Heavy reading but worth it......

[heaterman]

I think this should be required reading for anyone considering a new wood burner that is supposedly a "clean" unit. The document listed in the link is the actual test method used to establish the efficiency and the emissions of any wood burning hydronic heater, open or closed system, that a manufacturer wants to list. If you read through it, you will see that the specs generated are possible only with the use of a storage medium large enough to harvest the heat from an entire load without going into idle mode. At least that's the way I read it.
I have never seen an OWB operated in that manner and I would guess that few have.
Note also that the test does not take into account jacket loses. Hmmm, think there are any of those from a tank of 180* water sitting outside at -10*???? How does that relate to actual operating conditions?
Then there's the whole thing of the cribbed/stickered wood pile at a guaranteed MC........ and the number themselves. If a person takes the btu output and the grams per hour per 10,000 btu output and factors it up to the listed emissions per million btu, they don't match. What's up with that?

Sadly, I don't know where this leaves anyone looking at the yellow or white EPA sticker while considering a new wood burner. IMHO there is no way a person using any of these units can expect to see results approximating what is shown on the test reports.

(broken link removed to http://www.epa.gov/ttn/emc/prelim/otm15.pdf)

 

[sdrobertson]

Wow...the only good thing I see out of that EPA guide is they do re-enforce the principle of dry wood. Its taken a while but I think I've finally gotten it.

 

[shagy]

You have some good points Heaterman. Havent had time yet to read the whole thing but I sure am glad ya posted it.The heat loss is a big one. Both off stove and lines under ground. The ? is how do ya fix it? At this point 5 or 6 states are basing their regulations on the EPA results.Looks like NY and PA will also adapt this method as a guideline. Rumor is April 2012 all stoves will have to meet Phase 2 . In your humble opinion .... What are your thoughts of Econoburns attempt at outdoor furnaces?

 

[heaterman]

You have some good points Heaterman. Havent had time yet to read the whole thing but I sure am glad ya posted it.The heat loss is a big one. Both off stove and lines under ground. The ? is how do ya fix it? At this point 5 or 6 states are basing their regulations on the EPA results.Looks like NY and PA will also adapt this method as a guideline. Rumor is April 2012 all stoves will have to meet Phase 2 . In your humble opinion .... What are your thoughts of Econoburns attempt at outdoor furnaces?

I have not seen one so I can't comment on it specifically. Speaking generally, other models from them that I have worked with were of good design and constructed well.

My personal opinion is that any and all heating equipment should be located inside a conditioned space. Period. Makes no sense to me to place a heating unit in ambient temperatures that can reach well below zero. Color me stubborn.

 

[Jim K in PA]

There is an alternative testing protocol that is far more rational. ASTM E2618. Standard Test Method for Measurement of Particulate Emissions and Heating Efficiency of Outdoor Solid Fuel-Fired Hydronic Heating Appliances.

Of most relevence it the following section of the Scope:

1.2 The test method simulates hand loading of seasoned cordwood or fueling with a specified biomass fuel and measures particulate emissions and delivered heating efficiency at specified heat output rates based on the appliance’s rated heating capacity.

It is far harder to un-adopt a poor standard than it is to promote and adopt a good standard. Folks need to talk to their legislators in those states considering adopting the current EPA standard. The EPA may adopt the ASTM as an alternate test method, which would be a logical move. But logic and the EPA are strange bedfellows.

 

[shagy]

There is an alternative testing protocol that is far more rational. ASTM E2618. Standard Test Method for Measurement of Particulate Emissions and Heating Efficiency of Outdoor Solid Fuel-Fired Hydronic Heating Appliances.

Of most relevence it the following section of the Scope:

1.2 The test method simulates hand loading of seasoned cordwood or fueling with a specified biomass fuel and measures particulate emissions and delivered heating efficiency at specified heat output rates based on the appliance’s rated heating capacity.

It is far harder to un-adopt a poor standard than it is to promote and adopt a good standard. Folks need to talk to their legislators in those states considering adopting the current EPA standard. The EPA may adopt the ASTM as an alternate test method, which would be a logical move. But logic and the EPA are strange bedfellows.

You got the part of getting the Gov to repeal a decision and to adapt a new one is next to impossible. Good luck to us all. To your or anyone out there....Is there any furnaces inside or out testing and making public the results using the ASTM procedure?Is it going to be possible to test indoor and outdoor stoves with the same testing procedure? As much as some would like the outdoor manufactures to go away... It aint going to happen. They are here to stay. Ya know Mark Twain said "Common sense isn't so common"

 

[ken999]

What does an OWB sitting outside have ANYTHING to do with how clean it burns?

If there is an issue, does putting it in an insulated shed nullify any issue?

Unless I'm mistaken, there are quiet a few people who run indoor gassers without storage. They often idle. How is that different than a CB or other OWB gasser?

Currently, with the warmer weather I'm only fireing when I'm home with my 2300. I guess you could say that I'm charging my little outdoor 450 gal. storage tank to get me through the next 12 hours...

I'll be the first to admit that the combination of DD gasser and storage creating wide open burns with no idle is the most efficient and clean, but I'll bet that there are ALOT of applications like mine where an OWB gasser will be decent choice.

 

[heaterman]

What does an OWB sitting outside have ANYTHING to do with how clean it burns?
Very little with how clean it burns but there is a lot of heat loss going on that is not noticed in most cases.

If there is an issue, does putting it in an insulated shed nullify any issue?
Putting any heating system in an insulated enclosure will greatly reduce standby heat loss. Doesn't matter if it's fired by wood, oil or gas. All those roof top Heat&A/C units on top of commercial buildings are rated at 80% eff but in real life they drop down to about 65-70 when you factor in the jacket losses.

Unless I'm mistaken, there are quiet a few people who run indoor gassers without storage. They often idle. How is that different than a CB or other OWB gasser? Exactly! You hit the nail on the head. There is little difference in off cycle performance between an OWB and a DD gasser (if they were both sitting outside.)

Currently, with the warmer weather I'm only fireing when I'm home with my 2300. I guess you could say that I'm charging my little outdoor 450 gal. storage tank to get me through the next 12 hours...

I'll be the first to admit that the combination of DD gasser and storage creating wide open burns with no idle is the most efficient and clean, but I'll bet that there are ALOT of applications like mine where an OWB gasser will be decent choice.

I won't dispute that an OWB is often the only viable option to many folks. What grinds me is the blatantly false ratings from EPA and the ensuing manufacturers hype. Witness HeatMor's claim of 99% efficiency.

 

[ihookem]

I am sure my EKO is 80% efficiency. For 2 days I weighed my wood and found the btu's for the wood I burned. In that 2 days I figured the btu's my house should have used. My figures showed I needed 30k btu per hr. avrerage for 2days (1,400,000 btu) I burned 205 pounds of dry wood with 1.8 million btu for an avr. of 80 %. I was satisfied for a no storage unit. I don't know how I can do better unless I put it in the basement. EPA or not This is exceptable to me. Does this make sense?

 

[Piker]

What does an OWB sitting outside have ANYTHING to do with how clean it burns?

Nothing, except for any issues there may or may not be with regard to insulation of the unit and/or underground pipe and dry storage for the fuel... some of the same issues we face with indoor downdrafts installed apart from the living space. I believe that public skepticism lies in how we have stereotyped outdoor wood boilers... and perhaps with good reason given the last 20 years of unadulterated waste and pollution. It's going to take a lot of time, some new cutting edge equipment, and a few good installers to undo what's been done. Personally, I can't stand to see an OWB in the middle of winter with snow melted within a 15' radius of the 500° doors. Are you serious? Who thinks this is a good idea?

The bottom line is... a clean burning, efficient unit is only as clean and efficient as A) the system it's hooked to allows it to be... and B) the guy who's throwing the wood in allows it to be.

Storage of some type makes all the difference in the world with regard to emissions... this is why some of the OWB boilers with 400 or 500 gallons of water on board do so much better on the particulate emissions tests than the gasifiers without storage. You would have to skew the tests something fierce to get an ultra low particulate count on that test without storage... A typical downdraft might have 15 or 20 times the particulate emissions when run without storage as compared to being run with storage (depending on what stage of the test you're looking at.)

At some point, someone at the EPA is going to get smart and realize that there's no such thing as an uber-clean wood burning appliance without thermal storage of some sort... at that point, what do they do? Attempt to mandate thermal storage? Who knows...

cheers.

 

[ken999]

I've followed along on some of your previous posts about what it actually takes to approach 100% efficiency with these types of boilers and it ceratinly made sense to me what you were saying, so ya...I'm a little skeptical of claims like that one.

"Sadly, I don’t know where this leaves anyone looking at the yellow or white EPA sticker while considering a new wood burner. IMHO there is no way a person using any of these units can expect to see results approximating what is shown on the test reports. "


What it really comes down to is...can these units be neighbor friendly? After all, PO'd neighbors, thick plumes of smoke choking out entire valleys etc. are why we are in this whole EPA dance. If that's the testing method they came up with, so be it, as long as it is critical enough to seperate the dirty units from the 'clean' ones. In the end you can't do any more than put a capable unit in someones hands and hope that they run it well enough to not have 1/2 the town up in arms.

I'm quiet certain that if there were enough clowns running EKO's (insert any brand here...) poorly with wet wood and tons of idle time, then sombody would write some laws against that type of boiler once the smoke started rolling. Whether or not a unit hit 92% or 99% on the EPA test doesn't mean squat unless the end user does his or her part to run it the best they can with the set-up they have.

At any rate, I'm certainly glad we have been weened off the middle eastern oil teet with the E-Classic. No more 200 gal a month fill ups all winter long...if I can get 10 years outta the tin box, it'll have saved me enough to install that Garn I've been dreaming about...lol...

 

[ken999]

I agree on all points Piker.

I've wondered about the potential to mandate storage. I doubt they will get there, but the thoughts crossed my mind.

Heck I'm just tickled to see Econoburn spec'ing no less than 1 1/4" line for there new OWB. I always hear people with OWB say, " the bigger stuff was too expensive so I went with the 1". Then they wonder why things aren't working too well and they are buring tons of wood for nothing.

Hopefully all the manufactures get on board with the 'education' of their perspective customers. That'll go along way in itself.

 

[heaterman]

I agree on all points Piker.

I've wondered about the potential to mandate storage. I doubt they will get there, but the thoughts crossed my mind.

Heck I'm just tickled to see Econoburn spec'ing no less than 1 1/4" line for there new OWB. I always hear people with OWB say, " the bigger stuff was too expensive so I went with the 1". Then they wonder why things aren't working too well and they are buring tons of wood for nothing.

Hopefully all the manufactures get on board with the 'education' of their perspective customers. That'll go along way in itself.

In Europe, which is a tad more "enlightened" than we are here, a person can get really decent tax credits for installing a wood or bio-mass heating system but only if the utilize storage. They will let you install without but the credits are not available if you do so. Maybe something like that would work here too.

It's about time someone stepped up to the plate and tried to dispel the mythical capabilities of 1" pex. Glad to see Econoburn taking the lead on this. It may cost them some sales but they will be assured that their units will be running optimally for their customers.

 

[Piker]

I agree on all points Piker.

I've wondered about the potential to mandate storage. I doubt they will get there, but the thoughts crossed my mind.

Heck I'm just tickled to see Econoburn spec'ing no less than 1 1/4" line for there new OWB. I always hear people with OWB say, " the bigger stuff was too expensive so I went with the 1". Then they wonder why things aren't working too well and they are buring tons of wood for nothing.

Hopefully all the manufactures get on board with the 'education' of their perspective customers. That'll go along way in itself.

In Europe, which is a tad more "enlightened" than we are here, a person can get really decent tax credits for installing a wood or bio-mass heating system but only if the utilize storage. They will let you install without but the credits are not available if you do so. Maybe something like that would work here too.

It's about time someone stepped up to the plate and tried to dispel the mythical capabilities of 1" pex. Glad to see Econoburn taking the lead on this. It may cost them some sales but they will be assured that their units will be running optimally for their customers.

The tax credits for biomass in the states are pretty lame compared to what wind and solar get... and what's worse, the biomass equipment generally still yields a much better return on investment even without the tax incentives. At one time I had thought about getting on board the wind and solar bandwagon, but soon realized that once the gov't money dried up there would be zero business.


Specifying the larger line will definitely diminish calls to the factory regarding heat output. Just to make things clear though, 1" line does have it's place in some outdoor installations. Remember that the btu's that you can deliver through any given size pipe isn't just a function of flow rate, but also delta T... a big enough water to air heat exchanger can give you a handsome delta T, which will transfer many more Btu's... making 1" line do-able in - not all - but many circumstances. Just wanted to make sure we didn't start a myth that 1" pex is useless under all circumstances.

Cheers

 

[ken999]

Well, I'm pretty glad the 2300 came with a credit. Had there been an ADDITIONAL credit for storage I would have looked a little harder at an indoor unit w/ storage.

I think the Econoburns will do well in OWB mode. Sure they are going to loose some heat to due to exposure, but they will work well enough and have alot of WOW factor when openening the gas door for show and tell with the buddies...once they get a few out and about, they should do OK.

 

[Piker]

Well, I'm pretty glad the 2300 came with a credit. Had there been an ADDITIONAL credit for storage I would have looked a little harder at an indoor unit w/ storage.

I think the Econoburns will do well in OWB mode. Sure they are going to loose some heat to due to exposure, but they will work well enough and have alot of WOW factor when openening the gas door for show and tell with the buddies...once they get a few out and about, they should do OK.

Just a side note for anyone who's interested... opening the bottom door on a downdraft while gasifying wreaks havoc on your refractory. If you think about it... a 2000 degree stone that get's hit with 70° air when you open the door is going to experience some stress. That having been said... who can resist the temptation to peek once in a while?

cheers

 

[heaterman]

I agree on all points Piker.

I've wondered about the potential to mandate storage. I doubt they will get there, but the thoughts crossed my mind.

Heck I'm just tickled to see Econoburn spec'ing no less than 1 1/4" line for there new OWB. I always hear people with OWB say, " the bigger stuff was too expensive so I went with the 1". Then they wonder why things aren't working too well and they are buring tons of wood for nothing.

Hopefully all the manufactures get on board with the 'education' of their perspective customers. That'll go along way in itself.

In Europe, which is a tad more "enlightened" than we are here, a person can get really decent tax credits for installing a wood or bio-mass heating system but only if the utilize storage. They will let you install without but the credits are not available if you do so. Maybe something like that would work here too.

It's about time someone stepped up to the plate and tried to dispel the mythical capabilities of 1" pex. Glad to see Econoburn taking the lead on this. It may cost them some sales but they will be assured that their units will be running optimally for their customers.

The tax credits for biomass in the states are pretty lame compared to what wind and solar get... and what's worse, the biomass equipment generally still yields a much better return on investment even without the tax incentives. At one time I had thought about getting on board the wind and solar bandwagon, but soon realized that once the gov't money dried up there would be zero business.


Specifying the larger line will definitely diminish calls to the factory regarding heat output. Just to make things clear though, 1" line does have it's place in some outdoor installations. Remember that the btu's that you can deliver through any given size pipe isn't just a function of flow rate, but also delta T... a big enough water to air heat exchanger can give you a handsome delta T, which will transfer many more Btu's... making 1" line do-able in - not all - but many circumstances. Just wanted to make sure we didn't start a myth that 1" pex is useless under all circumstances.

Cheers

I agree that 1" line has its place. The problem I see on a consistent basis is that people buy it just becuse the sales guy told them it was all they needed. No heat loss done, no HX sizing, no consideration of run length............I could go on. 1" has become the default option and I have to say that even in residential applications, it's probably correct less than half the time. We have saved more than a few underground jobs by upsizing the HX installed in the furnace. Seems that's another area where corners are cut to save cost and hassle. The sizing method I usually see would go like this......... ....Salesman, "How big is your plenum"? ....Customer... "It measures 18x20"...... Salesman..."Well then that's the size heat exchanger you need for the job!!".

I'm sorry, but..........DOH!

 

[Piker]

I agree on all points Piker.

I've wondered about the potential to mandate storage. I doubt they will get there, but the thoughts crossed my mind.

Heck I'm just tickled to see Econoburn spec'ing no less than 1 1/4" line for there new OWB. I always hear people with OWB say, " the bigger stuff was too expensive so I went with the 1". Then they wonder why things aren't working too well and they are buring tons of wood for nothing.

Hopefully all the manufactures get on board with the 'education' of their perspective customers. That'll go along way in itself.

In Europe, which is a tad more "enlightened" than we are here, a person can get really decent tax credits for installing a wood or bio-mass heating system but only if the utilize storage. They will let you install without but the credits are not available if you do so. Maybe something like that would work here too.

It's about time someone stepped up to the plate and tried to dispel the mythical capabilities of 1" pex. Glad to see Econoburn taking the lead on this. It may cost them some sales but they will be assured that their units will be running optimally for their customers.

The tax credits for biomass in the states are pretty lame compared to what wind and solar get... and what's worse, the biomass equipment generally still yields a much better return on investment even without the tax incentives. At one time I had thought about getting on board the wind and solar bandwagon, but soon realized that once the gov't money dried up there would be zero business.


Specifying the larger line will definitely diminish calls to the factory regarding heat output. Just to make things clear though, 1" line does have it's place in some outdoor installations. Remember that the btu's that you can deliver through any given size pipe isn't just a function of flow rate, but also delta T... a big enough water to air heat exchanger can give you a handsome delta T, which will transfer many more Btu's... making 1" line do-able in - not all - but many circumstances. Just wanted to make sure we didn't start a myth that 1" pex is useless under all circumstances.

Cheers

I agree that 1" line has its place. The problem I see on a consistent basis is that people buy it just becuse the sales guy told them it was all they needed. No heat loss done, no HX sizing, no consideration of run length............I could go on. 1" has become the default option and I have to say that even in residential applications, it's probably correct less than half the time. We have saved more than a few underground jobs by upsizing the HX installed in the furnace. Seems that's another area where corners are cut to save cost and hassle. The sizing method I usually see would go like this......... ....Salesman, "How big is your plenum"? ....Customer... "It measures 18x20"...... Salesman..."Well then that's the size heat exchanger you need for the job!!".

I'm sorry, but..........DOH!

It's not really all that funny, but I AM laughing... you nailed it for sure.

cheers

 

[ken999]

I don't know a whole lot about sizing and am certainly no pro, but our office at work is 6000 sq. ft. Running a 5500 woodmaster on cheap junk 1" line (about 30'), the contractor then added a 30 plate HX (330k BTU IIRC).

Was there any doubt that we were not going to get much heat when the temps started dipping to -10? I finally talked the boss into turning the boiler up to 185 from 165...That helped SOME but....Back when our boiler was installed (we skipped the HX and went direct) I was trying to decide between a 50 and 70 plate, so I figured the 30 was going to be a little small.

It is.

 

[shagy]

I don't know a whole lot about sizing and am certainly no pro, but our office at work is 6000 sq. ft. Running a 5500 woodmaster on cheap junk 1" line (about 30'), the contractor then added a 30 plate HX (330k BTU IIRC).

Was there any doubt that we were not going to get much heat when the temps started dipping to -10? I finally talked the boss into turning the boiler up to 185 from 165...That helped SOME but....Back when our boiler was installed (we skipped the HX and went direct) I was trying to decide between a 50 and 70 plate, so I figured the 30 was going to be a little small.

It is.

Yep..... To small . The problem with many both indoor and outdoor dealers is they are just someone that decided that they could sell a certain brand and company's hand them a dealership. They may not be able to put lago blocks together but get a dealership !

 

[Jim K in PA]

...

What it really comes down to is...can these units be neighbor friendly? After all, PO'd neighbors, thick plumes of smoke choking out entire valleys etc. are why we are in this whole EPA dance. If that's the testing method they came up with, so be it, as long as it is critical enough to seperate the dirty units from the 'clean' ones. In the end you can't do any more than put a capable unit in someones hands and hope that they run it well enough to not have 1/2 the town up in arms.

...

Therein lies the conundrum, Ken. The current requirement does not seperate the dirty from the clean. The EPA test method uses a fuel configuration (milled, spaced "crib" wood) that is unlike anything a "typical" user will employ. You can build a unit to pass the EPA test, but the design will be inappropriate for randomly stacked cordwood. So you build a unit that passes an inappropriate test, and in real world use it works poorly! The ASTM test gets much closer to a real world simulation, and provides worthwhile data to the consumer.

Perhaps the best hope is that the EPA can be convinced to incorporate the ASTM protocol in addition to the existing protocol. Then a manufacturer has the option of choosing with method is best for their given design. A DD gassifier is a different beast than a GARN, and both are very different from an OWB. You cannot realistically make a one-size-fits-all test for these devices.

 

[shagy]

Jim... just looked at your install... Quit the project. I would be interested in how much moisture is in your insulation in the ground. I wish I had taken a pic of a line that was spayed with high dencity foam. The pic would have been me squeezing the water out of it. Other than that you did a profesional job

 

[heaterman]

Thanks for getting this thread back on track Jim. The purpose I had in mind in starting this thread is not to bash product or people.
Unscrupulous dealers and poorly designed product are a fact of life and the customer can control them to a certain extent if he/she takes a little time to research what they are buying. My desire in bringing this up was to help people learn about the EPA test method and how it relates to what they can expect to see. I know that both you and I have seen pictures of a Phase II compliant unit belching smoke like a steam engine with tar running out the loading door but there are a TON of people who haven't. They look at the yellow or white tag and assume the unit, being officially blessed by the EPA, is going to burn clean and not smoke out the neighbors. Many are going to find, to their great dismay that this is not the case. So are their neighbors and this is going to create major problems down the road. Think of it from the standpoint of a bureaucrat who is getting complaints and also seeing that the unit involved is supposedly clean and labeled as such. What are his options? He's basically down to an outright ban at this point........and that is not where we want to be.

I think that my goals in this thread are as follow:

A: to simply make people aware that the EPA test protocol is a very poor representation of real world performance

B: encourage people to write or e-mail the EPA and suggest, ask, beg, demand that a valid testing method be established.

C: write to all the OWB manufacturers and ask them to design, build and bring to market, products that are truly clean burning. Stop hiding behind a test method that is a farce.

D: help everyone who burns wood to realize that the practice of using wood for heating fuel is getting looked at very closely by people who are very high in the food chain of our government. They have the ability and the power to put measures in place that will be very detrimental to anyone who burns or wants to burn wood.

The name of the person in charge of the test program at EPA is Gil Wood and his e-mail address is [email protected]
I would ask that everyone reading this take a few minutes to drop him a line and ask that the EPA adopt the ASTM test method for certification of emissions and efficiency. Let him know that you are concerned with the future of wood burning, misleading manufacturers statements, information that makes no sense ...etc.
Keep your correspondence civil and polite.

We as a group need to let the people in the ivory tower at Research Triangle Park know that we are tired of poorly performing equipment and would like to see things done right.

We neglect these issues at our own peril.

 

[ken999]

Therein lies the conundrum, Ken. The current requirement does not seperate the dirty from the clean. The EPA test method uses a fuel configuration (milled, spaced "crib" wood) that is unlike anything a "typical" user will employ. You can build a unit to pass the EPA test, but the design will be inappropriate for randomly stacked cordwood. So you build a unit that passes an inappropriate test, and in real world use it works poorly! The ASTM test gets much closer to a real world simulation, and provides worthwhile data to the consumer.

Perhaps the best hope is that the EPA can be convinced to incorporate the ASTM protocol in addition to the existing protocol. Then a manufacturer has the option of choosing with method is best for their given design. A DD gassifier is a different beast than a GARN, and both are very different from an OWB. You cannot realistically make a one-size-fits-all test for these devices.

I'm not sure how stacking the wood in any given unit has a whole lot to do with how clean it burns. Stacking, spacing, cribbing, milled wood etc. seems to me like an attempt to remove some abiguity from the test method for repetitions sake. Should units be tested with 'real world wood'? Sure. Will it make a LOT of difference? Maybe...I'd be interested to see some data. I'm in total agreement that we should be using solid, comprehensive testing methods that will effectively guage how well the untis will perform as designed by each individual boiler. If that's not feasble or possible, then we should strive for a decent comprimise that still gives decent 'real world' numbers.

In the end though, a test is a test is a test. It's all going to be up to the operator. The majority of the units (OWB, Garn, Tarm etc.) have the ability to burn badly. I'm sure some E-Classic owners are not running there units as designed and instructed....and they probably are smoking things up pretty good...and in the end maybe it will turn into a law enforcement issue based on neighbors complaints, but at least with the compliant models we have a starting point.

What's the European standard? How do they test?

 

[heaterman]

True that they were trying to provide a common denominator for all units tested by utilizing a uniform fuel load. The issue there is that the fuel is so far removed from real world conditions that the results are skewed far from what an end user would realize in his back yard or basement. Why even test if the results are so far removed from reality that they become meaningless to the consumer.
Bark and other debris in a typical fuel load in the real world constitute a great percentage of the particulate matter present in the burn. When you remove it from the equation you can meet the standard with what amounts to a campfire.

I also think that the boilers should be tested under an intermittent load that simulates field conditions. This is done to a certain extent from what I read by reducing the load but still misses the mark of letting the boiler go into an extended period of shutdown. Maybe I'm reading that part of the EPA document incorrectly but it looks like they keep a continuous, but reduced load on the boiler throughout the test.

As far as the Euro thing goes, it would solve a multitude of problems if our agencies here would accept and adopt their standards for emissions, efficiency and pressure vessels.
I have a feeling that would probably render some of testing agencies feeling somewhat "sterile" and unable to throw their weight around and they wouldn't appreciate it.