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The EPA and conventional Outside Wood Boilers?

Post in 'The Boiler Room - Wood Boilers and Furnaces' started by fabguy01, Jun 9, 2009.

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  1. altheating

    altheating New Member

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    (20) salt water driftwood; or
    (21) any other fuel that is not recognized as an approved fuel pursuant to Section 247.4 of this Part.
    (c) No person shall cause or allow emissions of air contaminants from an outdoor wood boiler to the outdoor atmosphere of a quantity, characteristic or duration which is injurious to human, plant or animal life or to property, or which unreasonably interferes with the comfortable enjoyment of life or property. This prohibition applies, but is not limited to, the following conditions:
    (1) activating smoke detectors in neighboring structures;
    (2) impairing visibility on a public highway; or
    (3) causing a continuous visible plume migrating from an outdoor wood boiler and contacting a building on an adjacent property.
    The prohibition further applies to any particulate, fume, gas, mist, odor, smoke, vapor, pollen, toxic or deleterious emission, either alone or in combination with others, emitted from an outdoor wood boiler that results in the conditions or circumstances listed in this subdivision notwithstanding the existence of specific air quality standards or emission limits.
    (d) No person shall operate an outdoor wood boiler in such a manner as to create a smoke plume with an opacity of 20 percent or greater (six minute mean) except for one six-minute period per hour of not more than 27 percent opacity as determined using EPA Reference Method 9 (or equivalent) (see Table 1, Section 200.9 of this Title).
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    Section 247.4 Approved Fuels.
    (a) A person who operates an outdoor wood boiler may only burn the following fuels in such outdoor wood boiler:
    (1) clean wood;
    (2) wood pellets made from clean wood;
    (3) heating oil in compliance with Subpart 225-1 of this Title, L.P. gas or natural gas may be used as starter fuels for dual fuel-fired outdoor wood boilers;
    (4) non-glossy, non-colored papers, including newspaper, may be used only to start an outdoor wood boiler; and
    (5) other fuels approved by the department per the certification requirements of Section 247.8 of this Part.
    Section 247.5 Residential-Size New Outdoor Wood Boilers.
    (a) Emission limits. In order for a residential-size new outdoor wood boiler to be certified pursuant to Section 247.8 of this Part, it must not emit particulate emissions at a rate greater than a weighted average of 7.5 grams per hour using the year-round weighting factors in Test Method 28-OWHH (see Table 1, Section 200.9 of this Title). The particulate emission rate for any test run with a burn rate less than or equal to 1.5 kilograms per hour must not exceed 15.0 grams per hour. The particulate emission rate for any test run with a burn rate greater than 1.5 kilograms per hour must not exceed 18.0 grams per hour.
    (b) Setback. A residential-size new outdoor wood boiler shall not be located less than 100 feet from the nearest property line.
    (c)
    Stack height. A residential-size new outdoor wood boiler shall be equipped with a permanent
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    stack extending a minimum of eighteen (18) feet above ground level.
    Section 247.6 Commercial-Size New Outdoor Wood Boilers.
    (a) A commercial-size new outdoor wood boiler shall not be used in a solely residential application.
    (b) Emission limits. In order for a commercial-size new outdoor wood boiler to be certified pursuant to Section 247.8 of this Part, it must not emit particulate emissions at a rate greater than a weighted average of 10.0 grams per hour using the year-round weighting factors in Test Method 28-OWHH (see Table 1, Section 200.9 of this Title). Further, the particulate emission rate for any test run must not exceed 20.0 grams per hour.
    (c) Setbacks. A commercial-size new outdoor wood boiler shall not be located:
    (1) less than 150 feet from the nearest property line;
    (2) less than 300 feet from a property line of a residentially zoned property; and
    (3) less than 1000 feet from a school.
    (d) Stack height. A commercial-size new outdoor wood boiler shall be equipped with a permanent
    stack extending a minimum of eighteen (18) feet above ground level.
    Section 247.7 Permanent label.
    (a) A permanent label shall be affixed to all new outdoor wood boilers.
    (1) The label shall be made of a material that is sufficiently durable to last the lifetime of the new outdoor wood boiler.
    (2) The label shall be affixed to the new outdoor wood boiler in a readily visible or accessible location.
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    (3) The label shall be affixed in such a manner that it cannot be removed from the new outdoor wood boiler without causing damage to the label.
    (4) The following information shall be displayed on the label:
    (i) name and address of the manufacturer;
    (ii) date of manufacture;
    (iii) model name and number;
    (iv) serial number;
    (v) thermal output rating in Btu/h;
    (vi) list of approved fuels that may be burned in the new outdoor wood boiler;
    (vii) certified particulate emission rate in grams per hour.
    Section 247.8 Certification of new outdoor wood boilers.
    (a) Certified models. No person shall sell, lease or operate a new outdoor wood boiler unless the model has been certified by the department pursuant to this section.
    (b) Emission limits. In order to receive certification, a residential-size new outdoor wood boiler shall meet the emission limits in section 247.5 of this Part, and a commercial-size new outdoor wood boiler shall meet the emission limits in section 247.6 of this Part.
    (c) Application. Manufacturers requesting certification of a model shall submit an application to the department. An application shall consist of two complete copies of the application on a form provided by the department, along with two copies of the supporting documents required by this subdivision. Both copies of the application shall be signed by a responsible official of the manufacturer, and shall include the following:
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  2. altheating

    altheating New Member

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    (1) name and address of the manufacturer, the model name and number, serial number, date of manufacture and the thermal output rating, in Btu/h, of the new outdoor wood boiler tested;
    (2) four individual, color photographs of the tested unit showing the front, back and both sides of the unit;
    (3) engineering drawings and specifications for each of the following components:
    (i) firebox including a secondary combustion chamber;
    (ii) air induction systems;
    (iii) baffles;
    (iv) refractory and insulation materials;
    (v) catalysts;
    (vi) catalyst bypass mechanisms;
    (vii) flue gas exit;
    (viii) door and catalyst bypass gaskets;
    (ix) outer shielding and coverings;
    (x) fuel feed system; and
    (xi) blower motors and fan blade size.
    (4) final test report prepared by the testing laboratory; and
    (5) a copy of the operation and maintenance instructions.
    (d) Certificate of compliance. The department shall issue a certificate of compliance for a model if the certification application is determined to be complete and accurate and the model is determined to be compliant with the requirements set forth in this Part.
    (1) Only fuels listed in the certificate of compliance may be burned in the model.
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    (2) The certificate of compliance is valid for five years and shall expire on the date listed in the certificate unless it is renewed by the certificate holder.
    (3) A change in the design of a model resulting in a change in the thermal output rating of the model constitutes the creation of a new model which must be certified pursuant to this section.
    (4) Upon written notice to the certificate holder, a certificate may be withdrawn by the Department if it is determined that the application contained false or inaccurate information, or for other good cause.
    (e) Test method. To meet certification requirements for this section, particulate emissions from new outdoor wood boiler models shall be determined using Test Method 28-OWHH (see Table 1, Section 200.9 of this Title), as defined in paragraph 247.2(b)(14) of this Part.
    (f) Test laboratory. All certification testing shall be conducted by a laboratory accredited by the EPA in accordance with 40 CFR 60 Subpart AAA, Section 60.535 (see Table 1, Section 200.9 of this Title), or another accrediting organization approved by the department, which has no conflict of interest or financial gain in the outcome of the testing.
    Section 247.9 Notice to buyers.
    (a) 'Written notice.' Prior to the execution of a sale or lease agreement for a new outdoor wood boiler, the distributor shall provide the prospective buyer or lessee with a copy of this Part and a written notice which includes:
    (1) an acknowledgement that the buyer or lessee was provided with a copy of this Part;
    (2) a list of the approved fuels as set forth in Section 247.4 of this Part;
  3. altheating

    altheating New Member

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    and
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    (3) a statement that even if the requirements set forth in this Part are met, there may be conditions or locations in which the use of a new outdoor wood boiler interferes with another person’s use or enjoyment of property or even damages human health, and if such a situation occurs, the owner or lessee of the new outdoor wood boiler causing the situation may be subject to sanctions that can include a requirement to remove the device at their own expense, as well as any other penalty allowed by law.
    (b) ‘Completed notice.’
    (1) The written notice required by this section shall be signed and dated by the buyer or lessee and the distributor when the sale or lease of the new outdoor wood boiler is completed. In addition, the following information shall be included in the completed notice:
    (i) name and address of the owner or lessee of the new outdoor wood boiler;
    (ii) street address where the outdoor wood boiler was installed (if different from item (i) above);
    (iii) name of the manufacturer, model and date of manufacture of the new outdoor wood boiler;
    (iv) height of the permanent stack for the new outdoor wood boiler; and
    (v) distance from the new outdoor wood boiler to the nearest property line.
    (2) The distributor shall submit the original signed copy of the notice to the department’s regional office for the location where the new outdoor wood boiler is installed or as otherwise specified by the department within seven (7) days of making delivery of the new outdoor wood boiler to the buyer or lessee.
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    Section 247.10 Requirements for existing outdoor wood boilers.
    (a) Effective October 1, 2010, all existing outdoor wood boilers shall be equipped with a permanent stack extending a minimum of eighteen (18) feet above ground level.
    (b) No person shall operate an existing outdoor wood boiler between April 15 and September 30 of each year, except as follows:
    (1) An existing outdoor wood boiler that is a model certified by the department pursuant to Section 247.8 of this Part and sited 100 feet or more from the nearest property line is not subject to this subdivision;
    (2) An existing outdoor wood boiler sited 500 feet or more from the nearest property line and 1000 feet or more from a school is not subject to this subdivision; or
    (3) An existing outdoor wood boiler located on contiguous agricultural lands larger than five acres and sited 500 feet or more from the nearest residence not served by the existing outdoor wood boiler or 500 feet or more from a property line that is not on agricultural land and 1000 feet or more from a school is not subject to this subdivision.
    Section 247.11 Severability.
    Each provision of this Part shall be deemed severable, and in the event that any provision of this Part is held to be invalid, the remainder of this Part shall continue in full force and effect.



    Kind of a long way to get this posted , but it is what it is. A contact has heard that NYS may push this through as soon as Oct 1st of this year.
  4. stee6043

    stee6043 Minister of Fire

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    I'd love to see the device that consistently and accurately measures smoke opacity in varying light conditions outside....
  5. Wet1

    Wet1 Minister of Fire

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    It's called a pissed-off neighbor... okay maybe it's not all that accurate.
  6. altheating

    altheating New Member

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    And who is going to get certified to operate such device?
  7. stee6043

    stee6043 Minister of Fire

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    Ha....but when properly calibrated it can be very effective...
  8. smokywoodmaster

    smokywoodmaster New Member

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  9. Gooserider

    Gooserider Mod Emeritus

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    As an interesting question, what does this kind of regulation imply for those folks that are doing "Garn Barns" or a similar outdoor structure for a gasifier like an EKO or Econoburn that doesn't quite meet the description / definition for an OWB (not specifically designed for outdoor use, doesn't come with a shed enclosure, etc...)? Yes the units are clean, but would they have the certifications that are required for an OWB? Would they be needed? - I'd be worried that someone was doing a gasser in a shed, and a code person would say that it's the equivalent of an OWB, and no you can't do that because it doesn't have an OWB certification....

    Gooserider
  10. altheating

    altheating New Member

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    New York State has already addressed this issue. The NYS codes reads something like this. The definition of an OWB is any devise located in a structure not attached to the structure being heated with such devise. Some people have attempted to take the OWB's to a different level by placing the traditional OWB into a building thinking that because it was situated inside it is no longer concidered an OWB, well New York State addressed that too. The state code reads, any wood burning devise must be independent lab tested and labeled for indoor installation. Any OWB must also be tested and labeled for outdoor installation. There were a few OWB's that were deemed illegal for installation in New York State a few years ago. I know of no OWB that is labeled for inside installation at this time. As far as the certifications on the Eko and Econoburn goes, they are certified for indoor installs, but the codes still says they are OWB's if they heat a structure adjacent to the building they are in. Of course it makes no sense as they would be buring the same amount of firewood as if they were placed inside the home, where they are perfectly legal to install. I spent many hours at town meetings as well as many hours on the phone with the codes people in Albany a few years ago, talking with most of these people, most of them not having a clue.
  11. Gooserider

    Gooserider Mod Emeritus

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    Not quite sure I follow you AH - I understand about the code definition of an OWB, and that makes sense; but it isn't quite clear to me if you are saying that an indoor listed boiler in an outbuilding would be legal or not?

    (Not that it matters a great deal to me since I'm not in NY, and am thinking indoor installation regardless, but... Of course MA screws you over in other ways instead, that I've mentioned elsewhere)

    Gooserider
  12. crs7200

    crs7200 Member

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    I've seen this same basic discussion in here so many times, I can almost tell who will reply and what they will say.

    Same old stuff. OWB are bad. smoke a lot, burn too much wood, create too much pollution.

    Everything is going to be outlawed by the EPA because our elected officials, who wouldn't know the difference if the smoke was coming from a stove or their fat round cigars.

    I know people that heat with everything from a OWB, gassifier, coal stove, fireplace insert, oil/wood/ combo's, just about everything.

    You know what I have found to be the absolute truth is this...
    .......I don't care what you burn or how much it smokes out your neighbors, if it comes from a chimney that comes out of your house, NO ONE CARES. They all look the other way. No codes officers are called, no tickets are issued, and the burning and smoking goes on without a care.

    BUT !!!!!!...................... have a stove that is outside, burn nothing but seasoned wood, create less to almost NO smoke and some tree hugger that drives their hybrid (below 30mph of course) will say that you are the enemy of all the people who want nothing more than to breath clean air. All because they see your OWB and think they know it all.
    REGARDLESS of having to prove time and time again that it is not me making the smoke but my neighbor who has a woodstove that smokes likes crazy, I am always the first person they point fingers at.

    Finally after the first 2 years, they all know that it isn't me. The only good thing that has come from this is that my local government officials have learned alot about OWB from me and that they are not the enemy of the state.

    I've heard about (and know of some) that burn garbage and other items. Most of the ones that I have seen do this, do it from their stoves inside their houses.
  13. heaterman

    heaterman Minister of Fire

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    What I'm wondering is what happens in a case where an indoor rated boiler (IE, Garn, Eko, Econoburn etc.) is used to heat multiple buildings. As the NewYork regs state, the unit must be installed in the building being heated. So what if the owner wants to use the boiler for multiple tasks/ buildings?
  14. dogwood

    dogwood Minister of Fire

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    Out here in the western part Virginia a lot of people have plain old wood stoves for heat and the wealthier amongst us may have an OWB. It can get mighty smoky in the winter months. However there will be no bans here I suspect, since we have adapted to breathing a 50% smoke to air mix. Problems with wood smoke are relatively trifling. About fifteen years ago it took the whole community to prevent the local cement company from converting over to burning radioactive waste. That's the truth. Think about how that would affect your property value. Relatively speaking what's a little smoke? We're lucky not to be glowing in the dark.

    Mike
  15. greeninsulation

    greeninsulation New Member

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    AS a national factory direct distributor of Sequoyah and Wood Doctor, and have had an OWHH for 10 years I have heard/seen it all. I know that people will burn trash and cause the clean WHITE tag units to smoke and I know that my older Wood Doctor burns extremly clean. The newer gasification units are designed to help keep the environment cleaner but it depends upon the operator. The higher efficiency, longer burn times, less wood consumed are huge benefits for the gasifiers. I always spend a lot of time talking with potential customers in states that have options discussing the pros/cons of gasification furnaces. For more information on these units, and a video please see. www.woodgasificationfurnace.com or www.mainewooddoctor.com
  16. lawandorder

    lawandorder Member

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    So with all of this in mind what happens to the OWB that are already installed or which will be installed prior to the new regulations in New York State
  17. altheating

    altheating New Member

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  18. heaterman

    heaterman Minister of Fire

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    Geepers! What about someone with a lot that's less than 300x300' ? Did I read correctly that existing OWB's have to have an 18' stack? What the heck do they think a stack is going to do in the first place?
  19. Gooserider

    Gooserider Mod Emeritus

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    Presumably the idea is that if you have a small lot, you shouldn't be running an OWB... Get some other alternative. This doesn't seem totally unreasonable given that most of the fuss about OWB's comes from ones located in crowded areas, and generally speaking small lots are usually only found in crowded areas.

    The 18' stack is also looking at the same issue - a lot of the complaints are because the OWB smoke hugs the ground and floats around where people are standing. An 18' minimum stack gets the smoke up to a height similar to that of a short house, say a slab built ranch, so that the smoke has more of a chance to dissipate before it gets to ground level. Also if you look at "microclimates" it is not uncommon for there to be a thermal inversion layer close to the ground, smoke in that layer tends to be trapped and stay there, while smoke above it tends to go up and away - the tall stack helps in that regard...

    One might not like the regs, but there actually is some level of logic to them.

    Gooserider
  20. lawandorder

    lawandorder Member

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    So do current OWBs have to meet the requirments when the legislation is passed or do they just stay as is???
  21. heaterman

    heaterman Minister of Fire

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    Unless I read it wrong it looks like at least the stack height issue is retroactive and would apply to anything currently installed also.

    Section 247-3.3 Setback and Stack Height Requirements.
    (a) Stack height requirement. An existing outdoor wood boiler must be equipped with a permanent
    stack extending a minimum of eighteen (18) feet above ground level effective October 1, 2008.
    (b) Setback requirement. An existing outdoor wood boiler that does not meet the requirements set
    forth in Section 247-2.2(a) or Section 247-2.3(a) of this Part which is sited less than 500 feet from the nearest
    property line must be removed or rendered inoperable by September 30, 2010.
  22. heaterman

    heaterman Minister of Fire

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    Things are going to get interesting..........
  23. altheating

    altheating New Member

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    In all reality I think you will see little effect on currently installed boilers, UNLESS they are causing air quality issues with your neighbors. If that occurs I think you will see enforcement including cour orders to shut them down. I have heard that once a court order is issued a fine of $500 per day can be imposed to the homeowner for each day the unit remains in operation. Current DEC regulations cover offensive smoke emissions, but are rarely enforced. The new setback limits will reduce the number of people who will be able to install them.
  24. lawandorder

    lawandorder Member

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    Thats what I was thinking but I wasnt sure if I was interpreting it correctly Thats a big one on the Setback requirements.
  25. hoogie

    hoogie Member

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    all you guys make really good points i have a neighbors that are less than 300 feet away, my next door neighbor has a reg. owb the unit i just bought is a gasser, the reason that i choose that route is that i was afraid that with two regular units side by side someone would complain even though nobody has yet. Also to mention the ban on reg. owbs here in Indiana has been rumored for the last yr. i choose to run with the epa cert. white and orange tag unit....But like everyone one here knows inside or outside if ya burn crap thats whats gonna come outta your pipe....i would think with the added cost of a gasser that someone would not void there warranty with burnin crap....just my two cents worth....charlie...
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