all eyes on libby - omni-test montanafinal2.pdf · libby valley is the only location in the west,...

68 HEARTH & HOME FEBRUARY 2005

clean air

by James E. Houck, David R. Broderick and Carter Keithley

A small Montana town becomes the focus of theEPA’s efforts to clean up the air, and the hearthindustry’s desire to replace old, inefficient woodstoves with new, cleaner-burning models.

LLibby is a small western Montana townwith a serious air quality problem. TheLibby Valley is the only location in theWest, with the exception of southern Cal-ifornia, that exceeds the new federal fineparticulate (PM 2.5) standard on an annualbasis. There are a number of factors that,in combination, make Libby unique.

It is isolated; it is in a deep valley withlow wintertime wind speeds and pooratmospheric dispersion; it has no indus-try; it has no natural gas; it has very cold,long winters and is surrounded by forest.

As a consequence of these factors, its poorair quality is primarily due to one thingand one thing only – residential woodstoves. The wood usage per wood stoveaverages a whopping five cords per heat-ing season.

At first glance this looks like a night-mare for the hearth industry and certainlya nightmare for the 11,675 residents ofthe Libby Valley. But that may not bethe case if the Hearth, Patio & BarbecueAssociation (HPBA), the U.S. Environ-mental Protection Agency (EPA), the State

of Montana Department of Environmen-tal Quality (MDEQ) and the local Lin-coln County Environmental HealthDepartment officials have their way.

A tried and true solution for reducingparticulate levels in an airshed with woodstoves is a change-out program where old,high-emitting, uncertified wood stoves arereplaced with new, certified ones. Multi-ple annual PM2.5 nonattainment areas havebeen identified recently in the eastern U.S.,and they may benefit from wood stovechange-out programs.

All Eyes on LibbyAll Eyes on Libby

FEBRUARY 2005 HEARTH & HOME 69

Aerial view of Libby, Montana, situated in thenorthwestern corner of the state. The KootenaiRiver can be seen at the bottom of the image.

Aerial view of Libby, Montana, situated in thenorthwestern corner of the state. The KootenaiRiver can be seen at the bottom of the image.

So here is where the HPBA, the U.S.EPA, the State of Montana DEQ and theLincoln County Environmental HealthDepartment have come together. Theircommon goal is a wood stove change-out program in Libby, Montana, that notonly would solve the air quality problemfor local residents and the State of Mon-tana’s requirement under federal law to

meet the PM2.5 standard, but would serveas a demonstration project for the appli-cation of change-outs for eastern U.S.PM2.5 nonattainment areas. Cleaner air forthe residents of Libby, cleaner air in highlypopulated eastern areas and increased sales

of hearth products – everybody wins.The HPBA should be applauded.

Through the HPBA’s previous work withnumerous, albeit less comprehensive,wood stove change-out programs, theregulatory community has become con-vinced that wood stove change-out works.Now it’s on the table for considerationto solve Libby’s problem and, if suc-

cessful there, for expansion to other areas. The alternative – the general restric-

tion or banning of residential wood com-bustion – serves no one’s interests well.The HPBA has compiled an impressiveresume of wood stove change-out pro-grams. The practical issues associatedwith implementing the programs havebeen, in large part, worked out and theefficacy of the approach documented.

The Great Stove Change-out CampaignsPerhaps the best example of the “GreatStove Change-out” campaigns conductedby HPBA over the past 15 years is theCrested Butte, Colorado, project under-taken in 1989-90. HPBA (then knownas the Wood Heating Alliance) part-nered with the Colorado Department ofHealth, EPA, and the City Council inCrested Butte to implement a whole-sale change-out of all the uncertifiedstoves in this little mining town that,like Libby, is in a mountain valley.

The town council in Crested Butterecognized that the pall of wood smoke

that hung over the town in winter wasdiscouraging skiers from using the nearbyresort, an important source of revenuefor the residents. So they voted to imposea “polluters fee” on any homeowner whocontinued to use their old dirty-burningstove. This “stick” was combined withthe “carrot” of appliance discounts fromindustry and low-interest loans from alocal bank to encourage change-outs.

According to Carter Keithley, pres-ident and CEO of the Hearth, Patio &Barbecue Association, HPBA stationedits director of Public Affairs, JohnCrouch, in Crested Butte nearly theentire summer of 1989, and sponsoreda “Wood Stove Fair” to expose the localresidents to the certified stoves the indus-try was offering at discount. A total of195 of the 406 uncertified stoves inCrested Butte were replaced by newunits and another 135 were removed ordisabled. Air quality measurements inthe year following the change-outsshowed that pollution in the air wasreduced by 60 percent from the previ-ous winter as a result of the campaign.

Following that first success, HPBAand its regional affiliates conductedmany other “Great Stove Change-out”campaigns throughout the United States.HPBA published a guide for conduct-ing change-out campaigns in 1991 tohelp regions initiate campaigns in theirarea. The guide provided a checklist ofnecessary elements:

Define the area and scopeof the campaign.

Communicate with and organizearea dealers

Acquire the visible support of stateand local authorities.

Issue press releases and media kits.

Supply dealer participationand promotion kits.

Arrange for proper disposal ofold appliances.

Establish mechanisms fordocumenting replacements.

Campaigns in areas such as SouthernOregon, the Denver Metro region, North-ern California/Nevada, New England andthe Puget Sound area of Washington Stateresulted in replacement of thousands ofold, dirty-burning appliances.


clean air

(Continued on page 74)

Nonattainment Areas in the U.S.PM2.5 Standards

Nonattainment Areas (191 entire counties)Nonattainment Areas (34 partial counties)

Carter Keithley, president and CEO ofthe Hearth, Patio & Barbecue Association

The EPA’s recently released PM 2.5 map. For more information on nonattainment areas,visit the EPA’s Web site at www.epa.gov/pmdesignations/finaltable.htm.

clean air

Unfortunately, while these campaignshave made a start in reducing woodsmoke emissions in their areas, the real-ity is that there are still many more mil-lions of old, uncertified stoves in usethan there are new clean burners in place.

A Financial CatchEven though Libby seems like the idealsetting for the demonstration of woodstove change-out for PM 2.5 compliance– isolated, no other significant sourcesof PM 2.5, a relatively small population,high per capita ownership of woodstoves and the heavy use of those stovesdue to a cold climate – there is a catch.

The two major industries that histori-cally have supported the Libby com-munity – the vermiculite mine and thelumber mills – are closed.

Unemployment in the Libby Valleyis among the highest in Montana.Approximately 20 percent of the peo-ple in Lincoln County (Libby is thecounty seat of Lincoln County) are liv-ing below the poverty level. Manyhouseholds will require financial assis-tance to purchase a new stove and topay for the associated chimney workthat will be necessary in many homes.

While the exact number of uncerti-fied wood stoves is still being workedout through surveys, the estimate is thatthere are approximately 1,200 uncerti-fied stoves in the valley. Assuming thatthe average new stove with its associ-ated chimney upgrade costs $2,500, theprice tag for a complete change-out willbe on the order of $3 million, ignoringadministrative costs.

Other costs from dealing with themore minor wood-burning issues relatedto fireplaces, older wood-burning fur-naces, certified catalytic stoves withdegraded catalysts and wood-burningappliances in commercial buildingsalso need to be considered. Findingfiscal resources will be the major taskbefore the HPBA and the U.S. EPA.

Libby’s Air QualityTo get a good picture of the air qual-ity in Libby and its regulatory history,we interviewed experts within the Lin-coln County Department of Environ-mental Health, the Montana Departmentof Environmental Quality and Region8 of the U.S. EPA who have had along history of working with Libby’sair quality problems. These expertsincluded:


(Continued from page 70)


Ron Anderson, who has workedwith the Lincoln County Departmentof Environmental Health for 30 yearsand has been its director for 26 of thoseyears. Anderson was born in Libby andhe has been a lifetime resident of thecommunity. The air quality monitorsfor the area are located, literally, on theroof above his office.

John Coefield, who has worked withthe Montana Department of Environ-mental Quality since 1980. Coefield man-ages the analytical services section thatwill prepare the emission inventory forthe Libby State Implementation Plan (SIP),determine the source/impact relationships,evaluate control plan option effectivenessand prepare the demonstration of com-pliance for the proposed PM2.5 SIP.

Cindy Cody, who is the manager ofthe Air Quality Planning and Manage-ment Unit for EPA Region 8, which isresponsible for state compliance with theClean Air Act Standards in Montana,Colorado, Wyoming, Utah, North Dakotaand South Dakota. Cody is leading theEPA regional effort in Libby to assureits compliance with the PM2.5 standard.

To gain a further understanding of theair quality problem in Libby, we inter-viewed Dr. Tony Ward. Ward is aresearcher at the Center for EnvironmentalHealth and Sciences at the University ofMontana. He received his Ph.D. in chem-istry from the University of Montana andhas conducted air quality studies in bothMissoula and Libby, Montana.

The results of his Libby air qualitystudy conducted during the last heating

season have just been released, and theywill be pivotal in future planning toimprove air quality there. Ward is alsocurrently conducting a study for the HPBAin Libby to document changes in poly-cyclic aromatic hydrocarbon (PAH) lev-els before and after the envisionedchange-out occurs. PAH are a group ofair toxic compounds that have beentied to residential wood combustion.

We first asked the regulators aboutLibby’s air quality history and whetherresidential wood combustion was indeedthe predominate source of air pollution.

H&H: Could you give a brief sum-mary of the history and current statusof the air quality in the Libby Valley?

Is residential wood combustion animportant player?

COEFIELD/MDEQ: “Libby has hadparticulate issues ever since I have beenworking with the Montana Air QualityBureau, which is 24 years. Libby wasa TSP nonattainment area, then a PM10

nonattainment area. The initial SIP thatwe did included some controls on woodstoves. It also included the first bigimprovement that we made that broughtus into compliance with PM10. This wasthe better control of the re-entrained dustfrom the winter sanding of roads.

“We got a SIP in place for Libby thatincluded some more equipment to keepthe streets clean and some sanding stan-dards and the use of liquid de-icer. PlusLincoln County had a wood stove reg-istration program and a real-time par-ticulate monitor, which they could useto alert the public when it was time torestrict their burning.

“With these measures we were incompliance but still high. We remainedin compliance until the new PM 2.5 stan-dard came into being. Monitoringshowed we were okay on the 65 micro-gram per cubic meter daily limit, butwe are over on the annual limit. Really,what is left to address now is to directlyget at wood smoke.

OPPOSITE PAGE ABOVE: A winter inversion, 82percent of which is composed of wood smoke.OPPOSITE PAGE BELOW: A plume of smokefrom a wood stove.ABOVE: John Coefield of the MontanaDepartment of Environmental Quality.LEFT: As in most towns, some chimney instal-lations in Libby are, um, interesting.

“We haven’t written the source appor-tionment study, that is out in the futureseveral months yet, but it is clear thatwe are going to see wood stoves in thewinter responsible for 80 percent-plusof the particulate loading that we havedetected on the filters. It is during thewintertime period that we are gettingthe higher values that are driving ourannual average problem.

“Libby is an area, like in most ofwestern Montana, that has low sunangles in the wintertime. It gets a lotof trapped air inversions with very lit-tle flow out through either end of thevalley, so there are a lot of dispersionissues. Over two or three days in Libby,we will barely hit one hour with windspeeds of one mile per hour. We get alot of zeros. It is a place where the airpuddles and the smoke stays right thereuntil you finally get a front runningthrough. It is always going to be a prob-lem and always has been since we havehad a community there.

“Some pretty nasty air pollutionoccurs during some hours. There willbe times, say seven, eight or ninehours, when PM 2.5 concentrations areover a hundred micrograms per cubicmeter. Particulate concentrations atthat level are just unpleasant to bearound. It should be remembered thatLincoln County made some very goodstrides with wood stoves in the early’90s compared to where they were; itreally worked for PM 10 and helped tobring us into compliance. There hasjust been no impetus to be more strin-gent or harsh about wood stoves untilthis time. Wood stoves are a real sen-sitive issue because, in some cases,they are the sole source of heat.”

CODY/Region 8 EPA: “In the 1990s,it was discovered that the vermiculitebeing mined in the area contained a potentform of asbestos, exposure to which sig-nificantly increased the incidence ofasbestosis and mesothelioma in miners,their families, and townspeople not asso-ciated with the mine. The area wasdeclared a Superfund site in February2002, and has been undergoing cleanupsince spring of 2000, with an anticipatedcompletion date of 2008 at the earliest.

“In 1987, the EPA finalized healthstandards for airborne particles with anaerodynamic diameter less than or equalto a nominal 10 micrometers (PM 10).On Nov. 15, 1990, the EPA designatedthe town of Libby as nonattainment,for not meeting the PM 10 standard. The

area is currently attaining the PM10 stan-dards due to some wood smoke con-trol measures – permitting of new stovesand road dust control.

“In 1997, the EPA finalized newhealth standards for airborne particlessmaller than 2.5 microns in diameter,known as PM 2.5. EPA has determinedthat Libby will not meet these newhealth standards due almost certainlyto the wintertime emissions of smokefrom residential wood stoves. A nat-ural gas line does not serve Libby and,therefore, home heating is accomplished

by propane or wood stoves. Among the2,626 residents in the town and sur-rounding community, approximately1,500 homes utilize wood stoves as aprimary or secondary source of heat(7% serve as a primary source of heat),most of which are not EPA certified.”

ANDERSON/Lincoln County: “Ibelieve 80 percent or more of Libby’sPM 2.5 nonattainment is due to residen-tial wood combustion. We had assumedfor many years that a fair contributionwas from the large lumber mill in Libby.

“As you know, the mill was shut

down due to economic reasons. Whenthey were shut down we expected tosee a night and day difference in airquality. Nothing.

“That didn’t really leave much else.It boiled down pretty much to woodstoves.

“During the heating season, forestfires don’t happen at all. Open burn-ing, backyard burning, stops at the endof October for the general public. Thereis provision for timberland burning andagricultural burning through the monthof November, but conditions usually

don’t allow it. From a practical stand-point we looked at all these sourcesand said – what could it possibly bethat isn’t the obvious?

“So from everything we have lookedat, it all comes back to wood stoves. Ifeel the 80 percent accurately reflects thewood stove contribution. We have sur-veyed, evaluated, contemplated and delib-erated. What else can it be? We havelooked at everything that produces emis-sions that we can think of and identifyand the 20 percent remaining after the80 percent wood smoke value prettymuch covers all these other items.”


clean air

There are times when PM2.5 concentrations are over a hundred micrograms per cubicmeter, which is just unpleasant to be around.

H&H: What other measures besidesthe wood stove regulations alreadyinstituted as part of PM 10 control andthe envisioned wood stove change-outprogram are needed or already havebeen taken to achieve PM 2.5 attainment?

ANDERSON/Lincoln County:“Well, if you look at the improvement inair quality in the Libby Valley from whatit was years ago – just the steps we aretaking for PM10 improvement, and thefall burning smoke management program

that the DEQ put into place – we havealready taken a tremendous step forward.What is necessary now is just to take theregulations one step further, ratchet themdown a little bit more as we are basicallydealing with the same sources as we dealtwith for PM10 .

“I think that is really all we are goingto have to do, that and a continuing edu-cation program for the public on whatthey need to do. The road sanding changesall happened during the PM10 program.Road maintenance options were to changeto Freeze Guard or coarse sand. We wentto Freeze Guard. So the only sanding isnow outside the control area. That was

the major control we had for the coarseparticulate fraction.

“In addition, the city has done a lotover the last few years. The city has vol-untarily surfaced alleys. We have fewerunpaved parking lots. We have a localpaving company now that we never hadbefore. They have paved a lot of park-ing lots and driveways. This work wasall done without having to cite anyone.Road dust has kind of taken care of itself.

“PM 10 came into compliance and hasbeen in ever since 1994/95, with no

more PM 10 violations. Freeze Guard onthe roads and stove permitting – thoseare the two big control programs. Wereally did not do much to the open burn-ing season at all. The whole state ofMontana has a fall smoke managementprogram that includes timberland burn-ing within zone L, which is a specificairshed associated with Libby. We havecontrol over that if we want to over-ride the smoke manager’s call on burn-ing on certain days. But, as it turnsout, fall timberland burning hasn’t beensignificant, all the air pollution spikesare coming in November, December,January and February.”

Study of the Last Heating SeasonTo get a better understanding of the airquality study conducted in Libby dur-ing the last heating season, which willlikely provide much of the basis andsubstantiation for future regulatory deci-sions in Libby, we talked with Dr. TonyWard. While many of his responses arequite technical, one does not have tohold a doctorate to appreciate the state-of-the-art nature of the work that is doc-umenting the air quality status of Libby.

H&H: Could you provide a brief sum-mary of the study you conducted in Libbyduring the 2003-2004 heating season?

WARD/UM: “In the summer of 2003,the Montana Department of Environ-mental Quality requested that theUniversity of Montana, Center for Envi-ronmental Health Sciences (UM-CEHS)develop a research program to appor-tion the sources of PM 2.5 in Libby. Dur-ing the winter of 2003-2004, UM-CEHSconducted a PM 2.5 sampling program inLibby. The goal of this research pro-gram was to identify those sources ofPM2.5 in the Libby Valley that contributeto elevated concentrations measured inthe airshed.

“A Chemical Mass Balance (CMB)computer model was used to apportionthe sources of the fine fraction, whereinformation on the PM2.5 chemical com-position and anticipated sources in theLibby Valley served as model inputs.The existing PM2.5 chemical speciationsampler at the Libby sampling site mea-sured the mass and chemical composi-tion (including elements, ions and organicand elemental carbon) of the Libby PM2.5

every six days from Nov. 11, 2003,through Feb. 27, 2004.

“A collocated Federal ReferenceMethod (FRM) PM2.5 sampler was fit-ted with a quartz filter for each sampleday to measure levels of polar organics,many of which are signature chemicalmarkers emitted from sources in theLibby airshed. In addition, a high vol-ume (Hi-vol) polyurethane foam (PUF)sampler was installed at the Libby mon-itoring site to collect information onPAHs associated with both the particleand vapor phases. Most of these datawere then input into the CMB model todetermine the sources of PM2.5 in Libby.”

H&H: Did residential wood combus-tion play a significant role in the PM 2.5

nonattainment?


clean air

Dr. Tony Ward with monitoring equipment on a rooftop at the University of Montanain Missoula.

WARD/UM: “The final report for the2003/2004 Source ApportionmentResearch Study was submitted to Mon-tana DEQ on Jan. 11, 2005. The resultsof the CMB modeling revealed that res-idential wood combustion is the majorsource of PM 2.5 throughout the wintermonths in Libby, contributing an aver-age of 82 percent of the measured PM 2.5

throughout the sampling program.”

Wood StoveChange-outs in LibbyThe next logical question was to askRon Anderson, whose county depart-ment is on the front lines and whoknows the mood of the area, whethera wood stove change-out is right forLibby, and to ask the other two agen-cies directly involved (Region 8 ofthe U.S. EPA and the Montana DEQ)what they think about the efficacy ofa wood stove change-out program inLibby and what their roles would bein its implementation.

H&H: What do you think it will taketo make a wood stove change-out suc-cessful in Libby? Do you believe theLibby community will be amenable tothe change-out program?

ANDERSON/Lincoln County: “Yes,I think the community will be amenableto a wood stove change-out program.However, we need to promote it. I sensethere probably will be some reluctanceby some people. We can probably over-come that by a good, effective promo-tion program. One other thing that wedo have to deal with here is that we havea fairly high unemployment rate. Gen-erally, our unemployment rate for thecounty runs at the top of the list for thestate of Montana or very close to it. Theoverall economic level here is a littlelower than for a lot of other places. Ithink that’s why we probably have alarge number of older stoves.

“People depend on wood a lot tosupplement electricity. We don’t havethe benefit of a cheap natural gas source.Oil, propane and electricity are the heatsources here other than wood, so woodis an important fuel. We are surroundedby national forest and corporation for-est, so wood fuel is quite readily avail-able. All you need is a chain saw andan old pickup and, with no job, youhave the ability and all the time youneed to harvest wood.

“We are very excited about goingto the public and saying, ‘OK,. We’ve

got to get rid of old stoves; they arecreating a problem that we have to man-age, but we can help you with a replace-ment program’. I think a replacementprogram is going to be the key issue.If we just shut the door and say, ‘OK,if you have an old stove you can’t useit, do something on your own,’ we aregoing to have major problems. We arenot going to get the compliance weneed and it will take some awfully hard-nosed regulatory measures and enforce-ment. This would be a problem eventhough people have had a lot of yearsto think about it from the stove per-mitting program that has been in placefor several years, along with the restric-tions on the use of older stoves.

“We, of course, don’t know whatthe details of a replacement program

are going to be yet, but we are hope-ful that the people that need assistancethe most are going to get a real boost.I think that will make the program verysuccessful. The key is getting the wordout, getting the program up and run-ning, getting some success stories rollingout, and making it fit Libby’s economicsituation so that everyone can actuallyget a new stove.

“I understand why Libby is beinglooked as a pilot project. It is reallyan ideal setting for such a project. Weare not dealing with a huge popula-

tion. Libby is isolated; we don’t haveany other contributions – wood stovesare it. If you can replace them withhigh efficiency stoves and, all of a sud-den, voila, you solve your problem,that is as good as it gets.

“When EPA called me and said weare talking about a replacement pro-gram, I said, ‘Holy Smokes,’ yes! Weare just hopeful that it is at the fund-ing level that we need to be effectiveenough to get the job done. I am justafraid that if we end up with beingable to offer someone, say, $250, it isnot going to work. To be effective andto accomplish the anticipated numberof change-outs that we will have toaccomplish to get the reduction in emis-sions, we will have to have a signifi-cant replacement program.

“A large percentage of folks herereally could not afford to get rid of theold stove and go out and a buy a $2,000to $3,000 wood stove. Someone giv-ing them $250 or $300 to defray thecost of the old wood stove is not goingto do it. Wood is always going to havea presence in our community merelybecause we don’t have access to nat-ural gas. What I would really like tosee, since we will be dealing with woodfor a long time, is people equipped withthe best technology for utilizing thatenergy source.”


clean air

Ron Anderson, director of the Lincoln County Department of Environmental Health,with air quality monitors on the roof of his office building.

H&H: What do you envision your orga-nization’s role will be in a wood stovechange-out program in Libby?

CODY/Region 8 EPA: “EPA madethe designation of “PM2.5 nonattainment”for Libby this year. EPA Region 8 willhave the responsibility of reviewing theState Implementation Plan (SIP) thatMontana will be required to submit by2008 to demonstrate how the state willmeet compliance with the standard by2010. EPA recognizes that Libby facesa unique and difficult situation.

“The Libby population is already atrisk for airborne disease due to the ver-miculite contamination. Libby also hasvery few options for controlling PM2.5,since over 80 percent comes from woodsmoke. Therefore, EPA Region 8 hasbeen working closely with state and localofficials, prior to the designation, to beginlooking at possible control measures thatcould be implemented more quickly than2010. Through these efforts came theproposal of the wood stove change-outprogram. EPA Region 8 will continue towork with these state and local officialsto support the program.”

COEFIELD/MDEQ: “We are veryinvolved in it. The planning section isrolling forward with it. We will certainlydo the technical side trying to quantifythe benefits. We will help promote theprogram. Promotion activities will includethe pollution prevention side – forinstance, making sure that we have iden-

tified a way to dispose and recycle oldwood stoves. We want to definitely makesure that happens, as we don’t want themhanging around town.

“In addition, I am assuming if there isa wood stove change-out fair, we willhave a representative in Libby. We areworking closely with the county. Basi-cally this is a Lincoln County HealthDepartment show. We are there to helpthem as much as we can and we are inter-facing with the folks from EPA. We wouldalso like to see some kind of on-site man-ager help coordinate the program.”

H&H: Regarding the wood stove change-out program under consideration, whatis MDEQ’s opinion of this approach forachieving attainment in Libby?

COEFIELD/MDEQ: “We are veryhopeful that it will be a significant partof the SIP. We can’t tell at this pointwhether it will be enough all by itself.We are evaluating that right now. Weare doing a new wood stove survey andare going to try to quantify how manypeople in Libby burn how much woodin which type of stove. From this wewill be able to tell how much credit wecan get for a certain percentage of inroadsinto old wood stove replacement.

“For example, if we can get 40 or80 percent of noncompliant stoveschanged around, we hope we will beable to say how much benefit this willgive us. We are pretty excited about it.I really feel like it is a chance to goforward in Libby given the fact that wereally don’t have a natural gas option.It makes sense to try.

“At this point it is early in the game.We are not at all sure what kind ofpenetration we are going to need in thechange-out to get enough particulatereduction. When we come up with ouremission budget, and when we deter-mine the percent reduction we need intotal emissions, then we will have asense of how many noncompliant woodstoves will need to be changed over.

“We are not going to know that num-ber until February or March. The sur-vey will run through January. It is prettyfar out yet for us to confidently makeany statements about what we will getfor what. Certainly a change-out pro-gram can’t hurt. It should help a lot.Everyone is hoping that maybe it willbe the prime driver on our compliancestrategy for this SIP.

clean air

The wood usage per wood stove averagesa whopping five cords per heating season.

Early January in Libby, by the banks of the Kootenai.


“There are also other things to con-sider. For example, who is going to payfor the chimneys? The cost of the stovemay not be half of the total costs. Alot of installations have been there along time and the chimneys have justbeen cobbled together. Enough moneyto pay for the whole thing – wouldn’tthat be great? We are cautiously opti-mistic and we would get behind achange-out program. We will do what-ever we can. The alternative to this, ofcourse, is some way to coerce the pub-lic to stop burning wood by more per-mits and requirements to remove stoves.No one really wants to go there. Wealso feel that local support will be veryimportant for its success.”

H&H: What obstacles do you see tothe implementation of a successful woodstove change-out program?

CODY/Region 8 EPA: “There willneed to be many resources comingtogether to make this happen: financialassistance to lower income residents,availability of stoves and installers, anda public outreach campaign to obtainstrong interest from the community.Therefore, the timing may be impactedand we may need to phase this pro-gram over several years.”

H&H: If you were to define one thingthat would make this program successfulfrom MDEQ’s point of view, whatwould it be?

COEFIELD/MDEQ: “One thing tomake this program successful, the sin-gle, biggest thing is for someone tocome up with enough money to just doit all. Everything hinges on that rightnow. After we have the money, thenwe can worry about other things thatare important to the process and thatwill make it work.

“Right now we are thinking that weneed some sort of on-site manager – anon-site manager who knows where thepeople are, who knows what kind ofdevice someone has and who can lookat 47 different ways of having a poorinstallation and knows what to do to cor-rect them. This would be someone whois local, and who is committed to thisprogram and can make recommendationsfor each individual home, as well as hav-ing the right kind of technical expertise.

“I don’t know how you can do 700or 800 installations in a summer withchimney work to boot. This is a ter-

rific task. Someone who really, reallyknows his or her stuff will need to bein charge. In the budget, we want moneyincluded to have some local managerswho are advocates for the citizens andfor the program.”

The Libby Wood StoveChange-out as aDemonstration ProjectThe big hope, of course, is that the full-scale change-out of wood stoves inLibby will be successful and that it willbe used as a model for the numerouseastern PM 2.5 nonattainment areas. Forinsight into EPA’s thinking on the futurerole of wood stove change-outs in otherareas and the Libby opportunity, we talked

with Larry Brockman who works forEPA’s Office of Air Quality Planningand Standards (OAQPS) in Research Tri-angle Park, North Carolina. Brockman isthe team leader for a new effort to developand implement a voluntary ResidentialWood Smoke Reduction Initiative.

H&H: Can you tell us very briefly whatthe Residential Wood Smoke ReductionInitiative encompasses? Is this just aboutchanging out old wood stoves?

BROCKMAN/EPA: “EPA estimatesthat 80 percent of the 420,000 tons offine particle pollution from residentialwood smoke comes from wood stoves.

Although EPA’s primary focus is onfacilitating the change-out of old, dirty,inefficient “conventional” wood stovesto cleaner burning alternatives (e.g., EPA-certified stoves and gas stoves), there isdefinitely more to our initiative.

“We currently are participating viaan ASTM (American Society for Test-ing and Materials) committee to developa method for testing fireplace emissions.EPA foresees that this effort would allowthe potential development of an agreedupon emission standard and/or a nationalbuilding code for fireplaces. Also, basedon recommendations from numerousstates, we are looking further into themagnitude of outdoor wood-firedhydronic heater emissions.

“EPA is also participating in a newASTM committee that is working todevelop a consensus test method, andpotentially a consensus emission stan-dard, for these outdoor heaters. Finally,education and outreach is going to playa central role in all aspects of our initia-tive. We plan to have a new EPA Fire-place and Wood Stove Web site up inearly 2005. The Web site is geared pri-marily toward consumers, but also willhave wood stove change-out and techni-cal information for air program officials.”

H&H: Could you describe your inter-est, and the interest of your group fromRTP, in the Libby wood stove change-


Wood is free for the cutting in nearby national forests.

out?BROCKMAN/EPA: “Our No.1 inter-est – which I believe is similar to thatof the state of Montana, the EPA RegionalOffice and the city of Libby – is improv-ing air quality and reducing communitymembers’ exposure to the unhealthy

effects of wood smoke. As we begin ourResidential Wood Smoke Reduction Ini-tiative, we also see this effort as anopportunity to demonstrate, through pre-and post- air emissions monitoring, theeffectiveness of implementing wood stovechange-out campaigns.

“Having a successful wood stovechange-out campaign in Libby, and inour two other demonstration areas, will

certainly help us move closer to ourgoal of growing the wood stove change-out efforts into a program like the dieselretrofit program. For example, this grantprogram provides money to pay for the“retrofit” of older, less effective air pol-lution control equipment with state-of-the-art technology on a school bus.”

H&H: In what other locations do youenvision using the wood stove change-out approach after having studied Libby?

BROCKMAN/EPA: “We are currentlyplanning two other wood stove change-out pilots in areas that have fine particleproblems. We expect actual implementa-tion of these two pilots to occur in theearly fall of 2005. After we have com-pleted our work in Libby and in our twoother locations, we will share those resultswith state, local and tribal organizations.

“A number of organizations, includ-ing state, local and tribal agencies, havealready expressed interest in learningmore about our initiative and in imple-menting a wood stove change-out cam-paign. We expect those areas, particularlyin the eastern U.S. that have recentlybeen designated as not meeting the fineparticle standard, to have an interest indeveloping voluntary programs to reduceresidential wood smoke.”

H&H: What is the time frame for these

other programs?

BROCKMAN/EPA: “We hope to sup-port an additional three to six wood stovechange-out campaigns in 2006-2007. Ifresources become available, EPA wouldgradually ramp up the initiative fromdemonstration or pilot projects to a pro-gram between now and 2008.”

H&H: What sorts of things do youhope to learn from the Libby program?

BROCKMAN/EPA: “Recognizing alllocations are going to have their own setof issues, we hope to learn more aboutthe actual mechanics and roles and respon-sibilities of implementing a wood stovechange-out campaign. That is, what eachorganization (HPBA, state, EPA) is goingto need to do to carry out various tasksand at what level of effort. Everyone isstrapped for resources, and we want tobe able to provide a good estimate ofwhat it will take (time and money) forother communities to implement theirown campaign.”

H&H: What do you see as the key issuesthat will sway EPA to use change-outsin the future?

BROCKMAN/EPA: “I believe costeffectiveness is going to determine thefuture use of wood stove change-outprograms. It appears that changing outold, dirty, inefficient wood stoves tocleaner burning technologies is a verycost-effective way to reduce fine par-ticle pollution. In addition, air toxicsemissions are reduced as well. Basedon our preliminary estimates, it costswell below $2,000/ton, which is verycost effective relative to implementingother types of control technologies.”

H&H: If you were to define one thingto make the Libby program, and sim-ilar future programs, successful, what

clean air

EPA’s Larry Brockman, team leader of theResidential Wood Smoke Reduction Initiative.


would it be?BROCKMAN/EPA: “It is critical todemonstrate to public officials and otherpotential partners the human health,environmental, economic and other ben-efits associated with changing out theold, dirty, inefficient wood stoves withcleaner burning appliances.”

The Importance of the LibbyChange-out ProgramIn many respects, the Libby change-out proposal and the other projectsbeing planned by EPA are the culmi-nation of nearly 20 years of collabo-ration between HPBA and EPA, whichbegan with the regulatory negotiations(“Reg-Neg”) in 1986 that establisheda “New Source Performance Standard”(NSPS) for wood stoves.

From 1995 to 1997, HPBA was amember of a special EPA advisory com-

mittee known as the “Subcommittee forOzone, PM and Regional Haze Imple-mentation Programs.” It was partially outof the work of this subcommittee thatthe new PM2.5 air pollution standard wasdeveloped that became effective through-out the United States in 2004.

As a result of HPBA’s work on thesubcommittee, the association was invitedto become a member of the primary EPAadvisory committee on air quality issuesknown as the CAAAC (Clean Air ActAdvisory Committee). In January, 2004,

the CAAAC was presented with a reportfrom the National Academy of Sciences(NAS) on a study mandated by the U.S.Congress on the effectiveness of theClean Air Act. The report is a water-shed in air quality deliberations. It rec-ommends sweeping changes in the wayair quality management is undertakenin the U.S., including improvements inair quality measurement, expansion offederal and multi-state approaches,encouragement of innovative measures,and development of multi-pollutionstrategies. In other words, the NASreport said the old mechanisms aren’tworking anymore and, since our nationmust turn its attention to more difficultpollution sources, some new approachesare needed.

HPBA was appointed to a CAAAC“Working Group” to develop mecha-nisms for implementing the NAS Report.The Working Group forwarded its pro-

posals to EPA in December, 2004,including a recommendation that:

“EPA should further develop theResidential Wood Smoke initiative thatincludes working with states, locals,tribes, industry, non-governmental orga-nizations and others to support and facil-itate the change-out of dirty, inefficient‘conventional’ (pre-NSPS) wood stoveswith new, cleaner and more efficientheating appliances (e.g., EPA-certifiedwood stoves and gas appliances).”

It was in the course of the deliber-

ations over the Working Group pro-posals that EPA approached HPBA witha proposal to undertake one of the mostworthwhile air pollution abatement mea-sures ever: the Libby Change-out Pro-gram. The residents of Libby havesuffered tremendously from the effectsof breathing the asbestos dust created bythe vermiculite mining operation in thearea. Not only the miners, but their wivesand children were exposed to the terri-ble effects of the asbestos, and the suf-fering and deaths are well documentedin a book published in 2004 by AndrewSchneider and David McCumber titled,“An Air That Kills” (Putnam).

Recognizing that the wood smokeconcentrations in Libby exacerbate thesuffering of the residents in the town,many of whom have limited lung capac-ity and are on oxygen bottles, EPAsought HPBA’s help in relieving theproblem. This will not be an easy task.Libby is an economically depressedarea, and many of its residents cannotafford the cost of replacing their oldstoves. The hearth industry is ready tohelp, and our manufacturers and deal-ers have said they will find ways todiscount the appliances and installationsas much as possible. But other sourcesof funds must be found.

The hearth industry and all of thecompanies in it can be proud of thecontribution they are making to cleanerair in our country, and EPA has rec-ognized our contribution by making uspartners with them in these efforts. Oursis an industry of smart, caring, smallbusiness people with the very highestintegrity. They can sleep better at nightknowing they are part of “the solution


clean air

About the authors: Dr. James E.Houck is a research scientist with OMNIConsulting Services and has over 20years’ experience with air quality,energy and biomass combustion issues.David R. Broderick is an environmen-tal engineer with OMNI Environmen-tal Services with over 10 years’experience with air emission and effi-ciency measurements. Both authors canbe reached at (503) 643-3788 or viae-mail: [email protected] [email protected].

Carter Keithley is president and CEOof the Hearth, Patio & Barbecue Asso-ciation, and has been in charge of thatassociation for 25 years. He can bereached at (703) 522-0086 or via e-mail:[email protected].

In Libby, the air puddles and the smoke stays right there until a front finally comes through.

all eyes on libby - omni-test montanafinal2.pdf · libby valley is the only location in the west,...

Documents