Clean Air Board Community Meeting, June 2, 2011, 7 pm

“Reducing Diesel Particulate Emissions from Construction Projects”

CAB will look at successful projects which reduced particulate emissions from diesel engines at construction sites.

The presentation will be held at the Second Presbyterian Church, 528 Garland Drive, Carlisle, PA 17013, on June 2, at 7 pm.   Join us for a discussion of this important topic.

Mt. Holly passes burning ordinance: Sentinel News

September 15, 2009: Sentinel News

Mt. Holly passes burning ordinance

By Staff Reports

Be careful what you burn in Mt. Holly Springs.

Borough council passed an ordinance Monday regulating outdoor burning. According to the ordinance, it is intended to promote the health, safety and welfare and to safeguard health, comfort, living conditions and property values by regulating outdoor and open burning.

Council voted 4-2 to approve the draft without comment. Councilman Jim Collins and Councilwoman Suzanne Cornman voted against the ordinance. Councilwoman Deborah Brophy was absent.

According to the regulations, outdoor burning is defined as open burning or burning in an outdoor wood-fired boiler. Open burning means, “maintaining a fire where the products of combustion are emitted directing into the ambient air without passing through a stack or a chimney,” including a burn barrel.

Open burning is permitted in the borough under certain conditions. No trash may be burned. Leaf waste may be burned, but only in a non-combustible container and only a safe distance from a building, vegetation or other combustible material.

Burning ordinance debate heats up: Sentinel News

September 8, 2009: Sentinel News

Burning ordinance debate heats up

By Staff Reports

Excerpt:

The steel sheds that house outdoor furnaces look innocent enough. Most are fairly small structures with one door and a metal pipe protruding from the roof.

But proposed regulations governing the hydronic heaters used to heat many rural homes across Cumberland County are raising the temperatures of stove owners and putting some local officials on the hot seat.

Outdoor wood burners pose concerns: Sentinel News

September 8, 2009: Sentinel News

Outdoor wood burners pose concerns

By Andrea Ciccocioppo

Excerpt:

Outdoor wood-burning furnaces have become more common, especially in rural areas in the last few years. According to statistics from the state Department of Environmental Protection, in 2005 there were 12,000 of the burners across the state. Since heating fuel prices have increased, more residents are buying the burners as a way to save on costs.

DEP officials have not completed an official count since 2005 but estimate there are probably close to 20,000 of the units statewide today.

Hydronic heater emissions are cause for concern. Residential wood smoke contains fine particles, which can affect both the lungs and the heart.

“We have concerns about the amount of soot – or fine particulate matter – that comes from these burners, especially the older models,” said DEP Secretary John Hanger. “The older models in particular are a real threat to air quality.”

CAB: Comments to the Environmental Quality Board on Wood Burners

November 30, 2009

Read Full Testimony (Google Document)

Clean Air Board of Central Pennsylvania

Comments before the Environmental Quality Board on Outdoor Wood Burners

My name is Thomas Au. I am here today on behalf of the Clean Air Board of Central Pennsylvania.

The Clean Air Board was founded in the fall of 2005 after over 100 Cumberland County physicians signed an open letter in the newspapers informing the community of the danger of ozone and particulate pollution. The medical professionals observed that many of the health problems they see were attributable to air pollution that we all breathe. The populations they identified at particular risk include infants, children, and the older people with pre-existing heart and lung disease.

The Clean Air Board of Central Pennsylvania is a faith-based citizens’ initiative dedicated to achieving clean air to protect our health and quality of life. We accomplish our mission by: raising public awareness of air quality issues; advocating, promoting and coordinating policy and practices for clean air; and monitoring air quality. CAB is an entirely volunteer organization. The Clean Air Board includes people from many walks of life – ministers, teachers, doctors, lawyers, businessmen, civic leaders, and ordinary citizens. Our members support efforts to improve the quality of the air we breathe, for the benefit of all of us.

One of the continuing air pollution problems the Board has identified in central Pennsylvania is the inability to meet the air quality standards for fine particulate – PM2.5. Currently, the Harrisburg-Carlisle-Lebanon air basin does not meet the short term 24-hour standard for fine particulate (35 ug/m3) or the longer term annual average standard (15ug/m3). The nearby air basins in York and Lancaster also do not meet the fine particulate air quality standards.

Particulate emissions cause a range of health problems, including short term problems, such as eye, nose, throat, and lung irritation, coughing and shortness of breath. Over the longer term, it can result in asthma, bronchitis, emphysema, pneumonia, heart disease and increased cancer risk.

The Department of Environmental Protection is in the process of redesigning state implementation plans to correct this problem. These state implementation plans are required by the federal Clean Air Act where current regulations do not result in the attainment of air quality standards. In addition to focusing on the large sources of fine particulate, the Department of Environmental Protection needs to focus attention on the smaller sources of PM2.5. The Clean Air Board supports strategies that can significantly reduce the amount of air pollution emitted and reduce nuisance problems at the local level.

The proposed regulation includes provisions to control outdoor wood fired boilers similar to those being adopted by many municipalities. Many municipalities have recognized that outdoor wood fired boilers can cause smoky conditions in neighborhoods and aggravate breathing problems for nearby residents. For these reasons, municipalities have been proactively adopting ordinances similar to DEP’s previously released model ordinance.

Outdoor wood fired boilers are different from indoor wood stoves. Indoor wood stoves are regulated by the Environmental Protection Agency. Manufacturers of indoor wood stoves must meet certain EPA new source performance standards – much like automobile manufacturers who must certify that their cars and trucks emit no more than a certain level of pollutants.

Outdoor wood fired boilers, on the other hand, often employ unsophisticated combustion technology that allows the unit to operate in idle mode for long periods. In addition, many units are installed with short stacks which do not disperse emissions well. A short stack height combined with poor draft can cause smoky conditions near ground level. Wood smoke also contains organic pollutants associated with the incomplete combustion of the wood. The toxic air pollutants that can result include benzene, formaldehyde, dioxin, and polycyclic aromatic hydrocarbons.

The Northeast States Coordinated Air Use Management (NESCAUM) has been studying outdoor wood boilers for a number of years. The increase in the use of outdoor wood boilers and the cumulative emissions from these appliances are usually significantly higher than other EPA-certified wood burning appliances. Unlike wood and pellet stoves, emissions from outdoor wood fired boilers are currently unregulated by EPA.

As a result of the differences in construction and use, NESCAUM found that even outdoor wood fired boilers that meet the EPA 2007 voluntary limit of 0.6 pounds of particulate matter per million BTU can emit 12 more times the particulate matter than an indoor wood stove that meets the EPA new source performance standard. NESCAUM’s current Phase I emission level is 0.44 pounds of particulate matter per million BTU.

NESCAUM, requested the New York Department of Environmental Conservation to conduct an air quality dispersion model study of a variety of situations and configurations of outdoor wood boilers (OWBs). NYDEC issued a report entitled “Dispersion Modeling Assessment of Impacts of Outdoor Wood Boiler Emissions in Support of NESCAUM’s Model Rule” (January 26, 2007). http://www.nescaum.org/documents/woodboilefinal2.pdf/ The study concluded: “In order to avoid exceedences of EPA’s 24 hour PM2.5 standard, units [OWBs] must move to emissions rates proposed in Phase II of NESCAUM’s model rule.” At page 8. The Phase II emission level in the NESCAUM model rule is identical to that under consideration today — 0.32 pounds of particulate matter per million BTU.

According to NESCAUM:

To put OWB [outdoor wood boilers] emissions into perspective, NESCAUM estimates that the current generation of OWBs emits at least twenty times more emissions than the current generation of EPA-certified woodstoves, and emits as much particulate matter as 50 to 500 diesel trucks (depending on the truck age and level of control). NESCAUM Outdoor Wood Boiler Fact Sheet

http://www.nescaum.org/documents/owbfactsheetfinal.pdf

Air quality benefits can also be achieved by reducing the emissions from outdoor wood fired boilers. As we look at all sources of fine particulate matter, we should concentrate on those sources which have the potential to cause or exacerbate breathing problems, especially in people with pre-existing respiratory conditions such as asthma, bronchitis and emphysema. These air pollution concerns are not only evident in central Pennsylvania, but are also evident in rural communities across the state.

We believe requiring new sales, distribution, and installations of outdoor wood fired boilers to meet a Phase 2 limit (0.32 pounds of particulate matter per million BTU) is a sensible requirement and we support this requirement. Other states have adopted the same emission requirement of 0.32 pounds of particulate per million BTU, including Maine, Massachusetts, New Hampshire, and Vermont. Most have an effective date of April 1, 2010 for this requirement. New Jersey limits visible smoke from outdoor wood burners. Maryland prohibits the construction and operation of outdoor wood boilers, except under the solid waste regulation. New York is drafting a regulation with a similar 0.32 pounds per million BTU requirement.

We also support imposing a seasonal requirement on the use of outdoor wood fired boilers. According to DEP, as of 2005, there were 12,000 outdoor wood fired boilers in Pennsylvania. The emission limits set for Phase 2 outdoor wood fired boilers will not affect emission from existing units. A seasonal restriction on their use will help alleviate air quality problems during the warmer seasons, when people are more likely to be active outdoors.

The Clean Air Board wants to publicly thank the members of the Environmental Quality Board and the staff of the Department of Environmental Protection for the work that you have put into this proposed regulation.

The Clean Air Board of Central Pennsylvania

528 Garland Drive

Carlisle, PA 17013

717-243-4571

PA Bulletin: Outdoor Wood Burning is a Growing Source of Dangerous Emissions

October 17, 2009

Read Full Bulletin

Excerpt: “The health effects associated with exposure to PM2.5 are significant. Epidemiological studies have shown a significant correlation between elevated PM2.5 levels and premature mortality. Other important health effects associated with PM2.5 exposure include aggravation of respiratory and cardiovascular disease (as indicated by increased hospital admissions, emergency room visits, absences from school or work and restricted activity days), lung disease, decreased lung function, asthma attacks and certain cardiovascular problems. Individuals particularly sensitive to PM2.5 exposure include older adults, people with heart and lung disease and children.

A significant and growing source of PM2.5 emissions in this Commonwealth is from OWBs. OWBs, also referred to as outdoor wood-fired furnaces, outdoor wood-burning appliances, or outdoor hydronic heaters, are free-standing fuel-burning devices designed: (1) to burn clean wood or other approved solid fuels; (2) specifically for outdoor installation or installation in structures not normally intended for habitation by humans or domestic animals, such as garages; and (3) to heat building space or water by means of distribution, typically through pipes, of a fluid heated in the device, typically water or a water and antifreeze mixture. OWBs are being sold to heat homes and buildings and to produce domestic hot water.

The emissions, health effects and the nuisance factor created by the use of OWBs are a major concern to the Department. The Northeast States for Coordinated Air Use Management has conducted stack tests on OWBs. Based on the test results, the average PM2.5 emissions from one OWB are equivalent to the emissions from 205 oil furnaces or as many as 8,000 natural gas furnaces. Cumulatively, the smallest OWB has the potential to emit almost 1 1/2 tons of PM every year. Of the estimated 155,000 OWBs sold Nationwide between 1990 and 2005, 95% were sold in 19 states, of which this Commonwealth is one.

Unlike indoor wood stoves that are regulated by the EPA, no Federal standards exist for OWBs and the majority of them are not equipped with pollution controls. The EPA has initiated a voluntary program that encourages manufacturers of OWBs to improve air quality through developing and distributing cleaner-burning, more efficient OWBs. Phase 1 of the program was in place from January 2007 through October 15, 2008. To qualify for Phase 1, manufacturers were required to develop an OWB model that was 70% cleaner-burning than unqualified models by meeting the EPA air emission standard of 0.6 pound PM per million Btu heat input as tested by an independent accredited laboratory. Phase 1 Partnership Agreements ended when the Phase 2 Partnership Agreements were initiated on October 16, 2008. To qualify for Phase 2, manufacturers must develop an OWB model that is 90% cleaner-burning than preprogram, unqualified OWBs and meet the EPA air emissions standard of 0.32 pound PM per million Btu heat output as tested by an independent accredited laboratory. The emission standard established in the proposed rulemaking would be the Phase 2 emission standard described in the EPA voluntary program.

The proposed rulemaking would help assure that the citizens of this Commonwealth will benefit from reduced emissions of PM2.5 from OWBs. Attaining and maintaining levels of PM2.5 below the health-based NAAQS is important to reduce premature mortality and other health effects associated with PM2.5 exposure. There are many citizen complaints regarding the operation of OWBs. This proposed rulemaking would reduce the problems associated with the operation of OWBs, including smoke, odors and burning prohibited fuels including garbage, tires, hazardous waste and the like. Reductions in ambient levels of PM2.5 would promote improved human and animal health and welfare, improved visibility, decreased soiling and materials damage and decreased damage to plants and trees.

While there are no Federal limits for the OWBs that would be subject to regulation under this proposed rulemaking, section 4.2 of the APCA authorizes the Board to adopt regulations more stringent than Federal requirements when the control measures are reasonably necessary to achieve and maintain the ambient air quality standards. See 35 P. S. § 4004.2. These measures are reasonably necessary to attain and maintain the primary and secondary 24-hour NAAQS for PM2.5 in this Commonwealth.”