Page 1 of 23



## MASONRY HEATER NSPS PROPOSAL FINAL DRAFT

PREPARED FOR:

THE HEARTH, PATIO & BARBECUE ASSOCIATION

Masonry Heater Caucus

PREPARED BY:

Robert Ferguson

&

David Menotti

September 24, 2012Page 2 of 23

Background

In February, 2008, the Hearth Patio & Barbecue Asso ciation (HPBA) Masonry Heater Caucus submitted a White Paper 1 to EPA reporting on the emission performance of ma sonry heaters. This paper included background information about ma sonry heaters, test data accumulated from two decades of testing, conclusions drawn from that data and recommendations to EPA about how to best integrate masonry heaters into the clea n-burning solid fuel heating options that might be considered in particulate matter (PM) impacted a ir sheds.

The White Paper stated:

Modern masonry heater designs originated in Europe and those designs have been in use for many decades, if not centuries. While masonry heate rs 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 in dividual masons, making it hard to provide a precise number of installed units. The [HPBA] Mason ry Heater Caucus estimates that between 600 and 1,000 masonry heaters are installed in Nort h America each year. This represents only a fractional percentage of all solid-fuel burning app liance sales and installations.

More recent market research conducted by a masonry heater producer in conjunction with the
Small Business Regulatory Enforcement Fairness Act (SBREFA) review conducted by OMB,
SBA and EPA in the summer of 2010 identified approx imately 250 U.S. businesses involved in
the manufacturing, sales, and/or installation of ma sonry heaters. All identified masonry heater
industry participants qualify as small businesses.

The largest manufacturers of units are foreign enti ties (Finland, Canada, Germany and “others”
by order of sales). Their products are not custom site-built heaters but are instead site-assembled
and easily account for the majority of all sales. All of these manufacturers rely on U.S.
businesses for installation and marketing support.

The market research report prepared for EPA by Fros t and Sullivan 2 indicated that 730 masonry
heaters are installed yearly in the U.S. with total revenue of $6.6 million. Although masonry
heaters accounted for only 0.1% of the analyzed hea rth units sold, they accounted for 1.3% of
total hearth revenue. Taking in to account that m ore than one of these 250 businesses may
typically handle each unit through its manufacture, sale and installation, the average business
involved in the masonry heater industry certainly d eals with fewer than three units annually.

Regarding the particulate emissions impacts of maso nry heaters, the White Paper concluded:

1 Ferguson, R., A Report on the Particulate Emission s Performance of Masonry Heaters – Definition, Data , Analysis and Recommendations, February 13, 2008

2 Frost and Sullivan; Project: Market Research and R eport on North American Residential Wood Heaters, Fireplaces, and Hearth Heating Products Market (P.O . # PO1-IMP403-F&S), Final Report, EPA, April 26, 2 010, pp.

31-32.Page 3 of 23

The test data support previous conclusions regardin g the particulate emission performance of masonry heaters as a class and further defined as t hose designs that meet the criteria outlined earlier in this paper. Using a variety of test proc edures, 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 d ata is 2.9 g/kg. Again, the current AP-42 emission factor for masonry heaters is 2.8 g/kg.

The low average particulate emissions from masonry heaters combined with the small number of annual installations justifies allowing masonry hea ter 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 re gulators is appropriate in this case

.

Masonry Heater Definition

Definitions of the appliance category from three so urces are presented below:

1. From the February 2008 White Paper:

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

Specifically, a masonry heater has the following ch aracteristics:

• Site-built or site-assembled.

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

• Tight-fitting fuel loading doors that are closed du ring the burn cycle,

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

• Under normal operating conditions, the external sur face of the masonry heater, except immediately surrounding the fuel loading door(s), d oes not exceed 110 C. (230 F.).

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

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

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

• A combustion air introduction system that directs t he majority of the combustion air to

the area in the firebox that is at or above the lev el of the fire.

• Constructed or installed by qualified masonry heate r builders.Page 4 of 23

ASTM E-1602 “Standard Guide for Construction of Sol id Fuel Burning Masonry Heaters”
provides design and construction information for th e range of masonry heaters most commonly

built in the United States and can be used as the b asis for determining whether a particular design
qualifies for recognition as a masonry heater.”

2. From the NSPS Regulated Product Applicability/Defi nition Proposal submitted to EPA by

HPBA in June 2011:

“Masonry heaters are site-built (using local materi als or a combination of local materials and
manufactured components) or site-assembled (using m anufactured components), solid-fuel
burning heating appliances constructed mainly of re fractory materials (e.g., masonry materials
or soapstone) in which the heat from intermittent f ires burned rapidly in their fireboxes is stored
in their refractory mass for slow release to buildi ng spaces. They typically have an interior
construction consisting of a firebox and heat excha nge channels built from refractory
components, through which flue gases are routed. A STM E-1602 “Standard Guide for
Construction of Solid Fuel Burning Masonry Heaters” provides design and construction
information for the range of masonry heaters most c ommonly built in the United States. The
site-assembled models are generally listed to UL-14 82.”

3. From a consensus recommendation of the Masonry Hea ter Association (MHA) and Association of Masonry Heater and Oven Professional s (AMHOP).

Appliances considered under this regulation shall c onform to the definition of ASTM 1602, Section 3.2, “Definitions of Terms Specific to This Standard: Masonry Heater”.

“Masonry heater” will be considered to include:

Complete solid fuel burning appliances conforming t o a masonry heater design, or

a set of critical components necessary for construc tion of a masonry heater design to which commonly available masonry or other materials are i ntended to be purchased separately and added for installation, or custom and other units b uilt on site from common local or other components to a masonry heater design.

Determining Best Demonstrated Technology (BDT) for Masonry Heaters

There are two components to a Best Demonstrated Per formance analysis: a determination of the level of emissions performance that is technologica lly feasible, and an evaluation of the costs of achieving the various levels of control that are de termined to be technologically feasible. The decision on a performance standard reflecting BDT i nvolves an integration of the results from these two analyses. Both components are addressed below.Page 5 of 23

I. Technological Feasibility

A. Emission Standard paired with Approved Test Method( s)

For a broad range of masonry heater designs built o r installed in North America, the traditional NSPS approach of testing a representative example t o determine whether it meets an emission standard would be appropriate. Once the design has been approved, other units with the same or substantially similar designs would be presumed to perform the same, thus allowing the testing cost to be distributed over multiple installations, just as is done for other NSPS source categories.

This approach requires decisions to be made on (1) a test method or methods, (2) the format of the emission standard (e.g., g/hr, g/kg or g/MJ), a nd (3) a numerical value for the performance standard that reflects best demonstrated technology . Each of these issues is discussed in turn

below.

(1) Test Methods

Masonry heater emission testing that has been condu cted over the past 20 years has employed a variety of laboratory and in-situ testing protocols . This includes variations in both the fueling procedure and the way particulate emissions were me asured. Recent activity within the ASTM test method development forum has resulted in a new consensus-based test method for masonry heaters, ASTM E2817-11, which has been approved and published. This method is intended to be used in conjunction with ASTM E2515, Standard Test Method for Determination of Particulate Matter Emissions Collected by a Dilutio n Tunnel. Since ASTM E2817-11 is a recently established, consensus method for testing these appliances, it is the clear choice for a test method for use in this component of the NSPS.

There is currently no consensus-based masonry heate r efficiency test method in use in North America. Limited efforts have been made to adapt t he CSA B415.1-2010 stack loss method for use with masonry heaters. The technical hurdle is that the B415.1 calculation algorithm requires that the weight of fuel consumed for each sampling interval be known. This is because the algorithm is based on a mass balance principle. Ho wever, masonry heaters often exceed the total mass that can be accommodated by test laboratory pl atform scales for determining the incremental fuel load weight losses during the test run with the degree of resolution and accuracy needed for the CSA B415.1 calculation process. Eff orts to model the typical weight loss pattern in masonry heaters (as a way to provide the needed fuel weight inputs for the CSA B415.1 stack loss method) or to adapt a variation of the Total C ombustible Carbon (TCC) efficiency method (which works without fuel weight inputs) have been explored, but have not yet begun to be considered in any consensus-based standards develop ment process. Either approach will require confirmation testing across a range of typical maso nry heaters as the essential predicate for establishing an efficiency test method for use in a regulatory program.

EPA should continue to encourage the development of a workable and reliable masonry heater efficiency test method. With adequate lead time to allow the work to come to fruition, overall efficiency could be required to be reported as part of masonry heater certification testing and labeling rather than as part of the emission perfor mance determination. This would adequatelyPage 6 of 23

serve the purpose of providing consumers with the i nformation that might be useful when deciding if a masonry heater is right for them or w hich model they should choose.

(2) Format of the standard

As far as format of the standard is concerned, ther e really are only two available choices: fuel mass-based emission factor (g/kg) and emission rate (g/hr). Historically, the g/kg format has been the standard way to report and rank emissions from masonry heaters, and is used in the two state regulatory programs for these heaters (Colora do and Washington). 3 Testing to determine compliance with those programs has been the source of much of the available in-laboratory data.

To quote from the White Paper regarding format of t he standard:

“ This format [g/kg] provides the best way to compare emissions from high-burn-rate, highcombustion-efficiency, intermittently-fired applian ces. Emission rates, when available in the reports, have also been provided. However, as was b riefly 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 l ast only a few hours can provide heat for a full twenty-four hour period. Emission rates should ther efore be normalized over the period of time that heat is being provided by the masonry heater i f they are to be used to compare different appliance types .”

The other possible format, g/MJ or lb/MMBtu output, is simply not an option at this time, as there is currently no consensus-based North America n test method for determining masonry heater efficiency, and, for that reason, no efficie ncy database for this category of appliances. See discussion in the previous section.

3 It has been learned that EPA will solicit public co mment on whether the format should include a g/hr e missions cap, with 7.5 g/hr from the non-catalytic woodstove phase 2 standards offered as a “straw man.” As t he above quote from the White Paper points out, masonry heat ers and woodstoves have entirely different use patt erns, and that completely undermines any attempt to reason by analogy from one appliance category to the other. High combustion efficiency, single burn rate, intermitte ntly fired appliances are not an appropriate candid ate for regulation using emission rates, whether or not thi s format is appropriate for woodstoves. In any eve nt, the “cap” in the phase 2 woodstove standards had as its rational e providing additional incentives to assure more un iform emissions performance across the four required burn rates [“ The Phase II caps for individual runs are designed to assure that the emission control performance of woo d heaters is relatively constant across the full ra nge of operating conditions.”

, Preamble to Subpart AAA Proposal, 52 Fed Reg 4994, 5008 (February 18, 1987.], a rationale that has no place in the discussion of th e format for masonry heater standards, which operat e at a single (high) burn rate. And the cap in the Phase 2 woods tove standards is 15 g/hr; 7.5 g/hr is the weighted average emission rate that non-catalytic woodstoves need to achieve across four required burn rates to be cert ified. Even if a “cap” were an appropriate standard component for ma sonry heaters, the level of the cap would have to b e determined rigorously from the masonry heater data base, as part of the BDT determination; the Phase 2 woodstove cap would be entirely irrelevant to this analysis, as it is based on a BDT analysis for an entirely di fferent appliance

category.Page 7 of 23

(3) Performance Standard Reflecting BDT

The matter of defining BDT for masonry heaters is s omewhat confounded by the variety of test methods used to generate the available data. As me ntioned previously, several emission measurement methods and fueling protocols have been employed. These have encompassed both in-situ and laboratory testing. The emission sampling methods have included the ESS/AWES type stack sampling (where intermittent sa mples are drawn at prescribed intervals) to dilution tunnel sampling following EPA Method 5G and more recently, ASTM E2515. The fueling protocols have ranged from cordwood burned in homes by the users to several variations of Douglas fir crib configurations as well as sever al species of cordwood burned in a laboratory. Some of the most recent laboratory testing has been conducted using the new ASTM masonry heater test method cordwood protocol comparing the results directly to testing using the two new ASTM crib wood protocols 4

.

Although the fueling protocols in the new ASTM test method (E2817-11) should be very representative of the way masonry heaters are burne d in homes and this method represents the long sought consensus on how to best test masonry h eaters in the laboratory, the method has not been widely used at this point. The most recent da ta is from the in-house laboratory of the largest producer of masonry heaters where they test ed a number of their own models. Correlation between the preponderance of the existi ng data and data from the new ASTM test method is limited at this point but is presented in Table 1. Establishing a robust correlation would require re-testing of a significant number of previously tested masonry heater models to directly compare the old and new results. The co sts of such a test program are simply prohibitive.

It is therefore necessary to rely on what new data is available in combination with older data. For standard setting purposes, this approach implic ates developing a data set incorporating the new data from the ASTM method and data from previou s testing with methods which are reasonably similar to the ASTM method. These data can then be statistically analyzed and an emissions performance value selected that provides an appropriate margin of compliance, to take

into account both the fact that robust correlation between the new ASTM test method and the methods used to generate the current data base has not been established, and also to take into account the fact that the precision of the new ASTM test method has not been determined. That

discussion follows.

For purposes of this discussion, the known data can be categorized in three subsets. Attachment A is the compilation of data for testing conducted between 1990 and 2006 that was presented in Attachment 6 of the White Paper. Attachment B are test results from more recent testing including all known data using ASTM 2817-11. Attac hment C1 is a data summary table from a report from the Lopez Labs Co-operative that includ es results from testing a single heater using the Condar® sampling device while C2 shows comparat ive data between Condar® and ASTM

E2515 for two test runs.

4 The crib fueling method in ASTM E2817-11 Annex A2 a ddresses “bottom-up” combustion while Annex A3 addresses crib fueling for heaters employing “top-d own” burning. Annex A1 is the cordwood protocol.Page 8 of 23

When screening the available data with the intent t o use datasets that are consistent with the new ASTM masonry heater test method and ASTM E2515, or that was generated by what can be considered close surrogates for those methods, much of the available data must be set aside. The in-situ testing does provide a direct measurement o f field performance but the lack of data to correlate these results to the new test method prec ludes its use for determining BDT. The ESS sampling protocol used for Colorado and Washington State testing is significantly different than the dilution tunnel methods and only limited testin g has been done to establish correlation with other methods. Similarly, EPA has stated its objec tions to the OM-41(Condar®) sampling

method 5 for use in a regulatory program and we are not awa re of any change in that position. Consequently, that data must also be set aside for BDT purposes. It is not to say that the in-situ data and Condar® data cannot serve a useful purpose in the discussion. They can be used as a qualitative check for any proposed definition of BD T and to insure that adequate compliance margin is included in the passing grade.

When we apply this screening concept we are left wi th a somewhat limited amount of usable data. The following figures show the datasets for laboratory tests conducted using dilution tunnel sampling, together with a statistical analys is. Figure 1 shows the results of tests using cordwood fuel while the Figure 2 shows the result f rom using crib fuel

.

5 Federal Register/Vol. 53, No. 38/Friday, February 26, 1988/Rules and Regulations , pp. 5866-5867( rej ecting requests to allow use of OM41 in the NSPS program , finding “a number of technical deficiencies” with the method.)Page 9 of 23

Figure 1Page 10 of 23

Figure 2

The Student’s T distribution is applied to the data since there are so few data points. To determine the upper value at a 95% confidence level , a “p” factor is first determined from standard tables based on the degrees of freedom ass ociated with each dataset. The standard deviation for the dataset is multiplied by the “p” and added to the mean to determine the upper

value for the 95% confidence interval. Since we ar e interested only in the upper confidence limit in terms of the impact on an NSPS passing grade, on e-sided “p” values were used. In both cases, the 95% confidence intervals established using this procedure are less than the often-cited two standard deviations typically used to describe the 95% confidence interval.

The upper value determined for the cordwood tests u sing ASTM E2515/EPA M5G is 3.65 g/kg. Using various crib protocols, but again using dilut ion tunnel sampling, the upper value is 2.85 g/kg. These values are not too dissimilar consider ing the differences in the appliances and fueling as well as different laboratories conductin g the tests.

It is recommended that the 95% upper confidence lev el for cordwood be considered as the basis for determining BDT. But, additional compliance ma rgin must still be included in any NSPS passing grade to address the potential test method variability that cannot be determined without data from a properly designed study. A discussion of that issue follows.Page 11 of 23

Very little is known about the precision of any of the methods that have been used to test masonry heaters. We have to assume a certain level of variability is simply unavoidable since wood is being burned under natural draft conditions . This variability can be predicted by using components of the EPA Wood Heater Test Method Varia bility Study 6 . Part of that study examined potential sources of variability in EPA Me thod 28. Table 4 on page 17 of the report shows the variability in the high burn rate results for several of the round robin wood heaters. The average coefficient of variation (standard devi ation divided by the mean) for the measured maximum burn rates is 20%. Although we know that m asonry heaters are different in many ways from wood heaters, the maximum burn rate varia bility demonstrated during round robin testing by the wood heaters at a fixed maximum comb ustion air setting should give an indication that similar variability in burn rate could be expe cted from fixed burn rate masonry heaters if enough tests are conducted to allow even a simple s tatistical analysis. And by looking deeper at

the wood heater round robin results for the high burn r ate tests, it is possible to gain some insight into what might be expected for emissions variabili ty for masonry heaters. For example, if you

examine the maximum burn rate test results for non- catalytic model 3, which span multiple years of testing of the same exact heater in several diff erent test labs, you will see that the variations i n both the observed maximum burn rates and the partic ulate emissions at the maximum burn rate are wide. And this difference is not just between different labs in different years, this variability exists within the same lab during the same proficie ncy test series. Figure 3 shows this variability with emissions converted from g/hr to g/kg to bette r relate the results to masonry heaters.

6 Curkeet, R. and Ferguson, R., EPA Wood Heater Test Method Variability Study

, Analysis of Uncertainty, Repeatability and Reproducibility based on the EPA Accredited Laboratory Proficiency Test Database, Oc tober 6,

2010.Page 12 of 23

Figure 3Page 13 of 23

Note: The laboratory letter codes may apply to dif ferent labs in different years.

Figure 4 presents the same data but looks at the va riation in burn rate and emissions using simple statistical analyses. The coefficient of variation for both the burn rate and the emissions are significant and indicative of how much the variabil ity can be expected when burning the same heater multiple times at different labs. In this c ase, the coefficient of variation for the burn rate

was 33% while the coefficient of variation for emis sions was 49%. Analysis of other (meaning those models where adequate data is available) non- catalytic heater models used in the round robin test program show coefficients of variation for maximum burn rate ranging from 10% to 33% and for particulate emissions ranging from 27% to 76%.Page 14 of 23

Figure 4Page 15 of 23

Even if we postulate that masonry heaters are signi ficantly less variable in their operating characteristics than a non-catalytic wood stove fir ed at the maximum air setting, the ranges observed in the laboratory proficiency test round r obin still can provide useful insights into the expected variability in masonry heater emissions te sting. It is simply reasonable to expect that masonry heaters will not be immune from the variabi lity shown to exist when burning wood. Adding a compliance margin of at least 25% to the p assing grade is warranted based on the preceding analysis of the maximum burn rate data fr om the EPA woodstove proficiency test round robin. This would increase the proposed pass ing grade to 4.3 g/kg.

The in-situ, Colorado/Washington State ESS and Lope z Co-operative Labs Condar® datasets show a range of emissions performance from 0.5 to 6 .2 g/kg. As noted previously, these data can’t be used quantitatively, because the methods a re too dissimilar to ASTM E2817-11 and ASTM E2515. However, they do provide a qualitative insight into the possible range of PM emissions performance that might be expected in a m ore comprehensive E2817-11 data set.

B. Demonstrating Compliance with the Performance Stand ard using Demonstrated Parameterbased Approaches.

A different approach for determining compliance wit h the NSPS performance standard is justified for the sub-set of masonry heaters design s that fall within the parameter ranges that have been shown to provide emission performance that is equivalent to previously tested models or otherwise verified by testing.

Modeling/calculation approaches present an opportun ity to certify masonry heater designs that fall within established parameter limits without th e need for additional emissions testing.

With EN15544, the Austrians have already adopted th is approach for certain custom-built masonry heaters. The design is considered to confo rm (meaning meeting emission limits) if, after entering the individual design parameters int o the model, the algorithm determines that the combination of parametric values predicts that emis sions will fall below the established limits.

The Austrian trade association “Kachelofenverband” devoted the resources to research, develop, and extensively test 7 this mathematical model of particular masonry heate r materials and designs. By testing heaters within the parameters of the mod el, it was found possible to establish emissions performance for the entire modeled class. The basic theory and formulae are embedded in a public standard which was balloted un der the European Union committee CEN 295 and approved in 2009 as a consensus-based EU st andard (EN15544) for broader European use. The Kachelofenverband went further to place t his standard within its own licensed software as part of a verification program. Masonry heaters can be designed under EN15544’s provisions and once verified as conforming are certified witho ut further testing as meeting not only the

7 Schiffert, Dr. Thomas; Schriftreihe Nr. 5 “KACHELO FEN 2000-Technishe Entwicklungen der Holzverbrennungen im Kachelofen (Script Series #5 “ Tiled Stove 2000-Technical Development of Burning W ood in Tile Stoves)”, Ő sterreichischer Kachelofenverband, January 1996.Page 16 of 23

European Union emissions standards but also the mor e restrictive Austrian standards for carbon monoxide, nitrous oxides, organic hydrocarbons and particulates 8

.

The effort to translate and incorporate this EN sta ndard into an ASTM standard for masonry heaters has yet again been delayed despite successf ul balloting, because of legal issues between the European standards organization and ASTM regard ing the latter’s use of copyrighted material. How to best proceed to establish a North American adaptation of the EN 15544 calculation procedure is still under consideration. However, since EN 15544 is an established standard available for use by masonry heater manufa cturers where applicable to their heater designs, delays in the resolution of the ASTM/EN co pyright issues should not prevent incorporation of this standard in the NSPS.

At this time there are limited data showing the emi ssions performance of masonry heaters that have passed or would pass the EN 15544 requirements utilizing North American masonry heater test procedures. One unit that is certified in Eur ope using EN 15544 was tested using both the cordwood and crib fuel procedures from the final dr aft of what would become ASTM E2817-11 as well as the Colorado fueling protocol. The resu lts are shown in Figure 5. Model 4D is the same as shown in Figures 1 and 2. The emissions pe rformance of this heater design ranks it among the cleanest masonry heaters.

Figure 5

Two other models that were close to achieving a pas sing status when evaluated by the EN 15544 calculation procedure were also evaluated using the ASTM E2817 cordwood and crib fuel protocols as well as the Colorado fueling protocol. Exhaust passage configurations in these models, which were modified from the European desi gns to provide more venting flexibility for the North American market, were the reason they did not meet EN 15544 requirements. Firebox and combustion-related components were within the a llowable parametric ranges. These designs would require only slight modification to fully com ply with EN 15544. The test results from

these units are shown in Tables 1 and 2 as Models 1 A and 2B. All test results were under 1.5 g/kg. The fact that these units are slightly outs ide the allowed EN 15544 parameter ranges, but still easily pass the proposed NSPS performance sta ndard provides further support for including

EN 15544 in the NSPS as an alternative method for d emonstrating compliance, as it indicates that the NSPS performance standard compliance isn’t particularly sensitive to precise compliance with the EN 15544 algorithm.

8 Hofbauer, Dr. H. and Padouvas, E.; “Report about t he Test of the Guideline ‘Kachelofen (tiled stove) with Standard Combustion Chamber’”, Technical University of Vienna, December 14, 2001.Page 17 of 23

In addition, qualitative support for the suitabilit y of EN 15544 for use as an alternative NSPS compliance procedure is provided by test data from two other units. Inputting the parametric information for the Royal Crown masonry heater that has been installed in North America for many years shows that it would meet the requirement s for European certification using EN

15544. This model has not been tested to the new A STM E2817 test procedure but does have insitu test data (owner operated using cordwood) from testing conducted in 1991-1992. This data is shown in Attachment A, Reference C with emission s reported at 1.4 g/kg. The Biofire was also tested in-situ during the 1991-1992 test serie s. The reported emissions were 1.9 g/kg. It has been indicated by the importer that the successor m odel, which is similar in almost every way to

the tested model in-situ is EN 15544 certified.

Other parametric alternatives to emissions testing should also be considered, including those currently in use by Washington State 9 and Colorado 10 . These alternate certification options employ a “substantially similar” evaluation conduct ed by an approved laboratory where critical design parameters must be within prescribed limits when compared to previously tested and certified models. We suggest that EPA discuss the d etails of the “substantially similar” options in their rules with Washington State and Colorado air quality officials.

And the door should remain open for other modeling approaches after adequate confirmation has been achieved. Modeling-based procedures for deter mining compliance with NSPS emission limits are a way of reducing the regulatory burden on masonry heater builders while still maintaining a high degree of confidence that masonr y heaters that conform to the prescribed modeling requirements will satisfy the NSPS perform ance standard.

II. Cost Analysis

This component of the BDT analysis requires informa tion on the costs associated with the

various levels of control that were determined to b e technologically feasible. As discussed above, there are a number of masonry heater designs , all or almost all of which can be regarded in some way as “clean burning.” What is lacking, h owever, is a comprehensive ASTM E2817- 11 database on the emissions performance of these d esigns to permit an analysis of which designs would be included and which ones would be e xcluded if the “straw man” passing grade developed in the above analysis were adopted as BDT . For this reason, the cost analysis component will have to be deferred until significan tly more ASTM E2817 data are available.

9 Washington State Building Code/Chapter 51-50 WAC/WA C 51-50-31200 / Washington State Building Code

Standard 31-2/ STANDARD TEST METHOD FOR PARTICULATE EMISSIONS FROM FIREPLACES (See Section 2114, International Building Code), S ECTION 31.205 — APPROVAL OF NON-TESTED

FIREPLACES.

10 DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT / Air Quality Control Commission

/ REGULATION NO. 4 / CONCERNING THE SALE AND INSTALLATION OF WOOD-BURNIN G

APPLIANCES AND THE USE OF CERTAIN WOOD-BURNING APPL IANCES DURING HIGH
POLLUTION DAYS /5 CCR 1001-6, Section 3.2Page 18 of 23

These data will also, of course, permit the technol ogical feasibility analysis to be refined, as pointed out in the previous section.

Small Producer Exemption

The White Paper as well as the SBREFA submittals an d the Frost and Sullivan market analysis, all previously referenced, support the fact that th e vast majority of companies that install masonry heaters are very small businesses.

EPA has supported the concept of a small producer/i nstaller/builder exemption with an annual cap. This concept is sound as it addresses the und ue regulatory burden on these businesses with very little or no adverse environmental impact. It has already been established that masonry heaters, as a class, are very clean burning. It ha s further been established that most masonry heaters involve the site-assembly of pre-manufactur ed components rather than being one-off custom designs.

What is proposed is that individual masonry heater business entities that are “small businesses”

under the SBA definition be allowed to build/instal l up to 12 uncertified masonry heaters per calendar year. These heaters would be exempt from the performance requirements of the NSPS, however, specific record-keeping requirements would still be in force to allow determination that those business entities are in compliance with the terms of the exemption. The record-keeping would include the name of the owner, location of th e heater and the date the installation was completed.

For any given business entity, installation of any certified masonry heaters during a given calendar year would not count against the 12 heater exemption allowance.Page 19 of 23

Attachment A: Masonry Heater Test Data, 1990 - 200 6Page 20 of 23

Attachment B: Masonry Heater Test Data: 2008 - 20 12 11,12

11 Seaton, T, Recent Masonry Heater Test Results, Jul y 2011

12 Tulikivi In-House Data, April 2012Page 21 of 23

Attachment C1: Condar® Test Results 13, 14

13 Senf, N. and Chernov, A., Lopez Labs Co-operative, Summary of Masonry Heater Emissions Tests, Table 2, Data Summary, July 17, 2010

14 It should be noted that the data in this summary of Condar® test results on a single masonry heater en compasses several fueling and operating parameter variations. The mean of all data is 1.29 g/kg with a standard deviation of 0.7
g/kg. No other evaluation of this data has been co nducted by the authors of this proposal.Page 22 of 23

Attachment C1 (Continued)

Key: PM factors less than 1 g/kg are highlighted in gree nPage 23 of 23

PM factors between 1 – 2 g/kg are in white PM factors greater than 2 g/kg are highlighte d in brown

Attachment C2: Test Method Comparisons 15

15 Senf, N. and Chernov, A., Lopez Labs Co-operative, Summary of Masonry Heater Emissions Tests, Table 1, OMNI Test Results, July 17, 2010