Technical information document for residential wood combustion best available control measures




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United States Office of Air QualityEPA-450/2-92-002

Environmental Protection Planning and Standards September 1992

Agency Research Triangle Park, NC 27711


Air

TECHNICAL INFORMATION DOCUMENT FOR RESIDENTIAL WOOD COMBUSTION BEST AVAILABLE CONTROL MEASURES

EPA-450/2-92-002



TECHNICAL INFORMATION DOCUMENT

FOR RESIDENTIAL WOOD COMBUSTION

BEST AVAILABLE CONTROL MEASURES

U.S. Environmental Protection Agency

Office of Air and Radiation

Office of Air Quality Planning and Standards

Research Triangle Park, North Carolina 27711
September 1992

Disclaimer
This document reflects the latest information that the Environmental Protection Agency (EPA) has obtained on measures for control of residential wood combustion. As additional information becomes available, the document will be updated, as appropriate. Mention of trade names or commercial products is not intended to constitute endorsement or recommendation for use.
Copies
Copies of this document are available through the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711; or, for a fee, from the National Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.
CONTENTS
Section Page
1.0 Introduction 1-1
1.1 Purpose of Document 1-1

1.2 Statutory Background 1-2


1.2.1 Designations 1-2

1.2.1 Classifications 1-2

1.2.3 Serious Area Attainment Dates 1-4

1.2.4 Key Serious Area SIP Requirements 1-4

1.2.5 RACM and BACM Issuance 1-5
1.3 Document Organization 1-6
1.3.1 Available Control Measures for RWC BACM 1-6

1.3.2 RWC BACM Economic Feasibility Methodology 1-7


2.0 Integral Measures Available for RWC BACM. . . . . 2-1
2.1 Public Awareness and Education 2-1
2.1.1 Program Effectiveness and Tracking 2-2

2.1.2 Key Public Awareness and Education

Program Elements 2-2

2.1.3 Communication Strategy 2-3


2.2 Mandatory Curtailment Program 2-3
2.2.1 Public Awareness 2-4

2.2.2 Forecasting and Prediction 2-4

2.2.3 Public Notification 2-5

2.2.4 Exemptions 2-5

2.2.5 Enforcement 2-6

2.2.6 Tracking 2-7


2.3 Measures to Improve Wood Burning Performance 2-7
2.3.1 Control of Wood Moisture Content 2-7

2.3.2 Weatherization of Homes with Wood Stoves 2-8

2.3.3 Educational Opacity Program 2-9
2.4 All New Wood Stove Installations EPA-Certified,

Phase II Stoves or Equivalent 2-10

3.0 Flexible Measures Available for RWC BACM . 3-1
3.1 Emissions Reduction or Elimination -

Existing Installation 3-1


3.1.1 Conversion of Existing Wood Burning

Fireplaces to Gas Logs 3-1

3.1.2 Changeover to EPA-Certified Phase II

Stoves or Equivalent 3-3

3.1.3 Changeover to Low-emitting Devices 3-5
3.2 Emission Reduction or Emission Increase

Prevention -- New Installations 3-6


3.2.1 Gas Fireplaces or Gas Logs for New

Wood-Burning Fireplace Installation 3-6

3.2.2 Upgrade Offset 3-6

3.2.3 Restriction on Number and Density of

New Wood-Burning Stove and/or Fireplace

Installations 3-8

3.2.4 Requirement that New Wood Stove

Installations be Low-Emitting 3-9


3.3 Emissions Reduction -- New and Existing

Wood Stove Installations 3-9


3.3.1 Device Offset 3-10

3.3.2 Upgrade Offset 3-11


4.0 RWC BACM Economic Feasibility Methodology 4-1
4.1 Introduction 4-1
4.2Integral Measures . . . . 4-1
4.2.1 Public Awareness and Education 4-1

4.2.2 Mandatory Curtailment Program 4-2

4.2.3 Measures to Improve Wood

Burning Performance 4-7

4.2.3.1 Control of Wood Moisture Content 4-7

4.2.3.2 Weatherization of Homes

with Wood Stoves 4-8

4.2.3.3 Educational Opacity Program 4-9


4.2.4 All New Wood Stove Installations EPA-

Certified, Phase II Stoves or Equivalent 4-10


4.3 Flexible Available Measures . 4-12
4.3.1 Emissions Reduction or Elimination -

Existing Installations 4-12


4.4.1.1 Conversion of Existing Wood Burning

Fireplaces to Gas Logs 4-12

4.3.1.2 Changeover to EPA-Certified Phase II

Stoves or Equivalent 4-15

4.3.1.3 Changeover to Low-emitting

Devices 4-17


4.3.2 Emission Reduction or Emission Increase

Prevention -- New Installations 4-20


4.3.2.1 Gas Fireplaces or Gas Logs for New

Wood-Burning Fireplace

Installations 4-20

4.3.2.2 Upgrade Offset 4-23

4.3.2.3 Restriction on Number and Density of

New Wood Burning Stove and/or Fireplace

Installations 4-25

4.3.2.4 Requirement that New Wood Stove

Installations be Low Emitting 4-33
4.3.3 Emissions Reduction -- New and Existing

Wood Stove Installations 4-36


4.3.3.1 Device Offset 4-36

4.3.3.2 Upgrade Offset 4-39

APPENDIX A RWC BACM Task Force Membership A-1
APPENDIX B Methodology for Calculating Device

and Upgrade Offset Ratios B-1


TABLE

Table No. Page
1-1 Measures Available for RWC BACM ……… 1-8
SECTION 1.0
INTRODUCTION

1.1 PURPOSE OF THIS DOCUMENT

The purpose of this document is to provide technical information for the development of best available control measure (BACM) strategies for residential wood combustion (RWC) in areas that are designated serious nonattainment for PM-10 (particles with an aerodynamic diameter less than or equal to a nominal 10 micrometers). The information is needed by States to develop control strategies for their serious

PM-10 nonattainment area State implementation plan (SIP) submittals.

Note that while the guidance presented herein lists available measures which the Environmental Protection Agency (EPA) is recommending as BACM, and is intended to be comprehensive, it is by no means exhaustive. It also does not establish any binding requirements. Consequently, the State is encouraged to consider other sources of information and is not precluded from selecting other measures and demonstrating to the public and EPA that they constitute BACM.
1.2 STATUTORY BACKGROUND

1.2.1 Designations

Section 107(d) of the Clean Air Act (Act), as amended in 1990, provides generally for the designation of areas of each State as attainment, nonattainment or unclassifiable for each pollutant for which there is a national ambient air quality standard (NAAQS). Certain areas meeting the qualifications of section 107(d)(4)(B) of the amended Act were designated nonattainment for PM-10 by operation of law upon enactment of the 1990 Amendments to the Act (initial PM-10 nonattainment areas). A Federal Register notice announcing all of the areas designated nonattainment for PM-10 at enactment and classified as moderate was published on March 15, 1991 (56 FR 11101). A follow-up notice correcting some of these area designations was published August 8, 1991 (56 FR 37654). The boundaries of the nonattainment areas were formally codified in 40 CFR


Part 81, effective January 6, 1992 (56 FR 56694, November 6, 1991). All those areas of the country not designated nonattainment for PM-10 at enactment were designated unclassifiable [see section 107(d)(4)(B)(iii) of the amended Act].
1.2.2 Classifications

Once an area is designated nonattainment, section 188 outlines the process for classification of the area. In accordance with section 188(a), at the time of designation, all PM-10 nonattainment areas are initially classified as moderate by operation of law. A moderate area can subsequently be reclassified as a serious nonattainment area under two general conditions. First, EPA has general discretion under section 188(b)(1) to reclassify a moderate area as a serious area at any time the Administrator of EPA determines the area cannot practicably attain the NAAQS by the statutory attainment date for moderate areas. Second, under section 188(b)(2) a moderate area is reclassified as serious by operation of law after the statutory attainment date has passed if the Administrator finds that the area has not attained the NAAQS. The EPA must publish a Federal Register notice identifying the areas that have failed to attain and were reclassified, within 6 months following the attainment date [see section 188(b)(2)(B)].

Section 188(b)(1)(A) mandates an accelerated schedule by which EPA is to reclassify appropriate initial PM-10 nonattainment areas. The EPA proposed on November 21, 1991

(56 FR 58656) to reclassify 14 of the 70 initial moderate areas as serious. The final decision to reclassify the areas proposed will be based on the criteria utilized in the proposal, comments received in response to the proposal and on information in the moderate area SIP's that were due on November 15, 1991 for each of the areas.

In the future, EPA anticipates that, generally, any proposal to reclassify an initial PM-10 nonattainment area before the attainment date will be based on the State's demonstration that the NAAQS cannot practicably be attained in the area by December 31, 1994 [the statutory attainment date specified in section 188(c)(1) for initial PM-10 nonattainment areas].

In addition to EPA's general authority under section 188(b)(1) to reclassify as serious any area the Administrator determines cannot practicably attain the PM-10 NAAQS by the applicable date, for areas designated nonattainment for PM-10 subsequent to enactment of the 1990 Amendments, subparagraph (B) of section 188(b)(1) mandates that appropriate areas are to be reclassified as serious within 18 months after the required date for the State's submission of a moderate area SIP.1 Taken together with the statutory requirement that PM-10 SIP's are due within 18 months after an area is designated nonattainment [see section 189(a)(2)(B)], the statute thus requires that EPA reclassify appropriate moderate areas as serious within 3 years of the nonattainment designation.

Any decision by EPA to reclassify such a future nonattainment area as serious will be based on facts specific to the nonattainment area at issue and will only be made after providing notice in the Federal Register and an opportunity for public comment on the basis for EPA's proposed decision.
1.2.3 Serious Area Attainment Dates

The amended Act specifies that the initial moderate nonattainment areas (those designated nonattainment upon enactment of the 1990 Amendments) reclassified to serious are to attain the PM­-10 NAAQS as expeditiously as practicable but no later than December 31, 2001. Areas designated nonattainment subsequent to enactment that are reclassified as serious must attain the PM-10 NAAQS as expeditiously as practicable but not later than the end of the tenth calendar year after the area's designation as nonattainment [see section 188(c)(2)].


1.2.4 Key Serious Area SIP Requirements

As discussed above, States must develop and submit SIP's providing for the attainment of the PM-10 NAAQS for every area designated nonattainment and classified as moderate or serious for PM-10 under the amended Act. New revisions must be made to the PM-10 SIP in accordance with section 189(b) of the amended Act for areas that are reclassified as serious nonattainment areas. First, provisions must be adopted to assure that BACM (including BACT) will be implemented in the area [see section 189(b)(1)(B)]. Second, a demonstration (including air quality modeling) must be submitted showing that the plan will attain the NAAQS either by the applicable attainment date or, if an extension is granted under section 188(e), by the most expeditious alternative date practicable [see section 189(b)(1)(A)].

The SIP revisions to require the use of BACM must be submitted to EPA within 18 months after an area is reclassified as serious [see section 189(b)(2)]. The BACM are to be implemented no later than 4 years after an area is reclassified [see section 189(b)(1)(B)].

The serious area attainment demonstration required under section 189(b)(1)(A) must be submitted to EPA within 4 years after an area is reclassified based on a determination by EPA that the area cannot practicably attain by the statutory deadline for moderate areas. It is due within 18 months after an area is reclassified for actually having failed to attain by the moderate area attainment date [see section 189(b)(2)].


1.2.5 RACM and BACM Issuance

Section 190 of the amended Act requires EPA to issue technical guidance for RACM and BACM no later than 18 months from enactment of the 1990 Amendments to the Act for three PM-10 source categories: urban fugitive dust, RWC, and prescribed silvicultural and agricultural burning. In conjunction with publication of the "General Preamble for Title I of the Clean Air Act Amendments of 1990," EPA discharged the section 190 requirement to issue RACM technical guidance for each of these three source categories [57 FR 13541, April 16, 1992; 57 FR 18070, April 28, 1992]. The General Preamble provides a policy for how to utilize the available RACM technical guidance to develop area-specific RACM strategies. For RWC, the available RACM technical guidance cited is the existing RWC control measure document issued by EPA in September 1989, "Guidance Document for Residential Wood Combustion Emission Control Measures" (referred to as "RWC Guidance Document" in this document, see Ref. 1). As frequently suggested in this document, the 1989 RWC document should be consulted for background information on the available measures described in this document.

The issuance of this RWC BACM technical guidance document (and its fugitive dust and prescribed burning companion documents), together with EPA's previous issuance of RACM technical guidance, wholly fulfills EPA's statutory obligation to issue RACM and BACM technical guidance for urban fugitive dust, RWC, and prescribed silvicultural and agricultural burning under section 190 of the amended Act. Similar to the manner in which EPA provided guidance on Act requirements applicable to moderate PM-10 nonattainment areas in the General Preamble, including a policy or how to utilize the RACM technical guidance documents, the EPA is planning to provide guidance on Act requirements and provisions applicable to serious PM-10 nonattainment areas, including BACM, in an addendum to the General Preamble. [EPA made a draft of the addendum available for public comment on July 16, 1992 (57 FR 31477).] The portion of the addendum that addresses BACM provides a policy for how to utilize today's RWC BACM technical guidance (and companion technical guidance for control of fugitive dust and prescribed burning) to develop area-specific BACM strategies.

The information contained in this document was obtained, in large part, from the input and expertise of a task force assembled in December 1990. The task force met several times in 1991 and consisted of representatives from Federal, State, and local agencies involved in the control of residential wood combustion (see Appendix A).

The measures described in this document represent what the task force believes are the most effective measures for controlling PM-10 from RWC. Thus, not all the measures described in the 1989 "RWC Guidance Document" are included in this document because the task force did not regard them as "most effective."
1.3 DOCUMENT ORGANIZATION

1.3.1 Available Control Measures for RWC BACM

The available measures for RWC BACM recommended in this document are divided into two types (see Table 1-1 below): integral measures in column A and flexible measures in columns B-D. The suggested integral measures are measures that are regarded as critical for the success of RWC control programs in PM-10 nonattainment areas. The integral measures, though, are not, by themselves, intended to ensure long-term attainment of PM-10 NAAQS by serious areas. These measures are described in section 2.0 of this document.

The flexible measures (described in section 3.0 of this document) are intended to provide for long-term attainment of the PM-10 NAAQS and reduce the need for short-term episodic controls. The flexible measures are listed in three categories (columns B-D of Table 1-1): (1) Measures That Reduce or Eliminate Emissions From Existing Installations, (2) Measures That Reduce Emissions or Prevent Emission Increases From New Installations, and (3) Measures that Reduce Emissions From New and Existing Installations. The measures are listed in the categories only to show what emissions they impact and not because this guidance recommends serious areas adopt a certain measure or measures per se from each column.


1.3.2 RWC BACM Economic Feasibility Methodology

Section 4.0 provides a methodology that the implementing or lead planning agency should employ to assess the economic feasibility of the available measures described in sections 2.0 and 3.0. The methodology consists of an approach for estimating the emissions reductions and costs associated with each measure.


TABLE 1-1. MEASURES AVAILABLE FOR RWC BACM


A

INTEGRAL MEASURES



B
FLEXIBLE

MEASURES THAT REDUCE OR ELIMINATE EMISSIONS

FROM EXISTING INSTALLATIONS


C
FLEXIBLE

MEASURES THAT REDUCE EMISSIONS OR PREVENT

EMISSION INCREASES FROM NEW INSTALLATIONS


D
FLEXIBLE

MEASURES THAT REDUCE EMISSIONS FROM NEW AND EXISTING

INSTALLATIONS


1.Public awareness and education.
2.Mandatory curtailment during predicted periods of high PM-10 concentrations.
3.All new stove installations EPA- certified, Phase II stoves or equivalent.
4.Measures to improve wood burning performance:
- control of wood moisture content

- weatherization of homes with wood stoves

- educational opacity

program


1.Conversion of existing wood-burning fireplaces to gas logs.
2.Changeover to EPA-certified, Phase II stoves or equivalent.
3.Changeover to low emitting stoves.

1.Gas fireplaces or gas logs in new wood burning fireplace installations.
2.Upgrade offset.

3.Restriction on number and density of new wood-burning stove and/or fireplace installations.


4.Requirement that new stove installations be low emitting.

1.Device offset.
2.Upgrade offset.



References
1.U.S. Environmental Protection Agency, Guideline Series. "Guidance Document for Residential Wood Combustion Emission Control Measures." EPA-450/2-89-015. September 1989.
SECTION 2.0
INTEGRAL MEASURES AVAILABLE FOR RESIDENTIAL

WOOD COMBUSTION BACM

This section provides guidance on the suggested integral measures for RWC BACM. The measures are regarded as critical for the success of RWC control programs. The measures, however, are not intended, by themselves, to result in long-term attainment of the PM-10 NAAQS for serious PM-10 nonattainment areas.

A background discussion of each of the integral BACM measures is available in the EPA "RWC Guidance Document." The following subsections explain the purpose of each integral measure and recommend an effective strategy for their implementation.


2.1 PUBLIC AWARENESS AND EDUCATION

As the "RWC Guidance Document" explains, public awareness and education (PAE) is critical for the success of RWC emission control programs. The BACM PAE program should serve to inform the public about the RWC control program, (including program operational details, program justification and citizen responsibilities); and persuade and convince them to meet their responsibilities under the RWC control program.

The PAE program should address the following three areas: !Program Effectiveness and Tracking;

!Key PAE Program Elements; and

!Communication Strategy.
Section 2 of the "RWC Guidance Document" provides details on existing PAE programs.
2.1.1 Program Effectiveness and Tracking

The PAE program should be designed to educate the public effectively on the reason for controlling RWC emissions, as well as on the mechanics of controlling these emissions. The PAE program should also be tailored to the community's attitudes toward wood heating, their wood burning habits and patterns, and the extent and nature of the air quality problem. This information should be obtained by conducting a survey of the community's residents. The survey's findings should give implementing or lead planning agency officials an indication of how to tailor the PAE program to the community.

In addition, a follow-up survey should be conducted to assess the effectiveness of the PAE program on the parameters measured in the initial survey and to adjust the program accordingly as necessary. Additional information on assessing public attitudes and program effectiveness are provided in sections 2.1, 2.4, and 2.5 of the "RWC Guidance Document."
2.1.2 Key Public Awareness and Education Program Elements

The local implementing or lead planning agency should provide sufficient resources and staff to develop a PAE program that educates the public about:

!the health risks of wood smoke;

!proper wood-burning operation and maintenance;

!relevant State, local and EPA regulations;

!heating fuels and practice; and

!available stove types, including their relative

"in-home" field testing emissions for PM-10 and relative efficiencies.

More information on PAE program elements is contained in section 2.2 of the "RWC Guidance Document."
2.1.3 Communication Strategy

In a PAE program, the local implementing or lead planning agency should provide sufficient resources and staff to communicate the PAE elements to the public through all three types of media: print, broadcast, and public contact. (Section 2.3 of the "RWC Guidance Document" discusses each of these media at length.) An effective PAE program should include: (1) extensive public contact through events such as stove fairs and school assemblies; (2) the use of print media, including newspaper and brochures; and (3) the use of public service announcements for radio and television. Specific detail on a "High Level of Effort" PAE program is contained in section 2.4.3 of the "RWC Guidance Document."


2.2 MANDATORY CURTAILMENT PROGRAM

The purpose of wood smoke curtailment programs is to restrict wood burning during periods when atmospheric conditions and the level of wood burning activity result in ambient concentrations of wood smoke in excess of the NAAQS for PM-10. The curtailment program should include the following components:

!Public Awareness;

!Forecasting and Prediction;

!Public Notification;

!Exemptions;

!Enforcement; and

!Tracking.

The curtailment program should be implemented in a staged fashion, where the wood burning restrictions are less severe at lower predicted PM-10 concentrations. The implementing or lead planning agency administering the curtailment program should establish a two-stage curtailment program with two action points for determining when to call for restrictions on wood burning. One action point should trigger the implementation of Stage I voluntary curtailment (or mandatory with exemptions) and the other should trigger Stage II mandatory curtailment (with only low-income exemptions).

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