A-i EPA-600/R-98-174b December 1998
Residential Wood Combustion Technology Review

Volume 2. Appendices
Prepared by: James E. Houck and Paul E.Tiegs OMNI Environmental Services, Inc. 5465 SW Western Avenue, Suite G Beaverton, OR 97005

EPA Purchase Order 7C-R285-NASX

EPA Project Officer: Robert C. McCrillis U.S. Environmental Protection Agency (MD-61) National Risk Management Research Laboratory Air Pollution Prevention and Control Division Research Triangle Park, NC 27711

Prepared for: U.S. Environmental Protection Agency Office of Research and Development Washington, D.C. 20460A-ii Abstract

A review of the current states-of-the-art of residential wood combustion (RWC) was conducted. The key environmental parameter of concern was the air emission of particles. The technological status of all major RWC categories was reviewed. These were cordwood stoves, fireplaces, masonry heaters, pellet stoves, and wood-fired central heating furnaces. Advances in technology achieved since the mid-1980's were the primary focus. These study objectives were accomplished by reviewing the published literature and by interviewing nationally recognized RWC experts. The key findings of the review included: (1) The NSPS certification procedure only qualitatively predicts the level of emissions from wood heaters under actual use in homes, (2) Wood stove durability varies with model and a method to assess the durability problem is controversial, (3) Nationally the overwhelming majority of RWC air emissions are from non-certified devices (primarily from older non-certified woodstoves), (4) New technology appliances and fuels can reduce emissions significantly, (5) The ISO and EPA NSPS test procedures are quite dissimilar and data generated by the two procedures would not be comparable, and, (6) The effect of wood moisture and wood type on particulate emission appears to be real but to be less than an order of magnitude.A-iii Appendix A Residential Wood Combustion Literature

The following is a list of references related to residential wood combustion technology and air quality impacts. This list constitutes partial fulfillment (review of published literature) of theEPA: Residential Wood Combustion Technology Reviewproject funded by the United States Environmental Protection Agency (US EPA). The references listed within this document have been grouped into six (6) categories. These categories are: Category Title Page 1. In-Home Emission Studies

.......................................A-1 2. Laboratory Emission and Engineering Studies

.........................A-8 3. Wood Use and Energy Surveys

...................................A-23 4. Ambient Air Quality and Health Studies

............................A-27 5. Regulatory Reviews

...........................................A-43
6. General or Unclassified Residential Wood Burning Documents

...........A-47
The content of some referenced documents may fall into more than one of the six categories. In these cases the category representing the predominant subject matter was selected. All documents are listed only once. Within a category the references are arranged in descending chronological order. References within the same year, under one category, are arranged alphabetically by the first author’s last name.U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #1 — IN-HOME EMISSION STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION

1 Correll, Robert; Jaasma, Dennis R.; Mukkamala, Yagna 1997 Field Performance of Woodburning Stoves in Colorado during the 1995-96 Heating Season Department of Mechanical Engineering, Virginia Polytechnic Institute and State University, Blacksburg, VA; Prepared for the U. S. Environmental Protection Agency, Office of Research and Development, Air Pollution Prevention and Control Division, National Risk Management Research Laboratory, Research Triangle Park, NC (EPA-600/R-97-112) (NTIS PB98-106487) 2 Jaasma, Dennis R.; Stern, Curtis H.; Champion, Mark 1994 Field Performance of Woodburning Stoves in Crested Butte during the 1991-92 Heating Season Department of Mechanical Engineering, Virginia Polytechnic Institute and State University, Blacksburg, VA; Prepared for the U. S. Environmental Protection Agency, Office of Research and Development, Air and Energy Engineering Research Laboratory, Research Triangle Park, NC (EPA-600/R-94-061) (NTIS PB94-161270) 3 Barnett, Stockton G. 1993 Summary Report of the In-Home Emissions and Efficiency Performance of Five Commercially Available Masonry Heaters OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Masonry Heater Association

4 Barnett, Stockton G. 1992 In-Home Evaluation of Emissions from a Grundofen Masonry Heater OMNI Environmental Services, Inc., Beaverton, OR; Prepared for Mutual Materials Company, Bellevue WA; the Masonry Heater Association; and Dietmeyer, Ward and Stroud 5 Barnett, Stockton G. 1992 In-Home Evaluation of Emissions from a Biofire 4x3 Masonry Heater OMNI Environmental Services, Inc., Beaverton, OR; Prepared for Biofire, Inc. 6 Barnett, Stockton G.; McCrillis, Robert C.; Crooks, Richard B. 1992 Evaluation of Emissions from Masonry Heaters and Masonry Fireplaces in Homes OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Environmental Protection Agency, Air and Energy Engineering Research Laboratory, Research Triangle Park, NC; and Mutual Materials Company, Bellevue, WA (EPA-600/A-93-059) (NTIS PB93-173078) 7 Barnett, Stockton G. 1992 In-Home Evaluation of Emissions from a Tulikivi KTU 2100 Masonry Heater OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Tulikivi GroupA-1U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #1 — IN-HOME EMISSION STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION

8 Barnett, Stockton G.; Bighouse, Roger D. 1992 In-Home Demonstration of the Reduction of Woodstove Emissions from the Use of Densified Logs OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Oregon Department of Energy; and the U.S. Environmental Protection Agency, (Administered by the Bonneville Power Administration, Portland, OR) (DOE/BP-35836 -1) 9 Crouch, J.; Crank, W. 1992 Update on the Crested Butte Woodstove Experiment Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 680-685 (ISBN 0-923204-09-1) 10 Henry, D. 1992 A Comparison and Analysis of the Field and Laboratory Test Data for the Noncatalytic Stoves in the Klamath Falls Field Performance Study Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 593-600 (ISBN 0-923204-09-1) 11 Osterburg, R. 1992 Modeling the Ambient PM10Impact of a Woodstove Replacement Program in Crested Butte, Colorado Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards And Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 686-699 (ISBN 0-923204-09-1) 12 Barnett, Stockton G. 1991 In-Home Evaluation of Emissions from Masonry Fireplaces and Heaters OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Western States Clay Products Association, San Mateo, CA 13 Barnett, Stockton G. 1991 In-Home Fireplace Performance: Comparison of a Conventional Fireplace with a Retrofit Firecrest Masonry Insert in the Zagelow Residence, Vancouver, WA OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Mutual Materials Company, Bellevue, WA

14 Barnett, Stockton G.; Fields, Paula G. 1991 In-Home Performance of Exempt Pellet Stoves in Medford, Oregon OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Department of Energy; Oregon Department of Energy; Tennessee Valley Authority; and Oregon Department of Environmental Quality, (Administered by the Bonneville Power Administration, Portland, OR) (DOE/BP-04143-2)A-2U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #1 — IN-HOME EMISSION STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION

15 Barnett, Stockton G.; Houck, James E.; Roholt, Robert B. 1991 In-Home Performance of Pellet Stoves in Medford and Klamath Falls, Oregon Proceedings of the Air & Waste Management Association 84thAnnual Meeting & Exhibition, Vancouver, BC (91-129.3)

16 Houck, James E.; Barnett, Stockton G.; Roholt, Robert B. 1991 In-Home Performance of Residential Cordwood Stoves Proceedings of the National Bioenergy Conference, Coeur d’Alene, ID, (91-129.3)

17 Jaasma, Dennis R.; Champion, Mark; Gundappa, Mahesh 1991 Field Performance of Woodburning and Coalburning Appliances in Crested Butte During the 1989-90 Heating Season Department of Mechanical Engineering, Virginia Polytechnic Institute and State University, Blacksburg, VA; Prepared for the U.S. Environmental Protection Agency, Office of Research and Development, Air and Energy Engineering Research Laboratory, Research Triangle Park, NC; the Town of Crested Butte, Crested Butte, CO; and Colorado Department of Health, Denver, CO (EPA-600/7-91-005) (NTIS PB91- 106921) 18 Barnet, Stockton G.; Roholt, Robert B.; Houck, James E. 1990 1.Field Performance of Best Existing Stove Technology (BEST) Hybrid Woodstoves in Their Second Year of Use 2.Evaluation of a Modified Evacuation Cylinder Particulate Emissions Sampler (MECS) OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Oregon Department of Environmental Quality, Portland, OR

19 Barnet, Stockton G.; Roholt, Robert B. 1990 In-Home Performance of Certified Pellet Stoves in Medford and Klamath Falls, Oregon OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Department of Energy; and Oregon Department of Environmental Quality, Portland, OR; (Administered by the Bonneville Power Administration, Portland, OR) (DOE/BP-04143-1) 20 Barnett, Stockton G.; Fesperman, James 1990 Field Performance of Advanced Technology Woodstoves in Their Second Season of Use in Glens Falls, New York, 1990 OMNI Environmental Services, Inc., Beaverton, OR; Prepared for Canada Center for Mineral and Energy Technology, Energy, Mines, and Resources, Canada, Ottowa, OntarioA-3U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #1 — IN-HOME EMISSION STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION

21 Barnett, Stockton G. 1990 In-Home Evaluation of Emission Characteristics of EPA-Certified High Technology Non-Catalytic Woodstoves in Klamath Falls, Oregon, 1990 — Final Report OMNI Environmental Services, Inc., Beaverton, OR; Prepared for Canada Center for Mineral and Energy Technology, Energy, Mines, and Resources, Canada, Ottowa, Ontario

22 Dernbach, Sue 1990 Woodstove Field Performance in Klamath Falls, Oregon Elements Unlimited, Portland, OR; Prepared for the Wood Heating Alliance, Washington, DC 23 Jaasma, Dennis R.; Champion, Mark; Shelton, Jay W. 1990 Woodstove Smoke and CO Emissions: Comparison of Reference Methods with the VPI Sampler Journal of the Air & Waste Management Association, Vol. 40, No. 6 pp. 866-871

24 Barnett, Stockton G. 1989/ 1990 Final Report — Field Performance of Advanced Technology Woodstoves in Glens Falls, NY, 1988-89, Volume I; and Technical Appendix, Volume II OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the New York State Energy Research and Development Authority; U.S. Environmental Protection Agency; CONEG Policy Research Center, Inc.; Canadian Combustion Research Laboratory; and Wood Heating Alliance (EPA-600/7-90-019a&b) (NTIS PB91-125641 and -125658) 25 Jaasma, Dennis R.; Champion, Mark 1989 Field Performance of Woodburning Stoves in the 1988-89 Heating Season Department of Mechanical Engineering, Virginia Polytechnic Institute and State University, Blacksburg, VA; Prepared for the Town of Crested Butte, Crested Butte, CO; Colorado Department of Health, Denver, CO; and the U.S. Environmental Protection Agency, Region 8, Denver, CO 26 Simons, Carl A.; Jones, Stanton K. 1989 Performance Evaluation of the Best Existing Stove Technology (BEST) Hybrid Woodstove and Catalytic Retrofit Device OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Oregon Department of Environmental Quality, Portland, OR

27 Burnet, Paul G. 1988 Performance of Certified Woodstoves under Field Conditions Transactions of the APCA/EPA International Specialty Conference, PM10Implementation Standards, TR-13, San Francisco, CA; Published by the Air Pollution Control Association, Pittsburgh, PA, pp. 664-672A-4U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #1 — IN-HOME EMISSION STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION

28 Elements Unlimited 1988 In-Situ Emission Factors for Residential Wood Combustion Units Elements Unlimited; Prepared for the Emissions Standards Division, U.S. Environmental Protection Agency, Office of Air and Radiation, Office of Air Quality Planning and Standards, Research Triangle Park, NC (EPA-450/3-88-013) 29 OMNI Environmental Services, Inc. 1988 Final Report — Particulate Emission Test, Emission Control System Inspection and Leak Check of the Blaze King "King" in Home PO2 — Dr. John Rau OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Oregon Department of Environmental Quality, Portland, OR

30 Simons, Carl A.; Christiansen, Paul D.; Houck, James E.; Pritchett, Lyle C. 1988 Woodstove Emission Sampling Methods Comparability Analysis and In-Situ Evaluation of New Technology Woodstoves, Task G — Final Report OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Department of Energy, Pacific Northwest and Alaska Regional Biomass Energy Program, (Administered by the Bonneville Power Administration, Portland, OR) (DOE/BP-18508-6) 31 Simons, Carl A.; Christiansen, Paul D.; Pritchett, Lyle C.; Enns, Victor; Hayden, A.C.S. 1988 An In-Situ Residential Performance Evaluation of Conventional and New Woodheat Technologies in Whitehorse, Yukon Territory Proceedings of the 1988 Air Pollution Control Association Meeting, Dallas, TX (88-89.3)

32 Burnet, Paul G. 1987 Field Investigations of Catalytic and Low Emissions Woodstove Particulate Emissions, Efficiency and Safety Proceedings of the 1987 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Pittsburgh, PA, U.S. Environmental Protection Agency, pp. 697-706 (EPA-600/9-87-010) (NTIS PB88-113402) 33 OMNI Environmental Services, Inc. 1987 Final Woodstove and Catalytic Combustion Inspections: NCWS Study Homes Prepared for the Coalition of Northeastern Governors; New York State Energy Research and Development Authority; and the U.S. Environmental Protection AgencyA-5U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #1 — IN-HOME EMISSION STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION

34 OMNI Environmental Services, Inc. 1987 Performance Monitoring of Advanced Technology Wood Stoves: Field Testing for Fuel Savings, Creosote Buildup and Emissions, Volume I; and Technical Appendix, Volume II; also Published as: The Northeast Cooperative Woodstove Study OMNI Environmental Services, Inc., Beaverton, OR; Prepared for New York State Energy Research and Development Authority; CONEG Policy Research Center, Inc.; and U.S. Environmental Protection Agency, Research Triangle Park, NC (EPA-600/7-87-026a&b) (NTIS PB88-140769 and -140777)

35 OMNI Environmental Services, Inc. 1987 An In-Situ Performance Evaluation of the Catalytic Retrofit Devices OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Oregon Department of Environmental Quality, Portland, OR 36 Simons, Carl A.; Christiansen, Paul D.; Pritchett, Lyle C.; Buyerman, Glenn A. 1987 Whitehorse Efficient Woodheat Demonstration OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the City of Whitehorse, Whitehorse, Yukon

37 Houck, James E. 1986 A System to Obtain Time Integrated Woodstove Emission Samples Proceedings of the 1986 EPA/APCA Symposium on Measurement of Toxic Pollutants, Raleigh, NC; U.S. Environmental Protection Agency (EPA-600/9-86-013) (NTIS PB87-182713) 38 Morgan, S. 1986 Evaluating the Field Performance of High Efficiency and Catalytic Wood Stoves Proceedings of the 1986 EPA/APCA Symposium on Measurement of Toxic Pollutants, Raleigh, NC, U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-7, Pittsburgh, PA, pp. 713-723 (EPA-600/9-86-013) (NTIS PB87- 182713) 39 Ramdahl, T.; Schjoldager, J.; Currie, L.A.; Hanssen, J.E.; Moller, M. 1984 Ambient Impact of Residential Wood Combustion in Elverum, Norway The Science of the Total Environment Vol. 36, Elsevier Science Publishers B.V., Amsterdam, pp. 81-90A-6U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #1 — IN-HOME EMISSION STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION

40 Barnett, Stockton G. 1981 Determination of Woodstove Efficiency under In-Home Conditions Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by the Oregon Graduate Center, Beaverton, OR (1982), pp. 996-1037 41 Hornig, James F.; Soderberg, Roger H.; Larson, Deborah 1981 Ambient Air Assessment in a Rural New England Village where Wood is the Dominant Fuel Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 140-153

42 Sanborn, Cedric R.; Poirot, Richard L.; Heil, Gregory A.; Blanchet, Michael A. 1981 Preliminary Analysis of the Ambient Impacts of Residential Woodburning in Waterbury, Vermont Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 231-241

43 Modera, M.P.; Sonderegger, R.C. 1980 Determination of In-Situ Performance of Fireplaces Energy Performance of Buildings Group, Energy & Environment Division, Lawrence Berkeley Laboratory, University of California, Berkeley, CA (LBL-10701; UC-95d; EEB-EPB-80-8) 44 PEDCo — Environmental, Inc. 1977 Source Testing for Fireplaces, Stoves, and Restaurant Grills in Vail, Colorado PEDCo — Environmental, Inc., Kansas City, MOA-7U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 1 Valenti, Joseph C.; Clayton, Russell K. 1998 Emissions from Outdoor Wood-Burning Residential Hot Water Furnaces Acurex Environmental Corporation, Prepared for the U.S. Environmental Protection Agency, Office of Research and Development, Washington, DC (EPA-600/R-98-017) (NTIS PB98-131980) 2 Hubbard, A.J. 1995 Hazardous Air Emissions Potential from a Wood-Fired Furnace Combustion Science and Technology, Vol. 108, pp. 297-309

3 McCrillis, Robert C. 1995 Review and Analysis of Emissions Data for Residential Wood-Fired Central Furnaces Proceedings of the 88thAnnual Air & Waste Management Association Meeting and Exhibit, San Antonio, TX, U.S. Environmental Protection Agency, Air and Energy Engineering Research Laboratory, Research Triangle Park, NC (95-RP137.04) 4 Tiegs, Paul E. 1995 Design and Operating Factors which Affect Emissions from Residential Wood-Fired Heaters: Review and Update Proceedings of the 88thAnnual Air & Waste Management Association Meeting & Exhibition, San Antonio, TX (95-RP-137.02)

5 Bighouse, Roger D.; Barnett, Stockton G.; Houck, James E.; Tiegs, Paul E. 1994 Woodstove Durability Testing Protocol OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U. S. Environmental Protection Agency, Office of Research and Development, Office of Environmental Engineering and Technology Demonstration, Washington, DC (EPA-600/R-94-193) (NTIS PB95-136164)

6 Barnett, Stockton G.; Bighouse, Roger D.; Houck, James E. 1993 Final Report — Manufacturers Seminar on Woodstove Stress Testing OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Coalition of Northeastern Governors, Policy Research Center, Washington, DC; and Pacific Northwest and Alaska Regional Biomass Program, Bonneville Power Administration, U. S. Department of Energy, Portland, OR 7 Bighouse, Roger D.; Houck, James E.; Barnett, Stockton G.; McCrillis, Robert C. 1993 Stress Testing of Woodstoves Proceedings of the 86thAnnual Air & Waste Management Association Meeting & Exhibition, Denver, CO (93-RP-136.05) (EPA-600/A-93-268) (NTIS PB94-120011)A-8U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 8 Bighouse, Roger D.; Houck, James E. 1993 Evaluation of Emissions and Energy Efficiencies of Residential Wood Combustion Devices Using Manufactured Fuels Science Applications International Corporation, Beaverton, OR; Prepared for the Oregon Department of Energy, Salem, OR

9 Houck, James E.; Bighouse, Roger D. 1993 Reduction in Particulate and Carbon Monoxide Emissions from Fireplace and Woodstoves with the Use of Sawdust/Wax Firelogs Science Applications International Corporation, Beaverton, OR; Prepared for the Hearth Products Association, Washington, DC; and Firelog Manufacturers Association, c/o Canadian Firelog Ltd., Richmond, B.C., Canada 10 Karlsson, M. 1993 Emissions from Wood-Fired Domestic Central Heating Boilers – Load Dependence, (English Translation of Emissioner från vedpannor – lastföhållandets betydelse) SP Report – Swedish National Testing Institute (SP), Energy Division, p. 48

11 Karlsson, M.; Gustavsson, L. 1993 Characterization of Combustion Emissions from Wood-Fired Domestic Central Heating Boilers, (English Translation of Karaktärisering avrökgaser från vedpannor),SP Report – Swedish National Testing Institute (SP), Energy Division, p. 49

12 McCrillis, Robert C.; Watts, Randall R.; Zweidinger, Roy B. 1993 Comparison of Residential Oil Furnace and Woodstove Emissions Proceedings of the 1993 U.S. EPA/A&WMA International Symposium on Measurement of Toxic and Related Air Pollutants, Durham, NC; Published by the Air & Waste Management Association, VIP-34, Pittsburgh, PA, pp. 213-220 13 McCrillis, Robert C.; Jaasma, Dennis R. 1993 Woodstove Emission Measurement Methods: Comparison and Emission Factors Update Environmental Monitoring and Assessment, volume 24, pp. 1-12A-9U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 14 Barnett, Stockton G. 1992 Particulate and Carbon Monoxide Emissions from the Use of Hazelnut Logs in a Conventional Masonry Fireplace OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Hazelnut Growers of Oregon, Cornelius, OR

15 Barnett, Stockton G. 1992 Particulate and Carbon Monoxide Emissions from the Use of Palm Branch Logs in a Conventional Masonry Fireplace OMNI Environmental Services, Inc., Beaverton, OR; Prepared for Clean Burning Fuels, Inc., Tucson, AZ

16 Champion Mark; et al. 1992 Fireplace Smoke and CO Emissions: Comparison of a Field Sampler with Reference Methods Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 536-552 (ISBN 0-923204-09-1) 17 Nielson, P.A.; Joergensen, V. 1992 Mutagenic Activity in Samples of Emissions from Straw Combustion and Wood Chip Combustion, (English translation of Mutagen aktititet i prøver af røggas fra halm – g flisfry) The Danish National Food Regulatory Administration (Levnedsmiddelstyrelsen) Report NEI-DE-744

18 Shelton, Jay W. 1992 Testing of Sawdust-Wax Firelogs in an Open Fireplace Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 553-571 (ISBN 0-923204-09-1) 19 Stroud, T. 1992 Thermal Mass Solid Fuel Technology as a Low-Emission Residential Energy Option Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 572-584 (ISBN 0-923204-09-1) 20 Anonymous 1991 WHA Fireplace Emissions Test Method Procedures No Publication Information ListedA-10U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 21 Hayden, A.C.S.; Braaten, R.W. 1991 Reduction of Fireplace and Woodstove Pollutant Emissions through the Use of Manufactured Firelogs Proceedings of the 84thAnnual Air & Waste Management Association Meeting & Exhibition, Vancouver, B.C.

22 Stern, Curtis H.; Jaasma, Dennis R. 1991 Study of Emissions from Masonry Fireplaces — Final Report Department of Mechanical Engineering, Virginia Polytechnic Institute and State University, Blacksburg, VA; Prepared for the Brick Institute of America, Reston, VA 23 anonymous 1990 Continuation of the Design of a 12-Hour Catalytic Furnace Department of Energy, Mines and Resources, Canada (Contract No. 23216-8-90005/01-SZ) 24 Burnet, Paul G; Houck, James E.; Roholt, Robert B. 1990 Effects of Appliance Type and Operating Variables on Woodstove Emissions, Volume I — Report and Appendices A-C, Volume II — Appendices D-F OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Environmental Protection Agency, Air and Energy Engineering Research Laboratory, Research Triangle Park, NC (EPA-600/2-90-001a&b) (NTIS PB90-151457 and -151465) 25 Karlsson, M. 1990 Emissions from Small Scale Wood Burning – Comparison of Test Methods, (English translation of Emissioner vid småklig vedeldning – jämförelse av provningsmetoder) Swedish Energy Agency (Statens energiverk) (FBT 90/3, Project Number 276 359)

26 Shelton, Jay W.; Sorensen, Doug; Stern, Curtis H.; Jaasma, Dennis R. 1990 Fireplace Emissions Test Method Development Shelton Research Inc., Santa Fe, NM; and the Department of Mechanical Engineering, Virginia Polytechnic Institute & State University, Blacksburg, VA; Prepared for the Wood Heating Alliance, Washington, DC, Fireplace Emissions Research Coalition 27 Stern, Curtis H.; Jaasma, Dennis R.; Shelton, Jay W. 1990 Final Report on the Masonry Heater Emissions Test Method Development Department of Mechanical Engineering, Virginia Polytechnic Institute & State University, Blacksburg, VA; and Shelton Research, Inc., Sante Fe, NM; Prepared for the Wood Heating Alliance, Fireplace Emissions Research Coalition 28 Bushnell, Dwight J.; Haluzok, Charles; Dadkhah-Nikoo, Abbas 1989 Biomass Fuel Characterization: Testing and Evaluating the Combustion Characteristics of Selected Biomass Fuel — Final Report Department of Mechanical Engineering, Oregon State University, Corvallis, OR; Prepared for the Bonneville Power Administration, Portland, OR (DOE/BP-1363)A-11U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 29 Leese, K.E.; Harkins, S.M. 1989 Effects of Burn Rate, Wood Species, Moisture Content and Weight of Wood Loaded on Woodstove Emissions Research Triangle Institute, Research Triangle Park, NC; Prepared for the U.S. Environmental Protection Agency, Office of Research and Development, Air and Energy Engineering Research Laboratory, Research Triangle Park, NC (EPA-600/2-89/025) (NTIS PB89-196828) 30 Burnet, Paul G.; Simons, Carl A. 1988 Identification of Factors which Affect Combustion Efficiency and Environmental Impacts from Woodstoves, Task D — Final Report OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Department of Energy, Pacific Northwest and Alaska Regional Biomass Energy Program, (Administered by the Bonneville Power Administration, Portland, OR) (DOE/BP-18508-4) 31 Hayden, A.C.S.; Braaten, R.W. 1988 Techniques to Reduce the Emissions from Existing Woodburning Appliances Proceedings of the 1988 Air Pollution Control Association Meeting, Dallas, TX (88-89.1) 32 McCrillis, Robert C. 1988 Effects of Operating Variables on Emissions from Woodstoves Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 835-840 (EPA-600/9-88-015) (NTIS PB90-225863) 33 OMNI Environmental Services, Inc. 1988 Environmental Impacts of Advanced Biomass Combustion Systems — Final Report OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Department of Energy, Pacific Northwest and Alaska Regional Biomass Energy Program, (Administered by Bonneville Power Administration, Portland, OR) 34 Aiken, M. 1987 Canadian Firelog Ltd. Emission Testing Air Program, B.C. Research, Vancouver, B.C.; Prepared for Canadian Firelog Ltd., Richmond, B.C. 35 Merrill, Raymond G.; Harris, D. Bruce 1987 Field and Laboratory Evaluation of a Woodstove Dilution Sampling System U.S. Environmental Protection Agency, Air and Energy Research Laboratory, Research Triangle Park, NC (EPA-600/D-87-216) (NTIS PB87- 210381) 36 Shelton, Jay W.; Gay, Larry 1987 Colorado Fireplace Report Shelton Research, Inc., Sante Fe, NM; Prepared for the Colorado Air Pollution Control Division, Denver, COA-12U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 37 Swinton, Michael C.; Sinha, Robin P.; Haysom, John C. 1987 Modifications and Refinement of the Computer Model “Wood Burning Simulator” Scandia Consultants Limited; Prepared for Canada Mortgage and Housing Corporation

38 Swinton, Michael C. 1987 Residential Combustion Venting Failure a Systems Approach — Final Report — Project 2 — Modifications And Refinements To The Flue Simulator Model Scandia Consultants Limited, Scandia Sheltair Consortium; Prepared for the Research Division, Policy Development and Research Sector, Canada Mortgage and Housing Corporation

39 Burnet, Paul G.; Edmisten, Norman G.; Tiegs, Paul E.; Houck, James E.; Yoder, Rachel A. 1986 Particulate, Carbon Monoxide, and Acid Emission Factors for Residential Wood Burning Stoves Journal of the Air Pollution Control Association, Vol. 36, No. 9, pp. 1012-1018

40 Cottone, Lawrence E.; Messer, Edward 1986 Test Method Evaluation and Emission Testing for Rating Wood Stoves U.S. Environmental Protection Agency, Air and Energy Engineering Research Laboratory, Research Triangle Park, NC (EPA-600/2-86-100) (NTIS PB87-119897) 41 McCrillis, Robert C.; Merrill, Raymond G.; Westlin, P.R.; Weant, G.E.; Wagoner, D.E. 1986 Comparisons Between MM5, OM7, and Draft ASTM Measurements of Wood Stove Emissions Proceedings of the 1986 Air Pollution Control Association Annual Meeting (86-74.8) EPA-600/D-86-150) (NTIS PB86-223096)

42 Shelton, Jay W.; Gay, Larry 1986 Evaluation of Low-Emission Wood Stoves — Final Report Shelton Research, Inc., Sante Fe, NM; Prepared for the California Air Resources Board, Sacramento, CA 43 Tiegs, Paul E.; Burnet, Paul G. 1986 Improving Flue Loss Methods for Measuring Wood Heater Thermal Performance OMNI Environmental Services, Inc., Beaverton, OR

44 Barnett, Stockton G. 1985 Handbook for Measuring Woodstove Emissions and Efficiency Using the Condar System (The Manufacturer’s Instructions for Source Sampling Method 41 of Oregon’s D.E.Q.) No Publication Information ListedA-13U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 45 Becker, Mimi; Barnett, Stockton G.; Cowden, James W.; Barnett, Lucy; Graham, Penny; Van Den Bossche, Krista; Hannan, Karen 1985 Residential Wood Combustion Emissions and Safety Guidebook Environmental Resource Center, Hiram College, Hiram, OH; Prepared for the Council of Great Lakes Governors, Great Lakes Regional Biomass Energy Program, Madison, WI

46 Energy Task Force of the Urban Consortium for Technology Initiatives 1985 Residential Space Heating with Wood: Efficiency and Environmental Performance Energy Task Force of the Urban Consortium for Technology Initiatives, Environmental Health and Energy Department, Energy Management Division, Albuquerque, NM 47 McCrillis, Robert C.; Merrill, Raymond G. 1985 Emission Control Effectiveness of a Woodstove Catalyst and Emission Measurement Methods Comparison Proceedings of the 78thAnnual Meeting of the Air Pollution Control Association, Detroit, MI (EPA-600/D-85-132) (NTIS PB85-218816)

48 OMNI Environmental Services, Inc. 1985 Standard Test Method for Determining the Heat Output Range and Maximum Burn Cycle Duration OMNI Environmental Services, Inc., Beaverton, OR

49 Shelton, Jay W.; Jaasma, Dennis R. 1985 Critical Assessment of Various Flue Loss Methods for Solid Fuel Heater Efficiency Measurement Shelton Energy Research, Santa Fe, NM; Presented at the 1985 Annual Meeting of the American Society of Heating, Refrigerating & Air Conditioning Engineers 50 Shelton, Jay W. 1985 ASTM Emissions and Efficiency Tests on Four Stoves Shelton Energy Research, Santa Fe, NM; Prepared for the Wood Heating Alliance, Washington, DC 51 Shelton, Jay W. 1985 Overview of Efficiency Measuring Methods Shelton Energy Research, Santa Fe, NM 52 Shelton, Jay W. 1985 Wood Stove Particulate Matter Test Methods and Emissions Factors Shelton Energy Research Report No. 1185, Santa Fe, NM; Prepared for the Colorado Department of Health, Air Pollution Control Division, Stationary Sources Program 53 Shelton, Jay W.; Barczys, C. 1985 Creosote — The Truth about Green Wood Shelton Energy Research, Santa Fe, NMA-14U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 54 Shelton, Jay W. 1985 Is 100% Overall Energy Efficiency Possible in Solid Fuel Residential Heaters? Shelton Energy Research, Santa Fe, NM

55 Allen, John M.; Piispanen, William H.; Cooke, Marcus 1984 Study of the Effectiveness of a Catalytic Combustion Device on a Wood Burning Appliance Battelle — Columbus Laboratories, Columbus, OH; Prepared for the U.S. Environmental Protection Agency, Office of Research and Development, Industrial Environmental Research Laboratory, Research Triangle Park, NC (EPA-600/7-84-046) (NTIS PB84-171545) 56 Lipari, Frank; Dasch, Jean M.; Scruggs, William F. 1984 Aldehyde Emissions from Wood-Burning Fireplaces Environmental Science & Technology, Vol. 18, No. 5, pp. 326-330

57 Shelton, Jay W.; Graeser, L.; Jaasma, Dennis R. 1984 Sensitivity Study of Traditional Flue Loss Methods for Determining Efficiencies of Solid Fuel Heaters Shelton Energy Research, Santa Fe, NM; Presented at the 1984 Annual Meeting of the American Society of Mechanical Engineers

58 Tiegs, Paul E.; Edmisten, Norman G.; Hatch, Candice L. 1984 Technical Report — Comparative Analysis of Current Woodstove Technologies: Emissions and Efficiencies Proceedings of the 77thAnnual Air Pollution Control Association Meeting & Exhibition, San Francisco, CA

59 Truesdale, R.S.; Mack, K.L.; White, J.B.; Leese, K.E.; Cleland, J.G. 1984 Characterization of Emissions from the Combustion of Wood and Alternative Fuels in a Residential Woodstove Research Triangle Institute, Research Triangle Park, NC; and the U.S. Environmental Protection Agency, Office of Research and Development, Industrial Environmental Research Laboratory, Research Triangle Park, NC (EPA-600/7-84-094) (NTIS PB85-105336) 60 Van der Heeden, D.J. 1984 Vergelijkend Onderzoek naar de Luchtverontreiniging van 17 Kachels voor Vaste Brandstof (Dutch) — Comparison of Air Pollution by 17 Solid Fuel Stoves Ministerie van Volkshuisvesting, Ruimtelijke Ordening en Milieubeheer, Consumentenbond

61 Tennessee Valley Authority 1983 Residential Wood Heater Test Report — Phase II Testing, Volume I Tennessee Valley Authority, Division of Energy Conservation and Rates, Energy Use Test Staff, Chattanooga, TN 62 Barnett, Stockton G. 1982 Woodstove Design and Control Mode as Determinants of Efficiency, Creosote Accumulation, and Condensable Particulate Emissions Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 70-88A-15U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 63 Dasch, Muhlbaler 1982 Particulate and Gaseous Emissions from Wood-Burning Fireplace Environmental Science & Technology, Vol. 16, No. 10, pp. 641-645 64 Hayden, A.C.S. 1982 Effects of Firing Rate and Design on Domestic Wood Stove Performance Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 56-69 65 Jaasma, Dennis R. 1982 Measurement Techniques and Emission Factors for Hand-Fired Coalstoves Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 129-150 66 Knight, C.V. 1982 Emission and Thermal Performance Mapping for an Unbaffled, Air-Tight Wood Appliance and a Box-Type Catalytic Appliance Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 25-55

67 Ramdahl, Thomas; Alfheim, Ingrid; Rustad, Ståle; Olsen, Torbjørn 1982 Chemical and Biological Characterization of Emissions from Small Residential Stoves Burning Wood and Charcoal Chemosphere, Vol. 11, No. 6, pp. 601-611

68 Sanborn, Cedric R. 1982 Characterization of Emissions from Residential Coal Stoves Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 151-160 69 Shelton, Jay W.; McGrath, J.; Lewis, C. 1982 Relative Creosote Accumulation in DoubleWall Mass-Insulated Chimneys vs. TripleWall Air-Insulated Chimneys Shelton Energy Research, Santa Fe, NM

70 Shelton, Jay W.; Graeser, L. 1982 An Investigation of the Effects of Ambient Temperature and Forced Convection on Radiant Stove Efficiency Shelton Energy Research, Santa Fe, NM; Prepared for the Wood Heating Alliance, Washington, DC; and Brookhaven National Laboratory, Upton, NY 71 Shelton, Jay W.; Lewis, C. 1982 Measured Creosote Reducing Effects of the Smoke Dragon, the Smoke Consumer, and a Barometric Draft Control Shelton Energy Research, Santa Fe, NMA-16U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 72 Tennessee Valley Authority 1982 Residential Wood Heater Test Report — Phase I Testing Tennessee Valley Authority, Division of Energy Conservation and Rates, Energy Use Test Staff, Chattanooga, TN 73 Truesdale, Robert S. 1982 Residential Stove Emissions from Coal and Other Alternative Fuels Combustion Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, Air Pollution Control Association, Louisville, KY, pp. 115-128 74 Allen, John M.; Cooke, W. Marcus 1981 Control of Emissions from Residential Wood Burning by Combustion Modification Battelle — Columbus Laboratories, Columbus, OH; and the U.S. Environmental Protection Agency, Office of Research and Development, Industrial Environmental Research Laboratory, Research Triangle Park, NC (EPA-600/7-81-091) (NTIS PB81-217655) 75 Allen, John M. 1981 Control of Emissions from Residential Wood Burning by Combustion Modification Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 167-190 76 Barnett, Stockton G. 1981 The Effects of Woodstove Design onCondensible Particulate Emissions, InHome Delivered Efficiency, and Creosote Formation Rate Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 268-269

77 Barnett, Stockton G.; Shea, Damian 1981 Effects of Woodstove Design and Operation on Condensible Particulate Emissions Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 227-266 78 Brandon, Robert J. 1981 Residential Wood Fired Furnaces: Results from a Demonstration of Advanced Designs Proceedings of Energy from Biomass and Wastes V, Institute of Gas Technology, Chicago, IL 79 Brandon, Robert J.; Murray, D. 1981 Pellet Wood Stokers Evaluation and Testing of Available Systems Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 941-965 80 Brandon, Robert J. 1981 An Assessment of the Efficiency and Emissions of Ten Wood Fired Furnaces Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, p. 267A-17U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 81 Butcher, Samuel S.; Ellenbecker, Michael J. 1981 Particulate Emission Factors for Small Wood and Coal Stoves Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 289-303 82 Cooke, W. Marcus; Allen, John M.; Hall, Robert E. 1981 Characterization of Emissions from Residential Wood Combustion Sources Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 139-163 83 Dickinson, Roger; Payne, Robert C. 1981 United Kingdom Efficiency Tests and Standards for Residential Solid Fuel Heating Appliances Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1055-1088 84 Giammer, Robert D. 1981 Evaluation of Emissions from Residential Coal-Fired Boilers under Stokeless Operation Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 304-312 85 Hall, Robert E. 1981 Emissions Assessment of a Standard Wood Stove Comparing Stack versus Dilution Tunnel Sampling Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, p. 270

86 Harper, Jerome P.; Knight, C.V. 1981 Measurement of Wood Heater Thermal and Emissions Performance Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 210-226 87 Hubble, B.R.; Harkness, J.B.L. 1981 Results of Laboratory Tests on Wood Stove Efficiency and Emissions Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, p. 277A-18U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 88 Hubble, B.R.; Stetter, J.R.; Gebert, E.; Harkness, J.B.L.; Flotard, R.D. 1981 Experimental Measurements of Emissions from Residential Wood-Burning Stoves Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 79-138 89 Hughes, Thomas W.; DeAngelis, Darryl G. 1981 Emissions from Coal-Fired Residential Combustion Equipment Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 333-348 90 Jaasma, Dennis R. 1981 Catalysis of Woodstove Effluent Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 832-850 91 Jaasma, Dennis R. 1981 Measurements of Chemical Changes Due to Catalysis of Woodstove Effluent Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 221-230 92 Kowalczyk, John F.; Bosserman, Peter B.; Tombleson, Barbara J. 1981 Particulate Emissions from New Low Emission Wood Stove Designs Measured by EPA Method V Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 54-78 93 Macumber, Dale W.; Jaasma, Dennis R. 1981 Efficiency and Emissions of a Hand-Fired Residential Coalstove Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 313-332 94 Muhlbaier, Jean L. 1981 A Characterization of Emissions from Wood-Burning Fireplaces Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 164-187 95 Peters, J.A.; Hughes, T.W.; DeAngelis, D.G. 1981 Wood Combustion Emissions at Elevated Altitudes Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 252-259A-19U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 96 Peters, James A. 1981 POM Emissions from Residential Woodburning: An Environmental Assessment Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 267-288 97 Peters, J.A.;Hughes, T.W.; DeAngelis, D.G. 1981 Wood Combustion Emissions at Elevated Altitudes Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 199-209 98 Pullen, Donald R.; Holden, Roger 1981 Design Features and Test Experiences with Domestic Wood Fired Heaters in New Zealand Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1166-1179 99 Roberts, John; Austin, Fred; Rossano, A.T.; Willenberg, Jay 1981 Measuring and Improving the Efficiency of Large Wood-Fired Furnaces — Impact on Emissions and Fuel Use Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1089-1116 100 Rudling, Lars; Bengt, Ahlingt; Lofröth, Goran 1981 Chemical and Biological Characterization of Emissions from Combustion of Wood and Wood-Chips in Small Furnaces and Stoves Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 34-53 101 Rustad, Ståle; Olsen, Torbjørn 1981 Charcoal — The Feasible Fuel for a Small, Automatically Fed, Clean Burning Residential Stove Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 984-995 102 Sanborn, Cedric R.; Blanchet, Michael 1981 Particulate Emissions from Residential Wood Combustion in Vermont Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 188-198A-20U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 103 Shelton, Jay W. 1981 Thermal Performance Testing Methods for Residential Solid Fuel Heaters Shelton Energy Research, Santa Fe, NM

104 Shelton, Jay W.; McGrath, Jane 1981 The Effects of Fuel Moisture Content, Species and Power Output on Creosote Formation Shelton Energy Research, Santa Fe, NM

105 Shelton, Jay W.; Alfano, Joseph; Buchen, Anthony 1981 The Effects of Creosote on Stovepipe Heat Transfer Shelton Energy Research, Santa Fe, NM

106 Shelton, Jay W. 1981 Results of the Research on Catalytic Combustion on Wood Stoves Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, p. 278 107 Shelton, Jay W. 1981 Thermal Performance Testing of Residential Solid Fuel Heaters Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1117-1159 108 Shelton, Jay W.; Barczys, Cathleen 1981 Dilution Air for Reducing Creosote Shelton Energy Research, Santa Fe, NM

109 Short, C.A. 1981 Home Heating with Wood Chips Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 966-983 110 VanDewoestine, Robert V.; Zimar, Frank 1981 Catalytic Combustion in Residential Wood Stoves Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 154-166 111 Zimar, Frank; VanDewoestine, Robert V.; Allaire, Roger A. 1981 The Effect of Catalytic Combustion on Creosote Reduction, Combustion Efficiency, and Pollution Abatement for Residential Wood Heaters Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 924-940 112 Day, Bill 1980 Wood Stove Durability: A Literature Review with Illustrations Northwest Information Enterprises, Beaverton, OR; Produced for Western Solar Utilization Network, Portland, OR (WSUN-27)A-21U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 113 DeAngelis, D.G.; Ruffin, D.S.; Peters, J.A.; Reznik, R.B. 1980 Source Assessment: Residential Combustion of Wood Monsanto Research Corporation, Dayton, OH; Prepared for the U.S. Environmental Protection Agency, Office of Research and Development, Industrial Environmental Research Laboratory, Research Triangle Park, NC (EPA-600/2-80-042b) (NTIS PB81-136160) 114 DeAngelis, D.G.; Ruffin, D.S.; Reznik, R.B. 1980 Preliminary Characterization of Emissions from Wood-Fired Residential Combustion Monsanto Research Corporation, Dayton, OH; Prepared for the U.S. Environmental Protection Agency, Office of Research and Development, Washington, DC (EPA-600/7-80-040) (NTIS PB80-182066) 115 State of California Air Resources Board 1980 Emissions from Residential Fireplaces — Report No. C-80-027 State of California Air Resources Board, Stationary Source Control Division, Engineering Evaluation Branch, Eureka, CA 116 Butcher, Samuel S.; Sorenson, Edmund M. 1979 A Study of Wood Stove Particulate Emissions Journal of the Air Pollution Control Association, Vol. 29, No. 7, pp. 724-728 117 Butcher, Samuel S.; Buckley, Douglas I. 1977 A Preliminary Study of Particulate Emissions from Small Wood Stoves Journal of the Air Pollution Control Association, Vol. 27, No. 4, pp. 346-348 118 Snowden, W.D.; Alguard, D.A.; Swanson, G.A.; Stolberg, W.E. 1975 Source Sampling Residential Fireplaces for Emission Factor Development Valentine, Fisher & Tomlinson, Seattle, WA; Prepared for the U.S. Environmental Protection Agency, Office of Air Quality Planning & Standards, Monitoring & Data Analysis Division, Research Triangle Park, NC (EPA-450/3-76-010) 119 British Standards Institute 1969 Recommendations for the Design and Testing of Smoke Reducing Solid Fuel Burning Domestic Appliances British Standards Institute, British Standards House, London, England

120 Allen, John M. Undated Control of Emissions from Residential Wood Burning by Combustion Modification Battelle — Columbus Laboratories, Columbus, OH

121 Brandon, Robert J. Undated An Assessment of the Efficiency and Emissions of Ten Wood Fired Furnaces Institute of Man and Resources, Charlottetown, Prince Edward Island, Canada 122 Jaasma, Dennis R.; Shelton, Jay W. Undated Proposed Method for Determination of Energy Efficiency of Wood Heaters Virginia Polytechnic Institute and State University, Blacksburg, VA; and Shelton Energy Research, Santa Fe, NMA-22U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #3 — WOOD USE AND ENERGY SURVEYS # AUTHOR DATE TITLE PUBLICATION INFORMATION 1 Kochera, Andrew 1997 Residential Use of Fireplaces Housing Economics, pp. 10-11 2 Energy Information Administration 1995 Housing Energy Consumption and Expenditures 1993 Energy Information Administration, Office of Energy Markets and End Use, Washington, DC (DOE/EIA-0321(93)) 3 Energy Information Administration 1995 State Energy Data Report 1993 — Consumption Estimates Energy Information Administration, Office of Energy Markets and End Use, Washington, DC (DOE/EIA-0214(93)) 4 Energy Information Administration 1994 Estimates of U.S. Biofuels Consumption 1992 Energy Information Administration, Office of Energy Markets and End Use, Washington, DC (DOE/EIA-0548(92)) 5 Oregon Department of Environmental Quality 1994 Portland — 1993 Oregon Woodheating Survey, Overview Report Oregon Department of Environmental Quality, Air Quality Division, Portland, OR 6 Sifford, Alex 1994 Residential Biofuel Marketing & Delivery Method Study Oregon Department of Energy, Salem, OR

7 Energy Information Administration 1993 Housing Energy Consumption and Expenditures 1990; Supplement: Regional Energy Information Administration, Office of Energy Markets and End Use, Washington, DC (DOE/EIA-0321(90)/S) 8 Energy Information Administration 1993 Housing Energy Consumption and Expenditures 1990 Energy Information Administration, Office of Energy Markets and End Use, Washington, DC (DOE/EIA-0321(90)) 9 OMNI Environmental Services, Inc. 1992 Study of Firewood Sources and Costs in Klamath Falls, Oregon and Sandpoint, Idaho OMNI Environmental Services, Inc. Beaverton, OR; Prepared for the Air & Waste Management Association, Pacific Northwest International Section (PNWIS), Bellevue, WA 10 Energy Information Administration 1991 Estimates of U.S. Biofuels Consumption 1990 Energy Information Administration, Office of Energy Markets and End Use, Washington, DC (DOE/EIA-0548(90)) 11 ES Field Services, Inc. 1991 Pocatello Air Quality RWC Device Usage, Survey Results ES Field Services, Inc.; Prepared for Marketing Research, Boise, ID 12 Kelly, Lou Ellyn; Park, Y.M. 1991 Klamath Falls Wood Heating Survey, 1991 Klamath County Department of Health Services, Klamath Falls, OR; Oregon Department of Environmental Quality, Air Quality Division, Portland, ORA-23U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #3 — WOOD USE AND ENERGY SURVEYS # AUTHOR DATE TITLE PUBLICATION INFORMATION 13 U.S. Department of Agriculture; U.S. Forest Service 1991 Wenatchee National Forest, Naches Ranger District, Environmental Assessment, Personal Use Firewood Program and Appendix U.S. Department of Agriculture; U.S. Forest Service, Pacific Northwest Region, Wenatchee National Forest, Naches Ranger District, Wenatchee, WA

14 Zamula, William W. 1989 Directorate for Economic Analysis — Room Heating Equipment Exposure Survey — Final Report U.S. Consumer Product Safety Commission, Washington, DC

15 Greene, William T.; Simons, Carl A. 1988 Estimating the Volume of Residential Wood Burning in the Pacific Northwest and Alaska, Task C — Final Report OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Department of Energy, Pacific Northwest and Alaska Regional Biomass Energy Program, (Administered by the Bonneville Power Administration, Portland, OR) (DOE/BP-18508-3) 16 Armitage, Sarah V. 1987 Report on the 1987 Klamath Falls Area Wood Heating Survey Oregon Department of Environmental Quality, Air Quality Division, Program Planning and Development, OR, Section Report No. 87-11 17 Steffel, Richard 1986 1986 Missoula Wood-Use Survey — Residential Wood Burning and Pollutant Emissions Eco-Resource Systems, Missoula, MT; Prepared for the Missoula City-County Health Department, Missoula, MT

18 Cote, William A.; Kaleel, Robert J. 1985 A Survey of Residential Combustion of Wood and Coal in Colorado TRC Environmental Consultants, Inc. Englewood, CO; Prepared for the U.S. Environmental Protection Agency, Region VIII, Air Programs Branch, Air and Hazardous Materials Division, Denver, CO; and Colorado Department of Health, Air Pollution Control Division, Denver, CO 19 Force, Jo Ellen 1985 Evaluation of Residential Wood Energy Use in Idaho — Final Report Department of Forest Resources, University of Idaho, Moscow, ID; Prepared for the Idaho Department of Water Resources, Boise, ID 20 Hayden, A.C.S.; Braaten, R.W. 1985 Wood Stove Operation and Advanced Design to Reduce Emissions of Incomplete Combustion Products Canadian Combustion Research Laboratory, ERL/CANMET, Energy, Mines & Resources Canada, Ottawa, Canada; Prepared for the Northeast Regional Air Pollution Conference, Amherst, MA 21 Oregon Department of Environmental Quality 1985 Medford Area Wood Heating Survey Oregon Department of Environmental Quality, Air Quality Division, Portland, ORA-24U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #3 — WOOD USE AND ENERGY SURVEYS # AUTHOR DATE TITLE PUBLICATION INFORMATION 22 Church, Scott; Steffel, Richard; Vallie, Robin; Grenfell, Judy 1984 1983 Wood-Cutting Permit Survey, A Study of Firewood Collection and Storage Patterns among Wood Burners in Missoula, MontanaEnvironmental Health Division, Missoula City-County Health Department, Missoula, MT

23 Church, Scott; Steffel, Richard; Vallie, Robin 1984 1983 Wood-Cutting Permit Survey Missoula City-County Health Department, Missoula, MT

24 Energy Information Administration 1984 Estimates of U.S. Wood Energy Consumption 1980-1983 Energy Information Administration, Office of Coal, Nuclear, Electric and Alternate Fuels, U.S. Department of Energy, Washington, DC (DOE/EIA-0341(83)) 25 Lippert, Frederick W.; Dungan, Jennifer L. 1983 Residential Firewood Use in the U.S. Science, Vol. 219, pp. 1425-1427

26 Skog, Kenneth E.; Watterson, Irene A. 1983 Survey Completion Report — Residential Fuelwood Use in the U.S.: 1980-81 U.S. Department of Agriculture; U.S. Forest Service, Forest Products Laboratory, Madison, WI 27 Martin, Werner; Koenigshofer, Daniel R. 1982 Survey and Analysis of Current European Technologies for Wood Combustion Integrated Energy Systems, Inc., Chapel Hill, NC; Prepared for the U.S. Environmental Protection Agency, Industrial Environmental Research Laboratory, Research Triangle Park, NC (EPA-600/7-83-006) (NTIS PB83- 156729) 28 Simmons Market Research Bureau, Inc. 1982 - present Simmons Study of Media & Markets Simmons Market Research Bureau, Inc.

29 Butcher, Thomas A.; Isler, Robert J. 1981 Coal-Oil Mixtures — An Alternative Fuel for the Commercial Markets and Large Residential Markets Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 706-728 30 High, Colin 1981 The Wood Resource and Its Use for Energy in the U.S. Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 670-679A-25U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #3 — WOOD USE AND ENERGY SURVEYS # AUTHOR DATE TITLE PUBLICATION INFORMATION 31 Petty, P.; Hopp, W.; Chockie, A. 1981 Biomass Energy Utilization in the Pacific Northwest: Impacts Associated with Residential Use of Solid Fuels Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 680-705 32 Strehler, Arno 1981 Energy from Straw and Woodwaste Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 729-745 33 Wainwright, Phyllis Brooks 1981 Wood Energy — The North Carolina Effort Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 260-265 34 Mediamark Research Inc. 1979 - present Mediamark Research Household & Personal

Appliances, Etc. — Report Mediamark Research Inc.

35 Bernergård, Leif Undated Small-Scale Solid Fuel Combustion in Sweden National Environmental Protection Board, Solna, SwedenA-26U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 1 Houck, James E. 1993 Atmospheric Emissions of Carbon Dioxide, Carbon Monoxide, Methane, Non-Methane Hydrocarbons, and Sub-Micron Elemental Carbon Particles from Residential Wood Combustion Proceedings of the 86thAnnual Air & Waste Management Association Meeting & Exhibition, Denver, CO (93-RP136.01)

2 Klinedinst, Donna B.; Klouda, George A.; Currie, Lloyd A.; et al. 1993 Radiocarbon Measurements of Extractable Organic Matter from the Integrated Air Cancer Project Study in Roanoke, VA Proceedings of the 1993 U.S. EPA/A&WMA International Symposium on Measurement of Toxic and Related Air Pollutants, Durham, NC; Published by Air & Waste Management Association, VIP-34, Pittsburgh, PA, pp. 197-206 3 Lewis, Charles W.; Zweidinger, Roy B.; Claxton, Larry D.; et al. 1993 Source Apportionment of Fine Particle Organics and Mutagenicity in Wintertime, Roanoke Proceedings of the 1993 U.S. EPA/A&WMA International Symposium on Measurement of Toxic and Related Air Pollutants, Durham, NC; Published by Air & Waste Management Association, VIP-34, Pittsburgh, PA, pp. 207-212 4 Lewtas, Joellen 1993 Complex Mixtures of Air Pollutants: Characterizing the Cancer Risk of Polycyclic Organic Matter Environmental Health Perspectives, Vol. 100, pp. 211-218

5 Lewtas, Joellen; Walsh, D.B.; Lewis, C.W.; et al. 1993 The Integrated Air Cancer Project: Overview of Roanoke Study and Comparison to Boise Study Proceedings of the 1993 U.S. EPA/A&WMA International Symposium on Measurement of Toxic and Related Air Pollutants, Durham, NC; Published by Air & Waste Management Association, VIP-34, Pittsburgh, PA, pp. 175-184 6 Stevens, R.K.; Hoffman, A.J.; Baugh, J.D.; et al. 1993 A Comparison of Air Quality Measurements in Roanoke, VA, and Other Integrated Air Cancer Project Monitoring Locations Proceedings of the 1993 U.S. EPA/A&WMA International Symposium on Measurement of Toxic and Related Air Pollutants, Durham, NC; Published by Air & Waste Management Association, VIP-34, Pittsburgh, PA, pp. 185-189 7 McCrillis, Robert C.; Watts, Randall R.; Warren, Sarah H. 1992 Effects of Operating Variables on PAH Emissions and Mutagenicity of Emissions from Woodstoves Journal of Air & Waste Management Association, Vol. 42, No. 5, pp. 691-694 (EPA-600/J-92-226) (NTIS PB92-195809)A-27U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 8 Steiber, Raymond S.; McCrillis, Robert C.; Dorsey, James A.; Merrill, Raymond G. 1992 Characterization of Condensible and Semivolatile Organic Materials from Boise Woodstove Samples Proceedings of the 85thAnnual Air & Waste Management Association Meeting & Exhibition, Kansas City, MO (92-118.03) (EPA-600/A-92-160) (NTIS PB92-206606)

9 Lewis, Charles W.; Stevens, Robert K.; Claxton, Larry D.; Barraclough, Donna; Klouda, George A. 1991 Source Apportionment of Mutagenic Activity of Fine Particle Organics in Boise, Idaho Proceedings of the 84thAnnual Air & Waste Management Association Meeting & Exhibit (91-131.3)

10 Steiber, Raymond S.; McCrillis, Robert C. 1991 Comparison of Emissions and Organic Fingerprints from Combustion of Oil and Wood Proceedings of the 84thAnnual Air & Waste Management Association Meeting & Exhibition, Vancouver, BC, pp. 2-10 (91-136.2) (EPA-600/D-91- 152) (NTIS PB91-223222) 11 Anderson, Norman 1989 Final Report — Risk Assessment Document for Residential Wood Combustion Emissions Environmental Toxicology Program, Environmental Health Unit, Division of Disease Control, Bureau of Health, ME (Appropriation #1310-1012) 12 Rau, John A. 1989 Tracers of Pollution from Wood Burning and Receptor Modeling Transactions of the International Specialty Conference, Receptor Models in Air Resources Management, San Francisco, CA; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 353-366 (ISBN 0-923204-01-6) 13 Rau, John A. 1989 Do Residential Wood Smoke Particles Lose Organic Carbon during Their Atmospheric Residence Time? — A Receptor Modeling Study Proceedings of the 82ndAnnual Air & Waste Management Association Meeting & Exhibition, Denver, CO (89-145.5)

14 U.S. Government Interagency Program’s Pacific Northwest and Alaska Regional Bioenergy Program 1989 Environmental Impact of Wood Combustion in Residential Woodstoves Woodstove Research Summaries, U.S. Government Interagency Program’s Pacific Northwest and Alaska Regional Bioenergy Program Yearbook, pp. 25-30 (DOE/BP-1179)A-28U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 15 U.S. Government Interagency Program’s Pacific Northwest and Alaska Regional Bioenergy Program 1989 Environmental Impact of Advanced Biomass Combustion Systems Woodstove Research Summaries, U.S. Government Interagency Program’s Pacific Northwest and Alaska Regional Bioenergy Program Yearbook, pp. 30-32 (DOE/BP-1179)

16 Wolgamott, D. Mitch; Erickson, Spencer L. 1989 Carbon Monoxide in a Wood Burning Community Proceedings of the 26thAnnual Air & Waste Management Association, Pacific Northwest International Section Meeting & Exhibition, Spokane, WA 17 Burton, Robert M. 1988 Final Design and Field Evaluation of the High Volume PM2.5Virtual Impactor Proceedings of the 1988 EPA/APCA Symposium on: Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 890-895 (EPA-600/9-88-015) (NTIS PB90-225863) 18 Cupitt, Larry T. 1988 Transformation of Boise Sources: The Production and Distribution of Mutagenic Compounds in Wood Smoke and Auto Exhaust Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 885-889 (EPA-600/9-88-015) (NTIS PB90-225863) 19 Cupitt, Larry T. 1988 The Integrated Air Cancer Project: Overview and Boise Survey Results Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 799-803 (EPA-600/9-88-015) (NTIS PB90-225863) 20 Currie, L.A. 1988 What Should We Measure? Aerosol Data: Past and Future Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 853-863 (EPA-600/9-88-015) (NTIS PB90-225863)A-29U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 21 Hawthorne, Steven B. 1988 Methoxylated Phenols as Candidate Tracers for Atmospheric Wood Smoke Pollution Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 57-62 (EPA-600/9-88-015) (NTIS PB90-225863) 22 Highsmith, V. Ross 1988 Impact of Residential Wood Combustion and Automotive Emissions on the Boise, Idaho Airshed Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 841-852 (EPA-600/9-88-015) (NTIS PB90-225863) 23 Houck, James E.; Simons, Carl A.; Pritchett, Lyle C. 1988 Estimating Carbon Monoxide Air Quality Impacts from Woodstoves, Task A — Final Report OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Department of Energy, Pacific Northwest and Alaska Regional Biomass Energy Program, (Administered by the Bonneville Power Administration, Portland, OR) (DOE/BP-18508-2) 24 Lewis, Charles W.; Baumgardner, Ralph E.; Stevens, Robert K.; Claxton, Larry D.; Lewtas, Joellen 1988 The Contribution of Woodsmoke and Motor Vehicle Emissions to Ambient Aerosol Mutagenicity Environmental Science and Technology, Vol. 22, No. 8, p. 968

25 Lewis, Charles W. 1988 Sources of Fine Particle Organic Matter in Boise Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 864-869 (EPA-600/9-88-015) (NTIS PB90-225863) 26 McMullen, Roy G.; Evans, Dallas E. 1988 Fireplaces and Carbon Monoxide Levels in Houston, Texas during Exceedances of the 8-Hour Average Carbon Monoxide Standard 1983 through 1986 Proceedings of the 81stAnnual Air and Pollution Control Association Meeting, Dallas, TXA-30U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 27 Merrill, Raymond G., Jr. 1988 Semivolatile and Condensible Extractable Organic Materials Distribution in Ambient Air and Woodstove Emissions Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 821-827 (EPA-600/9-88-015) (NTIS PB90-225863) 28 Steiber, R.S. 1988 GC/MS Analysis of Woodstove Emissions and Ambient Samples from a Wood Smoke Impacted Area Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 828-834 (EPA-600/9-88-015) (NTIS PB90-225863) 29 Stevens, R.K. 1988 Annular Denuder Results from Boise, ID Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 870-878 (EPA-600/9-88-015) (NTIS PB90-225863) 30 Watts, R. 1988 Mutagenicity of Organics Associated with PM2.5and PM10HiVol Particles from a Wood Smoke Impacted Residential Area Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 879-884 (EPA-600/9-88-015) (NTIS PB90-225863) 31 Zweidinger, Roy 1988 Distribution of Volatile Organic Hydrocarbons and Aldehydes during the IACP Boise, Idaho Residential Study Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 814-820 (EPA-600/9-88-015) (NTIS PB90-225863) 32 Bell, Douglas A. 1987 Non-Aqueous Ion Exchange Chromatography as a Preparative Fractionation Method for Short Term Bioassay Analysis of Wood Smoke Extracts Proceedings of the 1987 EPA/APCA Symposium: Measurement of Toxic and Related Air Pollutants; U.S. Environmental Protection Agency, Pittsburgh, PA, pp. 677-684 (EPA-600/9-87-010) (NTIS PB88- 113402)A-31U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 33 Braaten, R.W. 1987 Effects of Retrofit to Reduce Emissions from Existing Wood Stoves Proceedings of the 1987 EPA/APCA Symposium: Measurement of Toxic and Related Air Pollutants; U.S. Environmental Protection Agency, Pittsburgh, PA, pp. 685-690 (EPA-600/9-87-010) (NTIS PB88- 113402) 34 Claxton, Larry D. 1987 The Mutagenicity of Ambient and Source Samples from Woodsmoke Impacted Air Sheds Proceedings of the 1987 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants; U.S. Environmental Protection Agency, Pittsburgh, PA, pp. 591-596 (EPA-600/9-87-010) (NTIS PB88- 113402) 35 Cupitt, Larry T. 1987 IACP Emission: Transformations and Fate Proceedings of the 1987 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants; U.S. Environmental Protection Agency, Pittsburgh, PA, pp. 597-604 (EPA-600/9-87-010) (NTIS PB88- 113402) 36 Greene, William T.; Freeburn, Scott A. 1987 Preliminary Health Effects Evaluation for Pollutants Generated by Field Burning, Slash Burning, and Residential Wood Combustion OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Oregon Department of Environmental Quality, Eugene, OR

37 Highsmith, V. Ross 1987 The Collection of Neighborhood Air Samples Impacted by Residential Wood Combustion in Raleigh, NC and Albuquerque, NM Proceedings of the 1987 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants; U.S. Environmental Protection Agency, Pittsburgh, PA, pp. 562-572 (EPA-600/9-87-010) (NTIS PB88- 113402) 38 Houck, James E. 1987 The Contribution of Residential Wood Combustion of Respirable and Inhalable Particulate Concentrations in Missoula, Montana Proceedings of the 1987 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants; U.S. Environmental Protection Agency, Pittsburgh, PA, pp. 691-696 (EPA-600/9-87-010) (NTIS PB88- 113402) 39 Khalil, M.A.K.; Rasmussen, R.A.; Rau, John A. 1987 Air Pollution from Residential Wood Burning: A Case Study in Olympia, WA Proceedings of the 80thAnnual Air Pollution Control Association Meeting, New York, NY (87-101.1)A-32U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 40 Klouda, George A. 1987 The Source Apportionment of Carbonaceous Products by Micro-Radiocarbon Measurements for the Integrated Air Cancer Project (IACP) Proceedings of the 1987 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants; U.S. Environmental Protection Agency, Pittsburgh, PA, pp. 573-578 (EPA-600/9-87-010) (NTIS PB88- 113402) 41 Lewtas, Joellen 1987 Overview of the Integrated Air Cancer Project Proceedings of the 1987 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants; U.S. Environmental Protection Agency, Pittsburgh, PA, pp. 555-561 (EPA-600/9-87-010) (NTIS PB88- 113402) 42 Merrill, Raymond G. 1987 Progress toward Identifying Source Specific Tracers Proceedings of the 1987 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants; U.S. Environmental Protection Agency, Pittsburgh, PA, pp. 585-590 (EPA-600/9-87-010) (NTIS PB88- 113402) 43 Merrill, Raymond G.; Brusick, David 1987 Mutagenicity and Toxicity of Residential Wood Combustion Residue Samples U.S. Environmental Protection Agency, Air and Energy Engineering Laboratory, Research Triangle Park, NC; and Hazelton Laboratories of America, Kensington, MD 44 Schonburn, Michael; et al. 1987 Options for Reducing Emissions from Wood Burning Units in the Denver Metropolitan Area Denver Metropolitan Air Quality Council, Denver, CO; and Colorado University, Denver Graduate School of Public Affairs, Denver, CO

45 Zweidinger, Roy 1987 Volatile Organic Hydrocarbon and Aldehyde Composition in Raleigh, NC during the 1985 Woodsmoke Study Proceedings of the 1987 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants; U.S. Environmental Protection Agency, Pittsburgh, PA, pp. 579-584 (EPA-600/9-87-010) (NTIS PB88- 113402) 46 Bell, D.A.; Kamens, R.M.; Claxton, Larry D.; Lewtas, Joellen 1986 Photoreaction of Wood Smoke Particles: Destruction and Creation of Mutagens in Sunlight Proceedings of the 79thAnnual Air Pollution Control Association Meeting, Minneapolis, MN

47 Buchanan, James W.; Shutian, Li; Calloway, Clifton 1986 A Refinement of the Potassium Tracer Method for Residential Wood Smoke Proceedings of the 79thAnnual Air Pollution Control Association Meeting, Minneapolis, MN (86-77.6)A-33U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 48 Buchanan, James W. 1986 A Refinement of the Potassium Tracer Method for Residential Wood Smoke Proceedings of the 1986 EPA/APCA Symposium on Measurement of Toxic Pollutants, Raleigh, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-7, Pittsburgh, PA, pp. 748-754 (EPA-600/9-86-013) (NTIS PB87-182713) 49 Edgerton, S.A.; Khalil, M.A.K.; Rasmussen, R.A. 1986 Source Emission Characterization of Residential Wood-Burning Stoves and Fireplaces: Fine Particle/Methyl Chloride Ratios for Use in Chemical Mass Balance Modeling Environmental Science and Technology, Vol. 20, No. 8, pp. 803-807

50 Gebhart, D. Howard; Anderson, Stephen R. 1986 A Study Design for Characterization of Residential Wood Combustion Impacts in Suburban Settings Case Study: Fort Collins, Colorado Proceedings of the 79thAnnual Air Pollution Control Associations Meeting, Minneapolis, MN (86-74.3)

51 Kleindienst, Tadeusz E.; Shepson, Paul B.; Edney, Edward O.; Claxton, Larry D.; Cupitt, Larry T. 1986 Wood Smoke: Measurement of the Mutagenic Activities of Its Gas- and Particulate-Phase Photooxidation Products Environmental Science and Technology, Vol. 20, No. 5, pp. 493-501

52 Kleindienst, T.E.; Shepson, P.B.; Edney, E.O. 1986 Mutagenic Activities of Wood Smoke Photooxidation Products U.S. Environmental Protection Agency, Atmospheric Sciences Research Laboratory, Research Triangle Park, NC (EPA-600/3-86-049) (NTIS PB86-239837) 53 Klouda, George A.; Currie, L.A.; Donahue, D.J.; Jull, A.J.T.; Naylor, M.H. 1986 Urban Atmospheric14CO and14CH4 Measurements by Accelerator Mass Spectrometry Radiocarbon, Vol. 28, No. 2A, pp. 625-633

54 Leese, K.E.; McCrillis, Robert C. 1986 Integrated Air Cancer Project, Source Measurement Proceedings of the 79thAnnual Air Pollution Control Association Meeting, Minneapolis, MN (EPA-600/D-86-152) (NTIS PB86-222924) 55 OMNI Environmental Services, Inc. 1986 Effects of Thermal Stress on Catalytic Combustion Performance — Volume I OMNI Environmental Services, Inc.; Prepared for the Matsushita Battery Industrial Co., Ltd., Osoka, JapanA-34U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 56 Rau, John A. 1986 Residential Wood Combustion Aerosol Characterization as a Function of Size and Source Apportionment Using Chemical Mass Balance Modeling Ph. D. Dissertation, Oregon Graduate Center, Chemical, Biological, and Environmental Sciences Department, Beaverton, OR

57 Edgerton, Sylvia A. 1985 Gaseous Tracers in Receptor Modeling: Methyl Chloride Emission from Wood Combustion Ph. D. Dissertation, Oregon Graduate Center, Environmental Science Department, Beaverton, OR

58 Environmental Research & Technology, Inc. 1985 Air Quality Monitoring and Control for the City of Fort Collins — Volume IV: Results of the 1984-1985 Winter Residential Wood Combustion Study Prepared for the City of Fort Collins Community Development Department Planning Division, Fort Collins, CO

59 Inoye, Daniel 1985 Estimation of Carbon Monoxide and Particulate Emissions from Woodburning Devices in the Fresno/Clovis Metropolitan Area No Publication Information Listed

60 Kamens, Richard M.; Bell, Douglas A.; Dietrich, Andrea; Perry, Jean; Goodman, Randall; Claxton, Larry D.; Tejada, Sylvestre 1985 Mutagenic Transformations of Dilute Wood Smoke Systems in the Presence of Ozone and Nitrogen Dioxide. Analysis of Selected High-Pressure Liquid Chromatography Fractions from Wood Smoke Particle Extracts Environmental Science and Technology, Vol. 19, No. 1, pp. 63-69

61 Rau, John A.; Huntzicker, James J. 1985 Size Distribution and Chemical Composition of Residential Wood Smoke Proceedings of the 78thAnnual Air Pollution Control Association Meeting, Detroit, MI (85-43.3) 62 Stapleton, Jim 1985 Air Pollution Due to Residential Space Heating in the Mid-Hudson Valley Hudsonia Limited, Bard College, Annandale, NY; Prepared for the Central Hudson Gas and Electric Corp., Poughkeepsie, NY 63 Core, John E.;Cooper, John A.; Neulicht, Roy M. 1984 Current and Projected Impacts of Residential Wood Combustion on Pacific Northwest Air Quality Journal of the Air Pollution Control Association, Vol.31, No. 2, pp. 138-143A-35U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 64 Currie, Lloyd A.; Klouda, George A.; Voorhees, Kent J. 1984 Atmospheric Carbon: The Importance of Accelerator Mass Spectrometry Nuclear Instruments and Methods in Physics Research, Vol. 233 [B5], No. 2, pp. 371-379

65 Department of Ecology, State of Washington 1984 Residential Wood Stove Emissions in Yakima and Olympia State of Washington Department of Ecology, Olympia, WA

66 Duker, D.C.; Levaggi, D.A.; Umeda, T.; DeMandel, R.E.; Perardi, T.E. 1984 Measurements of a Carbon Monoxide Cloud in San Jose, California Proceedings of the 77thAnnual Air Pollution Control Association Meeting, San Francisco, CA (84-87.4)

67 Kamens, Richard M.; Rives, Glenn D.; Perry, Jean M.; Bell, Douglas A.; Paylor, R. Flynn; Goodman, Randall G.; Claxton, Larry D. 1984 Mutagenic Changes in Dilute Wood Smoke as It Ages and Reacts with Ozone and Nitrogen Dioxide: An Outdoor Chamber Study Environmental Science and Technology, Vol. 18, No. 7, pp. 523-530

68 Zak, B.D.; Einfeld, W.; Church, H.W.; Gay, G.T.; Jensen, A.L.; Trijonis, J.; Ivey, M.D.; Homann, P.S.; Tipton, C. 1984 The Albuquerque Winter Visibility Study Vol. 1 Overview and Data Analysis U.S. Department of Energy, Sandia Report (SAND84-0173/1 DE84 014356)

69 Hytönen, S.; Alfheim, I.; Sorsa, M. 1983 Effect of Emissions from Residential Wood Stoves on SCE Induction in CHO Cells Mutation Research, Vol. 118, pp. 69-75

70 Kelly, Mary E. 1983 Sources and Emissions of Polycyclic Organic Matter (POM) U.S. Environmental Protection Agency, Research Triangle Park, NC (EPA-450/5-83-010b) (NTIS PB84-144153) 71 Ramdahl, Thomas 1983 Retene-A Molecular Marker of Wood Combustion in Ambient Air Nature, Vol. 306, No. 8, pp. 580-582A-36U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 72 Beck, Barbara D. 1982 Prediction of the Pulmonary Toxicity of Respirable Combustion Products from Residential Wood & Coal Stoves Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 264-280 73 Imhoff, Robert E. 1982 Final Report on a Study of the Ambient Impact of Residential Wood Combustion in Petersville, AL Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 161-188 74 Johnston, Ralph E.; Arkell, Donald R. 1982 A Preliminary Analysis of the Impact of Residential Wood Combustion Emissions on Ambient Carbon Monoxide Levels Lane Regional Air Pollution Authority, Eugene, OR

75 Kamens, Richard M. 1982 An Outdoor Exposure Chamber to Study Wood Combustion Emissions under Natural Conditions Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 207-225 76 Klouda, George A. 1982 Estimating the Impact of Atmospheric Carbonaceous Particulates on Urban and Rural Environments by Radiocarbon Measurements Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 189-206

77 Lipfert, Frederick W. 1982 A National Assessment of the Air Quality Impacts of Residential Firewood Use Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 226-239 78 Allwine, K.J., Jr. 1981 Assessment of the Long-Range Transport of Residential Woodstove Fine Particulate Emissions for Two Future U.S. Energy Scenarios Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 398-414 79 Barnard, Barry L. 1981 Regulating Residential Biomass Combustion in the Tennessee Valley Region Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1216-1228A-37U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 80 Benton, Gary; Miller, Don Paul; Reimold, Mary; Sisson, Richard 1981 A Study of Occupant Exposure to Particulates and Gases from Woodstoves in Homes Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 456-468 81 Bohac, Charles; Duncan, Joseph R.; Beeman, Larry E. 1981 Residential Wood Combustion Issues for the Tennessee Valley Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, p. 274

82 Brimblecombe, Peter 1981 Environmental Impact of Fuel Changes in Early London Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1-11 83 Carlson, James H. 1981 Residential Wood Combustion in Missoula, Montana: An Overview of Its Air Pollution Contributions, Health Effects, and Proposed Regulatory Solutions Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 539-550 84 Colome, Steven D.; Spengler, John D. 1981 Residential Indoor and Matched Outdoor Pollutant Measurements with Special Consideration of Wood-Burning Homes Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 435-455 85 Cooper, John A. 1981 Chemical and Physical Methods of Apportioning the Contributions of Emissions from Residential Solid Fuels to Reductions in Air Quality Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 349-364 86 Currie, L.A.; Klouda, George A.; Gerlach, R.W. 1981 Radiocarbon: Nature's Tracer for Carbonaceous Pollutants Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 365-385A-38U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 87 DeCesar, Richard T. 1981 The Quantitative Impact of a Residential Wood Combustion and Other Vegetative Burning Sources on the Air Quality in Medford, Oregon Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 551-565 88 Greene, W.T.; Tombleson, B.J. 1981 Institutional and Regulatory Approaches to Control Residential Wood Burning Emissions Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1229-1252 89 Hornig, James F.; Soderberg. Roger H.; Larsen, Deborah; Parravano, Carlo 1981 Ambient Air Assessment in Rural Village and Small Town Locations in New Hampshire where Wood Is an Important Fuel Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 506-519 90 Imhoff, Robert E.; Manning, Justice A.; Cook, William M.; Hayes, Timothy L. 1981 Preliminary Report on a Study of the Ambient Impact of Residential Wood Combustion in Petersville, Alabama Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 520-538 91 Jacobs, Philip; Snowden, Bunch 1981 Health Costs of Residential Wood Combustion Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 657-669 92 Kelsey, Morris I.; Kraybill, H.F.; Helmes, C. Tucker, Sigman, Caroline C. 1981 A Data Base of Organic Pollutants that Have Been Evaluated for Carcinogenicity and Mutagenicity Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 577-605 93 Kosel, Peter H. 1981 Pollution and Fireplaces in California Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 242-251 94 Kosel, Peter H. 1981 Pollution and Fireplaces in California Proceedings of the 1981 Wood Combustion Environmental Assessment ConferenceA-39U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 95 Kowalczyk, J.F.; Greene, W.T. 1981 New Techniques for Identifying Ambient Air Impacts from Residential Wood Heating Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 469-494 96 Lawther, P.J. 1981 Historic Changes in Air Pollution in Great Britain Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 566-576 97 Lewtas, Joellen 1981 Comparison of the Mutagenic and Potentially Carcinogenic Activity of Particle Bound Organics from Wood Stoves, Residential Oil Furnaces, and Other Combustion Sources Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 606-619

98 Lim, K.J.; Lips, H.I. 1981 Overview of Emissions from Wood Combustion Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, p. 273 99 Lipfert, Frederick W. 1981 An Assessment Methodology for the Air Quality Impact of Residential Wood Burning Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 415-434 100 Machlin, Paula R. 1981 Residential Solid Fuels in the Environmental Protection Agency Region VIII States Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1197-1215 101 Martin, Werner 1981 European Experiences and Activities in Assessing the Environmental Impacts from Wood Combustion Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1180-1196A-40U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 102 Meyer, H. Robert 1981 The Contribution of Residential Wood Combustion Local Airshed Pollutant Concentrations Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 386-397 103 Morris, Gregory 1981 Health Effects of Residential Wood Combustion — The Implications of Environmental Stochasticity Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 648-656 104 Mors, Terry A.; Blair, Terence T.; Cole, Robert H. 1981 Regulatory Options for Controlling Emissions from Combustion of Wood in Residential Applications Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1253-1271 105 Murphy, Dennis J.; Buchan, Roy M.; Fox, Douglas G. 1981 Ambient Particulate and Benzo (") Pyrene Concentrations from Residential Wood Combustion, in a Mountain Resort Community Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 495-505 106 Santodonato, Joseph; Basu, Dipak; Bruce, Robert 1981 Multimedia Human Exposure to Polycyclic Aromatic Hydrocarbons and Their Association with Cancer Risk Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 620-647 107 Schwengels, Paul; Bohac, Charles; Krickenberger, Kit 1981 An Integrated Environmental Assessment of Biomass Energy Development in the Tennessee Valley Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, p. 272

108 Cooper, John A. 1980 Environmental Impact of Residential Wood Combustion Emission and Its Implications Journal of the Air Pollution Control Association, Vol. 30, No. 8, pp. 855-861 109 Davis, Briant L. 1980 Composition and Sources of Airborne Particulate Matter Observed in Wintertime at Missoula, Montana Prepared for the Montana State Department of Health and Environmental Science, Missoula, MTA-41U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List 

### CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES # AUTHOR DATE TITLE PUBLICATION INFORMATION 110 Harris, Howard W. Undated An Investigation of Elevated Carbon Monoxide and Nephelometer Data in a Portland Residential Neighborhood Affected by Wood Smoke Oregon Department of Environmental Quality, Portland, OR

111 Hornig, James F.; Soderberg, Roger H.; Barefoot, Aldos C., III Undated Woodsmoke Analysis: Vaporization Losses of PAH from Filters and Levoglucosan as a Distinctive Marker for Woodsmoke Proceedings for the Eighth International Symposium on Polynuclear Aromatic Hydrocarbons: Mechanisms, Methods and Metabolism, Wilmington, DE, pp. 561-568 112 Lao, R.C.; Thomas, R.S.; Lanoy, M.; Lee, S. Win Undated Investigation of PAH and Polychlorinated Organic Pollutant Emissions from Wood Combustion Sources Laboratory Services Division, Air Pollution Control Directorate, Environment Canada, Ottawa, Canada, pp. 745-755

113 Weston, Roy F. Undated Particulate Emissions from Residential Wood Combustion — Final Report Roy F. Weston Co., West Chester, PA; Prepared for Northeast Regional Biomass Program, CONEG Policy Research Center, Inc.A-42U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #5 — REGULATORY REVIEWS # AUTHOR DATE TITLE PUBLICATION INFORMATION

1 U.S. Environmental Protection Agency 1996 1993 1992 1983 Emission Factor Documentation for AP-42

Section 1.9, Residential Fireplaces, and Section 1.10, Residential Wood Stoves U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Office of Air and Radiation, Research Triangle Park, NC, (Section 1.9 EPA-450/4-82-004, and Section 1.10 EPA-450/4-82-003 ) 2 Collier, David L. 1995 Medford And Klamath Falls, Oregon — Success in Controlling Residential Wood Combustion — Possible Implications of New Particulate Matter Standard Proceedings of an International Specialty Conference, Particulate Matter: Health and Regulatory Issues; Published by Air & Waste Management Association, Pittsburgh, PA, VIP-49, Pittsburgh, PA, pp. 776-788 3 Appel, J. 1992 Current Limitations and Future Prospects of Residential Wood Combustion Controls in the Pacific Northwest Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 614-624 (ISBN 0-923204-09-1) 4 Hough, M.; et al. 1992 Progress to Achieve Residential Wood Combustion PM10Emission Reductions in Medford, Oregon as Determined by Compliance Surveys and Ambient Monitoring Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 637-645 (ISBN 0-923204-09-1) 5 Manderino, L. 1992 An Integrated Community Approach to Reducing Residential Woodsmoke: Innovative Funding of Control Strategies Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 716-729 (ISBN 0-923204-09-1) 6 Maykut, N.; Fry, S. 1992 Woodsmoke Control in the Puget Sound Region Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 625-636 (ISBN 0-923204-09-1)A-43U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #5 — REGULATORY REVIEWS # AUTHOR DATE TITLE PUBLICATION INFORMATION

7 Morris, A.; et al. 1992 An Integrated Community Approach to Reducing Residential Woodsmoke: Community Analysis and Education Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 700-715 (ISBN 0-923204-09-1) 8 OMNI Environmental Services, Inc. 1992 Residential Wood Combustion Control Measures for the Pocatello PM10 Nonattainment Area OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Environmental Protection Agency, Region X, Seattle WA

9 Ono, D.; Taylor, W. 1992 Town of Mammoth Lakes Air Quality Regulations Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 657-668 (ISBN 0-923204-09-1) 10 Pettingill, D.; et al. 1992 Evaluation of Washoe County, NV Control Strategies for Reducing Emissions from Residential Woodburning Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 646-656 (ISBN 0-923204-09-1) 11 Shwayder, P. 1992 Burning Wood — A Political Perspective: Case Studies from the Denver Region Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 669-679 (ISBN 0-923204-09-1) 12 Stapp, S.; Harley, R. 1992 An Effective Woodburning Control Program: Albuquerque/Bernalillo County, New Mexico, USA Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 730-740 (ISBN 0-923204-09-1) 13 Stoneman, C.; Pace, T. 1992 Technical Guidance for Residential Wood Combustion: Reasonably and Best Available Control Measures Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 601-613 (ISBN 0-923204-09-1)A-44U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #5 — REGULATORY REVIEWS # AUTHOR DATE TITLE PUBLICATION INFORMATION

14 Davis, Bob 1989 Guidance Document for Residential Wood Combustion Emission Control Measures U.S. Environmental Protection Agency Office of Air and Radiation, Office of Air Quality Planning and Standards, Research Triangle Park, NC, (EPA-450/2-89-015) (NTIS PB90-130444) 15 Butler, Alan T. 1988 Control Of Woodstoves by State Regulation as a Fine Particulate Emission Control Strategy Transactions of the APCA/EPA International Specialty Conference, PM10Implementation Standards, TR-13, San Francisco, CA; Published by the Air Pollution Control Association, Pittsburgh, PA, pp. 654-663 16 Hough, Merlyn 1988 Oregon’s Approach to Reducing Residential Woodsmoke as Part of the PM10Strategy Transactions of the APCA/EPA International Specialty Conference, PM10Implementation Standards, TR-13, San Francisco, CA; Published by the Air Pollution Control Association, Pittsburgh, PA, pp. 646-653 17 Westlin, Peter R. 1987 The Environmental Protection Agency's Accreditation Program for Wood Heater Testing Laboratories Proceedings of the 1987 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, U.S. Environmental Protection Agency, Pittsburgh, PA, pp. 707-711 (EPA-600/9-87-010) (NTIS PB88- 113402) 18 Gay, Robert; Shah, Jitendra 1986 Technical Support Document for Residential Wood Combustion NERO and Associates, Inc., Portland, OR; Prepared for the U.S. Environmental Protection Agency, Office Of Air and Radiation, Office of Air Quality Planning and Standards, Research Triangle Park, NC, (EPA-450/4-85-012) (NTIS PB97-149538) 19 Jenkins, Pamela G. 1986 Wood Smoke: Emissions, Impacts, and Reduction Strategies. Washington Department of Ecology, Air Program, Olympia, WA

20 Radian Corporation 1986 Evaluation of Emission Limit Formats for Residential Woodburning Appliances Radian Corporation, Research Triangle Park, NC; Prepared for the U.S. Environmental Protection Agency, Emission Standard and Engineering Division, Research Triangle Park, NC (DCN no. 86-231-020-25-04) 21 Radian Corporation 1986 Wood Load Effect on Particulate Emissions from Residential Woodburning Appliances Radian Corporation, Research Triangle Park, NC; Prepared for the U.S. Environmental Protection Agency, Emission Standard and Engineering Division, Research Triangle Park, NC (DCN no. 86-231-020-25-02)A-45U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List


### CATEGORY #5 — REGULATORY REVIEWS # AUTHOR DATE TITLE PUBLICATION INFORMATION

22 OMNI Environmental Services, Inc. 1985 Standard Test Method for Determining the Heat Output Range and Maximum Burn Cycle Duration, Residential Wood-Fired Closed Combustion-Chamber Heating Appliances OMNI Environmental Services, Inc., Beaverton, OR

23 Braaten, R.W.; Hayden, A.C.S. 1984 Status of Canadian Standard for Efficiency and Emissions of Domestic Wood-Fired Appliances Canadian Combustion Research Laboratory, ERL/CANMET, Energy, Mines & Resources Canada, Ottawa, Canada

24 Grotheer, Wayne E. 1984 Overview of Control Strategies for Residential Wood Combustion Proceedings of the 77thAnnual Air Pollution Control Association Conference, San Francisco, CA (84-70.1) 25 Carlsson, Sten-Åke 1981 Residential Wood Combustion in Sweden — Environmental Aspects and Regulations Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1160-1165 26 Greene, William T.; Tomleson, Barbera J. 1981 Institutional and Regulatory Approaches to Control Residential Wood Burning Emissions Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, p. 271

27 Hall, R.E. 1981 EPA’s Research Program for Controlling Residential Wood Combustion Emissions Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 44-63 28 Sundström, Lars 1981 Method for Measuring Heat Output and Efficiency on Wood Heating Appliances and Results from Tests on Ten Woodstoves and Fireplaces Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 1038-1054 29 Hall, Robert E.; DeAngelis, Daryl G. 1980 EPA’s Research Program for Controlling Residential Wood Combustion Emissions Journal of the Air Pollution Control Association, Vol. 30, No. 8, pp. 862-867A-46U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List



### CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS # AUTHOR DATE TITLE PUBLICATION INFORMATION 1 Anonymous 1994 Fuelwood Plant Demonstrates Use of Clean, Renewable Fuel for Heating and Cooling Arbor Day, Nebraska City, NE, p. 7

2 Tiegs, Paul E.; Vaughan, Patrick; Bighouse, Roger D. 1993 Spillage of Combustion Byproducts from Woodstoves Operated in Negative Pressure Environments OMNI Environmental Services, Beaverton, OR; Prepared for Bonneville Power Administration, Resource Management Residential Department (DE-AP79-92BP60576-M001) 3 Walsh, Debra; Warren, Sarah; Zweidinger, Roy; et al. 1993 Mutagenicity of Indoor Air in Boise, Idaho and Roanoke, Virginia Proceedings of the 1993 U.S. EPA/A&WMA International Symposium on Measurement of Toxic and Related Air Pollutants, Durham, NC; Published by Air & Waste Management Association, VIP-34, Pittsburgh, PA, pp. 190-196 4 Broome, F. 1992 The Development of Clean-Burning Noncatalytic Manufactured Fireplaces Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 585-588 (ISBN 0-923204-09-1) 5 Bushway, Stephen 1992 The New Woodburner’s Handbook — A Guide to Safe, Healthy & Efficient Woodburning Capitol City Press Fast Printing, Storey Communications, Inc., Pownal, VT

6 CONEG Policy Research Center 1992 Pamphlet — How to Burn Wood Right — Choosing and Using Your Wood Stove in Today’s Environment CONEG Policy Research Center, New York State Energy Research and Development Authority

7 Myren, A., Jr. 1992 The Development of the Clean Burning Inside-Out Flame in Noncatalytic Woodstoves Transactions of the A&WMA/EPA International Specialty Conference, PM10Standards and Nontraditional Particulate Source Controls, Volume II, TR-22; Published by Air & Waste Management Association, Pittsburgh, PA, pp. 589-592 (ISBN 0-923204-09-1) 8 Barnett, Stockton G. 1991 Report to the City of Fresno, California on the Implications of a Project that Measured Masonry Fireplace and Heater Emissions in Homes OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the City of Fresno, CA; Prepared for the Masonry Institute and Western States Clay Products Association, San Mateo, CAA-47U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List



### CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS # AUTHOR DATE TITLE PUBLICATION INFORMATION 9 California Air Resources Board 1991 Woodburning Handbook — How to Burn More Efficiently in Your Stove or Fireplace and Produce Less Air Pollution California Air Resources Board, Sacramento, CA

10 Melcon, Daniel 1989 Pellet Primer — An Introduction to Heating with Wood Pellets Biomass Publications of America, Portland, OR

11 Barden, Albert; Hyytiäinen, Heikki 1988 Finnish Fireplaces — Heart of the Home Building Book Ltd., Finland

12 Evans, Robert J.; Milne, Thomas A. 1988 Relevancy of Wood Pyrolysis Chemistry to Wood Stove Emissions Chemical Conversion Research Branch, Solar Energy Research Institute, Golden, CO; Presented at the 1988 American Chemical Society National Summer Meeting, Denver, CO 13 Greene, William T. 1988 Cost/Benefit Analysis of Mitigation Measures for Minimizing Environmental Impacts of Residential Wood Combustion, Task F — Final Report OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Department of Energy, Pacific Northwest and Alaska Regional Biomass Energy Program, (Administered by the Bonneville Power Administration, Portland, OR) (DOE/BP-18508-7) 14 Greene, William T.; Simons, Carl A.; Houck, James E. 1988 Mitigation Measures for Minimizing Environmental Impacts from Residential Wood Combustion, Task E — Final Report OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the U.S. Department of Energy, Pacific Northwest and Alaska Regional Biomass Energy Program, (Administered by the Bonneville Power Administration, Portland, OR) (DOE/BP-18508-5) 15 Highsmith, V. Ross 1988 Influence of Residential Wood Combustion Emissions on Indoor Air Quality of Boise, Idaho Residences Proceedings of the 1988 EPA/APCA Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-10, Pittsburgh, PA, pp. 804-813 (EPA-600/9-88-015) (NTIS PB90-225863) 16 Peacock, Richard D. 1987 Wood Heating Safety Research: An Update Fire Technology, Vol. 223, No. 4, pp. 229-312 17 Wilson, Pamela L.; Funck, James W.; Avery, Robert B. 1987 Fuelwood Characteristics of Northwestern Conifers and Hardwoods — Research Bulletin 60 Forest Research Laboratory, College of Forestry, Oregon State University, Corvallis, ORA-48U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List



### CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS # AUTHOR DATE TITLE PUBLICATION INFORMATION 18 Chase, Craig L. 1986 Pacific Northwest and Alaska Bioenergy Program Glossary U.S. Government Interagency Program, Department of Energy, Bonneville Power Administration, Portland, OR 19 Harris, Robert A.; McMinn, James W.; Payne, Fred A. 1986 Calculating and Reporting Changes in Net Heat of Combustion of Wood Fuel Forestry Products Journal, Vol. 36, No. 6, pp. 57-60

20 Humphreys, Mallory P. 1986 Residential Wood Combustion Impacts on Indoor Carbon Monoxide and Suspended Particulates Proceedings of the 1986 EPA/APCA Symposium on Measurement of Toxic Pollutants, Raleigh, NC; U.S. Environmental Protection Agency; Published by the Air Pollution Control Association, VIP-7, Pittsburgh, PA, pp. 736-747 (EPA-600/9-86-013) (NTIS PB87-182713) 21 OMNI Environmental Services, Inc. 1986 Compendium of Environmental and Safety Regulations and Programs Affecting Residential Wood Heating Appliances OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the Bonneville Power Administration, Portland, OR

22 Canadian Wood Energy Institute 1985 Conference Proceedings of the Firewood 85 Canadian Wood Energy Institute

23 Hartman, M.W.; Rives, G.D. 1985 Literature Review and Survey of Emissions from Residential Wood Combustion and Their Impact Radian Corporation, Research Triangle Park, NC; Prepared for the U.S. Environmental Protection Agency, Office of Research and Development, Air and Energy Engineering Research Laboratory, Research Triangle Park, NC (EPA-600/2-85-047) (NTIS PB85-197820) 24 Ontario Task Force 1985 Report of the Ontario Task Force on Residential Wood Heat Safety Prepared for the Minister of Energy, Toronto, Ontario, Canada

25 Turbak, Gary 1984 New Technologies Fight — Wood-Stove Pollution Popular Science, December 1984, pp. 90-92

26 Portland, The City of 1983 Woodstoves — Installation and Use — Portland, OR The City of Portland, Portland, OR

27 U.S. Environmental Protection Agency 1983 Pamphlet — Wood Stove Features and Operation Guideline for Clean Air U.S. Environmental Protection Agency, Research and Development (EPA-600/D-83-112) 28 Allen, John M. 1982 Techniques for Achieving More Complete Combustion in Wood Stoves Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 2-24A-49U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List



### CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS # AUTHOR DATE TITLE PUBLICATION INFORMATION 29 Barnett, Stockton G. 1982 The Effects of Stove Design and Control Mode on Condensible Particulate Emissions, Flue Pipe Creosote Accumulation and the Efficiency of Woodstoves in Homes Proceedings of the Institute of Gas Technology Symposium for Energy from Biomass and Waste VI Meeting, Lake Buena Vista, FL, pp. 283-322

30 Bortz, Paul 1982 Getting More Heat from Your Fireplace Garden Way Publishing, Charlotte, VT 31 Busha, William; Morris, Stephen 1982 The Book of Heat — A Four Season Guide to Wood and Coal Heating The Stephen Greene Press, Brattleboro, VT, Lexington, MA (Rev. ed. of: The Book Of Heat (1948)) 32 Flagler, Gordon 1982 The North American Wood Heat Handbook Charles Scribner’s Sons, New York, NY (Rev. ed. of: The Canadian Wood Heat Book (1979)) 33 Martin, Werner 1982 European Activities in Solid Fuel Fired Heating Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 89-114 34 Miller, D.P. 1982 Indoor Exposure to Carbon Containing Particulates and Vapors in Homes which Use Wood for Heating Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 281-295 35 Neulicht, Roy M. 1982 Impact of Residential Wood Combustion Appliances on Indoor Air Quality Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 240-252 36 Osborne, Michael C. 1982 Residential Wood & Coal Combustion Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, p. 1 37 Traynor, Gregory W. 1982 Indoor Air Pollution from PortableKerosene-Fired Space Heaters, WoodBurning Stoves, and Wood-Burning Furnaces Proceedings of the Residential Wood & Coal Combustion — Specialty Conference, the Air Pollution Control Association, Louisville, KY, pp. 253-263

38 Anonymous 1981 Fireplaces and Woodstoves Time-Life Books Inc., Chicago, IL 39 Bendersky, Charles 1981 Results of the DOE Think Shop on Residential Wood Combustion Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, p. 275A-50U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List



### CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS # AUTHOR DATE TITLE PUBLICATION INFORMATION 40 Cohen, Maurice 1981 The Woodcutters Companion — A Guide to Locating, Cutting, Transporting, and Storing Your Own Firewood Rodale Press, Emmaus, PA

41 Earl, William L. 1981 An Investigation of Wood Pyrolysis Using Solid State13C Nuclear Magnetic Resonance Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 772-788 42 Faista, Michael B.; Davidovits, Paul 1981 Formation of Submicron Ash Particles in Coal Combustion Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 808-831 43 Harper, Jerome P. 1981 Residential Wood Heating Efficiency and Emissions — An Overview Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, p. 276 44 Hayden, A.C.S.; Braaten, R.W. 1981 Efficient Wood Stove Design and Performance Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 16-43 45 Knight, D. Karen 1981 Wood Heat Emission Proceedings of the Wood Heating Seminars 1980/1981, Wood Heating Alliance, Washington DC, pp. 73-86 46 Linström, Olle 1981 Gasification/Combustion of Wood Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 789-807 47 Morstead, H. 1981 Fireplace Technology in an Energy Conscious World Center for Research & Development in Masonry, Calgary, Alberta, Canada 48 Osborne, Michael C. 1981 The Inter-Government Research and Development Program for Residential Wood Combustion Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 17-33A-51U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List



### CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS # AUTHOR DATE TITLE PUBLICATION INFORMATION 49 Shafizadeh, Fred 1981 Chemistry of Pyrolysis and Combustion of Wood Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 746-771 50 Shelton, Jay W. 1981 Wood Heating System Design Conflicts and Possible Resolutions Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 873-891 51 Stegmeir, Paul B. 1981 Wood Energy — From the Forest to the Furnace Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 12-16 52 Thornton, Mark M.; Malte, Philip C. 1981 Combustion Rate of Model Wood Volatiles Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 851-872 53 Toynbee, Peter A. 1981 Domestic Coal Firing in Smokeless Zones Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 892-911 54 Trivett, Gordon S.; AlTaweel, Adel M.; Bond, W. Terence; MacKay, David M. 1981 Fluidized Bed Combustion on the Domestic Scale Proceedings of the 1981 International Conference on Residential Solid Fuels, Environmental Impacts and Solutions, Portland, OR; Published by Oregon Graduate Center, Beaverton, OR (1982), pp. 912-923 55 Harrington, Geri 1980 Fireplace Stoves, Hearths, & Inserts — A Coal- & Wood-Burner’s Guide & Catalog Harper & Row, Publishers, New York, NY

56 Newcomb, Wilburn, W. 1980 Wood Stove Handbook Theodore Audel & Co., A Division of Howard W. Sams & Co., Inc., Indianapolis, IN 57 Oregon State University Extension Service 1980 Fuelwood Facts — Extension Circular 1023 Oregon State University Extension Service, Corvallis, ORA-52U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List



### CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS # AUTHOR DATE TITLE PUBLICATION INFORMATION 58 U.S. Department of Energy 1980 Heating with Wood U.S. Department of Energy, Washington, DC (DOE/CS-0158) 59 Shelton, Jay. W. 1979 Wood Heat Safety Garden Way Publishing, Charlotte, VT 60 Adkins, Jan 1978 The Art and Ingenuity of the Woodstove Everest House Publishers, New York, NY 61 Soderstrom, Neil 1978 Heating Your Home with Wood Popular Science, Harper & Row; Published by Book Division, Times Mirror Magazines, Inc., New York, NY 62 Twitchell, Mary 1978 Wood Energy — A Practical Guide to Heating with Wood Garden Way Publishing, Charlotte, VT

63 Vivian, John 1978 The New, Improved Wood Heat (Reprint) Rodale Press, Emmaus, PA (Rev. ed. Of: Wood Heat (1976)) 64 Harrington, Geri 1977 The Wood Burning Stove Book Macmillan Publishing Co., Inc., New York, NY 65 Ross, Bob; Ross, Carol 1976 Modern and Classic Woodburning Stoves and the Grass Roots Energy Revival Overlook Press, Woodstock, NY

66 Shelton, Jay W. 1976 The Woodburner’s Encyclopedia — Wood as Energy Vermont Crossroads Press, Waitsfield, VT

67 Vivian, John 1976 Wood Heat Rodale Press, Emmaus, PA 68 Gay, Larry 1974 The Oregon Woodcutting and Heating Book Garden Way Publishing, Charlotte, VT (Rev. ed. of: Heating With Wood) 69 Gay, Larry 1974 The Complete Book of Heating with Wood Garden Way Publishing, Charlotte, VT 70 Havens, David 1973 The Woodburners Handbook — Rekindling an Old Romance Harpswell Press, Brunswick, ME

71 Young, Harold E. 1971 Preliminary Estimates of Bark Percentages and Chemical Elements in Complete Trees of Eight Species in Maine Forestry Products Journal, Vol. 21, No. 5, pp. 56-59

72 Mingle, J.G.; Boubel, R.W. 1968 Proximate Fuel Analysis of Some Western Wood and Bark Wood Science, Vol. 1, No. 1, pp. 29-36

73 Anonymous Undated Wood Heating Handbook Prepared for the Great Lakes Regional Biomass Energy Program, Council of Great Lakes Governors, Madison, WIA-53U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List



### CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS # AUTHOR DATE TITLE PUBLICATION INFORMATION 74 Trefil, James S. Undated Wood Stoves Glow Warmly Again in Millions of Homes No Publication Information Listed, pp. 55-62A-54A-iii Appendix B Summary of Expert Interviews Table of Contents
Page List of Experts Interviewed

..................................................B-1 Interview Briefing Package (contains interview questions)

...........................B-2 Individual Interview Summaries John Crouch

.......................................................B-13 Rick Curkeet

......................................................B-23 Bob Ferguson

.....................................................B-34 Skip Hayden

......................................................B-45 Daniel Henry

......................................................B-57 Dennis Jaasma

.....................................................B-69 Robert McCrillis

...................................................B-77 Ben Myren

........................................................B-88 Michael Van Buren

................................................B-103 unsolicited comments

...............................................B-113 List of Tables No. Title Page 1 Emission Factor Reduction Potential, in Mass/Unit Mass Dry Wood Burned,

.......B-7 for Various Alternatives to Conventional Stoves and Cordwood 2 Effective Pollutant Reduction Potential, in Mass/Thermal Unit Heat Delivered,

.....B-8 of Various Alternatives to Conventional Stoves and Cordwood 3 Emission Factor Reduction Potential, in Mass/Unit Mass Dry Wood Burned,

.......B-9 for Various Alternatives to Conventional Fireplaces and Cordwood 4 Emission Factor Reduction Potential, in Mass/Thermal Unit Heat Delivered,

......B-10 of Various Alternatives to Conventional Fireplaces and Cordwood 5 Comparison of ISO 13336 (Draft) with EPA Methods 28, 5G, and 5H

...........B-11 6 Method 28 - Burn Rate Weighted Probabilities for Calculating Weighted Average

. .B-12 Emission Rate Based on 43 Homes in Waterbury, VT, Glens Falls, NY, and Portland, ORA-1 List of Experts Interviewed Mr. John Crouch Director of Local Government Relations Hearth Products Association 7840 Madison Avenue, Suite 185 Fair Oaks, CA 95628 interviewed January 20, 1998 Mr. Rick Curkeet, P.E. Manager Intertek Testing Services 8431 Murphy Drive Middleton, WI 53562 interviewed January 14, 1998 Mr. Bob Ferguson President Ferguson, Andors and Company P.O. Box 678 South Royalto, VT 05068 interviewed January 16, 1998 Dr. Skip Hayden Director Combustion and Carbonization Research Laboratory 555 Booth Street Ottawa Ontario K1A0G CANADA interviewed February 26, 1998 Mr. Daniel Henry Vice President Aladdin Steel Products, Inc. 401 N. Wynne Street Colville, WA 99114 interviewed January 16, 1998 Dr. Dennis Jaasma Associate Professor Department of Mechanical Engineering Virginia Polytechnic Institute and State University Blacksburg, VA 24061 interviewed February 20, 1998 Mr. Robert C. McCrillis, P.E. Mechanical Engineer Mail Drop 61 U.S. Environmental Protection Agency National Risk Management Research Laboratory Air Pollution Prevention and Control Division 86 T.W. Alexander Drive Research Triangle Park, NC 27711 interviewed January 14, 1998 Mr. Ben Myren President Myren Consulting 512 Williams Lake Road Colville, WA 99114 interviewed February 5, 1998 Mr. Michael Van Buren Technical Director Hearth Products Association 1601 North Kent Street, Suite 1001 Arlington, VA 22209 interviewed January 14, 1998A-2 Interview Briefing Package - RWC Technology Review Environmental Protection Agency Order no. 7C-R285-NASX prepared by OMNI Environmental Services, Inc. 5465 SW Western Avenue Beaverton Oregon 97005 phone (503) 643-3788 fax (503) 643-3799 email:jhouck@omni-test.com ptiegs@omni-test.com

1. State-of-the-art of wood stove combustion and emission control technologies. 1.1 Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable? 1.2 Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable? 1.3 Can catalytic technology for use in wood stoves be fundamentally improved? 1.4 Is the use of manufactured fuel (densified and wax logs) a credible emission reduction strategy? See Tables 1 & 2 . 1.5 For non-catalytic stoves the heat retention adjustment with refractory material of various densities can reduce particulate emissions. How big an effect can this have? 1.6 Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic wood stoves and more than half for catalytic wood stoves. Are there improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions? 1.7 Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg? 1.8 Are the emissions and efficiencies for masonry heaters, based on in-home tests, shown in Tables 1 and 2 reasonable?A-3

1.9 The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). — Comments? 1.10Default efficiency values are used for wood stoves. This coupled with the fact that emission factors or rates (not g/MJ) are used to rank wood stoves does not provide an incentive for manufacturers to increase the efficiency of their stoves. — Comments? Should an efficiency test method as described (FR v. 55, n 161, p. 33925, Aug. 20,1990) be required to be used and the results listed? 1.11 Have certified stove design and performance improved since the first certified stoves? If so, how?

2. State-of-the-art of fireplace emission control technology. 2.1 Are the emission factors and efficiencies for the in-home use of fireplaces and inserts shown in Tables 3 and 4 reasonable? 2.2 There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. — What designs and technologies are available? What retrofit options are there? 2.3 The use of wax fire logs reduces emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even less emissions? 2.4 What are the distinctions between a masonry fireplace and a masonry heater? 2.5 As with wood stoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates. 3. State-of-the-art of wood-fired central heating furnace emission control technology. 3.1 According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified? 4. State-of-the-art of pellet-fired wood stove technology.A-4

4.1 Are the emissions and efficiencies for the in-home use of pellet stoves shown in Tables 1 and 2 reasonable? 4.2 The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification? 4.3 Have pellet stove design and performance improved since the first models were introduced? If so, how? 1. Ramifications of ISO. 5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO method 13336 with EPA methods 28, 5G and 5H.) Do you feel that the EPA methods should be replaced with or be made comparable to an international standard? 2. Correspondence between in-home and laboratory emission test results. 6.1 How accurately do certification tests predict in-home performance? 6.2 How would you design research testing in the laboratory to simulate in-home use? 3. EPA Method 28 strengths and weaknesses. 7.1 Method 28 is in part an “art”. Fuel loading density, fuel moisture, fuel characteristics (old vs new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have? 7.2 Burn rate weighting is based on very limited data and the cities from where the data were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole? 7.3 The equation for the calculation of the air-to-fuel ratio as in Method 28A is in error. The error produces a small but significant difference in the calculatedA-5 air-to-fuel ratio. Should the method be corrected or should it be left as a “predictor” of the air-to-fuel ratio? 7.4 The assumed mole fraction of hydrocarbons (Y HC) is defined as a constant in the air-to-fuel ratio calculations in Method 28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbon vapors (more appropriately, organic compound vapors) be measured as part of the method? 4. EPA Methods 5G and 5H correlations. 8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two methods be reevaluated? 5. Performance deterioration of EPA-certified wood stoves in the field. 9.1 It is the opinion of many in the wood stove industry that catalysts last only five years and that a stove designed for a catalyst operated without a functioning catalyst can produce as much emissions as a conventional stove. — Comments? 9.2 Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR and Crested Butte, CO showed that emissions from some catalytic stoves became appreciably worse even after two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been made in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program? 6. Stress test pros and cons. 10.1 A short-term laboratory woodstove durability testing protocol was developed topredict the long-term durability of stoves under conditions characteristic of inhome use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at very high temperatures over a one to two week period to predict long-term durability under in-home use. Is this a reasonable approach? 10.2Should a stress test be made part of the certification process? 7. Feasibility of developing separate emission factors for dry and wet wood and for softwood and hardwood species classes.A-6

11.1 Optimum wood moisture for low particulate emissions seems to be in the 18% to 20% range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species? 11.2 Wood from different tree species clearly burns differently. The chemical make-up and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If this is true different parts of the country may have different emissions factors for residential wood combustion. Are you aware of any data that document different emission factors for wood from different tree species? 8. Routine maintenance. 12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than non-catalytic stoves? Would this be relevant for pellet stoves with electronic and moving parts? 12.2Should the home owner be provided with a maintenance manual or a training course at the time of purchase? Should a maintenance program be part of the purchase price particularly for catalytic stoves? 12.3 What would the key elements of routine maintenance be?A-7 

### Table 1 Emission Factor Reduction Potential, in Mass/Unit Mass Dry Wood Burned, for Various Alternatives to Conventional Stoves and Cordwood Appliance Particulate Emission Factor

lb/ton g/kg reduction % Conventional 37 18.5

- Non-Catalytic 12 6 68 Catalytic 13 6.2 65 Pellet 4 2 89 Masonry Heater 6 3 84 Conventional with densified fuel 25 14 24

### Table 2 Effective Pollutant Reduction Potential, in Mass/Thermal Unit Heat Delivered, of Various Alternatives to Conventional Stoves and Cordwood Appliance Efficiency % Heat

Content (BTU/lb) Mass particulate emission/delivered heat

lb/MBTU g/MJ reduction % Conventional 54 8,800 3.89 1.68

- Non-Catalytic 68 8,800 1.14 0.49 71 Catalytic 72 8,800 1.02 0.44 74 Pellet 78 8,500 0.31 0.13 92 Masonry Heater 58 8,800 0.59 0.25 85 Conventional with densified fuel 57 8,800 2.79 1.20 27B-8a Wax logs on a mass particles per time basis show a 70% reduction which may be relevant due to the aesthetic use of fireplaces.

A-9 

### Table 3 Emission Factor Reduction Potential, in Mass/Unit Mass Dry Wood Burned, for Various Alternatives to Conventional Fireplaces and Cordwood Appliance Particulate Emission Factor

lb/ton g/kg reduction % Fireplace 25 12.5

- Fireplace with wax logs 21 10.5 16(70%)a 

### Non-Catalytic Insert 12 6 65 Catalytic Insert 13 6.5 89 Pellet Insert 4 2 84

### Table 4 Emission Factor Reduction Potential, in Mass/Thermal Unit Heat Delivered, of Various Alternatives to Conventional Fireplaces and Cordwood Appliance Efficiency

% Heat

Content (BTU/lb) Mass particulate emission/delivered heat

lb/MBTU g/MJ reduction % Fireplace 7 8,800 19.86 8.55

- Fireplace with wax logs 8 15,000 8.75 3.76 56 Non-Catalytic Insert 68 8,800 1.14 0.49 94 Catalytic Insert 72 8,500 1.02 0..44 95 Pellet Insert 78 8,500 0..31 0..13 98B-10a 

### N/A= Not Applicable 

### Table 5 Comparison of ISO 13336 (Draft) with EPA Methods 28, 5G, and 5H
Test Method Emission

Sampling Technique Fuel Spacing Fuel Species Efficiency Reporting Units
ISO 13336 dilution tunnel 0.75 inches many including coal calorimeter

room gram/kilogram
EPA 28 N/Aa 

### 1.5 inches Douglas fir N/A grams/hour weighted average EPA 5G dilution tunnel N/A N/A N/A N/A EPA 5H direct flue N/A N/A N/A N/AB-11a HDD = Heating degree days 

### Table 6

Method 28 - Burn Rate Weighted Probabilities for Calculating Weighted Average Emission Rate Based on 43 Homes in Waterbury, VT, Glens Falls, NY, and Portland, OR.

Waterbury, VT HDDa

### = 7953 Glens Falls, NY HDD = 7547 Portland, OR HDD = 4691

DOE/EIA - 0321 (93) Wood cords burned from December 1992 through November 1993 by HDD
HDD Millions of Cords >7000 7.0 5500-7000 5.6 4000-5499 6.7 <4000 8.0 27.4 totalB-12A-13



### John Crouch - Director of Local Government Relations, Hearth Products Association

1. State-of-the-art of wood stove combustion and emission control technologies. 1.1 Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable? Response: In terms of conventional stoves, the emissions reductions are very different, and

the conventional stove numbers and the emission reduction numbers are very different, depending on whether the household studied was an Eastern household or a Western household. I think the conventional stove emissions are higher in the West, because of lower degree days and the tendency of consumers in the West to acquire large firebox stoves and burn them on Western softwood. Now the emissionreductionmay be greater in the West, ironically, because of course we are tuning our stoves for douglas fir, which is still a softwood even though it is one of the denser softwoods.

1.2 Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable? Response: Probably, although we have to be careful here in that so much of the work in the

AP-42 database still relates to our industry’s earliest shots at certified stoves. And although certified stoves haven’t changed a lot in the last four years, some of the stoves which figured prominently in the in-situ work for those databases are much older than that, and are now history.

1.3 Can catalytic technology for use in wood stoves be fundamentally improved? Response: I think the answer is probably yes, and then the question is, does it need to be?

Are catalytics going to be used in the market place? Which, is a polite way to say, does anybody care? The market share for catalytic appliances has decreased markedly in recent years.

1.4 Is the use of manufactured fuel (densified and wax logs) a credible emission reduction strategy? See Tables 1 & 2 . Response: I think it is, but I haven’t been able to convince regulators that it is. There is tonsA-14 and tons of densified fuel sold in some cities. People in this industry or regulators who are not familiar with it probably think that densified Pres-to-Log® type fuel costs too much. Manufactured fuel is a credible emission reduction strategy. It’s credible technically, but as a salable strategy, I don’t know.

1.5 For non-catalytic stoves the heat retention adjustment with refractory material of various densities can reduce particulate emissions. How big an effect can this have? Response: No comment.

1.6 Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic wood stoves and more than half for catalytic wood stoves. Are there improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions? Response: No comment.

1.7 Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg? Response: Yes and no; they shouldn’t be classified as a woodstove, but they should be subject

to some type of certification. There needs to be a “Certified Masonry Heater” option for these appliances.

1.8 Are the emissions and efficiencies for masonry heaters, based on in-home tests, shown in Tables 1 and 2 reasonable? No comment.

1.9 The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). — Comments? Response: I agree with that in theory, but I have been in front of a lot of city councils and

county supervisors, and anything that would take away from the g/hr concept tends to make people suspicious. So it maybe too late to change the way we do this.A-15

1.10Default efficiency values are used for wood stoves. This coupled with the fact that emission factors or rates (not g/MJ) are used to rank wood stoves does not provide an incentive for manufacturers to increase the efficiency of their stoves. — Comments? Should an efficiency test method as described (FR v. 55, n 161, p. 33925, Aug. 20,1990) be required to be used and the results listed? Response: Yes, the industry has had enough time now to get used to this idea, and if there

were a period of two or three years where manufacturers could test their stove and be ready before their results were listed, it is appropriate.

1.11 Have certified stove design and performance improved since the first certified stoves? If so, how? Response: Absolutely. Certainly the difference between phase I and phase II was for some

stoves very significant. There were some stoves that were certified in phase I and the manufacturers gave up when it came time to certify to phase II, because the changes where so dramatic. They just packed it in. There were important changes in phase II that, probably, make the stoves more consistent performers in the field, and that’s what everyone is interested in. Could stoves be changed even more? Yes, I think that was the sum total of that Friday’s discussion, and I hope that would be the consensus here. They could be changed more, if we had an emissions test that wasmore accuratein terms of mimicking the real world. Until and unless the emissions test is reconceptualized, certified stoves will remain stuck where they are. This is probably appropriate, given the extremely low volume of sales.

2. State-of-the-art of fireplace emission control technology. 2.1 Are the emission factors and efficiencies for the in-home use of fireplaces and inserts shown in Tables 3 and 4 reasonable? Response: Well they are consistent with what I’ve seen in other published OMNI reports.

2.2 There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. — What designs and technologies are available? What retrofit options are there? Response: No comment.A-16

2.3 The use of wax fire logs reduces emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even less emissions? Response: No comment.

2.4 What are the distinctions between a masonry fireplace and a masonry heater? Response: I believe that heat exchange channels, however you define channels, are

fundamental to that distinction.

2.5 As with wood stoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates. Response: I strongly disagree. Fireplaces are not heat producing. Generally, fireplaces are an

aesthetic device from which consumers do not expect heat, just the feeling and the perception of warmth, but they don’t really expect real heat out of a fireplace. This concept is appropriate in wood heaters, pellet stoves, or masonry heaters, but by definition it is not appropriate in aesthetic fireplaces.

3. State-of-the-art of wood-fired central heating furnace emission control technology. 3.1 According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified? Response: The EPA New Source Performance Standards killed the indoor furnace industry

and created this little loop-hole which the outdoor furnace industry is beginning to exploit and kind of underscores the need for a more comprehensive wood burning regulation which sets out over a several year period to codify all forms of wood burning technology.

4. State-of-the-art of pellet-fired wood stove technology. 4.1 Are the emissions and efficiencies for the in-home use of pellet stoves shown in Tables 1 and 2 reasonable? Response: These are all that we’ve got, but we must remember that the ‘n’ value, the numberA-17 of data points used here, isverysmall and highly dependent on a handful of households and the stove and the size of the house and whether consumers had made the right choice or not. To my knowledge, most of the pellet stove models that were used in those studies are no longer available for sale. Here is one area where there needs to be some revisiting.

4.2 The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification? Response: I wouldn’t use the term “close the loop-hole”. I would say, “is the proper place to

cut off the definition of a wood heater?” We all know the whole discussion during the Reg-Neg ignored this emerging category of pellet stoves. So this gets back into my other broader comment, which is, instead of going back in and changing the NSPS in apiecemealfashion, there needs to be a true revision of the whole thing that deals with the category of pellets and masonry heaters and outdoor furnaces. To go back and mess with it piecemeal, just will create more potential loop-holes and mistakes.

4.3 Have pellet stove design and performance improved since the first models were introduced? If so, how? Response: Sure, more fully automated operations and much better handling of ash.

5. Ramifications of ISO. 5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO method 13336 with EPA methods 28, 5G and 5H.) Do you feel that the EPA methods should be replaced with or be made comparable to an international standard? Response: I don’t think we know enough. We really need to see the ISO methodology run

on some current EPA certified stoves and see what we get. We just don’t know enough yet really to advocate that. But I do feel strongly that if the EPA were to reopen the wood heater process and review that and then choosenotto adopt the ISO, that would be the end of the ISO method. So we need to do that before the EPA, if they ever do, reopen the NSPS. So it needs to be done earlier, rather thanA-18 later.

6. Correspondence between in-home and laboratory emission test results. 6.1 How accurately do certification tests predict in-home performance? Response: I believe certification tests are fairly accurate for that handful of families who burn

douglas fir 2 by 4's with an inch and a half of air space around each piece of fuel. For the rest of the country, I suspect it can be improved on.

6.2 How would you design research testing in the laboratory to simulate in-home use? Response: We have got to use different piece sizes and different surface to volume ratios and

we have got to reduce the amount of air space between the pieces. And we probably should test the stoves with wider moisture types; the stoves have to be certified not just with a focus on burn rates but with a focus on different moisture levels. Because of course, everyone’s woodpile has a little different moisture level in it. And that varies more than density. As a trade-off to all these changes, I think we could simplify the tests as well, just analyze for gas ratios, for instance,or just run a high and low run. The tests as they are currently constituted are far too expensive to run.

7. EPA Method 28 strengths and weaknesses. 7.1 Method 28 is in part an “art”. Fuel loading density, fuel moisture, fuel characteristics (old vs new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have? Response: See HPA’s input (Appendix C, page C-9).

7.2 Burn rate weighting is based on very limited data and the cities from where the data were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole? Response: See HPA’s input (Appendix C, page C-9). 7.3 The equation for the calculation of the air-to-fuel ratio as in Method 28A is in error.A-19

The error produces a small but significant difference in the calculated air-to-fuel ratio. Should the method be corrected or should it be left as a “predictor” of the air-to-fuel ratio? Response: See HPA’s input (Appendix C, page C-9).

7.4 The assumed mole fraction of hydrocarbons (Y HC) is defined as a constant in the air-tofuel ratio calculations in Method 28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbon vapors (more appropriately, organic compound vapors) be measured as part of the method? Response: See HPA’s input (Appendix C, page C-10).

8. EPA Methods 5G and 5H correlations. 8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two methods be reevaluated? Response: The overall suggestion of question 8 reflects the possibility of trying to ‘tweak’ the

existing NSPS, dealing with the correlation, and flow rates. I would advocate that what the EPA needs to do is fundamentally start over, which means allow itself several years. Start with test methodology and then move into wood heaters and then masonry heaters and pellet stoves and, if necessary, have different test methodologies for different appliances and not try to fix the weaknesses of the current methodology. Obviously, after such a revision was completed, the industry would need a reasonable period to phase in new models, and all existing models would need to be grandfathered to the end of their certificate date. 9. Performance deterioration of EPA-certified wood stoves in the field. 9.1 It is the opinion of many in the wood stove industry that catalysts last only five years and that a stove designed for a catalyst operated without a functioning catalyst can produce as much emissions as a conventional stove. — Comments? Response: Well I think that it’s clear that people are not replacing their catalyst as soon as

they should, from what I’ve been told by the company who sells replacement catalysts--so that’s a concern. The work that the late Skip Burnett did on durability also underscored the weakness of some stove designs in terms of their bypass designs. I’ve not seen data that would confirm that a stove designed for a catalyst can produce as much emissions as a conventional stove. My suspicion isA-20 that the opposite is true, that even a poorly functioning catalyst is still an improvement over a conventional stove.

9.2 Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR and Crested Butte, CO showed that emissions from some catalytic stoves became appreciably worse even after two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been made in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program? Response: It would be more important to have a certified installer who was certified to install

that stove, adjust the draft, because the stove is naked or unprotected against overdraft. That’s as true for non-catalysts as it is for catalysts, but it is much more destructive. What Glens Falls taught us was that it’s almost instantly destructive of catalytic stoves as compared to non-catalytic.

10. Stress test pros and cons. 10.1 A short-term laboratory woodstove durability testing protocol was developed to predict the long-term durability of stoves under conditions characteristic of in-home use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at veryhigh temperatures over a one to two week period to predict long-term durability under inhome use. Is this a reasonable approach?
Response: I have fundamental questions whether that was the best approach. A better

approach, it seems to me, is to redo the entire NSPS and require woodstoves, if they are going to be tested for a particular draft, to allow themselves to be run only at that draft or within a draft range. Yes, if they are going to be sold without any overdraft protection, then they would need a stress test to prove that they could do that. But the stress test should be removed if they are allowed, encouraged, or required to have overdraft protection. And I think with catalytic stoves that isfundamental, but it’s probably also useful in terms of all the others, all the noncatalysts.

10.2Should a stress test be made part of the certification process?A-21

Response: It’s asking the wrong question. “Should overdraft protection be made part of the

stove design?” is the better question. And the answer is yes.

11. Feasibility of developing separate emission factors for dry and wet wood and for softwood and hardwood species classes. 11.1 Optimum wood moisture for low particulate emissions seems to be in the 18% to 20% range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species? Response: I think this is a critical area and one that is not adequately addressed at all in the

certification test. And as I have said earlier in the woodstove portion, I just think we made a big mistake by field testing the stoves in cold parts of the country where people used hardwood and having them certified in a part of the country where people were using softwood--all of this to apply to air sheds that were in the softwood territory. We either just have to have different tests or the test has to be broadened to have us burn both types of wood, with very different types of moisture categories. Once again, this could only be addressed in the context of redoing the whole NSPS. You couldn’t just kind of do some touch up, by changing the fuel species. You need to rethink this from the start. Before you do that, you have to ask if the effort involved will really have any impact on the environment. With so few woodstoves being sold, would a complete rethinking of the NSPS really be warranted?

11.2 Wood from different tree species clearly burns differently. The chemical make-up and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If this is true different parts of the country may have different emissions factors for residential wood combustion. Are you aware of any data that document different emission factors for wood from different tree species? Response: I think that 11.2 is more critical then 11.1, that density is most critical. Other than

OMNI’s own fuel study, no I am not aware of any other data. Could emissions be different for different tree species? It could and probably is different.

12. Routine maintenance. 12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than non-catalytic stoves?A-22

Would this be relevant for pellet stoves with electronic and moving parts? Response: Probably yes. If a pellet stove gets so gummed up it’s going to shut down,

maintenance is really important for pellet stoves, it affects emissions because it shuts them off.

12.2Should the home owner be provided with a maintenance manual or a training course at the time of purchase? Should a maintenance program be part of the purchase price particularly for catalytic stoves? Response: Yes it’d be good theoretically. Automobile owners aren’t trained in the emissions

of their car when they purchase it, but it does have a “check engine light”. I suppose that’s a good idea, but not many people are buying catalytic stoves anymore, anyway.

12.3 What would the key elements of routine maintenance be? Response: Depends on the stove.A-23



### Rick Curkeet, P.E. - Manager, Intertek Testing Services

1. State-of-the-art of wood stove combustion and emission control technologies. 1.1 Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable? Response: Yes, they are reasonable. However, the baseline for “conventional stoves” does

not reflect the broad range of emissions rates for this type of stove. It is much greater than the range indicated in the table.

1.2 Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable? Response: The efficiencies for non-catalytic and pellet stoves are reasonable as averages for

the group. There are, of course, specific models which are significantly better and perhaps some that are significantly worse than the table indicates. Catalytic stoves, I would say do somewhat better than the table values on average, but again there is a substantial range between models. I think the conventional stove efficiency estimates are optimistic. Many of the ones we tested in the early days were below 50%.

1.3 Can catalytic technology for use in wood stoves be fundamentally improved? Response: I would say yes, and that also goes for non-catalytic technology. The greatest

gains might come from electronic control of combustion air to adjust for fuel and temperature variations and optimize the combustion conditions.

1.4 Is the use of manufactured fuel (densified and wax logs) a credible emission reduction strategy? See Tables 1 & 2 . Response: My first reaction is they could provide consistency in what goes into the unit to get

better consistency of performance. My second reaction is that, as a large scale emissions reduction strategy, it is not in the big picture. I don’t think we can tell consumers who bought wood stoves because of their ready access to free or low cost cordwood, that they now must purchase manufactured fuel. Burning cordwood is an environmentally friendly use of a readily available renewable energy source and should not be discouraged. Clean burning in well designed appliances is the best answer.A-24

1.5 For non-catalytic stoves the heat retention adjustment with refractory material of various densities can reduce particulate emissions. How big an effect can this have? Response: In my experience this is more a “trick of the trade” in obtaining good EPA

emissions test results than it is a reliable method of ensuring good field performance. In our experience, this method becomes important when you must get a good test result at a low burn rate. Our clients are often very particular about pre-burn conditions for the low burn tests that will assure the maximum allowable heating of the refractory materials. This improves the chances for a quick secondary combustion light-off and low emissions measurements. I doubt that the average consumer routinely reproduces this in the field.

1.6 Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic wood stoves and more than half for catalytic wood stoves. Are there improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions? Response: Yes. We have seen designs that have had a special “start-up” setting that helps get

a fire started quickly. We’ve had trouble with these though because EPA has considered such settings as operating controls and required full load tests with the controls fully open. This can result in such high burn rates that it overpowers catalysts or creates artificially high gram per hour emissions rates. As for wax logs, used as kindling I’m not sure it would have a similar impact on all types of stoves. Some might benefit but others might not.

1.7 Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg? Response: Not if it means they would have to be tested by the current EPA method. The

concern I have here is that masonry heaters are generally designed to burn wood loads at one high rate and store the bulk of the heat produced. The EPA method as currently written would force these units to produce a burn rate of less than 1 kilogram per hour. Thus the method is not compatible with the product and cannot produce a meaningful result.

1.8 Are the emissions and efficiencies for masonry heaters, based on in-home tests, shown in Tables 1 and 2 reasonable? Response: No comment.A-25

1.9 The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). — Comments? Response: I agree 100%. While emissions per heat output ratings may be difficult to fit into

the air quality model used by regulators, this format speaks to the purpose and environmental impact of the appliance. The current system does not reward the manufacturer for improving heating efficiency. But better efficiency means the user will need to burn less fuel and will therefore produce less pollution. It is possible to get lower gram per hour test results by simply extending the burn time for a particular setting. This does not result in a real emissions reduction since, if the user is not getting enough heat, he’ll simply reload the stove more often, burn smaller pieces or make some other adjustment which bears little relation to the scenario used in the EPA test.

1.10Default efficiency values are used for wood stoves. This coupled with the fact that emission factors or rates (not g/MJ) are used to rank wood stoves does not provide an incentive for manufacturers to increase the efficiency of their stoves. — Comments? Should an efficiency test method as described (FR v. 55, n 161, p. 33925, Aug. 20,1990) be required to be used and the results listed?
Response: I agree (see 10.9). As for an efficiency method, we should use one which is

already published and in use – CSA Standard B415. 1.11 Have certified stove design and performance improved since the first certified stoves? If so, how? Response: There have been some marginal improvements and a few significant emissions

reductions. Most improvements have been in making units more user friendly and tolerant of fuel and operating variations. I don’t think there has been any substantial move toward better efficiency. Between design restrictions inherent in the EPA test method and weak consumer demand there has been very little R&D in this field for several years.

2. State-of-the-art of fireplace emission control technology. 2.1 Are the emission factors and efficiencies for the in-home use of fireplaces and inserts shown in Tables 3 and 4 reasonable? Response: I guess I’d have to say they are fairly reasonable. Of course we’re alwaysA-26 concerned about how to determine efficiencies of open fireplaces. It’s highly dependent on outdoor air temperature and how much excess air is used. At some outdoor air temperature the effective fireplace efficiency will typically be zero – the heat produced all goes to heat the outdoor air drawn in to replace combustion air. This temperature is usually estimated at about 20 to 30 degrees F.

2.2 There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. — What designs and technologies are available? What retrofit options are there? Response: There are some available. It is really a question of price. If an emission control

strategy increases the fireplace cost enough, few people will buy fireplaces. I don’t think this is the best answer. Fireplace emissions can be readily reduced by good operating practices by the user and perhaps by some modest and inexpensive design improvements.

2.3 The use of wax fire logs reduces emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even less emissions? Response: No comment.

2.4 What are the distinctions between a masonry fireplace and a masonry heater? Response: A masonry heater is designed to capture and store a substantial portion of the

energy produced in combustion. The heat is then transmitted slowly back to the living space. With a fireplace there is no attempt to store the heat produced and most usually is lost up the chimney.

2.5 As with wood stoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates. Response: I agree to the extent that this approach penalizes manufacturers for design poor

heating units. However, fireplaces are usually considered decorative products intended for occasional use. If the user only burns a few pounds of wood once or twice a week the environmental impact of poor combustion and low efficiency may not be significant.A-27

3. State-of-the-art of wood-fired central heating furnace emission control technology. 3.1 According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified? Response: I don’t know how many new units are being produced but I’m sure it’s a very

small number. Still, one really poor unit can be a significant problem if it’s in your neighborhood. There have never been any standards for testing this type of product for emissions and efficiency. However, we have adapted existing methods and can say that the performance range is very wide. Poor designs may be 30% or less efficient and produce nearly 100 grams/hr emissions rates. Good designs are able to approach certified wood stove performance levels.

4. State-of-the-art of pellet-fired wood stove technology. 4.1 Are the emissions and efficiencies for the in-home use of pellet stoves shown in Tables 1 and 2 reasonable? Response: Yes.

4.2 The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification? Response: Yes. The way to amend the regulation is to simply remove the 35:1 air/fuel ratio

exemption. This has never been required by fireplaces (they meet the 5 kg/hr minimum burn rate exemption criterion anyway). Pellet units are readily able to meet emissions requirements and the exemption only encourages making these units less efficient to avoid the regulation.

4.3 Have pellet stove design and performance improved since the first models were introduced? If so, how?
Response: Yes, but not a whole lot in terms of emissions. There have been manyA-28 improvements in operating reliability, fuel handling, safety and other features. Emissions have not had much attention perhaps because they are low enough to begin with that there does not appear to be a lot to be gained. 5. Ramifications of ISO. 5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO method 13336 with EPA methods 28, 5G and 5H.) Do you feel that the EPA methods should be replaced with or be made comparable to an international standard? Response: I believe it has moved well through the ISO process, but there has been no input or

endorsement from the US that I know of. In the long run it would be good to harmonize test methods globally.

6. Correspondence between in-home and laboratory emission test results. 6.1 How accurately do certification tests predict in-home performance? Response: They are not at all accurate. The lab test results do show the trend that units

which are better in the lab are also better in the home. However, the actual emissions numbers can be very far from what happens in the field. We know, for example, that a unit which may do very well with an 18% moisture Douglas Fir lumber test load, can do very badly with the same fuel configuration at 22% moisture. I doubt that many consumers would pay the attention needed to get a “fussy” stove to do what it does in the lab.

6.2 How would you design research testing in the laboratory to simulate in-home use? Response: Some of the things which need to be looked at are: real cord wood (e.g., broad

range of size, shape density, moisture). Things such as starting a fire, when it is reloaded (coal bed size), changing settings during a burn, all can make significant differences in emissions rates. I think it could be more beneficial to look at a broader range of fuels than it is to focus solely on burn rate setting as the current standard now does. I think we need to rely more on the homeowner’s ability to adjust the unit for local conditions. At this point it’s not considered.

7. EPA Method 28 strengths and weaknesses.A-29

7.1 Method 28 is in part an “art”. Fuel loading density, fuel moisture, fuel characteristics (old vs new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have? Response: Yes, there is no question that all these factors can be adjusted and are adjusted.

The manufacturers are extremely concerned about things like coal bed conditioning and moisture content. Currently we see a lot of designs where very minor changes make the difference between a good light-off on a low burn rate and a smoldering dirty low burn test. These things often make the difference between certification and no certification.

7.2 Burn rate weighting is based on very limited data and the cities from where the data were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole? Response: The first thing I’d recommend is throw out the weighting method and just do a

straight average. These units are used throughout the heating season, not just on average days. They will be run more on high fire in a large room in a big house than they will in a small room. They will be turned up when it gets really cold out and turned down when it warms up. They will be used throughout their available range depending on many factors including weather, building size, and insulation level. The EPA averaging method, by trying to represent all operating conditions, actually represents none (or few).

7.3 The equation for the calculation of the air-to-fuel ratio as in Method 28A is in error. The error produces a small but significant difference in the calculated air-to-fuel ratio. Should the method be corrected or should it be left as a “predictor” of the air-to-fuel ratio? Response: First, this becomes a non-issue if the air/fuel ratio exemption is removed.

Secondly, the math and chemistry are wrong and should be fixed. I have written EPA on this subject (F0) and am awaiting a reply.

7.4 The assumed mole fraction of hydrocarbons (Y HC) is defined as a constant in the air-tofuel ratio calculations in Method 28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbon vapors (more appropriately, organic compound vapors) be measured as part of the method?A-30

Response: This is the same basic issue as in 7.3. It is not correct to set a fixed hydrocarbon

level and then attempt a chemical mass balance. This results in a mathematical paradox of an “over-determined system”. It is not necessary to measure hydrocarbons to resolve this issue. All that is needed is to carry out the mass balance calculation with an assumed hydrocarbon composition to account for the unburned hydrogen and carbon.

8. EPA Methods 5G and 5H correlations. 8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two methods be reevaluated? Response: It should not be reevaluated. 5H is a poor method and should not be applied to

combustion processes which do not operate in steady state.

8.2 It is the general perception that method 5H produces lower numbers than 5G. Method 5G is less costly and more precise than 5H. — Comments? — Should there be just one sampling method? Response: 5H should just be eliminated. The 5G results should be used as measured and not

“adjusted” by an unsupported factor.

8.3 The same points regarding flow rate calculations (air-to-fuel ratio) and hydrocarbons as made for Method 28A are applicable to Method 5H. — Comments? Response: I recommend throwing out 5H, so this question is not relevant.

8.4 The precision of EPA’s Method 5 is estimated as being about 20%. Almost one quarter of the 214 stoves listed as certified by the EPA as of 8/12/97 are within 20% of their respective (catalytic or noncatalytic) emission limits. — Comments? Response: I agree with the error band, but suspect it is even larger as it is applied to wood

stoves in 5H. Maybe plus or minus 50%. I do not think that the error of the method should be added to or subtracted from a test result to determine if something passes. Rather the error should be considered in setting the pass/fail limit so that the desired goal is achieved. It is, of course, difficult to do this and be fair, with a method that has such a large error band.A-31

8.5 Based on practical experience with the 5G and 5H, how can they be improved? Response: I think 5G works quite well as is. We might tweak it here and there, but I see no

major improvements that would make a big difference. It is already a pretty accurate method. 5H is simply not appropriate for wood stove testing in my opinion.

9. Performance deterioration of EPA-certified wood stoves in the field. 9.1 It is the opinion of many in the wood stove industry that catalysts last only five years and that a stove designed for a catalyst operated without a functioning catalyst can produce as much emissions as a conventional stove. — Comments? Response: I think catalysts can and do last longer than 5 years when well treated. However,

they should probably be replaced anyway. The problem is getting owners to do that, which I don’t think can be forced. Yes, catalysts do stop functioning but so do seals on doors and bypasses of non-catalytic stoves. I’ve seen units that operate just as well with an inactive catalyst substrate as they do with a new active catalyst. Clearly an active catalyst makes the unit easier to operate cleanly and less sensitive to fuel and operating conditions. The real issue is maintenance and the real answer is all stoves will operate better and cleaner if properly maintained.

9.2 Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR and Crested Butte, CO showed that emissions from some catalytic stoves became appreciably worse even after two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been made in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program? Response: First, I’d say improvements have definitely been made. I would say that in general

the units still in production (and it’s a pretty small list these days) are probably the best performers. That’s why they’re still here. I think it would be very difficult to set up any mechanism which would require people to perform a particular type of maintenance on their stove. It would be like trying to make a law that said you have to change your car’s oil every 3000 miles. It would be more effective to try to educate people about the need for routine maintenance and perhaps emphasize the efficiency benefits. I can’t see requiring people to pass a test or buy a license to own a wood stove.

10. Stress test pros and cons.A-32

10.1 A short-term laboratory woodstove durability testing protocol was developed to predict the long-term durability of stoves under conditions characteristic of in-home use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at veryhigh temperatures over a one to two week period to predict long-term durability under inhome use. Is this a reasonable approach? Response: I don’t believe this kind of stress test is needed. Manufacturers might want to use

it just as a means of making sure they won’t get a lot of complaints. However, as part of a certification process it poses a lot of questions. I would compare the proposed stress test concept to trying to determine the life expectancy of an automobile design by taking it to a test track and driving it at 150 miles per hour until something breaks. If the car lasts for only 10,000 miles under these conditions would you expect that that’s how long it would last under normal driving conditions? There are a lot of things that can go wrong with a wood stove (other than overheating) which will affect its performance. Catalysts can be plugged, poisoned or coated with creosote. Gaskets can become worn or permanently compressed and leak. Welds can break and open even with normal temperatures. Durability testing is a complicated issue and should not be imposed without some real certainty that what is being done is really meaningful. It is very easy to create problems that don’t come up in real life and miss the ones that do.

10.2Should a stress test be made part of the certification process?
Response: No, a stress test should not be part of the certification process.

11. Feasibility of developing separate emission factors for dry and wet wood and for softwood and hardwood species classes. 11.1 Optimum wood moisture for low particulate emissions seems to be in the 18% to 20% range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species? 11.2 Wood from different tree species clearly burns differently. The chemical make-up and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If this is true different parts of the country may have different emissions factors for residentialA-33

wood combustion. Are you aware of any data that document different emission factors for wood from different tree species? Response 11.1-11.2: I would not recommend separate factors. It would be better to include the broad

range of fuel characteristics in the test process and make sure the average emissions came out in the acceptable range. I think it would be more valuable to test with high density dry wood, low density wet wood, etc. and run four tests that way and average the results than it is to run four different burn rates with one fuel. 12. Routine maintenance. 12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than non-catalytic stoves? Would this be relevant for pellet stoves with electronic and moving parts? Response: Yes, it would apply to all three types of stoves to some degree. I think we assume

that catalytic stoves need more maintenance than non-catalytic. I don’t think that is necessarily true. I think we can see a lot of emissions and deterioration due to plugging up air inlets with ash, or maybe due to the deterioration of gasketing. As for pellet stoves, they seem to require a basic level of maintenance to keep them running which is probably sufficient.

12.2Should the home owner be provided with a maintenance manual or a training course at the time of purchase? Should a maintenance program be part of the purchase price particularly for catalytic stoves? Response: They should be offered. Training would be a very good idea, particularly if the

dealer could provide it when the product is purchased. I’m not sure how you would make this happen – who would pay for it, etc. – but it would be nice.

12.3 What would the key elements of routine maintenance be? Response: Keep it clean, replace worn or broken parts, make sure functioning parts function.A-34



### Bob Ferguson - President, Ferguson, Andors & Company

1. State-of-the-art wood stove combustion and emission control technologies. 1.1 Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable? Response: I don’t think the numbers looked too unreasonable and are fairly consistent with

the reductions we have always talked about in general. The reductions do appear to consider a partially degraded catalyst or leaking bypass for the catalytic stove and no degradation for the non-catalytic.

1.2 Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable? Response: This table shows the non-catalytic efficiency as being higher than the EPA default

number, which I always felt was too low. I think that it is hard to get a woodstove efficiency much above the low 70% range and still have it work well in the field.

1.3 Can catalytic technology for use in wood stoves be fundamentally improved? Response: I have always felt that the substrate and catalyst suppliers could improve the

technology. If the safe operating temperature range could be increased by a few hundred degrees, catalyst degradation would be dramatically reduced in the field. This would also allow designers to push the catalyst further in the application in the stove which is probably the only way you can ever get to a “zero emissions” stove. Manufacturers would be better off with a catalyst that cost 50% more, if performance and durability could be improved.

1.4 Is the use of manufactured fuel (densified and wax logs) a credible emission reduction strategy? See Tables 1 & 2 . Response: We have had limited experience with wood-wax logs, but have not seen them as

offering a big emission reduction potential. It depends on how the emissions are reported (g/hr, g/kg or g/MJ) and what the firing procedure is. We also have noticed an odor, which could be a nuisance if wood-wax logs were being burned regularly in many homes. I don’t know if this is the case with all wood-wax logs.A-35

1.5 For non-catalytic stoves the heat retention adjustment with refractory material of various densities can reduce particulate emissions. How big an effect can this have? Response: This has a big effect. How big? Like many important design parameters, the

difference between passing and failing--it could be a factor of two or more. None of these stoves would work at low burn rates without the right combination of insulation and/or refractory materials.

1.6 Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic wood stoves and more than half for catalytic wood stoves. Are there improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions? Response: From my perspective it’s a mass problem. You’ve got to get the stove hot and it

takes a certain amount of heat input to warm up a 400 pound stove. I don’t think you can get a big improvement by just looking at the initial kindling phase. I think that improvement can be made during refueling by the techniques employed.

1.7 Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg? Response: The 800 kg limit was arbitrary based on scale capacity and accuracy. It is my

understanding that emissions from masonry heaters are quite low if operated in the manner intended by the designers. How many heaters are being installed nationwide? It doesn't seem worth the effort to develop methods and standards to regulate a small number of generally clean-burning heaters.

1.8 Are the emissions and efficiencies for masonry heaters, based on in-home tests, shown in Tables 1 and 2 reasonable? Response: I have no direct knowledge.

1.9 The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). Comments? Response: From a logical perspective, it is a better measurement for heating equipment but I

don't think the issue of ranking between different types of wood burning appliancesA-36 is a particularly relevant issue. Within a single product category, such as woodstoves, I don't know how significant the changes in ranking will be in going from g/hr to g/MJ. I do know that adding an efficiency test method will add even more uncertainty to the results. Adding efficiency (delivered heat) to comparisons between product categories, woodstoves vs. fireplaces for example, could dramatically impact emission rankings regardless of whether it was compared to emission rate or factor.

1.10Default efficiency values are used for wood stoves. This coupled with the fact that emission factors or rates (not g/MJ) are used to rank wood stoves does not provide an incentive for manufacturers to increase the efficiency of their stoves. Comments? Should an efficiency test method as described (FR v. 55, n 161, p. 33925, Aug. 20,1990) be required to be used and the results listed? Response: There is no commonly used or well proven efficiency method. There doesn’t seem

to be any market-driven incentive. Emissions and efficiencies don’t sell woodstoves. Aesthetics, features and costs are the motivators. Until there is market pressure, you won’t see efficiency measured or reported. From a regulatory perspective, there is no justification to require efficiency testing and I don’t think it should be done. The increased costs offer no payback to the manufacturer, who already feels over regulated. The woodstove industry at present sales levels does not warrant any additional regulatory costs.

1.11 Have certified stove design and performance improved since the first certified stoves? If so, how? Response: I think it has improved. Non-catalytic emission technology has improved (at least

in terms of emission performance) more than the catalytic technology. I think the warranty costs have caused all surviving manufacturers to produce more durable products, rather than concerns over long term emission performance. The market forces are at work on this issue.

2. State-of-the-art of fireplace emission control technology. 2.1 Are the emission factors and efficiencies for the in-home use of fireplaces and inserts shown in Tables 3 and 4 reasonable? Response: I don’t have any first hand knowledge, only what I have read.A-37

2.2 There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. — What designs and technologies are available? What retrofit options are there? Response: Although there have been some attempts at developing products that retrofit into

fireplaces while maintaining true fireplace features, I’m not sure that there is anything that is commercially viable (or even available) at the moment, other than fireplace inserts. There is some question as to whether fireplace inserts have made things better or worse, as they tend to change the use of the fireplace from occasional to more frequent or continuous use. This has both emission and safety implications. Any new technology for use in a fireplace has to have a low retail price point or it will not sell. Most fireplaces are used only occasionally and people will not be able to justify the cost of adding expensive technology for such limited use. 2.3 The use of wax fire logs reduces emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even less emissions? Response: I have to bet that it could be. Also, I think that the way the log is burned could

have an impact on emissions. Right now, you just throw them on a conventional log grate. Some other type of holder could help.

2.4 What are the distinctions between a masonry fireplace and a masonry heater? Response: Obviously, there are not that many open doors, screens or loose fitting glass doors

on masonry heaters. They have a much more controlled air flow path and, obviously, intentional heat storage, compared to the straight-up flow path of a traditional masonry fireplace.

2.5 As with wood stoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates. Response: Most fireplaces are not used as heaters, so there is no need to rank them on a heat

delivered basis. They are primarily used for aesthetic purposes and are used, at best, only occasionally. They can be used as an emergency heat source, but this is very rare. Fireplaces as heating sources started to phase out soon after Ben Franklin invented the first stove.

3. State-of-the-art of wood-fired central heating furnace emission control technology.A-38

3.1 According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified? Response: I don’t feel there are enough units being sold to merit any activity what-so-ever.

There are only a handful of manufacturers. I don’t think there has been anything published--so if testing has been conducted, it is probably a good assumption that the numbers aren’t that good. They shouldn’t be certified, as you would have to develop test methods and standards. The country would be better off using the money to pay manufacturers to phase out of production, sort of like the agricultural method of paying farmers not to grow certain crops.

4. State-of-the-art of pellet-fired wood stove technology. 4.1 Are the emissions and efficiencies for the in-home use of pellet stoves shown in Tables 1 and 2 reasonable? Response: Exempt units are likely to be less efficient and represent the majority of existing

pellet stoves.

4.2 The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification? Response: The 35:1 cutoff was intended for fireplaces. However, pellet stoves are the only

product that even take advantage of the air-fuel exemptions. Fireplaces generally use the burn rate exemption. Pellet stoves probably don’t need to be regulated at all. They are all quite clean burning. Let the marketplace decide if exempt stoves are acceptable. If pellet stove users demand products that use fewer pellets (more efficient), the manufacturers will respond.

4.3 Have pellet stove design and performance improved since the first models were introduced? If so, how? Response: They have definitely improved. The driving force has been the cost of warranty.

There are some pellet stoves that are considered to be very reliable. In fact, I’dA-39 say that all the pellet stove manufacturers that are still alive out there produce a reliable product, or they would have been driven from the market.

5. Ramifications of ISO. 5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO method 13336 with EPA methods 28, 5G and 5H.) Do you feel that the EPA methods should be replaced with or be made comparable to an international standard? Response: It is a good idea, but the question is how to get people to solve their specific

differences?

6. Correspondence between in-home and laboratory emission test results. 6.1 How accurately do certification tests predict in-home performance? Response: Not very accurately on average. There are a lot of stoves out there that have been

designed to perform well during certification testing, without consideration for actual in-home performance. I think the performance in the home can vary widely, from good to bad for any given stove.

6.2 How would you design research testing in the laboratory to simulate in-home use? Response: You would have to look at fuel variables (e.g., species, moisture, piece size, air

spacing, logs versus cribs), fuel cycle variations (e.g., charcoal bed size and preparation, reload time, startup time, end-of-test). And then other factors, such as installation variables which could affect things like draft. It is a big job!!!

7. EPA Method 28 strengths and weaknesses. 7.1 Method 28 is in part an “art”. Fuel loading density, fuel moisture, fuel characteristics (old vs new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have? Response: I think that they all have an effect and that the effect of each can be large. WithinA-40 the necessary allowable ranges for these parameters, people have turned their manipulation into an art. The influence can be the difference between passing and failing.

7.2 Burn rate weighting is based on very limited data and the cities from where the data were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole? Response: Things have changed since the data were accumulated. Most people were using

woodstoves as primary heating sources, and that is no longer the case. They are used less frequently and for backup heat. Coming up with a weighting scheme which is good nationwide is tough. Manufacturers all consider themselves as national companies and will always want one test series that will allow them to sell their products anywhere. 7.3 The equation for the calculation of the air-to-fuel ratio as in Method 28A is in error. The error produces a small but significant difference in the calculated air-to-fuel ratio. Should the method be corrected or should it be left as a “predictor” of the air-to-fuel ratio? Response: I’m not sure how important it really is. Most air-fuel ratio exempted products are

pellet stoves, which are low emitters. I don’t know how hard it would be to fix it, or if the accuracy and precision is any worse than the emission test method.

7.4 The assumed mole fraction of hydrocarbons (Y HC) is defined as a constant in the air-tofuel ratio calculations in Method 28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbon vapors (more appropriately, organic compound vapors) be measured as part of the method? Response: To what advantage? I don’t see the point in terms of exemption issues.

8. EPA Methods 5G and 5H correlations. 8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two methods be reevaluated? Response: This is a big issue for me. The correlation has always been questionable, in my

opinion. There were very little data comparing methods in the area where it counts the most, at low emission rates. There were three correlation curvesA-41 presented and EPA chose the one which most severely penalized method 5G. You can’t have a zero emission stove, if you use 5G. Use getting rid of 5H as justification for developing a good correlation of the methods at low emission rates.

8.2 It is the general perception that method 5H produces lower numbers than 5G. Method 5G is less costly and more precise than 5H. — Comments? — Should there be just one sampling method? Response: It proves that it is a correlation issue, if true. 5G is penalized at low emission

rates.

8.3 The same points regarding flow rate calculations (air-to-fuel ratio) and hydrocarbons as made for Method 28A are applicable to Method 5H. — Comments? Response: This is not new. There have always been problems with the algorithm. This is

another reason to get rid of 5H.

8.4 The precision of EPA’s Method 5 is estimated as being about 20%. Almost one quarter of the 214 stoves listed as certified by the EPA as of 8/12/97 are within 20% of their respective (catalytic or noncatalytic) emission limits. — Comments? Response: If 20% are within the limit, how many stoves have failed, or how many extra runs

have been conducted that were 20% or less over? You will always have this issue, regardless of the precision. The passing grades were pushed lower in the beginning to account for precision, even though no one knew what the precision was. Obviously, the catching method is not the biggest problem here. The biggest variations occur in the Method 28 parameters. If Method 5 is 20%, what is the overall precision of woodstove emission testing?

8.5 Based on practical experience with the 5G and 5H, how can they be improved? Response: 5H is inherently more complicated than 5G. EPA made 5G more complicated than

it needs to be under the guise of QA, but for the most part it’s quite workable as is. It is hard to make generalizations about improving the method. A line-by-line analysis is needed.

9. Performance deterioration of EPA-certified wood stoves in the field.A-42

9.1 It is the opinion of many in the wood stove industry that catalysts last only five years and that a stove designed for a catalyst operated without a functioning catalyst can produce as much emissions as a conventional stove. — Comments? Response: I think there is a range of performance for catalytic stoves with removed or nonfunctioning catalyst. Some stoves have done other things besides just sticking a catalyst element in the ceiling and probably don’t perform as badly as a conventional stove unless really turned down low. Non-catalytic stoves can also perform as badly as a conventional stove if operated improperly.

9.2 Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR and Crested Butte, CO showed that emissions from some catalytic stoves became appreciably worse even after two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been made in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program? Response: Yes, I think they probably have. Certainly things like bypass dampers have

improved. Stoves are generally being used less, which prolongs catalyst life. Training has always been a good idea, but is hard to accomplish, generically. It has to be stove specific to be effective. Building additional cost into the stove will further diminish sales (which are pitiful anyway). Fewer old stoves will be replaced, if costs for new ones go up more.

10. Stress test pros and cons. 10.1 A short-term laboratory woodstove durability testing protocol was developed to predict the long-term durability of stoves under conditions characteristic of in-home use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at veryhigh temperatures over a one to two week period to predict long-term durability under inhome use. Is this a reasonable approach? Response: I know you can break anything if you try hard enough, so at what point do you say

it’s okay? Is high temperature the only factor you should look at?

10.2Should a stress test be made part of the certification process?A-43

Response: Unless you can make an airtight case that a stress test is good predictor of longterm in-home durability, you can’t justify its use. It would take years to properly determine this, rather than speculating at the expense of the manufacturers. The products already have to pass what amounts to a rare event stress test in order to get through safety testing. Market forces regarding warranty already push manufacturers toward producing durable products.

11. Feasibility of developing separate emission factors for dry and wet wood and for softwood and hardwood species classes. 11.1 Optimum wood moisture for low particulate emissions seems to be in the 18% to 20% range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species? Response: I don’t know of any recent data. Obviously no one is out there generating

comparative data because they can’t afford to. I feel that it could be different for different species.

11.2 Wood from different tree species clearly burns differently. The chemical make-up and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If this is true different parts of the country may have different emissions factors for residential wood combustion. Are you aware of any data that document different emission factors for wood from different tree species?
Response: There are some data, using a dilution tunnel, that looked at oak and fir and some

with maple cordwood vs. fir cribs. These data were presented during Reg Neg but were sort of dismissed because they were generated by manufacturer(s).

12. Routine maintenance. 12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than non-catalytic stoves? Would this be relevant for pellet stoves with electronic and moving parts? Response: I think that routine maintenance would help, as there is deterioration of important

components such as door and bypass gaskets which can affect emissions. I feelA-44 that all stoves need maintenance on a regular basis.

12.2Should the home owner be provided with a maintenance manual or a training course at the time of purchase? Should a maintenance program be part of the purchase price particularly for catalytic stoves? Response: Probably not. People don’t want to pay for it. Even if they do, some will not want

to be bothered as time goes on. I’m not sure how you get people to do the right thing.

12.3 What would the key elements of routine maintenance be? Response: Check and replace worn gaskets. Look for warpage or cracking and repair or

replace parts. Inspect the venting system. Make sure all moving parts are functional. Clean or vacuum out air passageways. Inspect, clean or replace catalyst element(s).A-45



### Skip Hayden, Ph.D.-Senior Research Scientist Advanced Combustion Technologies Laboratory

1. State-of-the-art of wood stove combustion and emission control technologies. 1.1 Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable? Response: We don’t see catalysts up here very much, let’s put it that way.

1.2 Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable? Response: Yes, I think that was reasonable. There certainly is a wide variation on what we

see, but 68 would be a better average. We haven’t seen many, the catalyst might be slightly higher strictly because of this pressure drop, but the higher incomplete combustion products sometimes might cancel it out. So I wouldn’t feel that the catalyst had significant advantages in terms of efficiency over the life of the appliance. Statement: OK, we had 72%. Response: Yes, I think that’s an overestimate.

1.3 Can catalytic technology for use in wood stoves be fundamentally improved? Response: Yes. If I took the better advanced combustion (non-catalyst) designs and worked

in a catalyst after the combustion chamber of those designs as a tertiary clean-up, we could end up with some stoves with extremely clean operation. So basically instead of loading the catalyst and requiring it to go through a very wide range, you’d be requiring it to operate the way it does best in a car, even, where it’s working with a relatively consistent fuel gas.

1.4 Is the use of manufactured fuel (densified and wax logs) a credible emission reduction strategy? See Tables 1 & 2 . Response: Potentially yes.A-46

1.5 For non-catalytic stoves the heat retention adjustment with refractory material of various densities can reduce particulate emissions. How big an effect can this have? Response: It’s an intertwining effect with the air release. I don’t think it’s in itself the

solution, so I have a hard time to define an answer to that question.

1.6 Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic wood stoves and more than half for catalytic wood stoves. Are there improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions? Response: Yes they would work. Basically what you’re trying to do is to get a heated up

chamber and some hot ash at the same time, without undergoing too much by-pass of the whole system. Question: I just threw that out there as an example. Are there any other technologies? Response: Certainly a small auxiliary ignition system would also do the trick.

1.7 Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg? Response: Yes. We have specific requirements for masonry heaters in our R2000

requirements.

1.8 Are the emissions and efficiencies for masonry heaters, based on in-home tests, shown in Tables 1 and 2 reasonable? Response: The efficiency range is extremely dependent on a specific heater. We’ve seen a

factor of over two for different heaters, and even for the same heater under different stages of development.

1.9 The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). — Comments? Response: Yes and no. One of the problems we’ve got with some appliance designs--and, if

you want, higher mass appliances fall into this category--is having sort of anA-47 uncontrolled heat release. If the appliance is used where it would normally be expected to be used, lets say between 7:00 PM and 9:00 PM, or something like that, and then it’s releasing heat into the house over a time when we’ve been counseling people to significantly reduce their thermostats and, hence, the heat input into the house, it’s not necessarily an optimal usage of that heat. So, while the efficiency generation of the appliance is good, it is not as effective a use of that energy as it would be if you were to put that heat into an insulated masonry and you had a means to extract the heat from that insulated masonry at some much later time when it was required. It’s sort of the opposite to if you’re using the space-heating ability of a woodstove, as opposed to a central furnace; you’re able to in effect lower sometimes the overall heat demand of the house--because you’re heating the primary space to be heated and letting the other parts go a little bit. Sometimes when we see seasonal efficiencies of woodstoves, and this is were I go back into those numbers that your were quoting, we can see significantly higher efficiencies than that, effective efficiencies, if the location of that appliance is in good concert with the design of the house and the usage patterns within the house.

1.10Default efficiency values are used for wood stoves. This coupled with the fact that emission factors or rates (not g/MJ) are used to rank wood stoves does not provide an incentive for manufacturers to increase the efficiency of their stoves. — Comments? Should an efficiency test method as described (FR v. 55, n 161, p. 33925, Aug. 20,1990) be required to be used and the results listed? Response: I think that using default values is wrong; you should have an efficiency test or at

least a valid means of calculating efficiency from the emissions test.

1.11 Have certified stove design and performance improved since the first certified stoves? If so, how? Response: Marginally with some, more with others, since EPA 1990 certification, primarily in

terms of the resilience of the product (especially baffles) and in the more intelligent multi-location usage of preheated air release. But due to the changing industry, the continued move to improve that product has in general not been what it could be. In recent years, most of the emphasis, intelligence and efforts have gone into gas fireplaces, rather than further advancing, what were potentially really excellent woodstove designs.

2. State-of-the-art of fireplace emission control technology. 2.1 Are the emission factors and efficiencies for the in-home use of fireplaces and insertsA-48

shown in Tables 3 and 4 reasonable? Question: Fireplaces with wax logs 10.5 grams per kg? Response: We’ve seen lower than that, but also the firing rate with wax logs, just by the way

they are run, is significantly lower, as well, giving further absolute emission reductions. Grams per hour reductions of a factor of four or five are possible. And that is with a non-efficient fireplace. That really is the important number for emissions, although it does nothing for efficiency. Question: OK, some other numbers from that table, I have a non-catalytic insert at six

grams per kg, catalytic insert at 6.5, and a pellet insert at two? Response: Well, pellet inserts can be all over the map. We’ve got one now that’s around 0.3,

while some exempt units can be over 12. Question: OK, we had efficiencies on one of those tables. We had a typical open radiant

fireplace as being 7% efficient. Response: We’d say plus or minus. It depends on the climate and the amount of what you’re

taking as the sort of the mean outside air temperature being heated up before it goes out. We think +/-5% to 7%, it’s a little colder in Canada, so that you can actually have a fireplace, with its very large air demands, operating at a negative overall efficiency on the colder winter days. Question: Let’s talk a little about the efficiencies of fireplace inserts, they are basically

woodstoves, just a little less efficient. Response: The efficiency can be lower by as much as half, because a lot of the inserts go into

fireplaces on outside walls, particularly ones that go in masonry fireplaces, and have no insulation on their outer casing (i.e. of the insert). On field trials, where we’d test an insert in the lab and its performance was effectively the same as a woodstove, above 50%, give or take a couple of percent, in some field installations we saw the real efficiency drop to the 30% range in the house, because you weren’t able to extract that heat from the unit into the heated house space. Instead it was being conducted to the outdoors through the masonry. Hence, one of the prime recommendations that we have in Canada for inserts is that they should have an insulated outer casing.

2.2 There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. — What designs and technology are available? What retrofit options are there?A-49

Response: Basically, I would say that the same options you have for wood stoves, in effect,

are available to you for fireplaces. We have a real hard time in Canada having such an appliance (i.e., a conventional wood burning fireplace) in a new house, which is significantly inefficient, being an appliance that runs at a high burn rate at high excess air, while polluting at the same time. Taking the same advanced combustion technology developed for woodstoves and using it in a fireplace design can be most effective. So reducing excess air and improving the completeness of combustion can be combined to give you significant reduction in particulate emissions. At the same time, efficiency is high and burn rate is low. This presupposes a tight unit that operates with the door always shut, except on loading, a ceramic glass front to allow most of the radiation from the flame into the room, good heat exchange, insulated outer casing and even sealed combustion. There is a major potential future for efficient clean burning wood fireplaces operating at low excess air with an attractive flame, allowing a renewable energy resource with CO2-neutral emissions to be used in the majority of North American homes, allowing this technology to be a contributing factor in mitigating global warming.

2.3 The use of wax fire logs reduce emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even less emissions?
Response: Yes, it would be significant. However, we still consider it to be only a decorative

use of the fireplace with no significant energy input into the house, and consider that to be a wasteful use of a renewable energy resource.

2.4 What are the distinctions between a masonry fireplace and a masonry heater? Response: I would put a lower or upper limit on excess air and I would also define it as a unit

that has no combustion air contact with the dwelling in which it’s installed. The masonry heater also has a significant amount of heat exchange surface.

2.5 As with wood stoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates. Response: The problem is on defining exactly what efficiency is and how it is truly measured.

Probably around 90% of the fireplaces in North America are being installed on outside walls. Right away, require that you have some kind of estimate, not only of combustion heat loss, but of casing loss and, potentially, of radiative, versusA-50 convective, versus off-cycle loss, as well as a charge for heated house air drawn through the appliance, especially when it is running.

3. State-of-the-art of wood-fired central heating furnace emission control technology. 3.1 According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified? Response: The number of central wood furnaces in Canada, certainly in comparison to the

United States, would be higher. In our Eastern provinces, it’s a relatively common add-on to existing oil furnaces. Generally, they are as dirty as can be. Question: Do you have any emission data on them? Response: There were a couple of papers produced at the wood conference that we had down

in New Orleans in the early 80's. In addition to the emissions seen from normal wood burning, as per stoves, there are dramatic peaks in emissions every time the furnace cycles “on” or “off”, as well as very high emissions during the “off” or “stewing” condition. Finally, the advances in wood combustion technology seen in the better stoves, have not found their way into the furnace designs, which generally use 1970's combustion technology.
Question: Do you think they should be certified? Response: Certainly, if the use of these central furnaces/boilers grows at all, they should not

be exempt, because they are potentially very dirty, as explained above. In Canada, there is a draft CSA B415.2 emissions standard for boilers and furnaces.

4. State-of-the-art of pellet-fired wood stove technology. 4.1 Are the emissions and efficiencies for the in-home use of pellet stoves shown in Tables 1 and 2 reasonable? Response: We saw a variation from one to two to up to ten g/h (and even higher), and the

efficiencies from the high 70's to the low 50's and below for units running on very high excess air. I think those numbers in the table are optimistic, particularly for the exempt units.A-51

4.2 The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification? Response: Yes. In Canada, we recommend that people buy only EPA-approved pellet stoves.

We have developed a high ash pellet stove that’s operating around 85% and its emissions are about 0.3 g/hr or less.

4.3 Have pellet stove design and performance improved since the first models were introduced? If so, how? Response: In particular, some units have learned how to handle high ash fusion and some

units have learned how to run at more concentrated (i.e. lower) excess air levels. Some units have been improved to handle accumulations of ash without disrupting the combustion process. Feeding techniques have advanced, as well as knowledge of satisfactory venting procedures.

5. Ramifications of ISO.

5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO method 13336 with EPA methods 28, 5G and 5H.) Do you feel that the EPA methods should be replaced with or be made comparable to an international standard? Response: I am unfamiliar with the ISO procedure. I feel that, as far as emissions are

concerned, the EPA standard in general is pretty good.

6. Correspondence between in-home and laboratory emission test results. 6.1 How accurately do certification tests predict in-home performance?
Response: It depends on the design of the unit. A design with simple, obvious air control

often has performance which reflects the lab very well. Complex operating procedures often do not translate into realized performance.A-52

6.2 How would you design research testing in the laboratory to simulate in-home use? Response: Ron Braaten (on my staff) would be a better one to talk to than me, although I do

believe that it can be done simply and intelligently.

7. EPA Method 28 strengths and weaknesses. 7.1 Method 28 is in part an “art”. Fuel loading density, fuel moisture, fuel characteristics (old vs new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have? Response: Ron is better equipped to answer that one.

7.2 Burn rate weighting is based on very limited data and the cities from where the data were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole? Response: In Canada, house insulation/heating load levels are usually set to reflect differences

in degree days, so that results from one zone are fairly easily transported to another.

7.3 The equation for the calculation of the air-to-fuel ratio is in Method 28A is in error. The error produces a small but significant difference in the calculated air-to-fuel ratio. Should the method be corrected or should it be left as a “predictor” of the air-to-fuel ratio? Response: Believe it should be corrected.

7.4 The assumed mole fraction of hydrocarbons (Y HC) is defined as a constant in the air-tofuel ratio calculations in Method 28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbon vapors (more appropriately, organic compound vapors) be measured as part of the method? Response: We have done so using some complex hydrocarbon analyzers (not just standard

FID’s or heated FID’s). In the initial development of clean burning equipment, it is important. It may not be so on an on-going basis where inference techniquesA-53 can be utilized. 8. EPA Methods 5G and 5H correlations. 8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two methods be reevaluated? Response: Ask Ron. (See response to 7.1)

8.2 It is the general perception that method 5H produces lower numbers than 5G. Method 5G is less costly and more precise than 5H. — Comments? — Should there be just one sampling method? Response: Yes, I think there should be just one.

8.3 The same points regarding flow rate calculations (air-to-fuel ratio) and hydrocarbons as made for Method 28A are applicable to Method 5H. — Comments? Statement: See my response to 7.3.

8.4 The precision of EPA’s Method 5 is estimated as being about 20%. Almost one quarter of the 214 stoves listed as certified by the EPA as of 8/12/97 are within 20% of their respective (catalytic or noncatalytic) emission limits. — Comments? Response: Ask Ron. However, if wood burning is going to increase as a technique to help

mitigate the global warming problem and meet climate change targets, technology should be improved, and the standards moved downwards, perhaps to 2.5 and 4 g/hr for catalytic and non-catalytic technologies, respectively.

8.5 Based on practical experience with the 5G and 5H, how can they be improved? Response: Ask Ron. (See response to 7.1) 9. Performance deterioration of EPA-certified wood stoves in the field. 9.1 It is the opinion of many in the wood stove industry that catalysts only last five years and that a stove designed for a catalyst operated without a functioning catalyst can produce as much emissions as a conventional stove. — Comments?A-54

Response: That’s certainly possible, plus it can spill more combustion gases into the house.

My experience has been that the deterioration will occur in sooner than 5 years.

9.2 Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR and Crested Butte, CO showed that emissions from some catalytic stoves became appreciably worse even after two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been made in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program? Response: We counsel Canadians to buy advanced combustion stoves, rather than catalyst

stoves. You can’t get that kind of performance over the long term, or even necessarily over the short term.

10. Stress test pros and cons. 10.1 A short-term laboratory woodstove durability testing protocol was developed to predict the long-term durability of stoves under conditions characteristic of in-home use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at very high temperatures over a one to two week period to predict long -term durability under in-home use. Is this a reasonable approach? Response: Well I think it’s reasonable; in fact we’re one of the initiators of that concept and

were participants in it. However, I conceived it more as a tool for manufacturers to develop a more durable product than as a requirement for certification. I think that in general there are better ways to require a certain amount of dollars being spent rather than having a fairly costly test done. I would be concerned that this would significantly increase the cost of the appliance.

10.2Should a stress test be made part of the certification process? Response: For advanced combustion stoves, no. For catalyst stoves, perhaps. 11. Feasibility of developing separate emission factors for dry and wet wood and for softwood and hardwood species classes. 11.1 Optimum wood moisture for low particulate emissions seems to be in the 18% to 20%A-55

range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species? Response: We did some work on wood moisture a few years ago, but I can’t remember what

the results were. Our general recommendation is that people use cordwood that’s been air dried for at least one year. We also don’t see significant difference between soft and hard wood in a good design.

11.2 Wood from different tree species clearly burns differently. The chemical make-up and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If this is true different parts of the country may have different emissions factors for residential wood combustion. Are you aware of any data that document different emission factors for wood from different tree species? Response: We did some work, but found that with a good combustion design there was not a

significant difference.

12. Routine maintenance. 12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than non-catalyticalytic stoves? Would this be relevant for pellet stoves with electronic and moving parts? Response: One of the features of the routine maintenance would be the tightness of the gasket

around the door and that might or might not, depending on the design, give you more or less particulate emissions on a non-catalyst stove. It would help you to control the burning rate, but it might also make it easier to burn wetter wood. Certainly routine maintenance around the catalyst, if that maintenance is such that you’re not actually potentially replacing the catalyst or to maybe open up or seal a by-pass that wasn’t there just by virtue of deposits. Also, interior cleaning to ensure the air ports are not restricted by ash deposit is important.

12.2Should the home owner be provided with a maintenance manual or a training course at the time of purchase. Should a maintenance program be part of the purchase price particularly for catalytic stoves? Response: Operational yes; the trouble with manuals is they are often a little too long and big

and the essential items don’t necessarily get followed or even perceived. So yesA-56 you should have it, but you should also have a short form of the important things to do. If you have a catalyst, there should be some sort of periodic means of verification and replacement built in to the cost of the unit. I do not believe that an external (i.e. non-houseowner) maintenance program should be a requirement.

12.3 What would the key elements of routine maintenance be? Response: Other then the verification of the state of the baffle and if it’s easily visible, the

glowing catalyst operation and the tightness of the door. I think the important things are the ongoing operational checks that a homeowner should do. Obviously the flue pipe and chimney need to be examined and cleaned as required. Air ports should not be blocked. We recommend the use of sealed double walled flue pipe from the appliance to the chimney to ensure good draft, to reduce likelihood of condensation/deposition in the chimney, and to run the appliance slightly hotter to ensure clean combustion.
An important general comment that I have is that for an advanced combustion (noncatalyst) stove or fireplace, the more attractive and complex the flame, the cleaner the combustion, so there is a good guiding tendency for the user to maintain lower emissions performance (for a woodstove or a fireplace).A-57



### Daniel Henry, Vice President -- Aladdin Steel Products, Inc. (Mike Hoteling with Aladdin Steel Products also present during interviews)

1. State-of-the-art of wood stove combustion and emission control technologies. 1.1 Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable? Response: I think Mike and I agree they are. The consumer can have a major impact on insitu wood stove performance. I think in some studies they were better trained than in other studies.

1.2 Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable? Response: Were all those stoves using the same method to determine efficiencies? I think, I

have a feeling in the back of my mind, or a gut feeling, that the catalytic stoves have a tremendous amount of forgiveness for both g/hr and efficiency as a result of the fact that it’s only determined after the by-pass is closed. 72% for catalytic overall seems kind of high. And good clean non-catalytics are kind of low.

1.3 Can catalytic technology for use in wood stoves be fundamentally improved? Response: My opinion is all technology can be improved. The data that I’ve seen and at all

the seminars where data are presented, the catalyst was not necessarily the problem--the stove design was, warping by-passes, combustors located in temperature environments that exceeded their capability. So, my answer is, I think all technology can be improved, be it catalytic or non-catalytic. And I don’tbelieve catalyst technology has reached its peak potential and I don’t think noncatalytics have either.

1.4 Is the use of manufactured fuel (densified and wax logs) a credible emission reduction strategy? See Tables 1 & 2. Response: I think so, if they were not too costly. And it would probably be more feasible in

an urban environment where people have access to buying their fuel. But in a rural environment where people are cutting their own wood, they are still going to cut kindling.A-58

1.5 For non-catalytic stoves the heat retention adjustment with refractory material of various densities can reduce particulate emissions. How big an effect can this have? Response: It goes both ways. It really is a design criterion that will tend to show that one

might be better than the other. We’re talking, on a 5 gram stove, a difference of plus or minus a gram between the high and low densities.

1.6 Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic wood stoves and more than half for catalytic wood stoves. Are there improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions? Response: I agree with that, albeit one of the things that will come up later is that in the

emission certification series we were limited to 5 minutes of having the appliance wide open. In a Northern climate zone, where a homeowner uses a woodstove for a primary heat source, the stove seldom needs to be kindled from a cold start. They just keep the stove going and keep feeding it. It’s the cold start kindling, when the mass of the stove is absorbing the majority of the fire’s heat that causes increased emissions. And in warmer regions, or during Spring and Fall in colder regions, when the stove is used only at night, it will need to be started cold. It may well be that specially designed wax logs or other products or devices could help reduce emissions, provided they didn’t cost too much.

1.7 Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg? Response: I feel all wood combustion systems should have to meet emissions standards. And,

I don’t care whether it’s a different standard than what woodstoves are currently tested under. Everything should have to prove to be clean burning, if they are going to regulate wood combustion or wood heat, because the wood stove has technically gotten a black eye for many years when there are other wood-burning systems that were emitting emissions.

1.8 Are the emissions and efficiencies for masonry heaters, based on in-home tests, shown in Tables 1 and 2 reasonable? Response: I don’t know.A-59

1.9 The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). — Comments? Response: I agree.

1.10Default efficiency values are used for wood stoves. This coupled with the fact that emission factors or rates (not g/MJ) are used to rank wood stoves does not provide an incentive for manufacturers to increase the efficiency of their stoves. — Comments? Should an efficiency test method as described (FR v. 55, n 161, p. 33925, Aug. 20,1990) be required to be used and the results listed? Response: That’s definitely true, if an accurate method for certifiable products can be

developed.

1.11 Have certified stove design and performance improved since the first certified stoves? If so, how? Response: Yes. There’s been kind of a laps the last couple of years, because the sales have

been low and there hasn’t been much incentive. But, I think now that there have been a few disasters as far as weather, wood stove sales are picking up and holding their own. Current technology stoves are more stable and reliable in their performance for emission certification.

2. State-of-the-art of fireplace emission control technology. 2.1 Are the emission factors and efficiencies for the in-home use of fireplaces and inserts shown in Tables 3 and 4 reasonable? Response: They seem to be.

2.2 There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. — What designs and technologies are available? What retrofit options are there? Response: In 1991 or 1992, I got a call from Majestic to build them a clean burning fireplace.

They were moving forward as a manufacturer under the belief that new fireplaces would be regulated, not unlike wood stoves, in the near future.A-60 I developed a single burn rate appliance on which we conducted EPA certification style testing and it came in at, I think, 3.6 grams per hour, and they did two or three runs to confirm it. All I really did was take a fireplace and design a secondary combustion system, with an insulated baffle and secondary tubes and developed the air flow to keep up with the burn rate. And, I think the burn rate, at that time, was in the three kilogram per hour range, which was what we determined, based on the limited amount of data that were available, was where the average fireplace burn rate was, with closed doors--fireplaces that had no doors were generally lower than that. I thought there was a tremendous opportunity to apply non-catalytic woodstove technology to fireplaces. But, the fireplace had limited volume production due to high retail costs.

2.3 The use of wax fire logs reduces emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even less emissions? Response: Don’t know.

2.4 What are the distinctions between a masonry fireplace and a masonry heater? Response: A masonry fireplace is a firebox, damper, and essentially a vertical flue. A

masonry heater on the other hand is generally a smaller firebox which transfers heat to the massive masonry. A masonry heater is located centrally in the room so little heat is lost to the outdoors.

2.5 As with wood stoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates. Response: I agree with that.

3. State-of-the-art of wood-fired central heating furnace emission control technology. 3.1 According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified? Response: I think a lot of these are used in rural areas and considering the fuels that are outA-61 there, I don’t think they should be regulated. Maybe just a spot check of some sort. I think the only thing that would benefit would be the testing laboratories. If it emits particulate into an air shed where it can have an adverse effect on the industry (my ability to make a living), then yes.

4. State-of-the-art of pellet-fired wood stove technology. 4.1 Are the emissions and efficiencies for the in-home use of pellet stoves shown in Tables 1 and 2 reasonable? Response: They seem to be. Yes.

4.2 The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification? Response: Well there are six or seven of us left that manufacture pellet stoves. There may be

two or three companies that I haven’t heard of, but the numbers they are doing at this point are pretty insignificant. There is no data that indicates that even a poorly operating stove is a dirty burning appliance. They are inherently clean, becoming more and more reliable, and don’t fix them if they aren’t broken.

4.3 Have pellet stove design and performance improved since the first models were introduced? If so, how? Response: Yes, vastly. You go back to the late 80's and early 90's, there were probably sixty

pellet stove manufacturers building something and putting a name on it. Field experience problems arrived on the issues of cash flow, poor performance and so on and so forth weeded them out.

5. Ramifications of ISO.

5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO method 13336 with EPA methods 28, 5G and 5H.) Do you feel that the EPA methods should be replacedA-62

with or be made comparable to an international standard? Response: I would vote for something that would be accepted internationally.

6. Correspondence between in-home and laboratory emission test results. 6.1 How accurately do certification tests predict in-home performance?
Response: For some reason we thought that in-home use should be represented in a

laboratory number, and in some cases they have been and in some cases they have not been. I believe that a laboratory number, with dimensional lumber and the latitude that we have within the test method, could be an indicator of performance, not what the stove should be able to do with firewood that’s got bark and dirt. We certify our woodstove with 15 feet of pipe, whenever homeowners burn the woodstove it can have anywhere from four to forty feet of pipe on it. That’s going to affect the way it burns. There is a real correlation between the height of the stack, static pressure, and the combustion air flowing through the firebox of the appliance that EPA and we in industry didn’t think too much about during the development of the standard. But, if we have in the field today an appliance experiencing what we refer to as an “over draft”--you could have a unit that’s capable of putting out significant amounts of BTUs into a room, stuck on a 30 foot stack and the guy says, “It burns the wood up in an hour and a half and I’m freezing to death;”--obviously, all the heat is going up the chimney. We’ve had to come up with solutions for those applications to try and bring the static pressure seen in the firebox back to within parameters that are closer to what was seen during the certification. That can range from a chimney damper to a ring around the top of the chimney that reduces the diameter to, in some cases, putting firebrick up on the baffle to restrict the outlet of the appliance.

6.2 How would you design research testing in the laboratory to simulate in-home use? Question: So, how would you design a test standard to accommodate all of that? (See

paragraph two of response to question 6.1.) Response: I don’t think we would do it that way. I think you require the manufacturer to

give actual static pressure numbers. Build a firebox that has got a static pressure port, and when you run the stove wide-open, require wood pieces that are roughly two inches square and are stacked in there in a crib form (four or five across and four or five left to right and then four or five front to back). Have certification requirements for certified wood installers and they burn the appliance and verifyA-63 the static pressure is within the allowable parameters--and you’d solve the problem. 7. EPA Method 28 strengths and weaknesses. 7.1 Method 28 is in part an “art”. Fuel loading density, fuel moisture, fuel characteristics (old vs new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have? Question: In your experience what things have the most effect on particulate emissions? Response: Every one of them. It would be difficult to say that any one or two of those has

more effect than one or two of the others. If I was going to make a pick, I would say fuel moisture. Question: How much influence do you think that can have? Can you estimate in grams per

hour? Response: From 40 down to 2. Well if you’ve got a piece of wood that goes “pop”, it blows

your low burn out and you’ve got a 40 gram run. If it doesn’t go “pop” and it burns and burns and burns, you’ve got a 2 gram run. That’s the difference. A lot of it depends on if the wood is stable or if it’s unstable. You can check that during the pre-burn. You cut a piece of the end and throw it in during the pre-burn. If it goes bang, pop, boom during the pre-burn, you don’t use it during your test. Question: Do you think that if there were more flexibility during the five minute start-up,

that these things would have less influence? Response: Absolutely. We write in our owner’s manuals: after a new load of firewood, put

the draft controls in the wide-open position and run the stove in wide-open condition until you’ve got all the wood engulfed in flame--and we put a time in there 15, 20 minutes wide-open and then shut the stove down. Well that heats the appliance up and gets the secondary system up to temperature, where it will maintain stable secondary, and it also kindles the new load of wood so that you are getting a release of combustibles that will sustain the secondary combustion. Once you’ve got that locked in, it’s self sustaining and it’s going to burn clean until that load of wood is in the char and you lose your secondary. So if the test method could replicate more real world instruction manuals, which the EPA has to approve also, then I think we would have cleaner performing field appliances. It would also allow us to do more things as far as firebox size.A-64

7.2 Burn rate weighting is based on very limited data and the cities from where the data were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole? Response: There are many factors that are going to come into this, but if you can get a region

that has 100 wood stoves per square mile and then other places that are going to have none and there’re going to be places that are going to be in proximity to wood and it’s almost mind boggling to try to figure that one out.

7.3 The equation for the calculation of the air-to-fuel ratio as in Method 28A is in error. The error produces a small but significant difference in the calculated air-to-fuel ratio. Should the method be corrected or should it be left as a “predictor” of the air-to-fuel ratio? Response: I have no objection to proving the accuracy of it.

7.4 The assumed mole fraction of hydrocarbons (Y HC) is defined as a constant in the air-tofuel ratio calculations in Method 28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbon vapors (more appropriately, organic compound vapors) be measured as part of the method? Response: I don’t think that it’s necessary to actually measure hydrocarbon vapor to

determine air-to-fuel ratio. It should be possible to determine ranges of values for various hard and soft wood species under typical combustion conditions to come up with a close enough approximation for practical purposes.

8. EPA Methods 5G and 5H correlations. 8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two methods be reevaluated? Response: I always thought that 5H was right and 5G was corrected to match 5H. Now it

appears that 5G is possibly correct and 5H was in error. There was quite a bit of discussion concerning if 5G is correct and the error with 5G is the correction factor and bring it up or down to 5H. I would lobby that if 5G is the correct number, then the problem with 5G is the correction factor. One of the things we have a lot of data on here is the Condar in parallel with 5G. Method 5G and the Condar were very very close, until we hit it with the correction number, and then they got apart and it was always in the negative, not the positive. We got to theA-65 point where I stopped using 5G and stayed with the Condar, because when I get certified with 5H it was more realistic data. I don’t have a problem getting rid of 5H and going with 5G. I would hate to voice my opinion or raise my hand to vote on it, if we would have to take a penalty in performance numbers. The industry is now getting used to seeing two to four gram non-catalytic stoves and one and a half to three and a half gram catalytic stoves. If we suddenly come back there with five gram stoves and it’s because of a number that we pulled out of our hats to use as the new single test method, then that’s going to have some serious ramifications on--Oh, our technology went backward instead of forward, and numbers like the State of Washington’s four and a half grams for non-catalytics, there is a potentially serious downside there. So whatever we end up doing, I don’t want to see that happen. If 5G is correct, there should be no correction factor, eliminate 5H and leave the standard at 7 1⁄2.

8.2 It is the general perception that method 5H produces lower numbers than 5G. Method 5G is less costly and more precise than 5H. — Comments? — Should there be just one sampling method? Response: 5H produces lower numbers than 5G.

8.3 The same points regarding flow rate calculations (air-to-fuel ratio) and hydrocarbons as made for Method 28A are applicable to Method 5H. — Comments? Response: I think they ought to correct that, it’s not going to hurt us as an industry; it’s just

going to give us a real number.

8.4 The precision of EPA’s Method 5 is estimated as being about 20%. Almost one quarter of the 214 stoves listed as certified by the EPA as of 8/12/97 are within 20% of their respective (catalytic or noncatalytic) emission limits. — Comments? Question: OK, the precision of EPA’s Method 5 is estimated as being about 20%. Response: I’ll buy that. Question: Almost one quarter of the 214 stoves listed as certified by the EPA as of 8/12/97

are within 20% of their respective (catalytic or noncatalytic) emission limits. Any comments on that? Response: That 20% error factor was discussed during the Reg Neg process. When theyA-66 turned the number from 9 grams an hour Oregon to 7.5 grams an hour EPA, I always felt like that 20% was accounted for. And another thing, in the Federal Register, No. 38, page 5877, in the rules, they have a different test frequency for people who are within 30% of the standard--so I believe it’s accounted for there.

8.5 Based on practical experience with the 5G and 5H, how can they be improved? Response: Covered that already.

9. Performance deterioration of EPA-certified wood stoves in the field. 9.1 It is the opinion of many in the wood stove industry that catalysts last only five years and that a stove designed for a catalyst operated without a functioning catalyst can produce as much emissions as a conventional stove. — Comments? Response: True, I believe a well cared for catalyst can last longer then 5 years.

9.2 Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR and Crested Butte, CO showed that emissions from some catalytic stoves became appreciably worse even after two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been made in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program? Response: Yes, should be up to the manufacturer’s discretion.

10. Stress test pros and cons. 10.1 A short-term laboratory woodstove durability testing protocol was developed to predict the long-term durability of stoves under conditions characteristic of in-home use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at veryhigh temperatures over a one to two week period to predict long-term durability under inhome use. Is this a reasonable approach? Response: See response to 10.2A-67

10.2Should a stress test be made part of the certification process? Response: I’m not standing for anything that raises the cost of certifying a product before we

can go to market. Anything that we use that’s going to increase the cost of certification, so that I can go to market with it, it’s going to drive up the retail price. You take the top five manufacturers nationwide and only one of them is selling more than 1,750 of any one model currently. But I think a stress test, durability test should be based on real world operations.

11. Feasibility of developing separate emission factors for dry and wet wood and for softwood and hardwood species classes.

11.1 Optimum wood moisture for low particulate emissions seems to be in the 18% to 20% range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species? Response: I think you’ve got that data with fuel performance and documenting the moisture

content of the firewood pile.

11.2 Wood from different tree species clearly burns differently. The chemical make-up and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If this is true different parts of the country may have different emissions factors for residential wood combustion. Are you aware of any data that document different emission factors for wood from different tree species? Response: Oak and it burned very very clean.

12. Routine maintenance. 12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than non-catalytic stoves? Would this be relevant for pellet stoves with electronic and moving parts? Response: Definitely; just like a car, routine maintenance improves the lifetime of anything.

Especially with pellet stoves, blowers, heat exchangers, that’s common sense. It tends to be far more critical for catalytic technology. They either work or theyA-68 don’t.

12.2Should the home owner be provided with a maintenance manual or a training course at the time of purchase? Should a maintenance program be part of the purchase price particularly for catalytic stoves? Response: Video format works really well. No.

12.3 What would the key elements of routine maintenance be? Response: Front door gasket.A-69



### Dennis Jaasma, Ph.D. - Associate Professor, Department of Mechanical Engineering, Virginia Polytechnic Institute and State University

1. State-of-the-art of wood stove combustion and emission control technologies. 1.1 Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable? Response: The numbers are a bit too low on pretty much everything. Catalytic and noncatalytic reductions are both listed too high. Whenever we have tested the conventional stoves the numbers have been around 22 g/kg. The estimate that I’m giving is on the Crested Butte data, it was never less than about 20. For catalytics the average is about 21. I don’t think things are that bad in general.

1.2 Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable? Response: I didn’t have any problems with efficiencies; the numbers weren’t that bad.

1.3 Can catalytic technology for use in wood stoves be fundamentally improved? Response: Anything like that can get better.

1.4 Is the use of manufactured fuel (densified and wax logs) a credible emission reduction strategy? See Tables 1 & 2 . Response: It’s not the answer to emission control due to the cost of the logs. People aren’t

going to pay for these, unless they become cheap.

1.5 For non-catalytic stoves the heat retention adjustment with refractory material of various densities can reduce particulate emissions. How big an effect can this have? Response: I don’t know.

1.6 Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic wood stoves and more than half for catalytic wood stoves. Are thereA-70

improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions? Response: Having the dry wood and proper operations goes a long way. For example,

kindling the fire and stacking it the right way.

1.7 Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg? Response: This is a regulatory issue. EPA may or may not have the money to regulate

masonry heaters.

1.8 Are the emissions and efficiencies for masonry heaters, based on in-home tests, shown in Tables 1 and 2 reasonable? Response: I can’t say, unless I knew how these appliances were operated.

1.9 The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). — Comments? Response: No, if testing costs are relevant the g/hr approach is OK for now. For masonry

heaters, a g/kg standard is a good choice in order to avoid unnecessarily complicated test procedures.

1.10Default efficiency values are used for wood stoves. This coupled with the fact that emission factors or rates (not g/MJ) are used to rank wood stoves does not provide an incentive for manufacturers to increase the efficiency of their stoves. — Comments? Should an efficiency test method as described (FR v. 55, n 161, p. 33925, Aug. 20,1990) be required to be used and the results listed? Response: It is really up to the EPA. I think it is a good idea.

1.11 Have certified stove design and performance improved since the first certified stoves? If so, how? Response: Larger firebox, cleaner glass, durability (people don’t want to have warrantyA-71 claims), consumer features. 2. State-of-the-art of fireplace emission control technology. 2.1 Are the emission factors and efficiencies for the in-home use of fireplaces and inserts shown in Tables 3 and 4 reasonable? Response: Emission factors for fireplaces were a lot too high.

2.2 There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. — What designs and technologies are available? What retrofit options are there? Response: Gas logs.

2.3 The use of wax fire logs reduces emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even less emissions? Response: Probably wax logs can be formulated to give reduced emissions.

2.4 What are the distinctions between a masonry fireplace and a masonry heater? Response: Masonry heaters have counter flow arrangements and more restricted air supply .

2.5 As with wood stoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates. Response: Fireplaces can’t compete if a standard is on a g/energy basis. There is more to life

then heat. Some could argue that fireplaces should be treated differently.

3. State-of-the-art of wood-fired central heating furnace emission control technology. 3.1 According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified?A-72

Response: Yes, central heaters merit further evaluation. I don't know how many models are

available. I think EPA has done some work on them, but I do not know any results. Yes, they should be certified. They are in danger of becoming extinct if they don't wind up with a certification program.

4. State-of-the-art of pellet-fired wood stove technology. 4.1 Are the emissions and efficiencies for the in-home use of pellet stoves shown in Tables 1 and 2 reasonable? Response: OK regarding PM factors. The efficiency numbers are reasonable.

4.2 The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification? Response: Pellet stoves are inherently clean burning unless there is something very bad about

their design. I am not concerned about regulating the currently uncertified units unless their field emissions are bad compared to certified stoves.

4.3 Have pellet stove design and performance improved since the first models were introduced? If so, how? Response: No comment.

5. Ramifications of ISO. 5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO method 13336 with EPA methods 28, 5G and 5H.) Do you feel that the EPA methods should be replaced with or be made comparable to an international standard? Response: The EPA standard should be improved, since it will be a long time before it is

replaced by something else. In the long run I hope the ISO effort becomes a standard and the US adopts it.A-73

6. Correspondence between in-home and laboratory emission test results. 6.1 How accurately do certification tests predict in-home performance? Response: Correlation is very poor.

6.2 How would you design research testing in the laboratory to simulate in-home use? Response: Use of reasonable volatility cordwood fuel, reasonable coal bed size, and a range

of burn rates.

7. EPA Method 28 strengths and weaknesses. 7.1 Method 28 is in part an “art”. Fuel loading density, fuel moisture, fuel characteristics (old vs new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have? Response: Coal bed size, can’t give a number on that.

7.2 Burn rate weighting is based on very limited data and the cities from where the data were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole? Response: I think this is a subject for discussion and an open review. 7.3 The equation for the calculation of the air-to-fuel ratio as in Method 28A is in error. The error produces a small but significant difference in the calculated air-to-fuel ratio. Should the method be corrected or should it be left as a “predictor” of the air-to-fuel ratio? Response: (None)

7.4 The assumed mole fraction of hydrocarbons (Y HC) is defined as a constant in the air-tofuel ratio calculations in Method 28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbon vapors (more appropriately, organic compound vapors) be measured as part of the method?A-74

Response: No, should calculate the hydrocarbon number, estimate the value from the

concentration of carbon monoxide in flue gases.

8. EPA Methods 5G and 5H correlations. 8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two methods be reevaluated? Response: No.

8.2 It is the general perception that method 5H produces lower numbers than 5G. Method 5G is less costly and more precise than 5H. — Comments? — Should there be just one sampling method? Response: Yes.

8.3 The same points regarding flow rate calculations (air-to-fuel ratio) and hydrocarbons as made for Method 28A are applicable to Method 5H. — Comments? Response: Eliminate 5H.

8.4 The precision of EPA’s Method 5 is estimated as being about 20%. Almost one quarter of the 214 stoves listed as certified by the EPA as of 8/12/97 are within 20% of their respective (catalytic or noncatalytic) emission limits. — Comments? Response: The precision of 5G is about +/- 2%. The relatively poor precision of 5H is an

additional reason to eliminate 5H.

8.5 Based on practical experience with the 5G and 5H, how can they be improved? Response: 5G, aluminum front filter holders, also dual train approach for 5G should be

required for good QA.

9. Performance deterioration of EPA-certified wood stoves in the field. 9.1 It is the opinion of many in the wood stove industry that catalysts last only five years and that a stove designed for a catalyst operated without a functioning catalyst can produceA-75

as much emissions as a conventional stove. — Comments? Response: Not a good answer for that; could be less then 5 years, could be more.

9.2 Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR and Crested Butte, CO showed that emissions from some catalytic stoves became appreciably worse even after two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been made in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program? Response: Homeowner training is an excellent idea. A paid-for-up-front

inspection/replacement program is not a good idea.

10. Stress test pros and cons. 10.1 A short-term laboratory woodstove durability testing protocol was developed to predict the long-term durability of stoves under conditions characteristic of in-home use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at veryhigh temperatures over a one to two week period to predict long-term durability under inhome use. Is this a reasonable approach? Response: Good idea,if stress test does a good job in predicting failures that actually occur in the field for specific models. The test would need to be confirmed before it is required.

10.2Should a stress test be made part of the certification process? Response: Yes.

11. Feasibility of developing separate emission factors for dry and wet wood and for softwood and hardwood species classes. 11.1 Optimum wood moisture for low particulate emissions seems to be in the 18% to 20% range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species?A-76

Response: There are much field data that could be looked at. Existing lab and field data

could be analyzed, or new data generated.

11.2 Wood from different tree species clearly burns differently. The chemical make-up and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If this is true different parts of the country may have different emissions factors for residential wood combustion. Are you aware of any data that document different emission factors for wood from different tree species? Response: Field data exist and could be reviewed, but I don’t know if anyone has done it.

12. Routine maintenance

. 12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than non-catalytic stoves? Would this be relevant for pellet stoves with electronic and moving parts? Response: Routine maintenance of catalytic stoves will reduce emissions from some models,

but have little impact on others. Routine maintenance of non-catalytics will also provide some emissions reductions. Same applies to pellet stoves.

12.2Should the home owner be provided with a maintenance manual or a training course at the time of purchase? Should a maintenance program be part of the purchase price particularly for catalytic stoves? Response: Yes, definitely yes for the training manual. But a maintenance program should not

be part of the purchase price for catalytic stoves. The most effective solution to poor field performance is intelligent local intervention triggered by excessive smoke.

12.3 What would the key elements of routine maintenance be? Response: Inspection, cleaning, and repair.A-77



### Robert C. McCrillis-Mechanical Engineer, U.S. Environmental Protection Agency

1. State-of-the-art of wood stove combustion and emission control technologies. 1.1 Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable? Response: I think they are for new installations, and of course that doesn’t account for any

degradation. And I suppose it’s possible that some of the newer, I mean all these tests were done on stoves that were built in the early 90's. So maybe some of the newer stoves might do a little better.

1.2 Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable? Response: Well I think they are, again for new installations. I have a suspicion and no way to

prove it that maybe since the manufacturers use these default efficiencies there is no incentive to make a stove efficient. And I think stoves burn better when you throw a little more heat up the chimney, so the actual efficiencies may have actually gone down.

1.3 Can catalytic technology for use in wood stoves be fundamentally improved? Response: I don’t know about the catalyst itself; I just don’t know, but there may be some

more attention that could be paid to the design of the way the catalyst is installed so that it doesn’t get overheated.

1.4 Is the use of manufactured fuel (densified and wax logs) a credible emission reduction strategy? See Tables 1 & 2 . Response: We don’t have very much data at all; the only thing that I have seen are the data

that you did. It may be reasonable. It may give you some gain or some reduction in the emissions, although the data are showing what, 20 to 30%. It is a more uniform fuel. I don’t know if anybody has looked at any other potential pollutants that might be coming out of wax logs. Personally, I wouldn’t make a big push to try to get the EPA, lets say, to recognize them as a way to get some emission reduction.A-78

1.5 For non-catalytic stoves the heat retention adjustment with refractory material of various densities can reduce particulate emissions. How big an effect can this have?
Response: The little bit of testing that we were able to do here in our lab with that prototype,

it seemed like it ran a lot hotter, and in some respects that was good, but then in other respects that was bad. When you threw a load of wood into that stove it retained a lot more heat, so that it tended to drive off volatiles fast and overwhelm the secondary. I’m sure it can have an effect and I suppose the effect could be good or it could be bad.

1.6 Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic wood stoves and more than half for catalytic wood stoves. Are there improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions? Response: Again, I think the EPA little gas burner would have helped to get that secondary

going quicker, especially on the non-catalytic. It probably wouldn’t have been applicable to a catalytic stove, unless you could use it to preheat the catalyst or maybe use a catalyst that is preheated electrically. As far as using some kind of a starter fuel, I don’t know--I suppose it might if you could get people to do it.

1.7 Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg? Response: I think it would be a good idea. I wouldn’t begin to want to try to develop the test

method for it, but I think it would be a good idea.

1.8 Are the emissions and efficiencies for masonry heaters, based on in-home tests, shown in Tables 1 and 2 reasonable? Response: Well I think so, but again, it’s a pretty small data set.

1.9 The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). — Comments? Response: I agree with you.A-79

1.10Default efficiency values are used for wood stoves. This coupled with the fact that emission factors or rates (not g/MJ) are used to rank wood stoves does not provide an incentive for manufacturers to increase the efficiency of their stoves. — Comments? Should an efficiency test method as described (FR v. 55, n 161, p. 33925, Aug. 20,1990) be required to be used and the results listed? Response: During the wood heater Regulatory Negotiation process, the Committee could not

agree on an efficiency method. When the regulation was promulgated, EPA stated that Appendix J, to be proposed separately, was an optional procedure for determining efficiency. Appendix J was proposed (see question) but never promulgated. I wish that the Agency would go ahead and promulgate the method and also do away with those default efficiencies. If a manufacturer wants to quote an efficiency, then he has to have it tested for efficiency by the proposed Federal Register Method.

1.11 Have certified stove design and performance improved since the first certified stoves? If so, how? Response: Yes, I think that is especially true for the non-catalytic technology. I think that the

Aladdin type design and as it’s been copied and improved on, I think, really made a big improvement on the non-catalytic technology. As far as catalytic technology, I don’t really know; I don’t have much experience. I have the impression that the life of the catalyst is probably improved since the first stoves, because the earlier ones had the other substrate that crumbled, and you know they did away with that. I don’t know about the catalytic stove technology, if that’s changed that much. I don’t think there has been a lot of change in the catalyst wash coat.

2. State-of-the-art of fireplace emission control technology. 2.1 Are the emission factors and efficiencies for the in-home use of fireplaces and inserts shown in Tables 3 and 4 reasonable? Response: Well, that is hard to say because there is so little data. It’s based on field data, but

that’s such a small data base. You really can’t comment on how reasonable it is; there is just so little of it.

2.2 There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. — What designs and technologies are available? What retrofit options are there?A-80

Response: What little bit of testing we did on that Majestic, it seemed to burn quite a bit

cleaner.

2.3 The use of wax fire logs reduces emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even less emissions? Response: That I don’t know.

2.4 What are the distinctions between a masonry fireplace and a masonry heater? Response: I have always thought of a masonry fireplace as being a regular conventional open

fireplace that you burn for the aesthetics, sucks all the heat out of your house. And a masonry heater is one of the European style massive units that stores the heat in the masonry and releases it into the dwelling all day long. I think there is a lot of confusion about those definitions.

2.5 As with wood stoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates. Response: I agree and it would force the fireplace designs toward a more closed unit with

heat recovery.

3. State-of-the-art of wood-fired central heating furnace emission control technology. 3.1 According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified? Response: In some localities I think these furnaces are a problem; I don’t know how many are

commercially available. I think I can name off six or eight companies and each one makes several models, but I don’t know what the total market is, maybe 10,000 - 15,000 a year. The little bit of testing that we did here, says that they are probably on a par with a conventional wood stove. The way those things work, they have a thermostatically operated draft and when the thermostat shuts off the draft closes, so you get this real smoldering burning situation. Secondary combustion technology probably wouldn’t work. Possibly a catalytic technology would, but IA-81 just don’t think it stays hot enough in there. I guess that really depends on the impact.

4. State-of-the-art of pellet-fired wood stove technology

. 4.1 Are the emissions and efficiencies for the in-home use of pellet stoves shown in Tables 1 and 2 reasonable? Response: I assume they are reasonable; I’ve done a variety of stoves in homes but, how

many stoves all together? I don’t know, maybe six, eight. Pretty small data base.

4.2 The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification? Response: Yes, all pellet stoves should be affected facilities and not subjected to that 35:1.

4.3 Have pellet stove design and performance improved since the first models were introduced? If so, how? Response: I don’t know because I haven’t tested any of them, but it’s my impression that they

have become more reliable, more bells and whistles on them, automatic lighting and things like that. The reliability thing has probably gone way up. It’s good technology. If people want to burn wood, I would like to see more of them choose pellet stoves instead of cordwood stoves.

5. Ramifications of ISO. 5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO method 13336 with EPA methods 28, 5G and 5H.) Do you feel that the EPA methods should be replaced with or be made comparable to an international standard? Response: I think ideally the EPA and the ISO should be the same, or be directly correlatable.

But from an economic point of view, I don’t think that it’s reasonable to ask U.S. manufacturers to retest all their stoves because of a change in procedure. And yetA-82 I can see where the international people don’t want to just adopt EPA’s method. It’s not to say that the EPA rule can’t be improved, it certainly can and that’s why we’re doing what we’re doing today. But I don’t think it should be done in a way that the stove manufacturers have to retest or redevelop stoves, or go through the development phase again and all that. Well you know a ten year cycle wouldn’t be a bad way to bring in a new revised procedure; I don’t think that would be too burdensome on the industry.

6. Correspondence between in-home and laboratory emission test results

. 6.1 How accurately do certification tests predict in-home performance? Response: It’s my impression that it’s only in a gross sense, the certified stoves burn cleaner

in homes than conventional stoves. But I’m not sure that if you rank the certified stoves from lowest emission rates to highest, I don’t think that same ranking would come out in in-home tests. But we don’t really have a big enough data base to say that either. You’d have to have 50 homes all burning each stove model, before you get enough statistics to draw a conclusion, because there is so much variation from one home to the next.

6.2 How would you design research testing in the laboratory to simulate in-home use? Response: My only suggestion there is if we could come up with a more typical home use

cycle, then that’s what we should use in research testing and in certification testing. I don’t really know what a more typical home use cycle would be.

7. EPA Method 28 strengths and weaknesses. 7.1 Method 28 is in part an “art”. Fuel loading density, fuel moisture, fuel characteristics (old vs new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have? Response: You know we did so much testing on that one stove here that we just found that it

had enormous effect on emissions, just in what we did in the pre-burn--before we even got to the one hour pre-burn, the regulated one hour. Nobody would run a stove the way we ran it; you wouldn’t do that in your home. To me that’s just not right. I understand that it gives you good numbers and it’s fairly repeatable and all that, but it’s just not realistic.A-83

7.2 Burn rate weighting is based on very limited data and the cities from where the data were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole? Response: I don’t really have any feel on that. Maybe it should be revised, but I don’t know

what data to use to do it.

7.3 The equation for the calculation of the air-to-fuel ratio as in Method 28A is in error. The error produces a small but significant difference in the calculated air-to-fuel ratio. Should the method be corrected or should it be left as a “predictor” of the air-to-fuel ratio? Response: I’m not really familiar with that; I know you talked about it. If it’s an error, I think

it should be fixed. Is it going to make a big difference to the whole certification? I just think that it should be fixed.

7.4 The assumed mole fraction of hydrocarbons (Y HC) is defined as a constant in the air-tofuel ratio calculations in Method 28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbon vapors (more appropriately, organic compound vapors) be measured as part of the method? Response: Again, if it is something in error it should be fixed. Do most labs already measure

hydrocarbons? So you’d be requiring them to buy a total hydrocarbon instrument.

8. EPA Methods 5G and 5H correlations. 8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two methods be reevaluated? Response: Yes, we really need to update that correlation. We generated a lot of data here in

our lab at a very low emission rate, where we measured both 5G and 5H. And we should redo that equation. At higher rates the Federal Register equation for 5G ends up higher then 5H, but the data show that is not true.

8.2 It is the general perception that method 5H produces lower numbers than 5G. Method 5G is less costly and more precise than 5H. — Comments? — Should there be just one sampling method?A-84

Response: Well maybe if the correlation equation was improved or updated then maybe that

perception would go away.

8.3 The same points regarding flow rate calculations (air-to-fuel ratio) and hydrocarbons as made for Method 28A are applicable to Method 5H. — Comments? Response: Whatever we said about Method 28A, I think applies to 5H.

8.4 The precision of EPA’s Method 5 is estimated as being about 20%. Almost one quarter of the 214 stoves listed as certified by the EPA as of 8/12/97 are within 20% of their respective (catalytic or noncatalytic) emission limits. — Comments? Response: I don’t really have a comment on that.

8.5 Based on practical experience with the 5G and 5H, how can they be improved? Response: We did a lot of 5G work here and it seemed that the one variable that we didn’t

have good control on was the filter temperature. Sometimes, depending on the stove and the burn rate and all that, it would get pretty high and sometimes it would be way down below 90°F. You know that’s going to affect how much of the organic condenses. 5H has so many opportunities for error, with tracer gas and all that, it’s much more complicated. I think it would be good to standardize, getting away from having to convert 5G to 5H.

9. Performance deterioration of EPA-certified wood stoves in the field. 9.1 It is the opinion of many in the wood stove industry that catalysts last only five years and that a stove designed for a catalyst operated without a functioning catalyst can produce as much emissions as a conventional stove. — Comments? Response: It’s certainly my observation that catalysts degrade, and in some stoves they

degrade rather quickly and in others they don’t; they degrade slowly. I shouldn’t say just the stove, but in some home/stove combinations. I don’t know how to get at this business with degradation, because it’s almost guaranteed that after a few years the stove isn’t going to be as clean. And it seems that some sort of maintenance procedures need to be mandated. I think everyone knows that any manufactured thing degrades, so maybe it’s something the industry needs to try to advertise and sell. Include something in there about town ordinances. Somehow it seems like this needs to come from the local community level, radioA-85 announcements and things and the industry can play their lobbying role about how important this is and kind of work with the regulators and maybe over time it could become a routine practice.

9.2 Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR and Crested Butte, CO showed that emissions from some catalytic stoves became appreciably worse even after two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been made in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program? Response: Catalysts do degrade. At the time of the sale of the wood stove the homeowner or

purchaser might be made more aware of what is required in the way of annual maintenance, what’s important so the stove would stay burning clean. Maybe include in the purchase price a one year or four year maintenance check, or something like that. Make a big deal out of the maintenance check part. Most people don’t want to even think about it, but it needs to be done.

10. Stress test pros and cons. 10.1 A short-term laboratory woodstove durability testing protocol was developed to predict the long-term durability of stoves under conditions characteristic of in-home use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at veryhigh temperatures over a one to two week period to predict long-term durability under inhome use. Is this a reasonable approach? Response: I always thought that a stress test was a reasonable approach. Maybe the test that

the late Skip Burnett (EPA-600/R-94-193) came up with was a little too vigorous. I would like to see it included somehow. You have to break in the catalyst before you test the catalytic stove. Maybe the break in they have to do is the stress test. But then we’d have to agree on what a stress test is.

10.2Should a stress test be made part of the certification process? Response: I think it should. You could say that the manufacturer has to do this on his own,

but is he really going to do it? The homeowner might not even know that something was wrong. If the catalyst isn’t working, he’s not really going to knowA-86 that unless he sees the smoke coming out of the chimney and realizes or remembers what it was like two years ago.

11. Feasibility of developing separate emission factors for dry and wet wood and for softwood and hardwood species classes. 11.1 Optimum wood moisture for low particulate emissions seems to be in the 18% to 20% range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species? 11.2 Wood from different tree species clearly burns differently. The chemical make-up and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If this is true different parts of the country may have different emissions factors for residential wood combustion. Are you aware of any data that document different emission factors for wood from different tree species? Response to 11.1 & 11.2:I don’t think this really can be done without a tremendous amount of test data.

You can look at existing data statistically and see there is a difference between wet and dry and a difference between oak and pine, but trying to put a number on it would be very difficult.

12. Routine maintenance. 12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than non-catalytic stoves? Would this be relevant for pellet stoves with electronic and moving parts? Response: Yes; I don’t know what routine is, but maybe once a year or every other year.

More relevant for catalytic stoves, but there are parts of non-catalytic that can deteriorate and fail too. Yes, I’m sure it would.

12.2Should the home owner be provided with a maintenance manual or a training course at the time of purchase? Should a maintenance program be part of the purchase price particularly for catalytic stoves? Response: I think they should. I think that should be a more important part of the sale than

maybe it is. That might not be a bad idea, if the dealer just includes it in the cost, but then the customer might ask for the cost without the maintenance program. And then if there is no law saying he has to do it, then the dealer will have toA-87 bargain. 12.3 What would the key elements of routine maintenance be? Response: Clean the stove inside. Inspect and repair any cracks in the metal. Remove and

clean the catalyst following the catalyst manufacturer’s practice. Replace door and window gaskets, if they need to be. Replace the bypass gasket, if there is one. Repair any standard damage to the brick or the firebrick lining. Check the bypass seal and hopefully be able to repair it, but there will be times when you can’t. Straighten and replace warped parts, again, there’re going to be situations where this is just not feasible. Inspect and repair the chimney system. Then run the stove and make sure everything runs right, the catalyst lights up, secondary burn and all those good things.A-88



### Ben Myren - President, Myren Consulting, Inc.

1. State-of-the-art of wood stove combustion and emission control technologies. 1.1 Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable? Response: I think the 18.5 g/kg factor for conventional stoves is low, particularly for the

West Coast stoves that we know so well--probably by a factor of 2 to 3. Question: What about the blend of conventional stoves that are out there right now--noncatalytics? Response: I think some of them have been replaced. One of the things that I ran into when I

was down at DRI this year is that they have an old conventional stove, but it had developed a leak and getting it to burn at extremely low airtight burn rates was virtually impossible. I think there are a number of units that are around doing that; how many and which way that affects the emissions is hard to say. Probably with more air it should tend to burn somewhat cleaner, but I don’t see the basic inventory changing. Question: What about the non-catalytics and catalytics, certified? Response: I think those are reasonable. I think, again, we have limited data. Some other data

are in that range. I’m kind of ambivalent on that one. I think that if there are reasonable numbers to deal with for the whole population of stoves that are out there, I would like to see it redone only with stoves certified to the State of Washington’s 4-1/2gram standard included to see if that makes a difference. I don’t know.

1.2 Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable? Response: I think that those are low. I think that 68%, because of the combustion efficiency

necessary for 4-1/2grams and 1 kg an hour burn rate, I think 70% would be a more real number. Question: OK, what about the catalytics--that was the non-catalytics. What about the

catalytics?A-89

Response: I think that is low as well. I think catalytic stoves, if they are done right, should be

in the high 70's, 77-78%.
Question: What about the conventional; do you think that one’s on the money? Response: I think that one could be all over the map. I think it’s a reasonable number. I

don’t have that much experience with those stoves to really tell you.

1.3 Can catalytic technology for use in wood stoves be fundamentally improved? Response: I believe it can. The problem that I see with catalyst technology is that it doesn’t

have aesthetic qualities that the consumers tend to be looking for. That’s why non-catalytics have sort of garnered the largest share of the market, the major share of the market. And then there is the replacement cost of the catalytic technology. I think the non-catalytic people have oversold that, because what they implied was that if you buy my stove you will never have to do anything to it and it will work forever. The big thing is that you don’t have to replace the catalyst. And I would hope that the catalytic manufacturers, themselves, would be hearing what was said here and say, well we got to make our product better so that the replacement cycle is not as frequent. I don’t know if that’s even possible, but that would be my message to them.

1.4 Is the use of manufactured fuel (densified and wax logs) a credible emission reduction strategy? See Tables 1 & 2 . Response: Yes, what you would get would be EPA appliances. I think that really that issue is

kind of a bogus issue--well it’s not a bogus issue, because that’s the world we live in. But, I think what you are getting out of the wax fuels is a fuel release rate that more closely approaches that and, probably, exceeds it a little bit that of the fuel crib that we are using for EPA testing purposes. We know there are some problems with that, but if you approach that, then you should be clean. Whereas, cordwood tends to run the other way in terms of its air-to-fuel ratio.

1.5 For non-catalytic stoves the heat retention adjustment with refractory material of various densities can reduce particulate emissions. How big an effect can this have? Response: Lots, but it’s stove specific. Not even when you have a stove line, you have mama

bear, papa bear, and baby bear, you can’t make the assumption that by putting a different brick in baby bear it’s going to have the same effect as in mama bear orA-90 papa bear--it doesn’t work that way. There are some advantages to denser bricks. There are some advantages to lighter bricks. It’s the mix you have to deal with, from a design point of view. I used to be a real fan of pumice bricks, but I have used them long term now, and they tend to degrade with time as you scoop the ash out and your banging cordwood in them and stuff. They just kind of tend to disintegrate and go away. I don’t think anyone has ever talked about that. They are replaceable so the question then becomes, how many people actually do it? I don’t know. That would be an interesting study; I think, to do an in-house maintenance check on 100 non-catalytic stoves, generic, and just see how many doors leak, how many baffles are right, etc.--just to see what happens. It would tell you a lot about what’s really going on in the real world. That would be great information to feed back into a design situation, in terms of what’s going on. And, the manufacturers get some of that through their warranty process--I’m sure.

1.6 Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic wood stoves and more than half for catalytic wood stoves. Are there improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions? Response: Definitely. I don’t know if it’s as high as you think it might be. But, I’ve done

some work where I have actually run tests, gases and temperatures, and I measured particulate emissions, using a Condar sampler, from kindling to the first warmup, second warmup, to the third warmup, which was essentially a temperature equilibrium situation at the end of a third warmup. And, this was just using 2 x 4's and watching what happens to emissions--and to no surprise, as the stove got hotter the thermal incineration tended to take over and the emissions went down. I found out that the kindling itself, the way you split it and how you lay it and the size of the kindling pieces themselves can make a huge difference in what happens in terms of emissions. That is something that we need to focus on. I don’t know how we put that out. Perhaps something like a HPA thing where we do an informational video, do it in the lab, and then have people watch it; they could take it home. Make the videos available through HPA and they can use it in their store and they can show people how to build fires.

1.7 Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg? Response: I think that it should be subject to some type of certification, even though they

weigh more then 800 kg. This brings me to the overall question. Eventually, the industry is going to have to come to the realization that we don’t care from EPA’sA-91 perspective. EPA should say, “We don’t care what you build. We don’t care what the burn rates are, as long as they are advertised appropriately. You can’t misrepresent what you have, but build whatever you want as long as it burns clean.” That creates some real opportunities, particularly for the people in the fireplace industry, to get away from this 5 kg/hr product that is a safety nightmare. I don’t think anyone should be exempt, period.

1.8 Are the emissions and efficiencies for masonry heaters, based on in-home tests, shown in Tables 1 and 2 reasonable? Response: I don’t know. I have never done any work in that area.

1.9 The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). — Comments? Response: I agree. The whole process of burning wood is useable heat. At least in my mind

it is. These people that talk about aesthetic burning; that’s fine, but why bother.

1.10Default efficiency values are used for wood stoves. This coupled with the fact that emission factors or rates (not g/MJ) are used to rank wood stoves does not provide an incentive for manufacturers to increase the efficiency of their stoves. — Comments? Should an efficiency test method as described (FR v. 55, n 161, p. 33925, Aug. 20,1990) be required to be used and the results listed? Response: True. Particularly for the 4 1⁄2 g/hr stove population. How can they have increased

the percent combustion efficiency and not the percent overall efficiency? I don’t see how one could happen and not the other, if you know what I’m saying, the inescapable byproduct thereof. I am neutral about the use of an efficiency program.

1.11 Have certified stove design and performance improved since the first certified stoves? If so, how? Response: Yes--and I think emissions have gone down; combustion efficiency and percent

overall efficiency have gone up. And I think the other thing that has happened as a better byproduct of the warranty process is we have learned a lot about how to build stoves that can take care of, or handle, over a relatively long period of time,A-92 the durability thing. We are not there yet but we’ve come a long way. We are still learning as we go along. And that’s true of everybody. It’s true of people who are making plate steel stoves, for people who are making cast iron stoves, and there are a whole range of issues that each has had to deal with. 2. State-of-the-art of fireplace emission control technology. 2.1 Are the emission factors and efficiencies for the in-home use of fireplaces and inserts shown in Tables 3 and 4 reasonable? Response Here again, I think the fireplace emission rate is low. I remember numbers that

were slightly higher than what you guys show. When you show it on a kg/hr burn rate, or g/kg, that’s somewhat deceiving, because if you have a fireplace where your burning 5 kg/hr of wood in the fireplace versus 2 or 3, it really changes the emission rate. And I think that fueling thing with fireplaces is kind of a hard one to grab hold of, because they vary so much in size and everything else. I don’t see any reason to doubt the data, but my gut intuition tells me it’s low.

2.2 There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. — What designs and technologies are available? What retrofit options are there? Response: You bet. I think fireplace needs to be redefined. Looking ahead to where we have

to go as an industry, fireplace is a definite category product. Masonry fireplaces are one thing, zero clearance fireplaces are another. The reason that I say it needs to be redefined is they need to have a very simple definition, so if they ever do set an emissions standard for it at a national level, we know exactly what it is that we’re talking about as far as product. To me fireplaces are units where the burn rate is based upon the fueling rate; there’s no air control in it.

2.3 The use of wax fire logs reduces emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even less emissions? Response: No comment.

2.4 What are the distinctions between a masonry fireplace and a masonry heater? Response: I think the big thing there is the masonry heater has some sort of heat exchange,

physical apparatus built into it, a longer smoke path, etc. Where fireplaces are, generally, up and through the throat and up the chimney and away she goes, withA-93 no thought to heat exchange. There’s probably gray in there somewhere, but very little.

2.5 As with wood stoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates. Response: I agree. To me what they should say is it’s so many g/hr, at such and such an

efficiency, which translates into so many g/MJ, or kW. Pick your number or your unit. I don’t care what it is, but that would give an intelligent consumer the ability to understand all the numbers. Advertise whatever they want, as long as it is true numbers--none of this hokus pokus stuff.

3. State-of-the-art of wood-fired central heating furnace emission control technology. 3.1 According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified? Response: I don’t think they should be exempt for any reason. As to the rest of it--are there

emissions data for them? I suspect there are. Should they be certified? Yes they should be certified. Nobody should be exempt from the process.

4. State-of-the-art of pellet-fired wood stove technology. 4.1 Are the emissions and efficiencies for the in-home use of pellet stoves shown in Tables 1 and 2 reasonable? Response: I think there is a difference for stoves just based upon their air-to-fuel ratio,

whether they are an affected facility, certified product or a non-certified product--I think, breaking it into two groups would provide more accurate numbers.

4.2 The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification?A-94

Response: I agree, no more loop-holes. The new technology stoves that are coming on the

market are going to be totally new critters. I don’t think that turning down the airto-fuel ratio, to make it whatever it is, should get you out of the loop. Some of those suckers have got to be just filthy. I mean you look at the flame. I’ve seen them burn at the trade show; you know, the glass is sooting up on the edges. You can just see it.

4.3 Have pellet stove design and performance improved since the first models were introduced? If so, how? Response: I think technology has improved, is improving and will continue to improve. I

think the efficiency thing drives it, because the cost of pellets is going up, and I think the warranty thing drives it, because nobody wants the headache of a pellet stove that doesn’t work right.

5. Ramifications of ISO. 5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO method 13336 with EPA methods 28, 5G and 5H.) Do you feel that the EPA methods should be replaced with or be made comparable to an international standard? Response: I don’t want to see it go to a calorimeter room. I think that’s a horrendous

mistake, in terms of cost and complexity. Should the EPA methods be replaced by, or made comparable to an international standard? I would hope so. That would give everyone a level playing field on which to compete in different markets. I would not object to that happening. (Additional response submitted 12/01/98): I do want to add some additional comments to my

response to question 5.1 on the ramifications of ISO 13336. When I originally responded, I had read the ISO standard but hadn

### *t worked on any stoves that had passed it. Since then I have had the opportunity to work on three different units from two different manufacturers that had passed the ISO test. None of these units would come close to passing the EPA test without substantial modifications. However, I have been told by manufacturers (clients who have taken EPA certified stoves to Australia to be tested) that the EPA certified stoves have little or no trouble in passing the ISO test. I have also been told that units can be taken to the test lab without any prior R&D testing and made (or helped) to pass the test by varying the air flow through theA-95 calorimeter room. I do not know of one EPA certified unit that made it through testing without substantial R&D testing prior to the trip to the lab for certification testing. The units I worked on all had a forced air (fan driven) secondary air supply. You vary the fan speed with the burn rate setting, i.e., off for low, on high for high. Since there is no Fan Confirmation test, one has no idea if the unit will burn cleanly with the fan off, particularly on high. Furthermore, they are allowed to burn off 20% of the test fuel weight at the start of the test before they shut the unit down to the run setting. This results in minimum burn rates that are in our medium high category, which is much too fast of a “low burn” for a lot of the US market. And the fuel load does not have to be loaded parallel to the longer dimension of the firebox (e.g., if the box is 20” wide and 16” deep, you can load the test fuel parallel to the shorter dimension). This, in my opinion, runs counter to what would happen in the field, because very few people are going to spend the extra time to cut 16” fuel when they can cut 20” fuel and get it in the stove. Thus, the air flow would be wrong. The one thing I do like about the ISO test is that it uses cord wood. However, since the test fuel is hardwood, there would probably be some changes in the combustion air supply ratios, amounts and distribution. Having said all of that, I guess my major comment would be that we need to approach the adoption of the ISO standard very carefully and knowledgeably. It is not necessarily the panacea that we might think. But I do support the idea and effort that there should be one standard emission certification test used world wide. The same is true for overall efficiency.

6. Correspondence between in-home and laboratory emission test results. 6.1 How accurately do certification tests predict in-home performance? Response: I think it’s stove dependent. We always tend to compare in-home performance

with the weighted average, which is really not an apples to apples comparison. We need to compare the in-home burn rate number with a sort of a weighted average or a comparable burn rate, based upon stove emissions in the lab.

6.2 How would you design research testing in the laboratory to simulate in-home use? Response: Eventually we’re going to have to open up the NSPS and deal with some

substantive issues in it. And I think the two big ones that I see right now are: a.)A-96 the fuel crib, and b.) the freely communicated stack in a warm enclosure. Those two are the major ones I think that upset the real world--make what we do in the lab less real world.

7. EPA Method 28 strengths and weaknesses. 7.1 Method 28 is in part an “art”. Fuel loading density, fuel moisture, fuel characteristics (old vs new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have? Response: It’s stove dependent and it’s also burn rate dependent, on that same stove. And it

is an art. It is a black art, unfortunately. I think while we may be able to eliminate some of that, I think the fact that wood is a non-uniform product that you are dealing with, and you have a wide range of variables that you are dealing with, so that that’s always going to be there to some degree. I don’t think you will ever be able to get rid of it. I think you can eliminate some of it, but never totally get rid of it.

7.2 Burn rate weighting is based on very limited data and the cities from where the data were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole? Response: Here, I think some more data would be helpful. I would think that we would need

to be population weighted. By that I mean, if you base everything upon Montana and North Dakota, where nobody lives, versus the I-5 corridor, where a lot of people live, I think you would be producing stoves that would be great for 1% of the population and not so good for the rest of the world. I think you need to look where the people live. Not only does it need to be a heat demand thing, but it needs to be population density weighted too. The East Coast is much more populated then the West, particularly the Great Plains, Northern Mid-West versus the Southern States. It needs to be looked at, but it needs to be addressed intelligently. That would be the only way to do it. That would just take some design work up front, and then you could do it. A lot of that information, I’m sure, is available. To me this is a number crunching exercise. You’ve got a lot of information and you put it into the computer and you come up with whatever it is you are looking for. The input will, of course, determine the output.

7.3 The equation for the calculation of the air-to-fuel ratio as in Method 28A is in error.A-97

The error produces a small but significant difference in the calculated air-to-fuel ratio. Should the method be corrected or should it be left as a “predictor” of the air-to-fuel ratio? Response: That should be corrected. Nothing should be left uncorrected. If you know

something is wrong, then it should be fixed. To me that is a given in life.

7.4 The assumed mole fraction of hydrocarbons (Y HC) is defined as a constant in the air-tofuel ratio calculations in Method 28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbon vapors (more appropriately, organic compound vapors) be measured as part of the method? Response: Yes, yes. I don’t know where EPA came up with the numbering in the first place,

but I don’t think it would be that difficult to do some work on some 4.5 gram stoves and figure out what the correct HC mole faction of EPA stoves really is. Do the same for the 7 1⁄2 gram stoves and then use it accordingly, and I think you’re going to find it’s going to be burn rate specific. If you are under 1 kg/hr you’re going to have this, at 1.25 to 1.9 you are going to have that. I don’t think there is a number that you could apply as an average to each burn rate, because the HC fraction is dependent upon the emission rate. Just look at emissions and M5H back half catches. I think that it’s that burn rate and emission specific. I suppose we could use FID’s, but that would be tough--I would not want to do it.

8. EPA Methods 5G and 5H correlations. 8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two methods be reevaluated? Response: Yes.

8.2 It is the general perception that method 5H produces lower numbers than 5G. Method 5G is less costly and more precise than 5H. — Comments? — Should there be just one sampling method? Response: Yes, that would be fine if it was excepted internationally. I think we have to talk

about the room setup and all of that, the full picture of what we’re proposing to do before we decide upon what to do. I think one of the things about 5H, it’s a tougher method to run. We know there’s an error in the hydrocarbon thing, if that were corrected the error might go away. That might take care of itself, becauseA-98 from a laboratory point of view, everyone would automatically go to 5G. But, 5H is more appropriate for other reasons.

8.3 The same points regarding flow rate calculations (air-to-fuel ratio) and hydrocarbons as made for Method 28A are applicable to Method 5H. — Comments? Response: It should be corrected

8.4 The precision of EPA’s Method 5 is estimated as being about 20%. Almost one quarter of the 214 stoves listed as certified by the EPA as of 8/12/97 are within 20% of their respective (catalytic or non-catalytic) emission limits. — Comments? Response: How many of those stoves that are within 20% are product lines that are still being

made? A lot of people have products on the list, but they aren’t making them anymore.

8.5 Based on practical experience with the 5G and 5H, how can they be improved? Response: There’s a ton of stuff that could be done there. EPA, they could take anything and

make it hard to do. How, what and why they do that is beyond me, but some of the stuff that they require, calibration and documentation, are utterly and totally nonsense. That’s the kind of requirements that should be ejected. Focus on what really counts.

9. Performance deterioration of EPA-certified wood stoves in the field. 9.1 It is the opinion of many in the wood stove industry that catalysts last only five years and that a stove designed for a catalyst operated without a functioning catalyst can produce as much emissions as a conventional stove. — Comments? Response: I think that’s true. Since most catalytic stoves were designed to be “creosote ”

cookers, which was what the old conventional air tight stove was. I would say they are probably just as bad when the catalytic combustor doesn’t work.

9.2 Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR and Crested Butte, CO showed that emissions from some catalytic stoves became appreciably worse even after two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been madeA-99

in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program? Response: I would say there were designs available that did not seem to have a problem and

those designs still around today. I think the same is true for non-catalytics. I don’t see any reason to exempt non-catalytics from inspection and maintenance, or make it any less rigorous for them. You just have to look at different things. Baffle warping, leaking air wash. The air wash gap is critical. Anything that moves through the use of improper steel or welding or whatever. All bets are off, emissions wise and I’ve been through that personally. Question: Let’s see; is it reasonable to require homeowner training? Response: I don’t see any reason why that shouldn’t happen. I guess my question would be

to the dealers, I hope they are doing it. When you are selling stoves to some place like Home Depot and you get a sales guy back there who knows anything about a wood stove, you’re lucky. I don’t know how to go about reaching those people who, other than, it’s part of their operating permit they have to go to a two hour night class where people talk to them about how to run a stove properly. If the dealer could do it through the inspection and maintenance program, so much the better. We should try to keep the government out, if we can, and have the industry guys do it. Question: What about incorporating the costs of an inspection and catalyst replacement

program? Response: I don’t have a problem with that. I would think that could be left to the local

people. I wouldn’t have a problem with it as long as it was across the board, played off fairly. I think that people should try it — fiddling around with that and see what happens from an airshed to airshed point of view, in terms of improvement and find out what works. I think that is one distinct possibility.

10. Stress test pros and cons. 10.1 A short-term laboratory woodstove durability testing protocol was developed to predict the long-term durability of stoves under conditions characteristic of in-home use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at veryhigh temperatures over a one to two week period to predict long-term durability under inhome use. Is this a reasonable approach?A-100

Response: I think there are two kinds of stress. I want to call them acute and chronic. What

acute is is what you’d get with what the late Skip Burnett (EPA-600/R-94-193) did. Chronic is more what happens to a stove, due to a large number of cycles of warming up and cooling off, warming up, cooling off that happens during normal operation. I think you’ll get some of the chronic effects with an acute kind of a test, but I think it maybe overkill in some instances and it may not even come close to documenting what really happens in the real world. How you’d balance that out is tough. When we have stoves come through our lab, if we see anything that might be a potential durability problem for that particular stove and that manufacturer, we start talking to them about it right up front right then. In the way we run our R and D program with my clients, is that hopefully, by the time we are through developing a stove, that stove has been cycled enough times that if there is something blatantly obvious that would show up, like in the kind of work that Skip Burnett was doing, we’ve kind of gotten through that. What we do everyday is we run the stove up to, basically, maximum heat storage and then we start our test from that. We’ve got a warmup period that is anywhere from 3 to 4 hours a day that’s wide open. Then we shut down and cool it off. Well, if you cycle a stove like that (to do an R&D project on a wood stove is probably a minimum of 90 days, more like 6 months, if you want to know the truth), you’ve really put that stove through its hoops. So to make a stress test part of the certification process, you’d have to convince me that that kind of a development process was not sorting things out, as far as durability is concerned. We know for a fact that one thing or another, can or cannot happen, and once the manufacturers are well aware of those issues and they don’t want to get into a certification series and suddenly find that their air wash gap has changed because of one thing or another, or so it goes. In some ways I would like to see some good 4.5 gram stoves, non-catalytic stoves be put into the field and monitored in the same way that the early stove studies where done. And do it for a number of years.

10.2Should a stress test be made part of the certification process? Response: Only if you could demonstrate through the field studies that we haven’t got our

basics covered. If you took some brand new stoves out into the field that were current products, 4.5 grams or better, and looked at what they did. Cast iron stoves should be included in that field study to see if they, because of the nature of cast, do better or worse. My gut reaction is they should do better.A-101

11. Feasibility of developing separate emission factors for dry and wet wood and for softwood and hardwood species classes. 11.1 Optimum wood moisture for low particulate emissions seems to be in the 18% to 20% range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species? Response: Given the EPA thing, when most of our fuel loads are somewhere between 17 and

18%, that’s just where we tend to be. Can it be isolated from other variables? That be a tough one. I think you could do it, but it would take repeated tests, because I don’t know how you would dial out barometric pressure. And we all know that can have a tremendous impact. Could it be different for wood from different species? You bet it would. Pine has a totally different emission profile than fir, larch or oak. Having said that, how do we deal with it? I haven’t got an answer for that.

11.2 Wood from different tree species clearly burns differently. The chemical make-up and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If this is true different parts of the country may have different emissions factors for residential wood combustion. Are you aware of any data that document different emission factors for wood from different tree species?
Response: Yes, I don’t know of any data, other then some work that EPA’s Robert C.

McCrillis did, that would document emission factors from different tree species.

12. Routine maintenance. 12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than non-catalytic stoves? Would this be relevant for pellet stoves with electronic and moving parts? Response: I think it would and I don’t think it’s more relevant for either stove type; I think

it’s across the board. Catalysts probably have the most potential for having emissions sky rocket particularly, if the catalyst doesn’t work; non-catalyst stoves,if something happens if the door leaks. If you upset the airflow inside a noncatalytic stove by very much, things go downhill very quickly. I think pellet stoves should be kicked in there too.A-102

12.2Should the home owner be provided with a maintenance manual or a training course at the time of purchase? Should a maintenance program be part of the purchase price particularly for catalytic stoves? Response: Yes, I think here the stove stores should really, as part of the sale for sure, you

take them over and say hey got a few things that I’d like to show you about how to make this stove really work. It’s part of the sales pitch. I think it needs to be done, I’d like to see the local stove shops do it. If they give tickets out for smoky stoves that might be part of the penalty to get your ticket fixed you have to have someone come out and go through your stove to make sure something isn’t wrong with it and be told and shown how to run it properly.

12.3 What would the key elements of routine maintenance be? Response: Bypass gap, outside air kits installed properly, air wash gap, window glass seal, ash

door seal, secondary combustion stoves that have tubes (or any other way of doing it), secondary system mounting system is intact, good baffle, no warpage, insulation, no wear, bricks are all there, baffle is not scaled. The list goes on & on. As for the rest of the testing issue, I see the need to do a high, low and perhaps a mid range run on each stove being tested. Problems always seem to occur at the margins, rather than in the middle. At the same time, I would eliminate all reciprocal certifications and the fan confirmation test. If a stove has a fan as an option, then you would do a high & low with the fan on and with the fan off. A fireplace insert would be treated the same way as would the change from a leg to a pedestal model.A-103



### Michael Van Buren - Technical Director, Hearth Products Association

1. State-of-the-art of wood stove combustion and emission control technologies. 1.1 Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable? Response: There are differences in catalytic and non-catalytic stoves. The conventional stove

is probably low; the pounds per gram or pounds per ton were probably a lot higher then that. You can see dramatic reductions using densified logs in EPA certified appliances in the field.

1.2 Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable? Response: I think that there is a variation from stove to stove. That is a hard number to give,

since there hasn’t been a lot of efficiency testing. What would you put down here for a conventional fireplace? I think what we will see in the future is more outdoor air being used and less indoor air, and how that would affect the efficiency of the product.

1.3 Can catalytic technology for use in wood stoves be fundamentally improved? Response: I would imagine that there are a lot of things that can be done, but a lot of those

things fall outside the realm of the EPA standards (i.e., natural and propane gas secondary combustion). The increased use of electronic control and larger catalysts could help, but all of these would also impact the cost of the stove.

1.4 Is the use of manufactured fuel (densified and wax logs) a credible emission reduction strategy? See Tables 1 & 2 . Response: I think it is especially for the fireplaces. I think that it is something that has been

overlooked in a lot of areas, particularly Phoenix. I don’t think it was looked at as an option, or it wasn’t conveyed as clearly as it could have been. More testing needs to be done to prove this.

1.5 For non-catalytic stoves the heat retention adjustment with refractory material of variousA-104

densities can reduce particulate emissions. How big an effect can this have? Response: It does make a difference. How much of a difference, as far as better emission

values, varies from stove to stove. I have limited experience with this at Hearthstone, we did do some work on a side loading door. Small modifications to a stove can have a major effect on emissions. Modifying the geometry of the stove, such as changes in the baffle or the baffle angle, can make a difference in emissions. Just changing the baffle insulation can affect emissions.

1.6 Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic wood stoves and more than half for catalytic wood stoves. Are there improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions? Response: I’m sure using some type of fire starter would reduce emissions. Anything that

touches off at a lower temperature is going to help. I think the two things that we run up against there is that’s basically a usage strategy of the homeowner, and how do you control that? From a regulatory viewpoint, is using a wax fire starter considered a dual fuel action? It’s a petroleum base product. Would EPA accept that under the present regulations? If they accept that, what other dual fuel options would they accept? And then whenever we start talking about electronic controls, we have to think about the actual market environment out there and purchasing stoves and what it does to the price of the stove.

1.7 Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg? Response: I don’t think they should be classified as wood stoves, because of their usage. I

think they could be potentially tested to some certification. The other thing is to look at how many of them are being sold and is it worth it? The answer may be no, because it’s not a large volume product. I think there needs to be some proof of those usage patterns.

1.8 Are the emissions and efficiencies for masonry heaters, based on in-home tests, shown in Tables 1 and 2 reasonable? Response: No comment.A-105

1.9 The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). — Comments? Response: You are now rating efficiencies and emissions. The question then becomes: should

there be some type of control on a woodstove that’s sensitive to room temperature? More work needs to be done on efficiency testing of wood burning appliances.

1.10Default efficiency values are used for wood stoves. This coupled with the fact that emission factors or rates (not g/MJ) are used to rank wood stoves does not provide an incentive for manufacturers to increase the efficiency of their stoves. — Comments? Should an efficiency test method as described (FR v. 55, n 161, p. 33925, Aug. 20,1990) be required to be used and the results listed? Response: Manufacturers have an incentive to build stoves that have good combustion

efficiency through the EPA emission standard. Lowering emissions requires raising the combustion efficiency. Thermal (sometimes referred to as heat transfer) efficiency should go hand-in-hand with combustion efficiency. An accurate method for measuring overall efficiency (combustion x thermal) needs to be developed before implementing an efficiency standard.

1.11 Have certified stove design and performance improved since the first certified stoves? If so, how? Response: Without a doubt, the certified stoves have improved dramatically. All you have to

do is look at the emissions that are coming out of the stove now. Almost all the stoves on the market meet the Washington standard versus the EPA standard, as far as I know. And I think the durability of the stoves has improved. The warranty times are longer. It used to be a one year warranty on products, now it’s three or five years, and that is a very good example of how they have improved.

2. State-of-the-art of fireplace emission control technology. 2.1 Are the emission factors and efficiencies for the in-home use of fireplaces and inserts shown in Tables 3 and 4 reasonable? Response: No comment.A-106

2.2 There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. — What designs and technologies are available? What retrofit options are there? Response: I think this comes down to a financial issue and what the market will pay for, but I

have seen electric afterburners that can go on fireplaces to lower emissions. I’ve seen designs that lower emissions, some type of secondary combustion through the same method as is used in non-catalytic stoves. I think there are plenty of things that can be done to lower emissions, secondary air in stoves; glass doors certainly help. It’s just a matter of what is financially feasible on the market.

2.3 The use of wax fire logs reduces emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even less emissions? Response: I understand that wood wax logs produce less emissions than cordwood. I am not

sure what can be done to further reduce emissions from today’s wood wax logs. The other thing to mention here is that the material used to manufacture all-wood logs is generally cleaner than ordinary cordwood, so it burns cleaner and that can lower emissions.

2.4 What are the distinctions between a masonry fireplace and a masonry heater? Response: Masonry heaters have a method of storing heat. They have longer passages.

Some have downflow in them to give the flue gas a longer path before it actually exits, so you have a mass inside the home that can be heated. A masonry fireplace does not have these features.

2.5 As with wood stoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates. Response: Given the study that was mentioned, 7% of the fireplaces are used as a primary

source of heat in a limited area, I don’t know if g/MJ is a reasonable way of measuring the emissions. I think maybe g/kg is a better way of doing it for a fireplace, because the usage is completely different than a wood stove. I think there is a distinct difference between fireplaces and wood stoves and their reasons for being used. I think their testing methods should be completely different. They are not used probably 99% of the time as a source of heat; they are used for aesthetic purposes. And therefore they should be tested accordingly, in g/kg.A-107

3. State-of-the-art of wood-fired central heating furnace emission control technology. 3.1 According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified? Response: I think there are a lot of products that fall into that category, including probably

masonry heaters. How many are being used, and is it worth regulating a small number across the country? I think there is good reason to have some testing. I don’t think they should fall under the same test standard as a wood stove, because the way they operate and the way they are used are completely different. I think there are under 10 different manufacturers and there are probably less then that, and they probably have one or two models each being a different size. There is one pellet burner; that’s all I know of at this point. I think there should be some type of testing on them.

4. State-of-the-art of pellet-fired wood stove technology. 4.1 Are the emissions and efficiencies for the in-home use of pellet stoves shown in Tables 1 and 2 reasonable? Response: I’d say they are probably pretty reasonable, as an average. I think the question

that comes up is, what stoves are above 35:1 air-to-fuel ratio? What do they emit versus a cleaner one? 4.2 The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification? Response: I don’t know what that loop-hole does, whether it really affects the operation of

the stove and the efficiency of the stove.

4.3 Have pellet stove design and performance improved since the first models were introduced? If so, how? Response: Absolutely. I think some of the stoves on the market have improved dramatically,

since the first stoves. Just in reliability, pellet stoves are much more reliable todayA-108 compared to 10 years ago. The basic materials used, the equipment used within the stoves have improved. Some now use microprocessors to control them.

5. Ramifications of ISO. 5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO method 13336 with EPA methods 28, 5G and 5H.) Do you feel that the EPA methods should be replaced with or be made comparable to an international standard? Response: I don’t feel that the EPA method should be replaced with the ISO standard. I do,

however, feel that the United States has to become involved in that ISO standard, if it starts to gain any strength. But I don’t see the ISO standard having any effect on us at the present time. I don’t think it’s refined enough. If we get involved, then we could help shape it. If we wait, what’s going to happen is we’re going to get something imposed on us by the ISO that we don’t like, and I think that is a bad alternative.

6. Correspondence between in-home and laboratory emission test results. 6.1 How accurately do certification tests predict in-home performance? Response: I have not seen any information that shows anything between the two, so I can

only speculate. I hope there is some correlation between a clean burning stove in the lab and a cleaner burning stove in the field. Are the numbers going to be close to the same? Absolutely not. There should be no assumption along those lines. But is the cleanest burning tested stove going to be the cleanest burning stove in the field?

6.2 How would you design research testing in the laboratory to simulate in-home use? Response: I would get away from using dimensional lumber. I would try to use more of a

cord wood and I would give more flexibility as to how the operator can work with the stove.

7. EPA Method 28 strengths and weaknesses. 7.1 Method 28 is in part an “art”. Fuel loading density, fuel moisture, fuel characteristicsA-109

(old vs new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have? Response: There are a lot of things that affect emissions. And the first thing we come to is

the low burn rate, and getting the stove to start up quickly, get flaming quickly and then once you get it burning that it doesn’t burn too fast. Moisture content has a big effect, picking the wood, where you put it. It is an “art”, and lots of different people will give you lots of different answers.

7.2 Burn rate weighting is based on very limited data and the cities from where the data were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole? Response: I think that the weighting just continues the art of having the stove pass. Where

your burn rates come in and do you make another run to try to get rid of that burn rate and what’s the weighting factor, is what makes it more of an art than a science.

7.3 The equation for the calculation of the air-to-fuel ratio as in Method 28A is in error. The error produces a small but significant difference in the calculated air-to-fuel ratio. Should the method be corrected or should it be left as a “predictor” of the air-to-fuel ratio? Response: No comment.

7.4 The assumed mole fraction of hydrocarbons (Y HC) is defined as a constant in the air-tofuel ratio calculations in Method 28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbon vapors (more appropriately, organic compound vapors) be measured as part of the method? Response: No comment.

8. EPA Methods 5G and 5H correlations. 8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two methods be reevaluated?A-110

Response: You can’t look at just 5H and 5G; you have to look at its entirety. Should you

really have two methods?

8.2 It is the general perception that method 5H produces lower numbers than 5G. Method 5G is less costly and more precise than 5H. — Comments? — Should there be just one sampling method? Response: Having a single method makes sense.

8.3 The same points regarding flow rate calculations (air-to-fuel ratio) and hydrocarbons as made for Method 28A are applicable to Method 5H. — Comments? Response: No comment.

8.4 The precision of EPA’s Method 5 is estimated as being about 20%. Almost one quarter of the 214 stoves listed as certified by the EPA as of 8/12/97 are within 20% of their respective (catalytic or noncatalytic) emission limits. — Comments? Response: I have looked at the list of 214 stoves and a lot of those stoves I did not recognize,

and I don’t know how many of those are still on the market. What are the factors that EPA built into the original test method to take that 20% into account?

8.5 Based on practical experience with the 5G and 5H, how can they be improved? Response: Any way of taking it out of an art in order to make it a science would help.

9. Performance deterioration of EPA-certified wood stoves in the field. 9.1 It is the opinion of many in the wood stove industry that catalysts last only five years and that a stove designed for a catalyst operated without a functioning catalyst can produce as much emissions as a conventional stove. — Comments? Response: Catalytic stoves need regular maintenance; are the operators keeping track of how

the catalytic is performing and are they checking the stove properly?

9.2 Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR and Crested Butte, CO showed that emissions from some catalytic stoves became appreciably worse evenA-111

after two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been made in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program? Response: Stoves have become more user friendly; they are easier to use. They are now

vertical instead of horizontal, so the ashes fall out. It is unreasonable to require training. There should be instructions, but not attached to the stove.

10. Stress test pros and cons. 10.1 A short-term laboratory woodstove durability testing protocol was developed to predict the long-term durability of stoves under conditions characteristic of in-home use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at veryhigh temperatures over a one to two week period to predict long-term durability under inhome use. Is this a reasonable approach? Response: No.

10.2Should a stress test be made part of the certification process? Response: No.

11. Feasibility of developing separate emission factors for dry and wet wood and for softwood and hardwood species classes

. 11.1 Optimum wood moisture for low particulate emissions seems to be in the 18% to 20% range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species? Response: ISO doesn’t take into effect the species of the tree. I don’t know

11.2 Wood from different tree species clearly burns differently. The chemical make-up and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If thisA-112

is true different parts of the country may have different emissions factors for residential wood combustion. Are you aware of any data that document different emission factors for wood from different tree species? Response: I don’t know of any data available.

12. Routine maintenance. 12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than non-catalytic stoves? Would this be relevant for pellet stoves with electronic and moving parts? Response: Regular maintenance should be done, especially when there are moving parts.

12.2Should the home owner be provided with a maintenance manual or a training course at the time of purchase? Should a maintenance program be part of the purchase price particularly for catalytic stoves? Response: An owner’s manual should be provided. No training should be required unless this

same training was also required for gas and oil products, such as water heaters, furnaces, boilers. Everything needs regular maintenance.

12.3 What would the key elements of routine maintenance be? Response: It should be looked at once a year to see if cleaning or maintenance needs to be

done. The flue should also be cleaned.A-113

Other unsolicited comments not in response to prepared questions:

1.) People [government regulators] who review the reports should be able to qualitatively assess them: does this make sense? 2.) They need to enforce the regulation to ensure that all players continue to abide by the rules. 3.) They need to welcome new technology and be willing to allow for changes in the methods as long as the results show that the product burns cleanly. Forcing everybody into the square or rectangular firebox fuel load configuration may eliminate some very viable technologies. In short, the NSPS should be technology enhancing rather than technology limiting. Right now EPA is preventing some very viable technologies from being developed.C-iii Appendix C Solid Fuel Committee of the Hearth Products Association (HPA) Comments on Review Topics Table of Contents Page Attendees to the HPA Solid Fuel Technical Committee Meeting

......................C-1 Summary of Committee Comments

............................................C-2C-1 

### Attendees to Solid Fuel Technical Committee Meeting
1.Dan Henry, Vice President, Aladdin Steel Products 2.Bill Sendelback, President & CEO, Breckwell 3.David Johnson, DSJ Technical Services 4.Prasad Deshmukh, Electronic Engineer, Duraflame 5.Thao Huynh, Chemist One, Duraflame
6.Paul Lynch, New Business Dev. Manager, Duraflame 7.Lohit Tutupalli, Research Scientist, Duraflame

•Dennis Jaasma, President, EECI

•Jim Kovacs, Mgr. Engineering R & D, FPI

•Ken Maitland, Director of Engineering, FMI

•Walter Moberg, President, Firespaces

•John Crouch, Director of Government Relations, HPA

•Michael Van Buren, Technical Director, HPA

•Denny Kingery, Product Engineer, Heatilator

•Wayne Terpstra, Vice President of Technical Services, Heatilator

•Rick Curkeet, Chief Engineer, Intertek Testing Services

•Ben Myren, President, Myren Consulting

•James E. Houck, Vice President, OMNI

•David McClure, Vice President, OMNI

•Paul Tiegs, President, OMNI

•John Francisty, R &D Manager, Pacific Energy

•Jerry Whitfield, President, Pyro Industries

•Eric Dufour, Director of R & D, Security Chimneys

•Tim French, Mgr. of Eng. Wood Products & Drafting, Superior Fireplace

•Steven Plass, Product Manager, Superior Fireplace

•Erkki Jarvinen, Technical Director, Tulikivi

•Bill Bradberry, President of Sales, Vestal Mfg.C-2 Hearth Products Association Solid Fuel Technical Committee Meeting

Friday January 9, 1998 Review of questions from OMNI Laboratories Residential Wood Combustion Technology Review EPA Purchase Order no. 7C-R285-NASX 1. State-of-the-art of woodstove combustion and emission control technologies. 1. l Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable? Dr. Houck explained that the values in Table 1 are from in-situ studies, they are not laboratory test results. Dr. Houck reviewed data taken from the mid 1980's through 1996. Dr. Houck explained that some of these numbers are best guess. The greatest uncertainty is with the conventional stoves - this data is optimistic. Rick Curkeet thought the emissions for conventional stoves are actually much worse. There was a question of how many of the convention stoves used in-situ had been developed to meet the Oregon standard. This would imply that the conventional stoves used for in-situ studies had improved emissions compared to those stoves that did not meet the Oregon standard.

The EPA data is based on 30 conventional stoves. A vote was taken in the room as to whether 18.5 g/kg was too low, the consensus was that it was too low. Rick Curkeet suggested that a range of 20-200 g/kg be used. Everyone agreed. Dr. Houck told the group that EPA wanted a specific number. All attendees agreed that there was not just one specific number. The comparison was made of fuel economy with different vehicles. It would depend on the vehicle and how it was driven. Dan Henry mentioned that he had seen some EPA approved appliances tested with densified fuels that had very low emissions, below 1 g/hr and that should be reflected in this table. 1.2 Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable? Rick Curkeet stated that the efficiencies of conventional stoves range from 20 to 50% efficient. The efficiencies for non-catalytic stoves go by EPA default efficiencies, which takes away the motivation to improve the efficiencies of non-catalytic stoves. There are two different types of non-catalytics, those that pass Washington State standards and those that do not. Conventional, catalytic and non-catalytic stoves go by default numbers for efficiencies, whereasC-3

pellet, masonry and densified fuel are calculated. 68% efficiency is more accurate than 63% for non-catalytic stoves. The default efficiency for pellet stoves is 78%. The group agreed that single numbers are misleading; a range of efficiencies should be used for each type of stove. Erkki, from Tulikivi questioned the efficiencies of the masonry heaters; use patterns have to be considered. There were concems on the efficiencies given to conventional stoves however, it is difficult to prove or disprove this number without additional in-situ data. 1.3 Can catalyst technology for use in woodstoves be fundamentally improved? Yes, microprocessors could be added to stoves to monitor and control the stove, preheating of the catalyst could be done with propane or electric resistance heat. However, EPA's current standards are design restrictive and do not allow these types of improvements. In addition, catalytic stoves have lost their market share over the last four years, in part due to their initial cost. Any modification to the stove that would drive up the cost of the stoves would probably end sales of these stoves altogether. 1.4 Is the use of manufactured fuel (densified and wax logs) a credible emission reduction strategy? See Tables 1 & 2. The committee does not look at this as an emission reduction strategy, but rather as a technological possibility. Yes, manufactured logs are an option for cleaning up woodstove emissions, both conventional and EPA approved. Whether or not they are a credible strategy would depend on the EPA State Implementation Plan. 1.5 For non-catalytic stoves the heat retention adjustment with refractory material of various densities can reduce particulate emissions. How big an effect can this have? Refractory materials and the type chosen can make a difference with light off in the first five minutes of a test burn. This can make the difference between a 5g/hr run and a 25g/hr run. This is fundamental, but very stove specific. There are other design characteristics that also make just as much of a difference. These types of "tricks" to make a stove perform better in an EPA emissions test may or may not make a difference on how stoves perform in the field. No one at the meeting had seen conclusive data to prove or disprove this correlation. There was general agreement that for some stoves, this can have a very large effect, both in the lab and in the field. 1.6 Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic woodstoves and more than half for catalytic woodstoves. Are there improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions?C-4

Dan Henry told the group how EPA and Aladdin Steel were working on a system with very stable secondary combustion. The system used a gas pilot light. Dan wanted to certify the stove using the pilot light. At first EPA approved this and later revoked it stating the appliance had to be tested without the pilot light running because this would be considered a dual fuel. The system was considered dual fuel and therefore could not be certified. An in-situ study was done in Spokane and Dennis Jaasma was going to perform an in-situ study in Virginia prior to EPA revoking this concept. There have been similar other products. Ben Myren told of a product that used an electric combustion enhancement and emissions reduction technology that also was rejected by EPA. High Btu wax logs can be used to achieve a fast start and therefore lower emissions of woodstoves, however EPA would probably consider this a dual fuel system. 1.7 Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg? Walter Moberg stated there are advantages for masonry heaters to be listed and tested to EPA standards, however the industry suffers because there is no fair way to do this at the present time under the existing standard. Erkki stated that those masonry heaters that are not built on site should have some type of certification, but masonry heaters should not be tested the same way a woodstove is tested. There was agreement that masonry heaters need to be certified, but not as woodstoves, but rather to their own masonry heater standard. 1.8 Are the emissions and efficiencies for masonry heaters, based on in- home tests, shown in Tables 1 and 2 reasonable? The thought was these numbers given are generally fair values, although efficiencies are difficult to measure. 1.9 The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). Comments? Dan Henry brought up the point that to go from g/hr to g/kg would mean re-educating the public and the state and local regulators. Historically, the industry initially wanted g/kg but the environmental community wanted g/hr. Neither g/hr nor g/kg motivates manufacturers to increase efficiencies. 1.10 Default efficiency values are used for woodstoves. This, coupled with the fact that emission factors or rates (not g/MJ) are used to rank woodstoves, does not provide an incentive for manufacturers to increase the efficiency of their stoves. -Comments? ShouldC-5

the efficiency test method as described (FR v. 55, n 1611 p. 33925, Aug. 20,1990) be required to be used and the results listed? Rick Curkeet commented that almost all EPA approved stoves have higher efficiencies than the EPA default efficiency. Grams/hr and efficiency are two separate parts of the equation. If woodstove manufacturers also were required to test for efficiency, this would drive up the cost of testing stoves. Grams/MJ vs. g/hr - g/hr makes an appliance that stores heat (such as a masonry heater) look bad. Another thing to consider is that g/MJ should take into account transmission losses, for instance, if the unit is outside the house. Jerry Whitfield stated that if you were to go to a g/MJ measurement, there would be more regulation, due to the fact that g/MJ is very difficult to define. 1.11 Have certified stove design and performance improved since the first certified stoves? If so, how? Yes - John Francisty pointed out that the stoves today are more durable, and more user friendly. Proof of this is the longer warranty periods on the stoves today. Manufacturers are more confident in the durability of their stoves. 2. State-of-the-art of fireplace emission control technology. 2.1 Are the emission factors and efficiencies for the in-home use of fireplaces and inserts shown in Tables 3 and 4 reasonable? EPA standards all look at emissions on a mass per mass source basis. Use patterns are critical and the purpose for an appliance is also critical. Are you talking about a heater such as a stove or a fireplace that is used for aesthetics? Grams/MJ should not be used to measure emissions from a fireplace. The problem is what do you do about the products in between a heater and a fireplace such as masonry heaters? There may in fact need to be three different test methods. Grams/kg may be the best way to test an appliance, but regulators wanted g/hr because they wanted emissions based on time. The thought of the group was that no-burn-days covers incidents such as the example given of fireplaces being used at Christmas time. Dr. Houck mentioned that 28% of cordwood is burned in fireplaces and 7% of those are used as a primary source of heat according to studies in the Southeastern U.S. It was also mentioned when looking at fireplaces, glass doors can make a difference in efficiencyC-6

of 30-40%. 2.2 There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. - What designs and technologies are available? What retrofit options are there? Walter Moberg mentioned that there have got to be options that have not been explored. Fireplaces are significantly under developed from an emissions standpoint. Glass doors in themselves can lower emissions. 2.3 The use of wax fire logs reduces emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even fewer emissions? Duraflame log representatives informed the committee that there are ways of lowering emissions from wood/wax logs that are being explored by some manufacturers. 2.4 What are the distinctions between a masonry fireplace and a masonry heater? The big differences between fireplaces and heaters are the hearth opening size, heating ability and efficiency. Masonry heaters have smaller openings, more heating ability, and higher efficiencies, but it is a matter of drawing a line in efficiencies to separate the two. Colorado has a masonry heater standard. 2.5 As with woodstoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates. See question 1.10 3. State-of-the-art of wood-fired central heating furnace emission control technology. 3.1 According to a Department of Energy survey, out ofthe 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified? Rick Curkeet pointed out that the lack of EPA regulations on wood fired central boilers has killed R&D on central heating furnaces. Outdoor furnaces could potentially give the wood burning industry a black eye. It is however a viable technology and is used in Europe. More automation could be developed. There is a need for a separate central furnace standard as opposed to a modified woodstoveC-7

standard. The Canadian standard CSA B415 committee started a furnace standard but sales of the product did not warrant it, so it was never finished. CanMet did some work on this. CSA B415 is a consensus standard, which allows for modifications, unlike the EPA standard, which has no method of modification or industry participation once it is set up. 4. State-of-the-art of Pellet-fired woodstove technology. 4.1 Are the emissions and efficiencies for the in-home use ofpellet stoves shown in Tables 1 and 2 reasonable'? Table 1 information comes from Klamath Falls and Medford, as well as estimates by OMNI staff. Jerry Whitfield stated that comparing particulate from cordwood and pellet stoves is apples and oranges. From pellet stoves, larger particles are being captured instead of smaller ones that are more of a health risk. There are no data that show this at the present time. Pellet burning in the field is more controllable and definable. For this reason pellet stoves should not be tested by the same method as a cordwood stove. 4.2 The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves - those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loophole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification? Jerry Whitfield stated that it is not necessarily true that "The latter class may have models that are less efficient and have higher emissions than the former". Dan Henry stated that it is very difficult to meet or exceed the 35:1 ratio. 4.3 Have pellet stove design and performance improved since the first models were introduced? If so, how? Yes, they have improved, but we are on the brink of a third generation of stoves that could be just as clean as gas or oil. 5. Ramifications of ISO. 5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO Method 13336 with EPA Methods 28, 5G and 5H.) Doyou feel that the EPA methods should be replaced with or be made comparable to an international standard? It was the feeling of the group that the ISO standard has very little relevance at this time. It isC-8

being used mainly in New Zealand and Australia. The group felt that the Canadian standard CSA B415 should be looked at more closely. The question is, should the U.S. get involved in the ISO standard so that it is a standard that the U.S. can agree with? At the present time manufacturers have very little interest in dedicating any resources to this effort. 6. Correspondence between in-home and laboratory emission test results. 6.1 How accurately do certification tests predict in-home performance? We don't know what the correlation is if any. Dan Henry stated that it is unlikely that a lab test would mirror in-home performance given the fuel alone used in the lab is different from cordwood. The original purpose of the test was to rank stoves given a standard test procedure. Also, given that the accuracy of the lab test is plus or minus 20% makes it difficult. Ben Myren brought up the Klamath Falls study where the cleanest lab stove was the cleanest stove in the field. The same held true for the dirtiest stove in the lab. The EPA test protocol may be very accurate at predicting relative field performance. It was also brought up that the EPA test should not designate a low burn, but allow the manufacturer to choose a low burn rate for its appliance. 6.2 How would you design research testing in the laboratory to simulate in-home use? This would be very difficult due to the variations in use patterns and fuel types in the field. 7. EPA Method 28 strengths and weaknesses. 7.1 Method 28 is in part an "art ". Fuel loading density, fuel moisture, fuel characteristics (old vs. new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have? There are many little things that affect emissions during a test burn and they vary with every stove. John Francisty stated that this industry has spent literally millions of dollars trying to get their appliances to reach a 1 kg/hr burn rate, which is unnecessary. There does not need to be a certain low burn rate. The low burn rate has the largest impact on the emissions of the stove. Everyone agreed that the low burn rate and the high burn rate were critical in the test procedure and the two middle burn rates were academic. 7.2 Burn rate weighting is based on very limited data and the cities from where the dataC-9

were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole? Don't use 1 kg/hr as an artificial minimum burn rate requirement. Plus the EPA rule is design restrictive. An example of this is in the late 1980's EPA stopped regulating wood burning furnaces and R&D stopped almost immediately. Historically, we ended up with a test method using conventional lumber because there was a database using conventional lumber. The 1 kg/hr low burn rate was imposed because regulators thought the industry would be getting away with something if an artificial low burn weren't imposed. As a note, there was an ASTM standard at the time that was repeatable and reliable. The question was asked if question 7 is irrelevant. Dr. Dennis Jaasma pointed out that most stoves in the field burned at the low burn rate category. However, burn rates with cordwood vary more than that of dimensional lumber. Users know that to get a longer burn, you use a larger piece of wood. It was also mentioned that the industry is not making or selling many woodstoves and that everything discussed is going to cost a lot of money for the industry to comply with. This should be considered with any possible change made to the present test methods. Ben Myren pointed out that with the new air quality standards, improvements would need to be made.7.3 The equationfor the calculation ofthe air-to-fuel ratio in Method 28A is in error. The error produces a small but significant difference in the calculated air-to-fuel ratio. Should the Method be corrected or should it be left as a “predictor” of the air-to-fuel ratio? Dr. Jim Houck pointed out that the calculation is flawed due to the volume occupied by hydrocarbon gas being considered a constant. What this error does is have a negative effect on stove efficiencies as well as measured air-to-fuel ratios. Stoves have to be well over the 35:1 ratio to actually meet the exemption. CSA B415 gives a solid basis for calculating efficiencies. It was brought up that there should be only one test if the tests do not give the same answers. 7.4 The assumed molefraction of hydrocarbons (Y HC) is defined as a constant in the airto-fuel ratio calculations in Method28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbonC-10

vapors (more appropriately, organic compound vapors) be measured as part of the Method? The committee as a whole had no strong opinion on this issue. 8. EPA Methods 5G and 5H correlation.
8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two Methods be re-evaluated? No, just eliminate Method 5H. There should not be two methods in one standard that do not produce identical results. One method should be eliminated. The perception is that 5H gives lower results even though theoretically it should give a higher result. The correlation between the two methods has never been tested, but they do not converge to zero, as they should with the correction. There is also a problem at higher burn rates. 8.2 It is the general perception that Method 5H produces lower numbers than 5G. Method 5G is less costly and more precise than 5H. - Comments? - Should there be just one sampling method? There should be one Method 5G, however the correction multiplier in 5G that is supposed to make 5G and 5H equal would have to be removed. 8.3 The same points regarding flow rate calculations (air-to-fuel ratio) and hydrocarbons as made for Method 28A are applicable to Method 5H. -- Comments? They are wrong and should be changed. This is a modification of Method 5. 8.4 The precision of EPA's basic Method 5 is estimated as being about 20%. Almost one quarter of the 214 stoves listed as certified by the EPA as of8/12/97 are within 20% of their respective (catalytic or noncatalytic) emission limits. -Comments? How many of the 214 are still being sold? The safety factor is already built into the Phase II appliances by dropping Phase I from 9 g/hr to 7.5 g/hr. 8.5 Based on practical experience with the 5G and 5H, how can they be improved? There are many improvements that are needed. An example of this are the calibration requirements. The test methods are also very susceptible to barometric pressure, especially at the low burn rate. Correct 5G and 5H so that the results match or get rid of 5H and get rid of the correction factorC-11

on 5G. This may mean changing the pass/fail number. 5G was designed for variable flow rates, which better represents wood stoves. 9. Performance deterioration of EPA-certified woodstoves in the field. 9.1 It is the opinion of many in the woodstove industry that catalysts last only five years and that a stove designed for a catalyst operated without a functioning catalyst can produce as much emissions as a conventional stove. -Comments? The thought was that the life of the catalyst was dependent upon the operator as well as the stove design so it is very difficult to say. Also the emissions from a catalytic stove without a functioning catalyst are very much a function of the stove design. 9.2 Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR, and Crested Butte, CO, showed that emissions from some catalytic stoves became appreciably worse even after only two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been made in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program? The Glens Falls stoves were “cooked” by overdrafting chimneys. Woodstoves are the only type of residential heating appliance that do not have some type of overdraft protection. This needs to be changed. Education of consumers would be helpful, but how would this be done? Would you require a stove owner to be licensed? This is not reasonable. 10. Stress test pros and cons. 10.1 A short-term laboratory woodstove durability testing protocol was developed to predict the long-term durability of stoves under conditions characteristic of in-home use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at veryhigh temperatures over a one to two week period to predict long-term durability under inhome use. Is this a reasonable approach? One manufacturer mentioned that his stove failed the stress test even though they have had very little problems with them in the field. This would indicate that the test was much too severe. 10.2 Should a stress test be made part of the certification process? The feeling was that a stress test should not be made a part of the certification test.C-12

11. Feasibility of developing separate emission factors for dry and wet wood and for softwood and hardwood species classes. 11.1 Optimum wood moisture for low particulate emissions seems to be in the 18% to 20% range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species? No one present knew of any data that were not already available to OMNI. 11.2 Wood from different tree species clearly burns differently. The chemical makeup and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If this is true different parts of the country may have different emissions factors for residential wood combustion. Are you aware of any data that document different emission factors for wood from different tree species? The committee generally agreed that testing with different wood species made more sense than at four burn rates on the same species. 12. Routine maintenance. 12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than noncatalytic stoves? Would this be relevant for pellet stoves with electronic and moving parts? The committee agreed that routine maintenance was very relevant and that training of chimney sweeps, who perform much of the routine maintenance, is important. 12.2 Should the homeowner be provided with a maintenance manual or a training course at the time of purchase? Should a maintenance program be part of the purchase price particularly for catalytic stoves? Homeowners are provided with maintenance instructions at the time of purchase. A maintenance program for catalytic stoves would likely make these stoves even less popular in the market than they already are. 12.3 What would the key elements of routine maintenance be? This varies from model to model, and is covered in each individual owner's manual.