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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. BrotherBart

    BrotherBart Hearth.com LLC Mid-Atlantic Division Staff Member

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    Since when is the EPA in the thermal transfer efficiency business. Sniffing the stack is their domain. They don't test thermal transfer efficiency of wood stoves that stand in the living space. What would any numbers about it in a shack away from the house have to do with anything? What gets into the living space is the only thing that counts.

    Yeah. I am ass deep familiar with EPA Method 28 for stoves. But it looks like now I have to go dig through the version for boilers. But Method 28 for stoves has not one thing to do with thermal efficiency.

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  2. __dan

    __dan Burning Hunk

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    You guys are nuts.

    Everyone who bought a Central Boiler or any OWB smoke dragon got exactly what they wanted. If they shopped a gasser with storage and an outbuilding, they would have been looking at over $20,000. installed. The CB's were probably marketed at $5.000 installed. That was the only number they were looking at. If they also looked at 20k systems, they would have said 5k for the CB and 15k for firewood, I won't be burning 15k in firewood.

    Most of the market action is price driven and anyone who competes to produce something knows you have to compete with a lot of crap at the low end. The market (the buyers) want the lowest price and the competitors target this market with lower quality, cheaper to produce solutions.

    The gov does have a role to play regulating this stuff, but if any low price junk was sold, it was because the buyer in the market wanted cheap low price crap. They were looking at the short term upfront low cost and not the best value investment over the long term. That is the majority of the market. There are very few buyers willing and able to pay more for high quality, long term capital investment grade hardware. Every contractor selling into the market knows this. Offer a fairly priced high quality solution and the buyer will buy a low cost, low quality, product from someone else.

    There is a huge market for low price jungle rules solutions. I'm sure the buyers took pride in stuffing tree stumps in their OWB's and watching them belch smoke and flames. I know I love watching mine burn tough nasty pieces of tree.
    arbutus likes this.
  3. leon

    leon New Member

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    AAAYYYYYY CARAMBA LUCY, you got some splainin to do;

    I enjoy this forum very very much and want to see this issue examined fully too.

    I wonder if the Garn folks are thinking outdoor wood and coal boiler(I hope so) since they were not
    using the EPA tests for their units.
  4. NE WOOD BURNER

    NE WOOD BURNER Minister of Fire

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    testing is like racing. You run what you Brung!

    as a consumer my site and buildings characteristics dictate what I can install outdoors. If I follow the law I can buy an approved outdoor unit and place closer to my nieghbors. Does it help the environment? does it piss off my nieghbors? potentially

    If I build an outbuilding and install an indoor unit I have no restrictions other than safety codes. I can even put in a non gasser.

    Makes very little common sense for me as a consumer to have to side step regulation for a basic right to provide heat to my home with wood as I have done for many years.

    For me its a challenge! for many I think they will just buy a used OWB non-gasser or buy a new phaseII OWB
  5. heaterman

    heaterman Minister of Fire

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    "Here is the real bottom-line: Manufacturers have not defrauded anybody."

    I disagree with this ^^^^^^^ on a moral basis.

    My family has been in business out here in the sticks of Northern Michigan since 1920 when my great grandfather started selling hardware, farm implements and groceries. We didn't manage to survive based on telling half truths to our customers. We feel that our customers need to know all the facts and the unvarnished truth about the products they buy from us. If a product performs well in a given circumstance but not another, we tell it like it is and let the customer decide. If a product does not live up to the claims made about it, we tell our customers that too. Not telling the complete story about a product is the same as lying to someone in my book.

    In the case of the ratings generated by the EPA test, I will flatly state that every single manufacturer involved knew the ratings were bogus. They have engineers and some that I have spoken with are pretty sharp. There is no question in my mind that all of them know what the real performance of their product is. They knew their stoves were not that clean and they knew their stoves were not nearly as efficient as the test results indicated. In spite of that, we saw advertising claiming efficiencies far beyond reality, so far beyond that it was to the point of being comedy.

    So here's the point; When any manufacturer publishes numbers that they know are misleading and shall we say, unattainable, even though they were generated by an approved method, they are indeed committing fraud in my book. Every one of the manufacturers had the option of telling the real story and taking the "high road" but none of them chose to do so.
  6. arbutus

    arbutus Feeling the Heat

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    There was a thread discussing price, return on investment, and value a month or so back.



    Price is how most Americans shop.
    Doing a little homework to know the VALUE of the product being purchased is beyond many Americans.

    Most manufacturers aren't going to give out the engineering and test data that will enable an ordinary customer to determine the value. I've worked in product design and development (surveying instruments) and have been given a list of marketing points that have to be fulfilled in a new product. We made it work at the price point marketing wanted, or told them what we could do at their price point and how much extra it was going to cost to meet their requirement, or told them in a couple of cases it couldn't be done with today's technology. Some of the competitors made what we thought were wild claims about their product. We never did.

    Air quality is a real concern that OWBs definitely affect. It's my opinion that the EPA has no business setting national air quality standards, rather, that should be up to each state. That aside, the EPA has and does set the standards, and is occasionally forced to modify the testing to better emulate the real world. The testing for vehicle mileage is no different.

    A listed test method and a thermal efficiency number on a big yellow Energyguide sticker might help consumers make a better educated decision, but very few are going to dig into the test method and compare it to their planned installation. I think many just want to cut the propane bill by 2/3, can come up with five or six thousand dollars one way or another, look at the maple or ash trees growing on the back of their ten acres, and think about being warm this winter. I don't begrudge these people, and certainly don't want the government to interfere in their decisions, rather I'd like to see them make a truly educated choice.
    BoilerMan likes this.
  7. NE WOOD BURNER

    NE WOOD BURNER Minister of Fire

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    Well I disagree a little bit.

    I think most will look at what they want and then reality of economics dictates that we downgrade our expectations of products.

    Resourceful folks will get what they want for a product with some creativity and Yankee engenuity within their means.

    The basic premise for saving energy is to conserve. Heating is a great place to conserve. with all the new wood and wood pellet boilers most are heating more square footage than before and the thermostat is @ like 72 degrees 24/7.
    IMHO the appliance is not the only issue in air quality.
    can they be improved absolutely. The main question for me is how do we change people and behaviors.

    I read much about the systems installed on this forum. If I heat my house as I do now. 60-62 degrees with no additional square footage utilizing anyone of the appliances available right now. I believe my wood consumption would decrease by a noticeble amount.
    Two things stand out for recommendations on this site. Get wood early and obtain heat loss calculation. since 1969 I have never seen a heat loss test performed in my area. the heat loss and proper sizing of the appliance is critical for the economics of the purchase. And a unit burning full out to storage is best for air quality.
    Burnwise would be wise to include this method of burning in their documentation of Hydronic heating. So that when consumers look for for appliances to fit their needs they could be exposed to a time tested way a burning that is not currently the way most think of burning wood. Burntime is a common question for a consumer with solid fuel burning appliance.
  8. begreen

    begreen Mooderator Staff Member

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    Smoke pollution doesn't respect state boundaries. This is a Fed issue when it can cause harm.
  9. heaterman

    heaterman Minister of Fire

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    The guys at Garn knew the testing protocol was retarded and the results were more than a little far fetched, to say the least. That is one reason they chose not to participate in the "voluntary" program. The other big reason was the the test protocol as it was written, was unable to accurately test boilers of any kind that are set up to use thermal storage. My gut tells me that if you see Garn agree to a test in the future, that test will be one you can bank on.
    I think that David Lunde, Martin's boy, was one of the first to submit some math to EPA showing them their numbers were either outright lies or else generated by aliens.
    Karl_northwind and Frozen Canuck like this.
  10. arbutus

    arbutus Feeling the Heat

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    Very respectfully, I believe the federal government lacks the constitutional power to establish pollution controls in the manner that has been established. The states can and should be managing this in cooperation with one another.

    We have the EPA and the EPA isn't going away, so we can hope that its policies, test methods, and regulations are truly beneficial, rather than incremental erosion of personal liberties.
    StihlHead and heaterman like this.
  11. heaterman

    heaterman Minister of Fire

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    Now THAT would be a concept that actually makes sense.......as such, it will never happen.
  12. John Ackerly

    John Ackerly Member

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    Glad to see this issue openly discussed here. Does Arborsite really ban folks for posting if they don't like the content? Who runs Arborsite?

    We put out something on this topic a month ago on our blog that adds a little bit of detail to what's been posted here. Haven't seen a link to it in discussion above: http://forgreenheat.blogspot.com/2013/05/epa-requests-outdoor-boiler-companies.html.

    OWB manufacturers were given a deadline of June 14 to remove all references to the discredited efficiency numbers not only on their websites, but also to discontinue use of any printed materials with this info that they, or their retailers have. I think EPA would appreciate hearing from folks if they see that companies are ignoring the June 14 deadline.

    john
    Chris Hoskin likes this.
  13. jebatty

    jebatty Minister of Fire

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    For anyone who thinks billowing smoke from an OWB, or any biomass burning appliance, is a private property right, I freely offer to terminate the stack of my former OWB into their house so that the smoke may be fully enjoyed in all of its richness, fragrance, and healthful benefits. And if that is not acceptable, then perhaps what would be acceptable is the concept that we all may freely exercise our private property rights so long as we do not infringe on the private property rights of others.

    While I would not endorse every governmental regulation as sound, supported by available data, and reasonable, I would say that regulation exists not for the purpose of prohibiting the free exercise of rights, but rather to allow the more free exercise of rights. For example, regulation requiring brakes on cars is not for the purpose of allowing cars to stop, but is for the purpose of encouraging the use of cars because they can stop. If cars did not have brakes, no one would drive a car.

    The same with biomass burning appliances. If there was no regulation of emissions, it wouldn't take long before no one would have their wood burner because the emissions would be so horrible that life as we know it could not survive. So emissions are regulated to low levels to encourage more use of wood burners. And as I said, I'm not saying that all EPA or other regulations are sound, but I am saying that emissions must be regulated so that citizens may freely exercise their private property rights to burn wood.

    Proven design and technology exists and is economically employed to greatly minimize the pollutants from wood burning appliances. If manufacturers choose not to use it, they have no private right to sell their product and they have no private property right to profit at the expense of the health and well being of others.
    FyreBug likes this.
  14. NE WOOD BURNER

    NE WOOD BURNER Minister of Fire

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    So again- The OWB concept is still a concept that many like the idea of.

    So if every indoor boiler company made an outdoor version and included additional storage wouldn't this be an advantage for sales?
  15. stee6043

    stee6043 Minister of Fire

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    I'm fortunate not to have any smoke dragons in the neighborhood but at the same time I find myself wondering what's worse - the OWB around the corner or the (10) diesel semi's parked idling at the rest area down the highway? Or on an even bigger scale do all the OWB's in this country combined, running for an entire year, emit as much "junk" into the air as the most recent Colorado wildfire?

    According to wiki in 2012 the fires that burned in Colorado consumed over 200,000 acres and over 600 homes. For round numbers lets say that is 200,000 cord of wood. And again, for round numbers, let's say every OWB uses 10 cord of wood per year. That's 20,000 OWB's worth of wood consumed in wild fires in one state, one year. Of course I know the wood isn't fully consumed in a wildfire but this is just an illustration for the sake of discussion.

    I'm not an advocate of irresonsible OWB use. But at the same time I'm not sure I agree that regulating them "in the name of the environment" makes a lot of sense given the scale on which this things operate compared to other issues we choose to ignore. I have absolutely no data to back this up but I'm guessing there is much, much lower hanging fruit available for the environmentalist if you look at diesel trucks, trains and heavy equipment vs the OWB crowd. But those other industries have substantial legal reserves and political lobbies as opposed to the relatively small wood burning market.

    My two cents only.
  16. jebatty

    jebatty Minister of Fire

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    Not quite. The traditional OWB is inherently inefficient and without substantial design changes, in the manner of gasification boiler design, cannot be made efficient. A firebox surrounded by water cannot produce an intense enough fire to be efficient and relatively pollution free. The steel walls will be around 212F keeping the fire "cool," allowing all sorts of unburned emissions. The addition of an intense heat secondary chamber insulated from the water, and then fire tubes to extract the heat from that intense secondary burn likely are essential. Also required is additional water storage to limit or eliminate cycling/idling and allow the fire to burn at a controlled high rate and absorb the btu output until the fuel is consumed.

    The Garn is an example of what might be considered a highly modified OWB that achieves high efficiency. The firebox is surrounded by water, but a large refractory holding the fire and a refractory, snaking fire tube through the large water storage tank achieves the intense high heat secondary burn, with the snaking fire tube continuing through the water to transfer heat to storage. The Garn also is designed to absorb a fuel load in a large batch burn without idling.

    A typical gasification boiler with sufficient external storage, in a shed to be outside, also works well and achieves the high efficiency without idling. My Tarm is inside, a 1000 gallon storage tank, and I typically burn for 4-6 hours, more than one load of wood, with no idling, as the tank rises to 190F, and then draw btu's from the tank for 2 days before another burn needs to take place during typical cold, MN winter weather.
  17. jebatty

    jebatty Minister of Fire

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    The "because someone else does something which is polluting and unhealthy, I should be able to do my polluting and unhealthy thing" is nonsense to me and illogical. No disagreement though that much needs to be done in many corners, including diesel trucks.

    We also have to deal with volcanoes, but is that a free ride for everyone to pollute as much as they wish? Not in my book.
    UMainah and Frozen Canuck like this.
  18. NE WOOD BURNER

    NE WOOD BURNER Minister of Fire

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    I recognize the differances. but the concept of having a boiler outside self contained is what CB and others are making money selling. I cant see why the indoor guys have not jumped aboard and start making them.

    Econoburn has one but cant be sold in NH. Garn is not an OWB.
  19. tronsliver

    tronsliver New Member

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    http://www.newsminer.com/news/local...cle_70ff3678-de37-11e2-86e0-0019bb30f31a.html

    This article has to do with two E-Classic 2300 OWBs that the state of Alaska was forced to intervene on. It underscores what I originally posted. I predict that eventually when this issue is completely fleshed-out there will be scrutiny of everyone involved in selling EPA qualified OWBs. Again, in my opinion, in 2010 when the EPA informed manufacturers that the efficiencies posted on their units were flawed and the manufacturers elected not to remove them, scores of people unknowingly purchased these units expecting something that is not possible. In the case presented here a consumer purchased the so called gasifer units in good faith only to find that they did not perform as promised. Keep in mind this was not a situation where the owner was burning materials outside the manufacture's recommendations. In fact, they tried retrofit devices, increased chimney heights etc. and it was all monitored by the state environmental department. The bottom-line: the unit did not function as advertised.

    The question becomes who is ultimately complicit or is there shared culpability? Since the EPA brought the efficiency problem to the attention of manufacturers, and they elected not to act, does it absolve the EPA? Did the manufacturers inform their dealers about the efficiency problem and/or should the dealers have known anyway based on their knowledge of the devices they were selling. It appears in the article that the defense attorney knows about the efficiency issue and is passing blame on industry. Based on a few comments from some of the dealers who visit these sites this was not an unknown phenomenon.

    Where does sizing come into play here? Should dealers be held responsible for selling oversized units to consumers when they know the square footage being heated is significantly less than the capability of the device. Should they be required to assess a home like air conditioning contractors do to ensure the unit is matched properly?

    When you look at this issue based on the law this is what manufactures and dealers would have to defend with respect to misrepresentation.

    Criteria for Misrepresentation
    Misrepresentation is one of several vitiating factors that can affect the validity of a contract. A misrepresentation occurs when one party makes a false statement, inducing another party to contract. For an action to be successful, some criteria must be met in order to prove a misrepresentation. These include:
    • A false statement of fact has been made,
    • The statement was directed at the suing party and
    • The statement had acted to induce the suing party to contract.
    I understand this is a difficult subject for some here but it is a subject with relevancy. Hopefully we can discuss the issue without dragging it and me into the gutter. This is what happened over at Arborsite. Interestingly, even though they banned me because they didn't like the content of what I posted, the topic is still alive.

    I believe OWBs are here to stay but I also feel that the devices should be advertised honestly. It is not lost on me that other industries dabble in misrepresentation also. Perhaps the difference here is the effect a poorly designed unit can have on others.
  20. If you explained your sudden interest in plastering your thoughts on the various woodburning oriented forums perhaps your message would go over better.


    Are you a 'victim' of CB, that was misled by the EPA test results? Are you considering a purchase? Have a neighbor with a smoke dragon? Dislike all burning of wood? Lawyer/Activist looking to sue Central Boiler for misrepresentation?

  21. A downdraft gasser with storage will never provide the simple plug and play of a typical OWB. Freeze protection also becomes an issue when batch burning.
  22. NE WOOD BURNER

    NE WOOD BURNER Minister of Fire

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    Tronsliver: So what is it you hope to happen? I believe the discussion is worthy.

    Clearly if you look at phase II approved OWB all of them state they where Batch tested. so yes they pass in controlled environment. Most if not all are run continuosly this method was not approved hence the reason I did not purchase. I could not find literature to hook a OWB to divorced storage so again I did not purchase. In my mind if I bought a white tag unit and installed based on legal setbacks and burned continuosly my money would be wasted as I did not purchase a legal appliance for this burning method. If I batch load and not idle I felt I would have a legal install. But again I did not find literature or a consumer to educate myself on hooking a white tagged OWB to storage. So this purchase has turned out to be a greator cost than I anticipated originally. But I do not feel I have been misled by any of the dealers I have spoke with IWB and OWB alike.


    I came here to the hearth and Wala there are other options as I envisioned building.

    Your wording in most if not all of your writing is directed @ CB My experience with my local CB dealer has not left me feeling I was misled. But I did not purchase a unit.
  23. NE WOOD BURNER

    NE WOOD BURNER Minister of Fire

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    I agree that is why CB has won the lions share of the market!


    If you seperate the downdraft gasser from the house circuit by utilizing a heat exchanger and add freeze protection(antifreeze) to just the boiler would this work?
  24. tronsliver

    tronsliver New Member

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    When this issue first came to my attention the only the letter provided was that from the EPA to CB. Although I suspected at the time that it was sent to all of them I did not know for sure. It appears now based on some of the comments posted it indeed was sent to all.
  25. Enough antifreeze to treat 1000 gallons of water is not cheap. And antifreeze has its own issues
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