[Stoves] Aprovecho's ISO certificates

[Nikhil Desai]

Crispin:

I understood test method and equipment are different. My concern with both
is about PM2.5 claims.

Tiers for PM2.5 were changed from the Lima Consensus to IWA without

LC had two sets of ratings for PM2.5. There were four Tiers in all, from 0
to 3.

One rating was in PM2.5 emission rate and % reduction - the top Tier being
>90% reduction and <50 mg/L.

The second was for "IAP rating" with > 95% reduction and [image: Inline
image 1].

IWA by contrast had five Tiers and for PM2.5, Tier 3 cut-off was set at =<
8 mg/min and Tier 4 at =< 2 mg/min.

Then again, another rating was in terms of power levels - "High Power PM"
Tier 4 was =< 41 mg/MJd and "Low Power PM" Tier 4 was =< 1 mg/min/L.

There is some chicanery going on here - from concentration (in Lima) to per
MJd and per min/L. Sure, there is a cooking cycle defined somewhere that
can link these three with the use of some kitchen circulation model.

That is, I am not prepared to buy the argument that this was just
over-simplification so that emission rate and concentrations can be linked
via a model of standardized cooking cycle, standardized fuel, standardized
kitchen volume and airflow, mobility. Rather, it is a deceit of
environmental health zealots, namely EPA and its contractors.

While you, Ron and many others on the List were arguing about efficiency,
EPA and WHO (who had some money from DfID via its "Evidence Base" contract
with GACC) were concocting PM2.5 emission ratings in such a way as to drive
solid fuel stoves out of market.

That is, the whole purpose of TC-285 and WHO grandstanding about Guidelines
for Household Fuel Combustion was NOT to galvanize market for BioLite,
EnviroFit, or Paul Anderson's TLUD stoves - any biomass stoves at all - but
to give Kirk Smith the chance to argue that no biomass stove was "truly
health protective".

On the basis of emission rates or concentrations, Prof. Smith has never
been explicit. But if he claims concentrations, then he is moving away from
his ideology of "dirty cooking fuels"; there are other pollutants in
household and ambient air. His and Ajay's HAPIT model runs on
concentrations before and during an intervention but adjusts for
concentrations other than cooking fuel, even chimneys. But only on some
impractically high bar such as =< 2 mg/min the argument that no solid fuel
is ever clean enough becomes sustainable.

Your mention of Aprovecho LEMS not being able to score at Tier 3.5 made me
connect the dots.

On the one hand, we have EPA Final Rule
<https://www.gpo.gov/fdsys/pkg/FR-2015-03-16/pdf/FR-2015-03-16.pdf)> on
residential wood heaters dated 16 March 2015, three  years after IWA - see
p. 13672 - with PM2.5 emission limit maximum 2g/hr = 3.3 m/min five years
after the rule became effective, i.e., 2020.

The 3.3 mg/min emission rate for PM is between Tiers 3 and 4 of IWA.

Is there any conceivable rationale that US would have a higher permissible
PM2.5 emission rates from heating stoves - with air-tight insulation - than
poor people's cookstoves out in the open or with doors and windows open
except in very cold areas and during heavy monsoons?

In short, what you think is my misunderstanding may have a grain of truth
by insight. It is not necessarily the case that "The Tier 4 target for the
IWA was supposedly based on work by the WHO." WHO did not come up with HFC
Guidelines until 2014, more than two years after the IWA. Besides, where in
the world did WHO come up with emission rates -> concentration model but
for BAMG/EPA?

I have known EPA shenanigans over the decades. Scientist bureaucrats are
worse than bureaucratic scientists; ideology corrupts.

Aprovecho equipment, procedures and "certification" merit independent audit
if any stovemaker relies on such and risks reputation or money. On the
other hand, businesses ought to be able to take EPA to court for poking its
nose where it does not belong. I cannot think of any Congressional
appropriation rationalized in terms of international standards for
cookstoves. GACC and ANSI have been carrying a secret business on dubious
legal grounds; it is not clear if Aprovecho is independent of these moves.

I am also surprised that "From that, equipment can be assembled with an eye
on the protocol so the result is within specification. As everyone knows,
that is not what people are doing." Please say more or start a new thread
if that is irrelevant to Aprovecho.

Nikhil




On Wed, Oct 18, 2017 at 2:41 PM, Crispin Pemberton-Pigott <
crispinpigott at outlook.com> wrote:

> Dear Nikhil and Xavier
>
>
>
> *>*Another thing -  when you bring up LEMS hood, are you saying that
> Aprovecho uses LEMS and that Berkeley (UC? BAMG?) analyzed the equipment to
> conclude that it could not rate stoves beyond Tier 3.5 for some
> emissions? Or efficiency?
>

<snip>

>
> >This may be significant since to my recollection, EPA did not bring in
> PM2.5 regulations for regulated entities until 1997. From what I remember
> of EPA approved laboratories for PM2.5 emissions for residential wood
> heaters - i.e., heating stoves - Aprovecho wasn't one of them.
>

> To my knowledge they have never made that claim. They have often offered
> and been paid for testing services. Similarly, Berkeley Air offers testing
> but I do not know what the equipment is. If they claim a stove is ‘tier 4’
> according to the IWA, it cannot be with a LEMS prior to January 2016.
>
>
> >Now, Aprovecho may not want to test for wood heating stoves in the US and
> nonetheless want to test and certify wood cookstoves for the developing
> world.
>
>
>
> They do offer that service.
>
>
>
> >What I am wondering is whether by setting Tier 4 for PM2.5 emissions as
> low as EPA did in IWA 2011:12,  and lower than those for US NSPS for
> residential wood heaters, EPA was setting up the ISO exercise in such a way
> that no wood cookstove would be tested above 3.5 Tier.
>
>
>
> No, that is a misunderstanding. The Tier 4 target for the IWA was
> supposedly based on work by the WHO, as explained in the document, but that
> work was entirely ignored by the latest exercise. In both cases the claim
> was made that the emissions were related to exposure and health. As
> discussed here, again *ad nauseum*, making such claims is challengeable
> on several grounds, not the least of which is that the single box model
> advanced by Berkeley to make the calculation is nearly irrelevant for
> predicting exposure.
>
>
> It has nothing to do with the Tier 3.5, which is entirely about making
> claims using particular apparatus.
>
>
> >To your knowledge, is this a protocol issue or an equipment issue, or
> both?
>
>
>
> Separately, any set of equipment can be rated using a protocol to see what
> the LOD and LOQ numbers are. The IWA sensibly sets a ‘quality’ requirement
> for results. *From that, equipment can be assembled with an eye on the
> protocol so the result is within specification. As everyone knows, that is
> not what people are doing, *They are specifying equipment first, using
> it, and then looking to see if it meets the spec (or not). The 19867-1
> document was prepared in the same manner as there was no one member capable
> (willing?) to do the necessary investigation.
>
>
>
> The Masonry Heaters Association investigated the EPA method and equipment
> and found that it was not nearly as good as the much cheaper Condar system
> when it comes to rating the performance of very clean fireplaces. The EPA’s
> system was designed for much larger and dirtier systems than small cooking
> stoves so should not be a surprise that it struggles with them. I have
> never seen a tier-related rating of the EPA system.
>
>
>
> >Who certifies LEMS equipment and for what purpose?
>
>
>
> It does not come with a certificate, not even the independent review
> conducted by Berkeley. It is similar in operating method to the EPA total
> capture dilution system, as is the math underlying it. *The instructions
> say that it should be returned annually to Aprovecho for calibration. A lab
> using the system will probably want to perform their own calibrations and
> linearization much more frequently than that. T*he SEET and BEST/CAU lab
> calibrates gas measurements daily. PM is zero-calibrated daily. Scales
> should be calibrated annually, and thermocouples twice in that time. Harold
> Annegarn says that a certifying lab should spend about 20% of its time
> calibrating equipment.
>
>
>
> There is a fairly straightforward method of testing a set of apparatus:
> have different labs test a stove and compare results. To get an ISO 17025
> certificate, that is the standard procedure. You replicate someone’s
> result. The definition of ‘replicate’ is contained in some ISO
> documentation.
>
>
>
> Regards
> Crispin
>
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