## A REPORT ON THE PARTICULATE EMISSIONS PERFORMANCE OF MASONRY HEATERS – DEFINTION, DATA, ANALYSIS AND RECOMMENDATIONS

Prepared for: The Masonry Heater Caucus of the Hearth, Patio and Barbecue Association

Prepared by: Robert Ferguson Ferguson, Andors & Company

P.O. Box 678 South Royalton, VT 05068

Date: February 13 , 2008

The scope of this report is to provide the U. S. Environmental Protection Agency with chronologically organized information about the particulate emissions performance of masonry heaters as a defined product class and to provide conclusions and

recommendations based on that information.A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 2 of 72 Table of Contents

Introduction .................................................................................... 3

Background ..................................................................................... 3

Definition ....................................................................................... 5

Data Summary ................................................................................. 5

Conclusions .................................................................................... 7

Recommendations .............................................................................. 7

Attachment 1: Excerpt from Federal Register (Footnote 1) ............................. 8

Attachment 2: Best Available Control Measures Document Excerpts (Footnote 2) . 9

Attachment 3: Renner Memo (Footnote 3) ................................................ 11

Attachment 4: McCrillis Memo Excerpts (Footnote 4) .................................. 14

Attachment 5: ASTM E1602-03 ............................................................. 19

Attachment 6: Test Report Summary Table ................................................ 28

Attachment 7: Referenced Report Bibliography ........................................... 29

Attachments 8 – 21: Referenced Report Cover Pages and Excerpts ..................... 31A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 3 of 72 Introduction

This White Paper is submitted by the Masonry Heater Caucus of the Hearth, Patio and Barbecue Association to support its request that the Office of Air Quality Planning and Standards (OAQPS) recognize that Masonry Heaters are a class of solid fuel heating devices that are inherently clean-burning and can be a viable emissions control option in PM-impacted areas. The White Paper has five parts:

Background

o Provides relevant background information on regulatory status, numbers installed annually, data sources, etc.

Definition

o Defines what comprises a clean-burning masonry heater including a list of

critical features.

Data

o Summarizes the available North American emissions performance data.

Conclusions

o Summarizes our conclusions on emissions performance.

Recommendations

o A section containing our recommendations that includes procedures that can be used to provide assurances that masonry heaters built in the field include the critical elements identified in the definition of clean-burning masonry heater.

Background

Modern masonry heater designs originated in Europe and those designs have been in use for many decades, if not centuries. While masonry heaters are installed in relatively large numbers across Europe, they represent only a small niche in the solid-fuel burning market in the United States. Masonry heaters are site-built, often by individual masons, making it hard to provide a precise number of installed units. The Masonry Heater Caucus estimates that between 600 and 1,000 masonry heaters are installed in North America each year. This represents only a fractional percentage of all solid-fuel burning appliance

sales and installations.

EPA's wood stove New Source Performance Standard (NSPS), 40 CFR Part 60, Subpart AAA, specifically exempts masonry heaters because the Regulatory Negotiation Committee recognized that they are inherently clean-burning due to their high burn rates and air-rich characteristics. This is explained in the preamble to the proposed regulations 1 as follows: “ The 800 kg cutoff was established as an easy means of excluding

1 Federal Register/Vol. 53, No . 38/February 26, 19 88/Rules and Regu lations/Page 5864. See Attachment 1.A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 4 of 72 high mass fast-burn wood-burning appliances known as “Russian stoves” or “European tile stoves.” These devices typically operate at hot, fast burn rates and cannot be damped. It is also likely that they are incapable of meeting the 5 kg/hr minimum burn rate. The intent of the committee was to exempt from the standards these appliances which rely on clean-burning air-rich conditions and which have high combustion efficiencies. ”

Notwithstanding EPA's clear determination in the NSPS rulemaking that masonry heaters are inherently clean-burning, because of their high burn rates and air-rich characteristics, masonry heaters have had a difficult time getting accepted by SIP planners as viable control options for PM-impacted areas. In some jurisdictions, only NSPS-certified wood

stoves have been allowed. While the intent may have been to eliminate “loop-hole” products as a means of improving air quality, the result for some product classes, including masonry heaters, has been to effectively ban a clean-burning alternative. Other areas have followed EPA's RACM/BACM guidance 2 and allowed NSPS-certified appliances, along with other appliances that have been shown to be “equivalent.” [See

also Renner memo 3 .] However, these equivalency provisions, although written with good intent, are flawed in concept. The NSPS emission limits were based on Best Demonstrated Technology (BDT) for traditional wood-burning stoves and inserts and were supported with significant data from the Oregon woodstove certification program. These levels do not translate to appliances employing different technologies and, therefore, with different BDT. Masonry heaters are not designed nor do they operate like NSPS certified stoves or inserts. Moreover, the very different operating profiles for masonry heaters compared to woodstoves present difficult issues when attempting to make "equivalency" findings. The fuel load in a masonry heater is fully-consumed in a short period of time. This heats a large mass of refractory, which in turn discharges the stored heat over many hours. Woodstoves are also batch loaded, but the heat is delivered as the fuel load is consumed. The length of the burn depends on how the operator sets the air controls. When comparing emissions performance on a gram/hr basis, the masonry heater emissions must be averaged over the period of time that useful heat is being provided to the home in order to compare them with woodstoves on an "apples to apples" basis. Finally, the fact that air quality planning agencies frequently require costly case-by-case showings of "equivalency" has been an additional, significant obstacle to masonry heater builders.

We are presenting the results of masonry heater testing that has been conducted in North America, but it is important to recognize that considerable testing has also been conducted in Europe and that testing corroborates the clean-burning performance of masonry heaters as a class of products.

2 Technical Information Document for Residential Woo d Combustion Best Available Control Measures,

U. S. Environmental Prot ection Agency, Office of Air and Ra diation, Office of Air Quality Planning and Standards, Research Triangle Park, NC , September 1992. See Attachment 2.

3 Memo: F. H. Renner to Chief, Air Branch, Region s I – X, September 23, 1991, Interpretation of EPA’s

Guidance for Residential Wood Combustion Emissi on Control Measures. See Attachment 3.A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 5 of 72 Definition

It is also necessary to establish a way to determine what masonry heater designs should qualify for recognition in that class and for that the following definition is proposed.

“A masonry heater is a site-built or site-assembled, solid-fueled heating device constructed mainly of masonry materials or soapstone in which the heat from intermittent fires burned rapidly in its firebox is stored in its massive structure for slow release to the building. It has an interior construction consisting of a firebox and heat exchange channels built from refractory components.”

Specifically, a masonry heater has the following characteristics:

Site-built or site-assembled.

A mass of at least 800 kg. (1760 lbs.).

Tight-fitting fuel loading doors that are closed during the burn cycle,

An overall average wall thickness not exceeding 250 mm (10 in.).

Under normal operating conditions, the external surface of the masonry heater, except immediately surrounding the fuel loading door(s), does not exceed 110 C. (230 F.).

The gas path through the internal heat exchange channels downstream of the firebox includes at least one 180-degree change in flow direction, usually downward, before entering the chimney.

The length of the shortest single path from the firebox exit to the chimney entrance is at least twice the largest firebox dimension.

A combustion air control that is designed to provide a high-fire burn rate only.

A combustion air introduction system that directs the majority of the combustion

air to the area in the firebox that is at or above the level of the fire.

Constructed or installed by qualified masonry heater builders.

ASTM E-1602 “Standard Guide for Construction of Solid Fuel Burning Masonry Heaters” provides design and construction information for the range of masonry heaters most commonly built in the United States and can be used as the basis for determining whether a particular design qualifies for recognition as a masonry heater. A copy for reference purposes only is included as Attachment 5.

Data

A table showing the reports from testing in North America that provides data relevant to types of masonry heaters that meet the above definition is included as Attachment 6. The table includes a brief description of the test parameters and the average emission results. The data comprises the results from research studies, test method development efforts, and testing for certification to state masonry heater rules. The average particulateA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 6 of 72 performance is presented as emission factors (grams of particulate per kilogram of fuel burned). This format provides the best way to compare emissions from high-burn-rate, high-combustion-efficiency, intermittently-f ired appliances. Emission rates, when available in the reports, have also been provided. However, as was briefly discussed in the Background section, emission rates (grams of particulate per hour) can be deceiving when evaluating intermittently fired high-mass appliances. One or two fires that last only a few hours can provide heat for a full twenty-four hour period. Emission rates should therefore be normalized over the period of time that heat is being provided by the masonry heater if they are to be used to compare different appliance types. The emission rates we are reporting here may not have been calculated using the same procedures in each case. Some values have been normalized, some have not. These differences should be taken into consideration when comparing individual values. We have also included ranges for data, as well as results from individual heaters when available in the reports.

The data that we are presenting represents all data from masonry heater testing in North America that we have been able to obtain with the exception of data from a test series conducted on four products from one manufacturer 4

. Please note that some additional reports have been issued that address sub-sets of testing results from the reports we have cited. Those reports have not been included if their data are contained within the cited reports. The table also includes a reference to the AP-42 emission factor for masonry heaters. Full references for each cited report are included in Attachment 7.

Report cover pages and extracted summaries or excerpts from the reports, when available, are included in Attachments 8 - 21. Copies of the full reports can be made available upon request.

Reference C (Attachment 10) is the report on the field testing of five heaters that represent a cross-section of the masonry heater designs that were being built across the country. This study from 1991-1992 was funded by Masonry Heater Association members. Ultimately, EPA was approached and agreed to monitor and audit this test program. In an EPA memorandum 5 , Dr. Robert C. McCrillis presents his evaluation of the test results from the masonry heater test program. These results (which covered a broad range of heater designs) were used by EPA to calculate the 2.8 g/kg emission factor for masonry heaters that is listed in EPA’s AP-42 document “Emission Factors from

Residential Wood Combustion”.

4 These data were excluded because the tests were not conducted following a masonry heater test protocol but were instead generated using a fueling and operating protoco l for factory-built fireplaces.

5 Memo: R. C. McCrillis to D. Mobley, May 8, 1992, Masonry Heater Field Performance Data. See

Attachment 4.A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 7 of 72 Conclusions

The test data support previous conclusions regarding the particulate emission performance of masonry heaters as a class and further defined as those designs that meet the criteria outlined earlier in this paper. Using a variety of test procedures, fueling protocols and fuel types, emission measurement methodologies, laboratory and in-situ measurements, the resultant average particulate emissions have ranged from 1.4 to 5.8 grams of particulate per kilogram of fuel burned. The average of the averages for this data is 2.9 g/kg. Again, the current AP-42 emission factor for masonry heaters is 2.8 g/kg. Note: We have not included the emission results for the Russian Heater cited in Reference B (Attachment 9). This heater was constructed by a mason inexperienced and untrained in masonry heater construction and the emission performance is considered as an outlier when compared to all other available data.

The low average particulate emissions from masonry heaters combined with the small number of annual installations justifies allowing masonry heater installations to continue without imposing undue burdens on the installers of these appliances. The cost associated with testing individual masonry heaters is simply prohibitive and does not represent a needed expenditure to protect air quality. Another means of satisfying air quality regulators is appropriate in this case.

Recommendations

Masonry heaters as a class should be accepted by EPA as clean-burning and EPA should give the appropriate guidance, in the form of a lette r from the Office of Air Quality Planning and Standards, to state, local and tribal air quality regulators. That letter should recommend allowance of the installation and operation of qualified masonry heaters in PM-impacted areas as a viable strategy for PM reduction from Residential Wood Combustion (RWC). We suggest that the current AP-42 emission factor of 2.8 g/kg continues to be representative of the expected performance of masonry heaters as a class.

Qualified masonry heaters are defined as those in conformance with the masonry heater definition included in this paper.

Conformance with the specified masonry heater design parameters should be confirmed and documented by an independent third party laboratory for each masonry heater design. This would be an engineering evaluation based on design drawings provided by the masonry heater builder or manufacturer. The conformance report would be applicable to each heater that is installed in accordance with the conforming design. Additional affirmations by the masonry heater installer or builder that the design as built in the field is in conformance with the design drawings could be considered if needed.A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 8 of 72 Attachment 1: Reference 1 – Excerpt from Federal RegisterA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 9 of 72 Attachment 2: Reference 2 – Cover pageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 10 of 72 Attachment 2: Reference 2 – ExcerptA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 11 of 72 Attachment 3: Reference 3 – Renner MemoA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 12 of 72A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 13 of 72A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 14 of 72 Attachment 4: Reference 4 – McCrillis Memo ExcerptsA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 15 of 72A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 16 of 72A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 17 of 72A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 18 of 72

# Copyrighted page(s) removed. Copyrighted material is not available in Regulations.gov since it may not be reproduced without consent of the copyright holder.

Removed pages can be viewed at the USEPA Docket Center, Public Reading Room.

Address: 1301 Constitution Ave, NW

Room 3334 Washington, DC 20004

Telephone: 202-566-1744

Email: docket-customerservice@epa.govA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 28 of 72 Attachment 6: Summary of Emission Test Reports for Masonry Heaters

Attachment 7: Reference ReportsA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 29 of 72 A. Stern, C. H, Jaasma, D. R. and J. W. Shelton, Masonry Heater Emissions Test
Method Development , Wood Heating Alliance, March 1990.

B. Barnett, S. G., In-Home Evaluation of Emissions from Masonry Fireplaces and

Heaters , Western Clay Products Association, Prepared by: OMNI Environmental
Services, Beaverton, OR, Report # 80-10201, September 6, 1991

C. Barnett, S. G., Summary Report of the In-Home Emissions and Efficiency
Performance of Five Commercially Available Masonry Heaters , Masonry Heater
Association, Prepared by: OMNI Environmental Services, Beaverton, OR, Report #
80-13301, May 22, 1992 (Revised June 1, 1993).

D. Barnett, S. G., McCrillis, R. C. and R. B. Crooks, Evaluation of Emissions from
Masonry Heaters and Masonry Fireplaces , OMNI Environmental Services, U. S.
Environmental Protection Agency, Mutual Materials Company, Report # 92-118.06,

1992

E. Bighouse, R, and S. G. Barnett, In-Home Evaluation of Emissions from a Temp-Cast
2001 Masonry Heater, Temp-Cast 2000 Masonry Heater Manufacturing, Inc.,
Prepared by: OMNI Environmental Services, Beaverton, OR, Report No. 80131-01,
May 8, 1992

F. In-Home Evaluation of Emissions from a Mastercraft Swedish Heater Kit Masonry

Heater , Mastercraft Masonry, Brush Prairie, WA, Prepared By: Science Applications
International Corporation, Beaverton, OR, March 23, 1993.

G. Evaluation of Efficiency and Emissions from a Moberg/Royal Crown MRC-3036

Masonry Heater , FireSpaces, Inc., Portland, OR, Prepared by: OMNI Environmental
Services, Beaverton, OR, Report No. 001S-013B, May 28, 1994.

H. H1: Moberg 3042 Masonry Heater Emissions Testing Report (Compliance with
Colorado Regulation No. 4 ), FireSpaces, Inc., Portland, OR, Prepared by: OMNI
Environmental Services, Beaverton, OR, Report No. 001-S-02-3-B, January 1996.
H2: Moberg 3042 Masonry Heater Emissions Testing Report (Compliance with
Washington State UBC Section 31-2 ), FireSpaces, Inc., Portland, OR, Prepared by:
OMNI Environmental Services, Beaverton, OR, Report No. 001-S-02-3-A, January

1996.

I. Report on Revisions to 5 TH Edition AP-42 Section 1.10 Residential Wood Stoves

, Contract No. 68-D2-0160, U. S. Environmental Protection Agency, Research
Triangle Park, NC, July 29, 1996.

J. J1: Test Report: Masonry Heater Particulate Emissions and Overall Efficiency.
Tulikivi Oy Model KTU-2100 , Tulikivi Oy, Juuka, Finland, Prepared by: OMNITest Laboratories, Inc., Beaverton, OR, Project # 020-S-01-03, May 1997.A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 30 of 72 J2: Test Report: Masonry Heater Particulate Emissions and Overall Efficiency.
Tulikivi Oy Model KTU-2100 , Tulikivi Oy, Juuka, Finland, Prepared by: OMNITest Laboratories, Inc., Beaverton, OR, Project # 020-S-01-03, May 1997.

K. Tulikivi Oy; Model TU 1000 Emission Testing Report (Protocol Conformance with
Colorado Regulation No. 4) , Tulikivi Oy, Juuka, Finland Prepared by: OMNI
Environmental Services, Beaverton, OR, Report No. 020-S-06-3, April 29, 1999.

L. Tulikivi Oy; Model TU 2200 Emission Testing Report (Protocol Conformance with
Colorado Regulation No. 4) , Tulikivi Oy, Juuka, Finland Prepared by: OMNI
Environmental Services, Beaverton, OR, Report No. 020-S-06-3, April 29, 1999.

M. Tulikivi Oy; Model TU 2450 Emission Testing Report (Protocol Conformance with
Colorado Regulation No. 4) , Tulikivi Oy, Juuka, Finland Prepared by: OMNI
Environmental Services, Beaverton, OR, Report No. 020-S-06-3, April 29, 1999

N. N1: Emissions Report, Swedish Kakelugn Style Masonry Heater , Built by Jerry
Frisch, Prepared by: OMNI-Test Laboratories, Inc., Beaverton, OR, 2006.
N2: Emissions Report, Swedish Kakelugn Style Masonry Heater , Built by Jerry
Frisch, Prepared by: OMNI-Test Laboratories, Inc., Beaverton, OR, 2006.A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 31 of 72 Attachment 8: Reference A - Report Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 32 of 72 Attachment 8: Reference A - Executive SummaryA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 33 of 72 Attachment 9: Reference B – Cover Report PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 34 of 72 Attachment 9: Reference B – Executive SummaryA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 35 of 72 Attachment 9: Reference B – Executive Summary (cont.)A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 36 of 72 Attachment 9: Reference B – Emission ComparisonA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 37 of 72 Attachment 10: Reference C - Report Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 38 of 72 Attachment 10: Reference C - Executive SummaryA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 39 of 72 Attachment 10: Reference C - Executive Summary (Continued)A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 40 of 72 Attachment 10: Reference C – Emission ResultsA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 41 of 72 Attachment 11: Reference D – Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 42 of 72 Attachment 11: Reference D – Excerpt from SummaryA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 43 of 72 Attachment 11: Reference D – Data SummaryA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 44 of 72 Attachment 11: Reference D – Emission Comparison ChartA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 45 of 72 Attachment 12: Reference E – Report Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 46 of 72 Attachment 12: Reference E – Excerpt from ReportA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 47 of 72 Attachment 12: Reference E – Data SummaryA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 48 of 72 Attachment 12: Reference E – Graphical PresentationA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 49 of 72 Attachment 13: Reference F – Report Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 50 of 72 Attachment 13: Reference F – Executive SummaryA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 51 of 72 Attachment 13: Reference F – Data SummaryA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 52 of 72 Attachment 13: Reference F – Graphical PresentationA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 53 of 72 Attachment 14: Reference G – Report Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 54 of 72 Attachment 14: Reference G – Summary PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 55 of 72 Attachment 15: Reference H1 – Report Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

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Page 57 of 72 Attachment 15: Reference H2 – Report Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 58 of 72 Attachment 15: Reference H2 – Summary PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

Page 59 of 72 Attachment 16: Reference I - AP-42 Revision Report ExcerptsA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY HEATERS February 13, 2008

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Page 64 of 72 Attachment 17: Reference J1 and J2 – Summary Page

This page redacted from docket version due to claim of confidentiality on page 63 above. For further information, contact OMNI Test Laboratory or Tulikivi at addresses shown on
page 63.A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY

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Page 65 of 72 Attachment 18: Reference K – Report Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY

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Page 66 of 72 Attachment 18: Reference K – Summary Page

This page redacted from docket version due to claim of confidentiality on page 65 above. For further information, contact FireSpaces, Inc., Portland, Oregon; tel. (503) 227-0547A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY

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Page 67 of 72 Attachment 19: Reference L – Report Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY

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Page 68 of 72 Attachment 19: Reference L – Summary Page

This page redacted from docket version due to claim of confidentiality on page 67 above. For further information, contact FireSpaces, Inc., Portland, Oregon; tel. (503) 227-0547A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY

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Page 69 of 72 Attachment 20: Reference M – Report Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY

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Page 70 of 72 Attachment 20: Reference M – Summary Page

This page redacted from docket version due to claim of confidentiality on page 69 above.

For further information, contact FireSpaces, Inc., Portland, Oregon; tel. (503) 227-0547A REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY

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Page 71 of 72 Attachment 21: Reference N1 and N2 – Report Cover PageA REPORT ON THE PARTICULATE EMISSIONS PE RFORMANCE OF MASONRY

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