EPA drops cordwood testing qualification

[BKVP]

Thanks for suggesting that to them. I have read dozens of these reports and it's frustrating with some of them. In a good report, I can get the pertinent info in a few minutes. In a weak report, it may take 5-10 minutes, and some don't list stuff like actual measurements of the stove firebox at all. The EPA template should have an executive summary at the beginning that covers pertinent test data and stove specifics.

Another weakness of EPA testing is that all stoves get a consistent draft with a stack of 15'. That's fine for an average ranch house, but way off for a 2 story colonial with attic. I want to know how much emissions go up with a tall stack and strong draft. If it's a notable amount then the EPA should acknowledge the value of a draft reducing device.

Draft will be addressed in the FRM. You know stoves are not aspirated outside, rather into a draft funnel. The draft is controlled by giant fans. Begreen, the problem is getting EPA to recognize the emissions profiles differ by technology. So "over drafting ", is associated with burning hotter=cleaner. But that logic applies to only one technology.

Next, filters are easily ruined if they get wet. So in order to keep filters dry, the filter train temps must remain high enough. We working on this.

 

[BKVP]

Thank you @BKVP for shedding some light on the situation. Your expertise is always appreciated.

You're welcome. I'll enjoy this until I retire then I'm not certain what I'll do. They guys at the big agency think I need to help them.

We'll see....right now, we need to build stoves...a lot of stoves!

 

[Poindexter]

I know perfectly well the mpg estimates on new cars are based on running all the cars through the same test cycle and my actual gas mileage is going to be some lower number. Does a Prius get better gas mileage than a Suburban? Yes it does.

I had a car once that was, according to the mfr sticker, capable of 28 mpg on the highway. I actually did get 28 mpg in that car, once, when I was driving downhill out of the Rockies with a tailwind. My average highway mpg in that car was a lot closer to 20 mpg.

It seems to me the cordwood test introduced a lot of variables into stove testing, at least compared to the crib wood method. I agree end user variability is going to have a large impact on actual emissions in the field. I can see that in my own neighborhood. Low air quality sucks.

I like burning wood because I am leaving a bit of crude oil in the ground a little bit longer by recycling carbon instead of digging up fossil carbon. I have zero interest in a woodstove that requires electricity to preheat the combustor for faster cold starts.

Who do I call and what do I scream into the microphone before they hang up on me?

 

[ABMax24]

Read my comments! I suggested with stick with M28R. Same 4 runs. However, as required by law, when we notify EPA 30 days in advance of our intent to test, EPA would ask the lab to complete one additional run on cordwood. That run would not have any influence on your emissions score. Had they taken my suggestion into consideration and implemented it, there would be 155 runs completed on various species, on various technologies at various burn rates.

We'd be able to then have data that could be compared to crib tested stoves. Consumers get comparable data, regulators get real world data (of course from a lab on a dilution tunnel).

I did read that, but it's not been implemented, so we are at square one as the data does not exist.

 

[BKVP]

I did read that, but it's not been implemented, so we are at square one as the data does not exist.

Indeed sir! But, I still have a positive opinion of EPA's willingness to listen, so I'll continue to try. The problem is, they cannot force mfgs to incur added expense in the certification process.

 

[ABMax24]

Indeed sir! But, I still have a positive opinion of EPA's willingness to listen, so I'll continue to try. The problem is, they cannot force mfgs to incur added expense in the certification process.

I agree, and I'm not necessarily a believer that adding a bunch more tests in the lab is going to change real world emissions especially when that data comes at such a cost.

What I would like to see is some money put forward so an agency or ideally a non-biased institution like a group of University researchers could do in-situ testing on current generation stoves to compare as operated in-situ results with lab results. I'm inclined to believe that certain stove technologies perform similar in real world as they do in the lab, and others don't achieve near the same results in an owners home. Ideally such testing could be performed on the same model of stove with at least 2 different draft conditions, one of roughly 15ft and one higher say 25ft or 30ft, again I believe there would be certain technologies that would stand out as superior here too. Ultimately that's what matters, my neighbors don't care what brand of stove I have or what emission test it did or didn't pass, they only care about how much smoke is emitted from my cap.

Maybe such testing has already been done, and I haven't stumbled across that data yet.

As an aside, the other topic I've been interested in lately is the effect wood and pellet smokers have on air quality, I'm guilty here too as mine is currently smoking a pork butt for pulled pork, but I watched my neighbor fire his up this morning and literally fill the neighborhood with white smoke, I'm assuming his pellets were wet. As far as detection goes this may be another source of wood smoke that could possibly be blamed on wood heat, as far as I know even if PM emissions are broken down for source it would be impossible to tell if its from a wood stove or a pellet smoker.

 

[BKVP]

I agree, and I'm not necessarily a believer that adding a bunch more tests in the lab is going to change real world emissions especially when that data comes at such a cost.

What I would like to see is some money put forward so an agency or ideally a non-biased institution like a group of University researchers could do in-situ testing on current generation stoves to compare as operated in-situ results with lab results. I'm inclined to believe that certain stove technologies perform similar in real world as they do in the lab, and others don't achieve near the same results in an owners home. Ideally such testing could be performed on the same model of stove with at least 2 different draft conditions, one of roughly 15ft and one higher say 25ft or 30ft, again I believe there would be certain technologies that would stand out as superior here too. Ultimately that's what matters, my neighbors don't care what brand of stove I have or what emission test it did or didn't pass, they only care about how much smoke is emitted from my cap.

Maybe such testing has already been done, and I haven't stumbled across that data yet.

As an aside, the other topic I've been interested in lately is the effect wood and pellet smokers have on air quality, I'm guilty here too as mine is currently smoking a pork butt for pulled pork, but I watched my neighbor fire his up this morning and literally fill the neighborhood with white smoke, I'm assuming his pellets were wet. As far as detection goes this may be another source of wood smoke that could possibly be blamed on wood heat, as far as I know even if PM emissions are broken down for source it would be impossible to tell if its from a wood stove or a pellet smoker.

Well, that data does exist with stoves certified post 2015. The state of Oregon did quite a bit of in-situ testing. Of course, being conducted in Oregon means a great deal of the data is based upon softwoods being burned.

They've kept the data privileged at this point. Several states and air agencies have, over the past few years been paying for their own testing and data acquisition. So far, it's not available for review.

Data collection is very costly, even in-situ.

 

[ABMax24]

Well, that data does exist with stoves certified post 2015. The state of Oregon did quite a bit of in-situ testing. Of course, being conducted in Oregon means a great deal of the data is based upon softwoods being burned.

They've kept the data privileged at this point. Several states and air agencies have, over the past few years been paying for their own testing and data acquisition. So far, it's not available for review.

Data collection is very costly, even in-situ.

I'd be okay with seeing the softwood data, it's most relevant to me.

I get that it's expensive to do the testing, what's frustrating is the tax-payer is effectively footing the bill for the testing yet the data is being withheld. If it was a company doing the testing for its own competitive purposes I'd understand keeping that information privileged.

 

[MR. GLO]

How can they keep the data privileged with open records laws in each state? Has anyone contested this in court?

 

[BKVP]

How can they keep the data privileged with open records laws in each state? Has anyone contested this in court?

It's very recent. FOIA's have been filed.

 

[john26]

As an aside, the other topic I've been interested in lately is the effect wood and pellet smokers have on air quality, I'm guilty here too as mine is currently smoking a pork butt for pulled pork, but I watched my neighbor fire his up this morning and literally fill the neighborhood with white smoke, I'm assuming his pellets were wet. As far as detection goes this may be another source of wood smoke that could possibly be blamed on wood heat, as far as I know even if PM emissions are broken down for source it would be impossible to tell if its from a wood stove or a pellet smoker.

I own a pellet smoker and an old charcoal smoker the new pellet smoker with PID control has very little smoke. The majority of the smoke is on start up and that is mostly form the grease burning off the baffle, in fact it seems to smoke less than my LP grill because it has better grease drip pan. My personal opinion is bbq pit manufacturers are using PID controls on pellet smokers and promoting them more than charcoal to try get a head of stiffer epa regulations on them. A few years back EPA did a study on LP grills and talks of Catalyst being required on them.

 

[ABMax24]

I own a pellet smoker and an old charcoal smoker the new pellet smoker with PID control has very little smoke. The majority of the smoke is on start up and that is mostly form the grease burning off the baffle, in fact it seems to smoke less than my LP grill because it has better grease drip pan. My personal opinion is bbq pit manufacturers are using PID controls on pellet smokers and promoting them more than charcoal to try get a head of stiffer epa regulations on them. A few years back EPA did a study on LP grills and talks of Catalyst being required on them.

Mines got the PID control as well, and while it definitely cleans up after startup its definitely not smoke free, there always a light blue smoke emanating from the grill, if it burnt 100% clean you'd never achieve the smoke flavor. This is backed up by indoor air quality meter, if I get any smoke smell at all blow into the house when opening the door the meter quickly notices a decrease in air quality. My NG grill does smoke some with grease as you've mentioned, but I've never had it drop indoor air quality like the pellet grill, and it only smokes when its burning grease, otherwise it is quite clean burning.