has restored nonattalnment conditions (Carlson, 1984).
The local air pollution control agency, the Mlssoula City-County
V-43
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fealth Department (MCCHD), has taken an active role In KWC
assessment and control, in response to direction from its
governing body, the Missoula City-County Air Pollution Control
Board, and strong citizen concern.
A 1976 petition with 10,000 signatures asked the Missoula County
Board of Commissioners to "do something" about deteriorated air
quality In Missoula. In early 1981, after several studies
involving citizen committees, the MCCHD began working with
Missoula citizens to develop a plan to reduce wintertime air
pollution from all sources, but especially from RWC. That effort
resulted in a public education campaign, which included radio and
TV commercials, and slide/tape and video presentations, as well as
brochures.
It also lead to a package of regulatory measures designed to
reduce the severity of air pollution episodes. An Air Stagnation
Plan was adopted, which was initially based on voluntary
curtailment not only of RWC but also of Industrial point source
emissions, if an air pollution Alert was declared.
In November, 1983 RWC control measures were strengthened, to
produce one of the most comprehensive RWC control strategies
enacted by any community. The main elements of this program are
as follows:
• Visible emission limits
- Smokestack plume opacity cannot exceed 60% at any time,
except for 15 minutes In any four hour period, allowed to
start up a fire. This applies at all times to ail
residential and commercial solid fuel burning devices
within the Missoula Air Stagnation Zone, which encompasses
most of the Missouia Valley.
V-44
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• Episode Controls (Mis sou la Air Stagnation Plan)
- Stage I Air Pollution Alerts and Stage II Warnings are
called if the eight-hour average TSP level exceeds, or is
3 3
projected to exceed, 150 ug/m and 300 ug/m ,
respectively.
- No visible emissions are allowed from any residential or
commercial solid fuel burning devices, except by special
permits of the following types: sole source of heat
permits; dealer demonstration permits; and, special need
permits.
Permit holders may burn, but cannot exceed 20% opacity,
except during fire start-up (20 minutes every four hours).
- Alerts and Warnings are voluntary in the Air Stagnation
Zone, but mandatory within a smaller High Impact Zone,
which includes urban areas of Missoula.
- People are also requested to limit vehicle driving to
necessary trips and use mass transit.
• Bi for cement/Penalties
- Inspectors check for improper visible emissions, issue
written warnings (first violation per season) and citations
for repeat violations, which can result in fines of
d20-100, or loss of special permits to burn.
- Enforcement is on-going for the visible emission (60%
opacity) limit.
- For episodes, MCCHD must give public notice of Alerts and
Warnings at least three hours prior to taking enforcement
action.
V-45
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MCCHD uses the media to announce Alerts and Warnings, and
maintains an Air Pollution Hot Line with a recorded message on RWC
curtailment status. last winter the agency had to increase the
number of phone lines to seven, and shorten the recorded message
to 10 seconds to handle episode calls (Ifedstrom, 1984).
Last winter (1983/84) was the first heating season under the new
mandatory Alerts. One hundred ten warnings were issued, and one
citation, which was successfully appealed. Alerts or Warnings
typically occur 10-30 times during a heating season.
MCCHD staff have estimated and compared the air quality benefits
of the all-voluntary RWC curtailment measures (pre-November '83)
versus the mandatory and voluntary curtailment program now in
place. Previous voluntary curtailment was estimated to reduce
emissions by 6%-12%, based on an estimated compliance rate of 30%
(Grotheer, 1984). The present program, with mandatory RWC
curtailment during episodes, could reduce RWC emissions by as much
as 23%-44% based on 100% compliance. Curtailment requirements are
expected to occur on 28-53 days each winter (120 day season). The
60% opacity limit is projected to reduce emissions by 3%, based on
a 10% violation rate, only 25% of which occur when enforcement is
possible - i.e., before dark (Grotheer, 1984).
MCCHD also estimated that the Alerts reduced daytime burning by
30%-35%, with matriatory alerts more effective than voluntary.
Based on a meteorological regime analysis, MCCHD has also
estimated ambient air quality improvements from the Alert
strategy, both in their 24-hour and seasonal average TSP
concentrations (Carlson, 1984).
A new phase of the RWC control program has been recently proposed,
in the form of proposed performance standards for new
installations of all residential solid fuel burning devices.
These are contained in proposed revisions to Missoula's air
pollution regulations. They would Incorporate Oregon's woodstove
V-46
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test Ing /cert Ideation methods, and utilize an expanded permit
system for Implementation as follows:
• Woodstoves may be issued a Class I permit by MCCHD to operate
during Alerts, if they meet a lowest achievable emission rate
(LAER) standard. The initial LAER standard proposed by MCCHD
is emissions which do not exceed 6 grams per hour, when tested
in conformance with the Oregon procedures.
• Within MissouLa's High Impact Zone, emissions from solid fuel
devices with Class I permits must not exceed 10% opacity
during Alerts, except for 20 minutes in any four hour period.
• Class I permits expire in two years, and repermitting may
require evidence at that time that the device can still meet
emission limits — e.g., evidence that catalytic combusters
have been replaced as needed.
• July 1, 1985 is the proposed start date for issuing Class I
permits. Thereafter, no new sole source permits would be
issued, and special need (hardship) permit duration and
eligibility rules would be tightened.
Appendix B contains: a) a copy of Missoula's regulations for
solid fuel burning devices, which Indicates proposed language for
adding woodstove performance standards and Class I permit
requirements; and, b) a summary of Missoula's current wood burning
regulations, which feature mandatory Alerts and Warnings, and
areawide visible emissions (60S opacity) limits.
The thrust of Missoula's latest proposed RWC control measures are
to promote the Installation of cleaner burning woodstoves, without
regulating this at the point of sale, as Oregon does. The
performance (emissions) standard proposed is stringent enough to
promote stoves with catalyst technology. The Class I permit
V-47
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renewal requirements (two years) would help guard against
deterioration of catalyst-equipped stove performance, but would
also add to the administrative burden of the program.
This Is the first full-fledged permit system proposed to regulate
RWC. The Mlssoula Air Pollution Control Board must now decide If
the administrative and political burdens of this approach are
acceptable. RWC controls have created vocal opposition to
woodstove regulation In Mlssoula. A group called "Woodbumers
United" tried but failed to put a measure on the ballot In the
fall of 1984 to repeal current RWC regulations and to prohibit
their readoptlon for two years.
3. Colorado
Concern about RWC Impacts In Colorado was first evidenced by a number
of ski communities. Their winter populations swell with temporary
visitors, and RWC Is widespread. Meteorology and terrain features
reduce ventilation, and ambient concentrations of TSP and CO
periodically exceed federal standards in winter. Recent research also
indicates that woodstoves may emit more pollutants at high altitudes,
other factors being equal (Shelton, 1985; Oregon DEQ, 1985).
Due to high fugitive dust levels often associated with winter road
sanding, many of these communities have avoided formal non-attainment
status for TSP. Visibility Impairment and hazy conditions are one of
the chief air quality concerns voiced about RWC, partly because It
direct ly threatens local economies which are dependent on tour Ism.
Following are brief descriptions of RWC control measures adopted or
proposed In several Colorado ski communities, and state level RWC
control actions.
a. Colorado Ski Communities
The Pitkln County (Aspen), Colorado community has been concerned
about RWC Impacts for over ten yeaxs. Vigorous public education
has long been conducted, to increase public awareness that RWC
causes problems, and In order to ask for voluntary curtailment
V-48
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when pollution levels are high. An active Citizens Clean Air
Advisory Board reviews RWC control statutes and works closely with
the City-County Bavlronmental Health Department. The County has
long had air quality regulations, which spell out alert
procedures, and call for vehicle restrictions during high CO
levels, but resources are lacking for monitoring and enforcement.
Both TSP and CO national ambient air quality standards are
exceeded In winter.
RWC problems were originally attributed largely to fireplaces. In
1977 the County adopted a fireplace ordinance (Pltkln, 1977)
limiting new fireplaces as follows: one per single family
2
dwelling, restaurant or bar; one per 3,500 ft. for four-plex
2
and other multlfamlly structures; one per 1,000 ft. for
duplexes or triplexes; and, one per lobby or guest entertainment
room for hotels, motels, lodges, and Inns (no fireplaces In guest
rooms were allowed).
Fireplace design standards were also adopted to reduce heat loss
from structures. Their requirements included glass (or other)
doors and air ducts to admit "other than room air". This was to
prevent room air from being drawn up the chimney, In order to
discourage cold air infiltration into the room from outside. A
copy of the original fireplace ordinance and design standards are
Included In Appendix B.
Woodstoves were not addressed because: a) there were more
fireplaces than stoves, b) fireplaces were thought to be more
polluting, and c) growth In stove use was considered unlikely, due
to anticipated growth limitations within the city of Aspen. This
also prompted the City of Aspen not to adopt RWC regulations as
the County had done.
However, stove use did grow, and in 1983 the City and County
adopted ordinances which limit the number of conventional
fireplaces or woodstoves per building, but allows unlimited
numbers of "certified" clean burning stoves (Pltkln, 1983).
V-49
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Currently, a list of "clean" wood burning devices Is maintained by
the City-County Environmental Health Officer, based on emissions
test data from manufacturers and the literature. The ordinance
specifies that Oregon test methods be used, and that testing be
done at specified burn rates and other conditions. A copy of this
ordinance Is referenced In Appendix B.
Vail, Colorado In 1978 adopted an ordinance (Vail, 1978) limiting
the number of new solid fuel burning devices per dwelling unit
(not per building, as Pltkln County had done). It also
established fireplace construction standards similar to Pltkln
County's. Voluntary curtailment of RWC was also asked whenever
carbon monoxide levels or coefficient of haze Index exceeded
specified limits (U.S. EPA, 1984b).
In 1983 Vail adopted another ordinance (Vail, 1983) which allowed
a second solid fuel burning device In any dwelling unit, provided
it compiled with Oregon's (then draft) partlculate emission
standard for wood stoves, of 0.067x10 grams/Joule. The
ordinance specified that Oregon's test procedures, or an
equivalent procedure, be the basis for judging woodstove emissions
performance.
The town's Envlromental Health Officer must certify In writing
that a woodstove meets this criteria, before a building permit can
be Issued for Its Installation. The Environmental Health Officer
will maintain and publish a list of devices known to be certified.
This ordinance also prohibits the burning of coal or refuse In
solid fuel burning devices. Appendix B contains a copy of this
ordinance.
The town of TellurIde, Colorado has also by ordinance limited the
number of solid fuel burning devices to one per building,
regardless of the number of dwelling units (TellurIde, 1976).
Continuing ambient standard violations Include some of the higher
partlculate air pollution levels In the state.
V-50
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A high level of public concern exists as evidenced from a recent
door to door survey in the town of Telluride, for the local
Environmental Commission, in which over 90% of respondents
expressed support for legislation, that would help clean up wood
stove pollution (Selby, 1984). At the present time City and
County officials are considering ways to respond to this situation
and concern. One approach receiving attention is to adopt RWC
regulations for a "Ttelluride region", which would encompass an
area larger than the Town of Telluride but smaller than San Miguel
County.
Snowmass Village, Colorado allows only one solid fuel burning
device per dwelling unit, restaurant or lodge (U.S. EPA, 1984b).
Crested Butte, Colorado limits woodstoves to one per new building
regardless of its number of dwelling units, and only if certain
conditions are met (Radderman, 1984), which are designed to
encourage highly Insulated structures and use of solar heating.
Tb obtain a building permit to install a solid fuel burning device
as a primary heat source, an applicant must demonstrate that his
entire building (walls, windows, etc.) is insulated to an overall
"envelope" factor of R-22 (Crested Butte, 1980). The town zoning
ordinance is the vehicle for regulating RWC, along with other
solid fuel burning devices. It also calls for active or passive
solar heating designs. It gives credit toward a permit for a wood
burning device for building designs which achieve "solar gain" -
e.g., which emphasize south facing windows and avoid north facing
windows.
Crested Butte is situated at an elevation of 9,000 feet, with a
population of about 1,000, a very high percentage of which burn
wood as their primary source of heat. Residential coal burning
has been banned due to air quality concerns, although coal is
readily available at competitive prices.
V-51
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The Beaver creek Resort Company, near Avon, Colorado Is a private
development of expensive homes which have instituted a unique RWC
control strategy. Regulations have been adopted which: a) place
restrictions on fireplace construction and prohibit woodstoves
entirely, b) monitor and enforce restrictions on starting or
continuing fireplace fires during high air pollution conditions.
The regulations (copy in Appendix B) will become effective when
the number of completed homes reaches 500.
An elaborate monitoring system includes a heat sensor and warning
light at each fireplace, wired to a central communication system.
Whenever the company concludes that continued RWC could result in
violations of Colorado's ambient air quality standards, the
warning light is activated in all homes. Thereafter, no new fires
can be started, or new wood added. The heat sensor allows
monitoring by the central office to ensure that burning has
stopped. If burning is not stopped, fines can be levied. The
Resort Company may even enter a home and extinguish a fire, if it
deems such action necessary.
b. State Level RWC Control Measures
State level concern and activity in Colorado related to RWC has
also increased in recent years to include the adoption of laws and
regulations to mitigate RWC impacts, as summarized in this section.
Denver has been the main focus of the few air pollution studies in
Colorado that have estimated RWC ambient Impacts (Wolff et al,
1980; GMEIL, 1982; Dennis, 1983; Poincenot, 1982). All of these
estimated significant RWC contributions to fine particulate mass
and/or to visibility impairment. Studies of RWC wood usage in
Colorado have also indicated that: a) about half of all households
have wood burning devices (Ryan, 1981; TRC 1985); and; b)
fireplaces are much more prevalent than woodstoves. In most
Colorado communities surveyed, fireplaces account for more wood
usage and resultant emissions than woodstoves, despite the fact
that average wood usage and emissions per burning unit are both
higher for stoves than fireplaces (TRC 1985; King, 1984).
V-52
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An Advisory Committee on _ Residential Wood and Coal Combustion
recommended the following types of RWC control approaches to the
Colorado Air Quality Control Commission (Colorado AQCC, 1983):
• Public education to promote proper selection and operation of
fireplaces, inserts and stoves;
• Emissions standards for all new stoves, Inserts and fireplaces
sold in Colorado; and,
• Economic incentives to decrease pollution from existing
fireplaces, inserts and stoves through retrofitting or
replacement with improved designs.
Based on these recommendations, the State of Colorado initiated a.
public education program for wood stove users through pamphlets
distributed at wood stove dealers (Grotheer, 1984). The State
also enacted enabling legislation (House Bill 1187, 1984),
Intended to reduce both particulate and carbon monoxide emissions
from RWC, by providing for the following RWC control measures:
• continued public education efforts;
• an evaluation and certification program governing the sale of
woodstoves in Colorado;
• voluntary no-bum days, whenever RWC is likely to adversely
affect air quality in any non-attainment area; and,
• structural design standards for fireplaces to reduce their
emissions.
Appendix B contains a copy of HB 1187, which was effective July 1,
1984. It calls for the Colorado Air Quality Control Commission to
promulgate rules to Implement all of its provisions by July 1,
1985. Appendix B also contains a preliminary draft of a rule to
implement the woodstove requirements by July 1985.
V-53
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Deadlines established In this law will require that store testing
and certification standards and procedures be established by July
1985, and that new wood stoves cannot be sold In Colorado after
January 1, 1987, unless they have been tested, certified, and an
emissions performance label attached.
Colorado may pattern Its stove testing and certification program
after Oregon's, but alternative approaches are being actively
promoted by affected manufacturers, through their trade
association, the Wood Heating Alliance. Colorado may have to
develop and include carbon monoxide (as well as particulate)
emissions standards in its certification program. Oregon's
program only uses particulate emissions standards.
House Bill 1187 provided that new fireplace design specifications
be adopted by the Commission by July 1, 1986, based on performance
tests of different designs. It also provided that all counties
and municipalities in Colorado which have building codes must
include the resulting fireplace design specifications, or stricter
specifications, by July 1, 1987.
To finance the start-up costs of this state RWC control program,
House Bill 1187 provided 349,134 aid one full time position, and
authorized acceptance of $75,000 in federal grant funds, for the
fiscal year beginning July 1, 1984. Fees for certification of new
wood stoves will also be established to help defray future costs
of the program.
4. Alaska
The Alaska Department of Hivlromental Conservation (ADEC) air quality
control regulations provide for designation of a Wood Smoke Control
3
Areas, if TSP from RWC alone exceeds 150 ug/m on a minimum of two
separate days (ADEC, 1983). Such levels must be measured by
ADEC-appro\ed Chemical Mass Balance (CMB) receptor modeling methods.
To date only the Mendenhall Valley of Juneau has been so designated.
V-54
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In Wood Smoke Control Areas the following restrictions apply^ (Air
Quality Control Regulations 18 AAC 50):
• Visible emissions may not exceed 50% more than 15 minutes In any
one hour.
- During an areawlde air quality Alert, this 50% opacity limit
applies everywhere outside Wood Smoke Control Areas too.
Alert criteria were expanded to Include not only the typical
3 3
areawlde TSP celling of 375 ug/m , but also a 150 ug/m
celling on partlculate matter solely from RWC within a Wood
Smoke Control Area.
• During an air Emergency, no RWC is allowed which results in the
emission of smoke.
Air Emergency criteria were expanded to include not only the
3
typical areawide TSP ceiling of 875 ug/m , but also a 260
3
ug/m ceiling on particulate matter from RWC within a Wood
Smoke Control Area.
Burning in a way that creates black smoke is always prohibited,
anywhere.
The State Air Quality Control Plan says ADEC will monitor in areas
where RWC Impacts are considered significant (ADEC, 1983). When
particulate levels reach 150 ug/m , where RWC is considered the
major contributor, chemical analysis of particulate samples and
Chemical Mass Balance (CMB) receptor modeling techniques are
explicitly called for in the Plan, to determine the actual impact from
all local sources to ambient particulate levels.
As described in Chapter IV of this report, CMB analysis can
distinguish quantitatively the contribution of locally generated RWC
emissions from any other sources of particulate matter for which a
unique chemical composition profile is established experimentally or
from literature sources. Thus, CMB analysis can estimate how much of
V-55
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the total partlculate levels measured are from local, RWC vs various
fugitive dust sources, vehicle exhaust, nearby Industry (1C any),
etc. It can similarly estimate "background1' contributions from remote
sources, If appropriate monitoring samples are available.
Thus, ADEC's RWC control strategy explicitly relies on CMB analysis to
help determine whether regulatory action Is appropriate. That Is,
Wood Smoke Control Areas would not be designated unless CMB analysis
showed that ambient TSP levels exceed*
exclusive of other source contributions.
3
showed that ambient TSP levels exceeded 150 ug/m from RWC alone,
The State Plan also emphasizes that local government should manage
adverse air quality conditions, with state assistance. The City and
Borough of Juneau (CBJ) has adopted several ordinances to regulate RWC
which Implement the state rule locally. For example, CBJ Ordlnace No.
84-30 (1984) designates the same Mendenhall Valley area as a Smoke
Hazard Area, and establishes the following RWC control measures for
that area:
• Visible emissions may not exceed 50% more than 15 minutes In any
one hour.
• Open burning Is prohibited between November 1 and March 31. This
ordinance also prohibits open burning outside the Smoke Hazard
area during these dates, unless a permit Is obtained from the CBJ,
based on a finding that the resulting smoke conditions are not
likely to endanger public health or become generally objectionable.
• Solid fuel burning may be temporarily prohibited entirely. This
requires the CBJ Manager to determine (and give public notice)
that a smoke hazard condition exists within a Smoke Hazard Area.
This determination Is defined as follows: "a determination that
weather conditions or smoke conditions within the smoke hazard
area are such as to be, or are likely to become, any danger to the
health of persons within the smoke hazard area or to become
generally objectionable to such persons".
V-56
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Exemptions to the last provision are available for persons whose sole
source of heat Is RWC, but only until January 1, 1986. Another
proposed CBJ Ordinance No. 84-18 (1984) would amend the building code
to require that e^ery dwelling unit and guest room ha\ie heating
facilities capable of maintaining a room temperature of 70
Fahrenheit, without combustion of solid fuel.
CBJ Ordinance No. 84-30 provides for fines up to 3300 for the first
violation and up to $500 or 30 days in jail, or both for subsequent
violations. The CBJ Polios Department, Animal Control Unit, has been
designated to enforce the ordinance, including Inspecting premises to
determine eligibility for exemptions (CBJ, PD, 1983). Written
warnings are authorized for first violations, but citations are
required thereafter.
A citizen Air Pollution Advisory Committee has been actively Involved
before and after adoption of the RWC ordinances. Their
recommendations to the CBJ Manager had included the following (not an
exhaustive list):
• A moratorium on the installation of wood burning devices as a
major source of heat, until emissions standards and a
certification program is established for such devices.
• That CBJ establish an Environmental Health Unit to monitor RWC and
other environmental health concerns.
• Extend the 50% opacity limitation throughout the CBJ.
Appendix B includes copies of: a) CBJ Ordinances 84-30 and 84-18; b)
ADEC State Air Quality Control Plan, Section G, "Wood Smoke Pollution
Control"; and, c) excerpts from ADEC's Air Quality Control
Regulations, 18 AAC 50.
V-57
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The ADEC has also addressed RWC through public education, and through
cooperative efforts with other agencies. For example, ADEC and the
USDA Forest Service encourage wood cutting in the spring rather than
In the fall (U.S. EPA, 1984b). This Is to promote better seasoning of
wood. Firing Inadequately seasoned wood is considered by ADEC to be a
prime cause of exceedances of the opacity limitations established to
control RWC impacts. A majority of RWC wood supply may originate from
Forest Service land in communities like Juneau and Fairbanks, both, of
which experience high RWC impacts.
5. Reno, Nevada
The Washoe County District Haalth Department regulates air pollution
in the Reno/Sparks metropolitan area, which lies within the Truckee
Meadows airshed. The Reno/Sparks area is a non-attainment area for
both total suspended partlculate (TSP) and carbon monoxide (CO). The
Truckee Meadows Air Quality Implementation Plan (AQIP) addressed RWC
primarily in terms of attaining National Ambient Air Quality Standards
for CO (Truckee Meadows AQIP, 1982).
The AQIP was based on a CO emissions inventory which estimated that
RWC produced 7,845 tons/year of CO emissions, or 39.3 tons per winter
day in 1980. This was projected to grow to 10,199 tons/year by 1987,
and 52.7 tons per winter day, if no RWC controls were applied. The
AQIP's proposed strategy for reducing RWC CO emissions consisted of
the following three elements.
• Better wood burning techniques
Public education through publication of a "Wood burners Guide"
(Regional APA, 1982) and media coverage were projected to induce
60% of all wood burner s to adopt and exercise proper burning
techniques on a continuous basis. The Improved techniques were
projected to achieve sufficiently higher bum rates to reduce CO
emissions by 64%, based on emissions test results reported by De
An gel Is et al, 1980. Thus, a 38.4% reduction (.6 x .64) in
uncontrolled 1987 CO emissions from RWC was projected for such
voluntary efforts, or 20.2 less tons of CO per winter day.
V-58
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• Institutionalized wood burning reductions
A "Developers Guide" (Washoe COG, 1981) was prepared, which
encouraged builders not to install wood stoves or fireplaces in
dwelling units, but instead to emphasize solar and energy
conservation building design. This was projected to result in 20%
of the 1987 single family dwellings not having wood stoves or
fireplaces that otherwise would have, resulting in 8.4 less tons
of 00 per winter day.
• Voluntary curtailment during episodes
An estimated 35% of all wood burners (R.WC households) were
projected to stop burning during air pollution alerts or inversion
advisories announced to the public through the media, "temperature
data monitored and reported by 30 volunteers at locations
throughout the area were to be used to anticipate inversions
(Grotheer, 1984). This estimated 35% curtailment effectiveness
was projected to reduce uncontrolled 1987 emissions by 18.4 tons
per winter day.
Thus, these three largely voluntary RWC control measures were
projected to reduce uncontrolled 1987 CO emissions on a winter episode
day by 47 tons (20.2 + 8.4 + 18.4) or by over 89%. The public
education materials were prepared and distributed, and the Washoe
County District Board of Health adapted its Air Pollution Control
Regulations, Emergency Episode Plan, to include RWC curtailment
measures and criteria, as discussed below.
The Emergency Episode Plan, criteria for RWC control actions were
strengthened in (October, 1984) and now provide for the following
actions, whenever ambient pollution concentrations reach the indicated
levels:
"Whenever the measurements of total suspended particulates, carbon
monoxide or ozone reach Stage I (Alert) levels (15 ppm CO, 0.2 ppm
3
0^, or 375 ug/m TSP, respectively) and adverse meteorological
V-59
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conditions, are predicted to persist, the burning of wood or coal
in commercial or residential stoves and/or fireplaces shall be
suspended unless it can be demonstrated that such fuels supply the
only heat available to the person burning them. The suspension
shall remain in effect until all episode stages have terminated".
(Washoe County, 1984; part 050.015)
A copy of the Emergency Episode Plan is included in Appendix B.
The strengthening revisions adopted in October 1984 lowered the
ambient pollutant concentrations at which the mandatory cessation of
RWC is to be triggered to those levels indicated above. These
correspond to the Stage I Alert level criteria in the Emergency
Episode Plan. At these lower trigger levels, Washoe County Health
Department staff who will enforce these rules expect four to five
curtailment days to occur in a typical winter season (Bonderson,
1984). Prior to this, only one curtailment day occurred (January,
1983) at higher trigger levels, which had been established at 75% of
stage II Warning levels (e.g., at 469 ug/m of TSP, and 22.5 ppm of
CO).
Stage I Alerts cannot be declared until pollutant concentrations which
exceed the trigger levels have actually been measured. However,
Health Advisories can be declared when pollution reaches 80% of the
3
Stage I Alert Level (i.e., at 12 ppm CO and 300 ug/m TSP).
Voluntary curtailment of RWC is requested under Health Advisories, and
public information announcements are increased to warn the community
that air pollution levels are increasing toward Alert levels.
On episode days, public notice of a Stage I Alert would be prominently
announced in the media. Health Department staff would immediately
begin patrolling and responding to complaints, and issuing information
packets to wood burners, on how to bum properly. After an Alert has
been declared, three hours is allowed for people to let their fires
burn down before any Notices of Violation would be issued. The number
V-60
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of agency staff available for surveillance and enforcement is so
limited that public notice and voluntary cessation of RWC is actually
relied upon for these episode controls to be effective.
Notices of Violation are intended primarily for flagrant violators.
The first, second and third violations of these episode regulations
during a period'of twelve consecutive months are considered "minor
violations", subject to fines of 325-50, $50-100, and $100-200,
respectively. Violation notices may be appealed to a Hearings Board,
or to the Washoe County District Board of Health, which ultimately
levies any fines.
In 1984, the first rigorous household survey of RWC was conducted for
the Reno/Sparks area, which indicated a much lower CO emissions
inventory attributable to RWC than bad been the basis for the AQIP
(Fitter et al, 1984). For example, the 52.7 tons of CO emissions per
winter day projected for 1987 from RWC was reestimated at 15.6 tons,
less than a third of the original estimate. EPA Region IX has also
recently indicated that it cannot agree to the proposed effectiveness
estimates for the three RWC control measures, as summarized above.
As a result, the area's CO control strategy must be reviewed. The
strategy's CO "design values" - i.e., the reduced CO emissions levels
that must be achieved by 1987 in order to project attainment of the CO
standards - have also been reduced. This is due to the lower total CO
emissions now estimated from all sources, as processed through EPA's
rollback procedures for establishing CO design values for SIP
development (Fitter et al, 1984).
However, after subtracting the CO emissions reductions projected in
the AQIP for proposed vehicular emission controls, the remaining CO
emissions reductions needed (21.2 tons/day) to achieve the new design
value is greater than the total CO emissions currently estimated f°r
RWC element. That is, if RWC CO emissions were eliminated entirely,
the CO design value would still not be achieved.
V-61
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While alternative RWC control measures are developed or refined,
Washoe County plans to conduct field studies this winter (1984-85)
which will directly assist their CO SIP development. One of these
will use radiocarbon analysis of CO samples to directly estimate the
relative contributions to elevated CO ambient levels from vehicle
exhaust versus RWC.
D. Approaches to Evaluation of the Potential Effectiveness of RWC Emissions
Control Measures
This section begins by providing an overview of pertinent considerations
in estimating the potential effectiveness of regulatory control measures
designed to reduce emissions and ambient Impacts from Residential Wood
Combustion (RWC). The use of dispersion and receptor modeling to evaluate
RWC control measures is briefly discussed. Evaluation of the following
types of control measures Is then discussed and illustrated: emission
standards for new wood stoves; weather izat ion of houses; wood moisture
controls; episode controls; and, public education. The role of a citizen
advisory process in developing and selecting control measures is also
briefly discussed.
1. Overview of RWC Control Measure Evaluation
Estimating the potential effectiveness of ary RWC control measure(s)
generally consists of analyzing the extent to which baseline RWC
conditions will be altered by implementing the measure(s). Baseline
RWC conditions, as Illustrated in Figure V-3, refer to the level of
present (and projected future) RWC wood usage, emissions and ambient
impacts which are estimated to exist in a locality, if no RWC control
measures are used. Section III.D of this document discusses how
household surveys and other approaches can be used to quantify RWC
wood usage and emissions, including projecting future RWC emissions.
Section IV of this document describes approaches for estimating
ambient RWC impacts using field monitoring and modeling methods.
V-62
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Assessing the effect on ambient pollutant concentrations is usually
the main goal in evaluating RWC control measures - e.g., to determine
how much a control measure(s) helps in attaining or maintaining
compliance with ambient air quality standards. Figure V-3 helps
visualize that this may involve first estimating how a control measure
would alter baseline wood usage or emissions. These would then be
translated into corresponding reductions in RWC ambient impacts using
appropriate RWC emissions factors or modeling.
The more completely local baseline RWC conditions can be
characterized, the better RWC control measures can be evaluated (and
targeted). As discussed in several sections of this document, some of
the parameters most useful for characterizing RWC conditions are
summarized in Table V-13.
As discussed in Section III.D, many of the parameters in Table V-13
are most reliably determined through local household surveys, because
of limitations Inherent in other approaches. In the absence of survey
information, some of the parameters in Table V-13 may have to be
estimated using best available local information and judgement. This
is because the first essential step in control measure evaluation is
quantitative characterization of baseline RWC conditions as completely
as possible.
Then control measures can be evaluated in terms of the estimated
changes they cause in various parameters such as those in Table V-13,
and how much these changes reduce RWC emissions. Subsequent
translation of estimated RWC emission reductions into improvements in
ambient air quality should utilize the best available models of the
local airshed. These may involve simple rollback models or more
complex dispersion models, as discussed in more detail in the
following subsection.
V-64
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TABLE V-13. Useful Parameters For Characterizing RWC Conditions
Ambient pollutant levels specifically attributable to RWC - e.g.,
ug/m^ of partlculates or ppm of carbon monoxide-preferably based
on chemical mass balance (CMS) or radiocarbon analysis, or on
dispersion models calibrated using such RWC tracer analyses.
Emissions Inventories for RWC pollutants, preferably based upon
quantification of some or all of the following types of parameters:
- Number of households which burn wood ;
- Average amount of wood burned per household ;
- Average household wood burning rates (e.g., In kg/hr) ; and,
- Pollutant emission factors for wood burning devices (e.g., In
g/kg of wood burned).
• The fraction of RWC wood usage or emissions associated with:
- woodburning for primary house heating, secondary house heating,
or burning for aesthetic purposes only ;
- major categories of wood burning devices, e.g., stoves,
fireplaces, Inserts, furnaces, etc.;
- Certain woodburning practices, e.g., starved air ("airtight")
burning vs higher burn rates; and,
- various demographic characteristics of woodburning households,
e.g., location, income, age, degree of weatherization, etc.
• Trend factors related to RWC activity levels, e.g.:
- population and household growth projections ;
- projected numbers of wood-burning devices by type, e.g., from
sales or construction forecasts ;
- price forecasts for wood and other fuels ;
- factors representative of wood use trends, e.g., wood cutting
permits Issued ; and,
- factors representative of trends in RWC emissions or ambient
Impacts, e.g., nephelometer (Bscat) data.
V-65
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The estimated benefits attributable to each control measure can then
be compared with estimated costs to implement each measure. For
example, the relative cost-effectiveness of various candidate measures
could be assessed in terms of dollar costs per unit of emission
reduction or per unit of ambient air quality improvements. It may
also be feasible to further translate these benefits into other
terms-e.g., improved visibility, or reduced exposure to toxic air
contaminants.
RWC control measures reduce emissions of all of the following
pollutants for which federal ambient standards or other regulatory
efforts exist:
• total suspended particulates (TSP);
• fine particulate matter, e.g., up to ten microns in particulate
diameter (PM1Q);
• carbon monoxide (00); and,
• certain toxic air pollutants, including polycyclic organic matter
(PCM) such as benzo(a)pyrene (B(a)P), or polyaromatic hydrocarbons
(PAH).
Most characterization of RWC impacts and controls to date have
involved particulates. However, EPA studies hav» identified RWC as
the single largest source nationally of POM emissions (Radian, 1983),
and a potentially significant source of CO emissions under certain
conditions (Nero and Associates, Inc., 1984). Thus, RWC control
measures ha\e multiple pollutant reduction benefits.
For localities with substantial wood bum ing activity, RWC may be an
especially important PM.Q emissions source. Virtually all RWC
particulate emissions are well below this particulate-size ceiling
(Watson, 1979; DeCesar and Cooper, 1981). RWC can account for
substantial total or fine particulate sample mass, and source activity
is concentrated during winter when meteorology is often poorest for
pollutant dispersion.
V-66
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Characterizing the effectiveness of some control measures is
inherently more speculative - e.g., the potential for public education
activities which promote cleaner wood burning practices to cause RWC
emission reductions. Subsection three below discusses factors to
consider in estimating RWC emissions reductions from five different
types of RWC control measures, Including public education.
Section V. B above described the findings of a Quantitative analysis of
generic RWC control measures. These are most useful as estimates of
relative particulate emissions reductions potentially available from a
wide variety of RWC control measures. These estimates cannot be
assumed to apply to any particular locality, although the approaches
used may be applicable.
Consideration of RWC control measures can be politically sensitive,
because many citizens may be directly affected. A local citizens
advisory committee can be especially helpful in formulating airshed
pollution control strategies which consider RWC control measures.
Subsection four below discusses the role and Importance of such a
citizens advisory process relative to RWC control selection.
In the early 1980's, the State of Oregon developed State
Implementation Plans (SIPs) for particulate matter for its three Air
Quality Maintenance Areas (AQMAs) - Portland/Vancouver, Washington,
Eugene/Springfield and Med ford /Ashland. All three contained RWC
control measures supported by quantitative technical analyses of RWC
wood usage, emissions and ambient Impacts. These are still the only
completed and EPA-approved SIPs which address RWC comprehensively.
Results of S IP-related analyses for the Med ford /Ashland AQ1A have been
published and were discussed in Section V.C.I.a above. These and
other Oregon SIP-related analyses are used to illustrate the following
discussions.
V-67
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2. Use of Dispersion and Receptor Models to Evaluate RWC Control Measures
Various receptor modeling and dispersion modeling approaches to RWC
analysis were described in Sections IV.C and IV.D respectively. This
section discusses the use of such models in evaluating candidate RWC
emission control measures.
Basically, the use of these models involves two steps: a) estimating
reductions in baseline RWC emissions attributable to the control
measure; and, b) translating these emissions reductions into the
corresponding reduction In ambient pollution levels using an
appropriate model. The estimated improvement in ambient air quality
is the ultimate measure of control strategy effectiveness in terms of
compliance with ambient air quality standards.
Dispersion modeling has been traditionally used for translating
emissions changes into corresponding changes in ambient air quality.
However, the recent development of Chemical Mass Balance (CMB)
receptor modeling described in Section IV.C, has introduced a powerful
new tool for analyzing Impacts from RWC and other sources In
conjunction with dispersion modeling.
CMB analysis of individual partlculate monitoring samples can
apportion total sample mass into contributions from RWC and other
sources. As Indicated in IV.C.5 and V.D.S.d, this enables validation
of particulate dispersion model predictions for individual emissions
source impacts, as well as for the combined particuiate impacts from
all sources. Previously, only the latter was feasible. This enables
refinements in individual source emissions databases, and/or model
adjustments, both of which should Improve the correlation of
dispersion model predictions with actual monitoring data.
In Oregon's SIP development, CMB analysis discovered unexpectedly
large particuiate Impacts from vegetative burning and soil dust area
sources. This prompted research Into defensible approaches for
improving emissions inventories for RWC and soil sources, as well as
V-68
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their geographic distribution for dispersion modeling purposes.
Spatially resolved emissions inventories for area sources such as RWC
and soil dust were developed using a 1-2 kilometer grid system.
As discussed in Section IV.D, models applicable to RWC analysis range
from simple proportional rollback and box models, to dispersion models
designed to simulate how emissions from many different point and area
sources are dispersed under the influence of local meteorology and
terrain. In Oregon, GRID cell models (see Section IV.D.2.b) were
developed for the Portland and Eugene area AQMAs. These were
considered more capable of simulating complex wind patterns in these
areas. Sufficient meteorological monitoring data were available to
satisfy GRID model requirements. The Medford area AQMA had the
highest RWC impacts, due to extensive RWC activity, and valley terrain
and wintertime meteorology which severely restricted pollutant
dispersion. However, since available meteorological data were
insufficient for the Eulerian grid cell model, a Gaussian model was
adapted for this AQMA (CDMQC, see Section IV.D.2.a). CMB analyses of
particulate monitoring samples were used to validate both types of
models in all three AQMAs.
For all three AQMA's, spatially resolved emissions inventories were
developed for area sources such as RWC and road dust. Household
telephone surveys in each area were used to estimate RWC wood usage
for stoves and fireplaces separately. These were converted to RWC
emissions estimates using RWC emissions factors developed from Oregon
source testing, coupled with GRID model and CMB findings, as discussed
in Section IV.D.2.b. Future RWC emissions were projected using short
term trend factors based on wood cutting permits issued by nearby
national forests, and longer term trends based on population
projections. For the Portland area, the results of a modeling study
of long term RWC wood usage (discussed in Section III.D.S.d) was used
to project future baseline RWC emissions.
V-69
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Calibrated grid cell or CDMQC models were used in all three ACtfAs to
evaluate potential RWC control measures in the following way.
Basically, two model runs were compared: both represented the same
time period and set of conditions, except that different RWC emission
database Inputs were used. One model run used baseline emissions for
all sources including RWC. The other used baseline emissions minus
RWC emissions reductions attributed to a control measure(s). The
resulting differences in model-predicted ambient pollutant levels at
various monitoring sites were the principal indicators of RWC control
measure effectiveness.
In this manner, various RWC control measures, and combinations of
control measures for RWC and other sources, were tested for each AOMA
in Oregon. Both the annual and shorter term average pollutant levels
were modeled, under average and worst case meteorological conditions.
The implementation costs, and energy use implications, of candidate
controls were assessed. In consultation with a citizens advisory
group in each AQMA, air pollution control agencies selected, a package
of proposed control measures for RWC and for other particulate sources
as the basis for their SIPs. The RWC controls selected for the
Medford-Ashland AQMA are summarized in Table V-8, and further
described in Tables V-9, V-10, and V-ll.
Table V-8 indicates estimates of reductions in annual average TSP
concentrations attributed to five different RWC control measures based
on dispersion modeling. Uncertainty in such dispersion modeling
evaluations will vary primarily with: a) how satisfactorily the model
simulates the spatial and temporal distribution of emissions and their
dispersion under the influence of local meteorology and terrain; and,
b) the level of uncertainty in the emissions changes attributed to the
RWC control measures and used as model inputs. The former type of
uncertainty can be addressed by validating dispersion model estimates
against ambient monitoring (especially CMB) data over a range of
meteorological conditions. The latter type of uncertainty can be
addressed through studies to better characterize RWC emissions, e.g.,
V-70
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through spatial (e.g., grldded) and/or temporal (e.g., day/night)
resolution of emissions input data. Sensitivity analysis can also be
conducted, using a range of emissions estimates (resulting in a range
of potential air quality improvements).
Substantial time, resources and adequate supporting data and special
studies are required to develop more complex dispersion models of the
type described above. The payoff lies In their capability to more
reliably characterize the Impacts of sources such as RWC. This
minimizes the chances of faulty targeting of pollutant control
measures, the costs of which could be substantial.
For example, Oregon's SIP related studies revealed the need for more
emphasis on controls for area sources, such as RWC and road dust, and
less emphasis on Industrial emission controls. Database development
and modeling efforts were essential in developing an understanding of
the magnitude of RWC impacts, and the potential effectiveness of
various RWC control measures. Without such knowledge, and facing
continuing exceedances of particulate standards, Oregon's past
emphasis on industrial point source controls might have continued to
be the main focus of Its particulate control plans. Instead, each
AQMA was able to justify and develop a package of control measures
which targeted both selected area sources as well as particular
industrial sources. These were considered most cost effective based
on various SIP related studies, which helped define the primary
sources of particulate emissions (as illustrated In Figure V-l).
As discussed In Section IV.D analysis of RWC impacts should begin with
simple screening models, and progress to more refined models, If
preliminary Impact assessment warrants the additional effort.
Localities with particulate non-attainment problems and very limited
resources and/or monitoring data may have to rely on simpler modeling
efforts - e.g., proportional rollback or box models (see Section
IV.D.2.c). CMB analysis of even a few selected particulate filters
would also be very useful In Identifying the relative Impacts from
various local sources (and background), as well as In validating a box
model.
V-71
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Even when simple models are used, characterizing emissions from RWC
and other major sources will still be required. Estimated reductions
In emissions for control measures will still govern the potential
improvements In ambient air quality projected by the simpler models,
as they do for more refined models.
3. Evaluating Potential Emissions Reductions from RWC Control Measures
This section discusses some of the main considerations Involved in
estimating potential emission reductions achievable from the following
types of RWC control measures:
• emissions standards for new woodstoves;
• home weatherizatlon;
• wood moisture controls;
• episode controls; and,
• public education.
This Is not an exhaustive listing, but contains most of the major
types of RWC control measures likely to be of Interest to most
localities.
a. Emissions Standards for New Woodstoves
Examples of this RWC control measure are Oregon's statewide
mandatory woodstove certification program (described In Section
V,C.l.b), and the New Source Performance Standard (NSP3) for
woodstoves currently under development by the U.S. Environmental
Protection Agency. These standards will limit permlssable
emissions rates from new stoves to much lower levels than the
average emissions rates of existing stoves. As described In
Section V.C.l.b, Oregon's Department of Environmental Quality
estimates that Its standards (Table V-12) will reduce baseline RWC
emissions by 70-74% over the 10-20 year period required for
certified stoves to largely replace existing stoves. This was
based on an estimated average emissions rate from existing stoves
In Oregon of 30-34 grams per hour compared to certified stoves,
which should not exceed nine grams per hour after 1988.
V-72
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Areas considering adoption of this type of control measure may
need to estimate potential emissions reductions at different
points during its implementation. Achievable reductions in
emissions for a future year would primarily be a function of the
following factors:
• growth (or decline) projected in the number of operating stoves
in a baseline year;
• replacement rate of existing stoves with certified stoves; and,
• the difference in average emissions between baseline and
certified stoves, which is governed by the emission standard
selected.
The percentage of stoves certified at any given time is a function
of the rate at which new stoves are purchased and the portion of
these which replace existing stoves. The replacement rate depends
primarily on average stove life. Market penetration rates for new
stoves must decline as available markets become saturated, but may
also rise rapidly during a period of booming interest in RWC as a
primary or secondary home heating source. If purchase of a
certified stove is optional, price differences between certified
and non-certified stoves would be a major factor governing the
market penetration by certified stoves.
For a given year, an estimated fraction of all stoves which are
certified, multiplied by the estimated difference in average
emission rates between certified and non-certified (baseline)
stoves, Is one approach to quantifying achievable emissions
reductions. Since average stove life may be 10-20 years, this
control measure achieves increasing emission reductions over many
years. RWC emissions reductions will be greater for mandatory
woodstove certification measures than virtually any other
practicable control measure, because baseline stoves will be
replaced with cleaner burning models at a maximum rate. If
purchase of certified stoves Is not mandatory, or some level of
non-compliance is anticipated, estimated annual emissions
reductions"will be correspondingly lower.
V-73
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Thus, key assumptions in quantifying reductions in emissions
Include: a) average baseline emission rates for existing stoves
(average rates for certified stoves can be assumed to be equal to
the emission standard); b) average stove life; and, c) the number
of stoves operating in future years, and the percentage of these
which are certified.
b. Home Weathertzation
Weatherizing houses generally reduces the amount of space heat
(fuel) needed to maintain indoor temperatures at a given
temperature level. Thus, weatherization could reduce wood usage,
and hence, RWC emissions would decrease. The extent of reduction
in emission will depend primarily upon: a) the number of wood
burning houses which are weatherized; b) the change in energy
efficiency resulting from weatherization (i.e., the magnitude of
decrease in the heating fuel use expressed in Btu or equivalent
units); and, c) how weatherization affects the installation and/or
operation of woodstoves or other RWC appliances particularly when
the woodburning is not a primary source for space heating.
The last factor is difficult to assess, and can cause substantial
uncertainty in evaluating the effectiveness of home weatherization
as an RWC control measure. For example, when homes heated
primarily with wood are weatherized, their wood usage could be
reduced In proportion to their reduced heating demands. This
could be as much as a 30-50% reduction for a fully weatherized
home (Table V-9). However, homes heated with wood as a secondary
fuel prior to weatherization might reduce their reliance on their
primary fuel (e.g., gas, oil, electricity), while maintaining or
even Increasing their wood usage. Some non-wood burning
households might weatherize and add RWC capability in order to
reduce conventional fuel costs.
Owners of houses weatherized prior to installing a woodstove,
could select a smaller stove (than they would have prior to
weatherization) to heat the same space. This could increase use
'of stoves with smaller fireboxes, which tend to be cleaner burning
V-74
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(Section III.B.5). However, If wood burning houses which
weatherIze have to decrease their burning rates, to avoid
overheating the home, their average RWC emissions may Increase.
This could be especially true If stoves are operated more In an
airtight mode after weatherlzatlon. However, catalyst-equipped
stoves may not tend to Increase their emissions at lower average
burn rates (Section III.B.I).
uncertainty about how weatherlzatlon could affect woodburnlng In
weatherlzed houses could be reduced by surveying such households.
Characterizing existing wood usage In terms of how much Is for
primary and secondary space heating, or the extent to which wood
burning households are already weatherIzed, would also help
determine potential RWC emissions reductions from weatherizatlon.
If a substantial fraction of houses in a wood burning community
are not yet weatherlzed, the- potential RWC emissions reductions
attributable to an extensive weatherizatlon program would be quite
significant.
In Medford, Oregon, weatherlzatlon ranked behind only mandatory
emissions standards for new woodstoves in terms of potential RWC
emissions reductions achievable (Table V-9). The RWC control
measures included In the 1983 Medford area SIP relied most heavily
on weatherlzatlon (Table V-8), because Oregon's statewide
mandatory woodstove certification requirements had not yet been
adopted.
Projected reductions In emissions in the Medford area corresponded
to an ambitious weatherization goal, established by local
government, of weatherizing all residences to cost-effective
levels within five years (by January 1, 1987). If weatherization
was not proceeding satisfactorily on a voluntary basis with
incentives, It was to be required as a condition of sale or rental
after January 1984. It was estimated that 70% of local homes
needed additional weatherlzatlon. A local utility estimated that
an average reduction in space heating demand of 40% was achieved
V-75
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by homes In Its weatherIzatlon program (Oregon DEQ 1983a). For
the two weatherization control measures quantitatively evaluated
In Table V-8, eslmated reduction In partlculate emissions from RWC
were approximately 300 tons/year and 500 tons/year respectively
(Oregon DEQ, 1981d).
Wood Moisture Controls
Seasoning firewood reduces Its moisture content, which Increases
Its heating value, due to less heat energy dissipated In
vaporizing water In the wood. Seasoning can also reduce
partlculate emissions per pound of wood burned, under certain
circumstances, Partlculate emissions can be higher from wetter
wood, presumably because the additional steam In the combustion
area reduces combustion zone temperatures, resulting In less
complete combustion of the wood. The combination of these two
potential benefits • of lowering firewood moisture content have
prompted efforts to promote better wood seasoning as an RWC
pollution control measure.
However, as discussed In Section III.B. 3 current Information Is
very limited upon which to base general relationships between
firewood moisture content and corresponding wood combustion
emissions for various RWC pollutants. Work by Shelton also
Indicates that such relationships may be different for wood burned
In stoves and fireplaces (Shelton, 1981).
Shelton estimated that fireplace combustion efficiency declined
steadily as wood moisture content Increased (Figure III-5).
However, he also found that woodstove combustion efficiency peaked
for wood moisture contents ranging from 20%-25% (wet basis), In
limited testing. The latter finding Implies higher pollutant
emissions on either side of this range. A subsequent study by
others similarly found an optimum wood moisture content range of
20-26% (wet basis), based on stove test results Illustrated In
V-76
-------
Figure III-4 (U.S. EPA 1984b, Task 4). Thus, the effectiveness of
wood moisture control strategies should Ideally consider fireplace
and stove wood usage separately. Unfortunately, the information
needed to do this properly is generally lacking.
To evaluate potential emission reductions achievable from firewood
moisture controls generally calls for information about parameters
which include: a) average wood moisture content before and after
control measures are implemented; b) the amount of wood usage
affected by control measures; and, c) a quantitative
relatlonship(s) between wood moisture content and heat energy
content and/or pollutant emissions per pound of wood burned.
Wood moisture controls were included in the SIP developed for the
Medford, Ashland, Oregon area (Oregon DEQ, 1983a). Household
surveys indicated that: a) over 40% of the firewood in the area
was cut in the fall; b) 52% of wood burning households seasoned
their firewood for six months or less; and, c) 25% seasoned it for
three months or less. Controls were designed to encourage 6-8
months minimum seasoning prior to burning. These included: a)
vigorous public education on proper seasoning of firewood; and, b)
working with public forest agencies to shift firewood cutting to
spring, both for the public and for commercial cutters if
poss ible.
The Medford-Ashland SIP claimed that "firewood seasoning programs
are expected to reduce the amount of firewood burned and
particulate emissions by 10% in the Medford area by 1984." While
this estimate was not documented in the SIP, supporting technical
documents indicate that the following assumptions were involved
(Oregon DEQ, I981d.)
• Typical moisture contents of wood, related to seasoning and/or
storage conditions, Include the following:
- 40-50% moisture in fresh cut, "green" wood;
V-77
-------
- 35% moisture in Douglas Fir logging residues after six
months outdoor exposure, including a rainy winter season;
and,
- 15-20% moisture in well seasoned wood stored in a very dry
location
• The average moisture content of wood used in the Medford area
was assumed to be 25-30%.
• Wood moisture content and relative heat energy content were
assumed to vary as shown in Table V-14.
Based on the SIP assumptions In Table V-14, heating with wood with
20% moisture content produces 31% more heat than using wood with
30% moisture content (88-67 * 67 « 31). Thus, a household heating
with 20% moisture content firewood, would use 31% less wood fuel,
to produce the same amount of heat, than a household using 30%
moisture content wood.
The drier wood should also burn with less particulate emissions
than the wetter wood, although how much less is difficult to
determine. If it is assumed that the drier wood affords 20% less
particulate emissions, then an overall emissions reduction of 45%
can be attributed to seasoning wood from 30% to 20% moisture
content: (100% - 31%) x .8 - 55% of emissions attributable to 30%
moisture content wood. Thus, even if only 20-25% of RWC
households accomplish this, total RWC particulate emissions would
be reduced by about 10%.
d. Episode Controls
As described in Section V. C, a number of the localities have
already adopted RWC controls which Include voluntary and/or
mandatory curtailment of wood burning during episodes of high
pollution. Estimating reduction in emissions associated with such
episode controls requires the following types of Information: a)
the number of episode days per heating season; b) the degree of
V-78
-------
TABLE V-14. Impact of Moisture on Relative Heat Content of Firewood
Wood Moisture Relative Heat
Content (%) Content
10% 1.00
20% .88
30% .67
40% .59
50% .47
* Wet basis, i.e. 10% moisture content = 10 Ib. water
10 Ib. water + 90 Ib. wood
Source: Oregon DEQ (1981d)
V-79
-------
anticipated compliance with voluntary and/or mandatory curtailment
requests - e.g., the percentage of wood burning households which
cease burning, or reduce burning by a specific amount; and, c)
the percentage of wood-burning households with no alternative heat
source, since such households are less likely to comply, and are
often exempted from episode control requirements, at least
initially.
In the Medford RWC control strategy, episode controls consisted of
several elements, as follows: a) voluntary curtailment during Air
Stagnation Advisories (ASAs), estimated to occur 10-40 times per
year; b) mandatory curtailment during exceedances of the primary
3
(health related) particulate standard of 260 ug/m (24-hour
average), which were occurlng about 5-15 times per year In Medford
in 1980; and, c) mandatory curtailment during ASA's, If the
primary standard was not attained by January, 1984.
Table V-8 Indicates, that these episode controls were estimated to
be about two-thirds as effective In reducing RWC particulate
levels as firewood moisture controls. The following hypothetical
analysis would result In a slmlllar level of effectiveness.
Assume that the heating season runs from October through March
(180 days), during which 25 Air Stagnation Advisory days occur.
Assume that on ten of these days the primary standard Is exceeded,
resulting In mandatory curtailment, which Is 80% effective (I.e.,
wood burning Is reduced by 80%). Assume that voluntary
curtailment Is requested on the other fifteen ASA days, and Is 25%
effective. Over the course of this heating season, RWC emissions
would be reduced to 93.5% of what they could have been without
these episode controls (180 - 10(.8) - 15(.25) - 93.5% of 180.)
If RWC emissions on episode days are higher than the average dally
emissions during the heating season, the episode controls would be
even more effective.
V-80
-------
Thus, curtailments would reduce seasonal total RWC emissions by at
least 6.5%, with reductions concentrated on days with the worst
pollution levels. The major uncertainties in this analysis are
the number of episode days and the degree of compliance by the
public.
e. Public Education
An important part of any effort to control RWC emissions is
educating the public about the need for RWC controls, and what
they can do to help. Public education efforts can promote a
variety of public actions which can reduce RWC emissions.
Examples include: a) proper operation of existing stoves and
fireplaces, b) proper seasoning of firewood, c) properly sizing
new stoves to the space to be heated, d) how to recognize and
respond to pollution episodes; and, e) benefits of home
weather izat ion.
The effectiveness of any public education effort is aimed at
reducing RWC emissions depends upon: a) the percentage of the
affected population taking action; and, (b) the effectiveness of
these action(s). Neither of these two factors can be measured,
except perhaps by extensive surveys, which may still not provide
accurate estimates. Unlike advertising, which can be evaluated
based on sales of the advertised product, measures of public
response to RWC educational efforts could be elusive.
Estimation of potential emission reductions attributable to public
education programs would require assumptions about changes in
behavior which could not be confirmed. To make justifiable
assumptions would require a fairly detailed description of RWC
households in terms of their wood burning habits and demographic
characteristics. Thus, it is more practical to treat public
education as a vital activity, supporting other RWC control
measures, without attributing emissions reductions to it. This
approach is reflected in Table V-8.
V-81
-------
4. The Importance of a Citizens Advisory Process
EPA regulations require Involvement of the general public, certain
special interest groups, local and areawlde governmental
organizations, elected officials of local governments, state agencies
and the State Legislature, and Federal land managers in the
development or revision of State Implementation Plans (SIPs). The SIP
must describe how this was carried out, significant Issues raised by
such participants, and how these were disposed of (40 CFR 51.252,
1983).
A citizens advisory group can render valuable assistance in SIP
development in many ways. They can review detailed agency staff
analyses and proposed control measures, and provide advice and opinion
which represents a broad spectrum of community interests and
viewpoints.
This process can be especially useful where proposed control measures
are controversial. Regulation of HWC and other area sources, which
directly affect everyday activities of the general public, can be much
more controversial than industrial controls, which usually affect the
public indirectly, if at all.
For example the Medford RWC control strategy relied most heavily on
home weather ization, including a. requirement that cost effective
weatherization be completed within 90 days of installing any space
heating device using solid fuel such as wood. Despite strong
opposition, due to its initial cost and mandatory nature, the Jackson
County Air Quality (citizens advisory) committee recommended approval
of this partial late control strategy element. It was eventually
enacted by county ordinance (Appendix B; Ordinance 82-6).
In all three Oregon Air Quality Maintenance Areas, citizens advisory
committees have played major roles in SIP development. All such
committees have endorsed RWC controls as elements of SIP strategy.
V-82
-------
Each of these committees was active over a period of six months or
more. Each faced internal disagreements, and often sharply questioned
agency staff. The advisory process afforded an effective forum to air
various issues and concerns, and to identify further documentation
needed from the agency staff. The agency gained support for its SIP
by taking time to explain local pollution data and problems, as well
as proposed solutions and options.
V-83
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VI-7
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VI-12
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VI-13
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VI-14
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VI-16
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APPENDIX A
Information Related to RWC Household Surveys
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APPENDIX A
Information Related to RWC Household Surveys
This Appendix contains the following information related to RWC household
surveys developed by the Oregon Department of Environmental Quality
(DEQ), 522 S.W. 5th Avenue, Portland, Oregon 97204.
Contact persons: a) John Kowalczyk, 502-229-6459
b) Marianne Fitzgerald 503-229-5353
Contents
1. "Survey Design and Costs" (undated)
2. Excerpts from presentation entitled "Creating an Inventory"
by Ms. Carol Cummings of DEQ, to "Residential Wood and Coal
Combustion Workshop" November 30, 1983, Portland, Oregon,
including:
a. "Summary Outline" of workshop presentation
b. "Sample Size Calculation", for mailback questionnaires
c. "Sampling Errors at a 95% Level of Confidence for Various
Percentages and Sample Sizes, Assuming a Simple Random
Sample", also for mailback questionnaires.
d. Sample calculation of RWC emissions from survey findings, for
Portland, Oregon, 1982.
3. Cover Letter and sample questionnaire for a 1985 household RWC
Survey by DEQ in Medford, Oregon.
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Survey Design and Costs
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SURVEY DESIGN AND COSTS
Below is an outline of survey design and cost factors to be considered
prior to doing a survey by mail. This summary is based on experience
gained from the first DEQ wood heating surveys completed in Portland
and Medford in 1981 and 1982.
SURVEY PLANNING
1. Outline the objectives of the survey and determine the uses for the
data to be gathered, for example emission inventory, planning,
tracking trends.
2. Select a few individuals to help with the question design and review
process, preferably including staff who will use the data most, as
well as someone from data processing and public affairs.
3. After drafting the questionnaire, send it to an outside researcr.
agency Csuch as Northwest Attitudes) for review. They can provide
valuable information and comments at a fairly low cost ("^SlOO) and
help avoid future problems with data reliability.
4. Do an in-house questionnaire pre-test using a few randomly selected
staff (^20). Have them fill out the questionnaire and comment on
any problems they found with the survey.
5. Allow approximately 1 month for survey design and review prior to
mailing.
DETERMINING SAMPLE SIZE
1. According to Northwest Attitudes, for statistically reliable results
(95% confidence level), it is necessary to have at least 400 completed
questionnaires returned from a selected random sample.
2. To calculate the number that needs to be mailed, consider:
a. a 30-35% return rate can be expected.
b. If you are interested in information about a particular sub-croup
of individuals from the survey population (ex. woodburners),
then you must receive 400 completed questionnaires from this
sub-group.
3. An example of determining sample size for the Portland wood heati-ig
survey:
a. Needed 400 completed questionnaires from people who burn wood.
b. Assumed that 50% of the population burn wood, then we needed at
least 800 questionnaires returned.
c. Assuming a 30-35% return rate, we needed to send at least 2G66
questionnaires or "-3000.
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4. Contact a few mailing list companies (ex. Statewide Mailing Lists)
and find out how much they charge forpre-sorted random mailing
lists with detachable (Avery) labels. Have purchase order made
up and sent to them along with a request for the number of copies
of the list (usually 2), the number of names to be selected, the
zip codes or areas they are to be sent to and whether you want
only single family dwellings or all residences (including apartments).
Allow 1 week for delivery.
5. Notify the mail room as soon as the sample size and date of mailing
are determined, to allow them enough time to plan ahead for xeroxing
and mailing. Make sure they have enough business reply envelopes
on hand for the return mailing. Allow 1 week for xeroxing and mailing
of the survey.
ESTIMATING SURVEY COSTS
1. Mailing Lists: (Using Avery labels, Statewide Mail List Co.)
- $20/1000 names for first copy
- $18/1000 names each additional copy.
- Cost for Portland survey (3 copies of 3000) = $168
2. Survey Review: (Northwest Attitudes)
- Cost for Portland survey = $100
- This included a 1 hour meeting with staff to discuss their comments
and provide suggestions.
3. Materials:
- Paper .007$/page
- Envelopes 2$/DEQ and business reply
- Colored report covers 2C/sheet
- Cost for Portland survey ^$210
4. Postage:
- Pre-sorted mail 17*/envelope. '* <" T< '" ,^'7-fin rtiflivA refcW
- Return postage 25C/business reply
- Cost for Portland $737
Approximate cost (not including personnel time) for a survey of 30CG = S1250
to $1300.
SURVEY DESIGN
Attached is a copy of the Portland questionnaire as an example of survey
format.
1. The cover letter should be personalized as much as possible. It .should
brief]-/ outline the purprse of" the .-survey and stross the importance of
participation. Also includo an explanation of how to return the
questionnaire, the date to be returned by, and the- confidentiality of
-------
-3-
of the responses. You should give a person and phone number to contact
in case of questions.
2. The questions and possible responses should be numbered and brief with
an explanation of how to answer after each questions. The simpler the
better (ex. circle the number of the response).
3. Ideally, all possible responses should be listed, write-in answers can
cause interpretation and data processing problems.
4. A few demographic questions such as zipcode, age, income, nunber of
household occupants should be included, to give an indication of the
randomness of the sample.
5. A note at the end of the questionnaire thanking the respondents for
their participation as well as how to get copies of the results is a
good idea.
DATA PROCESSING
Allow approximately 3 weeks from the date of mailing for questionnaire
returns.
1. Contact data processing for help in developing screen formats or programs
to handle the data entry. Allow at least one week to develop the forr.at
and programs and plan to use the questionnaire pre-test data to test them.
2. Notify those who will help with data entry and Quality Assurance prior
to survey return. Allow about 2 weeks for data entry and QA.
SURVEY COMPLETION
1. Allow about 2 weeks for data processing and summary (if using SIPs on
the Harris).
2. Allow 2 weeks for writing the final report, copying and distribution.
3. Work with public affairs to make up a survey summary sheet,if general
distribution is expected,to save costs.
4. The total amount of time that can be expected to complete a survey is
about 3-4 months. This allows approximately 1 month for planning and
design prior to mailing, 1 month to receive the questionnaires and
for data entry, and 1 month for data analysis and final report completion.
-------
Excerpts from Presentation entitled "Creating
an Inventory" by Ms. Carol Cummings of DEQ, to
"Residential Wood and Coal Combustion
Workshop" November 30, 1983, Portland, Oregon
-------
C :
RESIDENTIAL WOOD AND COAL COMBUSTION WORKSHOP
CREATING AN INVENTORY - SUMMARY OUTLINE
Carol Cummings
Oregon Department of Environmental Quality
Wednesday, November 30, 1983, 1:30 p.m.
1. Air Pollution from RWC (Residential wood Combustion)
a. Airshed Studies in Medford and Portland, Oregon
b. Increasing Nephelometer and CO in Residential Areas
2. Annual Wood Heating Surveys
a. Medford - 1981, 1983
b. Portland - 1982
c. Eugene - 1982
3. Objectives of Wood Heating Surveys
a. Creating an Emission Inventory
— Mo. of Devices (Woodstoves, inserts, fireplaces)
— No. of cords burned per year by device
— Age of device
— New and Replacement devices
b. Trends, Education, and Controls
— Purpose of wood heat (Primary, supplemental, recreational)
— Device operation rate and time
-- Source and type of wood
~ Wood seasoning
—- Home insulation
Comments
c. Demographics
— Age of respondent
Home ownership
-- Length of residence
— Income
4. Mail vs. Phone Survey
a. Cost
b. Length of Survey
5. Survey Design
a. Cover Letter
— Personalize
— Confidential
— Contact for questions
Clo.sir.g r.i'.'-.G of survey
-------
Creating an Inventory - Summary Outline Page 2
b. Format
~ Directions for responding
— Organization
~ Request for results
6. Sample Size
a. Reliability of Results
b. Response Rate
c. Assumptions about Population
7. Survey Checks
a. Outside Review
b. In-house Pre-test
8. Survey Mailing
9. Data Processing
a. Quality Assurance
b. Statistical Package for Analysis
10. Survey Results
a. Portland, Oregon
b. Medford, Oregon
11. Information for Emission Inventory
a. No. of Households
b. Percent (\) households with Each Type Wood Burning Device
c. No. Cords Burned per Year in Each Device
d. Emission Factors for Woodstoves and Fireplaces
12. Calculation of Emissions
a. Woodstove and Insert Emissions
b. Fireplace Emissions
13. Problems in Inventory Process
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Cover Letter and sample questionnaire for a 1985
household RWC Survey by DEQ in Medford, Oregon
-------
VICTOR ATIYEH
OOVtnuon
Department of Environmental Quality
522S.W. FIFTH AVENUE, BOX 1760, PORTLAND, OREGON 97707 PHONE (503)229-5696
May 3, 1985
Dear Resident:
The Department of Environmental Quality (DEQ) is conducting a survey to
gather more information about home heating patterns and use of wood burning
equipment of residents in the Medford area. The results of this survey
will be used by the DEQ Air Quality Division for educational and planning
purposes.
Your household is one of a small number in which people are being asked
about home heating and wood burning. It was selected in a random sample of
the entire area. So the results will be representative of the Medford
area, it is important that each questionnaire be completed and returned.
Information from individual households will be kept strictly confidential.
We ask that you fill out the enclosed questionnaire and return it to us on
or before May 31, 1985. A self-addressed, prepaid envelope is enclosed
for your convenience.
Your cooperation is appreciated. If you have any questions, please contact
Marianne Fitzgerald at 229-5353, or call toll free, 1-800-452-4011. Thank
you for your assistance.
Sincerely,
U/0
Fred Hansen
Director
MEF:n
AA3240
DEQ-1
-------
10.85 MEDFORD AREA WOOD HEATING SURVEY
Please read the following questions carefully and circle, or write in the
answer as indicated. Your cooperation is appreciated.
1. Your zipcode? (Please indicate in space below.)
2. Do you own or rent your home? (Please circle number of answer.)
1. OWN
2. RENT
3. What type of residence do you live in? (Circle number.)
1. SINGLE FAMILY HOME
2. APARTMENT OR DUPLEX
3. CONDOMINIUM
4. MOBILE HOME
4. How long have you lived at your present address? (Circle number.)
1. LESS THAN 1 YEAR
2. 1 TO 2 YEARS
3. 2 TO 3 YEARS
4. 3 TO 4 YEARS
5. 5 YEARS OR MORE
5. Which of the following areas are insulated in your home?
(Circle numbers of all answers that apply.)
1. CEILINGS
2. WALLS
3. FLOORS
4. STORM/THERMAL WINDOWS
5. STORM DOORS
6. WEATHER STRIPPING/CAULKING
7 DON'T KNOW
8. NONE
6. How many people live in your home? (Indicate in space below.)
PEOPLE
7. What was your total household Income in 1984, before taxes?
(Circle number.)
1. LESS THAN $10,000
2. $10,000 TO $19,999
3. $20,000 TO $29,999
4. $30,000 TO $39,999
5. $40,000 TO $49,999
6. $50,000 OR MORE
-------
1Q85 MEDFQRD AREA WOOD HEATING SURVEY •
8. Your present age Is? (Circle number of answer.)
1. LESS THAN 25 YEARS OLD
2. 25-34 YEARS
3. 35-44 YEARS
4. 45-54 YEARS
5. 55-64 YEARS
6. 65 AND OLDER
9. Which of the following fuel types do you use to heat your home?
(Please put the corresponding number in the appropriate space.)
MAIN SOURCE OF HEAT 1. NATURAL GAS
2. WOOD
SECONDARY SOURCE OF 3. ELECTRICITY
HEAT (IF ANY) 4. OIL
5. PROPANE
ADDITIONAL SOURCE 6. KEROSENE
OF HEAT (IF ANY) ?. SOLAR
8. TRASH/PAPER
9. OTHER
10. Do you burn wood in your residence? (Circle number.)
1. YES
2. NO
11. Have you installed a new or replacement woodstove or stove-like
fireplace insert during the past year? (Circle number.)
NEW APPLIANCE REPLACEMENT APPLIANCE
1. YES 1. YES
2. NO 2. NO
12. Have you installed a new woodstove or stove-like fireplace insert
during the past two to five years? (Circle number.)
1. YES
2. NO
13. Do you plan to install any new or replacement woodburning equipment
in the next two years? (Circle number.)
NEW EQUIPMENT REPLACEMENT EQUIPMENT
1. DEFINITELY 1. DEFINITELY
2. MAYBE 2. MAYBE
3. NO 3. NO
If you plan to purchase a new or replacement woodstove, please refer
to the list of informational brochures and publications available from
DEQ on page 6.
- 2 -
-------
10.85 MEDFORD AREA WOOD HEATING SURVEY
IF YOU BURN WOOD, PLEASE ANSWER THE FOLLOWING QUESTIONS. IF NOT, PLEASE
RETURN THE QUESTIONNAIRE IN THE RETURN ENVELOPE. THANK YOU FOR YOUR
COOPERATION.
14. Do you burn wood primarily for: (Circle one number.)
1. MAIN SOURCE OF HEAT?
2. SUPPLEMENTAL SOURCE OF HEAT?
3. ENJOYMENT?
15. How many cords of wood did you burn this heating season (October 1984 -
April 1985)? A cord is a stacked pile 4 feet high, 4 feet deep, and 8
feet long. (Please indicate amount burned below.)
„. CORDS
16. How much wood did you burn last heating season (1983-84) as
compared to this heating season (1984-85)? (Circle number.)
1. MORE
2. SAME
3. LESS
4. NONE
17. How much wood do you expect to burn next heating season (1985-86)
as compared to this heating season (1984-85)? (Circle number.)
1. MORE
2. SAME
3. LESS
4. NONE
18. Please mark the appropriate responses to the following questions.
Which of the following
wood heating devices
do you have?
(Circle yes or no.)
FIREPLACE (WITHOUT
STOVELIKE INSERT)
FIREPLACE (WITH
STOVELIKE INSERT)
WOODSTOVE
WOOD BURNING FURNACE
WOOD COOKSTOVE
OTHER (PLEASE SPECIFY)
How many devices
do you have?
(Write in
number below.)
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
Age of each
device?
(Write in
age below.)
YEARS
YEARS
YEARS
YEARS
YEARS
Total number
of cords
burned per
year in each
device?
(Indicate
below.)
CORDS
CORDS
CORDS
CORDS
CORDS
- 3 -
-------
1985 MEDFQRD AREAJtOOD JiEATIffiL SURVEY
19. If you use a woodstove or fireplace insert, in which position is the intake
air control set most of the time? (Circle number.)
1. LOtf (0 TO 1/3 OPEN)
2. MEDIUM (1/3 TO 2/3 OPEN)
3. HIGH (2/3 TO FULLY OPEN)
20. If you have a woodstove or fireplace insert, what kind of air intake control
do you have? (Circle number.)
1. AUTOMATIC
2. MANUAL
21. What percent of the following type(s) of firewood do you burn most often?
(Circle the numbers of all answers that apply and indicate approximate
percent.)
i
1.
2.
3.
4.
5.
6.
7.
FIR
MADRONE
OAK
PINE
MAPLE
CEDAR
LUMBER OR
MILL SCRAPS
8. OTHERS (PLEASE SPECIFY)
22. What are the four most frequent times you burn wood? (Please put
corresponding number in the appropriate space below.)
1. MIDNIGHT TO 6:00 A.M...WEEKDAYS 6. MIDNIGHT TO 6:00 A.M...WEEKENDS
2. 6:00 A.M. TO NOON WEEKDAYS 7. 6:00 A.M. TO NOON WEEKENDS
3. NOON TO 6:00 P.M WEEKDAYS 8. NOON TO 6:00 P.M WEEKENDS
4. 6:00 P.M. TO MIDNIGHT..WEEKDAYS 9- 6:00 P.M. TO MIDNIGHT..WEEKENDS
5. ALL DAY WEEKDAYS 10. ALL DAY WEEKENDS
MOST FREQUENT TIME
SECOND MOST FREQUENT TIME
THIRD MOST FREQUENT TIME
FOURTH MOST FREQUENT TIME
23. If you have a woodstove or fireplace insert, approximately how many days did
you burn this heating season (October 1984 - April 1985)? (Circle number.)
1. UNDER 60 DAYS
2. 60-99 DAYS
3. 100-200 DAYS
4. MORE THAN 200 DAYS
- 4 -
-------
1985 MEDFORD AREA WOOD HEATING SURVEY
24. What was the average time (in hours) you burned during those days? Include
any tine there was a fire or burning coals in your stove. (Please indicate
in space below.)
HOURS PER DAY
25. Where do you obtain most of your firewood? (Circle the numbers of the
answer that apply.)
1. PURCHASED FROM A DEALER
2. CUT ON PERSONAL PROPERTY
3. CUT ON PRIVATE LAND (OTHER THAN OWN)
4. CUT ON STATE FOREST LAND
5. CUT ON FEDERAL FOREST LAND
6. LUMBER OR MILL SCRAPS
7. RECEIVED FROM FRIENDS, NEIGHBORS,
RELATIVES
8. OTHER (PLEASE SPECIFY)
26. If you purchased your firewood, what was the price you paid per cord?
DOLLARS PER CORD
27. If you cut your own firewood, what was the average round trip mileage to
gather wood?
MILES
28. If you cut your own firewood, during which of the following seasons do you
cut it? (Circle the numbers of the answers that apply.)
1. WINTER (DECEMBER, JANUARY, FEBRUARY)
2. SPRING (MARCH, APRIL, MAY)
3. SUMMER (JUNE, JULY, AUGUST)
4. FALL (SEPTEMBER, OCTOBER, NOVEMBER)
29. From the time of cutting to the time of burning, how long do you store your
firewood before burning? (Circle the number that is most typical for you.)
1. 3 MONTHS OR LESS
2. 4-6 MONTHS
3. 7-12 MONTHS
4. 1-2 YEARS
5. MORE THAN 2 YEARS
6. DON'T KNOW
30. Where do you store most of your firewood? (Circle number.)
1. INSIDE HOME
2. GARAGE OR SHED
3. COVERED OUTSIDE
4. UNCOVERED OUTSIDE
- 5 -
-------
10.85 MEDFQRD AREA WOOD HEATING SURVEY
31. Did you hear about the 20 day air stagnation advisory in Medford in
January, 1985 (January 10 to January 29)? (Circle number.)
1. YES
2. NO
3. DON'T REMEMBER
32. Did you discontinue woodburning as requested during this period?
(Circle number.)
1. YES
2. NO
3. DON'T REMEMBER
33. Is there anything else you would like to tell us about home heating and use
of wood burning equipment? If so, please use this space for that purpose.
YOUR CONTRIBUTION TO THIS EFFORT IS GREATLY APPRECIATED. IF YOU WOULD LIKE A
SUMMARY OF THE RESUL'iS, PLEASE CONTACT THE DEQ REGIONAL OFFICE IN MEDFORD AT
776-6010.
The following publications are available free from the Department of
Environmental Quality, Public Affairs Section, P.O. Box 1760, Portland, Oregon
97207, or from any DEQ Regional office. Call Public Affairs at 229-5317 in the
Portland area, or toll-free from other parts of the state at 1-800-452-4011.
1. Sizing Wood Stoves - How to match heating capacity to heating
needs (1985 brochure).
2. Certified Woodatoves - Describes Oregon's woodstove
certification program (1985 brochure).
_3. List of DEQ Certified Woodstovea - (Current).
_4. Catalytic Woodstoves - Describes this new type of woodstove (1985
brochure). «
_5. Burn Wood Better - Shows heat values and drying times for various
types of wood; shows how to operate a stove to reduce emissions.
MEF:n
AA3240
- 6 -
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APPENDIX B
Examples of Lavs, Regulations and Ordinances
Related to Control of Residential Wood Combustion (RWC)
-------
APPENDIX B
TABLE OF CONTENTS
1. Oregon
a. Medford
o Jackson County, Oregon, Ordinance No. 82-6, Partlculate Air
Pollution Control Ordinance of Jackson County", adopted August 25,
1982.
o Jackson County Ordinance No. 84-29, adopted Oct. 17, 1984
o "Information Concerning County Weatherization Requirements",
Jackson County Department of Planning and Development, Medford,
Oregon (1984)
o Letter "To the Realtors of Medford and Ashland", from Jack Davis,
of Davis, Ainsworth, Pinnock, Davis, and Gilstrap, Ashland,
Oregon, Nov. 6, 1984.
b. Oregon's Woodstove Certification Program
o"House Bill 2235",enactedby the 1983 Oregon Legislature, 1983
Regular Session
o "Proposed Adoption of Woodstove Certification Rules, OAR
340-21-100 Through 340-21-166 As a Revision To the State
Implementation Plan", June 8, 1984, memo to the Oregon
Environmental Quality Commission, from the Director, Oregon
Department of Environmental Quality. Attachments included:
- Draft rules for Woodstove Certification OAR 340-21-100 through
340-21-166.
- Oregon Department of Environmental Quality" Standard Method for
Measuring The Emissions and Efficiencies of Woodstoves"
- Miscellaneous Fact Sheets for Oregon's Woodstove Certification
Program:
"DEQ Woodstove Certification Program
Fact Sheet"
Woodstove Certification Program
Steps Toward Certifying a Stove in Oregon"
"Confirmation Testing Summary"
- "Example Calculation of Weighted Average
Emissions
o Summary of first nine woodstoves certified in Oregon, by the
Oregon Department of Environmental Quality, March 14, 1985.
2. Missoula, Montana
~o"Summary -Wood Burning Regulations", summarizes regulations adopted
Nov., 1983 and currently enforced by the Missoula City-County Health
Department
-------
APPENDIX B (Continued)
TABLE OF CONTENTS
o Exerpts from air pollution regulations of the Mlssoula City-County
Health Department
3. Colorado
a. Ski Commmunities
o Pitkin County (Aspen), Colorado, Resolution
No. 72-104, adopted by the Pitkin Co. Board
of County Commissioners, Aug. 22, 1977
o Pitkin County, Colorado, Resolution No. 83-7,
adopted, January 24, 1983*
o Vail, Colorado, Ordinance 24, related to
solid fuel burning devices; adopted by the
town of Vail, Colorado, August 5, 1983
o Beavercreek Resort Company Regulations
b. S ta t e Leve1 RWC Control Measur e s
o"HouseBill No.1187" enacted by the State of Colorado General
Assembly, April, 1984
o "Notice of Public Hearing to Consider a New Regulation of the
Colorado Air Quality Control Commission.." issued by Joseph
Palomba, Jr., Technical Secretary, Colorado, Air Quality Control
Commission, February 25, 1985.
o "Proposed New Regulation No. 4 - Woodstove Regulation", issued by
the Colorado Air Quality Control Commission, (undated).
4. Alaska (Juneau)
o Ordinance No. 84-30, enacted May 21, 1984 by the City and Borough of
Juneau, Alaska, which amends the woodsmoke areawide restrictions on
open burning and smoke density in the Mendenhall Valley area
o Ordinance No. 84-18, introduced April 2, 1984 for consideration by the
City and Borough of Juneau, Alaska, which amends the Building Code to
require minimum residential heating facilities of a type not involving
the combustion of solid fuels
o State Air Quality Control Plan, Section G, "Wood Smoke Pollution
Control," as revised 1983, by the Alaska Department of Environmental
Conservation
-------
APPENDIX B (Continued)
TABLE OF CONTENTS
o State Air Quality Control Plan, Section G, "Wood Smoke Pollution
Control," as revised 1983, by the Alaska Department of Environmental
Conservation
o Excerpts from Air Quality Control Regulations 18 AAC 50, of the Alaska
Department of Environmental Conservation
5. Reno, Nevada
o "Emergency Episode Plan", (as revised Oct. 1984) from the Washoe
County Air Pollution Control Regulations of the Washoe County Disrict
Health Department, Reno, Nevada
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MEDFORD
-------
OHOIKANCI NO.
AN ORDINANCE establishing control strategies for Articulate air
pollution.
WHEREAS the City Council find* that prevailing weather patterns in the
city tend to hold pollutants in th« ulr; and,
WHEHEAS smoke and dust are parttculates which originate from many
aourceu, and which tend to collect In the air shed of Medford; and,
WHEHEAS MedforJ wishes to protect the general health, safety and
welfare of Its citizens by controlling the sources of partlculate air
pollution.
THE CITY OK MEOrOHD OKDAINVi At. KOLI,OWS:
1. iiENMAk J'EFIJOT t_ON3
1.1 Air stagnation advisory: Forecast made by the
National Weather Service for poor ventilation conditions.
1.3 Council: The City Council of th* City of Medford.
1.3 Cogt-effactive leyel^ of weatherlziition: Minimum,
cont-nff latent ntanJurds of wenthertz'itlon, Including
standards for materials and installation, which shall h« set
by the Director of Building Safety. These standards shall
re'.'li-ct, but not exceed the levels deflnef. In ORS U69.710
(2).
i.U Medfi:rJ-Aehl_a_n>l _ACJK\: That p/irt. of Jackson County,
Or'-gon, specifically identified by the Oregon Department of
Environmental Quality as an air quality maintenance area —
one of Inhaled during
lironLlilng p.nd can VM
1.6 Peraoni Includes Individuals, corporations,
uoBO.-lationa, flrmo, partnerships, and Joint stock companies.
1.7 Primary _jgarticulat<» _ jita_ndHrd: An average
purl. !•• iX-tti! concentration of 2^0 micrograras per cubic meter
of ulr during R twenty-four hour period.
l.fl Proof of weft tin-* r I /.at Ion: Certification, receipts,
iiontricts, or other such documents specifically listing
veatlnirlzutlon steps taken by the homeowners, which may be
revtr-v.'.l by building inspectors at the time of solid fuel
ti«nl.lni{ syuttfia installation.
1.9 Humiliations; Regulation* promulgated by Lli«
-il jiuroiiant to thin
' .in Residential building: An existing building us*d
for jifrinnnent or seasonal habitation by one or more persona,
.•on ttilnlng four or fewer dwelling units, and constructed
prior '.o January 1, 1979.
1. 11 Residential wpodburning: Utilisation of a wood
Ui'ul.ing .invion lnHlile a dw'e'll.'ing unit.
l.ir? Space heat ing: Raising the interior temperature of
H room or rooms.
No.
-------
1.13 Total suspended pe.rtioul«te level;
particulate In ambient air.
Aaount of
l.ll* Trackout; The deposition of mud, dirt and other
dubrlu on paved public roadways by rootor vehicles; the
material bntng to tracked onto public roadways. Trackout can
become pulverised and blown Into the air by vehicular
traffic, where It become* a part of the total suspended
paniculate level.
1.15 Ventilation Imlnxi The National Weather Service's
Indicator of the relative degree of air circulation for a
specified nrniv,
1.l6 Wood heating devices; A stove, heater, fireplace,
or other receptacle wherein wood Is heaterf to the point of
combustion.
SECTION 2. SEVKR ABILITY
2.1 If any portion of this ordinance Is declared to ixs
Invalid by A court of competent Jurisdiction, such Invalidity
•ilvxll !)>• -unfilled to the section to which such declaration of
Invalidity relates, and the remainder of thin ordinance shall
continue to be operative.
SECTION j. WEATHEHIZATION .REQUIREMENTS FOR SOLID, KUK :._ .HEATING
DEVICE YNSTAUJATTOM .............. "
The purpose uf thia section Is to reduce the amount of purtieulate
pollution resulting from residar.tlal woodburning for building heating. Most
buildings constructed before 1975 vere built to lower weatherization
standards than but'..' Lngu constructed since that date. A highly veatherized
and insulated biilldlag will require Inn* fuel to attain and hold a given
tnmjmrHUire. It will produce Isss smnki jjo.llution and will also result In «.
savings of the wood or other fael resource. Additionally, veatherization
prior to or c.t thn time of installation of a solid fuel heating device will
generally result in the selection of a device nor* appropriately sized for
the building and will lessen the potential aaount of snoXe produced.
Therefore:
3.1 The installation of a wood stove, fireplace, or any
other form of solid fuel, space heating device is allowed if:
A) The space heating device is installed pursuant
to the uniform building code and regulations of the
Kedford Department of Building Safety.
B) The structure contains an alternate form of
space heating, Including1 natural gas, propane,
electric, oil, solar, or kerosene, sufficient to
meet necessary space heating requirements, so that
during episode* of high pollution levels, the
occupant will be able to heat the hone with other
than a solid fu«l burning, smoke producing method.
C) The residence meets or io proposed to meet,
within 90 days the cost-effective levels of
weatherlzatlon as defined in Section 1.3 of this
RK'JIDENTIAI, WEATHERIZATIOH
The purpose 01 mis section is to minimize particulate emissions from
hone heating devices by Improving home weatherltation and reducing energy
Ions. This section Is also intended to encourage homeowners to make use of
freo «nergy audits and low-Interest financing available from local utility
-2-Crdlnar.ee No.
-------
companies. It in the City'* intent to advertise and make knovn programs
vhich art already available for veatnerlting homes and to assist citltens In
taking advantage of those program*.
^
It.l It is the goal of the City of Medford to assist citizens
to weetherlze all residence* to the cost-effective level by
January 1, 1987.
U.2 All residential buildings shall have received an energy
audit prior to the tins of sale or rental, and such information
shall b« made available to potential purchasers or renters as a
condition of such sale or rental. This section shall become
effective six months after adoption of this ordinance.
k.J In January of 198U, If the primary partlculate health
ata.nda.rdj ure not being maintained, all hones with a wood heating
system shall hn veatherlzed to cost-effective levels at the tine
of sale or rental. ^
SECTION 5. POLLUTIQK EPISODE. JCURTAUMEKT
The purpose r.f thia section Is to reduce the amount of participate
pollution during periods of air stagnation or when pollution levels are
critical. Periods of uir stagnation occur at various times in a year and
can create a severe Accumulation of pollutants. Residential voodburnlng oo.n
contribute as much as 50 percent of the particulate pollution during these
conditions.
5.1 The use of residential vooilburnlng devices 11 prohibited
on each day that an air stagnntlon ttdvlsory announcement for the
Medford-Aahland AQKA has been Issued by the National Weather
Service. This subsection tanns effect on July 1, 198U, if the
particuLate health standard is not attained In the Medford-Ashland
Air Qrj\llty Maintenance Area by that date.
5.2 ftnaldences having no other form of sptce heating in?
exempt from this section.
SECTION 6. TRACKOUT
The purpoMrt of this section is to lessen the amount of particuLate
pollution vhich originates from roads and roadvays. Dirt ejid other debrla,
vhich may become deposited upon paved roads, car. be ground and pulverized by
traffic into minute particles. These partlr.lns can then become airborne
adding to the partlculnte pollution problem.
6.1 No person shall place or deposit sud, dirt or debris
upon ar.y street, alley, sidewalk or other public way.
6.2 Violation of subsection 6.1 is hereby declared to be a
public nuisance and subject to summary abatement by the "Ity
;U;jHger or his designate. Suraw.ry nbatement Includes but is not
United to suspension of any and all city permits relating to
construction on the site which Is the source of the mud, dirt or
debris.
PASSED by the Council and signed by me In open session in
authentication of its pannage this 4^ day of J*WHDbsc__t 1982.
ATTEST .£•/.Daily-H.-Kirkhfln ^a/ JohnJiallett
City Recorder HCTINO Mayor
-3-Ordlnance Ho.
-------
BEFORE THE BOARD OF COUNTY COMMISSIONERS
STATE OP OREGON, COUNTY OF JACKSON
ORDINANCE NO.
AN ORDINANCE PROVIDING FOR CLEANER AIR.
WHEREAS Jackson County finds that prevailing weather patterns in certain
areas of the county tend to hold pollutants in the air; and,
WHEREAS smoke and dust are particulates which originate from many sources,
and which tend to collect in the air shed of Jackson County; and,
WHEREAS Jackson County wishes to protect the general health, safety and
welfare of its citizens by controlling the sources of particulate air
pollution.
THE BOARD OF COUNTY COMMISSIONERS OF JACKSON COUNTY ORDAINS:
SECTION 1. TITLE
1.1 This ordinance shall be known as the "Particulate Air Pollution
Control Ordinance of Jackson County" and may be so cited and pleaded,
and shall be cited herein as "this ordinance".
SECTION 2. GENERAL DEFINITIONS
2.1 Air stagnation advisory; Forecast made by the National Weather
Service for poor ventilation conditions.
2.2 Board; The Board of Commissioners of Jackson County.
2.3 Cost-effective level of weatherization; Minimum, cost-efficient
standards of weatherization, including standards for materials and
installation, which shall be set by the Director of Planning and
Development. These standards shall reflect, but not exceed the levels
defined in ORS 469.710 (2).
2.4 Medford-Ashland AQMA; That part of Jackson County, Oregon,
specifically identified by the Oregon Department of Environmental
Quality as an air quality maintenance area — one of several areas in
the state wherein air quality has deteriorated due to unhealthful
levels of pollutants in the air. The map of the Medford-Ashland AQMA
is attached to this ordinance as exhibit "A" and incorporated herein by
reference.
1-ORDINANCE
Date Typed: 8/19/82
-------
2.5 Open burning; Includes burning in burn barrels, incinerators,
open outdoor fires, and any other burning wherein combustion air is not
effectively controlled and combustion products are not effectively
vented through a stack or chimney.
2.6 Particulate; Airborne particles ranging from .01 to 1,000 microns
in size. These particles are inhaled during breathing and can be
harmful.
2.7 Person; Includes individuals, corporations, associations, firms,
partnerships, and joint stock companies.
2.8 Primary partieulate standard; An average particulate concen-
tration of 260 micrograms per cubic meter of air during a twenty-four
hour period.
2.9 Proof of_ weatherization; Certification, receipts, contracts, or
other such documents specifically listing weatherization steps taken by
the homeowners, which may be reviewed by building inspectors at the
time of solid fuel heating system installation.
2,10 Regulations; Regulations promulgated by the Board pursuant to
this ordinance.
2.11 Residential building; An existing building used for permanent or
seasonal habitation by one or more persons, containing four or fewer
dwelling units, and constructed prior to January 1, 1979.
2.12 Residential woodburning; Utilization of a wood heating device
inside a dwelling unit.
2.13 Spaceheating; Raising the interior temperature of a room or
rooms.
2.14 Total suspended particulate level; Amount of particulate in
ambient air.
2.15 Trackout; The deposition of mud, dirt and other debris on paved
public roadways by motor vehicles; the material being so tracked onto
public roadways. Trackout can become pulverized and blown into the air
by vehicular traffic, where it becomes a part of the total suspended
particulate level.
2.16 Ventilation index; The National Weather Service's indicator of
the relative degree of air circulation for a specified area.
2.17 Waste; Discarded or excess material, including;
A) Agricultural waste resulting from farming or agricultural
practices and operations.
2-ORDINANCE
-------
B) Nonagricultural waste resulting from practices and operations -
other than farm operations, including industrial, commercial,
construction, demolition and domestic wastes, and yard debris.
2.18 Wood heating devices; A stove, heater, fireplace, or other
receptacle wherein wood is heated to the point of combustion.
SECTION 3. GENERAL EXEMPTIONS
3.1 This ordinance shall not apply:
A) Within incorporated limits of any city.
B) To federal or state lands.
C) To prescribed slash burns regulated by the Oregon State Smoke
Management Plan.
D) To cooking fires or ceremonial fires.
SECTION 4. SEVERABILITY
4.1 If any portion of this ordinance is declared to be invalid by a
court of competent jurisdiction, such invalidity shall be confined to
the section to which such declaration of invalidity relates, and the
remainder of this ordinance shall continue to be operative.
SECTION 5. WEATHERIZATION REQUIREMENTS FOR SOLID FPEL HEATING DEVICE
INSTALLATION
The purpose of this section is to reduce the amount of particulate
pollution resulting from residential woodburning for building heating.
Most buildings constructed before 1979 were built to lower weatherization
standards than buildings constructed since that date. A highly weatherized
and insulated building will require less fuel to attain and hold a given
temperature. It will produce less smoke pollution and will also result in
a savings of the wood or other fuel resource. Additionally, weatherization
prior to or at the time of installation of a solid fuel heating device will
generally result in the selection of a device more appropriately sized for
the building and will lessen the potential amount of smoke produced.
Therefore:
5.1 The installation of a wood stove, fireplace, or any other form of
solid fuel, space heating device is allowed if:
A) The space heating device is installed pursuant to the uniform
building code and regulations of the Jackson County Department of
Planning and Development.
3-ORDINANCE
-------
B) The structure contains an alternate form of space heating,
including natural gas, propane, electric, oil, solar, or kerosene,
sufficient to meet necessary space heating requirements, so that
during episodes of high pollution levels, the occupant will be
able to heat the home with other than a solid fuel burning, smoke
producing method.
C) The residence meets or is proposed to meet within 90 days the
cost-effective levels of weatherization as defined in Section 2.3
of this ordinance.
SECTIONS. RESIDENTIAL WEATHERIZATION
The purpose of this section is to minimize particulate emissions from home
heating devices by improving home weatherization and reducing energy loss.
This section is also intended to encourage homeowners to make use of free
energy audits and low-interest financing available from local utility
companies. Information concerning free energy audit and low-interest
financing programs is available from the Jackson County Department of
Planning and Development or directly from the utility companies. It is the
County's intent to advertise and make known programs which are already
available for weatherizing homes and to assist citizens in taking advantage
of those programs.
6.1 It is the goal of Jackson County to assist citizens to weatherize
all residences to the cost-effective level by January 1, 1987.
6.2 All residences shall have received an energy audit prior to the
time of sale or rental, and such information shall be made available to
potential purchasers or renters as a condition of such sale or rental.
This section shall become effective six months after adoption of this
ordinance.
6.3 In January of 1984, if the primary particulate health standards
are not being maintained, all homes with a wood heating system shall be
weatherized to cost-effective levels at the time of sale or rental.
SECTION 7. RESIDENTIAL WOODBURNING
The purpose of this section is to reduce the amount of particulate
pollution during periods of air stagnation or when pollution levels are
critical. Periods of air stagnation occur at various times in a year and
can create a severe accumulation of pollutants. Residential woodburning
can contribute as much as 50 percent of the particulate pollution during
these conditions.
7.1 The county shall, through its air quality information program,
advise the public when air stagnation conditions exist or when
suspended particulate health standards are exceeded or when suspended
particulate health standards are projected to be exceeded.
4-ORDINANCE
-------
7.2 The use of residential woodburning devices will be allowed
within the air quality maintenance area except on days when it has
been determined that the ambient air quality exceeds, or is
projected to exceed, the 24-hour total suspended particulate health
standard of 260 micrograms per cubic meter.
7.3) The use of residential woodburning devices is prohibited on
each day that an air stagnation advisory announcement has been
issued by the Department of Environmental Quality. This subsection
takes effect on July 1, 1984, if the particulate health standard is
not attained in the Medford-Ashland Air Quality Maintenance Area by
that date.
7.4 Residences outside of the Medford-Ashland Air Quality
Maintenance Area and residences having no other form of space
heating are exempt from this section.
SECTION 8. TRACKOUT
The purpose of this section is to lessen the amount of particulate
pollution which originates from roads and roadways. Dirt and other debris,
which may become deposited upon paved roads, can be ground and pulverized
by traffic into minute particles. These particles can then become airborne
adding to the particulate pollution problem.
8.1 This section particularly applies to, but is not limited to,
construction sites, farm operations, and commercial and industrial
operations.
8.2 No person shall trackout mud, dirt or other debris from private or
public lands onto paved public roads without taking reasonable
precautions to prevent such particulate matter from becoming airborne.
These precautions shall include, where appropriate, the prompt removal
of such material from the paved road surfaces. This section does not
apply to noncommercial uses of public roads.
8.3 No person shall violate the provisions of a stop-work order issued
pursuant to subsection 8.4 of this ordinance.
8.4 The county may require the imposition of building permit
conditions for the prevention of trackout. Conditions imposed may
include, but are not limited to the following:
A) A bond of sufficient amount to be posted by the contractor to
assure available funds for roadway cleanup by Jackson County if the
contractor is negligent in cleanup of adjacent public roadway.
B) Street sweeping, vacuuming or other means of removing trackout
material from public roadways.
5-ORDINANCE
-------
C) Installation of wheel washers at exits of major construction
sites.
D) Use of temporary or permanent barricades to keep traffic off
unpaved areas.
E) Require graveling of access roads on site.
F) Limit the use of public roadways by vehicles.
G) Issue stop work order if trackout occurs and is not promptly
corrected.
8.5 Stop work orders issued pursuant to subsection 8.4 of this
ordinance shall be posted, where appropriate, at the work site, and
mailed by certified mail to alleged violators. Appeals to any such
orders shall be conducted pursuant to the provisions of Section 204 of
the Jackson County Building Code.
SECTION 9. OPEN BURNING
The purpose of this section is to minimize the accumulation of particulate
air pollution resulting from open burning. The public should be aware that
open burning may be restricted during the fire season (typically June
through October) by the fire districts or other fire regulating
authorities. These authorities typically base restrictions of open burning
on factors of low humidity, high winds, drought, or other conditions which
make outside burning unsafe.
9.1 Open burning of nonagricultural wastes is prohibited in the
Medford-Ashland Air Quality Maintenance Area from February 1 to
November 30 of each year on days when the ventilation index is less
than 400.
9.2 Open burning of nonagricultural wastes is prohibited during
December and January of each year due to generally poor smoke
dispersion.
9.3 Open burning of agricultural waste is prohibited on all days of
the year when the maximum ventilation index is below 200.
SECTION 10. ABATEMENT
10.1 Persons acting in violation of provisions of this ordinance, or
of permits issued, shall be subject to appropriate legal proceedings to
enjoin or abate such violation(s).
6-ORDINANCE
-------
SECTION 11. PENALTIES
11.1 Persons violating subsections 8.2, 8.3, 9.1, 9.2 and 9.3 shall be
subject to civil prosecution pursuant to Jackson County Ordinance
81-81.
ADOPTED this
day of
ATTEST:
at Medford, Oregon.
OP COMMISSIONERS
:er Sage, dnairnfan
APPROVED AS TO FORM:
By: Recording Secretary
County Counsel
7-ORDINANCE
-------
EXHIBIT "A"
JACKSON COUNTY, OREGON
MEDFORD-ASHLAND
AIR QUALITY MAINTENANCE AREA
33
-------
EXHIBIT "B"
BOUNDARY DESCRIPTION
MEDFORD-ASHLAND AIR QUALITY MAINTENANCE AREA
The Medford-Ashland Air Quality Maintenance Area is defined as beginning at
a point approximately one mile NE of the town of Eagle Point, Jackson
County, Oregon, at the NE corner of Section 36, T35S, R1W; thence south
along the Willamette Meridian to the SE corner of Section 25, T37S, R1W;
thence SE along a line to the SE corner of Section 9, T39S, R2E; thence SSE
to the SE corner of Section 22, T39S, R2E; thence south to the SE corner of
Section 27, T39S, R2E; thence SW to the SE corner of Section 33, T39S, R2E;
thence west to the SW corner of Section 31, T39S, R2E; thence NW to the NW
corner of Section 36, T39S, R1E; thence west to the SW corner of Section
26, T39S, R1E; thence NW along a line to the SE corner of Section 7, T39S,
R1E; thence west to the SW corner of Section 12, T39S, R1W; thence NW along
a line to the SW corner of Section 20, T38S, R1W; thence west to the SW
corner of Section 24, T38S, R2W; thence NW along a line to the SW corner of
Section 4, T38S, R2W; thence west to the SW corner of Section 5, T38S, R2W;
thence NW along a line to the SW corner of Section 31, T37S, R2W; thence
north along a line to the Rogue River, thence north and east along the
Rogue River to the north boundary of Section 32, T35S, R1W; thence east
along a line to the point of beginning.
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INFORMATION CONCERNING
COUNTY WEATHERIZATION REQUIREMENTS
DEPARTMENT OF PLANNING ft DEVELOPMENT • COUNTY COURTHOUSE . MEDFORO, OREGON »TSOI • UO3)77«-TSS4
The "Particulate Air Pollution Control Ordinance of Jackson County", also known as the
"Air Quality Ordinance," places responsibilities on certain Jackson County homeowners
when they sell their property. This ordinance was adopted by the Board of Commissioners
as part of a comprehensive effort on the part of state and local government to reduce
air pollutidri and its resultant adverse health impact on the community. The ordinance
deals with several subjects; however, this information sheet only pertains to
weatherization requirements, which are designed to reduce the amount of smoke produced
by homes heated with solid fuel by increasing the heat retention efficiency of these
homes. The requirements are summarized as follows:
1) The following regulations apply only to residences within the Medford-Ashland
Air Quality Maintenance Area (see attached map and description). The county
ordinance does not apply within city limits; however, cities may adopt similar
regulations.
2) Beginning January J^ 1985; The owner of any residence (other than a mobile
home) constructed before January 1, 1979, which does not meet minimum weatherization
standards, must provide an energy audit to potential purchasers of such residence.
3) Beginning January 1, 1985; Prior to sale of any residence (other than a mobile
home) constructed before January 1, 1979, and which has a_ solid fuel heating device,
the owner must ensure that the home will meet Minimum weatherization standards by:
a) Bringing t-.he home up to those standards; or
b) Filing a proposal with the Jackson County Department of Planning and
Development, signed by the new owner of the residence, stating that the new
owner will be responsible for bringing the residence up to minimum
weatherization standards within 90 days of the sale.
Minimum weatherization standards are defined as any of the following, at the option of
the property owner:
1) Ceiling resistance factor of 30 (R-30); and
Floor resistance factor of 19 (R-19); and
Double glazing of window areas or installation of storm windows; or
2) The installation of those weatherization alternatives which an energy audit has
determined will provide or save an amount of energy during their life cycle which,
based on the present cost of delivered energy, will exceed the cost of the installed
improvements; or
3) Those weatherization alternatives entirely authorized for installation through
any federal, state or utility company sponsored loan or grant prog'ram.
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Page -2-
Residence is defined as a building containing two or fewer dwelling units used for
habitation by one or more persons (excluding mobile homes).
Solid Fuel Heating Device is defined as a stove, heater, fireplace modified with an
insert, or other similar receptacle wherein wood or other solid fuel combustion occurs
for the purpose of space heating (unmodified fireplaces are excluded).
Compliance; Failing to comply with the above requirements may result in civil penalties
or civil liability.
Information concerning free energy audit and low-cost weatherization programs is
available from the following sources, depending upon the primary heating source of your
residence:
Primary Source Information Source
Electricity Pacific Power
P. O. Box 1148
Medford, OR 97501
776-5499
Natural Gas CP National
Weatherization Dept.
P. O. Box 1709
Medford, OR 97501
772-5281
Wood, Coal, Propane, Weatherization Audits:
Kerosene, etc. Oregon Heat Institute
P. 0. Box 42227
Portland, OR 97242
1-800-452-8660
Weatherization Grants:
Oregon Dept. of Energy
Labor & Industries Bldg-
Room 102
Salem, OR 97310
1-800-221-8035
A list of qualified independent energy auditors will be maintained by the Department of
Planning and Development for your information. Also available are copies of the
ordinance pertaining to residential weatherization. Please ask for copies of these
items at the reception desk.
-------
SAM B DAVIS
ilbkiE'" L AI"3WohfW
DONALD M. PINNOCK
JACK DAVIS
DAVID V GlLSTRAP
LAW orriccs
DAVIS, AINSWOUTH. PINNOCK, DAVIS & GILSTRAP. p. c.
bIB CAST MAIN STREET
AS in JIN D. OHEGON 9752O
November 6, 1984
ABCA CODE SOS
4UZ-3III
To the Realtors of Medford and AshZand:
It is time to become aware of the Particulate Air Pollution
Control Ordinance enacted by the Jackson County Board of
Comnissioners on October 17, 1984. This ordinance replaces an
earlier ordinance which was far more difficult to live with and
suspended before it went into effect due to the efforts of local
ReaI tors.
One purpose of the new ordinance is to encourage residents to
take advantage of the weatherization programs available. Because
a weatherized house with a wood stove requires less burning to
maintain warmth, and therefore less smoke for our air shed, the
second purpose of the ordinance is to reduce smoke in the Valley
through weatherization.
Understanding the new ordinance begins with knowing which sales
it does no£ apply to. Each of you should refer to this list with
every sa1e"until it is memorized.
1. The ordinance does not affect the sale of any real estate
excepting buildings containing one or two dwelling units used
for habitation.
2. It does not apply to the sale of any property in any
incorporated city.
3. It does not apply to the transfer of any leases on state
or federal lands.
4. It does not apply to the sale of any buildings constructed
after January 1, 1979.
5. It does not apply to the sale of mobile homes.
6. It does not apply to the sale of buildings outside the air
quality maintenance area as defined on the attached map.
The ordinance sticks us with two prongs. The first is as
follows: For all sales closed on January 1, 1985 and after, the
house must:
a) Have insulation of R-30 in the ceiling, R-19 in the floor,
and double glazed windows or storm windows; or
-------
Medford and
November 6,
Page -2-
Ashland
1984 -
Realtors
b) Have installed weather i zat ion
authorized energy audit.
alternatives directed by an
If the seller has not complied with either of these, the ordi-
nance can still be satisfied if the seller provides the purchaser
with an authorized energy audit at the close of escrow. A list
of qualified energy auditors will be available to the public at
the County Planning Department office. The energy audits of the
utility companies are also considered authorized.
The second prong of the ordinance affects only those residences
which have a wood stove, fireplace with an insert, or other
heater or receptacle which burns wood or other solid fuel for
heat. This branch of the ordinance does not apply to houses that
have only an unmodified fireplace. For sales closed on or after
January 1, 1985, the sellers of residences face the same alter-
natives mentioned in the preceding paragraph with this exception.
If the house lacks the insulation mentioned above and it was not
weatherized as directed in an authorized energy audit before the
close of escrow, it is not enough to simply provide the purchaser
with an energy audit at the close of escrow. The gurchase£ must
file with the Planning Director a statement to the e77^c7~That
those minimum standards wi 1 1 be met within 90 days. The
purchaser win th.en be responsible for implementing the weatheri-
zation within that prescribed time. The Planning Director has
the authority to waive or modify this requirement when the physi-
cal characteristics or intended use of the residence make it
impractical or unduly burdensome to require the implementation of
that min i mum we other izat ion.
So that your deals will close smoothly in January and after, it
would be prudent to now line up energy audits for the sales in
escrow. Please keep in mind the categories of sales which this
ordinance does not apply to. As soon as I become aware of
alterations or, perhaps, the repeal of this ordinance, I will
advise.
Yours truly,
DAVIS,
DAVIS &. (SILSTRAP,
JACK D/
BOARD LEGAL OX
JD/jIh
1_AW OFFICES OF
DAVIS. AINSWORTH, PINNOCK, DAVIS » G1LSTRAP. P.C.
SIS EAST MAIN toTftCCT
ASHLAND. OKEV.ON 97SIO
(503) 48C.3II 1
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Oregon's Woodstove Certification Program
-------
174 c. 333
62nd OREGON LEGISLATIVE ASSEMBLY-1983 Regular Session
Enrolled
House Bill 2235
Ordered printed by the Speaker pursuant to House Rule 12.00A (5). Presession filed (at the request of
Department of Environmental Quality)
CHAPTER
AN ACT
Relating to air pollution: creating new provisions; and amending ORS -KS8.275 and 468.290.
Be It Enacted by th* Peopte of the State ol Oregon:
SECTION I. ORS 4AX.27? is amended to read:
408.273. As used in [O&S 44H.3O3. 4*4.010 tu 4J4.04O, 4S4.30S t
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176 c. 333
(2) The woodstove is certified by Che department under the program established under section 5 of this
1983 Act; and
(3) An emission performance and heating efficiency label is attached to the woodstove.
SECTION 9. (I) The provisions of this 1963 Act do not apply to a used woodstove.
(2) As used in this section, "used woodstove" means any woodstove that has been soU, bargained,
exchanged, given away or has had its ownership transferred from the person who first acquired the woodstove
from the manufacturer or the manufacturer's dealer or agency, and so used to have become what is commonly
known as "second hand" within the ordinary meaning of that term.
SECTION 10. The commission shall use a portion of the net emission reductions in an airshed achieved by
the woodstov« certification program to provide room in the airshed for emissions associated with commercial
and industrial growth.
Approved by the Governor July 5, 1933.
Filed in the office of Secretary of State July 6, 1983.
Enrolled House Bill 2235
-------
VICTOfl ATIVEH
OOVfUso*
Environmental Quality Commission
Mailing Address: BOX 1760, PORTLAND, OR 97207
522 SOUTHWEST 5th AVENUE, PORTLAND, OR 97204 PHONE (503) 229-5696
MEMORANDUM
To:
From:
Subject:
Environmental Quality Commission
Director
Agenda Item No. A, June 8, 1984, EQC Meeting
Proposed Adoption of Woodstove Certification Rules OAR
21-100 Through 340-21-166 As A Revision To The State
Implementation Plan.
BACKGROUND
The 1983 Oregon Legislature passed HB 2235 which requires the EQC to adopt
rules by July 1, 1984 which deal with certification of new woodstoves.
Over the last 9 months the Department developed proposed rules with the
aid of a Woodstove Advisory Committee. The proposed rules cover testing
procedures, lab accreditation requirements, certification application pro-
cedures and fees, labeling criteria, and emission standards. The Woodstove
Advisory Committee, which primarily represented the Oregon woodstove
industry, supported the proposed rules with the exception of the emission
standard. On March 16,. 1984, the EQC authorized hearings on the proposed
rules drafted by the Department (Agenda Item A, March 16, 1984, EQC
Meeting).
Hearing Testimony
Day and night public hearings were held on the proposed rules in Portland,
Eugene, Medford, Bend and Pendleton. The hearings officers' reports are
included as Attachment 1. A summary of written testimony received while
the hearing record was kept open is included as Attachment 2. Copies of
both timely and late written testimony have been provided to the
Commission.
Fifty-six individuals testified in person at the hearings, and fifty
individuals submitted written testimony while the hearing record was kept
open. Six individuals submitted written testimony after the hearing record
was closed. Most testimony came from the woodstove industry which
primarily criticized the proposed second stage of the emission standard as
being unjustified and unachievable, and not in keeping with legislative
oeo-46
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EQC Agenda Item No. A
June 8, 1984
Page 2
intent. Testimony supporting this position included information to
indicate the baseline stove emission rate should be higher, population
growth projections in airshed strategies should be lowered and the test
fuel density was too low to represent reality.
Other significant issues raised by woodstove industry testimony included:
- The Condar participate sampling method should be recognized as
equivalent to Oregon Method ?•
- The Condar heating efficiency method should be recognized as
equivalent to calorimeter room and stack loss heating efficiency
methods.
- Testing costs should be reduced by reducing the number of tests
required.
- A provision should be made to protect confidentiality of stove
designs.
- Certification fees should be paid at the retail level.
- A fireplace insert test procedure should be provided.
- DEQ should not spend time inspecting stoves at the manufacturing
facility when testing laboratories can provide this service.
- DEQ should let testing laboratories review woodstove design
changes.
- DEQ should not immediately revoke manufacturer's certification if a
testing lab is found to have conducted an improper test.
- Uncertified stove advertising and sales should be allowed in Oregon
between manufacturers and dealers and to out-of-state customers.
- Degradation of non-catalyst stoves should be considered in setting
the emission standard.
- Stoves should not have to be recertified every five years.
- Catalyst warranty requirements should allow a 5-year pro-rated
•. . provision instead of 2-year full replacement provision.
- The Hoodstove Advisory Committee should periodically review the
program.
- Some testing equipment specifications should be revised.
Several individuals submitted testimony in support of regulation of wood-
stoves and some felt the Department was not being strict enough.
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EQC Agenda Item No.
June 8, 1984
Page 3
Several organizations, such as the Sierra Club, League of Women Voters of
Oregon, Oregon Environmental Council, and Oregon Lung Association, felt the
strictest standards should be adopted as a single stage standard as they
expressed fears that the second stage may never be implemented.
Only one local government, the City of Union, submitted testimony and asked
to be exempt from the rules.
Organizations, such as the Lane Regional Air Pollution Authority (LRAPA)
and Associated Oregon Industries, generally supported the proposed rules.
Suggestions were made by LRAPA that public education should be Included on
economic and safety benefits of catalysts and that the value of a financial
incentive should not be forgotten in relation to the possibility of
accelerated woodstove pollution clean up.
EVALUATION AND ALTERNATIVES
The appropriateness of the second stage 7 gram/hour non-catalytic and 3
gram/hour catalytic stove particulate emission standard (7/3 standard) was
the major issue raised by hearing testimony. The woodstove industry
generally supported the first-stage standard but felt that either a second-
stage standard was unnecessary to clean up airsheds or that more infor-
mation was necessary in order to identify an appropriate standard. The
Woodstove Advisory Committee had unanimously voted (with one member
abstaining and one member absent) to support a 9A second-stage standard
and some testimony was received from a few members of the woodstove
industry in support of adoption of the Advisory Committee recommendations.
There was considerable woodstove industry testimony that a 7/3 standard was
not achievable with available stove technology.
Airshed Model Uncertainties
In terms of the needed airshed improvements which were the basis for the
second-stage emission standard, testimony cited uncertainties of about
± 251 in the airshed models used to calculate these needs. Regarding
these model uncertainties, they are not considered unusual with even state
of the art models such as those used by the Department. The Department
believes there is an equal likelihood that airshed needs have been
underestimated as overestimated. The only reasonable approach in such
instances, in the Department's opinion, is to rely on average values
predicted by the models as has been done.
Population Growth Pro lections
When the issue of population growth projections and related increased wood
burning used in airshed models was reviewed with the Advisory Committee
last Fall, a check was made to verify that latest available population
growth projections were being used by the Department. Subsequent to this
check, hearing testimony pointed out that Portland State University
published preliminary revised growth projections about the first of the
year which indicate revised downward growth projections of about 25? for
-------
EQC Agenda Item No.
June 8, 1984
Page 4
the Portland and Medford areas for the periods of interest. While these
projections are preliminary in nature, it is clear that actual growth
within the first several years of the periods of interest have been much
lower than anticipated because of the lingering economic recession in
Oregon. Thus, it appears reasonable that these revised growth projections,
which take into account this fact, should be used in reevaluating airshed
improvement needs. Revised growth projections were used to revise the
Portland and Medford airshed model control strategy needs. The results are
shown below.
Airshed Reduction Needs From Woodstove Certification
Daily Standard Annual Standard
Medford Area (original) 80$ 76?
Portland Area (original) 75% 75%
Medford Area (revised) 78* 74%
Portland Area (revised) 72$ 72$
As can be seen from the above table, although growth projections have been
revised downward about 25$, airshed improvement needs do not go down
accordingly. This is because population growth is not the major cause of
the wood heating pollution problem. The main cause is the large base of
existing wood heating emissions.
In general, revisions of airshed control strategy needs based on revised
population projections indicate needs have been reduced*from a 75-80$ range
to a 72-78$ range. The lower end of this range would be most important,
considering population weighting to the Portland area needs.
Baseline Stove Emission Rate
Once the needed airshed emission reduction from woodstove certification is
identified, the appropriate emission standard to achieve such a reduction
can be calculated based on the average emissions from existing or baseline
stoves. The baseline emission rate identified by the Department (in the
range of 30 to 34 grams per hour) was criticized by many members of the
woodstove industry as too low.
The Department identified a baseline particulate emission factor of 20
grams/kilogram of wood in actual airshed monitoring and modeling studies.
This compared favorably with EPA's current emission factor of 21
grams/kilogram. The Department estimated an average baseline burn rate of
1.7 kilogram/hr (which when multiplied by the 20 gram/Kg emission factor
equals an emission rate of 34 g/hr) as being the baseline burn rate based
on the average heat demand for an average sized home with average
insulation in Oregon. The estimated 1.7 kilogram/hr average burn rate
translates to an equivalent heat load of 13,000 Btu/hr. The average
baseline burn rate estimated by the Department was also challenged by
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EQC Agenda Item No. A
June 8, 1984
Page 5
certain members of the woodstove industry who thought it should be higher.
A comprehensive study which measured actual burn rates in several
homes under heat load conditions similar to those of Oregon indicated burn
rates closer to 1 Kg/hr. This study, by Dr. Stockton Barnett in New York,
concludes that average burn rates may be slightly less than calculated heat
loads because extremities of homes are kept cooler. The Department has
also calculated burn rates in the range of 1.7 Kg/hour based on wood use
and burning habits reported in a survey in the Medford area. Thus, the
Department is confident that the burn rates used to calculate the average
baseline emission rate should not be higher than 1.7 Kg/hour as claimed by
woodstove industry testimony.
fiecent testing of conventional woodstoves (December, 1983/January, 1984)
using the proposed test procedures has also indicated a baseline stove
emission rate of about 30 grams/hour. The National Wood Heating Alliance
(WHA), however, presented substantial testimony which pointed to much
higher baseline emission rates for conventional stove tests.
WHA pointed to 4 tests conducted by DEQ in 1980 of conventional stoves
which averaged 81 grams per hour. A close examination of this data
indicates tests were conducted with unreal istically dry wood with a
moisture content of 14$. Wood at this moisture content has been shown by
EPA studies to have very high emission rates. The proposed test procedure
uses a more realistic average moisture content in the range of 16-20$. If
the Department's 1981 test data is adjusted from 14$ moisture to 18$
moisture, using EPA derived moisture/emission relationships, an emission
rate of about 36 grams/hour results.
WHA also cites 2 conventional stove tests conducted in 1981 within the
Department's proposed moisture range which average 48.5 grams per hour..
A close examination of this data indicates both tests were at higher heat
outputs than the Department's reference 13,000 Btu/hr. Projecting this
data to 13,000 Btu/hr results in an emission rate of between 34 and 39
grams per hour, depending on the assumed stove efficiency (50% or 65$).
WHA further cites test data by the State of Vermont which averages 51.8
grams per hour for conventional stoves. A close examination of this data
indicates an average emission factor of about 20 grams/kilogram (which
agrees with DEQ's factor) but at an average burn rate of about 3 Kg/hr
which is much higher than DEQ estimates and actual measured values for
Oregon heat loads. The Department therefore believes its estimate of
baseline stove emissions in the range of 30 to 34 grans/hour is justifiable
and usable to calculate an appropriate emission standard.
Test Fuel Loading
WHA also contends that the Department's test fuel density of 7 Ibs/cubic
foot of fire box volume is unrealistically low and thus produces
unrealistic baseline emission rates and unrealistic test conditions for
certification purposes. Investigation of this issue reveals that the
actual Department test fuel density is about 9 Ibs/cubic foot since a
test fuel bed of 20-25% of a 71bs/cubic foot test fuel charge is also
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p
EQC Agenda Item No. A <0-~?'-f
JuneB, 1984
Page 6
required. WHA points out that a major study o "*•*- ^"f^"
Battelle (a national research firm) used equiv
of 5 to 16 Ibs/cubic foot. This would put the
density in about the mid-range of such testing
also point out that other major studies, like 4r> "7/-»
Authority (1981-1983), used densities of 2.0 1 ' 5<
Dr. Stockton Barnett, a leading woodstove rest
testimony that he supports DEQ's fuel loading
size stoves on the basis of extensive experiei
homeowners to record weights of their fuel lo«
homeowners' overnight loads of hardwoods in tL. .
7-8 Ibs/cubic foot and 9-10 Ibs/cubic foot in the coldest parts of winter.
He postulates that loading densities are not greater because ash buildup is
irregular and several inches deep, reducing useable firebox volume; logs
are often non-optimum and variable length to fully utilize firebox length;
and log diameters and irregular cross-section geometry make tight packing
impossible.
The Department, therefore, concludes that a baseline emission rate of 30-34
grams/hour is appropriate and justifiable, based on: airshed modeling and
monitoring studies; calculated and measured heat loads and burn rates for
typical average Oregon homes; and actual emission tests of conventional
stoves using reasonable test fuel densities and the proposed test
procedure.
Needed Airshed Improvements and Emission Standards
Estimated emission reduction achievable for a 30-34 g/hr range of base-
line emission rates for the two most prominently considered emission
standards are shown below.
Emission Reductions Achievable
(*)
Emission 30 g/hr 34 g/hr
Standard Baseline Baseline
9/4 70? 74*
7/3 77* 79*
Since revised airshed emission reduction needs have brought the need down
from a 75-80* range to a 72-78* range with the population weighted number
much closer to the lower end of this range, it appears a 9/4 emission
standard is more solidly justified than a 7/3 standard. A 9/4 emission
standard resulting in an emission reduction in the range of 70 to 74* would
also be more in keeping with DEQ legislative testimony which indicated a
68-75* reduction in emissions was achievable from new woodstove technology.
The 68* reduction estimate was based on stoves meeting a 75* emission
reduction level and 10* bootlegging of non-certified stoves. The slight
additional airshed improvement needed to meet the daily standard in the
Medford area above and beyond that which would be provided by a 9/4
standard may be able to be achieved by an aggressive educational effort to
urge consumers to buy the lower emitting of the certified models or by
other control strategies.
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EQC Agenda Item No.
June 8, 1984
Page 7
Best Practical Woo^stove Control Technology
The woodstove industry severely criticized the proposed 7/3 emission
standard on the basis that it was unachievable by available technology,
even catalytic technology. Such criticism even came from the manufacturers
of the Blaze King stove, the stove upon which the Department justified the
achievability of the standard, and the Condar Company, the company that
supplied the design technology for the Blaze King stove.
The Department had substantiated the achievability of the 3 g/hr catalytic
standard on the basis of a Blaze King stove test with the proposed test
procedure which resulted in an emission rate of 1.2 g/hr. Industry
testimony criticized this data on the basis that the stove tested was a
prototype and that production models have been "detuned" in terms of
emission control to provide better catalyst life and better overall stove
performance. Also, it was pointed out that the 25 cell-3" thick - 6,000
hour catalyst used in the DEQ test is being phased out and replaced with a
less emission efficient 16 cell - 3" thick-12,000 hour catalyst in order to
provide better catalyst longevity and improved burn rate and smoke leakage
characteristics of the stove.
Upon confirming these facts several weeks ago, the Department decided to
test three production-model, Condar-technology stoves using the new 16
cell-12,000 hour catalyst. Testing was conducted near the 13>000 Btu/hr
reference heat output level using the proposed test procedure. The results
are shown below.
Condar Technology
Production Stoves
Blaze King Princess
Blaze King Princess
Brand X
Brand Y
Average
(95* Confidence Limit)
Emission Rate
g/hr fBtu/hr 1
2.39 (11,191)
1.44 (13,032)
2.49 (11,520)
1.06 (14,381)
g/hr (Estimate at
13.000 Btu/hr)
2,
1,
2,
75
44
65
0.93
1.94
(3.74)
The above results indicate there is some variability in emission
performance using Condar-technology. Test results would indicate that
Condar-technology production stoves with the new catalyst designs do emit
slightly more than the prototype stove tested earlier by DEQ, but still
slightly under 3 g/hr. A statistical analysis of the data, though,
indicates that the variability at the 95/1 confidence limit would put Condar
technology over a 3 g/hr standard but under a 4 g/hr standard. A
confidence limit statistical analysis is a common technique used to
identify the upper bound of a population. It is a technique the Department
used to develop a potential emission standard which was presented to the
legislature. The Condar Company, which analyzed past DEQ test data, had
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EQC Agenda Item No. A
June 8, 1984
Page 8
concluded an emission standard for catalysts in the range of 4-6 g/hr was
achievable, however, this conclusion was based on longer aged (higher
emitting) catalysts than called for under the proposed test procedure. A 4
g/hr emission standard, therefore, is strongly justifiable on the basis of
test data of several production model Condar technology stoves with latest
catalyst design. A 3 g/hr catalytic emission standard, while achievable
for some tests, would likely exclude a significant portion of the Condar
technology stove population. Condar technology is considered the best
available technology and a 3 or 4 g/hr standard would eliminate poorly
designed catalyst stoves.
Emision Standard
In summary, the Department's proposed 7/3 second stage emission standard
was based on a strong case of airshed needs and available technology.
Information gained through the public hearing process has led the
Department to conclude that airshed needs are slightly less than originally
projected due to downward revisions in population projections and that best
practical catalytic stove control technology is only capable of
consistently complying with a 4 g/hr standard. In essence, the Department
concludes that a weaker case exists to support a 7/3 standard while a
stronger case can be made to support a 9/4 standard. Considering many
other plus and minus arguments, (such as: potential further future
population growth and wood use reductions; many actual stoves being
certified at significantly less than the emission standard; some non-
replacement of catalysts and bootlegging of non-certified stoves), the
Department believes the most reasonable and justifiable approach is to
select a 9/4 standard. The 9 g/hr portion of the standard is likely
technology forcing for non-catalytic stoves, but a number of members of the
woodstove industry believe that such a standard would provide a potentially
achievable goal and would not discourage research in meeting this goal.
Condar Particulate Measurement Method Equivalency
Considerable testimony was submitted by the Condar Company in support of
recognizing the Condar particulate sampler as equivalent to the Oregon
Method 7 method now in the proposed rules. Equivalency criteria was
originally proposed in the rules and the Condar sampler has been tested
against this criteria. The criteria required consistency relationships
between the reference method and candidate method test points of ± 24$.
Fourteen simultaneous tests were run with both methods and 7 of the 14
failed the ± 24J criteria. Condar has requested that the consistency
criteria be modified to ± 41. 6J. At this level, Condar1 s analysis of the
data indicates 1 of 14 data pairs would fail the new criteria, while
Department analysis indicates 3 of 14 would fail.
If the weighted average of the four required tests over the full heat
output of the stoves are used to compare consistency relationships between
these two methods, the consistency relationship improves. EPA has new con-
sistency criteria out for the proposed new 10 micron particulate matter
standard which requires consistency between methods of ± 20%. This would
be more appropriate criteria to apply to woodstove particulate testing.
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EQC Agenda Item No.
June 8, 1984
Page 9
Applying this criteria to the weighted average Condar data would result in
1 of 3 tests failing. However, if dual Condar sampler data is used
(averaging the results of the dual samplers), then all three tests
would meet the criteria. The Department proposes to modify equivalency
criteria to more closely match proposed EPA ambient particulate matter
equivalency criteria. This should allow dual Condar sampling to be
recognized as equivalent to Oregon's Method 7 (with application of an
appropriate correction factor) with just a minimal amount of further
equivalency testing. The recognition of equivalency would not be expected
to reduce testing costs significantly or reduce the stringency of meeting
applicable emission standards. Recognition of the Condar sampler, though,
would make it much easier for manufacturers to perform the same
certification tests independent labs would perform. This could give
manufacturers more confidence in the ability of their unit to pass the
emission standard before incurring the large expense of actual independent
certification testing.
There was some assertion made that the Condar sampler simulated ambient
particulate measurement better than Oregon Method 7 and hence, it should be
the reference method. The Department sees no convincing proof of this
assertion. On the contrary, it can be argued that the Condar method
includes some water associated with hydrophilic particulate in woodstove
emissions. Oregon Method 7 and EPA's ambient high volume sampling method
both dessicate samples, thus removing water before weighing in contrast to
the Condar method which does not.
Condar Heating EfficienGv Method Equivalency
Condar Company supplied extensive testimony in support of recognition of a
simplified heating efficiency test method which could potentially sub-
stantially reduce certification testing costs. An actual statistical
analysis of the simplified method in comparison to Department results using
the reference stack loss or calorimeter room method was not provided. The
Department has shown that calorimeter room data is within 1} on an average
of the stack loss method. If the Condar Company can show similar
consistency in the future, this method could be potentially recognized
as equivalent. Equivalency criteria has been added to the proposed rules
to allow recognition of other heating efficiency test methods.
Reduction of Required Number of Teats
Some testimony suggested that testing costs should be reduced by reducing
the number of tests, especially for smaller manufacturers or for specialty
stoves with limited sales. The Department had originally felt two tests
would be sufficient to accurately judge stove compliance with emission
standards near the referenced 13|000 Btu/hr heat output level. Advisory
Committee and national industry views strongly supported requiring four
tests over an entire heat output range in order to: provide better
consumer information for optimum stove operation; correctly size stoves to
home heating needs; and provide useful data for other parts of the country
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EQC Agenda Item No.
June 8, 1984
Page 10
which might adopt a regulatory program at heat output levels different than
the Oregon 13,000 Btu/hr reference level. Manufacturers generally felt the
extra cost of testing at four points would, in the long run, save
manufacturers testing costs in other areas of the country. The Department
concurred with the Advisory Committee and industry views.
In certain instances, though, where stove model sales are very small
because of the size of the manufacturer or the specialty nature of the
stove, the Department can see value in allowing a two emission/efficiency
test option near the 13,000 Btu/hr reference point and a heat output
efficiency test at maximum firing rate. This would provide the necessary
information for determining compliance with the emission standard and for
sizing stoves to home heating needs. This alternative could reduce testing
costs by about 1/3 and provide an incentive to get more stoves certified
and thus provide more consumer selection.
Should too many manufacturers opt for the two emission test alternative
though, the overall airshed benefits of label information including optimum
operating point identification could be lost. A policy of allowing the two
emission test option in special cases of very small sales volume of a stove
model and requiring written notification to the Department prior to such
testing could provide some protection from abuse of this alternative. If
the option appeared to become too widely used, the Department would propose
to deal with the issue through further rule change.
Confidentiality of Stove Design
Some testimony raised concern about the need to protect certain stove
design plans with a confidentiality provision. ORS 468.095(2) provides
such protection if any stove manufacturer would request such confident-
iality protection in writing.
Payment of Certification Fees
There were some concerns that certification fees were too high and that
they should be collected through retail sales. HB 2235 specifically
authorizes certification application fees to be required from the
manufacturer or dealer. The proposed fees are the Department's best
estimate to cover costs of the program. No other billing system is
permitted by HB2235.
Fireplace Insert Test Procedure
Some testimony indicated a test procedure was needed for fireplace inserts.
Stove-like fireplace inserts are consuming a large portion of the stove
market and they are being proposed to be regulated in the certification
program. Specific test procedures were originally incorporated in the
proposed test procedure to cover testing of such devices and must have been
overlooked by the person providing such testimony.
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EQC Agenda Item No.
June 8, 1984
Page 11
DEQ Inspection, of Stove Manufacturers and DEQ Review of Stove Design Changes
Some testimony questioned the value of DEQ inspecting manufacturing
facilities to see that stove manufacturers continually met certification
designs. Also questioned was the need for DEQ to review and approve design
changes in stoves. Suggestions were made to let accredited labs do this
jsince they already do this for safety testing follow-up.
The Department has never had any intent to check manufacturing facilities.
The Department's primary enforcement mechanism is planned to be random
stove retailer checks where changes in designs by the manufacturer or
retailer can be identified. The Department will also check for the selling
of non-certified stoves during the retailer visits.
Considering the differences in areas of expertise between testing labs and
Department staff and the overall responsibility of the Department to
enforce the certification program, the Department believes it is reasonable
for the Department to review design changes to determine if they have the
potential to change emission and efficiency performances and hence affect
the continued validity of certification status.
Revocation of Certification
Testimony was submitted requesting a one year period before revocation of
certification in cases where labs are found to have improperly conducted
tests.
The Department believes procedures for revocation in OAR 340 Division 11
will provide due process and reasonable time for the revocation process.
Sale of Non-Certified Stoves
In one person's testimony, it was suggested that the rules be revised to
allow sales, etc. of non-certified woodstoves which are intended to be used
out-of-state. The Department's Counsel has advised that the State has
clear authority to prohibit retail sales, etc. of uncertified stoves in the
state even though certain of the consumers intend to use them out-of-state.
To base the regulations of retail sales in Oregon on the residency or
intent of the buyers would raise substantial problems of enforceability.
Therefore, the Department continues to propose to regulate all retail sales
in Oregon and all sales to Oregon retailers. Consequently, the presence of
an uncertified new woodstove in an Oregon retailer's showroom would
constitute a prima facie violation, without inquiry into the intent or
residency of prospective consumers.
It was this person's opinion that it did not appear to be the purpose of
the legislation nor would it be within the Jurisdiction of the Department
to regulate out-of-state emissions. This person concluded that it would
constitute an undue burden on interstate commerce in violation of the
United States Constitution. Because it is not the intent of the
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EQC Agenda Item No. A
June 8, 1984
Page 12
Department to regulate emissions throughout the country wherever Oregon
manufactured woodstoves might be used, the Department proposes to revise
the proposed rules to provide an exception to the prohibition of selling,
etc. an uncertified new woodstove, generally to not prohibit certain
wholesale transactions particularly those involving new woodstoves intended
for out-of-state retailers and consumers.
Degradation of Non-Catalyst Stoves
Some testimony requested that degradation of non-catalyst stoves be
considered in setting the emission standards in a manner similar to what is
proposed for catalyst stoves.
The Department recognizes that degradation in non-catalyst stove emission
performance can occur. However, this degradation in the form of warped
doors, burned out baffles and deterioration of thermostats are common to
both technologies and difficult to quantify. Catalyst degradation is
quantifiable and failure is expected before the total wearout of the stove
itself.. Therefore, the Department feels it is Justifiable to apply a
degradation factor just to catalyst stoves.
Reoertification Every Five Years
Some concern was raised about the need and costs for recertification every
five years. The Department had originally proposed that recertification
fees and testing requirements can be waived if no changes have been made to
the stove design which affect emissions. The Department believes it is a
reasonable policy to review the certified design specifications of each
certified stove against the actual production model stove each five years
to insure that no changes have been made without prior approval.
Catalytic Warranties
One catalyst manufacturer requested that the Department's proposed 2-year.
free replacement warranty requirement be changed to a 5-year prorated
warranty. The Department believes prorated warranties do not offer as much
consumer protection and, therefore, protection of the airshed, as full
replacement warranties, therefore, the Department does not propose to
change this requirement.
Advisory Coffi tt.ee Periodic Program Review
HB 2235 indicates an Advisory Committee may be formed to aid and advise the
Commission on adoption of emission standards and test procedures for wood-
stoves. While testimony requested the Advisory Committee periodically meet
to review the program, once the rules are adopted there is no specific
statutory authority for this particular advisory committee to continue in
existence. The Department believes the proper role of an advisory
committee in the future should be to continue to review and comment on rule
changes that the Department may propose in the future. The Department
would propose to appoint such an advisory committee, when and if necessary.
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EQC Agenda Item No.
June 8, 1984
Page 13
Test Procedure Equipment Specifications
Some testimony requested some minor changes in testing equipment speci-
fication. Changes considered reasonable have been made to the proposed
rules.
SUMMATION
1. The 1983 Oregon Legislature passed HB 2235 which requires the EQC to
adopt rules by July 1, 1984 to cover certification of new woodstoves.
2. The Department has worked extensively with a Woodstove Advisory
Committee, primarily representing Oregon's woodstove industry, to
develop proposed rules.
3. The Department and Woodstove Advisory Committee have been in virtually
unanimous agreement as indicated by committee votes with the parts of
the proposed rules dealing with testing procedures, certification
process requirements, laboratory accreditation and labeling. The
Department and Advisory Committee had different views on the second
stage of the emission standard.
4. Extensive hearings were held on the proposed rules throughout the state
during the first week in May. Approximately 112 people testified or
submitted testimony, some on behalf of major organizations.
5. The major issue raised in the hearing process came from the woodstove
industry which challenged the need and achievability of the second
stage of the emission standard which would represent approximately an
80} reduction in partlculate emissions in comparison to conventional
stoves.
6. The Department has extensively analyzed the information submitted by
the woodstove industry in support of their concern about the second
stage standard. The Department concludes that issues raised about the
uncertainty in airshed models, emission rates of baseline stoves, and
realism of test fuel density do not Justify making any changes in the
proposed rules. The Department finds that the issues of downward
adjustments to population projections used to project future wood use
and performance of production model catalyst stoves have merit.
7. Reassessment of airshed needs based on downward revised population
projections of about 25? indicate woodstove certification emission
reduction needs should be revised from the original 75 to 80? range in
the Portland and Medford airsheds to a 72 to 78? range.
8. Woodstove industry testimony indicated that the Department had
erroneously based its belief that catalyst stoves could meet a 3
gram/hr (80? reduction) standard on a prototype stove with a
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EQC Agenda Item No. A
June 8, 1984
Page 14
obsolete catalyst. Recent Department tests of three production model
stoves using the best available technology and newly designed catalysts
still indicate attainment of a 3 gram/hr standard but 2 of the 3 stoves
Just barely attained compliance. Statistical analysis of the
variability in these stoves' emission performances indicate a standard
of 4 grams per hour would be necessary to insure confidence that most
of these stove designs incorporating this technology would comply.
9. Considering that slightly less airshed reductions are needed than
originally thought due to recent downward revised population growth
projections and that best-available-technologyf production model
catalyst-stoves have slightly higher emission rates than the prototype
stove originally tested by the Department, the Department believes a
stronger case can be made to support a 9/4 emission standard than
a 7/3 emission standard. A 9/4 emission standard should provide at
least a 70-74? reduction in woodstove emissions. Such reductions would
also support Department legislative testimony which indicated a 68-75$
reduction was achievable with available technology.
10. The Department believes a dual Condar participate sampling technique
can be recognized as equivalent to Oregon Method 7 with minimally more
equivalency testing.
11. The Department believes that a two emission test option with a maximum
heat output efficiency test should be allowed in lieu of 4 tests to
reduce testing costs only in instances where prior written notice is
given to the Department and where small sales volumes of stoves are
expected, such as in the case of specialty stoves. 'Such tests would be
limited to Oregon Method 7 measurement because of increased
inaccuracies of the Condar sampling techniques with less than four
tests. Should this policy be abused, further rule changes would be
recommended to insure that the overall airshed benefits of full
performance labelling are not lost.
12. The Department believes that the specific statutory basis for the
Woodstove Advisory Committee expires with the adoption of the proposed
rules. An advisory committee may be appointed in the future to comment
on rule changes the Department may propose.
13- Other issues raised by testimony do not warrant modifications to the
proposed rules with the exception of clarification of sales of non-
certified stoves between Oregon manufacturers and dealers and to
non-Oregon businesses or residents and minor revisions to test
instrument specifications.
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EQC Agenda Item No. A
June 8, 1984
Page 15
DIRECTOR* S RECOMMENDATION
Based on the Summation, the Director recommends that the Commission adopt
the revised proposed rules OAR 340-21-100 through -166 in Attachment 4 as
an amendment to the State Implementation Plan.
Fred Hansen
Attachments: 1. Hearings Officers* Reports
2. Summary of Written Testimony Submitted as Part of Hearing
Record.
3. Draft Statement of Need For Rulemaking and Land Use
Consistency Statement
4. Proposed Revisions to Draft Rules OAR 340-21-100 Through
-166
AA4422
J.F. KCWALCZYK:s
229-6459
May 23, 1984
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Attachment 4
(DRAFT RULES)
WOODSTOVE CERTIFICATION
Chapter 340, Division 21, Sections 100-166
340-21-100 Definitions
-110 Requirements for Sale of New Woodstoves in Oregon
-115 Exemptions
-120 Emission Performance Standards and Certification
-130 Testing Criteria and Procedures
-140 General Certification Procedures
-145 Changes in Voodstove Design
-150 Labelling Requirements
-152 Permanent Label
-154 Removable Label
•156 Label Approval
-160 Laboratory Accreditation Requirements
-161 Accreditation Criteria
-162 Application for Accreditation
-163 On-Site Laboratory Inspection and Stove Testing Proficiency
Demonstration
-164 Accreditation Application Deficiency, Notification and Resolution
-165 Final Department Administrative Review and Certification of
Accreditation
-166 Civil Penalties, Revocations and Appeals
Appendix: Oregon Department of Environmental Quality, Standard Method
for Measuring the Emissions and Efficiencies of Woodstoves,
[March 8, 1984] Mav ?1.
AA4165
-1-
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(DRAFT RULES)
WOODSTOVE CERTIFICATION
Chapter 3^0, Division 21, Sections 100-166
Definitions
340-21-100 Unless otherwise required by context, as used in this Division:
(1) "Accredited" means a woodstove testing laboratory holds a valid
certificate of accreditation issued by the Department.
(2) "Audit test" means a test [used] conducted by the Department to verify
a laboratory's certification test results.
(3) "Catalyst-equipped" means a woodstove with a catalytic con bus tor that is
an integral component of the design and manufacture of a woodstove.
"Certify" means the Department has acknowledged in writing that a
woodstove meets Department emission standards when tested by an independent
laboratory according to Department test procedures.
"Coraunigr1* means anv person who buva a woodatove for oera
"Dealer" meana anv person engaged in yelling wpodatovea to retail era ir
other dealers for resale. A. dealar uhloh ia alan an Oregon
be considered to be only a retailer for purposes qf these rules.
AA4165 -2-
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[(5)] C-7) "Fixed air supply" means an air supply system on a woodstove which
has no adjustable or controllable air inlets.
C(6)J C8) "Heat output" means the heat output (3tu/hour) of a woodstove
during one test run, measured under test conditions prescribed by OAR 3^0-
21-130.
[(7)] £9) "Informal Departmental conference" means a meeting of a
manufacturer, dealer, retailer, or laboratory representative and a
representative of the Department to discuss certification or accreditation
denial or revocation, or civil penalties. An informal Departmental
conference is not part of a judicial process or the formal hearing process
as described in Oregon Administrative Rules Chapter 340, Division 11.
•. *
MO) "Manufacturer" means anv person who constructs a voodstove or parts for
veodstovea.
[(8)] £1H "New Woodstove" means any woodstove that has not been sold,
bargained, exchanged, given away or has not had its ownership transferred
fron the person who first acquired the woodstove from the manufacturer's
dealer or agency, and has not been so used to have become what is commonly
known aa "second hand" within the ordinary meaning of that term.
[(9)] 112) "Overall efficiency (J) over the range of heat outputs tested"
means the weighted average combustion efficiency (J) multiplied by the
weighted average heat transfer efficiency ($) measured under test conditions
AAJM65 -3-
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(range of heat outputs) and calculated according to specific procedures
prescribed by OAR 340-21-120(5). This definition is applicable to the Stack
Loss Methodology. For the Calorimeter Room Method, the weighted average
overall efficiency means the useful heat output released to the room,
divided by the total heat potential of the fuel consumed.
M3) "Retailer" means anv person enaged in the sale of voodatovea directly
[(10)] (1ft) "Smoke emission rate (grams/hour) over the range of heat outputs
tested1* means the weighted average particulate emissions (grams/hour) that
are produced by a woods tore under test conditions (range of heat outputs)
specified in OAR 340-21-130 and calculated according to procedures specified
in OAH 3^0-21-120(5).
[(11)] (15) "Weighted average" means the weighted average of the test
results to the distribution of home heating needs in Oregon. (Refer to OAR
340-211-20(5)).
[(12)] (16) "Woodstove" means a wood fired appliance with a closed fire
chamber which maintains an air-to-fuel ratio of less than 30 during the
burning of 90 percent or more of the fuel mass consumed in the low firing
cycle. The low firing cycle means less than or equal to 25 percent of the
maximum burn rate achieved with doors closed or the minimum burn achievable,
whichever is greater.
AA4165
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Requirements for Sale of Hew Woods tores In Oregon
340-21-110(1) On and after July 1, 1986, a person shall not advertise to
sell, offer to sell, or sell a new woodstove in [the State of] Oregon unless:
(a) The woodstove has been tested to determine its emission performance
and heating efficiency in accordance with criteria and procedures specified
in OAR 3^0-21-130; and
(b) The woodstove is certified by the Department in accordance with
procedures in OAR 340-21-140 as meeting the emission performance
standards specified in OAR 340-21-120; and
(c) The woodstove is labelled for emission performance and heating
. •
efficiency as specified in OAR 340-21-150[.]} provided, however, that tjhia
section (1^ shall not apply to anv gftle fr*3m anv manufacturer or dealer; ta
anv Oregon manufacturer or dealer! OP to any out-of-state manufacturer.
dealer or reta-tl er; or to any offer or advertisement for such flal *> fl
only tn auc a manufacturr- lr or out-of-state retil r-
(2) No manufacturer, [or] dealer or retailer shall alter either the
permanent or removable label in any way from the label approved by the
Department pursuant to OAR 340-21-156.
AA4165 -5-
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(3) Violators of any of the above rules may be subject to civil
penalties pursuant to OAK Chapter 340, Division 11 and 12 or other remedies
prescribed by rule or [order.] statute.
iptions
3*0-21-115 (1) Wood-fired appliances that are not suitable for heating
equipment in or used in connection with residences or commercial
installations are excluded from 340-21-110. For example, portable
camping stoves.
(2) Wood-fired forced air furnaces that primarily heat living space or water
through indirect heat transfer using forced air duct work or pressurized
water systems are excluded from 340-21-110.
Performanc* Standards and Certification
340-21-120 (1) New woodatovea with minimum "heat output" of less than 40,000
Btu/hr advertised for sale, offered for sale, or sold in [the State of]
Oregon within the period July 1, 1986 to June 30, 1988, shall not exceed the
following weighted average participate emission standards when tested to
procedures in OAfl 340-21-130.
AA4165 -6-
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(a) 15 grams per hour for a non-catalytic woodstove, or
(b) 6 grans per hour for a catalyst-equipped woodstove.
(2) New woodstoves with minimum "heat output" of less than 40,000 [Btu/hr]
Btu oer hour advertised for sale, offered for sale, or sold in [the State
of] Oregon on or after July 1, 1988 shall not exceed the following weighted
average particulate emission standard when tested and measured according to
test procedures in OAR 340-21-130.
(a) [7] 3. grams per hour for a non-catalytic woodstove or
(b) C33 JL grams per hour for a catalyst-equipped woodstove.
(3) New woodstoves with a minimum "heat output" of greater than 40,000 Btu
per hour, advertised for sale, offered for sale, or sold in [the State of]
Oregon after July 1, 1986 shall not exceed an average particulate emission
standard equal to the sum of 8.0 grams per hour plus 0.2 grams per hour for
each thousand Btu per hour heat output when tested to procedures in OAB 340-
21-130.
(4) The Department will certify a woodstove as meeting the applicable
woodstove emission standard after July 1, 1984 in accordance with procedures
in OAfl 340-21-140.
AA4165 -7-
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(5) The weighted average particulate emission shall be calculated as
follows:
where: E is the weighted average particulate emission rate in grams
per hour; E-j, Eg, Ej.-.En are the particulate emission rates in grams per
hour from test runs 1 through n in order of increasing heat output; and K-j
K2» 53... Kn are the weighting factors for test runs 1 through n.
The weighting factors (K^) are calculated as follows:
where Pj_ is the cumulative probability from Table 1 for the heat out-
put measured during each test run, Po s 0, and P^.^ s 1.
AA4165 -8-
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Table 1
(OAR 3^0-21-120)
CUMULATIVE PROBABILITY FOR A GIVEN HEAT OUTPUT
DEMAND BASED ON OREGON CLIMATE (POPULATION WEIGHTED*)
Heat Output
(Btu/hr)
0
600
1,200
1,800
2,400
3,000
3,600
4,200
4,800
5,400
6,000
6,600
7,200
7,800
8,400
9,000
9,600
10,200
10,800
11,400
12,000
12,600
13,200
13,800
14,400
15,000
15,600
16,200
16,800
17,400
18,000
18,600
19,200
19,800
20,400
21,000
21,600
22,200
22,800
23,400
24,000
Cumulative
Probability f
0.02640
0.03071
0.03503
0.04130
0.04888
0.05863
0.06879
0.08122
0.09837
0.11586
0.13522
0.15803
0.18394
0.21615
0.24867
0.28798
0.32621
0.37040
0.41575
0.46226
0.50831
0.55778
0.60326
0.64770
0.68572
0.72483
0.75743
0.78883
0.81816 .
0.84386
0.86822
0.88951
0.90667
0.92228
0.93620
0.94720
0.95545
0.96158
0.96699
0.97151
0.97515
Heat Output
(Btu/hH
24,600
25,200
25,800
26,400
27,000
27,600
28,200
28,800
29,400
30,000
30,600
31,200
31,800
32,400
33,000
33,600
34,200
34,800
35,400
36,000
36,600
37,200
37,800
38,400
39,000
39,600
40,200
40,800
41,400
42,000
42,600
43,200
43,800
44,400
45,000
45,600
46,200
46,800
47,400
48,000
> 48,000
Cumulative
Probability f_P)
0.97873
0.98256
0.98540
0.98713
0.98972
0.99096
0.99237
0.99316
0.99408
0.99472
0.99506
0.99526
0.99563
0.99589
0.99679
0.99711
0.99745
0.99774
0.99787
0.99817
0.99837
0.99851
0.99858
0.99882
0.99899
0.99915
0.99933
0.99945
0.99958
0.99968
0.99974
0.99986
0.99992
0.99995
0.99996
0.99999
1.00000
1.00000
.00000
.00000
1.00000
• Based on ambient temperature data during October through April, 1967-73 with
population weighting from eight Oregon locations (Portland, Medford,
Pendleton, Astoria, Burns, North Bend, Redmond, and Salem).
AA4165
-9-
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Testing Criteria and Procedures
3*0-21-130 (1) To be considered eligible for certification, a woodstove
must be tested in strict conformance with criteria and procedures contained in
the document Standard Method for Measuring the Emi^aiqns and Efficiencies of
jteaidenttal Woodatovea dated [March 8;, 1983], Mav 21. 1984. and incorporated
herein by reference and on file at the Department.
(2) All testing for certification purposes shall be conducted by a stove
testing laboratory accredited by the Department in accordance with
procedures specified in OAR 3^0-21-160.
(3) The Department may permit minor changes in the testing criteria and
procedures which the Department believes does not affect its accuracy with
respect to compliance with the emission standard providing such changes are
approved in writing by the Department prior to the actual conducting of such
tests.
General Certification Procedure
3*0-21-140 (1) Any woodstove manufacturer, or dealer, wishing to
obtain certification of a woodstove shall file an application with the
Department.
(2) An application for certification must include:
AA4165 -10-
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(a) An appliance description which includes the woodstove model name and
design number, a copy of the -appliance1s operating manual and a photograph
of the stove.
(b) Design plans of the woodstove, identified by design number, which
include overall dimensions of the appliance and all dimensions and
specifications of components critical to emission control and heating
efficiency performance. These components shall include combustion chamber
configurations, all air inlet controls, heat exchanger design and make and
model numbers of applicable purchased parts.
(c) All test data and support documentation shoving that the woodstove
has been tested in accordance with OAH 340-21-130 and that it meets the
emission performance standard specified in OAR 340-21-120.
(d) A non-refundable certification fee, payable to the Department at the
time the application is submitted to the Department, is required for each
stove model seeking certification. The fee is:
(a) $1600.00 for a manufacturer's first model seeking certification,
and
(b) $ 800.00 for each additional model submitted by the manufacturer.
(3) The Department will promptly review an application for
certification and:
AA4165 -11-
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(a) Notify the applicant in writing within 30 days of receipt of the
application, of any deficiencies in the application that cause the
application to be incomplete.
(b) Notify the applicant within 60 days of receipt of a completed
application whether certification is granted or denied pursuant to Sections
4 and 7 below.
(4) When all the proceeding requirements have been met, the Department
will issue or deny a certification document to the manufacturer or dealer
for the specified woodstove.
(5) If the Department grants certification, the certification status
shall be effective for no longer than 5 years unless extended or terminated
by rule or order.
(6) An application for a new document of certification shall be made by
submitting a completed application including retesta and fees at least 60
days prior to expiration of certification. The Department may waive the
retest and fees if the applicant demonstrates the previous evidence used to
certify the woodstove has not changed and remains reliable and applicable.
(7) If the Department denies certification of a woodstove, the
Department will notify the manufacturer or dealer in writing of the
opportunity for a hearing pursuant to OAH Chapter 340, Division 11.
AA4165 -12-
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Changes In Yoodstore Design
340-21-145 Certification of woodstoves shall be valid for only the specific
model, design, plans and specifications which were originally submitted, tested
and approved for certification. Any modification to the model, design, plans or
specifications shall cause the certification to be ineffective and any so
modified woodstoves to be uncertified, unless prior to making such modification
the certification holder submits the proposed modification to the Department for
approval, and the Department approves it. The Department may approve the
proposed modification if the holder demonstrates and the Department finds that
the proposed modification would not affect emission performance or heating
efficiency.
340-21-150 Woodstoves which must be labelled pursuant to OAH
340-21-110 and shall have affixed to them:
(1) A permanent label, that has been previously approved by the Department
in writing as to form, content and location, that shows the test emissions
and heating efficiency for the range of heat outputs tested.
(2) A point-of-sale removable label that verifies certification and shows
how the appliance's emission test results compare with the Oregon emission
performance standard; and shows the heating efficiency and heat output range
AA4165 -13-
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of the appliance. The label shall be affixed to the appliance at the point-
of-sale near the front and top of the stove and remain affixed until sold
and delivered to the consumer.
340-21-151 All woodstoves certified by the Department from July 1, 1984 on,
shall be labelled with a permanent and a removable label.
Permanent Label
340-21-152 (1) The permanent label, or "Certified Test Performance"
label, shall contain the following information:
(a) Testing laboratory
(b) Date tested
(c) Test procedure used
(d) Manufacturer of appliance
(e) Model
(f) Design number
AA4165
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(g) The statement: "Performance may vary from test values depending
on actual home operating conditions."
(h) A graph showing:
(A) Smoke emission rates, in grams/hour, over the range of heat outputs
tested.
(B) Overall efficiency over the range of heat outputs tested.
(2) The axis of the graph shall be identified as follows:
(a) Vertical axis, left side: "Smoke - grams/hour", with a scale of
0 to a maximum of 20, bottom to top.
(b) Vertical axis, right side: "Efficiency - 3", with a scale of a
minimum of 50 to a maximum of 90, bottom to top.
(c) Horizontal axis, bottom: "Heat Output - Btu/hour", with a scale
from 0 to a maximum of 5,000 Btu/hour higher than the highest
tested heat output.
(3) Curves describing emissions and efficiency at various heat outputs
shall be printed on the graph, and will be developed by the Department
as follows:
AA4165 -15-
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(a) The emissions curve will be developed by the Department by
fitting the emission test data to the quadratic equation:
y a
where
y s participate emissions (grams/hour)
z s heat output (Btu/hour)
ao, a-j, &2 ~ regression coefficients
(b) The overall efficiency curve shall be developed by the Department
by fitting the efficiency test data to the quadratic equation:
y s BO + a-|Z •»• a2x2
where
y s overall efficiency (J)
z s heat output (Btu/hour)
ao, »1, *2 s regression coefficients
(U^ If the tvo teat oetion frefer to Oregon DEQ Standard Method Far
Measuring T>ie ^m^g^^ons and Efficiencies of Woodatovea. Section S.8.8. Mav
21. 1Q81H la used to test for Missions and overall efficiency, theni.
AA4165 -16-
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The emissions and efficiency performance of the appliance will each be
described bv a line between the two test data points.
The maximum heat output will be identified as a single oolnt.
The statement: "Not tested over entire heat output range of appliance"
will be placed on the permanent label.
[(*)] £5T For woodstoves with a fixed air supply which have only two data
points for emissions and two data points for overall efficiency the
Department will :
(a) Develop the emission performance description by averaging the two
emission data points and describe the performance on the graph with
a single point representing the average.
(b) Develop the overall efficiency performance description by averaging
the two efficiency data points and describe the performance on the
graph with a single point representing the average.
1(5)] tfiV The curves, lines or single points will be developed and fit on
the graph by the Department and transmitted to the appliance manufacturer
for printing on the label. Changes from the above criteria may be made by
the Department as necessary to insure readability. Approval of the label
design, layout, and location on the woodstove will b« made by the Departaent
and shall be obtained pursuant to OAfl 340-21-156.
C(6)] £7) The label shall be permanently secured or fixed to the appliance
AA4165 -17-
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so that it is visibly located on the appliance and legible, and meets
the following criteria:
t
(a) A permanent label shall be a label that cannot be removed from the
appliance without damage to the label. The label shall remain
legible for the maximum expected useful life of the appliance in
normal operation.
(b) A label shall be readily visible after installation. Approval of
the locatio'n of the label on a woodstove will be made by the
Department and shall be obtained pursuant to OAH 340-21-156. The
label may be located on:
(A) Any visible exterior surface except the bottom of the
appliance, or on
(B) Any interior surface of the appliance, within stove
compartments, or under overlapping covers or doors, or at
another interior location, if the label can be seen after
installation and will remain legible for the life of the
stove.
(c) A legible label shall be quickly and easily read.
(d) It shall be acceptable to combine the permanent label with another
label, such as a safety label, if the design and integrity of the
AA4165 -18-
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permanent label is not compromised, and if the combination label meets
the approval of the Department.
C(7)J 131 Physical and Material Specifications
(a) The minimum dimensions of the label shall be at least 3-1/2" long
by 2" wide.
(b) The graph on the label shall be at least 3" long by 1-1/2" wide; and any
enlargement of the graph shall maintain a proportion represented by the
length to width ratio of 2:1.
(c) The label must be made of a material that will satisfy the
permanency rule (3*0-21-152(6)(a)). For instance, it may be made of
aluminum, brass, galvanized steel, or another metal, and of a thickness
that will ensure permanence of the label.
(d) The information on the label shall be applied to the label in a way
that will satisfy the permanency and legibility rules (3*0-21-152(6)(a) and
(c)). For instance, the information may be etched, silk-screened, or die-
stamped onto the label.
(e) The label shall be secured to the appliance in a way that it will
satisfy the permanency and visibility rules (3*0-21-152(6)(a) and (b)). For
instance, the label may be riveted, screwed, or bolted onto the appliance.
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Beaorable Label
340-21-154 (1) The point-of-sale removable label, or "Emissions and
Efficiency Performance" label, shall contain the following information:
(a) "Smoke (Ave.) grams/hour", weighted average of tested values.
(b) "Efficiency (Ave.) Jn, weighted average of tested values.
(c) Summary of the applicable emissions standard.
(d) Heat output range, tested values.
(e) Manufacturer of appliance.
(f) Model of appliance.
(g) Design number of model.
(h) A statement verifying certification.
(i) The statement "Performance may vary from test values depending
on actual home operating conditions."
AA4165 -20-
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If the tvo test option la used frp test f'jr gmiaai^na and efficiency.
statement "Not Tested Over Entire Heat Outnut flange of Appliance" will
be Placed on the removable label.
(2) The label shall be visibly located on the appliance when the
appliance is available for .inspection by consumers.
(3) This label may not be combined with any other label or with
other information.
(4) The label shall be attached to the appliance in such a way
that it can be easily removed by the consumer upon purchase. For
instance, the label may be attached by adhesive, wire, or string.
Label Approval
340-21-156 (1) Permanent label
(a) The Department will provide guidance on the design of labels
by supplying information that shall be placed on the label at the
time certification is granted.
(b) The manufacturer or dealer shall submit to the Department:
(A} The name, phone number and address of the label manufacturer.
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(B) A proof copy of the label, printed on a representative sample of the
label stock, shall be submitted to the Department, if practical; if not, a
sample of the label stock shall be submitted for review with a proof copy of
the label. The copy shall be as representative of the intended final
printed label as practical. The copy shall be actual size; and shall show
the proposed label design; layout; artwork; print size, style and color; and
shall show all the information required on the label, including curves or
points.
(C) A drawing, diagram, or photograph that identifies the location of the
permanent label on the woodstove.
(D) Information that describes or shows how the permanent label will be
affixed to the woodstove. For instance, it may be a description of an
adhesive type, adhesive manufacturer, and performance characteristics; or
rivet type, rivet manufacturer, and performance characteristics.
(c) Within 14 days of receipt of all information required in (b), the
Department will approve or deny use of the proposed label.
(2) Removable label
(a) The Department will provide the manufacturer or dealer, at the time of
certification with:
(A) A copy of the standardized printed removable label, with all printing
specifications, and
AA4165 -22-
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(B) The specific information that shall be printed in the spaces on the
label by the manufacturer.
(b) The manufacturer or dealer shall submit to the Department for review:
(A) A proof copy of the proposed label with the required information
printed on the labels.
(B) The method of attaching the removable label to the woodstove.
(C) The name, telephone number, and address of the label printer.
(c) Within 14 days of receipt of all the information required in (b), the
Department will approve or deny use of the proposed label.
(3) The manufacturer shall submit to the Department three final printed
permanent, and three final printed removable labels within 1 month of
receiving the labels from the printer.
Laboratory Accreditation Bequlreaenta
340-21-160 A laboratory submitting test data pursuant to requirements
in this rule shall have a valid certificate of accreditation issued by the
Department. A laboratory may initiate application for an accreditation
certificate by submitting written documentation to the Department that
accreditation criteria contained in OAR 340-21-161 are met. In addition,
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the laboratory oust demonstrate stove testing proficiency pursuant to OAR
340-21-162, in order to qualify for accreditation.
Accreditation Criteria
340-21-161 (1) All laboratories shall meet the following criteria and
standards at the time of application and shall continue to meet these criteria
as a condition of maintaining accreditation:
(a) The laboratory shall be an independent third-party testing organization
with no organizational, managerial, or financial affiliation with any
manufacturer, supplier or vendor of any woodatove covered under its testing
programs. For example:
•
(A) The laboratory shall not be owned by any manufacturer or vendor, or own
any manufacturer or vendor of woodstoves.
(B) The management of the laboratory shall not control or be controlled by
any manufacturer or vendor.
(C) The laboratory shall not be engaged in the promotion or design of the
woodstove being evaluated or tested.
(D) The laboratory shall have sufficient diversity of clients or activity
so that the loss or award of a specific contract regarding testing would not
be a determinative factor in the financial well being of the laboratory.
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(E) The employment security status of the personnel of the laboratory shall
be free of influence or control of any one or more manufacturers or vendors
of woodstoves tested.
(b) The laboratory shall be operated in accordance with generally accepted
professional and ethical business practices. For example:
(A) The laboratory shall accurately report values that reflect measured
data.
(B) The laboratory shall limit certification program test work to that for
which it can perform competently.
(C) The laboratory shall immediately respond and attempt to resolve every
complaint contesting test results.
(c) The laboratory shall be staffed by personnel competent to perform the
test procedures for which accreditation is sought, for example:
(A) The laboratory shall assure the competency of its staff through the
observation or examination or both of each relevant staff member in the
performance of tests, examinations, and inspections that each member is
assigned to perform. The observations oust be conducted at intervals not
exceeding one year by one or more individuals Judged qualified by the person
who has technical responsibility for the operation.
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(B) The laboratory shall make available the description of its training
program for assuring that new or untrained staff will be able to perform
tests and inspections properly and uniformly to the requisite degree of
precision and accuracy.
(C) The laboratory shall maintain records, including dates of the
observation or examination of performance of all personnel.
(d) The laboratory shall be equipped with the necessary instrumentation and
equipment to test all appliances in accordance with the Department's test
procedures.
(e) The laboratory must have in place and maintain a viable record keeping
system. This means that records must be easily accessible, in some logical
order and contain complete information on the subject. Records covering the
following items are required and will be physically reviewed during the on-
site assessment either in total or by selected sampling:
(A) Measuring equipment j. [-] each instrument name and description, name of
manufacturer, model, style and serial number. Specifications on range or
level of precision, date and documentation of calibration, record of
maintenance and frequency of calibration.
(B) Data systems j. [-] samples of raw and reduced data sheets, test report
format, method (manual or automated) of data recording, analysis and
reporting.
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(C) Staff training dates and results j.
(D) Staff competency review dates and results _».
(E) Equipment calibration (or verification) records shall include the
following: equipment name or description; model, style, serial number;
manufacturer; notation of all equipment variables requiring calibration or
verification; the range of calibration/verification; the resolution of the
instrument and allowable error tolerances; calibration/verification date and
schedule; date and result of last calibration; identity of the laboratory
individual or external service responsible for calibration; source of
reference standard and traceability.
(F) Test data and reports, including emissions and efficiency calculations
fully documented and all other items required by the specific test method.
(G) Sample tracking and logging records shall trace the movement of each
stove through the laboratory from its receipt through all the tests
performed to the final test report. Dates, condition of sample, and
laboratory personnel involved should be included.
(f) The laboratory shall maintain a quality control system to help assure
the accuracy and technical integrity of its work consisting of the
following:
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(A) The laboratory's quality control system must include a quality control
manual containing written procedures and information in response to the
applicable requirements of the test procedures. The procedures and
information may be explicitly contained in the manual or may be referenced
so that their location in the laboratory is clearly identified. The written
procedures and information must be adequate to guide a testing technician
and inspector in conducting the tests and inspections in accordance with the
test methods and procedures required for the stove testing for which
accreditation is sought.
(B) The laboratory shall have a current copy of its quality control manual
or laboratory operations control manual available in the laboratory for use
by laboratory personnel and shall make the manual available to the
Department for review and audit.
•
(C) The quality control manual shall consist of general guidelines for the
quality control of the laboratory's method of operation. Specific
information shall be [is] provided for portions of individual test methods
whenever specifics are needed to comply with the criteria or otherwise
support the laboratory's operations.
(g) The laboratory shall maintain an emissions and efficiency computer
program that produces reasonably the same results to the Department's, using
a standard data set provided by the Department.
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(h) Neither the laboratory owners or business affiliates shall discriminate
in management or business practices against any person or business because
of race, creed, color, religion, sex, age, or national origin. In addition,
neither the laboratory or its owners or operators shall be certified by any
association or are members of any association that discriminates by business
or management practices against any person or business because of race,
creed, color, religion, sex, age, or national origin.
Application for Laboratory Accreditation
340-21-162 (1) A laboratory applying for accreditation shall state in
writing and demonstrate by providing documentation, that they comply with the
criteria and standards in OAR 340-21-161 at the time of application, and how
they will continue to meet the criteria and standards on an on-going basis.
(2) The laboratory shall notify the Department in writing within 30 calendar
days should it become unable to conform to any of the criteria and standards
in OAR 340-21-161.
(3) The laboratory shall demonstrate to the Department that the
laboratory's emission and efficiency computer program produces reasonably
the same results to the Department's, using a standard data set provided by
the Department.
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(U) Deficiency in the application will be identified by the Department in
writing, and must be resolved by the laboratory before further processing
occurs.
(5) The application will not be considered complete for further processing
until the laboratory certifies in writing that the deficiencies have been
revolved. The application will be considered withdrawn if the applicant
fails to certify resolution within 90 days of postmark of notification by
the Department.
(6) When the application is approvable, the Department will inform the
laboratory in writing and schedule an on-site laboratory inspection.
On-Site Laboratory Inspection and Store Testing Proficiency Demonstration
340-21-163 (1) An on-site inspection will be conducted by a Department
representative after all laboratory information required by OAR 340-21-161, has
been provided by the laboratory, reviewed and approved by the Department. The
on-site visit will be conducted when a laboratory initially applies for
accreditation and when the laboratory reappltea for a new certificate of
accreditation j. [renewal.]
(2) During the on-site inspection, the Department representative will:
(a) Observe the Stove Testing Proficiency Demonstration specified in OAR
340-21-162(3).
AA4165 -30-
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(b) Meet with management and supervisory personnel responsible for the
testing activities for which the laboratory is seeking accreditation.
(c) Review representative samples of laboratory records. To facilitate
examination of personnel competency records, the laboratory should prepare
a list of names of staff members who perform the tests.
(d) Observe test demonstrations and talk with laboratory personnel to
assure their understanding of the test procedures. Refer to OAfl 340-21-130
and 3*0-21-162(3).
(e) Physically examine selected equipment and apparatus.
(f) At the conclusion of the on-site visit,' the Department will discuss
observations with responsible members of the laboratory management pointing
out any deficiencies uncovered.
(3) In order to be accredited and as a part of each on-site laboratory
inspection, each laboratory must demonstrate to the Department's
representative its ability to successfully and proficiently conduct and
report a woodstove emission and efficiency test. Each laboratory will be:
(a) Required to test one woodstove provided by the Department. Costs for
all stove shipping, catalytic combustors, or other necessary parts will be
paid by the laboratory.
AA4165 -31-
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(b) Required to test the stove in accordance with testing criteria and
procedures specified in OAR 3^0-21-130.
(c) Conduct the actual emission and efficiency testing in the presence of a
Department observer.
(d) Submit all test data, observations and test results to the Department
for technical evaluations.
Accreditation Application Deficiency, Botlflcation and Besolutioa
340-21-164 (1) Any deficiencies noted during the on-site inspection and/or
in the test data and test results submitted from the stove testing proficiency
demonstration will be specifically identified in writing and mailed to the
laboratory within 30 days of the on-site visit.
(2) The laboratory must respond in writing within 30 days of the date of
postmark of the notification by the Department and provide documentation
that the specified deficiencies have been corrected. All deficiencies must
be corrected prior to accreditation being granted.
(3) Deficiencies noted for corrective action will be subject to thorough
review and verification during subsequent on-site visits and technical
evaluations.
AA4165 -32-
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(4) Any deficiencies in the test data and/or results may result in
subsequent proficiency tests being required at the laboratory with a
Department representative present.
Final Department AdattrtatratlTe Beriew and Certificate of Accreditation
340-21-165 (1) When all application material has been received, including
the on-site inspection and the stove testing proficiency evaluation, and there
has been time for all deficiencies to be resolved, the Department will grant or
deny accreditation.
(2) Accreditation can be denied for failure to comply with or fulfill any
of the criteria in OAB 340-21-161, -162, and -163.
(3) When accreditation is approved, a certificate of accreditation will
be issued to the laboratory. Accreditation will be granted for a period of
three years (36 months) subject to rule change or revocation for cause,
pursuant to OAB 340, Division 11.
(4) A certificate of accreditation is not renewable. A holder may obtain a
new certificate of accreditation by completing the application procedure in
OAB Chapter 340-21-162, and demonstrates compliance with OAB [Chapter] 340-
21-161 and -163.
(5) The Department may select and audit test one stove tested by the
laboratory during its accredited status to verify certification test
AA4165 -33-
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results. Any discrepancies noted will be communicated to the laboratory
by certified or registered mail. The laboratory must respond in writing
within 30 days of postmark of notification and provide documentation or
certification by an authorized member of the laboratory management that
the specified discrepancies have been corrected or the laboratory may be
subject to civil penalties or revocation of accreditation.
(6) A laboratory may voluntarily terminate its accreditation by written
request at any time. The certificate of accreditation must be returned with
the request.
Civil Penalties, Revocation, and Appeals
340-21-166 (1) Violation of any of these rules shall constitute cause to
revoke the manufacturer or dealer's woodstove certification or laboratory's
certificate of laboratory accreditation, and also may be subject to civil
penalties and other remedies pursuant to rule or statute.
(2) Certification of a woodstove may be revoked if the woodstove was tested
at a laboratory that was found to be in violation of accreditation criteria
and rules at the time the woodstove was tested for certification.
(3) When certification or accreditation has been revoked, the holder shall
return the certification or accreditation document to the Department and
cease to use mention of Department certification or accreditation of the
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stove model or laboratory on any of its test reports, correspondence or
advertising.
(4) Stove certification and lab accreditation revocation [would be] shall
be bandied as contested cases pursuant to OAH Chapter 3^0> Division 11.
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APPENDIX 1
OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY
STANDARD MET20D FOR MEASURING THE EMISSIONS AND EFFICIENCIES
OF WOODST07ES
May 21, 1984
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TABLE OF CONTENTS
Page
SECTION 1: SCOPE AND PURPOSE 1
SECTION 2: TEST FACILITY AND APPLIANCE INSTALLATION 2
SECTION 3: TEST EQUIPMENT AND INSTBU MENTATION 3
SECTION 4: TEST FUEL REQUIREMENTS 7
SECTION 5: APPLIANCE OPERATING PROCEDURE 10
SECTION 6: TEST METHODOLCCI AND CALCULATIONS 15
SECTION 7: TEST DATA 25
SECTION 8: CATALITIC COMPONENT CERTIFICATION REQUIREMENTS 26
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SECTION 1: SCOPE AND PURPOSE
1.1 SCOPE
1.1.1 This document prescribes a standard method of testing
voodstoves to obtain particulate emission factors based on
useful heat output for appliances that produce less than 1.5 z
1
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SECTION 2: TEST FACILITY AND APPLIANCE INSTALLATION
2.1 DESCRIPTION OF TEST FACILITY
2.1.1 The testing will be conducted in an area with a height for
atmospheric discharge of flue effluent at 15 ±. 1 foot
(4.6 £ 0.3n) above the top surface of the scale.
2.1.2 The flue exit shall freely communicate with the laboratory,
that is, the area shall have essentially the same pressure
such that no artificial draft is imposed on the appliance.
2.1.3 the test chamber room temperature shall be maintained between
65° F and 90° F (18° C and 32° C) during the course of any
test.
2.1.4 Air velocities within 2 feet (0.6m) of the test appliance and
exhaust system'shall be less than 50 feet/minute (0.25 m/s)
without a fire in the unit.
2.1.5 All calorimeter rooms must meet the specific criteria in the
June, 1982 Wood Heating Alliance document, Standard for
Testing the Heating Performance of Wood-Fired Closed
Combustion Chamber Heating Appliances, for accuracy
verification and calibration procedures before conducting
appliance performance testing.
2.2 APPLIANCE TVSTALLATTOM FOR F3gg STANDING ST075S
2.2.1 Unless specified differently by the manufacturers, the flue
pipe shall be made of No. 24 gauge blaclc steel and shall have
an insulated metal solid pack type chimney above the
particulate and combustion gas sample probe port locations
with a minimum 1 inch (2.5 cm) solid pack material.
2.2.2 The flue shall extend to 15 ± 1 feet (4.6 ± 0.3m) above the .
platform scale on which the appliance is located. All flue
pipe cracks or Joints shall be sealed.
2.2.3 The appliance and parts shall be assembled and installed in
conformance with the manufacturer's published installation
instructions.
2.V APPLIANCE TMSTALLATTOW FOB FTggPLACS TttSgaTS
2.3.1 Fireplace inserts shall be installed on the platform scale
with R 12 insulation applied to all surfaces not normally
exposed to the room to be heated. The appliance parts and
exhaust system shall be assembled and installed in conformance
with the manufacturer's published installation instructions.
AA2837 - 2 -
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2.3-2 The flue pipe shall consist of an insulated metal solid pack
type chimney positively connected from the appliance flue
outlet, extending to the participate and combustion gas sample
probe port locations with a minimum 1 inch (2.5 cm) solid pack
material.
SECTION 3: TEST EQUIPMENT AND INSTHOMENTATION
TEST EQUIPMENT SET-OP
3.1.1 The equipment to be used for emissions and efficiency testing
is illustrated in Figure 3.1 and described belcw.
TEST FUEL WEIGHT
3.2.1 The balance used to weigh the fuel shall be accurate
to ± 0.1 pound (0.05 kg).
3.2.2 The appliance to be tested shall be centrally placed on a
platform scale. The scale shall have a monitor or other
feature such that the weight change of the fuel loads may be
continuously displayed. The scale shall be capable of reading
weights to 0.1 pound (0.05 kg) and shall have a tare feature.
J
FLUE GAS TEMPE3ATU3ES
3.3-1 Flue gas temperatures shall be determined with a thermocouple
or other temperature sensing device at a height of 8 to 9 feet
(2.4 - 2.7 m) from the top surface of the scale. The
temperature sensing device shall be located in the center
of the flue gas stream.
3.3*2 The temperature sensor and associated display and recording
equipment shall have a resolution of 1°F (0.5°C).
STOVE SOBFACE TEMPESATUBES
3.4.1 Stove surface temperatures shall be determined with a shielded
temperature sensing device placed at 5 locations on the
appliance's exterior surfaces. Temperature locations shall be
centrally positioned on the top, two sidewall, bottom and back
combustion chamber surfaces (not on heat shields) if these
surfaces are exposed while testing. Surface temperature
locations for unusual design shapes (spherical, etc.) shall be
positioned to conform to the intent of the locations
described.
AA2837
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3.1.2 The temperature sensing device and associated display shall
have a resolution of 1°F (0.5°C).
STOVE CQMBOSTION TEMPERATURES
3.5.1 Radiation shielded thermocouple^ ) or other equivalent
temperature sensing device(s) shall be located in the primary
and secondary (if applicable) combustion chambers to measure
gas temperatures at a location where direct flame impingement
on the sensing device does not normally occur. If a catalytic
combust or is part of the stove's combustion features, an
additional thermocouple must be located in the permanent
temperature monitoring port required in Section 8.4.1.
3.5.2 The temperature sensing devices and associated display shall
have a resolution of 1°F (0.5°C).
FLCTS. GAS COMPOSITION
3.6.1 Dry flue gas composition shall be measured with continuous
combustion gas analyzers to include percent by volume (dry
basis) carbon monoxide, carbon dioxide, and oxygen. Samples
shall be extracted at the same height as flue gas temperature
measurements and withdrawn through a probe and tubing made of
inert materials. The probe shall be bent into the flow of the
flue gases.
3.6.2 A gas stream sample conditioner using a glass fiber filter is
required in line before the analyzer. The sample conditioner
shall include two iapingers encased in an ice bath, one water
trap and a silica gel trap in sequence.
3.6.3 Minimum performance specifications for accuracy and precision
for the combustion gas analyzers and recorders include:
Drift £ ±. U of full scale per 8 hours
Repeatability ± 1} of full scale
Resolution: 0.1) for C02 and 02; 0.01) for CO by volume
Accuracy: ±. 1) of scale
?.7 TRACER GAS DETECTOR
^.7.1 Minimum ogrforrganoa ap«gtf toatiQpa for aeeuraev and precision
for th» tracer gag analyser Include;
of full agati» j<»r 8 hours
^ Percent of full
Accuracy *
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?.8 FLPg MOISTTraE CONT5KT DETS3MINATTON
3.8.1 A wet bulb-dry bulb technique shall be used to determine the
water vapor present in the flue gases for on-line sampling
purposes to maintain proportional sampling and appropriate
weighting of enthalpy losses during burn cycle. A wet bulb
temperature sensor shall be placed at the same location as
the flue gas dry bulb temperature sensor. The wet bulb sensor
shall consist of a thermocouple or other temperature sensing
device with a cloth sock placed at the sensor end and
saturated with water. The wet bulb sensor shall be placed
in the center of the flue gas stream until the temperature
reaches a steady state. The wet bulb temperature must be
taken while the sock is saturated with water. The appropriate
water vapor content is determined using psychometric charts
(See Oregon Source Sampling Method 4, Appendix 1).
3.9 DRAFT
3.9*1 The draft or static pressure (in inches of water) shall be
measured in the flue at a location no greater than 1 foot
(30.5 cm) above the flue connector at the stove outlet.
10 SELATTyE HPMTDITT
3.10.1 The test facilities ambient relative humidity shall be
measured and recorded prior to and at the completion of each
test cycle.
11 DATA BECOmTVn
3.11.1 Data recording shall commence upon charging of the test fuel
load and all measurements shall be recorded either manually or
automatically at least at every 5 minute interval for the
entire test period. In addition* appliance surface and
combustion chamber temperatures are also required at every
five minute interval one hour prior to the test cycle.
3.12 INSTRUMENT CALrBBATTOW
3.12.1 notwithstanding any standard calibration procedures designed
to assure and maintain the accuracy of standard source testing
equipment, the following calibration and testing methods must
be utilized on the auxiliary equipment when testing woodstoves
for air emissions.
3.12.2 Continuous gas analyzer(s) calibration
Upon receipt of equipment or any time the single point audit
described below fails, a multipoint calibration of the
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analyzer must be completed before the instrument ia put into
service.
a) Set up the instrument and allow it to operate for a suf-
ficient time to stabilize as recommended by the
manufacturer's published operating procedure.
b) Introduce zero gas into the instrument at the normal
sample flow being careful not to pressurize the sample
stream. Normally, this will be accomplished by allowing
the zero gas to flow into a three port vessel at a rate of
at least twice the instrument sample rate and withdrawing
sample from another port on the vessel while the third
port is allowed to vent to the atmosphere.
c) Introduce consecutively in the same manner as b) three
certified calibration gases in artificial air noting the
Instrument response of each. The gases should represent
approximately 20*, 50? and 80S of the instruments' full
scale concentration.
d) Construct a calibration curve using the data collected in
b) and c).
3.12.3 Continuous gas analyzer(s) audit
Before and after each test [and at intervals not to exceed 2
hours during the test], conduct a single point audit of the
instrument as described below. Tt la highly rgeopmeRded that
a. ainfflft gptnt audit rtf the tngtr^jqent be conducted at
interval a not to Meegd 2 hours during the teat periods.
a) Disconnect the instrument sample line from the sample
source at a point upstream of all sample conditioning
equipment (dryers, scrubbers, etc.).
b) Being certain to avoid pressurizing the system, introduce
a certified reference gas into the analyzer through all
sample conditioning equipment. The sample gas should be
in the range of 205 to 80$ of full scale of the
instrument.
c) If the instrument response to the audit gas differs by
more than 5J from the calibration curve, disregard all
data collected with the instrument since the last success-
ful audit and perform a multipoint calibration.
d) Before and after each test, leak check the system by plug-
ging the inlet and watching the sample flow rotometer.
1A2837 - 6 -
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3.12.4 Platform scale auditing
a) Upon installation of the scale, a multipoint calibration
must be performed using NBS traceable weights. This
function will normally be performed by the scale
manufacturer. As soon as practicable after the
calibration, one or more weights may be weighed for uae as
a calibration traceable standard weight for audit
purposes. The weight should be constructed from a weight
stable (non-oxidizable and non-hydroscopic) material and
maintained in such a way that its weight integrity is
assured.
b) Before and after each series of tests, the scale must be
audited by first zeroing and then weighing at least one
calibration traceable weight that corresponds to 20J to
80? of the expected charge load of the stove to be
tested. If the scale does not reproduce the value of
traceable weight within ±0.4 Ibs, the scale shall be
recalibrated before use and void previous results.
3.12.5 Tracer gas flow measurement
a) 111 rotoaeters used in conjunction with tracer gas
injection flow measurement techniques must be calibrated
with the intended gas using either a calibrated volume
measurement device such as a dry or wet gas meter or an
accurate volume (displacement).
b) The tracer gas detector must be calibrated at the begining
and end of each set of tests by introduction of a
certified reference gas. The gas must b« introduced
through all normal gas conditioning devices and in such a
way as to prevent system pressurization.
SECTION 4: TEST FUEL HEQOUJEMENTS
H.1 FHEL PHQPSBTTSS
4.1.1 The test fuel shall be untreated, air dried Douglas fir
lumber, iciin dried lumber ia not pliovad. To insure positive
identification of Douglas fir, species type is stamped D.F. oo
the lumber by the certified lumber grader at the mills. The
oven-dried density range shall be 28.7-37*4 pounds per cubic
foot (.46-0.60 gm/cm3). The density shall b« determined and
reported for certification purposes.
AA2837 - 7 -
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4.1.2 The teat fuel shall have a moisture content range between 16}
and 20? on the wet baaia (19-25J dry baaia). Moiature content
shall be determined by measurements made with a calibrated
electrical resistance type moisture meter or other equivalent
performance type meter. Note: To convert moisture meter
readings from the dry baais to the wet baaia: (100HJ dry
reading) 7 (100 •»• J dry reading).
4.1.3 Minimum performance specifications for accuracy of the
moisture meter shall be +, 3J of reading.
4.1.4 Moisture content determination per load shall be an average
of a minimum of three readings for each fuel piece measured
parallel to the grain of the wood on three sides (end readings
excluded). If an electrical resistance type meter is used,
electrode penetration shall be to a one inch depth using
insulated pins. Moisture content measurements shall be made
within a four hour period prior to testing, and the teat fuel
ahall be at room temperature.
4.1.5 Ho wetting of previously dried wood is allowed. It is recom-
mended that the test fuel be stored in a temperature and
humidity controlled room.
4.1.6 The test fuel shall be essentially free of toots, and free of
any rotted or molded areas or other defects such as pitch
seams.
4.1.7 The higher heat value of the fuel shall be determined by bomb
calorimetry using ASTM Method D 3286-77 or D 2015-77. A
composite sample from each piece of the test charge shall be
analyzed and reported for each test fuel load.
4.2 TJi!ST FtreL PTECSS
4.2.1 The dimension of each piece of fuel (flanged lumber) shall
conform to the nominal measurements of 2x4 and 4x4 lumber
(1-1/2 x 3-1/2 and 3-1/2 x 3-1/2 in).
4.2.2 The flanged lumber dimensions will vary according to the
appliance* s firebox volume aa indicated below:
Usable firebox volume Flanged lumber piece size
( norni n t
1.5 2x4
1.5 i 3 2x4 approximately 1/2 weight
of test fuel load
4x4 approximately 1/2 weight
of test fuel load
>3 4x4
AA2837 - 8 -
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4.2.3 Each flanged piece shall be constructed in a configuration to
conform to the following requirement for spacer dimensions and
spacing intervals: Spacers will be constructed from air dried
Douglas fir lumber (meeting the fuel specifications in Section
4.1) 5 inches in length, 1-1/2 inches in width, and 3/4 inches
in height (12.7 x 3.8 x 1.9 cm). The spacers are to be
attached by uncoated ungalranised nails or staples to the
lumber flush with the ends of each piece such that a 3/4 inch
(1.9 cm) extension of the spacer occurs at the width of each
end of the log as Illustrated in Figure 4.2-A.
4.2.4 An optional acceptable flanged fuel configuration has
identical spacing intervals as indicated in 4.2.3, but with a
greater spacer dimension in height as depicted in Figure 4.2-
A. The optional spacer configuration must conform to the
conditions specified in 4.2.3 and Beet the 5 inches in length,
1-1/2 inches in width and 1-1/2 inches in height (12.7 x 3.8 x
3.8 cm).
4.2.5 The length of each piece of test fuel shall be of equal length
and shall closely approximate 5/6 the length of the longest
usable dimension of the firebox. (S«e 4.3.2)
4.2.6 Test fuel pieces shall b«. arranged in the firebox in
conforaance with the manufacturers published written
instructions and in a configuration which maintains air space
intervals between the logs. The fuel shall be positioned so
that the flanges are flat (parallel) to the floor of the
firebox, with the flanged edges in contact (abutting each
other). If loading difficulties result, some fuel pieces may
be placed on edge. If the usable firebox volume is between
1.5 and 3.0 ft3, alternating the piece sizes in vertical
stacking layers is required to the extent possible. For
example, 2x4's shall be placed on the bottom layer in direct
contact with the coal bed and 4x4's on the next layer, etc.
(See Figure 4.2-B). Photo documentation of the loading
configuration for each test cycle shall be provided to the DEQ
for certification purposes.
4.2.7 Appliances of unusual or unconventional firebox design shall load
the fuel in a configuration which maintains air space intervals
between the flanged lumber and is in conforaance with the
manufacturers published written instructions. Any appliance that
will not accommodate the loading configuration specified in 4.2.6,
must obtain DEQ loading configuration approval prior to testing for
certification purposes.
4.2.8 Appliances that are designed to provide continuous feed
pelletized or chipped fuel must prearrange an equivalent test
criteria agreement with the DEQ prior to testing for
certification purposes.
AA2837 - 9 -
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LOAD SIZE
4.3.1 The initial fuel load and the teat fuel charge shall be baaed
on weight per usable firebox volume. The fuel loads shall be
equivalent to seven pounds of fuel as fired per cubic foot
(112 kg/m3) of usable firebox volume ± 10 J.
4.3.2 To avoid stacking difficulties, or when a whole number of fuel
pieces does not result, all piece lengths nay be adjusted
uniformly to remain within the specified loading density.
4.3*3 Usable firebox volume means the entire volume of the (primary)
combustion chamber less any volume where firewood could not
reasonably be placed, such as areas restricted by baffles or
firebrick, (see Figure 4.3)
SECTION 5: APPLIANCE OPERATING PROCEDURE
gSETEST STABT OP
5.1.1 The pretest startup phase is designed to bring the stove up to
a stabilized operating temperature that is reflective of the
heat output range required for the following test cycle. *
5.1.2 Pretest start up will begin with ignition of kindling from a
cold start with no charcoal residue in the firebox. A layer
of cold wood ashes spread to a uniform depth of up to one
inch in depth (2.54 cm) on the floor of the firebox or ash pan
is optional. The kindling load shall consist of between 4-3
pounds (1.3 - 3.6 kg) of finely split Douglas fir with a
moisture content range up to 20J on the vet basis. Crumpled
newspaper balls loaded with the kindling shall be used to help
attain ignition. The air supply controls may be adjusted per
the manufacturer's published instructions for the kindling start up
phase.
5.1.3 After 50 - 752 of the kindling by weight has been consumed, a
pretest fuel load shall be added. The pretest fuel load shall
meet the same fuel species and moisture content specifica-
tions as the test load. The pretest fuel load shall consist of
whole 2x4 lumber pieces, without flanges, that are no less than 1/3
the length of the teat fuel. Additional fuel may be added provided
it meets the above requirements and that uniform charcoalization
and weight specifications are adhered to before the test cycle
begins.
AA2837 - 10 -
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5.1.4 The air inlet supply setting may be set at any position
desired which will maintain combustion of the pretest fuel
load. It is recocuaended that the air inlet supply setting be
set at the position necessary to achieve the lowest heat
output level of the following test cycle and be set at least one
hour prior to addition of the test fuel load.
5.1.5 To document stabilized appliance heat storage effects and to
control heat output levels, surface temperatures shall be
recorded at each 5 minute interval during the one hour period
prior to charging the test fuel.
5.1.6 Ho emissions or efficiency measurements are required during
this pretest startup phase.
5.2 TgST CYCLE QP53ATTQM
5.2.1 All stove surface temperatures shall be averaged and compared
to those recorded at the beginning and the end of each test
cycle. To approximate thermal equilibrium, the averaged
beginning and ending test cycle stove surface temperatures
muat b« within 125°F (51.7°C) of each other. For all
appliances, a correction factor shall be made to correct for
heat storage effects. The correction factor shall be 0.12
Btu/lb °F multiplied by the averaged surface temperature
difference in °F obtained from the beginning and ending
temperatures of each test cycle. Some stoves (e.g., high mass
stoves) may require more than one pretest fuel load to stay
.within the required averaged temperature range at the
beginning and at the end of the test cycle.
5.2.2 An appliance may be tested in one continuous testing period
that encompasses discrete test cycles for each of the [four]
specified heat output levels (see 5.3) provided that a one hour
minimum interval between each discrete test cycle occurs. The
Interval between test cycles provides time to reposition the air
supply adjustment to the appropriate setting, re-establish and
maintain the required coal bed, and meet the surface temperature
requirements for the next desired heat output level.
5.3 TEST FTTEL
5.3*1 When the kindling and pretest fuel load has been consumed to
leave a weight equal to 20-25 percent of the test fuel load,
the test fuel load shall be charged. Manipulation of the hot
coal bed prior to charging the test fuel load shall conform to
the manufacturer's published written instructions. In the
absence of written instructions, breaking up, raking and
AA2837 - 11 -
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uniform spreading of the embers or hot coal bed is required
prior to addition of the test fuel load. No manipulation or
rearrangement of the test fuel load configuration is allowed
during any portion of the test cycle.
5.3«2 Additional fuel may be added between the test cycle intervals,
provided it meets the fuel species and moisture content
specifications. Whole 2x4 lumber pieces, without flanges, no
less than 1/3 the length of the test fuel may be used,
provided proper re-establishment of the hot ember bed is
controlled to the specified weight criteria and uniform
charcoalization of the ember bed is adhered to.
5.U AI3 STTPPL7 COMT30L
5.4.1 Adjustment of the primary air supply controls or holding the
fuel loading door open up to the first 5 minute phase of the
test cycle is allowed to insure good ignition of the test
charge and catalyst if so equipped. Adjustments should b«
conducted per the manufacturer's published written instructions.
Immediately thereafter, the primary inlet air supply control(s),
either manual or automatic, shall be set to the position necessary
to achieve the required heat output level. No additional
adjustments of the air supply controls or opening the loading door
will be allowed during the remainder of each test cycle.
5.4.2 Maximum heat output shall be achieved by operating the
appliance with the primary air supply inlet controls fully
open during the entire fuel load cycle unless the
manufacturer's published written instructions specify that
maximum heat output occurs at another setting.
5.4.3 All other heat output levels shall be achieved by operating
the appliance with the primary air supply inlet control or
other mechanical control device set In a predetermined position
necessary to obtain average heat output levels specified in
5.8 during the entire test cycle.
5.^.4 If the primary air supply inlet control(s) cannot be adjusted
to obtain variable burn rates or variable heat output levels,
the appliance shall be tested at the fixed air supply
setting.
5.4.5 Secondary or tertiary air supply may be adjusted one time only
during each test cycle following the manufacturer's published
written instructions.
AA2837 - 12 -
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g.5 TEST C?CLS COMPLETION
5.5.1 A teat cycle ends when the entire weight A 0.1 lb (.045 kg) of
the test fuel load has been consumed, (i.e., when a bed of
coals equal to the beginning coal bed weight remains).
5.. 6 . BLOHE3S. FANS
5.6.1 The use of blowers for heat exchange is optional. Beginning
with the start of the test cycle, blower speed may be
positioned at a recommended setting but no changes in
setting will be allowed throughout the entire test period and
the position setting shall be recorded at the time positioning
occurs.
5^7 07353 APTOR75NAMCSS
5.7.1 Shaker grates, by-pass handles, or other appurtenances (not
primary air supply controls) may be adjusted one time only
during each test cycle in accordance with the manufacturer's
written published instructions, and all adjustments shall be
recorded.
NUMBER OF TESTS
5.3.1 Simultaneous emissions and efficiency tests are required
during an entire test cycle within each of four discrete heat
output ranges as indicated below.
Teat Cvele Heat -Output
(Average Btu/hr)
Category Category Category Category
1. 2. 3. *•
< 10,000 10-1 5 , 000 15-25,000 Maximum heat output
5.8.2 If the lowest sustainable burn rate produces an average heat
output greater than the first category, then two tests must be
conducted near the low and high end of the second category
plus tests at the remaining categories. A total of four test
cycles are required.
5.8.3 If the lowest sustainable burn rate produces an average heat
output greater than the second category , then two tests must
b« conducted near the low and high end of the third category
plus a test at the remaining category. A total of three test
cycles are required.
AA2837 - 13 -
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5.3.U If the lowest sustainable burn rate produces an average heat
output greater than the third category, three tests must be
conducted, one at the lowest sustainable burn rate, one at the
maximum heat output level and one at an intermediate level
between the lowest and maximum level. A total of three test
cycles are required.
5.3.5 If lowest sustainable burn rate is greater than 10,000 Btu/hr
then documentation shall be submitted to demonstrate the
actual burn rate is the lowest sustainable. This
documentation can be in the form at proof that the appliance
. was run at its lowest permanent air supply setting or test
data that demonstrates the burn rate approaches zero (less
than 0.1 kg/hr) within the area of 1 to 1.1 tines the lowest
sustainable burn time and when greater than 90* of the test
charge has been consumed. Such test data shall be collected by
following all the stove operating procedures specified in this
document.
5.8.6 If an appliance has a fixed air supply setting, two replicate
tests shall b« conducted at the "on" firing mode setting. A •
total of two test cycles are required.
5.3.7 If an appliance is unable to achieve an average heat output
level of 25,000 Btu/hr at its maximum heat output, four tests
must be conducted. One test must be conducted at the first
category, one at the second category and two tests at the
third category, one conducted near the low end of the range
and one at the maximum heat output. A total of four test
cycles are required.
S.8.8 Two Teat Option.
(&) Two teata ^T*^ atlouytfl to be used to datgr*ging gml-aaiona
and efficiency, rather than the four testa required tn
5.8.1. if one teat ia conducted In each of the tvo heat
output categories indicated below. A heat outou* and
efficiency teat al^o muat be oerforaed at the marianim
heat output.
Teat Cvele Heat Qutout
(Average Btu/hr)
Category Category
1. 2.
10,000 - 13,000 13,000 - 15,000
Tf the two teat option ia to be used, eaiaaiona testa
shall h» f>onrine£i>d in eonforaanee with. Oreion. Source
AA2837 - 14 -
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Methods 5 & 7. a.s described in 5.1.1. Overall
effieienev tasta shall fof conducted in cgnfor^anea vlth
fche galorlaetar room aethod or the stack loss ?*ethed as
described in 6.S. gguivalgnt methods of determining
emission and overall efficiency gav not be used.
For the two teat option to be considered for certifica-
tion, the Department must be given written notice prior
to actual testing for certification purposes, that sueh
option has been enosen.^
SECTION 6: TEST METHODOLOGY AND CALCULATIONS
6.1 EMISSION TESTING
6.1.1 Particulate emission testing shall be conducted in confonnance
with Oregon Source Sampling Methods 5 and 7 (Attachments 2 and 3)
with the following exceptions: 1) no traverse of the flue is
necessary, 2) sample extraction shall occur in the center of the
flue at a height of eight to nine feet above the top surface of
the scale, 3) on-line stack gas velocity and volumetric flow rate
determination will be made using an alternate method (Section 6.3).
Total volume and average flow rates for the test period will be
calculated using a simultaneous stolcnlometric carbon, hydrogen
and oxygen balance method (Section 6.2.1).' Sample extraction rates
shall be maintained at or proportional to the flue gas velocity
as determined by the measured concentration of a tracer gas
injected into the stack gases to determine dilution rate and thus,
total flow. Adjustments to the sampling rate will be made at each
five minute interval during the entire test period.
6.2 PSOCEimftES FOB DETERMINING EOPT7ALENCS BETWEEN CANDIDATE METHODS
AMP THE REFERENCE METHOD FOR VQQDSTOVE EMISSION TESTIVG
6.2.1 Determination of Equivalence
The test procedures outlined in this section shall be used
to determine if a candidate method is equivalent to the
reference method when both methods measure participate
emissions from woodstoves. Equivalence is shown for the
methods when the differences between the measurements made
by a candidate method and the measurements made simultaneously
AA2837 - 15 -
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by the reference method are less than or eq.ua! to the
precision and consistency values specified [in Table 1] belcw.
Specif icatlgna Fir Woodatove gniaaiQn Teat Methods
' Onita Liraita
Emission rate range g/hr 1.0-C20.0]
Miniaua number of test runs [5] JLfi.
Miniaum number of simultaneous
samples per test run 4
(Candidate method) . ' (2)
(Reference method) (2)
Maximum analytical precision
(individual teat punsV J 18
analytical prec
(standard deviation) 5. 10
Maximum difference in
consistent relationship $ [24] 22.
(weighted averages)
£.2.2 Test Conditions
The woodstove burn rate and operating cycle shall be in
accordance with procedures specified by DEQ. Testing
procedures and schedules shall 'be approved by OEQ at least
60 days prior to testing. All test measurements or samples
shall be taken in such a way that both the candidate method
and the reference method receive stack gas samples that are
homogenous or as nearly identical as practical.
Collect simultaneous and duplicate samples of woodstove
emissions with both the reference and candidate methods until
at least [12] J& quadruple samples (duplicate pairs of both
candidate and reference methods) have been obtained. The
[12] .!£. quadruple samples should represent [12] 16 full test
runaC. ] i faur* teat runs on eaeh of four atovea. The teata qn
ea'eh stove shall b« in »aeh of the four heat outnut rqp.gea
In th eertifleatian prqeedursa and 5.1 f hia
Calculate the emission rates as determined by the candidate
and reference methods for each test run. For the reference
method, calculate the average participate emissions for each
AA2837 - 16 -
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test run by averaging the results calculated from the
duplicate analyses (A and B):
Hi ave = RjA * B13 6.2.2.3.
where B denotes results from the reference method and where
i is the sample number. Disregard all quadruple samples for
which the particulate emission rate as determined by the
average of the duplicate reference method analyses falls
outside the range of 1.0 to [20.0] ttS.Q grams per hour (g/hr).
All remaining quadruple samples must be subjected to [both of]
the following test[s] for precision fin 6.2.3) . [and
consistent relationship. At least five samples (average of
duplicate reference method analyses) must be within the 1.0 to
20.0 g/hr range and at least one sample within each of the 1.0
to 5.0, 5.0 to 10.0, 10.0 to 15.0, and 15.0 to 20.0 g/hr
ranges for the test to be valid.]
Calculate the weighted emission rates, using the procedures
•ypeeified in PAR 340-21-120(5). aa determined bv the candidate
and reference methods fop each of the f^ur vnndatnvea tested.
Par the reference netho^, ffalgulat;^ the average weighted
aniaalfln rate for eaeh woodatove tested bv averaging the
raaulta calculated from the duolioafeg analy^flg ( A and 5). One
voodstove weighted egKaaian rate ( average of duplicate
reference method analysis) guat be within each of the
following ranges for the procedure to be va^lj; Lesa than
5.0 g/hr. 5.Q to 10. Q f/hr. 10. Q to 15.0 g/hr. and greater
than 15. Q g/hr. All vgl^hted egia^^n rates must be 3Ub^eetad
to the eanaiatent relationship test fin 6.2.H fqllgving) .
6.2.3 Test For Precision
Calculate the precision (?) of the analysis (in percent) for
each duplicate sample and for each method, as the maximum
minus the minimum divided by the average of the duplicate
analyses, as follows:
?Hi » Hi «ar - H-t nin X 100* 6.2. 2. b
Hi ave
?Ci * Cj max - Cj min .x '100? 6.2. 2. c
GI ave
where C denotes results from the candidate method, R denotes
results from the reference method, and i indicates the sample
number.
A12837 - 17 -
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the standard deviation fSD) of the rgfgrenee
candidate nreciaign analyses 3.3 follows:
where P_
SDp =
SDC =
ave la.
1.77 X P* avo
1 .77 X PC *ve
the average of
$«3i2,
-------
The candidate method passes this test if the absolute values
of all of the applicable differences (D) are less than or
equal to [24] 22. percent.
6.2.5 Test For Equivalence
The candidate method must pass both the precision test and
the consistent relationship test to qualify for designation bv
DEQ as an equivalent method. DEO aav rggulr* dual units and
precision criteria bejtveen dual units. Qr other conditions in
designation aa an equivalent method.
6.2.6 Verification Testing
DEQ may conduct verification testing of the candidate method.
If DEQ testing does not verify the precision and consistent
relationship of the candidate method then the candidate method
will not be approved as an equivalent method.
TSACE3 GAS DILCTTTON MST50D
6.3*7 This method is used for on-line measurement of stack gas flows
during the test period. Other techniques that can provide
equivalent results may be accepted, provided prior approval
by. DEQ has been made before testing for certification purposes
commences.
a) Tracer Gas Dilution Method
A pure tracer gas (sulfur dioxide or equivalent, or
approved performance gas} is metered through a calibrated
rotoaeter for injection into the flue pipe. Injection
shall be made through a stainless steel multi-perforated
tub* loop located inside the stack at four flue diameters
dovnatream from the particulate and gas sampling port. A
downstream diluted sample extraction probe shall be
located 8 flue diameters downstream from the injection
loop. The dilution sample gas stream shall be processed
through.a sample conditioner consisting of a combustion
tube'furnace, and in series, a glass fiber filter and
three iapingers encased in an ice bath. Impingers one and
two shall be empty for vater collection and the third
shall contain silica gel.
The tracer gas content of the diluted gas sample stream
shall be determined with an appropriate calibrated
analyzer. Downstream tracer gas concentrations should not
exceed 0.52 of the total flue gas volume. The tracer gas
shall be as non-reactive with other flue gas constituents
AA2837 - 19 -
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aa possible and measurable by instrumentation capable of
obtaining an accuracy of ± 1? of the instrument scale
reading. Instrument calibrations shall be performed and
recorded before and after each test run.
Stack gas volumetric flow rates shall be calculated using
the following equations:
Flow (cfa) a Ir x 1 x _ Tr 6. 3.1. a
DC 60 Pr x 17.65*
Where: Ir = Tracer gas injection rate (ft3/hour)
Do a Downstream tracer gas concentration
(ppm x 10-^)
Tr « Injection gas temperature (°H) at the
rotometer
Pr a Injection gas pressure (inches Eg)
• * Density specific for S02
Other tracer gases such as helium may be substituted for
sulfur dioxide provided prior written agreement has been made
with the DEQ.
6.U STQTCHTQMETKTC CARBON. HTDRQG?N AND QTYGEN BALANCE M5T3QD
•
6.4.1 • 1 carbon, hydrogen and oxygen mass balance will be used
for determining overall flue gas volume— not for on-line
measurements during the test period.
a) The carbon, hydrogen and oxygen balance method for
volumetric flow rates is based on the following basic
combustion equation and will be determined and reported
for every five minute interval.
«CCxHyOz * pH20] + Tsg(1-k)(a) [02 + 3.785H2 * =^2°] 6.
TsgC(1-k)(dC02 * eCO * g02 * hH2) * JH26
Where g a Dry weight of fuel burned (Ibs)
x a Holes of carbon per Ib of dry fuel (assumed
0.0425)
y a Moles of hydrogen per Ib of dry fuel (assumed
0.073)
z a Moles of oxygen per Ib of dry fuel (assumed
0.0256)
p a Moles of H20 per Ib of dry fuel
a Dry basis moisture (free and combined) - 1800
a a Mole fraction of oxygen in air supply
a Moles 02 supplied per mole of stack gas
d a Mole fraction of C02 in stack gas
1A2837 - 20 -
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e a Mole fraction of CO in stack gas
g a Hole fraction of Oj in stack gas
h a Mole fraction of % in stack gas
j s Mole fraction of HgO in stack gas
k * Mole fraction of unburned hydrocarbon in
stack gas (as CHjj).
a * Mole fraction of ^0 in supply air (mole
per aole of supply oxygen)
Tsg * Total moles of stack gas (dry)
b) Mass balance equations for the combustion of g Ibs of
wood are as follows:
Carbon: x« a Tsg C(1-k)(d+e)+k] 6.4.1.b
Hydrogen: S(2p + y) + Tsg(1-k)(a)(2m) a Tsg(2j + 4k) 6.4.1.C
Oxygen: «(p*z) + Tsg(1-k)(a)[2+m] a Tsg[(1-k) 6.4.1.d
(2d + e + 2g) * J]
Nitrogen: 3.785 (a) » h . 6.4.1.e
Stack gas total as measured by combustion gas analyzers;
1 * (d * e + s * n) 6.4.1.f
The stack gas composition equation can b« solTed for "h"
which will then provide a solution for "a" in the
nitrogen balance equation. The remaining unknown values
for *g", *p", and "k" are determined by siaultaneously
solving the carbon, hydrogen, and oxygen balance
equations.
c) Two calculation runs of the simultaneous equation set
are performed for each set (5 minute teat segment) of
data collected. The first run is performed to determine
an average weighted *€* for the test burn. This first run
•£• is then used to determine a corrected Tsg for the
second run as follows:
Tsg'(corrected) a Tsg (tracer gas) t factual^ 6.4.1.g
8 (calculated first run)
Where: I(actual) * Dry weight burn rate for test
burn (Ib/hour)
d) "Tag" ia converted to a flow rate by the following
equation:
Flow (cubic feet per minute) a Tag * 186.2 6.4.1.h
60
JU2837 - 21 -
f\
-------
Thia calculation procedure is necessary for each five
minute teat period segment, therefore a computer program
ia recommended.
E3TTCT5NCY TESTING AND CALCTTLATIONS
6.5.1 If a calorimeter room is used to measure appliance efficiency,
combustion gaa analyzers must be included to determine and
report appliance combustion and heat transfer efficiencies for
each heat output level required.
6.5.2 Efficiency values shall be determined based on the following
stack loss method. The approach shall include determination
for each heat output level for combustion, heat transfer, and
overall efficiency.
a) Combustion Efficiency
Combustion effiencies are calculated as the percentage
represented by the actual heat produced in the firebox
relative to the total heat production potential for the
fuel consumed. Actual heat production in the firebox ia
calculated as the difference between the heat of
combustion of the incompletely combusted stack gaa
constituents (carbon monoxide and unburned hydrocarbon
equivalents) and the gross caloric content of the fuel
burned. The basic equation used for combustion efficiency
is aa follows:
Combustion Efficiency » Thi - Cia (x 100) 6.5.2.a
Thi
Where: Thi * Total heat content of the fuel consumed
do » Combustible losses out stack
b) The total heat content of the fuel consumed shall be
calculated using the following equation:
Thi « .Gcvf x Wfo 6.5.2.b
Vhere : Gcvf a Gross caloric value of the fuel
(use BE7 determined from bomb
calorimetry analysis)
Vfc * Weight of fuel consumed (Ibs) dry weight
U2837 - 22 -
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c) The heat content of the combustible losses are calculated
using the following equation:
Clo * Tsg [(ex Hco) «• (le x Huh)]
6.5.2.C
Where: Hco a Heat of combustion for carbon
monoxide
a 128,000 Btu/mole
Huh « Heat of combustion for unburned hydro-
carbons
s 131,000 Btu/mole (estimated!
This calculation procedure is necessary for each five
minute test period segment.
d) Heat Transfer Efficiency
Heat transfer efficiencies are calculated as the percentage
represented by the useful heat released to the room
relative to the actual heat produced in the firebox. The
useful heat released to the room (Ohr) is calculated as the
difference between the actual heat produced in the firebox
(Ahf or Thi-Qo}, and the sensible and latent heat losses
out the stack (Silo). The basic equation for heat transfer
efficiency is as follows:
Heat Transfer
Efficiency * Ohr s Ahf-Sllo s (Thl-Clo)-Sllo (z 100)
Ahf Ahf (Thl-do)
Where: Silo * Sensible and latent heat losses
« (To - II) [Tsg(dCpC02 * eCpCO *
JCpH20)] * (J-m)LH20
Where: To * Temperature of stack gases out
Tl * Temperature of inlet air and fuel
6.5.2.d
CpC02
CpCO
Cp02
CpH2
CpH20
LfljJO
Specific heat of C02 « 9.3 Btu/mole
Specific heat of CO » 7.0 Btu/mole
Specific heat of 02 » 7.1 Btu/mole
Specific heat of N2 « 7.0 Btu/mole
Specific heat of water « 8.3 Btu/mole
Latent heat of evaporation of water
18,810 Btu/mole
This calculation procedure is necessary for each five
minute test period segment.
AA2837
- 23 -
-------
e) Overall Efficiency
Overall average efficiency is calculated as the percentage
represented by tiie heat released to the room relative to
the total heat production potential of the fuel consumed.
The overall efficiency is calculated as the product of the
combustion efficiency and the heat transfer efficiency as
follows:
Overall Efficiency = Combustion Efficiency x Heat Transfer Efficiency
a IhX r air s Jibe 6.5.2.9
Thi Ahf Thi
6.5.3 A corrected flue gas moisture content for each five minute
interval must be determined as follows:
Final flue moisture determination shall be made by calculating
a corrected flue gas moisture content for each data interval
taken during the test cycle. The average vet bulb—dry bulb
moisture measurement must be weighted by the volumetric flow
rate for that 5 minute interval. The correction factor which
is applied to each 5 minute moisture determination is
calculated as the ratio between the average wet bulb-dry bulb
measurement and the Oregon Source Sampling Method 4
(Attachment 1) measurement (condensate catch) for the entire
burn cycle. •. •
6.6 gQTTTYALSNCE BETWEEN CAWDTDATS METHODS AMD THE REFERENCE METHOD FOR
tfOODSTQVE EFFICIENCY TESTING
fi.fi. 1 Candidate methods for vnodatove efficiency tasting mist
demonstrate eonaiatent relationship ta the p*fgr«ngg raathod
(stack Iqag) comparable to the ennalatant relationship between
the reference method f ataeic l^aa^ and fcfte, e.alnr'tnetap ream
method AS described in the DEQ'a Conftrgatloa Testing ftinmti^rv!
Section 18. Part C. Table 1; Comparison of Calorimeter Room
Method va. Staeie Leas Method.
fi.fi.? DEO mav conduct verification testing of the candidate aethod.
If PEO testing daea not verify egulval^nr>«> of the candidate
method to the reference net hod ( ataeit loaa^ . then the
candidate method will not b« approved as ' an equ't vat«»nt gethod.
AA2837 - 24 -
-------
SECTION 7: TEST DATA
7.1 DATA TO BE REPORTED
7.1.1 All raw and reduced test data must be included in the material
aent to OEQ for appliance certification. Reduced test data
snail be tabulated as indicated in Sections 7.1.2 through
7.1.10.
7.1.2 Particulate Emissions For Each Test Cycle
a) Concentration: total grains/dacf, total graos/a3
b) Emission rate: grams/hr
c) Emission factor: grams/kg (dry fuel weight basis)
d) Emission process rate: grams/10^ joule useful heat output
e). Front half catch: % of total
f) Total mass captured: front and back catch, mg
7.1.3 Average Efficiency Values For Each Test Cycle
a) Overall appliance efficiency *
b) Combustion efficiency %
c) Heat transfer efficiency J
7.1.4 Beat Output For Each Test Cycle
a) Btu/hr average over entire teat
7.1.5 Burn Bate For Each Test Cycle
The average values (kg/hr wet and dry basis) over the entire
test cycle and an hourly average over the entire test cycle at
each heat output level.
7.1.6 Average Fuel Moisture Content For Each Test Cycle
a) Kindling (wet basis) f
b) Teat fuel (wet basis) %
7.1.7 Air/Fuel Ratio
Mass of combustion air to the mass of fuel over 90$ or more of
each test cycle (Iba air/lbs fuel).
AA2837 - 25 -
-------
7.1.8 Average Stack Gas Composition For Each Test Cycle
a) Carbon dioxide 5
b) Carbon monoxide %
c) Oxygen %
d) Excess air %
-e) Moisture J
7.1.9 Average Stack Gas Flow and Draft Fqr Each Teat Cvela
a) Average flow rate cfo
b) Stack flow rate dscf/min (tracer gas and CHO balance)
c) Draft, inches
7.1.10 Average Stack Gas Emission Factors and Process Hates For Each
Test Cycle
a) Carbon monoxide: grams/kg, and grams/ 10$ joule (measured)
b) Hydrocarbons: grams/kg, and grams/10^ joule (calculated)
7.1.11 Average Temperatures For Each Test Cycle
a) Stack gas OF
b) Primary combustion chamber gas °F
c) Secondary combustion chamber gas (if applicable) °F
d) Above catalyst gas (if applicable) °F
e) Stove top surface °F
f) Stove sidevall surfaces °F
g) Stove back surface °F
h) Stove bottom surface °F
7.1.12 Fuel Load Weight and Burn Cycle Period [(Minutes)] POP ffaeh
Teat
a) Coal bed weight, Ibs
b) Test fuel load weight, Ibs
c) total burn cycle time period, minutes
SECTION 8: CATALYTIC COMPONENT CERTIFICATION REQUIREMENTS
8.1 CATALYTIC COMBOSTOK DESIGN
8.1.1 To insure equivalent performance of catalytic combustora used
in testing versus production model stoves, a combustor model
number for every catalytically equipped stove evaluated for
AA2837 - 26 -
-------
certification shall be supplied. The model number will serve
to identify catalytic combustor types by brand (manufacturer),
dimensions, and design (substrate and coating material). The
model number must be imprinted or inscribed on a readily
visible surface (such as a metal sleeve or canned surface).
This will allow DEQ field verification monitoring. Any
change in combustor brand, size and design type will require
reteating of the appliance with the new combustor model for
performance change unless test data or sufficient information
can be provided demonstrating equivalent or improved
performance.
8. 2 CATALYTIC COMBUSTOB AGING
3.2.1 [Any appliance that contains a catalytic combustor must have
the combustor pre-aged before emission performance testing to
a specified aging process. The aging process will consist of
the catalytic combustor tested in a woodstove (specifically
designed for an internal catalytic combustor) for a continu-
ous period of 50 hours. The test fuel shall consist of
Douglas fir dimensional lumber or cordwood with a aoisture
content range between 16-20$ wet basis. The accredited
testing laboratories must provide combustor temperature data
and certify to the DEQ that each catalytic appliance tested
for emissions and efficiency performance has met this
provision. ] Anv appliance that contains a eatalvtie aombuator
must nag a pre— a%gd eombuatar when testing for certification
purposes. The enmbuator aging process, v?^ ff>"aiat of burning
P^u^laa fir d^ffltinaional lumber or cordvood with a moiatur*
content range on the vet basis of 15-253 in a woodatove
apgeifleallv designed for an internal eatalvtie oombustor.
The stove must be operated at its mediun burn r*ate with a new
eatalvtie eombustor in olaee and in operation for a period of
5Q hours. The accredited testing laboratory must document and
provide eonbuator temperature data, hours of aging operation
and certify to the PEG that eaeh eatalvtie anolianee tested
for eertif ieation purposes has met thia provision.
8.3 CATALYTIC CQMBUSTOR LQNGCTTTT CSTTTBIA
8.3.1 All catalytic combustor manufacturers must submit to the DEQ
evidence in the form of test data that each combustor design
type, identified by model number, has been longevity tested
for 5000 hours and document that the percent reduction in
particulate emissions from the new state is no less than 70i.
Three teat conditions are required: 1) unused (0 hours), 2)
250 hours, and 3) 5000 hours. Testing must be performed by a
DEQ accredited laboratory. In lieu of thia requirement, the
manufacturer may substitute a 24 month non pro-rated combustor
replacement warranty.
A12837 - 27 -
-------
8.U CATALYTIC CQH3nSTOR TCMPg5ATOS5 MONITORING PROVISION
8.4.1 In order to qualify for DEQ certification, catalytically
equipped woodstoves oust be equipped with a permanent
provision to accommodate a commercially available temperature
sensor which can monitor combustor gas stream temperatures
within or immediately downstream (within 1.0 inch or 2.5 cm)
of the combustor surface.
AA2837 - 28 -
-------
345
-------
Test Fuel Size
'.1*40 1 « f' r na
±i.5
>«•$ 5,3
>3
inUi'n 7 »/'. • 102
[
2x4 approximately h ve.
tast fuel load
4x4 approximately h '•
test fuel load
r.t a:
at of
f ^-U v»J
••- I I
1/4*
Figure 4.2-A
-------
1X1 LXl
•r*^—~-1..-.
LXJ i
2X4
2x4 ENDVISW
>•• — I
AIS* SPACE
\
i ,, H.. .
4X4
FLANGZ
4x4 SOTVTZW
1X1
r - r '
2. 2 4 ft "4 2 4
V
A
--.
Woodstove Stacking & Loading Examples
Figure 4.2- B
-------
c
CQ
o -
^ 3
O 5
X
n
ca
z
-------
Attachment 1
of Appendix
S7AXS CT
D2PAK2G2IT C?
Source Sampling Method 4
Determination of Moisture Ccntaat of Stack Gases
1. Principle and Applicability
1.1 Principle. A gas sample is extracts^ frcn the flowing gas atraas
and ita aoistura r-aovec and aeasurad either Toisetrisall-/ or
graviaetrically. Aitarnatsiy, tie aoisturs can =e *sti=atad rv
.•• less acrurata techniques for the purpose of settinc the r.csccrapr.
fse isokinaeic sacpling. A wet buih—dry 'suib technique is
discussed.
1.2 Ayplicabilicy. The reference aethed is applicasle for the
determination of acisture in exhaust gases frctt stationary
sources. The alternate aethed is ta be used only for estimating
the moisture content for the purpose of setting the ncsagraph
unless otherwise snecified.
2. Reference sethod
2.1 The nethcd esployed is essentially the sane as osed in the
particulate determination- source saspling aethed ! and will not
be discussed here.
3. Alternate aethcd
3.1 Theory. The water rapoc in a non-saturated eas streas causes
a depression of the wet bulb teaperature which is proportional
ta the fraction of aoisture present.
3.2 Procedure
3.2.1 Measure the dry bulb temperature in the conventional way
using either a theracaeter or theraccouple.
3.2.2 Insert the end of the tesperature measuring device in a
cloth sock and saturate the sock with water. Inset the
sock into the flowing gas streaa and allow the tesperature
ta reach a steady state. Caution: after the watar en
the seek has evaporated, the tssoerature will rise to the
dry bulb temperature. (?igure 4-1}. The wet bulb
temperature sust be taken while the seek is saturated vi:h
aoisture.
3.2.3 Apply the wet bulb and dry bulb readings to the apprspriata
graph (?igure 4-2, 4-3, or 4-4) and determine the
approximate water vapor content if the barcoetric -csssura
is near 29.92 in. 2g.
-------
4.
3.2.4 Altarsasaiy aealy tha w«e sulh and dry suii raadir.gs to
aquation 4-1 is ?igurs 4-3.
Zatariarancas
4.1 tta> following conditions aay draati
csadisg cauai.-.g arrsr.eoos reaulra:
4.1.L •£:• jrsa«nca ci acid
S03, SCI.
y
=he v«c bulh
iraan, i.a. 50.,
4.1.2 7i» pr«sanca cf hydrceortcr.a in the gaa s-craam.
4.1.3 Marktd di'ferer.caa Jrca at=os=aeric jrassurs (29.3 i.-.. £5)
of the ?aa atrsaa (Lf tie graphs are ua«d) .
4.2 Should any o< tha above interfaraness b« peasant, the testae
should consider another approach Co daterair.ir.g :oisturt content.
4.3 AdditiORally, th« following eonditiaas can laad to di'f icultias.
4.3.1 V«r7 high dry bulb taascsatur* (Li excess of 500°?} .
4.3.2 7«ry high oc r«ry lew gas 7«leci:ies.
4.3.3 High concentration of oarticulata aattar vaich say adhere
to tie w«t sock.
tarn?.
v/b
drr
Tla*
-------
s
5
• I
•i-Ll
IgiilHiisnlliiiiJ:^
S£jggj^n^i^l:5i5=^
4-2
no
4-1
-------
100
30
-444-
100
:oo
MO WO 500
an ma istaouasxx T
figure 4-4
-------
2800 - 1.3 C
LOO
(4-1)
•• • 7aipcr
o£ 20 3 i , is. 2
(S«« Figura -4-51
T«isp.
? • Absoluts barsaetri'e prsssurs, Li.
t. « Dry bulb taaseraeura, ?
t - W«t bulb temperarurs, ?
7APOR PRESS^RSS OF WAT2S A" SATVRATTON-
(laei»a cf Mtrcur-y)
0 1 Z 3 4 3 8 7
•—20
—to
— —
9
10
20
30
40
50
80
' 70
80
9O
100
110
120
130
14O
130
180
no
180
I9a
300
310
320
230
240'
.0128
.0222
.0378
.0378
.0831
.1025
.1847
.3471
.3828
.5218
.7392
1.035
1.422
1.932
3.398
3.448
4.323
3.381
7.589
9.332
12.20
13.29
19.01
23.47
38.73
33.00
42.31
30.34
.0119
.02*9
.'0339
.0398
.0830
. 1080
.1718
.3378
.3784
.3407
.7848
i.088
1,487
1.992
3.872
3.543
4.847
8.034
7.739
9.883
12.48
13.83-
19.42
23.98
29.33
23.88
43. 11
31.78
.0112
. 0 199
.0329
.0417
.0898
. 1127
. 1303
.2377
.3908
.5801
.7912
1.102
1.513
2. «2
2.749
3.842
4.772
8. 190
7.932
10. 12
12.77
15.'98
19.34
34.48
20.92
38. 37
43.92
52.70
•Merhodj ror 3c:errs:ss::an if Vtleeitv.
W?-jo, Western ?r
.0108
.0137
.0324
.0483
.0723
.1158
.1878
,2712
.4032
.5302
.8183
1. 138
1.381
2. 114
2. 829
3.744
, 4.900
8.330
8.130
10.38
13.07
18.34
20.27
24.97
20.52
37.07
44.74
33.83
.uimi
.0178
.0308
.0441
.0788
. 1248
. 1935
.2891
.4203
.3009
.1482
1. 173
1.310
2.178
2.911
3.848
5.031
8.513
8.331
10.81
13.37
18.70
23,70
23.48
31.13
27.78
43,37
54.52
. 000 5
.0183
.0239
.0489
.0810
. 1 103
.2033
.3004
.4339
.8222
.3730
1.213
1.830
2.243
2.993
3.934
5.183
8.880
8.537
io.au
13.57
17.07
31. 14
29.00
31.73
33.50
48.41
35.80
s.-.e M
.. 0039
.0153
.3273
.0317
.3843
. 1373
. 2118
.3120
.4520
.8442
.9048
1.233
1.712
2.310
3.081
4.083
3.302
8.130
.8.787
11. 12
13.98
17.44
31.50
23.53
32.38
29.24
47.27
33.50
is: Cs
.0084
.0130
.0239
.0341
.3802
. 1429
.2203 ,
.3240
.4538
.5839
.9353
1. 293
1.783
2.379
3. 189
4. 174
3.442
7.024
*.98l
11.28
14.20
17.52
22.03
27.07
33.92
19. 39
43. 14
57.81
P.t«S! Of
.0080
.0142
. 3247
.037;
.0922
. 1302
, . 2292
.2264
.4333
.5903
.9888
(.333
1.319
2.449
2.259
4.239
3.533
7.292
9.290
11. »•
14.82
'.a. 2:
22.52
27.52
23.17
40. 73
49.02
53. S3
<** a s m «
.3073
.0124
.3223
.0153
.0982
. 1557
.2233
.3493
. J033
.7 144
.3989-
1.378
1.473
2.521
3. 231
4. 408
3.722
7. 384
9. 424
11.32
14.98
13. 51
22.39
23. 13
34.22
•(I. 32
43.93
S3. !T
•a .:••
-------
Attachment 2
STAT2 C? CHSGCM of Appendix 1
!2iE:rr c? savzaciaerrai
Source Sacsiing Method 3
Sampling Particulata Missions Frcs Stationary Sourc
es
L. Principle and Acplicabiii ry
1.1 Principle. Particuiat* aattar including csndensiiia gases are
withdrawn isofcineticaily from a flowing gas straaa. The
particaiata aattar is detarainad graviietricaliy if tar saaoval
at combined watar.
1.2 Applicability. TSij zeihed id acolicabis 53 the de?sr^i.~.atisr.
of particulaea missions iron stacicnary scuzcaa t.xcaoc thcs«
sourssa fsc which sn«ci'ied lamlir/; aethcds have :a«a devised
and are on file with the Ce*iar~*nt.
2. Acceptability. Hesulta of this sechcd vill ba accepted as
demonstration cf compliance (oc ncn— ecarplianea) pecvided that the
aathods included or referenced in this procedure are strictly adhered
to and a report containing at least the ainisa asnunt of indorsation
regarding the source is included as described in Sections 12 S IS.
Deviations 2rca the procedures described herein will be permitted only
if peraissicn frea the Department is obtained in writing in advance
of the tests.
3. Sasplin? Apparatus (?igure 3-1}
3.1 Probe - Kith beating systea capable of aaintaining sassle cas
temperature at 250° F at its exit end during saspling. Probes
which are ta be used at tasperatures of 500 ? or lass say have
liners constructed of seaoless 316 stainless steel, ?yrex Glass
or Incoloy 315^. Probes far tesseraturss Li excess of 500 f
a*y be constructed of Boroailicata glass (liait 900 ?) or Quart:
glass (liait 1650 ?1 . Probes for temperatures in excess of
1650° ! osust be approved by the Department before use. Testing
in corrosive acaospheres say recjuire a special probe liner to
prevent contamination, of the sasple.
3.2 Probe Sczzle - Constructed of stainless steel (315) with an
external taper 30 or less ta a sharp leading edge. The inside
diameter of the no«la shall be constant throughout the length
of the nozzle. The wall thickness of the aozzie shall be less •
than or equal to 0.063 in. and a straight run of at least tvo
tiaes the internal diaoeter shall be provided between the leading
edge and the first bend or point of disturbance. The r.ozsle shall
b« connected to the probe liner in such a way as to provide an
airtight seal with no exposed threads or gaps to collect
particulate natter. Calibration of the nozzle is covered in
Section 13.3.
1 Trade Mane
-------
?aga 2
3.3 ?itst tube - Type S or equivalent attached to tha prsbe. The
probe nozzle and faca openings of Che pi tot tube shall he adjaes.i
and parallel to each other (not aeeassarilv1 in the sase plane)
and the fraa saaca becwean the nozzle and the pi tat tube snail
ba> at least 0.2 in. Calibration of the pilot tube La coverad
in Section 3, Source Samslino Mechoc 2 .
3.4 Differential pressura gauges - Inclined or vertical fluid =ar.c-
aetar capable of seasurin
-------
Page 3
4. Sao?!* 2a«ver7
4.1 ?rssa brash and xasaie brash - ayian bristle cr «qnivalan-c at Least
as lane as the prcee Liaer and the nozzle respectively.
4.2 Wash bottisa - isert ta the solvent used is thea (usually acatane) .
4.3 Sasnle stsrage eantoiners - glass with glass or raflsa lined caa
or oc±i*r aa&trial which Is i*aJc £i;iit« rsaianst sa chesicaJ. ac-iacic
baa acatana aad allewa c=3l*sa reovsr? of par^icuLate =acnar.
4.4 ?««=! diJh«a - fcr filrar 9asal«4, ?laas or
indlridaal oap^r «nvicp«3 with vas«d rapar liters say i«
tar* aad final w«igh'^ should soe b« iselsded ir th* weighs of t
or lia»r.
4.5 Craduated cyliaar and/or balanea - ts sa&siirs ccr.der.sed soiatura ta
wishia 1 al or 1 g. Graduatt eylisd«ra shall have acbdiTiaisna of
2 al or lass and ialancsa shall b« senaiciv* ta 1 ?.
4.6 71aa«ie a^ara^* can-ga.ir.ara - air tight cantaintra ta scars silica
9«1 onlads ic Is weighed at th« sasplln^ si:* or transport* d ta the
lafccratar/ ia the iasiA
4.7 Raaber policsaan - ta aid ia r*c9*erir.
-------
?ag« 4
5.7 Staecack crsasa - aeatane rasistant, heat stasis, siiicar.e rrsase.
5.3 Oiathyl eaher - rsac.ant grade wish a --a-r- -»r"t tatai rssidue cantant
of 0.001). (0.01
5.9 Cilorafara - raacent grade with a ^a"'-^— ' residua cantant of 3.3
(0.01 ao/sl)
6. Sampling Train ?rsparatian
6.1 Weigh ntsasersd glass fiber filtsr pacer ta the searaat C.I =
-------
Pag* 3
cannectians, and tura en the arse* and filtar heating syatas. Adj-ist
tha heater cantrala ta aaintaia the appropriate tasaeraturaa .
3. teak Check
8.1 Plug the inlet ta the filter.
8.2 With the fine flew adjus-eant Csypaaa) casn lately open, open the
coarse flaw adjustsent canalataly and adjust: ta a vmcsisa of 12 Is.
'Hg by closing the line flow ad jus-sent. .
8.3 Ax/tar- sufficient ti=e has elassed far stabilisation , aaasura the
leaJcage rasa far 1 ainurs or aora and rscard. A leakage raza of
less than 0.02 e±3 ae L5 ia. 5g is aesapcable. Ca« acatane r
. stspcacfc ?reaae on i=?in?era and ball jcir.ta i^ .-.ecaasar*/ ts seal
leaks.
3.4 Slowly reaov« the plug £rsa the filter inlac and isBediatel/ close the
coarse flow adjuaermnt.
9. ? articulate Train Operation
9.1 Each point should be saspled a a-fnrmtn a£ 2 ainotas and a casalata
set of data raadinea anoiild be taken at tvery point. li each point
is sasspled aore than 5 ainutad, a eeaplete set of data raadinc.3 should
be ftalfitn at equal tnterrals daring the saaaling of e^ery paint bttt sot
leas f7*qaent than every fire sinataa.
9.2 Pack crushed ice aratzod the ispingers. turn on the prase heater and
adjust so that the gases lairing the prate an 220°T. Add ice occa-
sionally daring tha test in order ta :
-------
?age 6
9.7 Aftar the pits* rsadiscs aave staaiisad. nosa tie pitas rsadi::?,
calculate the desirsd orifice setting, and adjust wit:: the fir.e
and eaarae new adjustaenss ta the sew setting. Tiis should be
dene as rapidly as possible ta a-void anisoJcinecia sasniing.
9.3 Continue the abo^m steps until all tra-verae points have been sane lad
an «qTial la-e&s-ral of t±aa (cxces-s adjua'ssd era,v«rs« pai^ta as deacr^
in Scnrca SaatnLinq x«gi;cd 1.)
9.9 AC the esnela&ion of the rxa, close the caarse ilov adjnaraenc, ^o-es
the final ?aj ae^sr raadizg acd ssrscrarursa and withdraw the =r=i«
eeoalecal? .
9.10 Seal the nozzle with alrriirma fail u soon aa is eaoLa
ta do so, discancecr the prsae fraa the sacale ease^ seal all o-oher
epenisgs and traAS-sort ta the cleanup (or stara?e} area.
9.11 Tlirou^hour the saasl* r=n« collect an inte^ratxd caa sasale far c==-
oeite analysis aa deacrihed ia Sourra Saaollnq M-ethed 3.
9.12 Onder no drconataneaa disconnect or loosen any part of the airticht
train oatil the probe has been easnletaly r*aev«d frca the scaoc.
10. ?articalate train Cleanup
10.1 deanap should be performed ia aa area free of wind and airrene
dwit vnich say cenr.aninate the sample or cause sasale laaa. 1* possible,
the train should be cleaned in a laboracar?.
10.2 After Che prabe and oozale have cooled, rtacve the end seals and brssh
while rinsing with acecone infia a suitable container (labelled).
iTo-ee: Exercise caution so that none of the rinse is
last and no extraneous aaserial enters the rinse
(such as frea the pisat tubes).
10.3 Should it be necessary ta clean the train in she field, use she
following procedure:
10.3.1 Kins* all sample exposed surfaces prior ta the filter
(including the front half of the filter holder) with
acetone. Reao-re any adhering particles with the aid
of a rubber policesan. ?la'cc the rinsings in tne probe
rinse bottle.
10.3.2 Seaove the filter without disturbing the particulasa ca*e,
place in a petri dish and seal.
10.3.3 Measure and record the Teluae (or weight) increase ef tr.e
. first three ispingers and transfer their consents into a
labelled cansainer. Jtinse the iacingers and intereannects
wish distilled water and add ta the container.
-------
?age 7
10.3.4 Rinse all sample exposed glassware between tie filter
(excluding tie glass frit filtsr support) and tie icurti
ianinger with acetone and stars Li a suitable =ar:
-------
Page 3
12.1.3 2ets'"3i'"s the cor"ec~*cr
correction factor xcsocraeh, Figure :-2.a. as described
on the nomograph. Correction of the factor "C" for a
pitot C? other than 0.35 can be aade using the following
ecuation:
C (corrected)
12.2 Operating Scacgraph
12.2.1 Adjust the sliding seal* on the operating ncscgrapc,
Figure S-2b, such that the "C" factar detersined i-.
Section 12.1.3 is egaoaite Refsrsr.es ?oi^t A.
12.2.2 asi.-:^ th* 3ceiiai:iary jitst traverse data and duct
tcocerature deterair.ed in S«ctisn 7, draw a lir.e frca
T to th« values o£ d? and select a suitable 0 (r.cszle
diameter) srca the probe ti? diameter scaJe.
12.2.3 Draw a line frca ? through 0 (actual dia&eter at r.ezils
to be used) and note where the line cresses the £? scale.
12.2.4 Draw a line iron the 1? obtained in 12.2.3 ts R*iersr.ce
Point 3 on the iH scale and note where the line crosses
the X factor scale. Tais point should be =ar:
-------
?ag« 9
13.1..S Caiibrata th« qriiisa and dry g« aa-c«r «verv sen -si sr aft
5 caa-ea vtiicaav«r ocssra liraz-
13.3 7aa5«racsra gaugaa
12.2.1 CiacJe tsszsranra gaugas agaisat sarcary-ia glaaa tS
of cartdj£i«d aessraey cr again Tg Toiiabl* txsneracurs acar.
(bailing or frs^siz^ pciats) ae l«aa-s yvari/.
.3 ?rab« tessi*
13.3.1, yiautxra ti:« Lnaii» noz^l* diaaacar on ar Isaar 10
4Laa«e«fir- es S±« ae^rva-e 0.001 ise£ oairg a 3icr=aac*r or
cali?«r. t^« cassl* dias«esr is ^a a-7«ra?« of =i
53 &• aaaraat 0.001
13.3.2 Tia lar^ca? da-riarian from the aTera^ra should r.oc
of eha avaraga diamatar.
13.3.3 Calihrata 5ha no«=la at
14-. Calcalaaiona
14.1
14.1.1 Calculata tha avaraga gaa Talcedty, V , frca tha pitat tssa
raadiaga and gaa tasparaesrva uaiag a^oaeioa 5-2
tvJ*'*9 "ifL V<0«7a)'**' '(5-2)
Ar? M ' '
. 1 s a
Hfcara tlia aysJsola and cnisa ara tia Jaaa fsr *truacisn 2-2
ia Sourga Saaellr.c Xachod 2.
14.2 £aa ^oloaatsie flow raca
14.2.1 Calcalaca toa 7 ^ - CS-4J
-------
Page 10
wear* Q. • roluse of gas sasple, SZC?
a
0 » *eics» of cas tirougn setar (setar conditions) , ~
? • barometric prsssurs, acsciuta, in. 2c.
42 • average pressure drso across tie orifica / in . H.O
7 • a"werace dry gas aatar tasnerarsra , °A
14.3.2 la tha «wns th« gas piaai^g thrau^ft si:« dr/ ?as sa-esr
ne-e dr/, ei« «fcov« «quatiian susr r« salripLied by (1-3. )
whera 3 La ti:« TQlaa* *rz
-------
?a irac-iioa of d=y gas
12. Miniaoa Acs»ptabl« T«a«
12.1 Za oriar far a soars* tas-C by Cilia aathod to b« *cc*ptaal« *a
accurata «. th« folloving. r«quiraa«aca auat s« a«c onieaa
by t!i« C«p«jrtacat ia
12.1.1 A aiaisua aaspl* Tcleaa of 60 S3C? of 5*s ;«r r^a scat
12.1.2 A ainiTua rsa ti=» of 60 aiatxftu on csntiauecs operations or
on* eooplata eycl« cawriae; at Itaat 60 air.utaa on cyclic cc«r-
aticna. A irtniiitTa of t>c rsas ;«r tsat is rvcuirad.
13.1.3 Th* C«paz-=a«nt La notified ia adv«acai of all scurc* taata so
that it say bar* aa obscrvvr pc«s«at if d*slr«d.
12.1.4 All «quipB*nt ua«d ia th« tast shall b« as specified ia Section
3,4, and 2.
12.1.2 All tqnipaent vs«d ia th« tast shall b« calihratad at ^.« sr«ei
-------
Page 11
interval or sara often and the calibration data and results
iaciuded is the test resort.
15.1.6 Accurate description of the sampling sits iad-i4'-? phocserassa .
13.1.7 Sufficient data ta eanfim that the sanpllnc. rate was within
10* of Lsokinetic.
15. Minima Teat aepcrt Infar-Mfvon - tia fallowij:^ is£s:=aeicn csneer=in? the
aourea aha 11 be iscioded ia the sourss te*t z*ccrt.
16.1 Sellers
16.1.1 H«ae of Trannfacsarar, oaceplata casaeity, and isftxU.3.cicR
dace of boiler and associated central »coirseAt.
16.1.2 Central ecjoipaent on boiler (including ci.-.dar rsinjesrticn
16.1.3 Steam croduetian rate, rt*«a pressure and nr.c« of rteaa fl=v
wiser* passible. Cse of a rteam flow iate^rater is desirable.
16.1.4 fuel esaecsitian Ciaciudir.
-------
L3
IS.3 Zneinaratsra
16.3.1 Manttfaerorar and eayacisy of Lscisarscar.
16.3.2 Can-era 1 *qci;m«nr praa«se.
16.3.3 TTP« and qaancir? of sacerial incin«racad.
16.3.4 Ciar?ia? and TCakln? tinea.
16.3.3 Auzillar? fzcl os«d and qsanzir/ csnarnned durin? taaz
16.3.6 Ceacir/ r«adi.-.?3 during taa? by 4 osrzifiad oJ=s*r7«r.
16.3.7 ?ho-cs^rapii3 of iaeinaracsr in oceracisn including ?1'^=:
-------
c/clone filter
theracaetar
«=ST>r««fc ralve
s-i
-------
*->
> 1.4
•v i
% [" *•
,,.J -
* »-3 i 10
'***> • ' 0»
•"•C C . 1.9
2-2(a)
* •
«.*
«.»
«.«••
—«.*
•VI
cur
"TOT >tAe>MC.
•.*•!_
::|
"3
Ln«—*
.1 «
•*•
5-2
«.»-
"?
-1
"3
T,.«
A i 4l«MVM««Nt««a
-------
figur* 5-3
-------
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-------
5-5
VELCdTT DA^A AJffl CAlCSLAIICIlS
3**** So.
Plant
Data
-*g lacatiaa
5-4*.*.
go.
.
4
AT*.
Sf-arV
ftrsssars
Ps ia.Es
nuasra
Star^r
ts
*T
•
I
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2s
•2
Vat
E«ad
A? ia.H-0
— '
W. - -' 5414 ? s T.S
h
I
1
!
Ps * abaolnt*
Aafriettt ttsp« *
Aabicnt
S2ACX
- Pa * Po
of Zg
Btilb
v«t
W3-5G3
-------
ffiiT cr rsvrscMiE
stan
c
.
so.
•
.
Av?»
^tat^ig J
Ae=»«ha
Stack 9:
Dry Buii
w«e 3uli
XschM
'•
t
I
i
1
^
ric ?r»33uri
sasu;*, ?a
Te=?.
?csp.
Stack
ts
*T
•
, yj,
•T
.?
Tesn.
ta
•— •
^
In-K.
ia-H,
L^.H<,
"ei.
A? ia. H^O
0
-ti? X 73)
S-* Nj^C^ ? x Ta
i
t
I
ignr* 3-3
-------
5-7
CCMSUST:ON GAS ANAirsrs SAIA SESST
Sonrca Data,
5oia±
co2 o2 co
Analysis 1
Analysis 2
Analysis 3
co o, co JT
2 ' 2 2
AtnrnicWt. Atonic Wl. AiozsicTO. AtocricTO.
(44) (22) . (23) (23)
» Total
BTET
02 CO
Azalysta 1
Areraje
CO. 0,, CO 2T.
22 2
Atomic Wt. Atonic Wt. Atonic Wt. Atonic TO.
(44) (32) (23) (28)
TMtccnc-ci
» Total Aiosic TTt.
-------
LATi SAiiPLC'G CALCULArTO>?5
Date of Test
-
?ASAiETi2S TO 3£ CA-.C7L-A.rZD HS2TJLT2
bol
Qm
V
==
S
?o
VT
Md
Ps
S
C9
As
Ts
Dm
• w
w
%C02
Definition, Units
meter conditicss , ft.
% H20
Gas meter temp. , *?
Orifice srsssure
droo in SoO
Calcilaring Zquation
Avar, fcroni field data sheet '
Moisture es casing last
icsinger
Arg. fir. field data sheet
ATJ. fir. field data sheet
Barometric pressure (la. Eg) | Field data sheet
Toe. rol. of condensed vater
Molecular weight of dry gas
Stack pressure In Eg abs
^jVx ii"
Pitot Tube Caeff.
Stack area (In. *}
Stack temp. , *3
Nozzle diameter (in.) .
To^al 53^—1^-^ M— • f*{-j
. '
Total fir. lab data sheet
Gas analysis-Atomic Wt.
. 073S3 x ?s' +• Po
Arg fir. Vel calc. sheet
From Calibration Data
Reid data sheet
AT?, fr. field data sheet
Field data sheet
Total fr. field data sheet
Wt. of particolate sample , mgj Total fr. lab data sheet
% CO2
. _ "- • ;
QJJ I Dry gas sample vol. at
! std. cond. , scf.
QT
•BST
md
Ms
Vs
qs
r
.g
eg'
Ct
Tot. rol. of condensed water
Tanor® std cond. (scf)
% moisture in stack gas
Mole fraction of dry gas
Molecular ^n. of stack gas
Stack velocity at stack, fpm
Stack flowrute at standard
cond. . sc£m
Percent Isokinetic
Total parriculate grain
load. . rr/scf
Grain load, at 12% C09
gr/srf
Total particuiate emissioa
CO 2 analyzer
r^- 17. S3 (Qctl{ Po* i.H I
"* (tar*- 16 Cn L 13. 5 J
QT-0.04T4W
__100 Or
niv ™ , .. '>i. j
ly V * (»>C
"**FW
Ms - mdD/Id * 13 (1-sna)
?1''
-------
fiS-ura 5-3 (?.
Plant
3C?ARTM6?IT 0? PlV ! ».Qfi-*::TAi. C
AIR QUALITY C3:tTSOL OlVtSlO.'!
?A*TlOJJJkTc »-«'.! MS C.M.CU
Samel inc, Lscation
Data of Test
Sym-
bel ! 3«fim'tion, Units
' nwter esnaitioni. ft.
. a—
en S« «aetr two., .-
M i 3ri r ic* srwjure
j droo in H^3
fa i Sarasetric jressure(in.Mg)
Calculating tsiucion Siui___ 3un__ '*a,^ Avq.
Avo.frrr, f7.ld ^ea 5flM«
Av^.frem field data in««t
. i j
Av^.froa field data sft**t |
field data ih*et
Vv Tot. vol. of condensed »at*r Total fr. lab data* sheet
Hd Molecular ««i)nt of dry gas .
ft | Stack jrtaiure jn H^ abs
S
c9
Aj
~\r? « ~j
PI tot Tub* Oa«ff.
Stack arta (in. }
1 ' " *
Om
At
V
Moult diam«t«r (in.)
Sas analyi Is-Atseiie ut.
.OT3S5 x PS » ?o
Avf. fr. Vol. calc. ine«c
Pro* calibration data
i
field data jhe-et
Av^. fr. field data sneet • j
Meld data sn«*t |
Total lafflolin^ ti*M. ain. ! Total fr. field data Jh««t
Wt.af sarticulat. »a«ol«,«9.
**i!*Ca7
W
Dry jas jama I « vol. at
std. son*., ie5
- I Tot. vol. or «3rto«n»ea «4C*r
1 vaoer '* jtd. esnd. (i«f)
«v
^
X "oiitur* in stack gas
noU fraction of dry jas
ns | nol««ul«r w«. of itack «as
'/I
«
Z
C4
^
C:
Stack velocity at stack, fya
Scacx flewrac* it }(jn«ara
P«rcant I»okin«Cic
Total sartievilatt jrain
Total fr. lad data ih««t
CO. analyzer
«., „ 1 7. i5 (•">") |"?e» i?t ] i
^ fw»H$^ ) t ? ^ )
? t
10^^ ™ 5 j'S i '
(v»; (?»i "rs'j i^.:) (it) '
Co, . Q'^^IJ i I
|
1
i
i
i
1
i/-»in 1043. «c 1Z« C3, ' C* • C T '
tb/hr
C5- .8«57 (C«)(«J . j 1
-------
figsrm 3-3
sauacs
ANALYSIS CF ?.^T:CTJLAT;
Tast __
Oats of Test
C2HOEHSHD WA7IR OETrKHDlATTQM
Run
NO.
1.110 inger:
pinal weiont
Initial weiant
Net waicnt
final weicnt
Initial weiant
Net weight
Final weicnt
Initia-i weicnt
Net weicnt
?1
*l
?3
?4
To« 1
Condensats
RESULTS
Hun
*
i
Con tan ts •.
seaicer rio./Voi .
Gross wt.
Tare wt.
Met wt.
aianK wt.
Final wt.
Seaxar No./Voi .
Gross wt.
Tare wt.
Met wt.
31 ante wt.
Final wt.
3eaxar Ho./Voi .
Gross wt.
Tare wt.
Net wt.
8 Ian* wt.
Final wt.
M l tars
?rooe i r t i car
Holder
•»
icoincer
Rinse
uioinger
Extract
•
. i
unomger
'/later
,
I
I
VI t.
Sample Preparation;
Volatilss evaporated at
Water evaporated at
Oesicatad at
Laboratory Balanca Type
C, Duration
C, Duration
C, Duration
_nrs
"nrs
"nrs
-------
Attachment 3
of Appendix I
ZS CT CSSSCX
CE2AS=1E3T QT -aVTSCNKEnai
Sonrca Sacaling Ma tied 7
a
ispling Candansihla Ssiasioas fraa Stationary Sources
yriscipla and Appli
Principle: ?artic=Iata aattar inclnd'.ng cond
y from a flcvi
rtraae. Tia =art-
icolata aarsar is datazrdjiad er
with, organic solvents and •vaporatian.
1.2 Appiicabilif/: T^Ls a«thcd ia apaLLcabla to statisaary soorcas
whoa* prj.,rary cmiaaicna are csndasaiiia gases. It shculd be
. eenaidarad a aodi^isatian of Soursa SasztLL-.? Hethed 5 acd ap?Liad
only wh«a dLractad to do so by tia S«part=ant.
SaapLLs? Apearatns (?i?8sa 7-1)
2.1 TS« prab«» jaapling traia, aad aeearla? r/atea ar« tha saac
as otsKiiaad in 3. Sar-)linc Aocaratta cf Source SassLL-c Xathed
j_ with, th* Jallcwicij excapriocs :
2.1.1 Tha ha a tad liltar and cyclone are optional, bat shodd
b« naad Lf sicaificant quaatitiaa of solid participate
ara praaant.
2.1.2 Aa cnhaatad glass fiber flltar is placed batv««a tbe
tbird and feorth iapiagera.
3. Sa=?la Racs-vary Apparatus
3.1 "^h^ saaDle recsvmry appara-eas is the sasa as outliaad in 4.
Saaale Saco^er'r Aeparafus of source Sana line Mathod 5.
4. Saagenta
4.1 The raagents ara tha sa&a as outlined in S. -taaces^ia of
Sotarea Saaelinc Mathod S.
S. Saapling1 Traia Preparation
5.1 Tha saapliig train preparation is tha la.-a as outlined in S_._
?-»'^
-------
S. Sraeaat ?recaratisaa aad l*ad decic
6.1 " nui pratsat praparaticna and laafe caaOe ara taa saca as eist-
iii~* ia Sactiana 7 aad 3 of frim **~- 'l—g 'Bathed 5.
7.
Candanaiijla Sarticslata train Cparaticna
Taa traia operation ia tha sa=a as cutliaed ia Saction 3 of
sa S-»?*?Liaq Ha^od 5 . IS ia issorsantt ss r.o-ca
as
3.
Csndaaaihla ?*rtie-olat« Tr
s^ar suar sot «jea«d 7Qa7
lea a of candnnni'sle =arari
daaacp ahotald ba parfarsted la aa araa fre« af vir-d and air-
bora* &urc whiea aay eoncasia^ra tha sasole or eauaa a*=?i«
loaa. If jeaaibla, tha traia should ba ciaaaad ia a laborarary.
3.2 Aftar tia praba aad aczsla hava eaalad, rasove tha and aeala
and brsah vhlla riaaia? -^i^ii acatana iato a a'oitabla sarked
es&taiaar.
Hoca: £xereiaa eautics so eaa« sooa of taa riaaa ia icac
^ty* oo cxtraneoua sat^rial thtara tha riaaa (aue^
as from taa pitot tuiaa or condanaad satarial £r=a
tha outsida of taa aocala) .
8.3 Sneuld it ba sacaaaary ta claan taa traia la taa fi*ld, caa
taa follcwiag pzocadura:
8.3.1 taozooe^ly riaaa all aaspla axpcaad s-crfacaa prior to
taa front fiitar support, wita acatana. Raaava aay
adhariag partiolaa vita taa aid of a rshbar pclieeaaa.
?laea tha riaaisgs La. tha prsba riaaa botrti*. If tha
front filtar ia oot oaad, all saopla «x?oaed surfacsa
prior to taa first isaiasar aheuld ba iaei-odad ia taia
riaaa. -
8.3.2 Raaow taa front (If uaadj and raar filtara, plaea
is a patri diah aad aaal. Siaea a haavy loadia? of
eendaoaihla aatarial on taa raar filtar say i«a?a a
raaidua in tha filsar eontaiaar vniea --ould sacaaaitat*
raoo-raJ. vita sol-rant, ?laaa patri diahaa ara prafarrsd.
8.3.3 Maaaura and raeord taa volsaa (or waictit) iaeraaaa of
taa firat taraa iapia^ara to taa aaaraat 1 ad (or 1 9}
aad traaafar taair centanta to a labalad csntaiaar.
Siaaa tha iaDia^ara aad iatareoaaaeta vith diatilled
watar and add ta taa coctaiaar.
-------
-3-
3.3.4 3inse all sarnie e??csed giassvars between the frtnt
filtar (if used) or tha first i==inger (if tie frtnt
fiitmr is not used) and tha faurth i=?inger (ireladii?
glass filter frits) with acetane and place in a suitable
mrfced container. If the aoisfora cendensata in Section
3.3.3 was datasained by use of a graduated container, it
should also b« rinsed with acstane and the rinse added ta
tha tsninger rinse eanrai p.ar.
3.3.5 Caeassisa tha w«i<^it: gain of the silica gal in tha f=crth
inpin«i7hed
in tha lahoratazy.
3.3.6 Collect ad sannlaa should be analysed within cne v««jc of
collection in ^rder ta prevent any feasibility of bioloeisal
or ehagjcal degradaticn.
9. Analysis
9.1 Desiccate tha filtar(s) at 70°? or lass in tha field container
for 24 boors and weigh . ~~"
Sota: Za scaa cases* desiccatica say give rise to a slew
vaporisation of the ccndansihla aatarial. Therafcrs it
La not raecB&endad that an attasst ta weigh ta constant
weight be aade.
9.2 Transfer tha acetone rinse (Section 3.3.1) into a tarad bearer
or evaporating dish. Sinse tha container with acetane (police
ta raaov* particulate) and add the rinse ta the beaker. Svacorata
the solvent at 70°7 or less and laboratory pressure, desiccate
24 hoars and weigh . Sea note in Section 9.1.
9.3 Transfer the acetone rinse frcm the ispingars (Section 3.3.4}ta
a tared beafcer or evaporating dish and treat as in Section 9.2.
^
9.4 Transfer the water (Section 8.3.3) ta a separatery fennel. Sinse
tha container with distilled water and add to the separator? funnel.
Add 22 al of chlorafara to the separator-/ fsnnel, stopper and
vigorously shaJce 1 ainote, let separate and transfer the chioro-
fara (lower layer) into a tarad beaker or evaporating dish. Repeat
twice aora. Repeat the above extraction using three 22 nl portions
of diethyl ether in place of the chlcrofaa. Transfer the tther
(upper layer) to the saae container as ixsed to contain the chloro-
fc
Mote: It is necessary to rinse the field container far water (if
used) with solvent. This rinse nay be nade as ing the
cting reagents in which case it is added to the i^p
extract container or with acetane in --tiich case it is added
ta the container in Section 9.3.
-------
9.5 Transfer tha r«-vi i -, * n? vatar Irss tha separator? fannal ta
tarad haakar ar avaceraftinc; dish and evaporate ax 135
0*siccata far 24 hours and
9.6 Svapcrata tha cooained iraizger w«-&ar cxrrac=s Jrca S«c=isn, 9.4
at: TO4? or IASS and iabcraur? rrvaaurs, dasdecaca far 24
and w«j.
-------
Ccp-eicniiJ
-------
DEQ WOODSTOVE CERTIFICATION PROGRAM
PACT SHEET
Background
The 1983 Oregon Legislature passed a law allowing only new woodstoves and stove-like
fireplace inserts that pass an emission standard to be sold in the state after July
1986. Existing installed stoves, used or antique woodstoves, and fireplaces are
exempt from the rules. In developing the rules, the DEQ worked closely with an
advisory committee representing woodstove manufacturers and retailers, testing
laboratories, chimney sweeps, fire code experts, engineers, air quality specialists
and environmentalists. Two nonvoting medical advisors also participated.
The Environmental Quality Commission (EQC)* established phased-in smoke emission
standards and adopted rules in June 1984 covering:
o Procedures for testing woodstoves for emissions and efficiency
o Stove labels indicating the stoves' emissions and efficiency levels
o Procedures for certifying stoves for sale in Oregon
o Pees for certifying stoves
o Procedures for accrediting testing labs.
A two-year voluntary phase with stove labeling began July 1, 1984, and continues
until June 30, 1986. The mandatory sales restrictions phase begins July 1, 1986.
All new woodstoves must be tested by an independent woodstove testing laboratory.
The rules outline procedures that a testing laboratory must follow to become DEQ-
accredited to perform testing for Oregon's Woodstove Certification Program.
Basically, laboratories can not be financially dependent upon any woodstove business,
and they must demonstrate stove testing proficiency. Under the rules, a manufacturer
pays to have each stove model tested at low, medium, high and maximum heat output
levels, using Douglas fir. The results are averaged to determine whether the stove
meets the emission standard.
The Department of Environmental Quality (DEQ) is currently accrediting testing
laboratories and manufacturers are voluntarily submitting their stoves for testing
and labeling. An ongoing list of approved stoves with performance information will
be made available to the public as new stoves are certified.
Emission Standard
The new emission standards limit the amount of smoke (measured in grams per hour)
a stove can emit. The standards will be phased in: The 1986 standard reduces
emissions by about 50 percent; the proposed 1988 standard would reduce emissions
by about 70 to 75 percent.
*The Environmental Quality Commission is a five-member citizen board that sets
environmental policy and rules for Oregon and oversees the Department of
Environmental Quality (DEQ).
FD562 -1-
8/20/84
-------
Specifically, the rules call for new stoves equipped without catalysts to emit no
more than 15 grams of smoke per hour (grams/hour) after July 1986. Stoves with
catalysts will emit no more than 6 grams/hour. (The lower number is necessary for
catalyst-equipped stoves because the catalyst element degrades over time. A catalyst
that starts out emitting 6 grams/hour will emit an average of IS grams/hour over
its lifetime.) A catalyst, or catalytic combuster, is a device similar to those found
in automobiles to improve combustion. It allows the gases and particles in wood
smoke to burn at lowered temperatures before the smoke leaves the stove.
In July 1988, the emission standards will be tightened to 9 grams/hour for
noncatalyst-«quipped stoves and 4 grams/hour for stoves with catalysts. Some well
designed catalyst-equipped stoves can already meet the stricter 1988 standard. But
the average stove now on the market emits more than 30 grams/hour.
The Department proposed a phased standard in order to meet air quality standards
while providing consumers a wider choice of wcodstove designs. The 1986 standard
will begin cleaning up our air while allowing manufacturers time to develop a. variety
of clean-burning designs that will meet the 1988 standard. The stricter 1988
standard should allow most areas of the state to meet air quality standards by the
year 2000, and provide airshed space for growth and development.
Label Requirements
The consumer will find two labels on certified woodstoves and stove-like fireplace
inserts describing their tested performance. The technical label shows the tested
emissions and efficiency levels over the whole range of heat output levels; this
label is attached permanently to the stove. A second label, intended for the
consumer, shows the stove's average emissions and efficiency levels and the range
of heat output levels as well as Oregon's emissipn standard; this label can be
removed by the consumer and is primarily used for selection purposes when sizing
stoves, and comparing appliance efficiencies.
Benefits to the Consumer
For the first time, the consumer will have appropriate and accurate information to
make a knowledgeable decision, in selecting the right-size stove for the intended
space to be heated when purchasing a woodstove or stove-like insert.
Because woodstove retailers will be monitored for compliance with the law, the
consumer can also be assured that the stove passed an independent emission and
efficiency test when the stove is sold in Oregon. DEQ monitoring will not occur
in the home.
An added benefit will be the less polluted air because the consumer made the effort
to purchase a better designed, cleaner burning woodstove. The cleaner burning stoves
have higher efficiency ratings (more usable heat generated from less wood consumed)
and safety benefits (less creosote buildup with less chimney cleaning costs). The
purchase price of the new stoves may be somewhat higher, but savings in fuel usage
and chimney cleaning will offset the higher initial cost.
For More Information
More information or a copy of the rules can be obtained by writing to DEQ, P.O. Box
1760, Portland, 97207; or by calling 229-6488 or toll-free 1-800-452-4011.
FD562 -2-
8/20/84
-------
Department of Environmental Quality
WOODSTOVE CERTIFICATION PROGRAM
Steps Toward Certifying a Stove In Oregon
I. LAB ACCREDITATION
Before any stove models can be tested, laboratories have to be
accredited by the DEQ; it takes about a month to get a laboratory
accredited.
A. Labs must apply for accreditation, and document they meet the
accreditation criteria:
- Cannot be financially dependent on any woodstove business;
- Must follow generally accepted professional practices;
- Lab staff must be trained and then tested for competency
yearly;
- Lab must be equipped properly;
- Must keep complete and accessible records;
- Must have equipment, training records, testing data, etc.
available for DEQ inspection;
- Must maintain a quality control system;
- Must have an emissions and efficiency computer program
approved by DEQ;
• Cannot discriminate against persons or businesses, cannot
belong to associations that discriminate.
•
B. DEQ will inspect labs after application is considered complete:
- Lab will have to perform in DEQ's presence one complete
emissions and efficiency test on a woodstove provided by DEQ;
- Lab deficiencies must be corrected within 30 days, DEQ may
revisit.
C. DEQ will approve or deny accreditation after all information
is submitted.
• Accreditation is good for three years;
• DEQ may audit one stove test during the three years;
• Accreditation is not renewable, labs must go through the
application procedure again.
II. TESTING PROCEDURES
Manufacturers will take their stove models to an accredited lab for
emissions and efficiency testing. The testing and reporting will
take approximately two weeks and will cost approximately $6000 per
model.
A. Fuel
- Wood must be air dried Douglas fir lumber, room temperature,
with a moisture content of 16 to 20 percent, measured within
4 hours of testing;
MM (8/21/84)
FD686 -1-
-------
• Must be free of knots, pitch, rotted areas;
- Dimensions of the wood will depend upon the volume of the
stove firebox; for unusual designs, the loading oust be
cleared by DEQ before testing.
B. Testing
- Simultaneous emissions and efficiency tests are required for
four ranges of heat outputs (less than 10,000 BTUs/hour,
10-15,000 BTUs/hour, 15-25,000 BTUs/hour, maximum heat
output);
- If a stove cannot achieve one or more of the heat output
levels, additional tests must be conducted at the next closest
range;
- Testing is finished at each range when all the wood is
consumed;
- Standard method for measuring emissions is DEQ Method 7, or
modified EPA Method 5;
- Standard methods for measuring efficiency are calorimeter
rooms or stack loss;
- Substitute testing methods can be used, if precision and
accuracy tests are performed and equivalency is proven;
- Before a stove is tested, its catalytic comfaustor must be
aged by being used in a stove continuously for 50 hours.
III. SPECIAL CATALYST REQUIREMENTS
- Catalysts must be tested to ensure they are still 70 percent
effective after 5000 hours of use, or the manufacturer must provide
a 24-month complete replacement warranty;
- Stoves with catalysts must have a thermometer access installed
to allow the owner to monitor stove gas temperatures, which will
indicate whether the catalyst needs replacement. (The consumer
can purchase the thermometer, if desired.)
TV. APPLYING FOR CERTIFICATION, AND LABEL APPROVAL
After a manufacturer has its stove test results that meet the
appropriate participate standard, they can apply for certification.
When the DEQ concludes that the application is complete and that the
test results are accurate, it will provide the manufacturer with the
approved emissions and efficiency content for the labels. The
manufacturer will produce the labels and submit them to the Department
for approval. If the labels are approved, and all other requirements
are met, the DEQ will certify the stove.
A. Application for certification must include:
- Description of the stove, including design plans and operating
manual;
- Testing information, including particulate and gas emissions,
heat output, burn rate, average efficiency values, gas
composition and temperatures for each test cycle;
MM (8/21/84)
FD686 -2-
-------
- Nonrefundable application fee of $1600 for a manufacturer's
first model, and $300 for each additional model.
«
B. Label requirements
- A legible permanent label (sample attached) must be attached
on the outside of the stove (except on the bottom), or on
the inside the stove, if it can be seen and will remain
legible;
- A removeable label (sample also attached) must be visibly
located on the stove at the point of sale;
- Before the Department can approve the labels and certify the
stove, the manufacturer must submit proofs of the labels,
diagrams of where the labels will be attached, information
on how the permanent label will be attached, and the name of
the label printer;
- The Department must approve or deny the use of the labels
within 14 days;
- The manufacturer must submit to the DEQ final copies of the
labels within one month of printing.
C. Certification approval
- The Department must notify a manufacturer within 60 days of
receiving a completed application whether certification is
granted or denied;
- Certification is good for five years, manufacturers must apply
for a new certification 60 days before the old certification
expires. The fees and testing requirements may be waived if
no changes to the stove have been made that affect emissions
or efficiency;
- Manufacturers must apply for new certification (even before
five years) if the stove is altered in any way that changes
its emissions or heating efficiency.
7. ENFORCEMENT
• Manufacturers, retailers or labs that violate the rules or statute
are subject to civil penalties;
- If a lab violates the accreditation rules, stoves tested at that
time may lose their certification;
- If certification is revoked, no one may claim the stove is approved
by the Department.
MM (8/21/84)
PD686 -3-
-------
Permanent Woodstove Label
(Example)
CERTIFIED TEST PERFORMANCE
T»«ted by: _Dat«: Procedure:
D
O
Z
5
20, . ___ =====90
pro 0]
o \ r *
O
Joo
m
TJ
2
o
«0
4
«.«• W.Mt II.OM ».M> ».1M 14.a
HEAT OUTPUT • BTU/HOUR
Manufaetuf »r • Uedel:
Parformanea m»y vary from test v«,Iut« dep«ndln< on 4etu*I horn* op«f»tlng aondltlorn
Removable Woodstove Label
(Example)
A.VO
(non-catalytic stoves)
Smotce graaa/hour (EEQ Standard! 15 until 07/88)
» after 07/88)
______ * (No OEQ Standard)
HEAT OCT?CT RAKCS
to 8TtJfs/hour
0«sigr.
Nace Mane Nuocer
(Performance »»•/ vary from test values depending on actual home
operating conditions)
Pursuant to OAS _. this unit has seen certified as
meeting Oregon Oeparx?.e,it of Environmental Cuality emission
standards and nas seen approved for sale in tir.e State of Oregon
until July 1, 1988.
-------
Section 13
Part B
CONFIRMATION TESTING SUMMARY
TESTING PROGRAM DESIGN
The finalized Oregon Woodstove Testing Procedure was performed by OMNI
Environmental Services, Inc. in December 1983, and January 1984 according
to the following scenario:
- Four Stoves
o Blaze King Princess - medium size catalytic
o Jotul 201 - small size dual combustion chamber
o WHA Generic - large size conventional
o Oregon Mfg. Catalytic - large size catalytic
- Simultaneous Stack Loss and Calorimeter Room Heating Efficiency
Methods on above four stoves.
- Dual Method 7 Particulate Sampling Trains on all four stoves
- Dual Condar Particulate Samplers on Jotul 201, Generic, and
the Large Catalytic (WHA sponsored)
- 5000 hour catalytic longevity test on Blaze King Princess
- Additional two stoves - Method 7 and Jaasma Dilution Tunnel {WHA
Sponsored)
o Medium size conventional
o Small size conventional
SIGNIFICANT FINDINGS
1. The revised final test procedure was found to be very wor(cable - no
problems were identified.
2. Calorimeter Room method vs. Stack Loss Efficiency method on an average,
.produced results within + 1% of each other and 7% maximum difference.
This was virtually identical to previous testing. Both methods are
still considered acceptable.
3. Oregon Method 7 precision was found to be very good with highest
deviation ± 9% between dual trains. This is better than reported for
EPA MS which does not use an impinger catch.
4. The Condar sampler had precision equivalent to Oregon Method 7.
Condar accuracy as compared to Method 7 did not meet equivalency
criteria previously agreed to by WHA. Criteria called for accuracy
within + 12%. Results indicated average accuracy of about ± 30% with
highest and second highest deviations being 165% and 74% respectively.
The deviation on a gm/hr basis averaged + 2 gm/hr and did not exceed
AA4183 -1-
-------
Section 18
Part B
4.8 gra/hr, reaffirming the Condar to be a very useful and reliable
tool for screening stoves and research and development work. These
results are based on latest corrections to Condar data.
5. The Jotul 201 had somewhat higher emissions than expected with a
weighted average emission performance of 9 to 16 gin/hour depending on
which 4 of the 7 test runs are used to develop the weighted average
emission level.
6 The small conventional stove was found to enit 11 gm/hr. This very
small non-catalytic unit is widely copied by other manufacturers and is
readily available in some inexpensive versions ($99). Performance of
the copies may be similar.
7. The two catalytic stoves performed under the DEQ and Committee proposed
6 gm/hr emission standard. A weighted average performance of 1 gm/hr
was measured for the Blaze King Princess.
8. The WHA Generic stove had a large firebox size requiring only 4x4
fuel. The unit performed similarly to previous tests with 2x4 cribs
except at the very low heat output where emissions dropped due to stack
creosoting. The weighted average emissions were 31 gra/hour.
9. An average size conventional stove using a 2x4/4x4 mix of fuel was
measured at a weighted average emission rate of 27 gm/hr.
10. Quadratic curve fitting of the four data points per stove produced
reasonable curves.
11. Virtually all possible methods of calculating emissions produce very
similar results (i.e., curve fit 8 13000 Btu/hr, curve fit or actual
data with cumulative probability heat output, etc.).
12. A catalyst degradation test with the finalized test method confirms
Corning data that the catalyst is 80% efficient at 5000 hours (i.e.,
about 6 gm/hr on the Blaze King Princess).
13. The medium and large conventional stove tests with the finalized test
method indicate a baseline emission rate in the range of 30 gm/hr.
This closely agrees with the 34 gm/hr baseline DEQ originally
identified from extensive ambient monitoring and modeling (i.e.,
20 gm/kg emission factor 8 1.7 kg/hr average burn rate.)
14. The Advisory Committee's original 20AO & 9/6 (non-cat/catalyst) staged
emission standard recommendation would result in only about a 33%
reduction in emissions based on a 30 gm/hr baseline with the first
stage and likely no existing non-catalyst stoves meeting the second
stage.
AA4133 -2-
-------
Section 13
Part B
15. Some optional emission standards based on confirmation test results
would include:
A. 14/6 (which would pass Jotul 201 and possibly many small
conventional stove types). Approximately 50% airshed emission
reduction.
B. 12/6 (which may exclude Jotul 201 but possibly include many small
conventional units). Approximately 60% airshed emission reduction.
C. 7/3 (which would include the better performing catalysts and
set a goal to reach for non-catalysts). Could achieve needed
airshed reduction level of approximately 80%.
0. A S C or B & C as 2-stage standards.
AA4183 -3-
-------
EXAMPLE CALCULATION OF WEIGHTED AVERAGE EMISSIONS
STEP ONE
A woodstove is tested at four heat outputs as outlined below:
Emissions Heat Output Order of
Stove Model Run fg/hrl f3tu/hr) Heat Output
Example Catalytic A 4.1 11,067 2nd
Example Catalytic B 10.4 17,663 3rd
Example Catalytic C 9.7 20,074 4th
Example Catalytic D 2.0 7,652 1st
Note that Run 0 was at a heat output of <10,000 Btu/hr, Run A at
10-15,000 Btu/hr, Run B at 15-25,000 Btu/hr, and Run C at maximum
heat output.
STEP TOO
The test results are now rearranged in order of increasing heat
output, extra lines are added before and after the test runs, and
cumulative probability figures are taken from Table 1 of the rules
(OAR 340-21-120):
Order of Line Heat Output Emissions Cumulative
Heat Output Nupber (Btu/hr1) (g/hrl Probability (Pi
0 0.00000
1st 1 7,652 2.0 0.21615
2nd 2 11,067 4.1 0.46226
3rd 3 17,663 10.4 0.86822
4th 4 20,074 9.7 0,93620
5 1.00000
STEP
Now the weighting factors (K^) are calculated:
Ki s P2 - P0 = 0.46226 - O.COOOO = 0.46226
*2 - P3 ~ P1 = 0-36822 - 0.21615 = 0.65207
K3 s PU - P2 » 0.93620 - 0.46226 = 0.47394
KiJ s P5 - P3 = 1.00000 - 0.86822 = 0.13178
*1 + K2 + K3 + £4 = 1.72005
STEP FOUR
Finally, the weighted average emissions (S) are calculated;
E s
•»• K3 + K4)
E = (Q. 46226 x2.0 U( Q. 65207 x4.lUfQ.U7_Tlci4-x1Q. 4 )*( 0.1 "178x0.71
(1.72005;
E = 5.7 g/hr
MLH:a
4/10/84
AA4374
-------
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MISSOULA
-------
WOOD BURNING REGULATIONS
SUMMARY
I. OPACITY (Density of Smoke)
-Opacity cannot exceed 60% (see photo) except during start-up of a fire.
A 15 minute grace period is allowed for start-up.
-To whom does it apply? It applies to all residential and commercial solid
fuel burning devices; no exemptions.
-Where does it apply? Both Zone 1 and Zone 2 (see maps).
-When does it apply? All times except during Alerts (when no visible
emissions are allowed) in Zone 1; all times in Zone 2.
II. STAGE I AIR POLLUTION ALERTS AND STAGE II AIR POLLUTION WARNINGS
-No visible emissions from any residential or commercial solid fuel
burning devices.
Exemptions: Sole Source of Heat Permits.
Dealer Demonstration Permits.
Special Need Permits.
These sources are allowed to burn with a valid permit, but opacity
cannot exceed 20% (see photo) except during start-up of a new fire. A
20 minute grace period is allowed for start-up. Information concerning
these permits is available at the Health Department.
-Where does it apply? Alerts and Warnings are mandatory in Zone 1 and
Voluntary in Zone 2 (see maps).
-When does it apply? Alerts and Warnings will be called either at 9 AM,
Noon, or 5 PM and remain in effect until the Health Department cancels
them.
CALL THE AIR POLLUTION HOTLINE
728-AIRE (2473)
For The Latest Air Quality Status
-Air quality status is also available from local TV and radio stations and
every 5 minutes on the 24 hour cable weather channel. The Missoulian
also carries a forecast prediction on the front page. No enforcement
will occur until 3 hours after and Alert has been called. However,
it is your responsibility to know if an Alert or Warning is in progress.
-You are requested to limit your vehicle driving to necessary trips only
and use mass transit whenever possible.
-------
III. PENALTIES
-All firsc violations during any one burning season are warnings. If
you wish to contest a first violation, you must submit to the Health
Department a written request, within 7 days of receipt of your
Notice of Violation, for a hearing before the Air Pollution
Control Board.
-For all subsequent violations during any one burning season a
complaint will be filed in Justice Court and can result in
a maximum penalty of $100.00. If you have an exemption permit,
subsequent violations are grounds for revoking your permit.
IV.
-Educational materials or an educational classroom sessions are
available upon request from the Health Department.
-------
Section XII. "EMERGENCY PROCEDURE - MISSOULA COUNTY AIR STAGNATION PLAN:"
(A) Purpose and Explanation
The following plan was devised using Missoula County air quality inventory data
specifically assembled for inversion periods. The objective of the strategies
is to provide protection to the community during an air stagnation period and
also to aid in meeting the annual TSP compliance by reducing inversion-related
high TSP values.
(B) General Provisions
(1) Total Suspended Particulates (TSP)
(a) Ambient concentrations of TSP will be determined by the Department
by utilizing a reference method or functional equivalent air quality
monitoring and sampling devices which have been approved in writing by
the Department of Health and Environmental Sciences.
(b) The Stage I Alert and Stage II Warning shall be declared by the
Department whenever the ambient concentration of T.S.P. exceeds the
specified level for that stage averaged over an eight hour period and
when scientific and meteorological data indicate that the average
T.S.P. concentrations will remain at or above the specified level if a
Stage I Alert or Stage II Warning is not called. The Department may
call a Stage I Alert or Stage II Warning whenever availible scientific
and meteorolgical data indicate that the ambient concentration of
T.S.P. can reasonably be expected to exceed the specified level
averaged over an eight hour period within the next 24 hours, as
determined by the Department.
(c) Stage III EMERGENCY and Stage IV CRISIS shall be declared by the
Department whenever the TSP concentrations equal or exceed the
specified level for twenty-four (24) hours.
(d) Any of the above stages for TSP shall be reduced to the
appropriate stage when measurements of the ambient air indicate a
corresponding reduction in TSP levels.
(e) When, in the opinion of the Department, meteorological and
scientific data indicate that the particulate measured is not
hazardous (e.g. non-respirable ), the level may be adjusted.
(2) Sulfur Dioxide, Carbon Monoxide, Oxidants, Nitrogen Dioxide
(a) Ambient concentration of sulfur dioxide, carbon monoxide, oxidants
and nitrogen dioxide will be determined by the Department by utilizing
reference methods or functionally equivalent air quality monitoring
and sampling devices which have been approved in writing by the
Department of Health and Environmental Sciences.
(b) The Stage II WARNING, Stage III EMERGENCY, and Stage IV CRISIS
will be declared by the Department whenever the ambient concentation
of any of the pollutants listed above equals or exceeds the level
specified under each stage for the specified period of time.
-------
(c) Any of the above stages for sulfur dioxide, carbon monoxide,
oxidants or nitrogen dioxide shall be reduced to the appropriate stage
when measurements of the ambient air indicate a corresponding
reduction in sulfur dioxide, carbon monoxide, oxidants or nitrogen
dioxide levels and available meteorological data indicates that the
concentration of such pollutant will not immediately increase again.
(C) Area of Application
(1) The provisions of Section XII shall apply to all sources of air pollution
located within the geographical area designated as the Air Stagnation Zone.
(2) The provisions of Section XII shall also apply to all point sources within
Missoula County emitting or capable of emitting twenty-five (25) tons or more
per year of any pollutant, when, based on available scientific and
meteorological data, the Department determines that such source or sources are
causing or contributing to ambient concentrations of any pollutant anywhere
within Missoula County in excess of the concentrations set forth in this Section
XII.
(D) Abatement Plan for Certain Sources
Each point source within Missoula County emitting or capable of emitting
twenty-five (25) tons or more per year of any regulated pollutant shall submit a
plan of abatement for reducing emissions of each such pollutant when the ambient
concentration of such pollutant equals or exceeds the concentrations set forth
in this Section XII. Such plan shall be subject to review by the Department and
shall be approved if the plan sufficiently demonstrates the ability of the
source to reduce emissions as required under each stage of the emergency plan.
Such abatement plan shall be submitted within 60 days after the effective date
of this regulation.
(E) Procedure
(1) Nothing in Section XII shall be construed to limit the authority of the
Control Board or Department to act in an emergency situation.
(2) If any of the provisions of Section XII are being violated, or if, based on
scientific and meteorological data, the Control Board or Department has
reasonable grounds to believe that there exists in Missoula County a condition
of air pollution which requires immediate action to protect the public health or
safety, the Department or the Control Board or any law enforcement officer
acting under the direction of the Department or Control Board may order any
person or persons causing or contributing to the air pollution to immediately
reduce or complet ely discontinue the emission of contaminants.
(3) The order shall specify the provision of the Program being violated and the
manner of violation, and shall direct the person or persons causing or
contributing to the air pollution to reduce or completely discontinue the
emission or air contaminants immediately. The order shall notify the person to
whom it is directed of the right to request a hearing. The order shall be
personally directed to the person or persons in violation or their agent.
If a hearing is requested by a person or persons allegedly in violation of
the provisions of Section XII, the Department shall fix a time and place within
Page 2
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24 hours for a hearing to be held before the control board or a hearings
examiner appointed by the Control Board. Not more than 24 hours after the
commencement of such hearing, and without adjournment, the Control Board shall
affirm, modify or set aside the order. A request for a hearing does not stay or
nullify an order.
(5) If a person fails to comply with an order issued under this Section XII, the
Department or the Control Board may initiate action under Section XV and Section
XVI of this program.
(6) The right to request a hearing before the Board under this Section shall not
apply to violations of Section X 4100. Enforcement procedures for violations of
Section X 4100 are described in Section X 4100 (G).
(F) When in effect, the requirements of Section XII shall supersede all other
regulations under this program which are less restrictive.
(G) STAGE I - ALERT
The following provisions shall take effect when the ambient concentration of
total suspended particulate (T.S.P.) meets or exceeds 150 micrograms per cubic
meter as set forth in Section XII (B) (1) (b).
(1) The Department shall advise citizens via public media of the actions listed
under Alert, and of medical precautions.
(2) The Department shall not issue any open burning permits and shall suspend
existing open burning permits.
(3) Residential solid fuel burning devices shall comply with the applicable
requirements of Section X 4100 Subsection E. Permitted devices shall comply
with conditions set forth on the permit.
(4) The Department shall request citizens to limit automobile driving to
necessary trips only and to avoid driving on unpaved surfaces such as dirt roads
and unpaved shoulders and alleys. Alternative transportation shall be
encouraged.
(5) The Department shall request construction companies to take effective
dust-control action for roads under construction or repair.
(6) The Department shall request commercial boiler operators to limit boiler
lancing and soot blowing to early afternoon hours.
(7) The City, County and State road departments shall be required to take
actions appropriate under the prevailing weather conditions to reduce road dust
along heavily travelled streets. Plans from each governmental road department
describing such appropriate actions shall be submitted to the Department for
review within 60 days after the effective date of this regulation and shall be
approved if they demonstrate reasonable measures to minimize road dust.
(8) A point source may not switch to a higher sulfur or ash content fuel unless
that source has continuous emission reduction equipment for the control of
emissions caused by the alternate fuel.
(9) Each point source emitting or capable of emitting twenty-five (25) tons or
Page 3
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more per year of any pollutant shall be required to implement its abatement plar
to reduce emissions during an Alert. Maximum efficiency of abatement equipment
shall be required.
(10) Licensed incinerators, except pathological incinerators and crematoriums,
shall cease operation during an Alert.
(H) STAGE II - WARNING
The following provisions shall take effect when ambient concentrations equal or
exceed those set forth in the table below and declared as set forth in section
XII (B).
300 ug/m TSP 8 hour average
800 ug/m S02 24-hour average
17.0 mg/m CO 3-hour average
MOO ug/m Ox 1-hour average
1130 ug/m N02 1-hour average
(1) The Department shall advise citizens via public media of the actions
described under Warning, and of medical precautions.
(2) All Alert conditions shall remain in effect except where Warning steps an
more stringent.
(3) The Department shall strongly advise the public to eliminate all
non-essential driving, and urge citizens to make prearrangements for car-pooling
or use public transportation during a Warning condition.
(4) Residential solid fuel burning devices shall comply with the applicable
requirements of Section X 4100. For sources other than residential solid fuel
burning devices, no person shall cause, allow or discharge visible emissions
from any source unless such source has a State or County air contamination
permit.
(5) Each point source emitting or capable of emitting twenty-five (25) tons or
more per year of any pollutant shall be required to implement its abatement plan
to reduce emissions during a Warning and maximum efficiency of abatement
equipment shall be required in accordance with that abatement plan. Such point
sources shall be advised of possible Emergency conditions and shall be prepared
to take action as advised under the Emergency conditions.
(I) STAGE III - EMERGENCY
The following provisions shall take effect when ambient concentrations equal or
exceed those set forth in the table below:
625 ug/m TSP 24-hour average
1600 ug/m S02 24-hour average
Page 4
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34.0 mg/ra CO 3-hour average
800 ug/m Ox 1-hour average
2260 ug/m N02 1-hour average
(1) The Department shall advise citizens via public media of the actions
described under an Emergency episode and of medical precautions.
(2) All Alert and Warning conditions remain in effect during Emergency, except
where Emergency steps are more stringent.
(3) All nonessential public gatherings should be voluntarily cancelled.
(4) All trips by car should not be made without carefully considering the use of
public transportation and carpooling, and the necessity of the trip.
(5) Specific advisement shall be issued that conditions are continuing to worsen
and that total curtailment under a Crisis condition is possible.
(6) Each point source emitting or capable of emitting twenty-five (25) tons or
more per year of any pollutant shall be required to implement its abatement plan
to reduce emissions during an Emergency episode. A minimum forty percent (40J)
reduction in emissions below maximum permissible operating emissions shall be
required.
U) STAGE IV - CRISIS
The following provisions shall take effect when ambient concentrations equal or
exceed those set forth in the table below:
875 ug/m TSP 24-hour average
2100 ug/m S02 24-hour average
46.0 mg/m CO 8-hour average
1000 ug/m Ox 1-hour average
3000 ug/m N02 1-hour average
(1) All conditions from the Alert, Warning, Emergency are in effect except where
Crisis steps are more stringent.
(2) Only those establishments associated with essential services may remain
open. Essential services are news media, medically associated services
(hospitals, labs, pharmacies), direct food supply (grocery markets,
restaurants), police, fire and health officials and their associated
establishments. It is expressly in tended that any sevice not defined as
essential shall cease all business. Examples given here are not all-inclusive,
but are instructive as to identify the general types of business considered
non-essential: banks, all offices, laundries, gas stations, barber shops,
schools (all levels), repair shops, amusement and recreation facilities,
libraries, city, state and federal offices.
Page 5
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(3) Point sources shall cease all manufacturing functions, but they will be
allowed to maintain operations necessary to prevent injury to persons or damage
to equipment.
History:
APCB Hearing 8-25-83
APCB Approval 11-10-83
DHES Approval 11-14-83
Co. Commission Approval 11-16-83
Page 6
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ZONE I
HIGH IMPACT AREA/MANDATORY ALERT
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ZONE II
L' , !••'
« i
t >
*
• :•• V.:**«C;-Y*~.
AIR STAGNATION ZONE
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Section X. 4100 RESIDENTIAL SOLID FUEL BURNING DEVICES
A. The intent of this Section is to regulate and control the emissions of
air contaminants from residential solid fuel burning devices in order to
further the policy and purpose declared in Section II.
B. DEFINITIONS
1. Air Stagnation Zone: the geographical area designated as such by a map
adopted by the Missoula City-County Air Pollution Control Board on September 24,
1981. Attached hereto and by this reference made a part hereof.
2. Burning season: that period of time from the first day of July through the
last day of June of the following year.
3. "Class of device" means a group of residential solid fuel buning devices
similar in technology utilized, age, heat output, or design which the department
determines to be appropriate for the purpose of setting emission rates. These
classes include but are not limited to existing woodstoves, fireplaces and wood
furnaces.
4. Class I permit is an emissions permit issued by the Department to operate a
residential solid fuel burning device during an air pollution Alert and during
periods when the air stagnation plan is not in effect. Residential solid fuel
burning devices must meet lowest achievable emission rate to qualify for a Class
I emissions permit.
5. High Impact Zone: the geographical area designated as such by a map adopted
.by the Missoula City-County Air Pollution Control Board on August 25, 1983.
Attached hereto and by this reference made a part hereof.
6. "Lowest Achievable Emission Rate" means an emission limitation for any one
or more of the following: visible emissions, TSP, PM10, CO. This rate shall
represent the most stringent limitation achieved in practice by a class of
devices as set forth in Section X4100,D.1.b.
7. Residential Solid Fuel Burning Device: any fieplace, fireplace insert, wood
stove, woodburning heater, wood stick boiler, coal-fired furnace, coal stove, or
similar device burning any solid fuel used for aesthetic, cooking, or
space-heating purposes and installed or used in a private residence or
commercial establishment, which burns less than 1,000,000 B.T.U.'s per hour.
8. Sole Source of Heat: one or more residential solid fuel burning devices which
constitute the only source of heat in a private residence for purpose of space
heating. No residential solid fuel burner or burners shall be considered to be
the sole source of heat if the private residence is equipped with a permanently
installed furnace or heating system, designed to heat the residence connected or
disconnected from its energy source, utilizing oil, natural gas, electricity, or
propane. A sole source permit may be issued by the department when the heating
system is only minimally sufficient to keep the plumbing from freezing. Only
residences equipped with a woodstove which qualifies for a Class I Permit may
obtain a new sole source of heat permit after July 1, 1985, unless a sole source
of heat permit was issued before July 1, 1985, in which case such permit may be
renewed.
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9. Woodstove means a wood fired appliance with a heat output of less than
40,000 BTU/HR with a closed fire chamber which maintains an air-to-fuel ratio of
less than 30 during the burning of 90 percent or more of the fuel mass consumed
in a low firing cycle. The low firing cycle means less than or equal to 25
percent of the maximum burn rate achieved with doors closed or the minimum burn
achievable, whichever is greater. Wood fired forced air combustion furnaces
that primarily heat living space, through indirect heat transfer using forced
air duct work or pressurized water systems are excluded from the definition of
"woodstove".
C. VISIBLE EMISSIONS
1. Within the air stagnation zone, no person owning or operating a residential
solid fuel burning device shall cause, allow, or discharge emissions from such
device which are of an opacity greater than forty (40) percent.
2. The provisions of this subsection shall not apply to emissions during the
building of a new fire, for a period or periods aggregating no more than fifteen
(15) minutes in any four (4) hour period.
/
D. EMISSION STANDARDS AND CERTIFICATION FOR NEW INSTALLATIONS
1. Woodstoves.
a. The Board hereby adopts the Oregon Department of Environmental Quality
"Standard Method for Measuring the Emissions and Efficiencies of Woodstoves",
sections 1 through 8 and O.A.R. Chapter 340, Division 21 Sections 100, 130, 140,
145, 160, 161, 162, 163, 164, 165 as applicable for the sole purpose of
establishing a uniform procedure to evaluate the emissions and efficiencies of
woodstoves, including criteria for the acceptance of equivalent test methods.
b. The Department may issue a Class I Permit to woodstoves for which a permit
application was recieved during the period July 1, 1985 and June 30, 1988 if the
emmissions do not exceed six (6) grams per hour weighted average when tested in
conformance with X4100 D.1.(a). The Department may issue a Class I Permit to
woodstoves for which a permit application was recieved on or after July 1, 1988
if the emissions do not exceed four (4) grams per hour weighted average when
tested in conformance with X4100 D.1.(a). In order to qualify for a Class I
permit, catalyst equipped woodstoves must be equipped with a permanent provision
to accommodate a commercially available temperature sensor which can monitor
combustor gas stream temperature within or immediately downstream (within 1.0
inch or 2.5 cm) of the combustor surface.
c. The department shall accept as evidence of compliance with the emission
limitation imposed in X4100, D,1,(b), labels affixed to the stove in compliance
with OAR 340-21-150 or documentation which, in the opinion of the department, is
sufficient to substantiate that the specific model, design, and specifications
of the woodstove for which a permit is requested meet standards specified in
X4100 D.(a) and (b).
d. Class I permits issued for wood stoves which may be operated during an air
pollution Alert shall be valid for a period of two years. They shall not be
transferable from person to person or from place to place unless repermitted by
the Department. When the permitted device is repermitted , the department may
require information to determine if the woodstove is capable of meeting emission
Page 2
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requirements. If an inspection of the appliance during operation is not allowed
by the applicant, the department shall require evidence that any non-durable
parts (e.g. catalytic combustor) have been replaced as necessary to meet
emission limitations set forth in X4100 D.,1.,b. and E.,3.
e. The department shall issue a Class I permit when the applicant has submitted
information, on forms supplied by the department, which indicates compliance
with Section X4100 D.1, and other applicable provisions of this program.
E. PROHIBITION OF VISIBLE EMISSIONS DURING AIR POLLUTION ALERTS AND WARNINGS
1. Within the high impact zone, no person owning, operating or in control of a
residential solid fuel burning device shall cause, allow, or discharge any
visible emissions from such device during an air pollution Alert declared by the
Department pursuant to Section XII (G) unless a sole source of heat permit,
dealer's demonstration permit, special need or Class I permit has been issued
for such device pursuant to Section X4100 F.
2. Within the high impact zone, no person owning, operating, or in control of a
residential solid fuel burning device for which a sole source of heat permit,
dealer's demonstration permit, or special need permit has been issued shall
cause, allow, or discharge any emissions from such device which are of an
opacity greater than twenty (20) percent during an air pollution Alert declared
by the Department pursuant to Section XII (G). The provisions of this paragraph
shall not apply to emissions during the building of a new fire or for refueling
for a period or periods aggregating no more than twenty (20) minutes in any four
(4) hour period.
3. Within the high impact zone, no person owning, operating, or in control of a
residential solid fuel burning device for which a Class I Permit has been issued
shall cause, allow, or discharge any emissions from such device which are of an
opacity greater than ten (10) percent during an air pollution Alert declared by
the Department pursuant to Section XII (G). The provisions of this paragraph
shall not apply to emissions during the building of a new fire, or for refueling
for a period or periods aggregating no more than twenty (20) minutes in any four
(4) hour period.
4. For the purposes of this section, the Department shall declare an air
pollution alert to be in effect whenever the ambient concentration of total
suspended particulate (T.S.P.) within the high impact zone equals or exceeds 150
micrograms per cubic meter (ug/m3) averaged over any eight (8) hour period and
when scientific and meteorological data indicate that average TSP concentrations
will remain at or above 150 ug/m3 if an Alert is not called. The Department may
call an Alert whenever available scientific and meterological data indicate that
the ambient concentration of T.S.P. within the high impact zone can reasonably
be expected to equal or exceed 150 ug/m3 averaged over an eight (8) hour period
within the next 24 hours. When in the opinion of the Department, meterological
and scientific data indicate that the particulate measured is not hazardous
(e.g., non-respirable), the level may be adjusted.
5. The Department has a duty, when declaring an air pollution Alert to be in
effect, to take reasonable steps to publicize that information and to make it
reasonably available to the public at least three (3) hours before initiating
any enforcement action for a violation of this subsection.
Page 3
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6. Every person operating or in control of a residential solid fuel burning
device within the high impact zone has a duty to know when an air pollution
Alert has been declared by the Department.
7. Within the high impact zone, no person owning, operating, or in control of a
residential solid fuel burning device shall cause, allow, or discharge any
visible emissions from such device during an air pollution Warning declared by
the Department pursuant to Section XII (H) unless such device has a sole source
of heat permit. Within the high impact zone, no person owning, operating, or in
control of a residential solid fuel burning device for which a sole source of
heat permit has been issued shall cause, allow, or discharge any emission's from
such device which are of an opacity greater than twenty(20) percent during an
air pollution Warning declared by the Department pursuant to Section XII(H).,
The provisions of this paragraph shall not apply to emissions during the
building of a new fire, for a period or periods aggregating no more than twenty
(20) minutes in any four (4) hour period.
F. FUEL
Within Missoula County no person shall burn any material in a residential solid
fuel burning device except newspaper, untreated kraft paper, untreated wood and
lumber, and products manufactured for the sole purpose of use as fuel. Products
manufactured or processed for use as fuels must conform to any other applicable
section of this program.
G. PERMITS
1. Within the high impact zone, no person owning, operating, or in physical
control of a residential solid fuel burning device which is the sole source of
heat shall cause, allow, or discharge any visible emissions from such device
during an air pollution Alert declared by the Department unless a sole source of
heat permit has been issued for the device by the Department.
2. Within the high impact zone, no person owning, operating, or in physical
control of a residential solid fuel burning device which is a demonstration
model in an authorized dealer's showroom shall cause, allow, or discharge any
visible emissions from such device during an air pollution Alert declared by the
Department unless a dealer's demonstration permit has been issued by the
Department. (The intent of this subsection is to allow authorized dealers to
demonstrate residential solid fuel burning devices during Alerts).
3. Within the high impact zone, no person owning, operating, or in physical
control of a residential solid fuel burning device which is eligible for a Class
I permit shall cause, allow, or discharge any visible emissions from such device
during an air pollution Alert declared by the Department unless a Class I permit
has been issued for the device by the Department. The Department shall issue
Class I permits to qualified applicants beginning July 1, 1985.
4. Special need permit; Eligibility
(a) A person who demonstrates an economic need to burn solid fuel for
residential space heating purposes by qualifying for energy assistance according
to economic guidelines established by the U.S. Office of Management and Budget
under the low income energy assistance program (L.I.E.A.P.), as administered in
Missoula County by the District XI Human Resources Development Council, is
Page M
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eligible for a special need permit which shall be issued by the Department.
(b) Application for a special need permit may be made to the Department at any
time, and a special need permit shall be valid for a period of not more than one
(1) year from the date it is issued. Special need permits may be renewed
providing the applicant meets the applicable need and economic guidelines at the
time of application for renewal. Special need permits shall be issued at no
cost to the applicant. A special need permit is not transferable from place to
place and is not transferable to a person other than the person to whom it is
issued.
(c) A person may apply to the department for a temporary special need or sole
source permit if not qualified for a permit under Sections X4100 G.1, 2, 3, 4a.
The department may issue a temporary permit if it finds that; the emissions
proposed to occur do not constitute a danger to public health or safety; and
compliance with the air stagnation plan would produce hardship without equal or
greater benefits to the public and; that compliance with the air stagnation plan
would create unreasonable economic hardship to the applicant, or render the
residence as equipped severely uncomfortable for human habitation, or cause
damage to the building or its mechanical or plumbing systems. The Department
may place conditions on a temporary permit which are adequate to insure that the
permittee is in compliance with the Program when the permit expires. The
Department shall arrange for an applicant interview to be conducted within five
(5) working days of receipt of a written request for a temporary permit and
shall render its decision within ten (10) working days of receipt of the written
request. Application to and denial by the Department for a temporary permit
shall not prevent the applicant from applying to the Board for a variance under
the appropriate provisions of this program. Temporary permits issued pursuant
to this section shall be valid for a period determined by the Department, but
shall not exceed one (1) year and shall not be renewable.
(d) In an emergency situation the Department may issue a temporary special need
permit above to a person who has applied for a special need permit variance
pursuant to X4100,G.,5. The temporary special need permit shall be valid until
the Board issues a decision on the application for a variance. An emergency
situation shall include but is not limited to a situation where a person
demonstrates that his furnace or central heating system is inoperable other than
through his own actions or the situation where the furnace or central heating
system is involuntarily disconnected from its energy source by a public utility
or other fuel supplier.
5. A person who demonstrates a special need to burn solid fuel for residential
space heating purposes in a private residence but who does not qualify for a
sole source of heat permit, dealer demonstration permit, Class I permit, special
need permit, or emergency special need permit, may apply to the Board for a
special need permit variance under the provisions of Section XIII of this
Program. The board shall consider applications for a special need permit
variance on a case by case basis and may issue such variance when the criteria
in Section XIII (1) are established. The Board shall consider economic hardship
and special circumstances when considering an application for a special need
permit variance. The Board shall conduct a hearing and issue it's decision on
an application for a special need permit variance within thirty (30) days after
receiving a written application.
Page 5
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6. Unless otherwise provided in this program, sole source of heat permits,
dealers demonstration permits, special need permits, and Class I permits for
residential solid fuel burning devices shall be issued, denied, suspended, and
revoked, in accordance with Section XI of this Program relating to Operational
Permits.
7. Whenever the Department issues a sole source of heat permit, dealer's
demonstration permit, special need permit, or Class I Permit the Department
shall provide the applicant with the following:
(a) A summary of Section X4100,
(b) Educational materials and/or an instructional session in good wood
use techniques, and
(c) A summary of the L.I.E.A.P. guidelines.
H. ENFORCEMENT OF REQUIREMENTS RELATING TO RESIDENTIAL SOLID FUEL BURNING
DEVICES
1. Unless otherwise provided in these regulations, the provisions of Sections
XIV, XV and XVI, shall govern enforcement of the requirements of Section X 4100
relating to residential solid fuel burning devices .and penalties for violations
thereof.
2. For a first violation during any one burning season, whenever the Department
determines that there are reasonable grounds to believe that a person has
violated the provisions of Section X4100, the Department shall issue a written
notice of violation and order to take corrective action to the person
responsible, as provided in Section XIV (1) of this program. The person to whom
a written notice of violation and order to take corrective action is issued
under this paragraph shall have the right to request an informal hearing before
the Board as provided in Section XIV. For a subsequent violation of the same
provision of Section X4100 during the same burning season, the Department may
initiate any enforcement action authorized by the Montana Clean Air Act and this
Program, but in no event shall such enforcement action result in the imposition
of a civil penalty or fine in excess of the amounts provided for in the table
below.
TABLE
Maximum civil penalty or fine for subsequent violations of the same
provision of Section X4100 during the same burning season after the
Department has issued a Notice of Violation and Order to Take
Corrective action for a first violation:
Second violation - Twenty Dollars ($20.00)
Third Violation - Fifty Dollars ($50.00)
Fourth or Subsequent Violation - One Hundred Dollars ($100.00).
3. The Department shall not issue any written notice of violation or order to
take corrective action, or take any other enforcement action, against any person
in violation of the provisions of Section X 4100(E) prohibiting the discharge of
any visible emissions, or emissions exceeding the maximum allowable opacity,
from a residential solid fuel burning device within the high impact zone during
an air pollution Alert declared by the Department, unless the Department has
first made the fact that an air pollution Alert has been declared to be in
Page 6
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effect reasonably available to the public for at least three (3) hours prior to
initiating enforcement action, as provided in Section X 4100 (E)(4).
4. Whenever the Department issues notice of violation and order to take
corrective action to a person for a first violation of any provision of Section
X4100 during any one burning season, the Department shall provide such person
with the following:
(a) A summary of Section X4100,
(b) Educational materials and/or an instructional session in good wood
use techniques, and
(c) A summary of the L.I.E.A.P. guidelines.
5. Anyone against whom an enforcement action is taken by the Department under
the provisions of Section X4100 may ask the Department for an administrative
review after which the Deparment may rescind, modify, or affirm the enforcement
action. A request for an administrative review shall not prevent a person
against whom an enforcement action is taken from pursuing any other appeals
process provided by this program or by law.
History:
APCB Hearing 10-25-84
APCB Approval 11-8-84
DHES Approval 11-21-84
Co. Commission Approval 11-28-84
Page 7
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COLORADO
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PITKIN COUNTY
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SESOLCTION or -VIIE DOAHO or COUNTY
COMMISSIONERS OF PITKXN COUNTY, COLORADO,
ADCPTXJIC VWUOnS LOCAL 'AMENDMENTS TO
ONXTORK aciMiHa cats, 1975 zorrzoti
Ha. 77-
o
WBSSEAS, to* Board of County Cammissianara desirea_,
for the benefit of th* residents of Pitkia County, to adopt
various am*adm*nta ta ta* 1978 edition of_ta* naifera Building
Cad* pttrsuant to th* authority and procedures established ia
C.X.4. 1973, Section 30-28-204,
• • BON, TH5HETORZ, BE XT RESOLVES by th* Board of County •
Coemissioaera of ?itkia County, Calormdo, that ta* 137S edition
"J Of th* Caifarm Building Cod* adopted by this Board's Resolution
Ho. 77-82 with amendments, b* farther amended, by
1. ta* addition of Section 3708 to Chapter 37 C'Xasonry
or Concrete Chimneys, fireplaces aad Barbecues') ta
~r*ad as followss
Section 3708 Regulation of Member and,Canatraction
(a)
nunbcr of firvplaeas that aa.y b« eoaatr^ctcd
is h«r*by liaitad ta ta« following:
(1) Siagla family dv^lliag.
unit,
.on* fir*olac* p«r
(2) Hotel, aot«l, iaa, lod?*...on* fireplaea p*r
lobby or yu*st «at*rtaina*nt roaa; oo . f iraplac*a
in gn_*t rooms.
o
(3) Restaurant or bar. ..an* firealac* p«r rvstaurant
or bar or r*stauraat/bar
(4) Duplex or tri-pl*x. . .an* firvplae* p*r unit
provided that each unit has 1,000 square f*«t or
•or* of internal haatad floor area, vita no fire-
places in saallor units.
(5) ?oar-plax- and all other sralti- family structures
...on* fireplace par 3300 xquar* ?s«t oi i.iterr.ai
bected floor are* ta bo allocated ameao ta* units
' ta b* constructed.
Cb) Ml ^ug^^s shall We carv«6iucl*d eucK tkat t-u.iir
oparatian win increase heat energy supplied ta
• the living area in quantities greater than that
lost through air exchange during combustion: and,
in addition, be constructed in confomance with
*ny design standards ' that ««iy be promulgated (or
-------
Q
approved) by the County, Engineer which are
designed to.increase heat energy supplied. .
(e) The term "fireplace" as used herein includes a
• conventional masonry fireplace, a prefabricated
zero clearance fireplace, and any similar fire-
place whose operation requires it to be built
into the structure as a component of the building.
Badiant room heaters, heating stoves and similar
appliances designed for space heating purposes
are not included within the definition of "fire-
. place" and are net subject to the limitations set
forth in subparagraph (a) of this subsection.
. 2. the addition of subsection (h) to Section 7006
(•Grading Permit Requirements') to read as follows:
(h) Other provisions of this Chapter 70 to the contrary
notwithstanding, no permit required herein for
excavation, grading, and earthwork construction,
including fills and embankments, shall issue if
the work is to be done in preparation of the
construction of improvements or establishment
of a use which is not in conformance with all
land use regulations of ?itkin County. In the
event that the Building Inspector is unable to
determine whether a permit shall or shall not
issue under the provisions of this section, he
Ttull direct the applicant to supply those plans
and specifications described in Section 7006 (c)
hereof requiring as additional information thereon
•, ill improvements and uses proposed for'the site •
ia anticipation of'which the excavation, grading,
'earthwork construction, including fills and
embankments, is to be done.
Approved by the Board of County Commissioners at its
regular meeting held August 22, 1977.
O
APPHOVSO AS TO TORN:
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nrsourrioN OF TIIK IIOAKO or
COUNTY COMHISSION1CKS OF PITKIN COUNTY, COLORADO,
V
" . ADOPTING REGULATIONS OF THE INSTALLATION AND
USE OF SOLID FUEL BURNING DEVICES IN HIE
•
• • MORE DENSELY POPULATED AREAS OF PITKIN COUNTY
. Resolution No."83'- 7 "'
"' • VniEREAS, the Board of County Commissioners believes that the use
•
of fireplaces, vood stoves and other solid fuel burners has contributed
4 . •
to the degradation of air quality within the more .densely populated
• areas of Pitkin County; and ' ' ' .
• VltERZAS, the Environmental Protection Agency indicates that airtight
, vpod-burning stoves, as commonly operated to heat a home, emit significant
- '.' amounts of carbon monoxide and particulars natter; and
. \ . WHEREAS, the County Commissioners of Pitkin County believe that
•* . . the number of such solid fuel burners should be limited; and
1 ' * * **
'_' . WHEREAS, residential coal-burning appliances cause significantly
•ore air pollution than other solid fuel burning devices and the County
Commissioners' wish to prevent coal-burning, from becoming a problem
now, before significant.numbers of'people switch from wood-heaeing
. ^ to coal; and . •.._.''
WHEREAS, certain zone districts and other areas within Titkin
County involve high densities'of human activity where air pollution is
.or may become a significant problem, it is hereby a finding that the
densities allowed in zone dis'tricts R-30, R-15, R-fi, SR, AF-2, AF-3,
" AR-1, AR-2 H.D., T, B-l, B-2, X, and PMH; and in all. subdivisions in
• ' * Pitkin County containing lots of lass than five (5) acres in size (except .
•"^ ' • those subdivisions zoned RS-160) are sufficiently high .«"d of such a '_ .
W> ••• ' •
'* character to require these mir pollution restrictions to protect the
. ' public health, welfare and safety. . .. • '• *_•'.''
: • . NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF COUNTY CO>MISSIONERS
' OF PITKIN COUNTY; COLORADO, that Resolution No. 77-104 b€ amended by chancing
Section 3703 of Chapter'37 of the Uniform Building Code as adopted by
Pitkin County ("Masonary or Concrete Chimneys, Fireplaces and Barbecues")
to rend as follows:
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Section 3700. Seculntion of Unrulier find Cnmitmet fon of SolM
Fuel Bumcm. . • •
a. In areas of fititin County within lone districts R-30, R-13,
* •
R-6, SR, AT-2, AF-3, AR-l/AR-2 It.D., T. B-l , B-2, I, «nd ' '
' •
Wfll; and in-all subdivisions in Pitk'in County contnininc lots
•'" of less than five (3) acres in size (except those subdivisions
zoned. R.S-160) ; the number of solid fuel burning devices that
nay- be constructed or installed is hereby limited to the followin
_• ' (1) Single family dwelling: One solid fuel burning device
•' ': • per •dwelling unit. • .
•
• . " (2)- Hotel, motel, inn, or lodge: One solid fuel burning device
• • ' . per lobby; no such device in guest rooms.
. (3) Restaurant or bar: One solid fuel burning device per"
' . • • '. •.
restaurant or bar or restaurant/bar combined. . '
'.' '• • . (<) Duplex: One-solid fuel burning device per unit provided
• '
•'.' ' • . that each unit has 2,000 square feet or more of internal.
.*.•• . * • . •
• heated floor area. No solid fuel burning devices shall be
' * allowed in units-with less than 2,000 square feet of interna
• ' .. heated floor area. ' • • .
• .. ' (5) Multi-unit residential and all other structures: One
•olid fuel burning device per building.
V. Any solid fuel burning device having particulat'e emissions of
"" ° —6
less than 0.330* 10 gm/Joule of useful heat output, »ver«ged
over at least six (6) tests, or no more than 0.63 x 10~ gm/joule
•o"£ useful heat output: fox any single Cose, shall be exempt from
'•' . ' ' \
provision (a) of this'regulation.
. Ho building permit shall be issued for installation of any solid,
• fuel burning device in any building in Pitkin County in excess
' of the numbeys allowed in section (a), unless the Aspen/PltJtin
Environmental Health Department (hereinafter referred to as the
Department) has certified that that device'has particulate
' emissions less than those specified above. The Department will
.• . so certify any device found to have the required emissions pro-
'. vided tests arc conducted by an independent testing lab using
the Orccon Method 7 nnd opcratinc procedures ns determined by
' the Orccon Department of Environmental Quality or nn equivalent
' procedure, ns determined by the Department. Tests must be
conducted at n "low-medium or lower burn rate.
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Prior to June 1 of each ycor, Uv? Dcpartnvrnt will make
public a list of devices known to be certified.
c. All solid fuel burning dc'vices shall be constructed such
that their operation will increase heat energy supplied
. to the living area in quantities greater than that lost
through air exchange during- ccnbustion; and, in addition,
they shall be constructed in conf ormance' with any design
standards that may be promulgated (or approved) by the County
_ Engineer which are designed to increase heat energy supplied.
'
d. The term "solid fuel burning device" as used herein includes'
but is not limited to a freestanding fireplace, conventional
masonary fireplace, a prefabricated zero clearance fireplace,
any similar fireplace whose operation requires it to be
' built into the structure as a ccmponent of the building,
Franklin stove, airtight stove, fireplace insert, or
,
any other stove or appliance designed to bum solid fuel
' for heating and/or enjoyment purposes.
*
. No solid fuel -burning device shall be allowed to burn-
•
ooal except for those devices 'already being used to burn •
' goul on Dscerrber 31 / 1962. Operators of such devices
shall receive an exenption fron this section by applying
to the Aspen/Pitkin Enviionmantal Jfealth. Department within
three months of adoption .of this resolution and demonstrating '
to said Dspartrant that this appliance has been used to
» > .
. burn coal in the past for space-heating purposes. Provided,
• • \
however, that upon the showing of good cause for excusable
neglect, 'an operator can apply for such an' exerrption after
>' . . ' the passage of said three months.
• £ . Any other provision of this Section 3708 notwithstanding,
those areas of Titkin County within the drainages of tha
Crystal lUv«r and Frying Pan River and any area of Pitkin
County not included within the "Aspen Mstro Area" as that
area is defined in Section 5-510.1 (a) (1) of the Land Use Coda
and the Aspen Area Growth Management Plan, shall not ba subject
to this Section 3708.
APPH3VED UPON FIRST READING THIS 13T11 DAY OF DECEMDEK
198£ , BY TIE DOAnn CF COUNTY COWISSIONETCS.
-3-
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VAIL, COLORADO
-------
r f
ORDINANCE 24
Series of 1983
AN ORDINANCE REPEALING AND REENACTING CHAPTER 28
OF THE VAIL MUNICIPAL CODE RELATING TO SOLID FUEL
BURNING DEVICES; PROVIDING CERTAIN DEFINITIONS;
REGULATING THE NUMBER AND CONSTRUCTION OF SOLID
FUEL BURNERS; REQUIRING HEAT EFFICIENT UNITS;
PROHIBITING COAL USAGE.
WHEREAS, the setting of the Town of Vail in a valley between two
mountains restricts air movement through the valley;
WHEREAS; the movement of air through the Gore Valley is further
restricted in cold times of the year;
WHEREAS, the pollutants in the air caused by solid fuel burning devices
have become increasingly worse;
WHEREAS, the Town Council finds that the pollution caused by solid
fuel burning devices is exacerbated by the altitude, topography, climate
and meteorology of the Town of Vail; and
WHEREAS, the Town Council finds that these sources of air pollution may
be minimized by presently-existing, practical and economical technologies.
NOW, THEREFORE, 8E IT ORDAINED BY THE TOWN COUNCIL OF THE TOWN OF VAIL,
COLORADO, THAT:
Section 1. The Vail Municipal Code is amended by the addition of a new Chapter
8.28 "Air Pollution Control" which reads as follows:
8.28.010 Purpose and Applicability
These regulations are enacted for the purpose of promoting
the health, safety, and general welfare of the residents
and visitors in the Town of Vail. These regulations are
intended to achieve the following more specific purposes:
(1) To protect the air quality in the Town of Vail;
(2) To reverse the trend towards increased air degradation
in the Town of Vail;
(3) To provide heat sources that are efficient and have a
reduced polluting effect;
(4) And to generally protect the air for the purpose of the
public's health, safety and welfare.
The provisions of this Chapter shall apply to all areas of
the Town of Vail.
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8.23.020 Definitions
(1) Solid Fuel Burner: A fixed apparatus that burns fuel to
provide heat, including, but not limited to, a masonry fireplace,
prefabricated zero clearance fireplace, freestanding fireplace,
Franklin Stove, or air tight stove.
(2) Oregon Method 7: Shall mean tests promulgated by the State
of Oregon Department of Environmental Quality in effect on the
date of certification as provided herein.
(3) Refuse: Means all solid wastes, garbage and rubbish, whether
combustible or noncombustible, including rubble.
(4) Clean Solid Fuel Burning Device: Any solid fuel burning device
having particulate emissions of less than 0.33xlO"6 gn/joule of
useful heat output, averaged over at least six tests, or no more
than 0.65xlO"6 gm/joule of useful heat output for any single test.
(5) Any word, term or phrase not hereto defined or specified shall
be defined in accordance with Title 18 "Zoning" of the Vail
Municipal Code or Title 8 "Health and Safety of the Vail
Municipal Code.
Seciton 8.28.030 Solid Fuel Burning Devices
It shall be unlawful for any person to construct, install, maintain or operate
any solid fuel burning device within the Town of Vail in a manner not in compliance
with this section.
(A) No building permit shall be issued for or including the installation
of any solid fuel burning device(s) or component(s) thereof unless
the number of such device or devices in each structure is less than
or equal to the following:
(1) Each dwelling unit may have one solid fuel burning device per
dwelling unit. Reference (C) for exceptions.
(2) A hotel, motel, inn or lodge may have one solid fuel burning
device per lobby. Solid fuel burning devices in individual
guest rooms, accommodation units and lock-offs are hereby
prohibited.
(3) A restaurant or bar may have one solid fuel burning device
per restaurant or restaurant/bar combined.
-------
-3-
uas Fireplaces: The .-ssinctiona of tms Chapter snail noi
apply to a fireplace fueled by natural gas, propane, or any
similar liquid fuel so long as said fireplace is designed and
constructed so that said fireplace cannot be used or modified
to burn solid fuels. Gas fireplaces shall be permitted in any
unit.
(C) Additional Solid Fuel Burning Devices: Each dwelling unit may
have two solid fuel burning devices in the following types of
combinations: one fireplace and one clean woodburning stove
or two clean woodburning stoves.
1. No building permit shall be issued for installation of any
clean burning solid fuel burning device in any building of
the Town of Vail unless the Vail Environmental Health Officer
has first certified in writing that the device has particulate
emissions less than or equal to those specified above. The
Environmental Health Officer will so certify a^y device found
to have the required emissions provided tests on that brand or
class of device are conducted by an approved independent testing
using the "Oregon Method 7" and operating procedures as determined
by the Oregon Department of Environmental Quality or an equivilant
procedure, as determined by the Environmental Health Officer. Tests
must be conducted as a low-medium or lower burn rate, as defined
by Oregon Method 7". On or before June 1 or each year, the
Environmental Health Officer will publish a list of devices known
to be certified, which list shall be available for inspection at
the Community Development Officer.
2. All solid fuel burning devices shall be constructed, installed,
maintained and operated in such a manner that their operation will
result in an increase in heating energy, i.e. that the heat supplied
to the living area will be greater than that lost through air
exchange during combustion.
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-4-
8.23.040 Coal Usage Prohibited
The burning of coal is hereby prohibited within the Town of Vail.
8.28.050 Refuse Burning Prohibited
The burning of refuse in any solid fuel burning device is hereby prohibited
within the Town of Vail.
Section 2. If any part, section, subsection, sentence, clause or phrase of this
ordinance is for any reason held to be invalid, such decisions shall not affect
the vailidityof the remaining portions of this ordinance; and the Town Council
hereby declares it would have passed this ordinance, and each part, section,
subsection, sentence, clause or phrase thereof, regardless of the fact that
any one or more parts, sections, subsections, sentences, clauses or phrases
be declared invalid.
Section 3. The Town Council hereby finds, determines and declares that this
ordinance is necessary and proper for the health, safety and welfare of the
Town of Vail and the inhabitants thereof.
INTRODUCED, READ AND PASSED ON FIRST READING THIS £~££ day of
19S3, and a public hearir.g shall be held on this ordinance en ^zr/? &£> day
of C-k^^, , 1533, at 7:30 p.m. in the Council Char-bars of ths
Vail Tiunicipal Building, Vail, Colorado.
Ordered published in full this
Rod nay E. Slifer, Mayor ?*
4.
_
Pamela A. Brandfisyer 0
Town Clerk
INTRODUCED, READ AND ;?.-.= DVED CN SECC.'JD RE-DING AND ORDERED PUBLISHED
a^ -'is /?tU, ._-'V of
•V ?
o
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BEAVERCREEK, COLORADO
-------
Beavercreek Resort Company Regulations
3.12 Environmental Monitoring Function: The Resort Company may monitor
air and water quality in Beaver Creek to determine trends, to detect
violations of state pollution laws and may control and enforce fireplace
construction and utilization pursuant to regulations promulgated by the
Resort Company from time to time and in accordance with Declarant's
Mountain Development Plan as in effect from time to time, A copy of which
shall be kept in the offices of the Resort Company.
3.18 Right TO Make Rules and Regulations: The Resort Company shall be
authorized to and shall have the power to adopt, amend and enforce rules
and regulations applicable within Beaver Creek with respect to any Facility
or Function, and to implement the provisions of this Declaration, the
Articles of Incorporation or Bylaws of the Resort Company, including but
not limited to, rules and regulations to prevent or reduce fire hazard; to
prevent disorder and disturbances of the peace; to regulate pedestrian and
vehicular traffic; to regulate animals; to regulate signs; to regulate use
of any and all Facilities to assure fullest enjoyment of use by the persons
entitled to enjoy and use the same ; to promote the general health, safety
and welfare of persons within Beaver Creek; and to protect and preserve
property and property rights. All rules and regulations adopted by the
Resort Company shall be reasonable and shall be uniformly applied, except
such rules may differentiate between reasonable categories of Sites,
Owners, Leasees, Subowners, or Guests. The Resort Company may provide
for enforcement of any such rules and regulations through reasonable
and uniformly applied fines and penalties, through exclusion of violators
from Facilities or from enjoyment of any Functions, or otherwise. Each
Owner, Leasee, Subowner and Guest shall be obligated to and shall comply
-------
wich and abide by such rules and regulations and pay such fines or penalties
upon failure co comply with or abide by such rules and regulations and such
unpaid fines and penalties shall be enforceable in accordance with Section 5.4.
7.2 Land Use Restrictions; In addition to the restrictions found in this
Section VII, all or any portion of the Property to be sold or leased by
Declarant shall be further restricted in its use, density or design according
to one or more Supplemental Declarations of Land Use Restrictions for Beaver
Creek recorded with the Clerk and Recorder of Eagle County, Colorado, prior
to the time Declarant transfers or conveys any such Property to the Resort
Company or to any third party.
7.5 No JToxious or Offensive Activity: No noxious or offensive activity
shall be carried on upon any Property nor shall anything be done or placed
on any Property which is or may become a nuisance or cause any significant
embarrassment, disturbance or annoyance to others.
7.8 No Annoying Lights. Sounds or Odors: No light, shall be emitted from
any Property which is unreasonably bright or causes unreasonable glare; no
sound shall be emitted from any Property which is unreasonably loud or
annoying; and no odor shall be emitted from any Property which is noxious
or offensive to others.
7.13 Restriction on Fireplaces: Except as permitted in writing by the Review
Board there shall be no fireplaces in any Lodge or dwelling unit (as that term
is defined in the Master Plan). Each fireplace built shall have an outside
air intake and be provided with glass doors at the hearth except as other-
wise authorized in writing by the Review Board. No fireplace shall be
operated during periods of adverse meterological conditions or adverse air
-------
pollution conditions as determined by the Resort Company. There shall be
no fireplaces permitted in any building or structure other than chose
specifically set forth in this Section 7.13.
-------
REGARDING TlfE CGNTKOL
OF
FIIU-:PLACK UUKK ;.[•;<::
IN
iJEAVliK CRiiliK
Pursuar. c co the authority <',;• .rated ':•< Lii couLroi l"i rup l.'u:c tmrniiu' .m\l to •.•iv.u'.'o l.h.s r .ill
ownors, subuvyncr r; .-iiul ('.uci-Ci; of iie.'ivt::" (Ji'i-i.'l< -n.-ty «.-r, ji>y t.nc tisc «
-------
III. REGULATIO:!: '.-.'hen the fircp . .'.c:e piL-r Li;',iii. i :•. MC M va tori . r.iic
owner, .3 '.i b o '.-:: icr • '•' ,«.;•.•.•.::; fl is :>rr:h LI, i. Led fro::: scare i iv..», ,1 new
fire. If t'-.'j owner, subowuc:.- ur sucji: already h-us ,A rii'vi
burning in his firepl-ce .inu the pilot light is activated,
wh-2 swr.cr. subov/ner or guest is proii Liii^od i'^oui ...cidir.j; fu-i.
to chc i'lr*?.
RiiASUI!: F i rep ! >icu pilot; iij'.hu.s wLLl be.1 ;ic L iv.-ii:ud v.-Iicn , L:\
the juu'j'jir.on L ui u!\c Kcsorc Company or chc liable County
Hnvirotiinc!! t:.i I ii'j.i! '-I"1. Oi'Licot jr hi:; dc.s if;,n.'i Led rcprc:;:cii >:a CIVL .
CT.C! :.cv(>L o;' ;• -:ir L:' jui.iLO r.i.-ici.'.",' uo'.v.-on cr.i; i ••;) in L:II- ilc.r., .•
Creuk Air .Si-.u-J ^;; in u.^v.or i>C cxcmciini', cho Scaca Air
PolluCioii CoucroL Division'a allowable ccnccncra "i'.m.
IV. R£GUiJ\Tf.C)il: in i.!u- C-VCIM: Ui/i': ;i new (Tiro 1.5; s L.ifv'v.i i.n .;
firopliicc v.-liiLi? riu.-1 ' L::ep l.'co piloL 1 ij-hu Lr. L ;.;•,; ir.t-ti ,ji ,..,
existing L;Lrc in ;\ (. i r.--j' I ;icc L.i .uii: ex cin^u i.shcd v:i L:-. i.n L!:: . •.•
hours of Lho 1 Li-,hi Lii),; '.sf ciic !.';.rcp 1 ace pil.oL ligh:, ;:H Kc-.crL
Cotripany personnel .nay en cur ihc premises in which suei;
fireplace is locauca and uxcinguish che fire, and (b) a fine
shall be levied against chc owner, subowner and/or guesc oT
the dwelling unit or cu:«nierci«il space in which ci;c fireplace
is locnted in accordance with the I'ollowiny schedule:
1st offense wnrning
2nd offense $100
3rd offense ^250
4th offense $500
REASON: The Resort Company must ensure that the visitors and
residents of Oeaver Creek may enjoy the use of fireplaces
without violating the Colorado Air Pollution Control Division's
nir qunlity standards.
V. AMENDMENT; These regulations may be amended at any ci;nc by
the Resort Company's Board of Directors if such amendment is
approved by the Colorado Department of Health.
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State of Colorado
RWC Control Measures
-------
1984
HOUSE BILL NO. 1187.
BY REPRESENTATIVES Paulson, Allison, Bath, Bowen, Brown,
Dambman, Dunning, Fenlon, Fleming, Hernandez, Herzog, Knox,
Markert, Neale, Reeves, Robb, Skaggs, Taylor, and Wright;
also SENATORS Traylor, Glass, and Stewart.
CONCERNING THE CONTROL OF POLLUTION CAUSED BY WOOD STOVE
EMISSIONS, INCLUDING EMISSIONS FROM FIREPLACES, AND
MAKING AN APPROPRIATION THEREFOR.
Be H enacted by_ the General Assembly of the State of Colorado:
SECTION 1. Article 7 of title 25, Colorado Revised
Statutes, 1982 Repl. Vol., is amended BY THE ADDITION OF A
NEW PART to read:
PART 4
CONTROL OF POLLUTION CAUSED BY WOOD SMOKE
25-7-401. Legislative declaration. The general assembly
hereby declares that it is in the interest of the state to
control, reduce, and prevent air pollution caused by wood
smoke. It is therefore the intent of this part 4 to
significantly reduce particulate and carbon monoxide emissions
caused by burning wood by developing an evaluation and
certification program, in the department of health, for the
sale of wood stoves in Colorado and by encouraging the air
quality control commission to continue efforts to educate the
public about the effects of wood smoke and the desirability of
achieving reduced wood smoke emissions. The general assembly
hereby finds that it is beneficial to the state to implement a
program of voluntary no-burn days whenever the air quality
control division determines that the anticipated level of wood
smoke will or is likely to have an adverse impact on the air
quality in any nonattainment area in the state.
Capital letters indicate new material added to existing statutes;
dashes through words indicate deletions from existing statutes and
such material not part of act.
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25-7-402. Definitions. As used in this part 4, unless
the context otherwise requires:
(1) "Evaluate" means to review woodburning appliances'
emission levels, as determined by an independent testing
laboratory, and compare the emission levels to the emission
performance standards established by the commission under
section 25-7-403.
(2) "Fireplace" means a structure designed for the
burning of wood which is an integral part of the construction
of a building and which would commonly be considered a
fireplace.
(3) "Wood stove" means a wood-fired appliance, including
a fireplace insert, with a closed fire chamber which
maintains an air-to-fuel ratio of less than thirty during the
burning of ninety percent or more of the fuel mass consumed in
the low-firing cycle. The low-firing cycle means less than or
equal to twenty-five percent of the maximum burn rate achieved
with doors closed or the minimum burn rate achievable.
25-7-403. Commission - rule - making. (1) On or before
July 1, 1985, the commission shall promulgate rules and
regulations to carry out the provisions of this part 4 in
conformity with the provisions and procedures specified in
article 4 of title 24, C.R.S., and which shall become
effective only as provided in said article.
(2) (a) In promulgating such rules and regulations, the
commission shall:
(I) Set emission performance standards for new wood
stoves;
(II) Establish criteria and procedures for testing new
wood stoves for compliance with the emission performance
standards;
(III) Prescribe the form and content of the emission
performance label to be attached to a new wood stove meeting
the emission performance standards;
(IV) Establish procedures for administering the program
and for collecting fees for the certification of new wood
stoves;
(V) Establish fees for certifying new wood stoves at a
level such that said fees reflect the direct and indirect
costs of administering the program less any general fund or
federal grant moneys appropriated to cover the starjt-up costs
of the program; and
PAGE 2-HOUSE BILL NO. 1187
-------
(VI) tsUblish structural design specifications for
fireplaces to minimize emissions.
(b) The moneys collected under this subsection (2) shall
be transmitted to the state treasurer, who shall credit the
same to the stationary sources control fund established in
section 25-7-114 (5) (b). Any moneys not appropriated by the
general assembly shall be retained in the stationary sources
control fund and shall not revert to the general fund at the
end of any fiscal year.
25-7-404. Wood stove testing program established.
(1) There is hereby established, in the department of health,
an evaluation and certification program for the control of air
pollution caused by wood stove emissions, which is designed to
significantly reduce particulate and carbon monoxide
emissions, referred to in this part 4 as the "program".
(2) The program as implemented by rules and regulations
as set forth in section 25-7-403 shall be administered by the
air quality control division. The said division shall
establish a program that:
(a) Determines whether or not any new wood stove
complies with the emission performance standards set by the
commission when tested by an independent testing laboratory;
(b) If such new wood stove complies with the emission
performance standards, certifies such compliance.
(3) On or after July 1, 1985, a wood stove manufacturer
or dealer may request the air quality control division to
evaluate the emissions performance of any new wood stove.
(4) A new wood stove may be certified at the conclusion
of an evaluation and before January 1, 1987, if:
(a) The air quality control division finds that the
emission levels of the new wood stove comply with the emission
performance standards established by the commission; and
(b) The wood stove manufacturer or dealer submits the
fee established by the executive director of the department of
health pursuant to section 25-7-403.
25-7-405. Certification required for sale. (1) On or
after January 1, 1987, a person shall not advertise to sell,
offer to sell, or sell a new wood stove in Colorado unless:
(a) The particular model of wood stove or the particular
configuration' of wood stove appliance has been evaluated to
determine its emission performance and has been certified by
PAGE 3-HOUSE BILL NO. 1187
-------
the air quality control division under the program established
under this part 4; and
(b) An emission performance label is attached to the
wood stove.
25-7-406. Fireplace design program. The air pollution
control division shall establish a program to study the ways
that differences in the structural design of fireplaces affect
emissions. The objective of this program will be to determine
those structural designs of fireplaces which effectively
minimize emissions. The division shall conduct performance
tests of different fireplace designs to identify those designs
that minimize emissions.
25-7-407. Commission to establish design specifications
for fireplaces - compliance required. (1) Based on the
information supplied by the performance tests conducted by the
air pollution control division and on any other relevant
Information, the commission shall adopt by July 1, 1986, a set
of approved design specifications for the building of
fireplaces in Colorado.
(2) All fireplaces installed on or after July 1, 1987,
in any structure located in the state shall comply with the
approved design specifications established by the commission.
25-7-408. Required compliance in building codes.
(1) By July 1, 1987, every board of county commissioners of a
county which has enacted a building code, and thereafter every
board of county commissioners of a county which enacts a
building code, shall, pursuant to section 30-28-201 (2),
C.R.S., adopt a building code provision requiring any person
who constructs any fireplace to comply with the approved
design specifications for fireplaces.
(2) By July 1, 1987, every governing body of a
municipality which has enacted a building code, and thereafter
every governing body of a municipality which enacts a building
code, shall, pursuant to section 31-15-601 (2), C.R.S., adopt
a building code provision requiring any person who constructs
any fireplace to comply with the approved design
specifications for fireplaces.
(3) Nothing in this article shall prevent a board of
county commissioners or a governing body of a municipality
from enacting a building code which requires more stringent
standards for wood stoves and for fireplace design.
25-7-409. Voluntary no-burn days. Whenever the air
quality control division determines, after investigation, that
the level of wood stove emissions anticipated will -contribute
PAGE 4-HOUSE BILL NO. 1187
-------
adversely or is likely to have an adverse impact on the air
quality in any nonattainment area in the state, the comnission
should implement and announce a program of voluntary no-burn
days.
25-7-410. Applicability. The provisions of this part 4
do not apply to a used wood stove and shall not apply to any
fireplace constructed prior to July 1, 1987.
SECTION 2. 30-28-201, Colorado Revised Statutes, 1977
Repl. Vol., is amended to read:
30-28-201. Commissioners may adopt - emission standards
required. (1) A board of county commissioners is authorized
to adopt a building code in all or part of the county, and not
embraced within the limits of any incorporated city or town.
Such code shall provide for the regulation of the future
construction or alteration of dwellings, buildings, and
structures, together with plumbing and electrical
installations therein or in connection therewith. A structure
means a combination of roof and supporting walls and columns.
Buildings or structures used for the sole purpose of providing
shelter for agricultural implements, farm products, livestock,
or poultry may be excepted. The requirements shall be uniform
for each class of dwelling, building, or structure. The board
of county commissioners may employ qualified technical experts
to assist in the preparation of the text of the area building
code.
(2) BY JULY 1, 1987, EVERY BOARD OF COUNTY COMMISSIONERS
OF A COUNTY WHICH HAS ENACTED A BUILDING CODE, AND THEREAFTER
EVERY BOARD OF COUNTY COMMISSIONERS OF A COUNTY WHICH ENACTS A
BUILDING CODE, SHALL ENACT A BUILDING CODE PROVISION TO
REGULATE THE CONSTRUCTION AND INSTALLATION OF FIREPLACES IN
ORDER TO MINIMIZE EMISSION LEVELS. SUCH STANDARDS SHALL 8E
THE SAME AS OR STRICTER THAN THE APPROVED DESIGN
SPECIFICATIONS FOR FIREPLACES ESTABLISHED BY THE AIR QUALITY
CONTROL COMMISSION IN THE DEPARTMENT OF HEALTH PURSUANT TO
SECTION 25-7-407, C.R.S.
SECTION 3. 31-15-601, Colorado Revised Statutes, 1977
Repl. Vol., is amended BY THE ADDITION OF A NEW SUBSECTION to
read:
31-15-601. Building and fire regulations - emission
standards required. (2) By July 1, 1987, every governing
body of a municipality which has enacted a building code, and
thereafter every governing body which enacts a building code,
shall enact a building code provision to regulate the
construction and installation of fireplaces in order to
minimize emission levels. Such standards shall be the same as
or stricter than the approved design specifications for
PAGE 5-HOUSE BILL NO. 1187
-------
fireplaces established by the air quality control commission
in the department of health pursuant to section 25-7-407,
C.R.S.
SECTION 4. 25-7-114 (5) (b), Colorado Revised Statutes,
1982 Repl. Vol., is amended to read:
25-7-114. Air pollutant emission notices and emission
permits. (5) (b) A single fee shall be charged to any
applicant for any indirect source plan or plans submitted to
the division at any one time. A permit shall be deemed to run
with the land, and a new permit and additional permit fees may
be required only when, in the judgment of the commission,
plans for the indirect source have been substantially changed.
The moneys collected under this subsection (5) AND IN SECTION
25-7-403 shall be remitted to the state treasurer, who shall
credit the same to the stationary sources control fund, which
fund is hereby created. From such fund the general assembly
shall appropriate to the department of health, at least
annually, only such moneys as may be necessary to cover the
division's costs of processing, administration, and
enforcement described in this subsection (5), AND TO COVER THE
DIVISION'S COSTS OF DEVELOPING AND MAINTAINING AN EVALUATION
AND CERTIFICATION PROGRAM FOR THE CONTROL OF AIR POLLUTION
CAUSED BY WOOD STOVE EMISSIONS AND OF DEVELOPING AND
MAINTAINING A FIREPLACE DESIGN PROGRAM FOR THE CONTROL OF AIR
POLLUTION CAUSED BY FIREPLACE EMISSIONS. Any moneys not
appropriated by the general assembly shall be retained in the
stationary sources control fund and shall not revert to the
general fund at the end of any fiscal year.
SECTION 5. Appropriation. (1) In addition to any other
appropriation, there is hereby appropriated, out of any moneys
in the stationary sources control fund not otherwise
appropriated, to the department of health for allocation to
the air pollution control division, for the fiscal year
commencing July 1, 1984, the sum of forty-nine thousand three
hundred twenty-four dollars ($49,324) and 1.0 FTE, or so much
thereof as may be necessary, for the purposes of this act.
(2) In addition to any other appropriation, there is
hereby appropriated, to the department of health for
allocation to the air pollution control division, for the
fiscal year commencing July 1, 1984, the sum of seventy-five
thousand dollars ($75,000), for the purposes of this act.
Such moneys shall be from federal grant moneys.
SECTION 6. Safety clause. The general assembly hereby
PAGE 6-HOUSE BILL NO. 1187
-------
finds, determines, and declares that this act is necessary for
the immediate preservation of the public peace, health, and
safety.
B. Bledsoe
SPEAKER OF THE HOUSE
OF REPRESENTATIVES
Ted L. Strickland
PRESIDENT OF
THE SENATE
Cprraine f.\Lomoandl
CHIEF CLERK OF THE HOUSE
OF REPRESENTATIVES
Marjorie L. Nielson
SECRETARY OF
THE SENATE
APPROVED
nhn.[\
1-
- ao
•1
RTfch
GOVE
rd 0. Lamm
tNOR OF THE STATE OF COLORADO
PAGE 7-HOUSE BILL NO. 1187
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COLORADO
AIR QUALITY DEPARTMENT OF HEALTH
CONTROL 4210 E.I1TH AVENUE
COMMISSION
NOTICE OF PUBLIC HEARING
TO CONSIDER A NEW REGULATION
OF THE COLORADO AIR QUALITY CONTROL COMMISSION
TO BE HELD BEFORE THE COLORADO AIR QUALITY CONTROL COMMISSION
Notice of Public Hearing;
Pursuant to the notice requirements of Colorado Revised Statute 24-4-103,
and 25-7-110 and the Procedural Rules for Activities of the Air Quality
Control Commission, hereinafter the "Procedural Rules," and in accord with
the notice provisions of 40 CFR 51.4 NOTICE is hereby given that the Colorado
Air Quality Control Commission will conduct a public rulemaking hearing at
the time and place and on the subject matter set forth in this notice. The
proceeding may be continued at such places and times as the Commission may
announce.
DATE: May 9, 1985
TIME: 9:30 a.m.
SUBJECT: New Regulation No. 4, "A Regulation Concerning
the Sale of New Wood Stoves"
PLACE: Room 412, Colorado Department of Health
4210 East llth Avenue
Denver, Colorado
Preamble:
The Colorado Air Quality Control Commission will hold a hearing to consider
the views of the public regarding the proposed adoption of a New Regulation
No. 4 - "A Regulation Concerning the Sale of New Wood Stoves".
The regulation would require that new wood stoves may not be sold, offered
for sale, or advertised for sale on or after January 1, 1987 unless stoves
meet emission standards for carbon monoxide and particulates.
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The regulation would also establish a system for State approval of
laboratories qualified to determine whether a stove meets the emission
standards. In particular, the regulation would establish the following
with regard to the sale of new wood stoves after January 1, 1987:
definitions of specific terms; requirements for sale of wood stoves;
reciprocal approval agreement; certification procedure; emissions stand-
ards; quality control and testing requirements; labeling requirements;
independent laboratory accreditation procedures; laboratory inspection
procedures and accreditation criteria; enforcement provisions; and a list
of certified stoves compiled by the Division. These sections are com-
prehensive in nature covering all aspects of an approval and certification
program for new wood stoves which must be met for any new stove sold after
January 1, 1987.
Concern about the increase of residential wood burning has been mounting
since the mid-1970's. Recent studies conducted by several investigators have
demonstrated the contribution of emissions from woodburning as a significant
part of the "Brown Cloud" in the Denver Metropolitan area and in many
locations throughout Colorado such as small mountain communities and ski
resorts. In addition to the visual impact of emissions from wood stoves is
the concern about carbon monoxide and fine particulate emissions each of
which has the potential to affect human health.
The Commission, in adopting this proposed regulation for the control of
new wood stoves, sees the regulations as a first step in resolving some of
the important concerns expressed about air pollution from this source. In
addition, the Commission has been advised that stoves meeting the requirements
of this regulation may offer a cost incentive to the owners of these stoves
through a savings in fuel costs due to greater heating efficiency which will
be a consequence of the designs needed in order to meet these emission require-
ments.
The proposed regulation is attached to and made a part of this Notice for
the convenience of the public, and has been published in the Colorado Register
of March 10, 1985. Additional copies are available upon request from the
Commission's office at the address stated in this notice.
Issues of Particular Concern:
The Commission is especially interested in receiving comments and infor-
mation from the public on the following issues:
1. Emission Standards - Several questions concerning the standards
will be under discussion. These include: should the standard
be technology forcing; should there be different standards for
catalytic and non-catalytic stoves; what should the units of
the standards be (e.g., grams per hour or pounds per million
BTU); what is the cost effectiveness of the standards, and
should there be a sliding scale for stoves of over 40,000 BTU
per hour heat output?
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2. Test procedures to be used to determine certification. Comments
are especially solicited regarding loading densities to be used
in conducting tests. Comments are solicited regarding benefits
and/or disadvantages of the Oregon OM-7 vs. the proposed ASTM
Testing Methods.
3. Fees to be charged for the administration of the program, includ-
ing both primary and reciprocal certification and design changes.
4. Control of sales of wood stoves other than through retail and
wholesale outlets located in Colorado; (i.e. mail order catalogues,
magazine advertisements, direct mail advertisements, etc.
5. Should the label affixed to the wood stove be required to contain
the heating efficiency of the particular wood stove.
6. Should the regulation be expanded to include any appliance which
can burn solid fuel; i.e., wood, coal, paper logs, etc..
Public Views Encouraged:
The Commission encourages all interested persons to provide their
views on the proposed Regulation No. 4, concerning the sale of new wood
stoves either in writing by mail, or by making oral comments, or submit-
ting written comments at the hearing. The Commission encourages
comments and analyses from persons who will incur directly some cost
or receive some benefit from the proposed regulations as well as the
participation of the general public.
Persons who wish to submit written comments should mail them to the
following person by the date of the hearing:
Mr. Joseph Palomba, Jr., Technical Secretary
Colorado Air Quality Control Commission
4210 East llth Avenue
Denver, Colorado 80220
For additional information, please call Mr. Palomba at 331-8596.
Authority for the Commission's Actions:
The authority under which the Commission shall hold and conduct said
hearing is prescribed by C.R.S. 24-4-103, 25-7-105, -106, -110, and -403,
and the hearing will be conducted in accord with provisions of C.R.S.
24-4-103 and 25-7-110, the Procedural Rules, and as otherwise stated in
this notice. This list of authority is not intended to be exhaustive. It
is furnished for convenience of the public only.
(iii)
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Public Comment:
All persons are encouraged to present their views at this hearing.
In the interest and the convenience of the public, the Commission will
try to take public testimony beginning as close to 9:30 a.m. on May 9,
1985 as possible, and also from time to time during the remainder of the
hearing. (Members of the public are encouraged to call the Commission's
office at 331-8597 for information concerning the progress of the hear-
ing). The Commission requests, but does not require, that written copies
of expected testimony also be submitted to allow review by Commissioners
prior to oral presentation at the hearing. All such written submissions
should be mailed to the Technical Secretary, Air Quality Control Commis-
sion, at the above-stated address, before the scheduled date for hearing.
The Commission expressly reserves the right to limit or exclude unduly
repetitious, irrelevant, or incompetent evidence during these proceedings.
Obtaining the Right to Cross-Examination at the Hearing; Pre-hearing
Conference:
A. In order to have the right of cross-examination at this hearing, a
member of the public will be required to comply with several require-
ments, as set forth below:
1. As of Right:
Any person proposing a regulation differing from the
Commission's regulation shall have the right to cross-
examine witnesses if fifteen (15) copies of the differing
regulation are filed with the Commission not less than
twenty (20) days prior to the hearing (5:00 p.m., April
19, 1985). The differing regulation shall be open for
public inspection at the Commission office.
2. In the Commission's Discretion:
The Commission may grant to any person the right of
cross-examination if that person has submitted an appli-
cation requesting that right at least twenty (20) days
prior to the hearing (5:00 p.m., April 19, 1985). Such
application shall include a description of the person's
interest in the hearing, name, address, and telephone
number. Applications filed less than twenty (20) days
prior to the hearing shall not be considered except upon
motion for good cause shown.
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3. Pre-hearlng Conference:
A pre-hearing conference, if requested, will be held at
9:30 a.m., April 25, 1985, Colorado Department of Health,
Bridge Conference Room, 3rd floor, Ptarmigan Building located
at 3773 North Cherry Creek Drive (at South Colorado Boulevard),
Denver, Colorado. At any such conference, exhibits and
pre-hearing statements will be exchanged among the parties
(and party applicants) and fifteen (15) copies of each exhibit
and statement will be tendered to the Commission. All pre-
hearing motions also must be presented at the pre-hearing
conference. Persons who have applied for the right of cross-
examination twenty (20) days prior to the hearing shall
receive written notice if a prehearing conference is requested.
Failure to participate in the pre-hearing conference will
result in denial of the right of cross-examination.
B. Pursuant to Rule V.E.5. of the Procedural Rules, the Air Pollution Control
Division has elected to exercise the right of cross-examination at the
hearing.
Delegation of Authority:
For purposes of this hearing, Commissioner Melvyn C. Branch has been
designated by the Commission to perform the following functions (under
C.R.S. 24-4-103(13), as amended): sign and issue subpoenas, fix the time
of filing of documents (other than those described in this notice), approve
depositions, and issue appropriate orders.
Wood Stove Subcommittee:
In developing the proposed regulation, the Commission has been assisted
by a subcommittee chaired by Commissioner Branch. The subcommittee may
convene again prior to the rulemaking hearing. Any person desiring to receive
notice of subcommittee meetings may file a request for such notice with
Mr. Joseph Palomba, Jr., Technical Secretary, Air Quality Control Commission,
4210 East llth Avenue, Denver, Colorado 80220.
When the record will close and availability of proceedings:
The record of these proceedings may, at the discretion of the Commission,
remain open for up to ten (10) days after the scheduled hearing is adjourned.
The Commission will consider and make a part of that record all evidence,
sworn testimony, and written submissions on the aforementioned regulations
presented at these public hearings as well as any related matters properly
submitted before the record of these proceedings is closed. A full and
complete transcript of the proceedings shall be made and a copy thereof will
be available to any person making request and paying the reporter's fee therefor,
In addition, the Commission may make a reasonable charge to supply copies of
any written submission or other material related to these hearings.
(v)
-------
Minutes of general meetings and other records of the Air Quality
Control Commission are always available for public inspection during the
hours of 8:30 a.m. to 5:00 p.m., Monday through Friday, (holidays
excepted) in the office of the Technical Secretary, Colorado Air
Quality Control Commission, located in the West Tower, 3rd floor of
the Ptarmigan Building, 3773 North Cherry Creek Drive (at South Colorado
Boulevard), Denver, Colorado.
The Commission shall deliberate upon the evidence and testimony
collected at these hearings and reach a determination with all deliberate
speed and in accord with the spirit and directives of the Colorado Air
Quality Control Act.
COLORADO AIR QUALITY CONTROL COMMISSION
Secretary
DATED: February 28, 1985
(vi)
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PROPOSED
NEW REGULATION NO. 4
WOOD STOVE REGULATION
Colorado Air Quality Control Commission
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TABLE OF CONTENTS
SECTION NO. AND TITLE PAGE
I. Definitions 1
II. Requirements for Sale of Wood Stoves 2
III. Reciprocal Approval Agreement 2
IV. Certification Procedure 2
V. Emissions Standards, Qunlity Control and Testing 4
VI. Labeling Requirements 9
VII. Changes in Wood Stove from Wood Stoves Tested for
Certification 12
VIII. Laboratory Accreditation Procedures 13
IX. Laboratory Inspection 15
X. Accreditation Criteria 16
XI. Enforcement 18
XII. List of Certified Wood Stoves 20
APPENDIX A - Standard Method for Measuring the Emissions and
Efficiencies of Wood Stoves 21
Attachment 1 - State of Oregon
Sampling Method 4
Attachment 2 - State of Oregon
Sampling Method 5
Attachment 3 - State of Oregon
Sampling Method 7
(with Table I, "Comparison of
Calorimeter Room Method vs.
Stack Loss Method")
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PROPOSED
REGULATIOK ON SALE OF NEW WOODSTOVES
I. DEFINITIONS
A. Unless otherwise required by the context, as used in
this regulation:
1. "Accredited laboratory" means an independent
testing laboratory which has obtained either primary accredita-
tion or reciprocal accredation.
2. "Catalyst-equipped wood stove" means a wood
stove with a catalytic combustor that is an integral component of
the stove.
3. "Certified wood stove" means a wood stove which
is a unit of a wood stove model, or which contains a configura-
tion of appliance, for which either primary certification or re-
ciprocal certification has been granted.
4. "Dealer" means a person who sells wood stoves
on a regular basis.
5. "Fixed air supply" means an air supply system
on a wood stove which has no adjustable or controllable air
inlets.
6. "Heat output" means the amount of heat in BTU
per hour generated by a wood stove during one test run.
7. "Manufacturer" means a person who constructs a
wood stove or parts for wood stoves.
8. "Model" means a group of wood stoves which are
identical to one another regarding design, emissions, and heating
performance.
9. "New wood stove" means any wood stove other
than one which has been previously sold to an individual for his
personal use.
10. "Standard method" means the applicable testing
procedures and criteria set forth in "Standard Methods for Mea-
suring the Emissions and Efficiencies of Residential Wood
Stoves," set forth in Appendix A.
11. "Wood stove" means a wood-fired appliance, in-
cluding a fireplace insert, with a closed fire chamber which
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maintains an air-to-fuel ratio of less than 30 during the burning
of 90 percent or more of the fuel mass consumed in the low-firing
cycle. The low-firing cycle means less than or equal to 25 per-
cent of the maximum burn rate achieved with doors closed or the
minimum burn rate achievable.
II. REQUIREMENTS FOR SALE OF WOOD STOVES
A. On or after January 1, 1987, no person shall adver-
tise to sell, offer to sell, or sell a new wood stove unless it
is a certified wood stove that meets the requirements of section
VI. at the time it is sold.
B. Following the certification of a wood stove no person
shall alter the emissions plate or the compliance certificate
submitted to the Division as part of an application for certifi-
cation.
III. RECIPROCAL APPROVAL AGREEMENT
A. The Division may enter into a reciprocal approval
agreement with another state, provided the Division determines
that the other state has established a program regulating the
sale of wood stoves which is at least as stringent as the program
established by this regulation.
B. The reciprocal approval agreement shall include, but
not be limited to, the following provisions:
1. The Division shall consider the other state's
approval for sale of a wood stove as evidence that the stove
should be certified.
2. The Division shall consider the other state's
approval of the use of test results produced by a laboratory as
evidence that the laboratory should be accredited.
3. The other state shall establish a procedure for
notifying the Division of any suspension or revocation of its ap-
proval for sale of a wood stove, and of any design changes in
wood stoves subject to the other state's regulatory program.
IV. CERTIFICATION PROCEDURE
A. On or after July 1, 1985 a dealer or manufacturer may
apply to the Division for primary certification or reciprocal
certification of a wood stove model or appliance configuration.
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B. An application for primary certification shall in-
clude the following:
1. An appliance description which includes the
wood stove model name and design number, a copy of the stove's
operating manual and a photograph of the stove;
2. Design plans of the wood stove, identified by
design number, which include overall dimensions of the stove and
all dimensions and specifications of components critical to emis-
sions control and heating efficiency. These components shall in-
clude combustion chamber configurations, all air inlet controls,
heat exchanger design and make and model numbers of applicable
purchased parts.
3. Either a proof copy of the emissions plate
printed on a representative sample of the plate stock, or a proof
copy of the plate and a sample of the plate stock. The copy sub-
mitted shall show all information required pursuant to section
VI.
4. A proof copy of the compliance certificate con-
taining all information required on the certificate pursuant to
section VI;
5. All test data and support documentation showing
that the wood stove has been tested in accordance with section V
and that it meets the emissions performance standards of that
section;
6. A drawing, diagram or photograph that identi-
fies the location of the emissions plate on the wood stove.
C. An application for reciprocal certification shall
contain documentation demonstrating that the applicant's wood
stove has been approved for sale by another state with which the
Division has a reciprocal approval agreement. The application
shall contain the information required by section IV.B. for an
application for primary certification, except that the data re-
quired by section IV.B.5 may be summarized rather than submitted
in total.
D. Within 20 working days after receipt of an applica-
tion for primary certification or reciprocal certification, the
Division shall notify the applicant if the application is com-
plete. Within 40 working days after receipt of a complete appli-
cation for primary certification, or within 15 working days after
receipt of a complete application for reciprocal certification,
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the Division shall notify the applicant whether the application
satisfies all requirements for certification other than the pay-
ment of a certification fee, and of the amount of the fee re-
quired pursuant to section IV.F. If all other requirements have
been met, the Division shall issue a certificate granting certi-
fication upon receipt of the fee.
E. The Division shall grant certification if:
1. The applicant submits all information required
by section IV.B or section IV.C., as applicable, and that infor-
mation demonstrates that the wood stove model or configuration of
appliance meets the requirements of this regulation; and
2. The applicant pays the fee required pursuant to
section IV.F.
F. Applicants for certification shall pay a fee to the
Division at a rate of $ 64.00 per hour for each hour of Division
staff time spent evaluating an application. The applicant shall
pay the fee regardless of whether his application is withdrawn,
denied or approved. No certification shall be granted until the
certification fee is received by the Division.
G. If the Division denies certification, the Division
shall notify the applicant in writing of the opportunity for a
hearing before the Commission pursuant to section 24-4-104(9),
C.R.S. (1982).
V. EMISSIONS STANDARDS, QUALITY CONTROL AND TESTING
A. No new wood stove with a minimum heat output of
40,000 BTU per hour or less shall be advertised for sale, offered
for sale, or sold, on or after January 1, 1987, unless the stove
does not exceed the following weighted average particulate or
carbon monoxide emissions standards:
1. Wood stoves that are not catalyst equipped
shall emit less than 9 grams per hour of particulates and less
than 150 grams per hour of carbon monoxide when the stove is
tested prior to certification.
2. Catalyst equipped wood stoves shall either
(a) Emit less than 4 grams per hour of
particulates and less than 50 grams per hour of carbon monoxide
when they are tested prior to certification, or
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(b) Emit, during the usable life of the stove,
an average of less than 9 grams per hour of particulates and an
average of less than 150 grams per hour of carbon monoxide.
B. No new wood stove with a minimum heat output of more
than 40,000 BTU per hour shall be advertised for sale, offered
for sale, or sold on or after January 1, 1987, unless the stove
does not exceed a weighted average particulate emission standard
equal to the sum'of 8 grams per hour plus 0.2 grams per hour for
each 1,000 BTU per hour heat output.
C. The weighted average shall be calculated by initially
determining the unweighted average in accord with the applicable
standard methods, and then applying the following equation:
t* T- j-f C J.ITT 4- If TT
K 1 C. 1 "*" f^r\ C-n * *»O*-»i • • • T "^^n
a : 22 3 3 nn (£ON> 1}
where: E is the weighted average particulate or carbon
monoxide emission rate in grams per hour;Ej ,E2,E3, . . .Enare the
unweighted emission rates from test runs 1 through n in order of
increasing heat output, and K-J , Ko, K3, . ..Kn are the weighting
factors for test runs 1 through n." The weighting factors(Ki) are
calculated as follows:
Ki
where Pj_ is the cumulative probability from table 1 for
the heat output measured during each test run, P =0 and P =1
o • **
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If the cumulative probability for a given heat output is not
stated in table 1, the probability shall be interpolated from
that table.
TABLE 1
CUMULATIVE PROBABILITY FOR A GIVEN HEAT OUTPUT
DEMAND BASED ON COLORADO CLIMATE (POPULATION WEIGHTED)
Heat Output
(BTU/hour)
0
525
1050
1575
2100
2625
3150
3675
4200
4725
5250
5775
6300
6825
7350
7875
8400
8925
9450
9975
10,500
11,025
11,550
12,075
12,600
13,125
13,650
14,175
14,700
15,225
15,750
16,275
16,800
17,325
17,850
18,375
Cumulative
Probability (P)
0.0510
0.0584
0.0655
0.0731
0.0815
0.0902
0.1014
0.1111
0.1224
0.1344
0.1459
0.1615
0.1746
0.1892
0.2044
0.2193
0,2401
0.2571
0.2765
0.2954
0.3145
0.3384
0.3598
0.3826
0.4063
0.4269
0.4544
0.4777
0.5027
0.5277
0.5512
0.5812
0.6071
0.6328
0.6619
0.6849
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18,900 0.7156
19,425 0.7384
19,950 0.7626
20,475 0.7838
21,000 0.8023
21,525 0.8239
22,050 0.8404
22,575 0.8556
23,100 0.8699
23,625 0.8823
24,150 0.8961
24,675 0.9058
25,200 0.9152
25,725 0.9233
26,250 0.9305
26,775 0.9381
27,500 0.9440
27,825 0.9497
28,350 0.9550
28,875 0.9591
29,400 0.9635
29,925 0.9674
30,450 0.9707
30,975 0.9741
31,500 0.9770
32,025 0.9800
32,550 0.9826
33,075 0.9846
33,600 0.9866
34,125 0.9883
34,650 0.9900
35,175 0.9914
35,700 0.9925
36,225 0.9936
36,750 0.9946
37,275 0.9958
37,800 0.9964
38,325 0.9971
38,850 0.9976
39,375 0.9981
39,000 0.9984
40,425 0.9986
40.950 0.9988
41,475 0.9990
42,000 0.9991
42,325 0.9993
43,050 0.9994
43,575 0.9994
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44,100 0.9995
44,625 0.9996
45,150 0.9997
45,675 0.9997
46,200 0.9998
46,725 0.9998
47,250 0.9999
47,775 1.0000
48,300 1.0000
D. The weighted average net efficiency referred to in _
section VI.E.3. shall be calculated using EQN 1 above where: E
is the weighted average net efficiency in percent and Ei,E2iE3, ...En
are the unweighted efficiencies from test runs 1 through n in
order of increasing heat output, and Kl» K2> K3» •••^n are the
weighting factors for test runs 1 through n. The weighting fac-
tors Ki are calculated as follows:
Ki = "
where Pi is the cumulative probability from table 1 for
the heat output measured during each test run,P0=0, and Pn+1 =
If the cumulative probability for a given heat output is not
stated in table 1, the probability shall be interpolated from
that table.
E. To ensure quality control for a certified wood stove
model or appliance configuration, it shall be a condition of cer-
tification that the manufacturer of the model of configuration is
inspected at least twice per year by representatives of an ac-
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credited laboratory and that such inspections demonstrate that
units of the wood stove model or appliance configuration are con-
structed in accord with the requirements of this regulation.
Such inspections shall be performed without notice to the manu-
facturer, and the results of such inspections shall be reported
to the Division within 90 days.
F. All testing required by this regulation shall be con-
ducted by an accredited laboratory.
G. All testing required by this regulation shall be per-
formed in strict conformance with the applicable standard method,
unless, prior to the commencement of such testing, the Division
has approved in writing a minor variation from the applicable
standard method, on the grounds that the variation will not af-
fect the accuracy of the testing.
VI. LABELING REQUIREMENTS
A. On or after January 1, 1987 no person shall advertise
to sell, offer to sell, or sell a new wood stove without a label,
composed of the emissions plate and the compliance certificate
described in this section. The emissions plate shall be affixed
to the stove. The compliance certificate shall be affixed either
to the stove or to a carton containing the stove.
B. The emissions plate shall contain the following in-
formation:
1. Name of testing laboratory;
2. Date that wood stove model or appliance config-
uration was tested;
3. Test procedure used;
4. Name of manufacturer;
5. Name of model;
6. Design number of model;
7. The following statement: "Performance may vary
from test values depending on actual home operating conditions."
8. A graph meeting the following specifications --
a. The graph shall show the unweighted par-
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ticulate emissions rate, in grams per hour, and the unweighted
net efficiency, over the range of heat outputs tested.
b. The axes of the graph shall be labeled as
follows:
(i) Vertical axis, left side: "Smoke-
grams/hour," with a scale of 0 to 20, bottom to top.
(ii) Vertical axis, right side:
"Efficiency-percent," with a scale of 50 to 90, bottom to top.
(iii) Horizontal axis, bottom: "Heat
output-BTU/hour," with a scale from 0 to a maximum of 5,000 BTU
per hour higher than the highest tested heat output.
c. Curves describing unweighted emissions
and net efficiency at various heat outputs shall be printed on
the graph, and shall be developed by the testing laboratory as
follows:
(i) The emissions curve shall be devel-
oped by fitting the particulate emissions test data to a least
squares multiple regression for the following second degree
polynomial: , ^2
* y = ao + alX + a2x
where; y = unweighted particulate emissions (grams/hour)
x = heat output (Btu/hour)
ao al» a2 = regression coefficients
(ii) The net efficiency curve shall be
developed by fitting the efficiency test data to a least squares
multiple regression for the following second degree polynomial:
y = ao + axx + a2x2
where; y _ unweighted net efficiency (%)
x = heat output (Btu/hour)
ao, al' a2 = regression coefficients
(iii) For wood stoves with a fixed air
supply which have only two data points for particulate emissions
and two data points for net efficiency, the testing laboratory
shall develop the particulate emissions curve by connecting the
emissions data points with a straight line, and the net efficien-
cy performance curve by connecting the two efficiency data points
with a straight line.
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d. The curves shall be developed and fit onto the
graph by the testing laboratory and transmitted to the wood stove
manufacturer for printing on the emissions plate.
C. The emissions plate shall be:
1. Permanent, so that it cannot be removed from
the wood stove without damage to the plate;
2. Made of aluminum, brass, galvanized steel, or
other metal, and of a thickness that will ensure the permanence
of the plate;
3. Riveted, screwed, bolted, or otherwise perma-
nently secured to the stove;
4. Legible, and shall contain information which
has been applied by etching, silk screening, die stamping or some
other process which ensures legibility;
5. Located on any visible exterior surface except
the bottom of the stove, or on any interior surface of the stove
if the plate can be seen after installation of the stove.
D. The emissions plate shall be at least 3 1/2 inches
long by 2 inches wide. The graph on the plate shall be at least
3 inches long by 1 1/2 inches wide and any enlargement of the
graph shall maintain a length to width ratio of 2:1. The emis-
sions plate may be combined with another label, such as a safety
label, if the design and integrity of the emissions plate is not
compromised, and if the combination label is approved in writing
by the Division.
E. The compliance certificate shall contain the follow-
ing information:
1. "Smoke (Avg.) grams/hour," weighted average
of tested values;
2. "Carbon monoxide (Avg.) grams/hour,"
weighted average of tested values;
3. "Efficiency (Avg.) %," weighted average of
tested values;
4. A statement of the applicable emissions stan-
dards;
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5. The heat output range of the stove and the val-
ues at which the stove was tested;
6. Name of manufacturer;
7. Name of model;
8. Design number of model;
9. A statement that the wood stove has been certi-
fied;
10. The following statement: "Performance may vary
from test values depending on actual home operating conditions."
F. The information to be placed in the compliance cer-
tificate shall be developed by the testing laboratory, and trans-
mitted to the manufacturer, who shall then print the compliance
certificate. The compliance certificate may not be combined with
any other information, and shall be given to the purchaser of the
wood stove.
VII. CHANGES IN WOOD STOVE FROM STOVES TESTED FOR CERTIFICATION
A. Where primary certification has been granted for a
wood stove model or configuration of appliance, individual stoves
of that model or configuration shall not be considered certified
if their construction or design differs in any way from that of
the stoves tested by an accredited laboratory for the purpose of
obtaining certification, unless Division approval is obtained
through the following procedure:
1. Prior to implementing any modification in the
design or construction of any model or configuration of appli-
ance, the manufacturer shall inform an accredited laboratory of
the proposed modification. The laboratory shall then inform the
Division in writing whether the proposed modification would af-
fect the emissions rate of the model or configuration, and of the
basis for its conclusion. The Division shall review the
laboratory's conclusion, and within 15 working days of receipt
thereof shall notify the laboratory and the manufacturer in writ-
ing whether the Division has determined that the modification may
affect the emissions rate.
2. If the Division determines that the modifica-
tion will not affect the emissions rate, that determination shall
constitute approval of the sale of the wood stove with the modi-
fication.
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3. If the Division determines that the modifica-
tion may affect the emissions rate, it shall also prescribe addi-
tional tests which the laboratory must perform on the wood stove
with the modification. The laboratory shall report the test re-
sults to the Division, and the Division shall assess the wood
stove manufacturer a fee of $ 64.00 for each hour of Division
staff time spent evaluating the results. The manufacturer shall
pay the fee regardless of whether the Division approves or disap-
proves sale of the wood stove as modified.
4. Within 15 working days after receipt of the re-
sults of the tests, the Division shall notify the manufacturer
and the laboratory whether it approves of the sale of the wood
stove with the proposed modification. The wood stove, with the
modification, shall be considered certified only if approval is
granted.
B. Where reciprocal certification has been granted for a
wood stove model or configuration of appliance, individual stoves
of that model or configuration shall not be considered certified
if their construction or design differs in any way from that of
the stoves originally approved by the state with which the Divi-
sion has a reciprocal approval agreement, unless the state has
notified the Division in writing that it has approved of the sale
of the stoves as modified.
VIII. LABORATORY ACCREDITATION PROCEDURES
A. A laboratory may apply to the Division for primary
accreditation or reciprocal accreditation.
B. The following procedures shall apply to applications
for reciprocal accreditation:
1. An application for reciprocal accreditation
shall contain the following —
a. A brief description of the organization,
facilities, and personnel structure of the applicant;
b. Documentation demonstrating that a state
with which the Division has a reciprocal approval agreement has
approved the use of test results produced by the applicant as a
means of complying with the state program regulating the sale of
wood stoves.
2. Within 20 working days after receipt of a com-
plete application for reciprocal accreditation the Division shall
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notify the applicant whether reciprocal accreditation has been
granted or denied. If it is granted, the Division shall issue to
the applicant a certificate of reciprocal accreditation, which
shall remain valid as long as the applicant is considered an ap-
proved laboratory for wood stove testing by the state with which
the Division has a reciprocal approval agreement.
C. The following procedures shall apply to applications
for primary accreditation:
1. An application for primary accreditation shall
contain all information necessary to demonstrate that the appli-
cant complies with the criteria of section X.
2. Within 20 working days after receipt of an ap-
plication, the Division shall inform the applicant whether the
application is complete, and, if is not, of the deficiencies in
the application. An application shall be considered withdrawn if
the deficiencies have not been eliminated within 90 days after
the Division issues its completeness determination.
3. Within 30 days after the submission of a com-
plete application, the Division shall conduct an on-site inspec-
tion of the laboratory pursuant to section IX.
4. Within 30 days after the Division has completed
the on-site inspection and received all data required to be sub-
mitted pursuant to section IX., the Division shall notify the ap-
plicant of any facts or conditions which indicate that the appli-
cant does not meet the criteria for accreditation of section X.
5. Within 30 days after receipt of the notifica-
tion issued by the Division pursuant to section VIII.C.4., the
applicant shall inform the Division in writing of any measures it
has taken to correct any deficiencies noted by the Division. The
Division may then conduct further on-site inspections, and re-
quire the performance of additional tests at the laboratory, to
determine whether the corrective action necessary for the grant-
ing of accredation has been performed.
6. The Division shall determine whether to grant
or deny accreditation based on the criteria set forth in section
X. If accreditation is granted, the Division shall issue a cer-
tificate of primary accreditation to the applicant. Each certif-
icate of primary accreditation shall be valid for three years.
D. During each three-year period that a laboratory holds
a certificate of primary accreditation, the Division shall audit
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test at least one stove tested by the laboratory to verify the
laboratory's test results. The Division shall notify the labora-
tory of any errors or deficiencies in testing indicated by the
audit test. The laboratory shall then inform the Division in
writing within 30 days of the measures it has taken to correct
the errors or deficiencies. Failure to correct the deficiencies
shall be grounds for revocation of accreditation.
E. A laboratory may voluntarily terminate its accredita-
tion by written request at any time. The laboratory shall return
the certificate of accreditation with the request.
IX. LABORATORY INSPECTION
A. Following the submission of a complete application
for primary accreditation, the Division shall inspect the appli-
cant's laboratory.
B. During the inspection, a representative of the Divi-
sion shall:
1. Observe the testing demonstration required by
section IX.C., and discuss test procedures with laboratory per-
sonnel;
2. Meet with management and supervisory personnel
responsible for wood stove testing;
3. Review representative samples of laboratory
records, including records related to the competence of each lab-
oratory staff member who performs wood stove testing. The appli-
cant shall furnish the Division with a list of the names of all
such staff members,
4. Examine selected equipment and apparatuses;
5. Discuss with laboratory personnel, at the end
of the inspection, any deficiencies in the laboratory's proce-
dures or operations.
C. During each inspection, laboratory personnel shall
perform a wood stove emissions rate and heating efficiency test,
in accord with the requirements of the standard methods, on a
stove furnished by the Division. The applicant for accreditation
shall pay the costs for stove shipping and for catalytic
combustors or other required parts. The applicant shall submit
the test results and observations to the Division, for the pur-
pose of enabling the Division to evaluate the applicant's ability
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to perform tests and report test results in accord with this reg-
ulation.
X. ACCREDITATION CRITERIA
A. A laboratory shall meet the criteria and standards of
subsections B through J of this section in order to obtain pri-
mary accreditation, and shall continue to meet these criteria and
standards as a condition of maintaining such accreditation.
B. The laboratory shall be an independent third-party
testing organization with no financial, organizational, or mana-
gerial affiliation with any manufacturer or dealer, in accord
with the following:
1. No officer, director, stockholder, or employee
of the laboratory shall be engaged in the sale or manufacture of
wood stoves, nor shall any such person hold any financial inter-
est in, or be employed by, any manufacturer or dealer.
2. The laboratory shall not be engaged in the pro-
motion or design of any wood stove which it tests.
3. The laboratory shall have a diverse group of
clients, or shall be engaged in activities other than wood stove
testing, to the extent necessary to demonstrate that the loss or
award of a specific contract for testing would not be a determi-
native factor in the financial well being of the laboratory.
4. The employment security of laboratory personnel
shall not be subject to the influence of any manufacturer or
dealer.
C. The laboratory shall be operated in accord with gen-
erally accepted professional and ethical standards, including,
but not limited to, the following:
1. The laboratory shall accurately report values
that reflect measured data.
2. The laboratory shall undertake only testing
which it is competent to perform.
3. The laboratory shall immediately respond to,
and attempt to resolve, any complaint it receives from the Divi-
sion regarding testing results.
D. The laboratory shall employ personnel competent to
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perform the testing for which accreditation is sought. On an an-
nual basis, the laboratory shall require each of its employees
who performs wood stove testing to pass an examination on testing
procedures, or to perform satisfactorily the work for which he is
normally responsible, while being observed by supervisory or man-
agerial personnel. The laboratory shall also develop a program
to train new employees in proper testing procedures, and shall
make available to the Division a written description of that pro-
gram.
E. The laboratory shall employ field inspectors who are
adequately trained to perform the quality control inspections re-
quired for certification by section V.E. Such inspectors shall
be trained to make selections of materials for testing from manu-
facturers' stock or from distributors' establishments, and to
evaluate manufacturers' quality control records to ascertain with
reasonable certainty that the manufacturer is complying with this
regulation.
F. The laboratory shall hold a registered certification
mark from the United States Patent Office and shall agree to au-
thorize the use of that mark by manufacturers as evidence of com-
pliance with this regulation.
G. The laboratory shall be equipped with the instrumen-
tation and equipment necessary to perform tests in accord with
the requirements of this regulation.
H. The laboratory shall maintain complete, readily ac-
cessible records of the following items:
1. For each piece of measuring eq.uigment, the in-
strument name and description, name of manufacturer, model, style
and serial number, specifications on range or level of precision,
date and manner of calibration, and maintenance record;
2. Samples of raw and reduced data sheets, a test
report format, a statement as to whether data is recorded manual-
ly or by automation;
3. The dates on, and manner in which, staff were
trained, and the dates and results of all testing procedure exam-
inations or observations of staff performance;
4. For each calibration or verification of a piece
of equipment, the name and description of the equipment, model,
style, serial number, name of manufacturer, notation of all
equipment variables requiring calibration or verification, range
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of calibration or verification, resolution of the instrument and
allowable error tolerances, calibration/verification date and
schedule, date and result of last calibration or verification,
name of laboratory personnel or outside agency responsible for
calibration or verification, source or reference standard, and
traceability;
5. For each wood stove tested, a description of
the stove, including the model name and design number; a copy of
the stove's operating manual; a photograph of the stove; design
plans, identified by design number, showing the overall dimen-
sions and specifications of components critical to emissions con-
trol and heating performance, including combustion chamber con-
figurations, air inlet controls, heat exchanger design, and make
and model numbers of applicable purchased parts; documentation of
all modifications to the model or appliance configuration ini-
tially tested; and all test data and results, including emissions
rate and heating efficiency calculations.
6. Sample tracking and logging records tracing the
movement of each wood stove through the laboratory from its re-
ceipt through all tests performed to the final test report, in-
cluding information on the dates of test performance, condition
of the stove, and the names of laboratory personnel performing
the tests.
I. The laboratory shall develop and follow a laboratory
quality control manual setting forth procedures consistent with
those required by the standard methods. The manual shall be
readily available to laboratory personnel and shall be made
available to the Division. t
J. The laboratory shall maintain an emissions rate and
heating efficiency computer program that produces results similar
to those calculated by the Division using a standard data set
provided by the Division.
K. Reciprocal accreditation shall be granted for a labo-
ratory if a state with which the Division has a reciprocal ap-
proval agreement has approved the use of test results produced by
the laboratory as a means of complying with the state program
regulating the sale of wood stoves. Such accreditation shall re-
main valid as long as the approval of the other state remains in
force.
XI. ENFORCEMENT
A. The Division may enter and inspect the property or
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premises of any manufacturer, dealer or accredited laboratory,
for the purpose of investigating any actual, suspected', or poten-
tial violation of this regulation; and may, at reasonable times,
have access to and copy any document, inspect any wood stove,
wood stove component, or testing equipment, or test the emissions
of any wood stove, possessed by any manufacturer, dealer, or ac-
credited laboratory, for the purpose of ascertaining compliance
or noncompliance with this regulation. Refusal by a laboratory
to permit the Division to conduct an inspection at any reasonable
time shall constitute grounds for revocation of accreditation.
Refusal by a manufacturer or dealer to permit the Division to
conduct an inspection at any reasonable time shall constitute
grounds for revocation of the model or configuration of appliance
manufactured or sold by the manufacturer or dealer.
B. The Division may revoke the certification of a wood
stove model or configuration of appliance if testing to support
certification was conducted at a laboratory which was not in com-
pliance with the accreditation criteria of section IX.
C. The Division may revoke the accreditation of any lab-
oratory which has violated the accreditation criteria of section
IX.
D. Following revocation of accreditation or certifica-
tion, the person to whom a certificate of accreditation or certi-
fication was issued shall return the certificate to the Division.
In any correspondence, advertising, or test results, the labora-
tory shall then cease referring to itself as being accredited,
and the person who formerly held a certificate for a wood stove
model or configuration of appliance shall cease referring to the
model or configuration as being certified.
E. The Division shall also enforce the provisions of
this regulation through all means authorized by Part 1 of Title
25, C.R.S.
-19-
-------
XII. LIST OF CERTIFIED WOOD STOVES.
Each dealer shall make available to consumers a current
list of certified wood stoves. The list shall be compiled by the
Division and distributed to dealers.
AG Alpha No. HL AP HXLP
AG File No. CNR8500372/KH
-20-
-------
Note: Appendix A to this Proposal New Regulation No. 4 is the same as
the Appendix To Oregon's "Draft Rules for Woodstove Certification",
which appears earlier in this Appendix.
-------
ALASKA
-------
Presented by: The Manager
Introduced: 05/7/84
Drafted by: J.R.C.
ORDINANCE OF THE CITY AND BOROUGH OF JUNEAU, ALASKA
Serial No. 84-30
AN ORDINANCE AMENDING THE WOODSMOKE CODE TO REGULATE THE BURNING OF
SOLID FUEL, IMPOSE AREAWIDE RESTRICTIONS ON OPEN BURNING AND SMOKE DENSITY,
AND DECLARE A MORATORIUM ON THE INSTALLATION OF SOLID FUEL-FIRED HEATING
DEVICES IN THE MENDENHALL VALLEY.
* Section 1. ClassIffcation. This ordinance is of a general and
permanent nature and shall become a part of the city and borough code.
* Section 2. Amendment of Chapter. Chapter 36.40 of the Code of
the City and Borough of Juneau is amended to read:
Chapter 36.40
SOLID FUEL-FIRED BURNING DEVICES
36.40.010 FINDINGS-. The Assembly of the City and Borough of Juneau
finds that there has been a significant and unprecedented increase in
the installation and use of solid fuel-fired heating devices in the city
and borough; that the increase in such installations and use in the Menden-
hall Valley has been especially great; that such devices generally produce
a high level of harmful airborne pollutants; and that the above conditions
combined with atmospheric conditions throughout the municipality and other
factors cause recurring smoke pollution conditions which are detrimental
to the health of, and offensive to, the people of Juneau. It is the purpose
of this chapter to reduce the increase of airborne pollutants from open
burning and from solid fuel-fired heating devices at the times and in
the areas of the city and borough that appear to be most adversely affected
by such pollutants.
36.40.020 SMOKE HAZARD AREA MAP ADOPTED. There is adopted as the
map identifying the smoke hazard area of the City and Borough of Juneau
that map entitled, "Smoke Hazard Area Map, City and Borough of Juneau,
Alaska," dated September 12, 1983.
36.40.030 DEFINITIONS. As used in this chapter, the following words
and phrases have the meanings indicated:
(a) "Solid fuel-fired heating device" means a device designed for
solid fuel combustion so that usable heat is derived for the interior
of a building, and includes solid fuel-fired stoves, fireplaces, solid
fuel-fired cooking stoves, and combination fuel furnaces or boilers which
burn solid fuel.
-------
(b) "Open burning" means the burning of a material which results
in the products of combustion being emitted directly into the ambient
air without passing through a stack or flue, but not,including the burning
of campfires, barbeques, candles, or tobacco.
(c) "Person" means an individual, partnership, corporation, company
or other association.
36.40.040 SOLID FUEL SMOKE EMISSION STANDARDS, (a) No person may
operate a solid fuel-fired heating device in such a manner that visible
emissions reduce visibility through the exhaust effluent by fifty percent
or greater for more than fifteen minutes in any one hour as determined
by a test conducted in substantial compliance with the regulations applicable
to the visual determination of stationary source emission opacity promulgated
at 40 CFR 60, Appendix A by the United States Environmental Protection
Agency; provided, and notwithstanding any contrary provisions in the
regulation, opacity observation shall be made at the point of greatest
opacity in any portion of the emissions plume without regard to the presence
or absence of condensed water vapor.
(b) No person may engage in the open burning of material in a smoke
hazard area between November 1st and March 31st.
(c) No person may engage in the open burning of material outside
a smoke hazard area between November 1st and March 31st without first
obtaining a permit ta~be issued by the manager or his designee upon
a finding that weather conditions or smoke conditions are not such as
to be, or are likely to become, any danger to the public health or to
become generally objectionable. Such determination may be based upon
reports or information from the United States Weather Service or other
weather reporting service or upon the report or recommendation of the
Alaska Department of Environmental Conservation or the United States
Environmental Protection Agency.
36.40.050 SOLID FUEL PROHIBITION, (a) Upon notification by the manager
that a smoke hazard condition exists within a smoke hazard area, no person
may burn solid fuel in any manner whether within or outside of any solid
fuel-fired heating device after the time stated in the notice as the time
after which all solid fuel burning must cease.
(b) Notice is adequate if published in a newspaper of general circulation
within the city and borough, or if given orally at least three times during
a six-hour period by a least two radio stations operating within the city
and borough, or if made available to the general public in the form of
a recorded telephone message the telephone number for which is published
1n a telephone directory or newspaper of general circulation within the
city and borough. The prohibition shall be effective from the earlier
of the time stated in the notice, six p.m. of the day the notice is published
In a newspaper, the time the last required announcement of the notice
1s given by radio, or two hours after the time the recorded message is
first made available by telephone.
-2- Ord. 84-30
-------
(c) The manager or his designee shall give notice under this section
upon a determination that weather conditions or smoke conditions within
the smoke hazard area are such as to be, or are likely to become, any
danger to the health of persons within the smoke hazard area or to become
generally objectionable to such persons. Such determination may be based
upon reports or information from the United States Weather Service or
other weather reporting service or upon the report or recommendation of the
Alaska Department of Environmental Conservation or the United States
Environmental Protection Agency.
(d) Any person owning a building for which, on November 5, 1983,
a solid fuel-fired heating device was the sole source of heat may apply
to the manager for an exemption from the provisions of this section.
Such exemption shall expire no later than January 1, 1986 and may not
be renewed.
36.40.060 PENALTIES. For the first violation of any section of this
chapter a fine of not more than three hundred dollars may be imposed.
For any violation of this chapter following conviction of a prior violation
under this chapter a penalty not to exceed five hundred dollars or thirty
days in jail or both may be imposed.
Adopted this 21st day of May, 1984.
/Mayor
Attest:
Clef!
-3- Ord. 83-30
-------
Presented by: The Manager
Introduced: 04/02/84
Drafted by: J.R.C.
ORDINANCE OF THE CITY AND BOROUGH OF JUNEAU, ALASKA
Serial No. 84-18
AN ORDINANCE AMENDING THE BUILDING CODE TO REQUIRE
MINIMUM RESIDENTIAL HEATING FACILITIES OF A TYPE
NOT INVOLVING THE COMBUSTION OF SOLID FUELS.
* Section 1. Classification. This ordinance 1s of a general and
permanent nature and shall become a part of the city and borough code.
* Section 2. Amendment of Section. CBJ 19.11.010(9) 1s renumbered
as subsection (10), subsequent subsections are renumbered accordingly, and
a new subsection (9) 1s added reading:
(9) In section 1211 delete the existing language and substitute new
language reading:
"Section 1211. Every dwelling unit and guest room shall be
provided with heating facilities, capable of maintaining a room temperature
of 70° Fahrenheit at a point three feet above the floor In all habitable
rooms without Involving the combustion of a solid fuel."
Adopted this 16th day of April, 1984.
~/ Mayor
Attest: '
-------
•LASKA DEPARTMENT OF ENVIRONMENTAL CONSERWION
STATE AIR QUALITY
CONTROL PLAN
VOLUME II: ANALYSIS OF PROBLEMS,
CONTROL ACTIONS
S«v1se
-------
G. WOOD SMOKE POLLUTION CONTROL
1. Problem Description
Use of residential wood-fired heating devices has been demonstrated
to cause air quality problems in locales where atmospheric ventil-
ation is low, wood use per capita is high and the populations
density is moderate to high. State and federal 24-hour standards
for total suspended particulate matter (TSP) have been exceeded
several times in portions of the Mendenhall Valley of Juneau.
Although TSP is the pollutant of primary concern, a potential for
exceeding the eight-hour carbon monoxide standard does exist when
particulate exposure is significantly above the health standard.
Wood use and hence wood smoke occurs in a large number of cities
and communities throughout Alaska. However, climatic conditions
are usually sufficient to disperse the pollution from the area.
Although the Juneau area is presently the only known location to
exhibit unhealthful air quality due to wood burning, this pollution
problem will most likely increase in portions of the state where
wood resources are plentiful.
Administrative procedures to maintain ambient air quality standards
in locations where emissions from residential wood burning activities
threaten public health are outlined in the following pages of
this section.
2. Problem Assessment and Initial Control
The Department will install and operate air quality monitors in
locations where wood smoke pollution is considered significant.
If measured exposures approach or exceed the ambient standards,
the relative impacts of all local activities will be assessed
towards their respective contribution to the ambient exposure.
If exposures are anticipated to ryach or exceed the air quality
alert value of 375 micrograms per cubic meter (uy/m-*) [see 18 AAC
50.610(a)(1)(U)], the Department will issue an dir quality alert
and enforce the requirements of 18 AAC bO.U8b(l). Additional air
quality alerts will be issued when similar atmospheric and wood
stove use conditions recur that may cause exposures above the
ambient air quality standards.
Should exposures reach or exceed 150 ug/m^ when wood smoke
pollution is considered to be the major contributor, additional
chemical analysis, approved chemical mass balance techniques and
receptor models will be utilized to discern the actual impact
of all local sources to the ambient exposure.
3. Local Government
Wood smoke pollution problems tend to be very characteristic of
specific conditions such as frequency and severity of air
stagnations, local terrain features, seasonal and daily wood use
patterns, and type and quantity of wood and wood-burning appliances.
III.G-1 7/1/83
-------
Because of these factors, adverse air quality conditions are best
managed by the local government entities. The Department will assist
communities in the development of appropriate cm
-------
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MENDENHALL VALLEY WOOD SMOKE CONTROL AREA
7/1/83
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RENO, NEVADA
-------
EMERGENCY EPISODE PLAN
050.000 PURPOSE
The purposes of the following Sections are:
A. To advise persons with respiratory or cardiac
problems of air pollution levels which may be
harmful to their health; and
B. To initiate corrective control measures to
prevent build-up of air contaminants to levels
which would cause significant harm to a
significant portion of the population in the
Vashoe County Health District.
050.002 HEALTH ADVISORY
Prior to declaring a Stage 1 (Alert) episode as
outlined in Section 050.005 the Control Officer may
initiate a Health Advisory whenever the pollutant
concentrations reach 80Z of that required to
declare a Stage 1 episode. The purpose of this
advisory is to serve as advance notice to the
public that an unhealthful pollutant level is
expected and it should also provide information as
to the remedial measures that the public may take
to lessen the impact and possibly avoid a Stage 1
episode.
050.005 "EMERGENCY EPISODE STAGES
A. Ambient air contaminant levels specified in
Table I of this Section are emergency episode
determinants for which control action shall be
taken in accordance with provisions of this
Section.
-------
B. Whenever the concentrations of an air
contaminant reach or are predicted to reach a
Stage 1,2 or 3 as specified In Table I, at an
air monitoring station operated by the Vashoe
County District Health Department, and the
concentrations are expected to persist for at
least eight additional hours, the Control
Officer may declare that an emergency episode
stage exists and take the actions specified in
Sections 050.010 and 050.015.
TABLE 1
EPISODE CRITEIA LEVELS
POLLUTANT
CARBON
MONOXIDE
OZONE
SUSPENDED
PARTICULATES
Averaging
Time
8 Hour
1 Hour
24 Hour
Stage 1
(Alert)
PSI 200
Health
Advisory
12.0 ppm
0.16 ppm
300 DG/M3 375 ug/m3
Stage 2
(Warning)
PSI 300
30 ppm
0.40 ppm
625 ug/m3
Stage 3
(Emergency)
PSI 400
40 ppm
0.50 ppm
875 ug/m3
050.010 NOTIFICATION OF AM EPISODE STAGE
A. When an episode stage is declared, the Control
Officer shall notify:
1. The news media and shall request that they
publish or broadcast all appropriate
warnings, notices and advisories;
2. The Washoe County Manager and the managers
of the cities of Reno and Sparks;
3. Managers and operators of all stationary
sources covered under Sections 050.030; and
4. Other agencies which, in the opinion of the
Control Officer, should be notified.
B. Notification of an episode stage shall include
information as to which stage has been
predicted or reached, the expected duration of
the episode, the geographic boundaries of the
affected area, the specific air contaminant for
which the stage has been declared, a statement
of the public health significance of the
episode stage, and the appropriate voluntary or
mandatory control measures to be taken, as
described in Section 050,015.
-------
1. The Public Notification shall be updated to
reflect the more severe conditions;
2. For oxidant episodes - programs which
involve physical exertion by persons using
public parks or public recreational
facilities shall be suspended;
All commercial and industrial activities
such as dry cleaning, spray painting and
degreasing that emit reactive organic
compounds shall be notified to cease
operations. Such activities as roofing,
asphalt paving and surface coating where
the use of large quantities of volatile
organic material is involved shall also be
prohibited;
3. For carbon monoxide episodes - if the
occurrence of this stage is determined to
have been due to traffic congestion in that
area, take measures to reduce the traffic
congestion in that area.
4. For suspended particulates episodes - dust
emitting construction and agricultural
activities such aa grading, leveling,
plowing and digging shall be prohibited;
and
5. A request shall be made to the general
public to avoid the area of the episode.
C. Stage 3
In addition to the control measures specified
in Subsections A and B above, the approprate
law enforcement and civil defense agencies may
be requested to:
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C. If an episode stage 2 or 3 is declared, the
Control Officer may request that the Director
of The Division of Emergency Management for
Vashoe County coordinate all emergency control
measures.
050.015 EPISODE CONTROL ACTIONS
The Control Officer and the appropriate law
enforcement and public health officals shall take
the following control actions upon declaration of
the following stages:
A. Stage 1
1. A health warning for sensitive persons
shall be included in all notifications
given pursuant to Section 050.010;
2. All open burning must be terminated;
3. The use of permitted incinerators shall be
termina ted;
4. A request shall be made to the public to
curtail any unnecessary motor vehicle
operation;
5. Whenever, the measurements of total
suspended particulates, carbon monoxide or
ozone reach Stage 1 levels'and adverse
meteorological conditions are predicted to
persist, the burning of wood or coal in
commercial or residential stoves and/or
fireplaces shaj.4. be suspended unless it can
be demons tra*?£3* tha t such fuels supply the
only heat available to the person burning
them. The suspension shall remain in
effect until all episode stages have
termina ted.
6. Sources covered under Section 050.030 will
start curtailment of operations as per
their submitted and approved plans.
B. Stage 2
All of the control measures specified in
Subsection A shall be implemented under a Stage
2 episode and, in addition:
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1. Close all public, commercial and industrial
establishments vhich are not immediately
necessary for public health and safety and
are within the affected area;
2. Close principal streets within the affected
area to the general public;
3. Require emergency carpooling or use of mass
transit by the public;
4. Set-up and implement evacuation procedures
if deemed necessary; and
5. Inspect stationary sources covered by
Section 050.030 to insure source compliance
with curtailment plans.
050.020 TERMINATION OF EPISODE
The Control Officer shall declare an episode stage
terminated when the concentration of a contaminant
falls below the criteria level shown in Table 1 of
Section 050.005 and/or when meteorological data
indicate that the contaminant concentration will
decrease to below the criteria level.
050.025 NOTIFICATION OF TERMINATION
Upon declaration of termination of an episode
stage, the Control Officer shall notify those
persons and offices specified in Subsection A of
Section 050.010. The notice shall also advise
which curtailed activities may resume and which
activities must remain curtailed, as specified in
Section 050.015.
050.030 CONTROL PLANS FOR EMISSION CURTAILMENT
The owner or operator of any stationary or mobile
source with the potential to emit 50 tons or more
per year of an air contaminant therefrom shall,
upon request of the Control Officer, prepare and
submit a plan for reducing or eliminating such
emission in accordance with the episode stages of
Alert, Warning and Emergency as defined in these
Regulations.
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TECHNICAL REPORT DATA
(flcssc read Instmcnons on :he reverse before corrpleringj
3HPOKT vC.
:?A-45G/4-S5-CI2
|3. RECIPIENT'S ACCESSION NO.
. TiTLE AND SUBTITLE
Technical Support Document For Residential Wood
Combustion
IS. REPORT DATE
February 1986
6. PERFORMING ORGANIZATION CODE
7. ACTnORIS)
Dr. Robert Gay
Dr. Jitendra Shah
8. PERFORMING ORGANIZATION REPORT "v'O.
5. PERF3RMir»<3 ORGANIZATION MAMS AND ACDKESS
NERO and Associates, Inc.
Portland, Oregon
10. PROGRAM ELEMENT NO.
111. CONTRACT/GRANT NO.
68-03-3871
SB08410462
12. SPONSORING AGENCY NAME AND ADDRESS
Air Management Technology Branch
Monitoring and Data Analysis Division
US EPA (MD-14)
Research Triangle Park, N.C. 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
Project Officer
°'~B "ffns Technical Support Document is prepared to assist State and local air pollution
control agencies in assessing and controlling Residential Wood Combustion (RWC) air
pollution impacts. It provides an overview, description and leading references to many
technical topics related to characterization of wood usage, pollutant emissions and
resulting ambient concentrations attributable to RWC.
RWC emissions relative to other emissions sources, and various methods for estimating
RWC wood usage and resulting emissions are described and quantified. Factors affecting
the magnitude of RWC emissions from woodstoves and fireplaces are analyzed. Past and
future trends are exarrired.
Leading examples of RWC emissions control strategies are described, based on pro-
grams implemented in Oregon, Montana, Colorado, Alaska, and Neveda. Example laws,
regulations, local ordinances and informational materials related to these cases are
included in an Appendix. Methods for estimating the potential effectiveness of RWC
emission measures are described and illustrated, including the use of receptor and
dispersion models.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTlFlERS/OPEN ENDED TERMS
c. COSATI Field/Croup
Emissions
Receptor Modeling
Woodstoves & Fireplaces
Dispersion Modeling
State & Local Residential
Rules & Regulation
is. DISTRIBUTION STATEMENT
19. SECURITY CLASS (ThisReport/
21. NO. OF PAGES
20. SECURITY CLASS (T'na page/
22. PRICE
EPA For-n 2220-1 (Rtv, 4-77) PREVIOUS EDITION is OBSOLETE
i
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