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EPA demands Efficiencies be removed from OWBs

Post in 'The Boiler Room - Wood Boilers and Furnaces' started by tronsliver, Jun 25, 2013.

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  1. tronsliver

    tronsliver New Member

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    See the enclosed letter from the EPA to Central Boiler written a few weeks ago. Keep in mind that OWB manufactures knew that the efficiency rating shown on hang-tags attached to their units, and published in their marketing materials, were flawed as early as 2010 when the EPA pulled the efficiency data from its Burnwise website. Also relevant is the fact that many states promulgated its laws based on these flawed efficiencies.

    For example, the EClassic 2300 showed 86% efficiency on its hang-tag and that's what was listed on the Burnwise website. A study sponsored by the EPA showed the EClassic 2300 (three stage HH) as having only 30% thermal efficiency under real-world use. This is one of the reasons the efficiencies were pulled in late 2010.

    The EPA told the manufacturers about the flawed efficiencies at the time they were pulled from Burnwise but the manufacturers elected not to remove them from the hang-tags or their marketing materials. In essence, they continued to misrepresent the boilers to consumers until the recent EPA letters were sent. The only reason the EPA sent the letters out last month is because they knew that a number of law firms found out about the flawed efficiencies and elected to do damage control. In other words, push blame on the manufacturers by proving that the manufactures knew about the flawed efficiencies yet decided not to remove them ( remember it's a volunteer program)

    From a consumers perspective, if a person pays $200 dollars for a full cord of wood and the OWB burns an average of 13 full cords of wood per heating season, the consumer expects only 14% waste (100 - 86%) or $364 dollars per heating season based on a 86% thermal efficiency. Based on the Gullett’s study a person who purchased a EClassic 2300 actually loses $1820 dollars per heating season because the actual efficiency is only 30%.

    70% (waste based on 30 percent efficiency) x 200 (per cord) = $140 (waste per cord) x 13 cords of wood = $1820

    Additionally, when a consumer shops for a heating appliance many base their decision to purchase on the efficiency of the device. In essence, they compare to other appliances such as gas, oil and electricity before making the purchase. As you can see from the aforementioned example consumers' are being duped and neighbors are suffering the consequences - efficiency has a direct coloration to smoke and pollution. The higher the efficiency the hotter the fire burns and hence less smoke and PM 2.5.


    Lastly, after Method 28 OWHH was found flawed , also as a result of the efficiency issue, NESCAUM and NYSERDA strongly questioned the raw data obtained from Method 28 OWHH on all models tested, to include the data which determined the amount of Particulate Matter measured for each test. The EPA baulked because it would require them to force retesting for 23 models at 20 thousand dollars per test. This would obviously prompt lawsuits against them from manufacturers so they massaged the data to salvage the PM results. Bottom-line is the PM results are suspect too.

    For over three years now consumers have been intentionally mislead into purchasing Phase II OWBs based on deliberate false marketing schemes costing consumers thousands of dollars. Both the EPA and manufacturers are complicit.

    Attached Files:

    hobbyheater likes this.

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  2. arbutus

    arbutus Feeling the Heat

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    Would you happen to have a link to the overall thermal efficiency test data?
  3. tronsliver

    tronsliver New Member

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    The test data is available at the EPA through a FOIA.
  4. Chris Hoskin

    Chris Hoskin TarmSalesGuy

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    tronsilver, thank you for your thorough and accurate assessment of the situation. Well done.
    BoilerMan likes this.
  5. BoilerMan

    BoilerMan Minister of Fire

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    There is no free ride. OWB's and their questionable construction and insulation. Hook it up to thermal storage weigh the wood, and fire it in real world sub zero conditions with their insulated line buried 6" deep (oh and it has to be 1" PEX). Then we can get some real world numbers. I'd be scared to try this if I owned one, in fear of how much wood I really am wasting :mad:. I'll bet 30% would be high.

    Really we, or anyone who is familiar with hydronic heat, would know that the things don't put out much heat for the wood consumed by the fact that 1" PEX can be used for such a long distance. The math doesn't lie. I'm not anti OWB, just anti bologna economics and am personally too busy to process 6 zillion cord of wood for heat.

    TS
  6. heaterman

    heaterman Minister of Fire

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    I'll make a wild, and I do mean wild,_g guess as to where the whole wood burning/EPA thing is going to end up unless the manufacturers AND users really and truly get serious about burning clean.............

    The issue, the MAIN issue, with testing is developing a standard protocol that is repeatable and consistent. This is simply not possible with cordwood as there is too much variation in exposed surface area, moisture content and density of the particular species. Add to that the fact that any standard that the EPA chooses will not be able to be duplicated under actual use conditions. Users get lazy and don't season their wood. The wood is frozen solid and covered with ice and snow when it is thrown into the combustion chamber (I use that term very loosely). Garbage and other undesirable fuel is used indiscriminately and then there are the boilers themselves........ very poor combustion characteristics, many have very poor heat transfer capability, and the basic design premise of firing it with a huge load of fuel to "hold Fire" all day lends itself to ghastly amounts of pollution and poor efficiency.

    So.....

    Sooner or later, EPA is going to figure all that out and they will come to the conclusion that the only real way to address the problem is to regulate the fuel itself. They will realize that the variation in the fuel is a moving target in the wood burning equation. Then they will begin to think about standard size and moisture content and realize this is not possible. This will drive the control freaks and green people within that organization stark raving nuts.

    I would not be surprised that at some point one of the high mucky mucks there will have a light bulb moment and realize that such a fuel does indeed exist. It is consistent, very low in moisture content, readily available, easy to test and it is called wood pellets. Neither would I be surprised if after said light bulb moment that a mighty effort is expended to ban all wood burning boilers and remove them from the market along with announcing that pellets are the fuel of the future. Thus will come to pass the end of wood burning boilers.

    You heard it here first. ;)
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    PS:
    This was meant partially in jest but knowing how government "works" these days.......who knows what they are thinking.
    jeff_t and mikefrommaine like this.
  7. heaterman

    heaterman Minister of Fire

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    Saw your post over at Arboristsite and came here to check if you had blessed these good folks with the same info. It must be said that ALL OWB manufacturers received the same letter from what I understand. EPA felt that the bogus standard and test protocol applied to everyone and rightly so.

    Thanks for sharing. Seriously.
  8. jebatty

    jebatty Minister of Fire

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    For a long time I have been a strong proponent of weighed wood burns to determine real world wood boiler performance (efficiency). Note the comment by BoilerMan which accurately states that the only way to really measure efficiency is with thermal storage and weighed wood burns. I have measured efficiency for 3 different wood gasification boilers in real world operation using the thermal storage and weighed wood burn standard. Those three boilers (Garn WHS3200, Tarm Solo 140 and Wood Gun E500) all have measured efficiency in the mid to high-80% range.

    A thermal storage with weighed wood burn method of efficiency is simple:
    1) water has a known heat storage content per gallon (8.34 btu/lb/degreeF) ;
    2) wood at 20% moisture content and 400F stack temperature (fairly normal real world operational characteristics) has a known btu content per lb (6,050 btu/lb);
    3) a weighed wood burn has known btu availability;
    4) increase in temperature of a known gallon volume of water x 8.34 / wood burn btu availability = efficiency.

    Example: 100 lbs of wood = 605,000 btu available.
    If burning that wood resulted in an increase of 60F in the temperature of 1000 gallons of water, then
    60 x 8.34 x 1000 = 500,400 btu were transferred to the water (thermal storage) from burning the wood, and
    Efficiency = 500,400 / 605,000 = 83%
    arbutus, BoilerMan and heaterman like this.
  9. heaterman

    heaterman Minister of Fire

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    Absolutely agree Jim. The problem with storage based efficiency ratings is that few boilers incorporate it into their product and a lot of manufacturers flat out say their boiler doesn't need it and works fine without it.
    In Europe it pretty much standard or even mandatory in some locales. Should be here too.

    When you look at the numbers the way you have them laid out it's easy to see why the OWB's do so poorly.
    Start with this fact; 100 pounds = 605,000 btu's. Now how many OWB's get loaded with 200 or even 300 pounds of fuel and then sit there and idle most of it away. To "hold a million to a million and a half btus a person would need a very wide temp swing on 2,000+ gallons of water.
  10. tronsliver

    tronsliver New Member

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    Keep in mind that EPA’s Method 28 OWHH and the new Method 28 WHH use a testing methodology based on compromise. The EPA’s Phase II program is a volunteer program. This means the only way the EPA can get manufacturers to participate is to give them a seat at the table.The 67-69 % now being reported for some units under WHH is also overly optimistic when compared to real-world results. The only way OWBs will ever get to high efficiencies is to eliminate cycling technology.

    Along these same lines there's currently a federal tax credit allowing up to $300 for OWBs that meet a 75% thermal efficiency rating. Many of the manufactures are claiming their units meet the criteria by continuing to use the same efficiency values removed from the Burn Wise website and recently ordered off their hang tags. To cover their bases a few manufacturers had their units tested using EN303-5 which is the European standard. The type of technology employed in American OWB systems cannot be adequately tested using this standard. The design of EN303-5 assumes wood heating systems that do not cycle (damper closed when building quits calling for heat) or employ an auxiliary heat storage system that allows the boiler to run continually. Only a few American manufacturers employ this type of technology.

    The federal statute is not explicit as to how the 75% must be measured so those manufacturers with the wherewithal (paying for testing) are taking advantage of the current language by using inappropriate testing methods. There is nothing illegal about using EN303-5 except the fact that consumers end up being the victim. Yes the consumer receives a tax credit, but again there is the assumption that the device purchased is achieving these advertised high efficiencies. In the long run the cost of operating the device far exceed the measly amount obtained from the initial tax credit.

    Bottom-line: Not only are some OWB manufacturers immorally defrauding the federal government but continue to find ways to knowingly misrepresent high thermal efficiency values via advertisement as well. Google CB E-Classic 1450 brochure and look at the bottom right of page one. If you’re an average consumer how would you interpret the 90% efficiency listed on the brochure? What makes this so immoral is the fact that CB knows its units cannot come anywhere close to the efficiency listed on the brochure based on the EPA informing them in 2010 about the flaws in its Method 28, but has absolutely no second thoughts about consumers incurring thousands of dollars in losses over the life of the product. If you purchased a Phase II OWB under these false pretenses between 2010 and present you should be furious.
  11. NE WOOD BURNER

    NE WOOD BURNER Minister of Fire

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    Well- this just confuses the general public more!

    The e-1450 was not on this list in the pdf

    So if you wanted to buy an owb right now in NH. What is the current list that can legally be sold? the Burn wise is very outdated. Econoburn OWB looks like it should be able to pass but not currently available.
  12. NE WOOD BURNER

    NE WOOD BURNER Minister of Fire

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    Ok so the central boiler brochure(e-1450) states over 90 percent effieciency based on en 303-5.

    EN303-5 based on what I read in this thread is based on a batch load to storage or a batch load to storage incorporated in the boiler.

    so reading the list of approved OWB they all state batch loads.

    So I have asked before if anyone has tried running an OWB to additional storage and batch burning.

    Seems like its the technique/method of burning not the appliance that will give EPA their desired results.

    CB also states the epa approved gassers have a combustion effiecency of 100%. I would think this would be an easy claim to make @ nearly 2000 degrees.

    so what I got so far is in my sig. waiting for the industry to come together and offer an OWB that is legal to both purchase and install and run in a batch load to storage that can be purchased with real economics in mind.
  13. samuel

    samuel Member

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    I’m glad to see that Heaterman pointed out that ALL manufacturers that tested to EPA Method 28 OWHH were sent similar letters.

    On Monday, I had an email forwarded to me that originated from Nancy Alderman from EHHI based in Connecticut. If you are not familiar with her she is an anti-everything zealot who would ban all lawn fertilizer/chemicals, astro-turf sporting fields, tanning beds, etc. The list goes on and on and on about what her group is trying to ban. At least Nancy’s email included the letters to ALL of the manufacturers – where tronsliver makes insinuations about one manufacturer. tronsliver pretty much takes Nancy’s email verbatim and posts it here and also posted pretty much the same thing on forestyforum.com and arboristsite.com – who knows where else.

    I have questions for tronsliver exclusively: Has the U.S. EPA and woodstove manufacturers misled consumers while using default efficiencies of 63%, 72% and 78% since 1990 (23 years)? They are default efficiencies. When tax credits were given to consumers who purchased indoor woodstoves from retailers/manufacturers were they defrauding EPA and consumers?

    ALL of the manufacturers who chose to participate in the EPA Programs (Phase 1 and 2) were forced to use the test methods dictated to them by the EPA and they were also forced to use the information that came from the tests if they wanted to use hang tags/qualifying labels and be involved in the Program. In other words, the EPA dictated everything to the manufacturers – use this test and put this information on your hang tags/qualifying labels. If manufacturers did not follow EPA’s requirements they would be removed from the Program.

    You should also be aware that EPA chose to adopt EPA Test Method 28 OWHH based upon pressure from Northeast states including NESCAUM and many NESCAUM state agencies – most of them specifically regulated outdoor hydronic heaters. EPA pretty much took – verbatim – the language from a draft 4 of an ongoing ASTM test standard development. When the ASTM standard eventually passed in 2008– it was draft #12 - I believe. Intertek wrote a paper and mentions this issue more in-depth.

    EPA did change the method and the changes are PUBLICLY shown on EPA’s website and I’ve discussed the changes in-depth here before. While it was a compromise – the compromise involved input from the U.S. EPA, NYSERDA, NESCAUM, state air agencies, test laboratories, manufacturers, etc. tronsliver appears to want people to think that the compromise was reached between EPA and manufacturers alone. You should also be aware that states like New York specifically adopted EPA Test Method 28 OWHH and would not adopt EPA Test Method 28 WHH in their regulation by name. Why do you think NYS DEC chose to do this?
    (13) Test Method 28-OWHH. "EPA Test Method 28 OWHH for Measurement of Particulate Emissions and Heating Efficiency of Outdoor Wood-Fired Hydronic Heating Appliances", Attachment 2 of the "EPA Outdoor Wood-fired Hydronic Heater Program Phase I Partnership Agreement" dated March 16, 2007 (see table 1, section 200.9 of this Title).

    Your claims about EN303-5 are also extremely misleading.


    Here is the real bottom-line: Manufacturers have not defrauded anybody. The intent of EPA’s Program remains intact – reduce emissions faster than what could be achieved by Federal Regulations being enacted. I consider people like tronsliver to be nothing more than internet trolls – trying to influence people with misinformation. I’m disappointed when trolls like tronsliver get on these forums simply to disparage certain manufacturers knowing full well that EVERY manufacturer that qualified a hydronic heater to Test Method 28 OWHH received the same letter and then spew false and misleading information about issues they fully well don’t understand. Eventually - they will all have to retest the methods prescribed by EPA and/or states - then what happens if they are at or above 75%, 80%, 90%? Does this start all over?
    martyinmi likes this.
  14. NE WOOD BURNER

    NE WOOD BURNER Minister of Fire

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    Who ever he is? He defiantly saw what I saw about the approved list. the testing was for batch loading/burning. not the way OWB are currently operated from my research. The industry needs to unify and make the EPA and state environmental boards aware of proper hydronic heating methods prior to regulating the appliance.
  15. tronsliver

    tronsliver New Member

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    The reason it wasn't on the list is because it was tested under WHH. (the new test method) However, your inquiry brings to light another example as to how CB continues to misrepresent its products to consumers, even with full knowledge of the efficiency controversy. Under the new test the 1450 achieved a 77% percent efficiency, but since many of its competitors have not yet tested under the new method they elected not to advertise the 77% because it would put the 1450 in a unfavorable marketing position. The 1450 is still considered Phase II qualified but instead of using the 77% in its advertisement they elected to use the unsanctioned EN303-5 so they could boast 90%. What makes all of this so damning is the fact that CB sat on the committee which adopted Method 28 WHH. So on one hand they helped design WHH essentially blessing the method, but on the other still decided to misrepresent its model to consumers by disregarding the 77% in its advertisement to protect against losing market share.
  16. And over on AS he got banned after 2 posts with the same information.

    Touchy group those big bad OWB guys are I guess.
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  17. NE WOOD BURNER

    NE WOOD BURNER Minister of Fire

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    What ever the numbers are is irrelavent. I drive an old car keep it tuned and I still get 33mpg after 220,000 miles no one told me I could not buy it. I cant buy a new OWB that works for my economics based on a law that is flawed based on EPA phase II tag.
    I have no beef with CB or their advertising as they appear to be trying to stay alive. My CB local dealer would love to sell one to me, but ran the numbers and said I would not be satisfied with the economics. I also had an Indoor wood boiler rep state the same thing. I do not not think any have been misleading. But rather truthful of their products and the capabilities of them.
    But I do ask lots of questions!
    Efficiencies have been put on everything. MPG on cars/trucks/water heaters/oil burners but you cant purchase from these numbers. you look up the brands you pick one out then you call around and check on who stocks parts for them. and walah! I buy the unit that I can get parts for on a sunday or saturday.
    Keep in mind that there is nothing earth shattering in wood boiler technology currently. It is all old technology trying to be put together on the cheap and marketed for the maximum profit. The imports of the indoor gassers have a differant economic model based on dealer fees and such that makes it hard to get the profits up to a desired level. IMHO
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  18. Jags

    Jags Moderate Moderator Staff Member

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    This is good discussion so far. Let us not turn it into a dog pile.
  19. You can discuss it all you want. But the attitude present over there is a lot more prevalent then on this forum. It's only a matter of time before some version of the events Heaterman predicted come to pass.
  20. tronsliver

    tronsliver New Member

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    There was interest in the information presented over at AS but a few long-time members had a hard time grasping the concepts. What they didn't understand or refused to consider was not answered with sensible debate but simply resorting to name calling. I would assume even though I was banned they'll be here reading and trying to disrupt the conversation.

    Samuel,

    I agree with some of what you said and although I was told there were additional letters sent to other manufacturers I did not have copies so chose not to mention it. I'm not very knowledgeable about what happened in the past with indoor wood burners so I have nothing to add to the topic. With regard to the EPA dictating the criteria of the volunteer program I will add that the resulting Method 28 OWHH did favor manufacturers with respect to how PM was measured over long burn times, instead of GPH, and how efficiencies were ascertained. You are also right about the other stakeholders involved in the process. That said, in my opinion, up to the point where Method 28 OWHH was found to be suspect there was no deliberate misrepresentation of thermal efficiencies.

    However, when it became known that the efficiencies were flawed and the EPA informed the manufacturers in 2010 to remove the flawed efficiencies from their marketing material they refused to do so. The EPA had no legal power because it was a volunteer program. See my original post as to why the EPA didn't require retesting at that time.

    The manufactures completely understood that the original qualifying contract was for five years and if they refused to retest under WHH they felt comfortable continuing misrepresenting the flawed thermal efficiencies until the contracts were up. See post above concerning the circumstances of the E-Classic 1450.

    Please enlighten me as to why you feel EN303-5 is an honest test concerning American wood boilers. I would very much like to hear your explanation of EN303-5's tested burn rates compared to Method 28 WHH tested burn rates when it comes to cycling technology. Please explain why EN303-5 does not employ a Category 1 burn rate like Method 28.

    Samuel you appear to be a smart guy, I guess I'm surprised as to why you would resort to name calling before you even asked me for an explanation of my comments. From my experience with forums, this is a common tactic when someone else is telling the truth and the person being effected becomes uncomfortable. In essence you're trying to discredit me so the information I'm providing does not gain traction. I respectfully ask that you please give me the same respect I'm giving you.
  21. TMonter

    TMonter Minister of Fire

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    If the EPA's own tests and standards that resulted in those efficiencies was referenced what is the problem? It was the EPA's mistake, not the manufacturers.
  22. BoilerMan

    BoilerMan Minister of Fire

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    Who is doing the testing? The manufacturers, the EPA, or third party? Third party (Intertek) should be doing the tests on ALL the units using the same procedure. Would the efficiencies replicate real world? Prolly not. But at least we'd have some numbers to compare one unit to another.

    It's a hard subject to say the least. OWB's are not super-efficient, but manufacturers are putting numbers on them that say they are. This is done by using the EN303-5 loophole which is not meant for this type of boiler........this has been stated. Personally, I don't think wood burning will be banned entirely, this is almost complete socialism, I still have some hope for freedom here in the USA.

    My prediction: dirty burning and the majority of OWB is a problem, and is something drastic does happen, indoor or gasser installs will not be banned, rather others will be forced to buy gassers (and will continually operate them inefficiently). To be completely honest, there are some OWB around here that burn pretty clean, as they are connected to large loads and don't bother anyone.......

    I drive an old car, which would be considered a gross polluter in some states:rolleyes: but is gets great gas mileage, and has many miles on it, but that is another discussion. OWB, do not have a huge lifespan, so if they are forced to be "cleaner" then the "clean ones" will be phased in and the old ones will rust out.

    The problem Heaterman stated, is the kicker as we all know. Wood is so inconsistent and anyone can take a state-of-the-art gasser and soot it all up and billow smoke. But for the Gov't to take the RIGHT away for someone to burn wood would make a lot of people poor and cold, clean burn or not!

    TS
  23. It's more or less happening out west already.

    New houses aren't allowed to have wood heat as a primary source. And on certain days all woodburning is prohibited unless your primary heat source is wood. I believe wood pellets are even prohibited on 'spare the air' days.

    It's only a matter of time... With laws like that no one will be able to rely on wood heat and people will be are forced to use alternative fuels. Then the gov't will come out with a new law prohibiting all wood burning. The writing is on the wall.
  24. You need to follow the money trail. I smell a class action lawsuit in the works.
  25. martyinmi

    martyinmi Member

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    tronsilver-
    Care to tell us why you are taking the time to provide us with this information?
    And, what is your agenda?
    Things that make one go hmmm.;)
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