New York State Energy Research and Development Authority

Review of EPA Method 28 Outdoor Wood Hydronic Heater Test Results

Final Report September 2011

No. 11-17

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REVIEW OF EPA METHOD 28

OUTDOOR WOOD HYDRONIC HEATER TEST RESULTS

Final Report

Prepared for the

NEW YORK STATE

ENERGY RESEARCH AND

DEVELOPMENT AUTHORITY

Albany, NY www.nyserda.org

Nathan Russell Assistant Project Manager

Prepared by: BROOKHAVEN NATIONAL LABORATORY

Dr. Tom Butcher

and

Nathan Russell Assistant Project Manager

NYSERDA NYSERDA September 2011 Report 11-17

http:www.nyserda.org

Notice

This report was prepared by Tom Butcher, Ph.D. in the course of performing work contracted for and sponsored by the New York State Energy Research and Development Authority (hereafter NYSERDA). Nathan Russell also contributed to writing the final report. The opinions expressed in this report do not necessarily reflect those of NYSERDA or the State of New York, and reference to any specific product, service, process, or method does not constitute an implied or expressed recommendation or endorsement of it. Further, NYSERDA, the State of New York, and the contractors make no warranties or representations, expressed or implied, as to the fitness for particular purpose or merchantability of any product, apparatus, or service, or the usefulness, completeness, or accuracy of any processes, methods, or other information contained, described, disclosed, or referred to in this report. NYSERDA, the State of New York, and the contractors make no representation that the use of any product, apparatus, process, method, or other information will not infringe privately owned rights and will assume no liability for any loss, injury, or damage resulting from, or occurring in connection with, the use of information contained, described, disclosed, or referred to in this report.

ii

Preface

EPA began Phase II of the Voluntary Hydronic Heater Program after October 15, 2008. To qualify under this White Tag program, appliances are tested using EPA Method 28 Outdoor Wood Hydronic Heater (M28 OWHH) and must achieve a weighted emissions rate of 0.32 lb/mmBtu (output) less. In late 2010, EPA recognized that the efficiency values determined using M28 OWHH did not represent actual efficiencies of qualified White Tag units and removed the efficiency values from the website while the issue was reviewed.

The work described in this report was conducted as a screening-level review of the M28 OWHH test results for the 23 units that were qualified under Phase II of the program at that time. Personnel from Brookhaven National Laboratory, NYSERDA, the Northeast States for Coordinated Air Use Management (NESCAUM), New York State Department of Environmental Conservation (NYSDEC), Vermont Department of Environmental Conservation, Maine Department of Environmental Protection, and Massachusetts Department of Environmental Protection participated in the review of the White Tag qualification data to identify possible sources of error.

Concurrent to this effort was EPAs stakeholder process to make improvements to M28 OWHH that included representatives from state air agencies, NYSERDA, and BNL as well as manufacturers in the Voluntary Program and the commercial test laboratories that conducted the original tests. Many of the recommendations found in this report have already been implemented in EPAs test method revision, Method 28 Wood Hydronic Heater (M28 WHH).

iii

Acknowledgments

This research was supported by the New York State Energy Research and Development Authority. NYSERDA acknowledges the contribution of Louis Fontaine, Maine Department of Environmental Protection; Phil Etter, Vermont Department of Environmental Conservation; Marc Cohen, Massachusetts Department of Environmental Protection; Randy Orr and John Barnes, NYSDEC; Lisa Rector, NESCAUM, and Chris Brown, BNL. We also acknowledge extensive dialogue on these test results coordinated by the EPA to modify the test method. Participants included the EPA accredited test labs, manufacturers of OWHHs as well as those listed above. The modified test method M28 WHH which resulted from EPAs stakeholder process can be found on the Burn Wise website.

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Table of Contents

1. Introduction ............................................................................................................................................................. 1

2. Overview of Test Method 28 OWHH (M28 OWHH) ........................................................................................... 2

3. Review of Test Results............................................................................................................................................. 4

4. Implementation of Review ...................................................................................................................................... 8

5. Findings of the Review .......................................................................................................................................... 10

5.1. Impacts of Sizing ........................................................................................................................................... 11

5.2. Effect of Improper Hydronic Heater Sizing on Operational Load, Efficiency and Emissions Rate..............14

6. Conclusions ............................................................................................................................................................ 18

6.1. Energy Output and Efficiency Measurements ............................................................................................... 18

6.2. Emissions Rate Measurements ...................................................................................................................... 18

6.3. Impacts of Sizing ........................................................................................................................................... 19

6.4. Improving the Accuracy of M28 OWHH...................................................................................................... 19

6.5. Additional Considerations for the NSPS ....................................................................................................... 20

7. References .............................................................................................................................................................. 22

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List of Figures

Figure 1. Generic piping arrangement in Test Method 28 OWHH. The appliance (also hydronic

heater or supply) side is to the left of the heat exchanger while the load side is to the right of

the heat exchanger .................................................................................................................................................. 2

Figure 2. Illustration of reported particulate emissions vs. output for selected units. Emissions generally

increase significantly with decreasing load on the heating system, even exponentially higher below

20%. Removing the lowest load from the test via substantial revisions to the test method weighting

factors and load limits will greatly reduce the calculate