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

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