"In addition to the local problems caused by widespread biomass burning, two other related issues have not been addressed. First, the amount of monitoring for particulate air pollution is not even close to what is needed. Second, our public health laws are not effective in helping people who are being exposed to biomass smoke by a neighbor. The difference in how sewage system incursion on to neighboring property is addressed is much more clear and reliable than how wood smoke “trespassing” is treated by public officials."
USA
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Pm2.5 Violations and Threats to Life and Health Common as shown by Pm2.5 Ranges from Modeling Submitted by: Ernest Grolimund, retired unregistered engineer, BSCE, Waterville.
Violations of the legal US PM standards are common from old stoves heating houses, 30% of Maine's population. The range of pm is 25 – 200 mcg/m3 plus with an average of 50 mcg/m3 PM2.5, 24 hr average, before background PM2.5 is added. Background pm is about 24 mcg/m3 or 25 mcg/m3 and changing rapidly. Total PM2.5 is 50 mcg/m3 – 225 mcg/m3 commonly indicating virtually all old stoves heating houses like OWB’s will violate ambient PM2.5 standards. Given this statistical occurrence, old equipment should be shut down upon complaint immediately instead of waiting 20 yrs for a voluntary change-out program to work. That is because these concentrations with higher toxicity than ambient mixed PM from oil and gas combustion can cause immediate threats to life and health and long term cancer threats like second hand smoke.
A Swedish study on emission factors for wood stoves (note 1) shows a variation from the average to maximum emissions of 4. An EPA study on certified fireplaces (note 2) shows the same factor of 4. This will result in a range of PM2.5 concentration for old stoves. ME DEP-EPA modeling (note 2) shows about 50 mcg/m3 PM2.5, 24 hr average modeled for an old conventional stove heating a whole house, ignoring background PM. The max value from the range will be 4 times that or 200 mcg/m3 PM2.5, 24 hr average. The 3 hr average will be 600 mcg/m3 PM2.5 per ME DEP modeling. The 1 hr PM will be 1,200 mcg/m3 per VT DEC monitoring of OWBs. The dose of PM2.5 is 1,200 mcg/m3,hr (Concentration x Time) And the safe dose guideline for wildfire smoke PM2.5 is about 180 mcg/m3,hr and the safe dose for mixed ambient PM2.5 is 840 mcg/m3,hr. PM ranges for the average stove heating just 1/3 of a house would be 1/3 the above values. The +/- 17 mcg/m3 PM2.5, 24 hr average, without background PM would be 68 mcg/m3 in difficult conditions per Swedish studies. The max 3 hr average pm concentration would be 200 +/- mcg/m3 PM2.5 and the 1 hr concentration would be 400 mcg/m3 +/-.
Instantaneous values could be even higher as shown by the NESCAUM modeling and monitoring values for OWBs. The modeled OWBs at 50 mcg/m3 PM2.5 were monitored at 2,000 mcg/m3 instant 5 min PM values corresponding to choking by the auto damper. The Swedish study and others show the maximum lab values and field values can be up to 100 times more but these are considered extraneous rare values on the extreme end of a statistical bell curve. But when people are exposed to these high concentrations for short periods of time, their eyes sting in minutes and health problems from cataracts can develop leading to possible blindness .It is a common nuisance or bother as well as a health nuisance. Professor Todd took an advanced stove estimated to cause 4 mcg/m3 from modeling and made it cause 100 times more PM ( note 3 )or I estimate: 400 mcg/m3 in a lab at U Tasmania. The ALA did the same thing. The range factor is an astounding 100. Applying this to the 50 mcg/m3 modeled amount for a whole house checked with EPA monitoring, you would get an astonishing 5,000 mcg/m3 PM2.5, instant measurement, from maximum choking and the widest range. This is why all complaints about wood smoke must be investigated, because extreme pollution like this is possible.
So, estimating the common max concentration in a number of ways results in an approx concentration of 1,200 mcg/m3, for an old stove heating a house. Something like this may have happened in my neighborhood where a heart attack and asthma attack happened near a house heated by wood from old equipment. To avoid repeats of the same thing, it is essential that engineering be used to model or estimate the PM concentration from all types of wood burning equipment in line with DHHS policy to investigate, research, stop and prevent threats to life and health. And a new procedure for modeling may have to be developed because of the need for 1 hr concentration which is not necessary apparently for large sources.
If you convert the ambient pm std to a dose it is 840 mcg/m3,hr. This dose will be exceeded by the max 1 hr dose from the old stove at 1,200 mcg/m3,hr. But the old stove can burn 4 hrs. The dose from that is 4,800 mcg/m3,hr or about 6 times the legal ambient PM dose. But the EPA R+D Dept says that wood smoke PM is not ambient PM from mixed sources. They say it is more toxic and Ron Severance of the ME DEP agrees. The safe dose for wood smoke PM from the EPA and Dr Brown and the CDC for Wildfire Smoke is 180 mcg/m3,hr. This can be thought of as 10 minutes to heart attacks in some people !, which is obviously a threat to life and or health not allowed by the constitution. So, old stoves heating houses must be regulated after checked modeling. The burn wise program does not eliminate the threats so is illegal because high constitutional rights to life and health are not guaranteed.
The range of possible PM values is too high to ignore though most politicians think all stoves and fireplaces are OK because they have been used for hundreds of years. But the London Fog Air Pollution Disaster showed how dangerous fireplaces can be ( 1,500 mcg/m3 PM2.5 24 hr average, region wide city PM from common burning) and the recent modeling and monitoring of OWBs and stoves by all manner of research shows that the wood burning is violating ambient PM levels at house hotspots and violating ambient PM across whole regions like the NYS Hudson River Valley. The Swedish emission factor range study begins to show the extreme pm values that can be reached when the values are plugged into modeling programs, and even the lab values by Professor Todd and the ALA must be considered. It is possible that 5,000 mcg/m3 PM2.5 can be reached in the most extreme cases with extreme choking. This could last for hours with a stove. The field monitoring of OWB’s by NESCAUM shows this can happen in real life, at 2,000 mcg/m3 PM2.5, instant values. Yet, when pollution like this is believed to occur in cities, no one will investigate and monitor it most of the time. ME instituted an OWB law where inspections were supposed to be done but the DEP reports only 12 or so valid complaints to the CT DEC reports of 900 or so complaints. Statistics shows virtually all old OWB’s will violate PM standards and cause health problems when another house is nearby. Yet the Maine DEP is reporting only a handful of valid complaints. This seems to be a gross error by a DEP reluctant to enforce the law to try to save money from possible court challenges.
The EPA says wood smoke nuisances are a state and local problem. The DHHS says it is a DEP problem and the DEP says it does not have doctors to consider the health ramifications and they are not authorized to monitor or model home air pollution episodes, except OWBs. They say it is a local responsibility and cities say it is a civil matter as they do not want increased enforcement costs. So victims sue neighbors if they can afford it, but most people cannot afford this. The threat of death and hospitalization means this is an emergency matter in many situations and governments should be intervening but they are not. Politicians who control the DEP and DHHS and CEOs do not understand the problem and won’t let government even study the problem. University and American Lung Associationn studies are showing 5,000 mcg/m3 PM is theoretically possible, worst case, and it is not being checked out, except for the much needed Swedish study at Aarhus University. The ME Toxic Emergency statute and DEP emergency powers are waiting to be used to handle this problem along with other law. Legislators and Governors and Congress people and Whitehouse personnel do not seem to understand the problem and are making dangerous laws and programs that are a danger to life and health like the change-out program and burn it wise program, that allow the recognized pollution to remain for the 20 years it takes to work, and do not check PM levels or increased toxicity of wood smoke compared to ambient PM.
In Maine, new laws were passed allowing the legislature to be bypassed in emergencies but the Governors Office must be educated to avoid rulings based on outdated and very incorrect beliefs. The Governor still oversees everything and another layer of political bureaucracy exists in the DEP Board that must be dealt with too. So leadership from the Air Bureau going up must be strong on this, but is not, and the Air Bureau should not just obey dangerous orders based on old fashioned dangerous traditions, but it is. NESCAUM could prove to be an ally in this to over come the inherent resistance to change and regulation in the Republican party that is the ruling party in Maine right now. Democrats are not much better. But this is a matter of law and cannot be ignored theoretically at least. ME DEP census data shows this is a problem affecting 300,000 people though it is not a regional layer of pollution in most cases and regional pm monitors designed by law to miss hotspots are doing just that and not recording the pollution.
The Maine modeler has said he did not know how to even begin to model and study this problem because of input problems and because it had never been done. So, the EPA was called in. A PE in the Maine Air Bureau says this should be done by the EPA as it is difficult for Maine. I see the states point and see the problem with politics in the EPA and DEP so suggest having an expert or team of experts from academia study this. But Maine says it cannot accept science from any place except the EPA and preferably when the science is a part of law like pm standardds, so a study overseen by the EPA may be necessary. However, the EPA says that all states have the ability to model stoves and boilers a shown by Maine. My first thoughts for independent study are Dr Brauer from U B.C. in Vancouver or Dr Larson, U Washington. But the DEP may know of others to get involved. The ALA was talking about possibly doing a big study on this at the U Vermont headed by a medical doctor. But the ME DEP says it cannot or will not recognize any science except EPA science. NESCAUM is another possibility. Modeling is going to be key as I see it and not regional modeling. The approach would be to consider this a consumer product safety issue involving engineers for the determination of concentrations in the field at houses and toxicologists to investigate the safe dose. A lot of the work has already been done but problems remain with BACT approaches not checking to see if pm standards are met. The cozy relationship of the EPA and politicians with the HPBA is also a problem according to some as NESCAUM is reporting EPA test methods are allowing dangerous pm from phase II OWB’s. Politicians do not want to destroy an industry and jobs and tax revenues but judges have repeatedly ruled that economic interests must not be considered when life and health are an issue. The companies are already transitioning to an industry dominated by 70% gas stove sales. Change-outs therefore should be for conversion to gas equipment. It would not be out of the picture to call in the U.N. either given their recommendation that developed countries phase out wood burning in certified stoves even, allowing only pellet stoves. They got started on this out of concern for the global warming problem which is another issue beyond me and maybe the DEP at this point. But they are studying women using essentially open fireplaces in kitchens with 5,000 mcg/m3 PM monitored. Pictures of smoke filled kitchens have been circulated, like houses engulfed by wood smoke from OWB’s and stoves. The U.N. monitoring checks the 5,000 mcg/m3 derived from ALA and University PM estimates in a rough way. At least it shows a ball park figure possible in a dead calm wind inversion.
The U.S. ATSDR has engineers and toxicologists and wrote a health assessment on an OWB for national interest. It recognized both the increased PM in the field from OWBs and the increased toxicity and new safe dose for wood smoke pm adapted by the CDC from Dr Browns EPA study. Perhaps they could be asked to study this through political channels via the Governors office or Legislature or DHHS Committee or a national Congressman.
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Could your family be affected? The inhalable particle pollution from one woodstove is equivalent to the particle pollution emitted from 3,000 gas furnaces producing the same amount of heat per unit. |