Small commercial boiler - federal certification?

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mapratt

New Member
Jan 12, 2011
45
Coastal Oregon
Hi, guys -

Because people have created toxic waste by concentrating thousands of cows in a feedlot, or tens of thousands of chickens in an egg factory, I have to register my little sheep and goat dairy as a federal Confined Animal Feedlot Operation, and have additional tasks and paperwork to do on an ongoing basis, proving I am following the rules the feds have had to put together for big cow operations.

Because outdoor wood boilers have at least historically been such abysmal sources of pollution, Oregon and Washington state have outlawed the sale or installation of residential wood boilers of any sort, indoor or outdoor. Period. Full stop. No can do.

Last Friday, Oregon did pass a temporary ruling that small commercial operations can install boilers of less than 1million BTU in size. But they have to meet the federal certification for commercial biomass boilers, which is apparently more expensive set of tests to conduct. This ruling is in effect for 6 months.

The federal certification rules for this class of boiler apparently only came out in March of this year.

I've no idea how to find which units I might purchase. I was going to get a Frohling 40/50, 1000 gallons of thermal storage.

I am so unspeakably frustrated.

Does anyone on the list know of boilers that meet the brand-new federal requirements for small commercial wood-fired boilers?

thanks -
marilyn, in western oregon, who really wants to hit something
 
From what I have heard, and this is just hearsay, the commercial specs are virtually impossible to hit with a small unit that is economically feasible.
I do know for certain that the Garn 1500 just beat the EPA Phase II emissions standard by about 50%. ...and that's using real cord wood. Not the fairy tale kiln dried stuff the EPA test protocol uses.
Garn has that on paper from an independent lab and if you call them I'm sure they would send you a copy you could show your local authorities. They may grant an exemption after seeing that it is a completely different burn process than any other boiler. A couple other things Garn has going for them is that it IS approved and certified for indoor use and it is technically NOT a boiler.

I, along with about everyone here, feel your pain. To me it's ludicrous that the enviro nazis have made burning wood or bio-mass "verbotten" just we we really need it. I think i'd put in the cleanest thing I could and stand there with a gun when they came to try and shut it down. Call here for help. You'll probably get it. :)
 
Thanks, Heaterman - Question, though... Why do you say it's technically not a boiler? Walks like a boiler, quacks like a boiler, ... ? From the Garm site:

"DEALING WITH THE EPA AND PHASE II QUALIFIED UNITS:
The EPA will not accept any test data from any manufacturer at this time, so we cannot be EPA Phase II qualified until an agreement between the manufacturers, states, and EPA has been reached about a revised EPA Method 28 test method (which is used to test OWB’s, not GARN equipment) and Partnership Agreement."

Why would they be talkin' about the test methodology used for OWBs?

I'm definitely getting in touch with them.
 
Yeah, actually, the Garn site calls them wood boilers. They just aren't outside wood boilers. My moment of hope is deflating a bit...

They did pass the EPA Phase II test, but the EPA is not accepting test results at this time so they can't call themselves EPA Phase II Qualified.

But Oregon's ruling rules out all residential wood-fired boilers. Test results are irrelevant. Facts are irrelevant. I am so frustrated.
 
No doubt that the EPA shares blame in casting a too broad net, as have some of the states. It seems to me, though, that the OWB industry and users share greater blame. Being branded "smoke dragons," which certainly described my old OWB accurately, and which motivated me to purchase a gasification boiler, the OWB industry which markets smoke dragons and the user of smoke dragons all were begging for major trouble. Clean air and reduction of particulates is a real concern -- ask anyone who suffers from asthma or other respiratory conditions. Besides, who in their right mind thinks they have the right to spew clouds of smoke into the air that all living things rely upon for the breath of life itself?

All of this could have been avoided if the industry wasn't more motivated by short term greed than by developing and marketing products which were models of clean air burning. The western European countries have dealt successively with clean air wood burning, and their wood gasification burners put to shame the historical wood burning industry in the US.

For a country which touts its mythical technology and entrepreneur-ship, the US is so often shown instead to be a model of sloppy, cheap, inferior and inefficient products. The OWB is a clear example.

It is unfortunate regulation and mandatory prescription by government has come to where it is in some areas, but that should be a clear lesson everywhere else that clean air matters, dirty air is not going to be in vogue, and it's way past time for industry to clean up its act and for users to purchase environmentally responsible products.
 
Check these links:
http://www.deq.state.or.us/aq/burning/woodstoves/heatSmart.htm
http://www.deq.state.or.us/aq/burning/docs/heatsmart/ohhRegistration.pdf

OUTDOOR HYDRONIC HEATER REGISTRATION FORM
EPA Phase 1 or Phase 2 Qualified Devices
This form is required to register your EPA Phase 1 or Phase 2 qualified outdoor hydronic heater (OHH) with the Oregon Department of Environmental Quality. Oregon law requires that wood heating devices which do not meet emission standards (specifically, EPA’s New Source Performance Standards for woodstoves, 40 CFR Part 60 Subpart AAA) be removed from a home when it is sold. Some types of wood heating devices are exempt from this law, including EPA Phase 1 or Phase 2 qualified outdoor hydronic heater (OHHs) that are registered by DEQ on or before July 1, 2011. By registering your EPA Phase 1 or 2 qualified OHH you will not be required to remove the device when you sell your home. (OAR 340-262-0700)

It looks to me that you can still register an EPA phaseII wood boiler before July 1-2011.

Also, it seems that you can install what you want, only when you are selling the home or buying the home you will need to remove the unit if the unit was not registered.

Buy a clean burning unit, preferably much cleaner then EPA phaseII.

If it is for a commercial location it is more important that the wood boiler (meaning pressurised) is ASME Section IV certified (H-stamp), and now the list becomes really short ... .
 
jebatty said:
No doubt that the EPA shares blame in casting a too broad net, as have some of the states. It seems to me, though, that the OWB industry and users share greater blame. Being branded "smoke dragons," which certainly described my old OWB accurately, and which motivated me to purchase a gasification boiler, the OWB industry which markets smoke dragons and the user of smoke dragons all were begging for major trouble. Clean air and reduction of particulates is a real concern -- ask anyone who suffers from asthma or other respiratory conditions. Besides, who in their right mind thinks they have the right to spew clouds of smoke into the air that all living things rely upon for the breath of life itself?

All of this could have been avoided if the industry wasn't more motivated by short term greed than by developing and marketing products which were models of clean air burning. The western European countries have dealt successively with clean air wood burning, and their wood gasification burners put to shame the historical wood burning industry in the US.

For a country which touts its mythical technology and entrepreneur-ship, the US is so often shown instead to be a model of sloppy, cheap, inferior and inefficient products. The OWB is a clear example.

It is unfortunate regulation and mandatory prescription by government has come to where it is in some areas, but that should be a clear lesson everywhere else that clean air matters, dirty air is not going to be in vogue, and it's way past time for industry to clean up its act and for users to purchase environmentally responsible products.

Jebatty,
I do agree with most of what you say, but the Europeans also have their problems with the clean burning of a lot of brands and models sold.
Not all gasification boilers are EQUAL.
There are front runner countries like Austria and Germany, but what about all the other European countries ... .
 
I too don't intend to cast too broad a net. The point is that efficient, wood-burning technology exists, it is proven, it is economical, and it is not new.
 
Looks like the EPA NSPS will only have a 0.15Lbs/mmBTU requirement for 2013/2014 for hydronic heaters.
Looks like they seems to go away from the 650 ppm CO additional requirement
This would be, again, a halt to innovative technologies for the biomass industry. History repeats itself.
There are combustion technologies available that go 50 ppm and less also in the US.
 
Boiler: By definition a boiler is a sealed pressurized vessel that is closed off from the atmosphere. A Garn is not closed so it is technically not a boiler. Many other wood heaters including OWB's fall into the same category but don't tell them that. Seriously.

Garn would not, will not and can not est to the EPA standard using their present testing protocol for two very simple reasons. 1>The testing protocol they have come up with is ridiculous and bears no resemblance to actual use of these wood burners, therefore rendering test results wholly ineffective in determining actual emission and efficiency levels. 2>The EPA test protocol has no method for testing heat storage type systems such as a Garn so putting a Garn or any other storage type unit through their test would be inconclusive at best and completely wrong at worst.
 
Hi, guys - they actually have had an independent lab do the EPA Phase II test, and passed with flying colors (Heaterman noted this above, thank you!). They also apparently came in well under the wire for at least one of the commercial criteria during that test, but I don't know how to map that to the tests required by Oregon as of this past Friday; hopefully Garn will be able to parse that out.

The announcement of the test results is here:
http://www.garn.com/page.wml/storeid/4656/p/emissions.htm?SessionID=0a00001e07db06160a043b2472

The challenge with those tests is that they aren't the tests for boilers/ hydronic devices, and the EPA isn't accepting test results right now, I guess due to all the flap about the ridiculosity of the tests.

So, all I need to do is build my building and get the unit installed and certified by July 1. I had read the ruling, but don't know the lingo well enough to map that to what I want to do. I wonder if I might have been able to do it, if I had started mid-May when I learned I was potentially in trouble (as opposed to waiting for the result of this temporary ruling, which I only learned the details of during a chat with Oregon DEQ air quality specialist yesterday).
 
Marilyn said:
So, all I need to do is build my building and get the unit installed and certified by July 1. I had read the ruling, but don't know the lingo well enough to map that to what I want to do. I wonder if I might have been able to do it, if I had started mid-May when I learned I was potentially in trouble (as opposed to waiting for the result of this temporary ruling, which I only learned the details of during a chat with Oregon DEQ air quality specialist yesterday).

Any possible way to build a small shed, hook up the boiler you want using just plain garden hoses to get a install? Then you could build a "addition" to the shed down the road, and "replace" the garden hoses with insulated pex and get your system then. In Michigan, for an "addition" you only have to leave one wall up and its allot easier to pull any permits. If you get the boiler "installed", you may have time to get it done.
 
Oregon EQC, June 2011, Agenda Item J Attachment, Presentation to ...
heaters). â—‹ Devices must meet the federal New. Source Performance Standard for woodstoves to be sold in Oregon. Outdoor Wood Boiler ...
www.deq.state.or.us/about/eqc/.../J-Att-EQCPresentation.pdf

The O DEQ presentation is misleading to a certain extent.

The O DEQ particulate emission limit for "outdoor wood boilers" under 1 million Btu/hr is 7.5 g/hr. Almost every EPA Phase 2 Hydronic Heater on EPA's List already meet this requirement but O DEQ wrote the rule so that only they can determine if the Hydronic Heater test method is equivalent to EPA certified indoor woodstoves. The only thing in question in that EPA program is the calculation for efficiency and it has nothing to do with the particulate sampling method (ASTM E2515) because it is the same sampling method used for certified woodstoves, pellet stoves, fireplaces, etc.

Washington's limit is 4.5 g/hr and over half of EPA Phase 2 Hydronic Heaters meet it.

The EPA Program long ago did away with the ability to test with cordwood - they use cribs because EPA certified woodstoves use cribs (and it is repeatable) and most of the States think that this will showcase worst case scenario emissions. For a period of time any manufacturer in the Phase 1 Program could have submitted cordwood testing to prove - whatever it was they are trying to prove. Even after the efficiency calcs are corrected - a manufacturer still can't submit cordwood testing for approval.

I'm not so sure a manufacturer should make claims of PHase 2 when the testing standards (EPA Test method 28 OWHH, ASTM E2618 and E2515) were not followed. ASTM E2618 may be changed to include it and EPA could accept the results but until then it is probably a non-issue.

The problem with the Federal Regs for Industrial, Commerical and Institutional "Boilers" is that it muddies the water regarding who SHOULD NEVER be included that own small wood heaters (under 1 million btu/hr) that heats wood working shops, kiln, greenhouses, hearth shops, etc. and how they would be clueless as to bi-ennial "tune-up" requirements or similar reuqirements. The average small business operator can't keep up with it, don't know what they have to do, and can't make heads or tails of a 56 page Fed Reg: http://www.epa.gov/ttn/atw/boiler/fr21mr11a.pdf.
 
Thanks, I'm checking w/ Garm to see if it's legal for them to sell their units in Oregon (the law prohibits sale of certain classes of wood-burning appliances, as of some time in April).

Digging into the just-adjusted ruling, needs to comply with this for the new exemption:
(1) No person shall cause, suffer, allow, or permit the emission of particulate matter, from any fuel burning equipment in excess of:

(a) 0.2 grains per standard cubic foot for existing sources;

(b) 0.1 grains per standard cubic foot for new sources.

(where I'm pretty sure this would be a "new source").

The other requirement is visual opacity inspection; the pictures of what's coming out of the flue from operating Garm units look pretty damned clear.
 
Thanks, Sam - for the record, Garm is not making claims they are Phase 2 qualified, since EPA is not accepting anyone's test results at this time. They are describing the results of their tests, though.

They also have an article about their opinion of the tests, and a comparison of their units' real-life performance to tested units' real-life performance.
 
Hello Marilyn,

Have you looked at the FlexFuel by WoodMaster? They are EPA qualified and have the best test results on the website. Not sure what size you are looking at but they do have a 60kW which is an output of 200,000 BTUs. You can also hook multiple units up to get more BTUs if needed. It is European technology built in the U.S.
I would look into it because you are able to heat with multiple fuel options...cordwood, wood pellets, wood chips...self ignition, self cleaning...wow too many options to type.

check out their website..http://www.woodmaster.com/flexfuelfurnaces/

Looks to be the luxury gasification boiler available in the U.S.
Havent found anything that compares

Thought I would mention this to you.

Elroy
 
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