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. 20460
                      A-i

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                                        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-ii

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                                      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 the EPA:
Residential Wood Combustion Technology Review project 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-l

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.
                                           A-iii

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                     U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
      AUTHOR
         CATEGORY #1 — IN-HOME EMISSION STUDIES

DATE                  TITLE                                     PUBLICATION INFORMATION
Correll, Robert; Jaasma,    1997
Dennis R.; Mukkamala,
Yagna
Jaasma, Dennis R.; Stern,   1994
Curtis H.; Champion,
Mark
Barnett, Stockton G.
1993
        Field Performance of Woodburning Stoves
        in Colorado during the 1995-96 Heating
        Season
        Field Performance of Woodburning Stoves
        in Crested Butte during the 1991-92 Heating
        Season
Summary Report of the In-Home Emissions
and Efficiency Performance of Five
Commercially Available Masonry Heaters
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)

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)

OMNI Environmental Services, Inc., Beaverton, OR;
Prepared for the Masonry Heater Association
Barnett, Stockton G.        1992
Barnett, Stockton G.        1992
Barnett, Stockton G.;       1992
McCrillis, Robert C;
Crooks, Richard B.
Barnett, Stockton G.        1992
        In-Home Evaluation of Emissions from a
        Grundofen Masonry Heater
        In-Home Evaluation of Emissions from a
        Biofire 4x3 Masonry Heater

        Evaluation of Emissions from Masonry
        Heaters and Masonry Fireplaces in Homes
        In-Home Evaluation of Emissions from a
        Tulikivi KTU 2100 Masonry Heater
                                         OMNI Environmental Services, Inc., Beaverton, OR;
                                         Prepared for Mutual Materials Company, Bellevue WA;
                                         the Masonry Heater Association; and Dietmeyer, Ward and Stroud

                                         OMNI Environmental Services, Inc., Beaverton, OR;
                                         Prepared for Biofire, Inc.

                                         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)

                                         OMNI Environmental Services, Inc., Beaverton, OR;
                                         Prepared for the Tulikivi Group

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                           U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
            AUTHOR
         CATEGORY #1 — IN-HOME EMISSION STUDIES

DATE                   TITLE                                     PUBLICATION INFORMATION
8     Harriett, Stockton G.;       1992
      Bighouse, Roger D.
9     Crouch, I; Crank, W.      1992




10    Henry, D.                 1992




11    Osterburg, R.              1992




12    Barnett, Stockton G.        1991


13    Barnett, Stockton G.        1991
14    Barnett, Stockton G.;       1991
      Fields, Paula G.
         In-Home Demonstration of the Reduction of
         Woodstove Emissions from the Use of
         Densified Logs


         Update on the Crested Butte Woodstove
         Experiment
         A Comparison and Analysis of the Field and
         Laboratory Test Data for the Noncatalytic
         Stoves in the Klamath Falls Field
         Performance Study

         Modeling the Ambient PM10 Impact of a
         Woodstove Replacement Program in Crested
         Butte, Colorado
         In-Home Evaluation of Emissions from
         Masonry Fireplaces and Heaters

         In-Home Fireplace Performance:
         Comparison of a Conventional Fireplace
         with a Retrofit Firecrest Masonry Insert in
         the Zagelow Residence, Vancouver, WA

         In-Home Performance of Exempt Pellet
         Stoves in Medford, Oregon
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)

Transactions of the A&WMA/EPA International Specialty Conference,
PM10 Standards and Nontraditional Paniculate Source Controls,
Volume II, TR-22; Published by Air & Waste Management Association,
Pittsburgh, PA, pp. 680-685 (ISBN 0-923204-09-1)

Transactions of the A& WMA/EP A International Specialty Conference,
PM10 Standards and Nontraditional Paniculate Source Controls,
Volume II, TR-22; Published by Air & Waste Management Association,
Pittsburgh, PA, pp. 593-600 (ISBN 0-923204-09-1)

Transactions of the A& WMA/EP A International Specialty Conference,
PM10 Standards And Nontraditional Paniculate Source Controls,
Volume II, TR-22; Published by Air & Waste Management Association,
Pittsburgh, PA, pp. 686-699 (ISBN 0-923204-09-1)

OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the
 Western States Clay Products Association, San Mateo, CA

OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the
Mutual Materials Company, Bellevue, WA
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)

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                           U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
            AUTHOR
                                  CATEGORY #1 — IN-HOME EMISSION STUDIES

                         DATE                  TITLE                                    PUBLICATION INFORMATION
15
16
17
18
19
20
Harriett, Stockton G.;
Houck, James E.; Roholt,
Robert B.

Houck, James E.;
Harriett, Stockton G.;
Roholt, Robert B.

Jaasma, Dennis R.;
Champion, Mark;
Gundappa, Mahesh
Barnet, Stockton G.;
Roholt, Robert B.;
Houck, James E.
Barnet, Stockton G.;
Roholt, Robert B.
Barnett, Stockton G.
Fesperman, James
1991
1991
1991
1990
1990
1990
In-Home Performance of Pellet Stoves in
Medford and Klamath Falls, Oregon


In-Home Performance of Residential
Cordwood Stoves
Field Performance of Woodburning and
Coalburning Appliances in Crested Butte
During the 1989-90 Heating Season
1.Field Performance of Best Existing Stove
Technology (BEST) Hybrid Woodstoves in
Their Second Year of Use
2.Evaluation of a Modified Evacuation
Cylinder Paniculate Emissions Sampler
(MECS)

In-Home Performance of Certified Pellet
Stoves in Medford and Klamath Falls,
Oregon


Field Performance of Advanced Technology
Woodstoves in Their Second Season of Use
in Glens Falls, New York, 1990
Proceedings of the Air & Waste Management Association 84th Annual
Meeting & Exhibition, Vancouver, BC (91-129.3)
Proceedings of the National Bioenergy Conference, Coeur d'Alene,
ID, (91-129.3)
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)

OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the
Oregon Department of Environmental Quality, Portland, OR
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)

OMNI Environmental Services, Inc., Beaverton, OR; Prepared for
Canada Center for Mineral and Energy Technology, Energy, Mines,
and Resources, Canada, Ottowa, Ontario

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                           U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
            AUTHOR
         CATEGORY #1 — IN-HOME EMISSION STUDIES

DATE                   TITLE                                    PUBLICATION INFORMATION
21    Harriett, Stockton G.
22    Dernbach, Sue
23    Jaasma, Dennis R.;
      Champion, Mark;
      Shelton, Jay W.

24    Barnett, Stockton G.
25    Jaasma, Dennis R.;
      Champion, Mark
26    Simons, Carl A.; Jones,
      Stanton K.
27    Burnet, Paul G.
1990     In-Home Evaluation of Emission
         Characteristics of EPA-Certified High
         Technology Non-Catalytic Woodstoves in
         KlamathFalls, Oregon,  1990 —Final
         Report

1990     Woodstove Field Performance in Klamath
         Falls, Oregon

1990     Woodstove Smoke and CO Emissions:
         Comparison of Reference Methods with the
         VPI Sampler

19897    Final Report — Field Performance of
1990     Advanced Technology Woodstoves in Glens
         Falls, NY, 1988-89, Volume I; and
         Technical Appendix, Volume II
1989    Field Performance of Woodburning Stoves
        in the 1988-89 Heating Season
1989    Performance Evaluation of the Best Existing
        Stove Technology (BEST) Hybrid
        Woodstove and Catalytic Retrofit Device

1988    Performance of Certified Woodstoves under
        Field Conditions
OMNI Environmental Services, Inc., Beaverton, OR; Prepared for
Canada Center for Mineral and Energy Technology, Energy, Mines,
and Resources, Canada, Ottowa, Ontario
Elements Unlimited, Portland, OR; Prepared for the Wood Heating
Alliance, Washington, DC

Journal of the Air & Waste Management Association, Vol. 40, No. 6
pp. 866-871
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)

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

OMNI Environmental Services, Inc., Beaverton, OR; Prepared for the
Oregon Department of Environmental Quality, Portland, OR
Transactions of the APCA/EPA International Specialty Conference,
PM10 Implementation Standards, TR-13, San Francisco, CA; Published
by the Air Pollution Control Association, Pittsburgh, PA, pp. 664-672

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                           U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
            AUTHOR
         CATEGORY #1 — IN-HOME EMISSION STUDIES

DATE                   TITLE                                    PUBLICATION INFORMATION
28    Elements Unlimited
29    OMNI Environmental
      Services, Inc.
30    Simons, Carl A.;
      Christiansen, Paul D.;
      Houck, James E.;
      Pritchett, Lyle C.

31    Simons, Carl A.;
      Christiansen, Paul D.;
      Pritchett, Lyle C.; Enns,
      Victor; Hay den, A.C.S.

32    Burnet, Paul G.
33    OMNI Environmental
      Services, Inc.
1988     In-Situ Emission Factors for Residential
         Wood Combustion Units
1988    Final Report — Paniculate Emission Test,
        Emission Control System Inspection and
        Leak Check of the Blaze King "King" in
        Home PO2 — Dr. John Rau

1988    Woodstove Emission Sampling Methods
        Comparability Analysis and In-Situ
        Evaluation of New Technology Woodstoves,
        Task G — Final Report

1988    An In-Situ Residential Performance
        Evaluation of Conventional and New
        Woodheat Technologies in Whitehorse,
        Yukon Territory

1987    Field Investigations of Catalytic and Low
        Emissions Woodstove Paniculate
        Emissions, Efficiency and Safety

1987    Final Woodstove and Catalytic Combustion
        Inspections: NCWS Study Homes
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)

OMNI Environmental Services, Inc., Beaverton, OR; Prepared for
the Oregon Department of Environmental Quality, Portland, OR
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)

Proceedings of the 1988 Air Pollution Control Association Meeting,
Dallas, TX (88-89.3)
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)

Prepared for the Coalition of Northeastern Governors; New York State
Energy Research and Development Authority; and the U.S. Environmental
Protection Agency

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                           U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
            AUTHOR
         CATEGORY #1 — IN-HOME EMISSION STUDIES

DATE                  TITLE                                    PUBLICATION INFORMATION
34    OMNI Environmental
      Services, Inc.
35    OMNI Environmental
      Services, Inc.

36    Simons, Carl A.;
      Christiansen, Paul D.;
      Pritchett, Lyle C.;
      Buyerman, Glenn A.

37    Houck, James E.
38    Morgan, S.
      Ramdahl, T.;
      Schjoldager, I; Currie,
      L.A.; Hanssen, IE.;
      Moller, M.
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

1987    An In-Situ Performance Evaluation of the
        Catalytic Retrofit Devices

1987    Whitehorse Efficient Woodheat
        Demonstration
1986    A System to Obtain Time Integrated
        Woodstove Emission Samples
1986    Evaluating the Field Performance of High
        Efficiency and Catalytic Wood Stoves
1984    Ambient Impact of Residential Wood
        Combustion in Elverum, Norway
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)
OMNI Environmental Services, Inc., Beaverton, OR; Prepared for
the Oregon Department of Environmental Quality, Portland, OR

OMNI Environmental Services, Inc., Beaverton, OR; Prepared for
the City of Whitehorse, Whitehorse, Yukon
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)

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)

The Science of the Total Environment Vol. 36, Elsevier Science
Publishers B.V., Amsterdam, pp. 81-90

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                           U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
            AUTHOR
         CATEGORY #1 — IN-HOME EMISSION STUDIES

DATE                   TITLE                                    PUBLICATION INFORMATION
40    Harriett, Stockton G.
41    Hornig, James F.;
      Soderberg, Roger H.;
      Larson, Deborah

42    Sanborn, Cedric R.;
      Poirot, Richard L.; Heil,
      Gregory A.; Blanchet,
      Michael A.

43    Modera, M.P.;
      Sonderegger, R.C.
44    PEDCo —
      Environmental, Inc.
1981    Determination of Woodstove Efficiency
        under In-Home Conditions
1981     Ambient Air Assessment in a Rural New
         England Village where Wood is the
         Dominant Fuel

1981     Preliminary Analysis of the Ambient
         Impacts of Residential Woodburning in
         Waterbury, Vermont
1980    Determination of In-Situ Performance of
        Fireplaces
1977     Source Testing for Fireplaces, Stoves, and
         Restaurant Grills in Vail, Colorado
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

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, pp. 140-153
Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, pp. 231-241
Energy Performance of Buildings Group, Energy & Environment
Division, Lawrence Berkeley Laboratory, University of California,
Berkeley, CA (LBL-10701; UC-95d; EEB-EPB-80-8)

PEDCo — Environmental, Inc., Kansas City, MO

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                      U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                 CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
#             AUTHOR           DATE

1      Valenti, Joseph C.;           1998
       Clayton, Russell K.
Hubbard, A.J.              1995
McCrillis, Robert C.         1995
Tiegs, Paul E.              1995
Bighouse, Roger D.;         1994
Harriett, Stockton G.;
Houck, James E.; Tiegs,
Paul E.
                                                    TITLE

                                    Emissions from Outdoor Wood-Burning
                                    Residential Hot Water Furnaces
                                           Hazardous Air Emissions Potential from a
                                           Wood-Fired Furnace

                                           Review and Analysis of Emissions Data for
                                           Residential Wood-Fired Central Furnaces
                                           Design and Operating Factors which Affect
                                           Emissions from Residential Wood-Fired
                                           Heaters: Review and Update

                                           Woodstove Durability Testing Protocol
                 PUBLICATION INFORMATION

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)

Combustion Science and Technology, Vol. 108, pp. 297-309
Proceedings of the 88th Annual 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)

Proceedings of the 88th Annual Air & Waste Management Association
Meeting & Exhibition, San Antonio, TX (95-RP-137.02)
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)
Barnett, Stockton G.;        1993
Bighouse, Roger D.; Houck,
James E.
Bighouse, Roger D.; Houck,  1993
James E.; Barnett, Stockton
G.; McCrillis, Robert C.
                                           Final Report — Manufacturers Seminar on
                                           Woodstove Stress Testing
                                           Stress Testing of Woodstoves
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

Proceedings of the 86th Annual Air & Waste Management Association
Meeting
& Exhibition, Denver, CO (93-RP-136.05) (EPA-600/A-93-268) (NTIS
PB94-120011)

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                            U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                       CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
10
11
12
13
             AUTHOR
      Bighouse, Roger D.; Houck,   1993
      James E.
      Houck, James E.; Bighouse,   1993
      Roger D.
Karlsson, M.
Karlsson, M.; Gustavsson,    1993
L.
McCrillis, Robert C.
Watts, Randall R.;
Zweidinger, Roy B.


McCrillis, Robert C.
Jaasma, Dennis R.
 DATE                    TITLE

          Evaluation of Emissions and Energy
          Efficiencies of Residential Wood
          Combustion Devices Using Manufactured
          Fuels

          Reduction in Paniculate and Carbon
          Monoxide Emissions from Fireplace and
          Woodstoves with the Use of Sawdust/Wax
          Firelogs

1993      Emissions from Wood-Fired Domestic
          Central Heating Boilers - Load
          Dependence, (English Translation of
          Emissioner fran vedpannor -
          lastfohallandets betydelse)

          Characterization of Combustion Emissions
          from Wood-Fired Domestic Central Heating
          Boilers, (English Translation of
          Karaktarisering avrokgaser fran vedpannor),

1993      Comparison of Residential Oil Furnace and
          Woodstove Emissions
1993      Woodstove Emission Measurement
          Methods: Comparison and Emission Factors
          Update
                                                                                              PUBLICATION INFORMATION

                                                                            Science Applications International Corporation, Beaverton, OR;
                                                                            Prepared for the Oregon Department of Energy, Salem, OR
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

SP Report - Swedish National Testing Institute (SP),
Energy Division, p. 48
SP Report - Swedish National Testing Institute (SP),
Energy Division, p. 49
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

Environmental Monitoring and Assessment, volume 24, pp. 1-12

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                            U.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
      Harriett, Stockton G.
1992      Paniculate and Carbon Monoxide Emissions  OMNI Environmental Services, Inc., Beaverton, OR; Prepared for
          from the Use of Hazelnut Logs in a          the Hazelnut Growers of Oregon, Cornelius, OR
          Conventional Masonry Fireplace
15
       Barnett, Stockton G.
16     Champion Mark; et al.
1992      Paniculate and Carbon Monoxide Emissions
          from the Use of Palm Branch Logs in a
          Conventional Masonry Fireplace

1992      Fireplace Smoke and CO Emissions:
          Comparison of a Field Sampler with
          Reference Methods
17    Nielson, P.A.; Joergensen,    1992
      V.
18     Shelton, Jay W.
19     Stroud, T.
20
       Anonymous
                                           Mutagenic Activity in Samples of Emissions
                                           from Straw Combustion and Wood Chip
                                           Combustion, (English translation of
                                           Mutagen aktititet i prever af reggas fra halm
                                           - g flisfry)
                                 1992      Testing of Sawdust-Wax Firelogs in an
                                           Open Fireplace
                                 1992      Thermal Mass Solid Fuel Technology as a
                                           Low-Emission Residential Energy Option
1991      WHA Fireplace Emissions Test Method
          Procedures
OMNI Environmental Services, Inc., Beaverton, OR; Prepared for
Clean Burning Fuels, Inc., Tucson, AZ
Transactions of the A&WMA/EPA International Specialty
Conference, PM10 Standards and Nontraditional Paniculate
Source Controls, Volume II, TR-22; Published by Air & Waste
Management Association, Pittsburgh, PA, pp. 536-552
(ISBN 0-923204-09-1)

The Danish National Food Regulatory Administration
(Levnedsmiddelstyrelsen)  Report NEI-DE-744
Transactions of the A&WMA/EPA International Specialty Conference,
PM10 Standards and Nontraditional Paniculate Source Controls,
Volume II, TR-22; Published by Air & Waste Management Association,
Pittsburgh, PA, pp. 553-571 (ISBN 0-923204-09-1)

Transactions of the A&WMA/EPA International Specialty Conference,
PM10 Standards and Nontraditional Paniculate Source Controls,
Volume II, TR-22; Published by Air & Waste Management Association,
Pittsburgh, PA, pp. 572-584 (ISBN 0-923204-09-1)

No Publication Information Listed

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                             U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                       CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
#

21



22



23


24




25
26
27
28
       AUTHOR

Hayden, A.C.S.; Braaten,
R.W.
Stern, Curtis H.; Jaasma,
Dennis R.
anonymous
Burnet, Paul G; Houck,
James E.; Roholt, Robert B.
Karlsson, M.
Shelton, Jay W.; Sorensen,
Doug; Stern, Curtis H.;
Jaasma, Dennis R.
Stern, Curtis H.; Jaasma,
Dennis R.; Shelton, Jay W.
Bushnell, Dwight J.;
Haluzok, Charles;
Dadkhah-Nikoo, Abbas
 DATE                    TITLE

1991      Reduction of Fireplace and Woodstove
          Pollutant Emissions through the Use of
          Manufactured Firelogs

1991      Study of Emissions from Masonry
          Fireplaces — Final Report
1990      Continuation of the Design of a 12-Hour
          Catalytic Furnace

1990      Effects of Appliance Type and Operating
          Variables on Woodstove Emissions,
          Volume I — Report and Appendices A-C,
          Volume II — Appendices D-F

1990      Emissions from Small Scale Wood Burning
          - Comparison of Test Methods, (English
          translation of Emissioner vid smaklig
          vedeldning - jamforelse av
          provningsmetoder)

1990      Fireplace Emissions Test Method
          Development
1990      Final Report on the Masonry Heater
          Emissions Test Method Development
1989      Biomass Fuel Characterization: Testing and
          Evaluating the Combustion Characteristics
          of Selected Biomass Fuel — Final Report
                  PUBLICATION INFORMATION

Proceedings of the 84th Annual Air & Waste Management
Association Meeting & Exhibition, Vancouver, B.C.
Department of Mechanical Engineering, Virginia Polytechnic
Institute and State University, Blacksburg, VA; Prepared for
the Brick Institute of America, Reston, VA

Department of Energy, Mines and Resources, Canada
(Contract No. 23216-8-90005/01-SZ)

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)

Swedish Energy Agency (Statens energiverk)
(FBT 90/3, Project Number 276 359)
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

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

Department of Mechanical Engineering, Oregon State University,
Corvallis, OR; Prepared for the Bonneville Power Administration,
Portland, OR (DOE/BP-1363)

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                            U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                       CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
#

29
30
31
32
33
34
35
       AUTHOR
McCrillis, Robert C.
OMNI Environmental
Services, Inc.
Aiken, M.
Merrill, Raymond G.;
Harris, D. Bruce
 DATE
Leese, K.E.; Harkins, S.M.   1989
Burnet, Paul G.; Simons,     1988
Carl A.
Hayden, A.C.S.; Braaten,     1988
R.W.
1988
1988
1987
1987
36     Shelton, Jay W.; Gay, Larry   1987
                TITLE

Effects of Burn Rate, Wood Species,
Moisture Content and Weight of Wood
Loaded on Woodstove Emissions
Identification of Factors which Affect
Combustion Efficiency and Environmental
Impacts from Woodstoves, Task D — Final
Report

Techniques to Reduce the Emissions from
Existing Woodburning Appliances

Effects of Operating Variables on Emissions
from Woodstoves
Environmental Impacts of Advanced
Biomass Combustion Systems — Final
Report
Canadian Firelog Ltd. Emission Testing
Field and Laboratory Evaluation of a
Woodstove Dilution Sampling System
                                     Colorado Fireplace Report
                 PUBLICATION INFORMATION

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)

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)

Proceedings of the 1988 Air Pollution Control Association Meeting,
Dallas, TX (88-89.1)

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)

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)

Air Program, B.C. Research, Vancouver, B.C.; Prepared for
Canadian Firelog Ltd., Richmond, B.C.

U.S. Environmental Protection Agency, Air and Energy Research
Laboratory, Research Triangle Park, NC (EPA-600/D-87-216) (NTIS PB87-
210381)

Shelton Research, Inc., Sante Fe, NM; Prepared for the Colorado
Air Pollution Control Division, Denver, CO

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                            U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                       CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
#

37



38




39




40



41
       AUTHOR

Swinton, Michael C.;
Sinha, Robin P.; Haysom,
JohnC.

Swinton, Michael C.
Burnet, Paul G.; Edmisten,
Norman G.; Tiegs, Paul E.;
Houck, James E.; Yoder,
Rachel A.

Cottone, Lawrence E.;
Messer, Edward
44    Barnett, Stockton G.
                                 DATE
                                 1987
                                 1987
                                 1986
                                 1986
                          1986
      McCrillis, Robert C.;
      Merrill, Raymond G.;
      Westlin,P.R.; Weant, G.E.;
      Wagoner, D.E.

42    Shelton, Jay W.; Gay, Larry   1986
43     Tiegs, Paul E.; Burnet, Paul   1986
       G.
                          1985
                TITLE

Modifications and Refinement of the
Computer Model "Wood Burning
Simulator"
                 PUBLICATION INFORMATION

Scandia Consultants Limited; Prepared for Canada Mortgage
and Housing Corporation
Residential Combustion Venting Failure a
Systems Approach — Final Report —
Project 2 — Modifications And Refinements   Canada Mortgage and Housing Corporation
To The Flue Simulator Model
Scandia Consultants Limited, Scandia Sheltair Consortium; Prepared
for the Research Division, Policy Development and Research Sector,
Paniculate, Carbon Monoxide, and Acid
Emission Factors for Residential Wood
Burning Stoves


Test Method Evaluation and Emission
Testing for Rating Wood Stoves
Comparisons Between MM5, OM7, and
Draft ASTM Measurements of Wood Stove
Emissions
                                    Evaluation of Low-Emission Wood Stoves
                                    — Final Report

                                    Improving Flue Loss Methods for
                                    Measuring Wood Heater Thermal
                                    Performance
Journal of the Air Pollution Control Association, Vol. 36, No. 9,
pp. 1012-1018
U.S. Environmental Protection Agency, Air and Energy Engineering
Research Laboratory, Research Triangle Park, NC (EPA-600/2-86-100)
(NTISPB87-119897)

Proceedings of the  1986 Air Pollution Control Association Annual
Meeting (86-74.8) EPA-600/D-86-150) (NTIS PB86-223096)
                                        Shelton Research, Inc., Sante Fe, NM; Prepared for the
                                        California Air Resources Board, Sacramento, CA

                                        OMNI Environmental Services, Inc., Beaverton, OR
                                           Handbook for Measuring Woodstove          No Publication Information Listed
                                           Emissions and Efficiency Using the Condar
                                           System (The Manufacturer's Instructions for
                                           Source Sampling Method 41 of Oregon's
                                           D.E.Q.)

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                            U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                       CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
#             AUTHOR

45    Becker, Mimi; Harriett,
      Stockton G.; Cowden,
      James W.; Harriett, Lucy;
      Graham, Penny; Van Den
      Bossche, Krista; Hannan,
      Karen

46    Energy Task Force of the
      Urban Consortium for
      Technology Initiatives

47    McCrillis, Robert C;
      Merrill, Raymond G.


48    OMNI Environmental
      Services, Inc.
49     Shelton, Jay W.; Jaasma,
       Dennis R.
50     Shelton, Jay W.


51     Shelton, Jay W.

52     Shelton, Jay W.
53     Shelton, Jay W.;Barczys,
       C.
 DATE
1985
1985



1985



1985



1985



1985


1985

1985



1985
                TITLE

Residential Wood Combustion Emissions
and Safety Guidebook
Residential Space Heating with Wood:
Efficiency and Environmental Performance
Emission Control Effectiveness of a
Woodstove Catalyst and Emission
Measurement Methods Comparison

Standard Test Method for Determining the
Heat Output Range and Maximum Burn
Cycle Duration

Critical Assessment of Various Flue Loss
Methods for Solid Fuel Heater Efficiency
Measurement

ASTM Emissions and Efficiency Tests on
Four Stoves
                 PUBLICATION INFORMATION

Environmental Resource Center, Hiram College, Hiram, OH; Prepared
for the Council of Great Lakes Governors, Great Lakes Regional
Biomass Energy Program, Madison, WI
Energy Task Force of the Urban Consortium for Technology Initiatives,
Environmental Health and Energy Department, Energy Management
Division, Albuquerque, NM

Proceedings of the 78th Annual Meeting of the Air Pollution Control
Association, Detroit, MI (EPA-600/D-85-132) (NTIS PB85-218816)
OMNI Environmental Services, Inc., Beaverton, OR
Shelton Energy Research, Santa Fe, NM; Presented at the 1985
Annual Meeting of the American Society of Heating, Refrigerating
& Air Conditioning Engineers

Shelton Energy Research, Santa Fe, NM; Prepared for the
Wood Heating Alliance, Washington, DC
Overview of Efficiency Measuring Methods   Shelton Energy Research, Santa Fe, NM
Wood Stove Paniculate 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
Creosote — The Truth about Green Wood     Shelton Energy Research, Santa Fe, NM

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                             U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                        CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
#

54


55
56
57
58
59
60
62
       AUTHOR

Shelton, Jay W.
Harriett, Stockton G.
 DATE                   TITLE

1985      Is 100% Overall Energy Efficiency Possible
          in Solid Fuel Residential Heaters?
Allen, John M.; Piispanen,    1984
William H.; Cooke, Marcus
Lipari, Frank; Dasch, Jean    1984
M.; Scruggs, William F.

Shelton, Jay W.; Graeser,     1984
L.; Jaasma, Dennis R.
Tiegs, PaulE.;Edmisten,     1984
Norman G.; Hatch, Candice
L.

Truesdale, R.S.;Mack,       1984
K.L.; White, J.B.; Leese,
K.E.; Cleland, J.G.
Van der Heeden, D.J.         1984
61     Tennessee Valley Authority   1983
          Study of the Effectiveness of a Catalytic
          Combustion Device on a Wood Burning
          Appliance
          Aldehyde Emissions from Wood-Burning
          Fireplaces

          Sensitivity Study of Traditional Flue Loss
          Methods for Determining Efficiencies of
          Solid Fuel Heaters

          Technical Report — Comparative Analysis
          of Current Woodstove Technologies:
          Emissions and Efficiencies

          Characterization of Emissions from the
          Combustion of Wood and Alternative Fuels
          in a Residential Woodstove
          Vergelijkend Onderzoek naar de
          Luchtverontreiniging van 17 Kachels voor
          Vaste Brandstof (Dutch) — Comparison of
          Air Pollution by 17 Solid Fuel Stoves

          Residential Wood Heater Test Report —
          Phase II Testing, Volume I
1982      Woodstove Design and Control Mode as
          Determinants of Efficiency, Creosote
          Accumulation, and Condensable Paniculate
          Emissions
                  PUBLICATION INFORMATION

Shelton Energy Research, Santa Fe, NM


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)

Environmental Science & Technology, Vol. 18, No. 5, pp. 326-330


Shelton Energy Research, Santa Fe, NM; Presented at the 1984
Annual Meeting of the American Society of Mechanical Engineers
Proceedings of the 77th Annual Air Pollution Control Association
Meeting & Exhibition, San Francisco, CA
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)

Ministerie van Volkshuisvesting, Ruimtelijke Ordening en
Milieubeheer, Consumentenbond
Tennessee Valley Authority, Division of Energy Conservation and
Rates, Energy Use Test Staff, Chattanooga, TN

Proceedings of the Residential Wood & Coal Combustion —
Specialty Conference, the Air Pollution Control Association,
Louisville, KY, pp. 70-88

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                                 U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                            CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
ON
     #             AUTHOR

     63    Dasch, Muhlbaler


     64    Hayden, A.C.S.
     65
       Jaasma, Dennis R.
     66    Knight, C.V.
67     Ramdahl, Thomas;
       Alfheim, Ingrid; Rustad,
       Stale; Olsen, Torbjern

68     Sanborn, Cedric R.
                                  DATE
                                 1982
                                 1982
1982
                                 1982
                                      1982
                                      1982
     69     Shelton, Jay W.; McGrath,    1982
            I; Lewis, C.
     70     Shelton, Jay W.; Graeser,     1982
            L.
     71     Shelton, Jay W.; Lewis, C.    1982
                          TITLE

          Paniculate and Gaseous Emissions from
          Wood-Burning Fireplace

          Effects of Firing Rate and Design on
          Domestic Wood Stove Performance
Measurement Techniques and Emission
Factors for Hand-Fired Coalstoves
Emission and Thermal Performance
Mapping for an Unbaffled, Air-Tight Wood
Appliance and a Box-Type Catalytic
Appliance

Chemical and Biological Characterization of
Emissions from Small Residential Stoves
Burning Wood and Charcoal

Characterization of Emissions from
Residential Coal Stoves
                                           Relative Creosote Accumulation in Double-
                                           Wall Mass-Insulated Chimneys vs. Triple-
                                           Wall Air-Insulated Chimneys

                                           An Investigation of the Effects of Ambient
                                           Temperature and Forced Convection on
                                           Radiant Stove Efficiency

                                           Measured Creosote Reducing Effects of the
                                           Smoke Dragon, the Smoke Consumer, and a
                                           Barometric Draft Control
                  PUBLICATION INFORMATION

Environmental Science & Technology, Vol. 16, No. 10,
pp. 641-645

Proceedings of the Residential Wood & Coal Combustion —
Specialty Conference, the Air Pollution Control Association,
Louisville, KY, pp. 56-69

Proceedings of the Residential Wood & Coal Combustion —
Specialty Conference, the Air Pollution Control Association,
Louisville, KY, pp. 129-150

Proceedings of the Residential Wood & Coal Combustion —
Specialty Conference, the Air Pollution Control Association,
Louisville, KY, pp. 25-55
                                                   Chemosphere, Vol. 11, No. 6, pp. 601-611
                                                   Proceedings of the Residential Wood & Coal Combustion —
                                                   Specialty Conference, the Air Pollution Control Association,
                                                   Louisville, KY, pp. 151-160

                                                   Shelton Energy Research, Santa Fe, NM
                                                   Shelton Energy Research, Santa Fe, NM; Prepared for the
                                                   Wood Heating Alliance, Washington, DC; and Brookhaven
                                                   National Laboratory, Upton, NY

                                                   Shelton Energy Research, Santa Fe, NM

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                            U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                       CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
#

72


73



74
76
77
       AUTHOR
 DATE                    TITLE
Tennessee Valley Authority   1982
Truesdale, Robert S.
Allen, John M.; Cooke, W.   1981
Marcus
75     Allen, John M.
Barnett, Stockton G.
Barnett, Stockton G.; Shea,   1981
Damian
78     Brandon, Robert J.


79     Brandon, Robert J.
       Murray, D.



80     Brandon, Robert J.
          Residential Wood Heater Test Report -
          Phase I Testing
1982      Residential Stove Emissions from Coal and
          Other Alternative Fuels Combustion
          Control of Emissions from Residential
          Wood Burning by Combustion Modification
1981      Control of Emissions from Residential
          Wood Burning by Combustion Modification

1981      The Effects of Woodstove Design on
          Condensible Paniculate Emissions, In-
          Home Delivered Efficiency, and Creosote
          Formation Rate
          Effects of Woodstove Design and Operation
          on Condensible Paniculate Emissions
                          1981       Residential Wood Fired Furnaces: Results
                                     from a Demonstration of Advanced Designs

                          1981       Pellet Wood Stokers Evaluation and Testing
                                     of Available Systems
                          1981       An Assessment of the Efficiency and
                                     Emissions of Ten Wood Fired Furnaces
                  PUBLICATION INFORMATION

Tennessee Valley Authority, Division of Energy Conservation
and Rates, Energy Use Test Staff, Chattanooga, TN

Proceedings of the Residential Wood & Coal Combustion —
Specialty Conference, Air Pollution Control Association,
Louisville, KY, pp. 115-128

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)

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, pp. 167-190

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, pp. 268-269
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

Proceedings of Energy from Biomass and Wastes V, Institute
of Gas Technology, Chicago, IL

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

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, p. 267

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                            U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                       CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
#

81
82
83
84
85
86
87
       AUTHOR
DATE
Butcher, Samuel S.;         1981
Ellenbecker, Michael J.
Cooke, W. Marcus; Allen,    1981
John M.; Hall, Robert E.
Dickinson, Roger; Payne,     1981
Robert C.
Giammer, Robert D.         1981
Hall, Robert E.              1981
Harper, Jerome P.; Knight,   1981
C.V.
Hubble, B.R.; Harkness,      1981
J.B.L.
                TITLE

Paniculate Emission Factors for Small
Wood and Coal Stoves
         Characterization of Emissions from
         Residential Wood Combustion Sources
         United Kingdom Efficiency Tests and
         Standards for Residential Solid Fuel Heating
         Appliances
         Evaluation of Emissions from Residential
         Coal-Fired Boilers under Stokeless
         Operation


         Emissions Assessment of a Standard Wood
         Stove Comparing Stack versus Dilution
         Tunnel Sampling

         Measurement of Wood Heater Thermal and
         Emissions Performance
         Results of Laboratory Tests on Wood Stove
         Efficiency and Emissions
                 PUBLICATION INFORMATION

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

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

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

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

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, p. 270
                                        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

                                        Proceedings of the Wood Heating Seminars 1980/1981, Wood
                                        Heating Alliance, Washington DC, p. 277

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                            U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                       CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
89
90
92
93
94
95
              AUTHOR
      Hughes, Thomas W.;
      DeAngelis, Darryl G.
      Jaasma, Dennis R.
91    Jaasma, Dennis R.
      Kowalczyk, John F.;
      Bosserman, Peter B.;
      Tombleson, Barbara J.
      Macumber, Dale W.;
      Jaasma, Dennis R.
      Muhlbaier, Jean L.
                                  DATE
      Hubble, B.R.; Stetter, J.R.;    1981
      Gebert, E.; Harkness,
      J.BL.;Flotard, R.D.
1981
1981
                                 1981
1981
1981
1981
      Peters, J.A.; Hughes, T.W.;    1981
      DeAngelis, D.G.
                          TITLE

          Experimental Measurements of Emissions
          from Residential Wood-Burning Stoves
Emissions from Coal-Fired Residential
Combustion Equipment
Catalysis of Woodstove Effluent
Measurements of Chemical Changes Due to
Catalysis of Woodstove Effluent

Paniculate Emissions from New Low
Emission Wood Stove Designs Measured by
EPA Method V
Efficiency and Emissions of a Hand-Fired
Residential Coalstove
A Characterization of Emissions from
Wood-Burning Fireplaces
          Wood Combustion Emissions at Elevated
          Altitudes
                  PUBLICATION INFORMATION

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

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

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

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, pp. 221-230

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

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

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

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, pp. 252-259

-------
                             U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                       CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
>
o
#             AUTHOR

96     Peters, James A.
97     Peters, J.A.;Hughes, T.W.;
       DeAngelis, D.G.
98     Pullen, Donald R.; Holden,
       Roger
99     Roberts, John; Austin,
       Fred; Rossano, A.T.;
       Willenberg, Jay
100    Rudling, Lars; Bengt,
       Ahlingt; Lofroth, Goran
101    Rustad, Stale; Olsen,
       Torbjern
102    Sanborn, Cedric R.;
       Blanchet, Michael
 DATE                    TITLE

1981      POM Emissions from Residential
          Woodburning: An Environmental
          Assessment
1981      Wood Combustion Emissions at Elevated
          Altitudes
1981      Design Features and Test Experiences with
          Domestic Wood Fired Heaters in New
          Zealand
1981      Measuring and Improving the Efficiency of
          Large Wood-Fired Furnaces — Impact on
          Emissions and Fuel Use
1981      Chemical and Biological Characterization of
          Emissions from Combustion of Wood and
          Wood-Chips in Small Furnaces and Stoves


1981      Charcoal — The Feasible Fuel for a Small,
          Automatically Fed, Clean Burning
          Residential  Stove
1981      Paniculate Emissions from Residential
          Wood Combustion in Vermont
                  PUBLICATION INFORMATION

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

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

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

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

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

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

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. 188-198

-------
                                 U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                            CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
     #             AUTHOR

     103    Shelton, Jay W.
 DATE
1981
     104    Shelton, Jay W.; McGrath,    1981
            Jane
     105    Shelton, Jay W.; Alfano,      1981
            Joseph; Buchen, Anthony

     106    Shelton, Jay W.             1981
     107    Shelton, Jay W.             1981
£    108    Shelton, Jay W.;Barczys,     1981
            Cathleen

     109    Short, C.A.                 1981
     110    VanDewoestine, Robert V.;   1981
            Zimar, Frank

     111    Zimar, Frank;               1981
            VanDewoestine, Robert V.;
            Allaire, Roger A.
     112   Day, Bill                   1980
                TITLE

Thermal Performance Testing Methods for
Residential Solid Fuel Heaters

The Effects of Fuel Moisture Content,
Species and Power Output on Creosote
Formation

The Effects of Creosote on Stovepipe Heat
Transfer

Results of the Research on Catalytic
Combustion on Wood Stoves
                 PUBLICATION INFORMATION

Shelton Energy Research, Santa Fe, NM


Shelton Energy Research, Santa Fe, NM



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

          The Effect of Catalytic Combustion on
          Creosote Reduction, Combustion Efficiency,
          and Pollution Abatement for Residential
          Wood Heaters

          Wood Stove Durability: A Literature Review
          with Illustrations
                                         Shelton Energy Research, Santa Fe, NM
                                        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

                                        Proceedings of the Wood Heating Seminars 1980/1981, Wood
                                        Heating Alliance, Washington DC, pp. 154-166

                                        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

                                        Northwest Information Enterprises, Beaverton, OR; Produced for
                                        Western Solar Utilization Network, Portland, OR (WSUN-27)

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                             U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                       CATEGORY #2 — LABORATORY EMISSION AND ENGINEERING STUDIES
#
AUTHOR
120    Allen, John M.
121    Brandon, Robert J.
122    Jaasma, Dennis R.;
       Shelton, Jay W.
DATE                   TITLE
113    DeAngelis, D.G.; Ruffin,     1980
       D.S.; Peters, J.A.; Reznik,
       R.B.
114    DeAngelis, D.G.; Ruffin,     1980
       D.S.; Reznik, R.B.
115    State of California Air       1980
       Resources Board

116    Butcher, Samuel S.;          1979
       Sorenson, Edmund M.

117    Butcher, Samuel S.;          1977
       Buckley, Douglas I.

118    Snowden, W.D.; Alguard,    1975
       D.A.; Swanson, G.A.;
       Stolberg, W.E.
119    British Standards Institute    1969
                              Source Assessment: Residential Combustion
                              of Wood
                              Preliminary Characterization of Emissions
                              from Wood-Fired Residential Combustion
                              Emissions from Residential Fireplaces —
                              Report No. C-80-027

                              A Study of Wood Stove Paniculate
                              Emissions

                              A Preliminary Study of Paniculate
                              Emissions from Small Wood Stoves

                              Source Sampling Residential Fireplaces for
                              Emission Factor Development
                              Recommendations for the Design and
                              Testing of Smoke Reducing Solid Fuel
                              Burning Domestic Appliances
                   Undated    Control of Emissions from Residential
                              Wood Burning by Combustion Modification

                   Undated    An Assessment of the Efficiency and
                              Emissions of Ten Wood Fired Furnaces

                   Undated    Proposed Method for Determination of
                              Energy Efficiency of Wood Heaters
                  PUBLICATION INFORMATION

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)

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)

State of California Air Resources Board, Stationary Source Control
Division, Engineering Evaluation Branch, Eureka, CA

Journal of the Air Pollution Control Association, Vol. 29, No. 7,
pp. 724-728

Journal of the Air Pollution Control Association, Vol. 27, No. 4,
pp. 346-348

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)

British Standards Institute, British Standards House,
London, England
                                                  Battelle — Columbus Laboratories, Columbus, OH
                                                  Institute of Man and Resources, Charlottetown,
                                                  Prince Edward Island, Canada

                                                  Virginia Polytechnic Institute and State University, Blacksburg, VA;
                                                  and Shelton Energy Research, Santa Fe, NM

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                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                                     CATEGORY #3 — WOOD USE AND ENERGY SURVEYS
#             AUTHOR

1      Kochera, Andrew

2      Energy Information
       Administration

3      Energy Information
       Administration

4      Energy Information
       Administration

5      Oregon Department of
       Environmental Quality

6      Sifford, Alex
       Energy Information
       Administration

       Energy Information
       Administration

       OMNI Environmental
       Services, Inc.
10     Energy Information
       Administration

11     ES Field Services, Inc.
12     Kelly, Lou Ellyn; Park,
       Y.M.
 DATE                    TITLE

1997      Residential Use of Fireplaces

1995      Housing Energy Consumption and
          Expenditures 1993

1995      State Energy Data Report 1993 —
          Consumption Estimates

1994      Estimates of U. S. Biofuels Consumption
          1992

1994      Portland — 1993 Oregon Woodheating
          Survey, Overview Report

1994      Residential Biofuel Marketing & Delivery
          Method Study

1993      Housing Energy Consumption and
          Expenditures 1990; Supplement: Regional

1993      Housing Energy Consumption and
          Expenditures 1990

1992      Study of Firewood Sources and Costs in
          Klamath Falls, Oregon and Sandpoint,
          Idaho

1991      Estimates of U. S. Biofuels Consumption
          1990

1991      Pocatello Air Quality RWC Device Usage,
          Survey Results

1991      Klamath Falls Wood Heating Survey, 1991
                  PUBLICATION INFORMATION

Housing Economics, pp. 10-11

Energy Information Administration, Office of Energy Markets
and End Use, Washington, DC (DOE/EIA-0321(93))

Energy Information Administration, Office of Energy Markets
and End Use, Washington, DC (DOE/EIA-0214(93))

Energy Information Administration, Office of Energy Markets
and End Use, Washington, DC (DOE/EIA-0548(92))

Oregon Department of Environmental Quality,  Air Quality Division,
Portland, OR

Oregon Department of Energy, Salem, OR
Energy Information Administration, Office of Energy Markets
and End Use, Washington, DC (DOE/EIA-0321(90)/S)

Energy Information Administration, Office of Energy Markets
and End Use, Washington, DC (DOE/EIA-0321(90))

OMNI Environmental Services, Inc. Beaverton, OR; Prepared for
the Air & Waste Management Association, Pacific Northwest
International Section (PNWIS), Bellevue, WA

Energy Information Administration, Office of Energy Markets
and End Use, Washington, DC (DOE/EIA-0548(90))

ES Field Services, Inc.; Prepared for Marketing Research,
Boise, ID

Klamath County Department of Health Services, Klamath Falls, OR;
Oregon Department of Environmental Quality, Air Quality Division,
Portland, OR

-------
                                  U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                                         CATEGORY #3 — WOOD USE AND ENERGY SURVEYS
   #             AUTHOR

   13     U.S. Department of
          Agriculture; U.S. Forest
          Service
    14     Zamula, William W.
    15     Greene, William T.;
          Simons, Carl A.
    16     Armitage, Sarah V.
>    17    Steffel, Richard
    18     Cote, William A.; Kaleel,
          Robert J.
    19     Force, Jo Ellen
   20     Hayden, A.C.S.; Braaten,
          R.W.
   21     Oregon Department of
          Environmental Quality
 DATE                    TITLE

1991      Wenatchee National Forest, Naches Ranger
          District, Environmental Assessment,
          Personal Use Firewood Program and
          Appendix

1989      Directorate for Economic Analysis — Room
          Heating Equipment Exposure Survey —
          Final Report

1988      Estimating the Volume of Residential Wood
          Burning in the Pacific Northwest and
          Alaska, Task C — Final Report
1987      Report on the 1987 Klamath Falls Area
          Wood Heating Survey

1986      1986 Missoula Wood-Use Survey —
          Residential Wood Burning and Pollutant
          Emissions

1985      A Survey of Residential Combustion of
          Wood and Coal in Colorado
1985      Evaluation of Residential Wood Energy Use
          in Idaho — Final Report

1985      Wood Stove Operation and Advanced
          Design to Reduce Emissions of Incomplete
          Combustion Products

1985      Medford Area Wood Heating Survey
                  PUBLICATION INFORMATION

U.S. Department of Agriculture; U.S. Forest Service, Pacific
Northwest Region, Wenatchee National Forest, Naches Ranger
District, Wenatchee, WA
U.S. Consumer Product Safety Commission, Washington, DC
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)

Oregon Department of Environmental Quality, Air Quality Division,
Program Planning and Development, OR, Section Report No. 87-11

Eco-Resource Systems, Missoula, MT; Prepared for the Missoula
City-County Health Department, Missoula, MT
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

Department of Forest Resources, University of Idaho, Moscow, ID;
Prepared for the Idaho Department of Water Resources, Boise, ID

Canadian Combustion Research Laboratory, ERL/CANMET, Energy,
Mines & Resources Canada, Ottawa, Canada; Prepared for the
Northeast Regional Air Pollution Conference, Amherst, MA

Oregon Department of Environmental Quality, Air Quality Division,
Portland, OR

-------
                               U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
#             AUTHOR

22     Church, Scott; Steffel,
       Richard; Vallie, Robin;
       Grenfell, Judy

23     Church, Scott; Steffel,
       Richard; Vallie, Robin

24     Energy Information
       Administration
25     Lippert, Frederick W.;
       Dungan, Jennifer L.

26     Skog, Kenneth E.;
       Watterson, Irene A.

 27    Martin, Werner;
       Koenigshofer, Daniel R.
28     Simmons Market Research
       Bureau, Inc.

29     Butcher, Thomas A.; Isler,
       Robert J.
30     High, Colin
    CATEGORY #3 — WOOD USE AND ENERGY SURVEYS

 DATE                    TITLE                                     PUBLICATION INFORMATION
1984
1984
1984
1983
1983
1982
1982-
present

1981
1981
1983 Wood-Cutting Permit Survey, A Study   Environmental Health Division, Missoula City-County Health
of Firewood Collection and Storage Patterns   Department, Missoula, MT
among Wood Burners in Missoula, Montana
1983 Wood-Cutting Permit Survey
Estimates of U.S. Wood Energy
Consumption 1980-1983
Residential Firewood Use in the U.S.
Survey Completion Report — Residential
Fuelwood Use in the U.S.: 1980-81

Survey and Analysis of Current European
Technologies for Wood Combustion
Simmons Study of Media & Markets
Coal-Oil Mixtures — An Alternative Fuel
for the Commercial Markets and Large
Residential Markets
The Wood Resource and Its Use for Energy
in the U.S.
Missoula City-County Health Department, Missoula, MT
Energy Information Administration, Office of Coal, Nuclear,
Electric and Alternate Fuels, U.S. Department of Energy,
Washington, DC (DOE/EIA-0341(83))

Science, Vol. 219, pp. 1425-1427
U.S. Department of Agriculture; U.S. Forest Service, Forest
Products Laboratory, Madison, WI

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)

Simmons Market Research Bureau, Inc.
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

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. 670-679

-------
                                 U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
   #             AUTHOR

   31     Petty, P.; Hopp, W.;
          Chockie, A.
   32     Strehler, Arno
>
ON
                                        CATEGORY #3 — WOOD USE AND ENERGY SURVEYS
 DATE
1981
1981
   33     Wainwright, Phyllis Brooks   1981
   34     Mediamark Research Inc.
   35     Bernergard, Leif
1979 -
present

Undated
                TITLE

Biomass Energy Utilization in the Pacific
Northwest: Impacts Associated with
Residential Use of Solid Fuels
Energy from Straw and Woodwaste
                 PUBLICATION INFORMATION

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

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
Wood Energy — The North Carolina Effort   Proceedings of the Wood Heating Seminars 1980/1981, Wood
                                        Heating Alliance, Washington DC, pp. 260-265

Mediamark Research Household & Personal   Mediamark Research Inc.
Appliances, Etc. — Report
Small-Scale Solid Fuel Combustion in
Sweden
National Environmental Protection Board, Solna, Sweden

-------
                        U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                      CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
#             AUTHOR

1      Houck, James E.
Klinedinst, Donna B.;
Klouda, George A.; Currie,
Lloyd A.; et al.


Lewis, Charles W.;
Zweidinger, Roy B.;
Claxton, Larry D.; et al.


Lewtas, Joellen
Lewtas, Joellen; Walsh,
D.B.; Lewis, C.W.;etal.
Stevens, R.K.; Hoffman,
A.J.; Baugh, J.D.; et al.
McCrillis, Robert C;
Watts, Randall R.; Warren,
Sarah H.
 DATE                    TITLE

1993      Atmospheric Emissions of Carbon Dioxide,
          Carbon Monoxide, Methane, Non-Methane
          Hydrocarbons, and Sub-Micron Elemental
          Carbon Particles from Residential Wood
          Combustion

1993      Radiocarbon Measurements of Extractable
          Organic Matter from the Integrated Air
          Cancer Project Study in Roanoke, VA
1993      Source Apportionment of Fine Particle
          Organics and Mutagenicity in Wintertime,
          Roanoke
1993      Complex Mixtures of Air Pollutants:
          Characterizing the Cancer Risk of
          Polycyclic Organic Matter

1993      The Integrated Air Cancer Project:
          Overview of Roanoke Study and
          Comparison to Boise Study


1993      A Comparison of Air Quality Measurements
          in Roanoke, VA, and Other Integrated Air
          Cancer Project Monitoring Locations
1992      Effects of Operating Variables on PAH
          Emissions and Mutagenicity of Emissions
          from Woodstoves
                                                                                               PUBLICATION INFORMATION

                                                                              Proceedings of the 86th Annual Air & Waste Management
                                                                              Association Meeting & Exhibition, Denver, CO (93-RP136.01)
                                                                                    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

                                                                                    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

                                                                                    Environmental Health Perspectives, Vol. 100, pp. 211-218
                                                                                    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

                                                                                    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

                                                                                    Journal of Air & Waste Management Association, Vol. 42, No. 5,
                                                                                    pp. 691-694 (EPA-600/J-92-226) (NTIS PB92-195809)

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                                 U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                                CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
                 AUTHOR
>
oo
    10
    11
    12
Steiber, Raymond S.;
McCrillis, Robert C;
Dorsey, James A.; Merrill,
Raymond G.

Lewis, Charles W.;
Stevens, Robert K.;
Claxton, Larry D.;
Barraclough, Donna;
Klouda, George A.

Steiber, Raymond S.;
McCrillis, Robert C.
Anderson, Norman
Rau, John A.
    13     Rau, John A.
    14     U.S. Government
          Interagency Program's
          Pacific Northwest and
          Alaska Regional Bioenergy
          Program
 DATE                    TITLE

1992      Characterization of Condensible and
          Semivolatile Organic Materials from Boise
          Woodstove Samples


1991      Source Apportionment of Mutagenic
          Activity of Fine Particle Organics in Boise,
          Idaho
1991      Comparison of Emissions and Organic
          Fingerprints from Combustion of Oil and
          Wood

1989      Final Report — Risk Assessment Document
          for Residential Wood Combustion
          Emissions

1989      Tracers of Pollution from Wood Burning
          and Receptor Modeling
                           1989       Do Residential Wood Smoke Particles Lose
                                     Organic Carbon during Their Atmospheric
                                     Residence Time? — A Receptor Modeling
                                     Study

                           1989       Environmental Impact of Wood Combustion
                                     in Residential Woodstoves
                 PUBLICATION INFORMATION

Proceedings of the 85th Annual Air & Waste Management Association
Meeting & Exhibition, Kansas City, MO (92-118.03) (EPA-600/A-92-160)
(NTIS PB92-206606)
                                                                                       Proceedings of the 84th Annual Air & Waste Management Association
                                                                                       Meeting & Exhibit (91-131.3)
Proceedings of the 84th Annual Air & Waste Management Association
Meeting & Exhibition, Vancouver, BC, pp. 2-10 (91-136.2) (EPA-600/D-91-
152) (NTIS PB91-223222)

Environmental Toxicology Program, Environmental Health Unit,
Division of Disease Control, Bureau of Health, ME
(Appropriation #1310-1012)

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)

Proceedings of the 82nd Annual Air & Waste Management Association
Meeting & Exhibition, Denver, CO (89-145.5)
                                                   Woodstove Research Summaries, U.S. Government Interagency
                                                   Program's Pacific Northwest and Alaska Regional Bioenergy
                                                   Program Yearbook, pp. 25-30 (DOE/BP-1179)

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                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                            CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
#

15
16
17
20
       AUTHOR
U.S. Government
Interagency Program's
Pacific Northwest and
Alaska Regional Bioenergy
Program

Wolgamott, D. Mitch;
Erickson, Spencer L.


Burton. Robert M.
 18    Cupitt, Larry T.
19     Cupitt, Larry T.
Currie, L.A.
 DATE                    TITLE

1989      Environmental Impact of Advanced
          Biomass Combustion Systems
1989      Carbon Monoxide in a Wood Burning
          Community
1988      Final Design and Field Evaluation of the
          High Volume PM2 5 Virtual Impactor
                           1988       Transformation of Boise Sources: The
                                     Production and Distribution of Mutagenic
                                     Compounds in Wood Smoke and Auto
                                     Exhaust
                           1988       The Integrated Air Cancer Project:
                                     Overview and Boise Survey Results
1988      What Should We Measure? Aerosol Data:
          Past and Future
                 PUBLICATION INFORMATION

Woodstove Research Summaries, U.S. Government Interagency
Program's Pacific Northwest and Alaska Regional Bioenergy
Program Yearbook, pp. 30-32 (DOE/BP-1179)
Proceedings of the 26th Annual Air & Waste Management Association,
Pacific Northwest International Section Meeting & Exhibition,
Spokane, WA

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, VTP-10, Pittsburgh, PA, pp. 890-895 (EPA-600/9-88-015)
(NTIS PB90-225863)

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, VTP-10, Pittsburgh, PA, pp. 885-889 (EPA-600/9-88-015)
(NTIS PB90-225863)

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, VTP-10, Pittsburgh, PA, pp. 799-803 (EPA-600/9-88-015)
(NTIS PB90-225863)

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, VTP-10, Pittsburgh, PA, pp. 853-863 (EPA-600/9-88-015)
(NTIS PB90-225863)

-------
                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                            CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
#             AUTHOR

21     Hawthorne, Steven B.
22     Highsmith, V. Ross
23     Houck, James E.; Simons,
       Carl A.; Pritchett, Lyle C.
 24    Lewis, Charles W.;
       Baumgardner, Ralph E.;
       Stevens, Robert K.;
       Claxton, Larry D.; Lewtas,
       Joellen

25     Lewis, Charles W.
26     McMullen, Roy G.; Evans,
       Dallas E.
                                  DATE                   TITLE

                                 1988      Methoxylated Phenols as Candidate Tracers
                                           for Atmospheric Wood Smoke Pollution
                                 1988      Impact of Residential Wood Combustion
                                           and Automotive Emissions on the Boise,
                                           Idaho Airshed
                                 1988      Estimating Carbon Monoxide Air Quality
                                           Impacts from Woodstoves, Task A — Final
                                           Report
                                 1988      The Contribution of Woodsmoke and Motor
                                           Vehicle Emissions to Ambient Aerosol
                                           Mutagenicity
                                 1988       Sources of Fine Particle Organic Matter in
                                            Boise
                                 1988      Fireplaces and Carbon Monoxide Levels in
                                           Houston, Texas during Exceedances of the
                                           8-Hour Average Carbon Monoxide Standard
                                           1983 through 1986
                  PUBLICATION INFORMATION

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)

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)

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)

Environmental Science and Technology, Vol. 22, No. 8, p.  968
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)

Proceedings of the 81st Annual Air and Pollution Control Association
Meeting, Dallas, TX

-------
                                 U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                                CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
   #             AUTHOR

   27     Merrill, Raymond G., Jr.
 DATE
1988
   28     Steiber, R.S.
1988
   29     Stevens, R.K.
1988
~   30    Watts, R.
1988
   31     Zweidinger, Roy
1988
   32     Bell, Douglas A.
1987
                TITLE

Semivolatile and Condensible Extractable
Organic Materials Distribution in Ambient
Air and Woodstove Emissions
GC/MS Analysis of Woodstove Emissions
and Ambient Samples from a Wood Smoke
Impacted Area
Annular Denuder Results from Boise, ID
Mutagenicity of Organics Associated with
PM2 5 and PM10 HiVol Particles from a
Wood Smoke Impacted Residential Area
Distribution of Volatile Organic
Hydrocarbons and Aldehydes during the
IACP Boise, Idaho Residential Study
Non-Aqueous Ion Exchange
Chromatography as a Preparative
Fractionation Method for Short Term
Bioassay Analysis of Wood Smoke Extracts
                 PUBLICATION INFORMATION

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)

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)

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)

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)

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)

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)

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                                 U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                                CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
>
OJ
   #             AUTHOR

   33     Braaten, R.W.




   34     Claxton, Larry D.




   35     Cupitt, Larry T.
   36     Greene, William T.;
          Freeburn, Scott A.
   37     Highsmith, V. Ross
   38     Houck, James E.
   39     Khalil, M.A.K.;
          Rasmussen, R.A.; Rau,
          John A.
 DATE                    TITLE

1987      Effects of Retrofit to Reduce Emissions from
          Existing Wood Stoves
1987      The Mutagenicity of Ambient and Source
          Samples from Woodsmoke Impacted Air
          Sheds
1987      IACP Emission: Transformations and Fate
1987      Preliminary Health Effects Evaluation for
          Pollutants Generated by Field Burning,
          Slash Burning, and Residential Wood
          Combustion

1987      The Collection of Neighborhood Air
          Samples Impacted by Residential Wood
          Combustion in Raleigh, NC and
          Albuquerque, NM

1987      The Contribution of Residential Wood
          Combustion of Respirable and Inhalable
          Paniculate Concentrations in Missoula,
          Montana

1987      Air Pollution from Residential Wood
          Burning: A Case Study in Olympia, WA
                 PUBLICATION INFORMATION

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)

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)

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)

OMNI Environmental Services, Inc., Beaverton, OR; Prepared for
the Oregon Department of Environmental Quality, Eugene, OR
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)

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)

Proceedings of the 80th Annual Air Pollution Control Association
Meeting, New York, NY (87-101.1)

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                                 U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                                CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
>
OJ
   #             AUTHOR

   40     Klouda, George A.




   41     Lewtas, Joellen




   42     Merrill, Raymond G.
   43     Merrill, Raymond G.;
          Brusick, David
   45     Zweidinger, Roy
   46     Bell, D.A.;Kamens, R.M.;
          Claxton, Larry D.; Lewtas,
          Joellen

   47     Buchanan, James W.;
          Shutian, Li; Galloway,
          Clifton
 DATE                    TITLE

1987      The Source Apportionment of Carbonaceous
          Products by Micro-Radiocarbon
          Measurements for the Integrated Air Cancer
          Project (IACP)

1987      Overview of the Integrated Air Cancer
          Project
1987      Progress toward Identifying Source Specific
          Tracers
1987      Mutagenicity and Toxicity of Residential
          Wood Combustion Residue Samples
   44     Schonburn, Michael; et al.    1987
          Options for Reducing Emissions from Wood
          Burning Units in the Denver Metropolitan
          Area
1987      Volatile Organic Hydrocarbon and
          Aldehyde Composition in Raleigh, NC
          during the 1985 Woodsmoke Study


1986      Photoreaction of Wood Smoke Particles:
          Destruction and Creation of Mutagens in
          Sunlight

1986      A Refinement of the Potassium Tracer
          Method for Residential Wood Smoke
                 PUBLICATION INFORMATION

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)

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)

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)

U.S. Environmental Protection Agency, Air and Energy Engineering
Laboratory, Research Triangle Park, NC; and Hazelton Laboratories
of America, Kensington, MD

Denver Metropolitan Air Quality Council, Denver, CO; and Colorado
University, Denver Graduate School of Public Affairs, Denver, CO
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)

Proceedings of the 79th Annual Air Pollution Control Association
Meeting, Minneapolis, MN
Proceedings of the 79th Annual Air Pollution Control Association
Meeting, Minneapolis, MN (86-77.6)

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                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                             CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
>
OJ
#             AUTHOR           DATE

48     Buchanan, James W.         1986
49     Edgerton, S.A.; Khalil,       1986
       M.A.K.; Rasmussen, R.A.
50     Gebhart, D. Howard;         1986
       Anderson, Stephen R.
 51    Kleindienst, Tadeusz E.;      1986
       Shepson, Paul B.; Edney,
       Edward O.; Claxton, Larry
       D.; Cupitt, Larry T.

52     Kleindienst, T.E.; Shepson,    1986
       P.B.; Edney, E.G.
53     Klouda, George A.; Currie,    1986
       L.A.; Donahue, D.J.; Jull,
       A.J.T.;Naylor, M.H.

54     Leese, K.E.; McCrillis,        1986
       Robert C.

55     OMNI Environmental        1986
       Services, Inc.
                TITLE

A Refinement of the Potassium Tracer
Method for Residential Wood Smoke
Source Emission Characterization of
Residential Wood-Burning Stoves and
Fireplaces: Fine Particle/Methyl Chloride
Ratios for Use in Chemical Mass Balance
Modeling

A Study Design for Characterization of
Residential Wood Combustion Impacts in
Suburban Settings Case Study: Fort Collins,
Colorado

Wood Smoke: Measurement of the
Mutagenic Activities of Its Gas- and
Particulate-Phase Photooxidation Products
Mutagenic Activities of Wood Smoke
Photooxidation Products
Urban Atmospheric 14CO and 14CH4
Measurements by Accelerator Mass
Spectrometry

Integrated Air Cancer Project, Source
Measurement

Effects of Thermal Stress on Catalytic
Combustion Performance — Volume I
                                                                                                          PUBLICATION INFORMATION

                                                                                        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)

                                                                                        Environmental Science and Technology, Vol. 20, No. 8, pp. 803-807
                                                                                        Proceedings of the 79th Annual Air Pollution Control Associations
                                                                                        Meeting, Minneapolis, MN (86-74.3)
                                                                                        Environmental Science and Technology, Vol. 20, No. 5, pp. 493-501
                                                                                        U.S. Environmental Protection Agency, Atmospheric Sciences
                                                                                        Research Laboratory, Research Triangle Park, NC (EPA-600/3-86-049)
                                                                                        (NTIS PB86-239837)

                                                                                        Radiocarbon, Vol. 28, No. 2A, pp. 625-633
                                                                                        Proceedings of the 79th Annual Air Pollution Control Association
                                                                                        Meeting, Minneapolis, MN (EPA-600/D-86-152) (NTIS PB86-222924)

                                                                                        OMNI Environmental Services, Inc.; Prepared for the Matsushita
                                                                                        Battery Industrial Co., Ltd., Osoka, Japan

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                                   U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
#
56
AUTHOR
Rau, John A.
DATE
1986
TITLE
Residential Wood Combustion Aerosol
PUBLICATION INFORMATION
Ph. D. Dissertation, Oregon Graduate Center, Chemical, Biological,
UJ
(Jl
    57    Edgerton, Sylvia A.
    58
    59
    60
    61
Inoye, Daniel
Kamens, Richard M; Bell,
Douglas A.; Dietrich,
Andrea; Perry, Jean;
Goodman, Randall;
Claxton, Larry D.; Tejada,
Sylvestre

Rau, John A.; Huntzicker,
James J.
    62    Stapleton, Jim
                            1985
Environmental Research &    1985
Technology, Inc.
1985
1985
1985
                            1985
    63     Core, John E.; Cooper, John   1984
          A.; Neulicht, Roy M.
Characterization as a Function of Size and
Source Apportionment Using Chemical
Mass Balance Modeling

Gaseous Tracers in Receptor Modeling:
Methyl Chloride Emission from Wood
Combustion

Air Quality Monitoring and Control for the
City of Fort Collins — Volume IV: Results
of the 1984-1985 Winter Residential Wood
Combustion Study

Estimation of Carbon Monoxide and
Paniculate Emissions from Woodburning
Devices in the Fresno/Clovis Metropolitan
Area

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

Size Distribution and Chemical
Composition of Residential Wood Smoke

Air Pollution Due to Residential Space
Heating in the Mid-Hudson Valley

Current and Projected Impacts of
Residential Wood Combustion on Pacific
Northwest Air Quality
                                                                                          and Environmental Sciences Department, Beaverton, OR
                                                    Ph. D. Dissertation, Oregon Graduate Center, Environmental Science
                                                    Department, Beaverton, OR
                                                    Prepared for the City of Fort Collins Community Development
                                                    Department Planning Division, Fort Collins, CO
No Publication Information Listed
Environmental Science and Technology, Vol. 19, No. 1, pp. 63-69
Proceedings of the 78th Annual Air Pollution Control Association
Meeting, Detroit, MI (85-43.3)

Hudsonia Limited, Bard College, Annandale, NY; Prepared for the
Central Hudson Gas and Electric Corp., Poughkeepsie, NY

Journal of the Air Pollution Control Association, Vol.31, No. 2,
pp. 138-143

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                                 U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                                CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
UJ
ON
   #

   64




   65


   66





   67
   68
   69
       AUTHOR
Currie, Lloyd A.; Klouda,
George A.; Voorhees, Kent
J.

Department of Ecology,
State of Washington

Duker, D.C.; Levaggi,
D.A.; Umeda, T.;
DeMandel, R.E.; Perardi,
T.E.

Kamens, Richard M;
Rives, Glenn D.; Perry,
JeanM; Bell, Douglas A.;
Paylor, R. Flynn;
Goodman, Randall G.;
Claxton, Larry D.

Zak,  B.D.;Einfeld, W.;
Church, H.W.; Gay, G.T.;
Jensen, A.L.; Trijonis, J.;
Ivey, M.D.; Homann, P.S.;
Tipton, C.

Hytonen, S.; Alfheim, I.;
Sorsa, M.
   70     Kelly, Mary E.
   71
Ramdahl, Thomas
 DATE                    TITLE

1984      Atmospheric Carbon: The Importance of
          Accelerator Mass Spectrometry
1984      Residential Wood Stove Emissions in
          Yakima and Olympia

1984      Measurements of a Carbon Monoxide Cloud
          in San Jose, California
1984      Mutagenic Changes in Dilute Wood Smoke
          as It Ages and Reacts with Ozone and
          Nitrogen Dioxide: An Outdoor Chamber
          Study
1984      The Albuquerque Winter Visibility Study
          Vol. 1 Overview and Data Analysis
1983      Effect of Emissions from Residential Wood
          Stoves on SCE Induction in CHO Cells

1983      Sources and Emissions of Fob/cyclic
          Organic Matter (POM)

1983      Retene-A Molecular Marker of Wood
          Combustion in Ambient Air
                  PUBLICATION INFORMATION

Nuclear Instruments and Methods in Physics Research, Vol. 233
[B5],No. 2, pp. 371-379
State of Washington Department of Ecology, Olympia, WA
Proceedings of the 77th Annual Air Pollution Control Association
Meeting, San Francisco, CA (84-87.4)
Environmental Science and Technology, Vol. 18, No. 7,
 pp. 523-530
U.S. Department of Energy, Sandia Report
(SAND84-0173/1 DE84 014356)
Mutation Research, Vol. 118, pp. 69-75
U.S. Environmental Protection Agency, Research Triangle Park, NC
(EPA-450/5-83-010b) (NTIS PB84-144153)

Nature, Vol. 306, No. 8, pp. 580-582

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                                   U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
#
72
AUTHOR
Beck, Barbara D.
DATE
1982
TITLE
Prediction of the Pulmonary Toxicity of Pn
PUBLICATION INFORMATION
oceedings of the Residential Wood & Coal Combustion —
>
OJ
    73    Imhoff, Robert E.
    74    Johnston, Ralph E.; Arkell,
          Donald R.
    75    Kamens, Richard M.
    76    Klouda, George A.
    77    Lipfert, Frederick W.
    78
Allwine, K.J., Jr.
    79    Barnard, Barry L.
                                      Respirable Combustion Products from
                                      Residential Wood & Coal Stoves

                            1982      Final Report on a Study of the Ambient
                                      Impact of Residential Wood Combustion in
                                      Petersville, AL

                            1982      A Preliminary Analysis of the Impact of
                                      Residential Wood Combustion Emissions on
                                      Ambient Carbon Monoxide Levels

                            1982      An Outdoor Exposure Chamber to Study
                                      Wood Combustion Emissions under Natural
                                      Conditions

                            1982      Estimating the Impact of Atmospheric
                                      Carbonaceous Particulates on Urban and
                                      Rural Environments by Radiocarbon
                                      Measurements

                            1982      A National Assessment of the Air Quality
                                      Impacts of Residential Firewood Use
1981       Assessment of the Long-Range Transport of
           Residential Woodstove Fine Paniculate
           Emissions for Two Future U.S. Energy
           Scenarios

1981       Regulating Residential Biomass Combustion
           in the Tennessee Valley Region
                                                     Specialty Conference, the Air Pollution Control Association,
                                                     Louisville, KY, pp. 264-280

                                                     Proceedings of the Residential Wood & Coal Combustion —
                                                     Specialty Conference, the Air Pollution Control Association,
                                                     Louisville, KY, pp. 161-188

                                                     Lane Regional Air Pollution Authority, Eugene, OR
                                                     Proceedings of the Residential Wood & Coal Combustion —
                                                     Specialty Conference, the Air Pollution Control Association,
                                                     Louisville, KY, pp. 207-225

                                                     Proceedings of the Residential Wood & Coal Combustion —
                                                     Specialty Conference, the Air Pollution Control Association,
                                                     Louisville, KY, pp. 189-206
Proceedings of the Residential Wood & Coal Combustion —
Specialty Conference, the Air Pollution Control Association,
Louisville, KY, pp. 226-239

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

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. 1216-1228

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                                  U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                                CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
   #

   80
    81
       AUTHOR
UJ
oo
Benton, Gary; Miller, Don
Paul; Reimold, Mary;
Sisson, Richard
Bohac, Charles; Duncan,
Joseph R.; Beeman, Larry
E.
    82     Brimblecombe, Peter
    83     Carlson, James H.
    84     Colome, Steven D.;
          Spengler, John D.
    85     Cooper, John A.
    86     Currie, L.A.; Klouda,
          George A.; Gerlach, R.W.
 DATE                   TITLE

1981      A Study of Occupant Exposure to
          Particulates and Gases from Woodstoves in
          Homes
1981      Residential Wood Combustion Issues for the
          Tennessee Valley
                           1981      Environmental Impact of Fuel Changes in
                                     Early London
                           1981      Residential Wood Combustion in Missoula,
                                     Montana: An Overview of Its Air Pollution
                                     Contributions, Health Effects,  and Proposed
                                     Regulatory Solutions

                           1981      Residential Indoor and Matched Outdoor
                                     Pollutant Measurements with Special
                                     Consideration of Wood-Burning Homes


                           1981      Chemical and Physical Methods of
                                     Apportioning the Contributions of
                                     Emissions from Residential Solid Fuels to
                                     Reductions in Air Quality

                           1981      Radiocarbon: Nature's Tracer for
                                     Carbonaceous Pollutants
                  PUBLICATION INFORMATION

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

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, p. 274
                                                   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

                                                   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

                                                   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

                                                   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

                                                   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. 365-385

-------
                               U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
#
87
AUTHOR
DeCesar, Richard T.
DATE
1981
TITLE
The Quantitative Impact of a Residential
PUBLICATION INFORMATION
Proceedings of the 1981 International Conference on Residential
>
OJ
       Greene, W.T.; Tombleson,    1981
       B.J.
89     Hornig, James F.;            1981
       Soderberg. Roger H.;
       Larsen, Deborah;
       Parravano, Carlo

90     Imhoff, Robert E.;            1981
       Manning, Justice A.; Cook,
       William M; Hayes,
       Timothy L.

91     Jacobs, Philip; Snowden,     1981
       Bunch
92     Kelsey, Morris I.; Kraybill,   1981
       H.F.; Helmes, C. Tucker,
       Sigman, Caroline C.
93     Kosel, Peter H.
                                      Wood Combustion and Other Vegetative
                                      Burning Sources on the Air Quality in
                                      Medford, Oregon

                                      Institutional and Regulatory Approaches to
                                      Control Residential Wood Burning
                                      Emissions
                                      Ambient Air Assessment in Rural Village
                                      and Small Town Locations in New
                                      Hampshire where Wood Is an Important
                                      Fuel

                                      Preliminary Report on a Study of the
                                      Ambient Impact of Residential Wood
                                      Combustion in Petersville, Alabama
                                      Health Costs of Residential Wood
                                      Combustion
                                      A Data Base of Organic Pollutants that
                                      Have Been Evaluated for Carcinogenicity
                                      and Mutagenicity
94
Kosel, Peter H.
                            1981       Pollution and Fireplaces in California
                                      1981      Pollution and Fireplaces in California
Solid Fuels, Environmental Impacts and Solutions, Portland, OR;
Published by Oregon Graduate Center, Beaverton, OR (1982),
pp. 551-565

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

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

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

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

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

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, pp. 242-251

Proceedings of the 1981 Wood Combustion Environmental
Assessment Conference

-------
                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                             CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
#
AUTHOR
95     Kowalczyk, J.F.; Greene,
       W.T.
96     Lawther, P.J.
97     Lewtas, Joellen
 98    Lim, K.J.; Lips, H.I.
99     Lipfert, Frederick W.
100    Machlin, Paula R.
101    Martin, Werner
 DATE                   TITLE

1981      New Techniques for Identifying Ambient
          Air Impacts from Residential Wood Heating
                    1981       Historic Changes in Air Pollution in Great
                              Britain
                    1981       Comparison of the Mutagenic and
                              Potentially Carcinogenic Activity of Particle
                              Bound Organics from Wood Stoves,
                              Residential Oil Furnaces, and Other
                              Combustion Sources

                    1981       Overview of Emissions from Wood
                              Combustion

                    1981       An Assessment Methodology for the Air
                              Quality Impact of Residential Wood
                              Burning
                    1981       Residential Solid Fuels in the
                              Environmental Protection Agency Region
                              VIII States
                    1981       European Experiences and Activities in
                              Assessing the Environmental Impacts from
                              Wood Combustion
                  PUBLICATION INFORMATION

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

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

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
                                                   Proceedings of the Wood Heating Seminars 1980/1981, Wood
                                                   Heating Alliance, Washington DC, p. 273

                                                   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

                                                   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

                                                   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. 1180-1196

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                               U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                             CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
#             AUTHOR

102    Meyer, H. Robert
103    Morris, Gregory
105    Murphy, Dennis J.;
       Buchan, Roy M.; Fox,
       Douglas G.
 DATE                   TITLE

1981      The Contribution of Residential Wood
          Combustion Local Airshed Pollutant
          Concentrations
1981      Health Effects of Residential Wood
          Combustion — The Implications of
          Environmental Stochasticity
104    Mors, Terry A.; Blair,        1981
       Terence T.; Cole, Robert H.
106    Santodonato, Joseph; Basu,    1981
       Dipak; Bruce, Robert
107    Schwengels, Paul; Bohac,     1981
       Charles; Krickenberger, Kit
108    Cooper, John A.
109    Davis, Briant L.
          Regulatory Options for Controlling
          Emissions from Combustion of Wood in
          Residential Applications
1981      Ambient Particulate and Benzo (oc) Pyrene
          Concentrations from Residential Wood
          Combustion, in a Mountain Resort
          Community
          Multimedia Human Exposure to Poly cyclic
          Aromatic Hydrocarbons and Their
          Association with Cancer Risk
          An Integrated Environmental Assessment of
          Biomass Energy Development in the
          Tennessee Valley
1980      Environmental Impact of Residential Wood
          Combustion Emission and Its Implications

1980      Composition and Sources of Airborne
          Particulate Matter Observed in Wintertime
          at Missoula, Montana
                  PUBLICATION INFORMATION

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

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

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

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

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

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, p. 272
Journal of the Air Pollution Control Association, Vol. 30, No. 8,
pp. 855-861

Prepared for the Montana State Department of Health and
Environmental Science, Missoula, MT

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                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                            CATEGORY #4 — AMBIENT AIR QUALITY AND HEALTH STUDIES
#             AUTHOR

110   Harris, Howard W.
Ill   Hornig, James F.;
      Soderberg, Roger H.;
      Barefoot, Aldos C., Ill

112   Lao, R.C.; Thomas, R.S.
      Lanoy, M; Lee, S. Win


113   Weston, Roy F.
 DATE                   TITLE

Undated   An Investigation of Elevated Carbon
          Monoxide and Nephelometer Data in a
          Portland Residential Neighborhood Affected
          by Wood Smoke

Undated   Woodsmoke Analysis: Vaporization Losses
          of PAH from Filters and Levoglucosan as a
          Distinctive Marker for Woodsmoke

Undated   Investigation of PAH and Polychlorinated
          Organic Pollutant Emissions from Wood
          Combustion Sources

Undated   Paniculate Emissions from Residential
          Wood Combustion — Final Report
                 PUBLICATION INFORMATION

Oregon Department of Environmental Quality, Portland, OR
Proceedings for the Eighth International Symposium on Polynuclear
Aromatic Hydrocarbons: Mechanisms, Methods and Metabolism,
Wilmington, DE, pp. 561-568

Laboratory Services Division, Air Pollution Control Directorate,
Environment Canada, Ottawa, Canada, pp. 745-755
Roy F. Weston Co., West Chester, PA; Prepared for Northeast
Regional Biomass Program, CONEG Policy Research Center, Inc.

-------
                        U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                                       CATEGORY #5 — REGULATORY REVIEWS
        AUTHOR
                             DATE
                TITLE
                  PUBLICATION INFORMATION
U.S. Environmental
Protection Agency
Collier, David L.
Appel, J.
                            1996
                            1993
                            1992
                            1983

                            1995
                            1992
Hough, M.; et al.
                            1992
Manderino, L.
                            1992
Maykut, N.; Fry, S.
                            1992
Emission Factor Documentation for AP-42
Section 1.9, Residential Fireplaces, and
Section 1.10, Residential Wood Stoves
Medford And Klamath Falls, Oregon —
Success in Controlling Residential Wood
Combustion — Possible Implications of
New Paniculate Matter Standard

Current Limitations and Future Prospects of
Residential Wood Combustion Controls in
the Pacific Northwest
Progress to Achieve Residential Wood
Combustion PM10 Emission Reductions in
Medford, Oregon as Determined by
Compliance Surveys and Ambient
Monitoring

An Integrated Community Approach to
Reducing Residential Woodsmoke:
Innovative Funding of Control Strategies
Woodsmoke Control in the Puget Sound
Region
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 )

Proceedings of an International Specialty Conference, Paniculate
Matter: Health and Regulatory Issues; Published by Air & Waste
Management Association, Pittsburgh, PA, VIP-49,
Pittsburgh, PA, pp. 776-788

Transactions of the A&WMA/EPA International Specialty
Conference, PM10 Standards and Nontraditional Paniculate
Source Controls, Volume II, TR-22; Published by Air & Waste
Management Association, Pittsburgh, PA, pp. 614-624
(ISBN 0-923204-09-1)

Transactions of the A&WMA/EPA International Specialty
Conference, PM10 Standards and Nontraditional Paniculate
Source Controls, Volume II, TR-22; Published by Air & Waste
Management Association, Pittsburgh, PA, pp. 637-645
(ISBN 0-923204-09-1)

Transactions of the A&WMA/EPA International Specialty
Conference, PM10 Standards and Nontraditional Paniculate
Source Controls, Volume II, TR-22; Published by Air & Waste
Management Association, Pittsburgh, PA, pp. 716-729
(ISBN 0-923204-09-1)

Transactions of the A&WMA/EPA International Specialty
Conference, PM10 Standards and Nontraditional Paniculate
Source Controls, Volume II, TR-22; Published by Air & Waste
Management Association, Pittsburgh, PA, pp. 625-636
(ISBN 0-923204-09-1)

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                               U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                                              CATEGORY #5 — REGULATORY REVIEWS
              AUTHOR


      Morris, A.; et al.
       OMNI Environmental
       Services, Inc.


       Ono, D.; Taylor, W.
10    Pettingill, D.;etal.
11     Shwayder, P.
12     Stapp, S.;Harley, R.
13     Stoneman, C.; Pace, T.
DATE                    TITLE
1992     An Integrated Community Approach to
         Reducing Residential Woodsmoke:
         Community Analysis and Education
1992     Residential Wood Combustion Control
         Measures for the Pocatello PM10
         Nonattainment Area

1992     Town of Mammoth Lakes Air Quality
         Regulations
1992     Evaluation of Washoe County, NV Control
         Strategies for Reducing Emissions from
         Residential Woodburning
1992     Burning Wood — A Political Perspective:
         Case Studies from the Denver Region
1992     An Effective Woodburning Control
         Program: Albuquerque/Bernalillo County,
         New Mexico, USA
1992     Technical Guidance for Residential Wood
         Combustion: Reasonably and Best Available
         Control Measures
                  PUBLICATION INFORMATION
Transactions of the A&WMA/EPA International Specialty
Conference, PM10 Standards and Nontraditional Paniculate
Source Controls, Volume II, TR-22; Published by Air & Waste
Management Association, Pittsburgh, PA, pp. 700-715
(ISBN 0-923204-09-1)

OMNI Environmental Services, Inc., Beaverton, OR; Prepared for
the U.S. Environmental Protection Agency, Region X, Seattle WA
Transactions of the A&WMA/EPA International Specialty Conference,
PM10 Standards and Nontraditional Paniculate Source Controls,
Volume II, TR-22; Published by Air & Waste Management Association,
Pittsburgh, PA, pp. 657-668 (ISBN 0-923204-09-1)

Transactions of the A&WMA/EPA International Specialty Conference,
PM10 Standards and Nontraditional Paniculate Source Controls,
Volume II, TR-22; Published by Air & Waste Management Association,
Pittsburgh, PA, pp. 646-656 (ISBN 0-923204-09-1)

Transactions of the A&WMA/EPA International Specialty Conference,
PM10 Standards and Nontraditional Paniculate Source Controls,
Volume II, TR-22; Published by Air & Waste Management Association,
Pittsburgh, PA, pp. 669-679 (ISBN 0-923204-09-1)

Transactions of the A&WMA/EPA International Specialty Conference,
PM10 Standards and Nontraditional Paniculate Source Controls,
Volume II, TR-22; Published by Air & Waste Management Association,
Pittsburgh, PA, pp. 730-740 (ISBN 0-923204-09-1)

Transactions of the A&WMA/EPA International Specialty Conference,
PM10 Standards and Nontraditional Paniculate Source Controls,
Volume II, TR-22; Published by Air & Waste Management Association,
Pittsburgh, PA, pp. 601-613 (ISBN 0-923204-09-1)

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                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
                                             CATEGORY #5 — REGULATORY REVIEWS
14
17
        AUTHOR


Davis, Bob
15    Butler, Alan T.
16    Hough, Merlyn
Westlin, Peter R.
.K    18    Gay, Robert; Shah, Jitendra




    19    Jenkins, Pamela G.


    20    Radian Corporation




    21    Radian Corporation
                                   DATE
1989
                            1988
                            1988
1987
                                   1986
                                   1986
                                   1986
                                   1986
                          TITLE
                                                Guidance Document for Residential Wood
                                                Combustion Emission Control Measures
                                                Control Of Woodstoves by State Regulation
                                                as a Fine Paniculate Emission Control
                                                Strategy

                                                Oregon's Approach to Reducing Residential
                                                Woodsmoke as Part of the PM10 Strategy


                                                The Environmental Protection Agency's
                                                Accreditation Program for Wood Heater
                                                Testing Laboratories
                                      Technical Support Document for Residential
                                      Wood Combustion
                                      Wood Smoke: Emissions, Impacts, and
                                      Reduction Strategies.

                                      Evaluation of Emission Limit Formats for
                                      Residential Woodburning Appliances
                                      Wood Load Effect on Paniculate Emissions
                                      from Residential Woodburning Appliances
                                                                                                           PUBLICATION INFORMATION
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)

Transactions of the APCA/EPA International Specialty Conference,
PM10 Implementation Standards, TR-13, San Francisco, CA; Published
by the Air Pollution Control Association, Pittsburgh, PA, pp. 654-663

Transactions of the APCA/EPA International Specialty Conference,
PM10 Implementation Standards, TR-13, San Francisco, CA; Published
by the Air Pollution Control Association, Pittsburgh, PA, pp. 646-653

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)

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)

Washington Department of Ecology, Air Program, Olympia, WA
                                                   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)

                                                   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)

-------
                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
               AUTHOR
DATE
                                             CATEGORY #5 — REGULATORY REVIEWS
TITLE
PUBLICATION INFORMATION
22     OMNI Environmental         1985
       Services, Inc.
23     Braaten, R.W.; Hay den,        1984
       A.C.S.
24     Grotheer, Wayne E.           1984
25     Carlsson, Sten-Ake            1981
 26    Greene, William T.;           1981
       Tomleson, Barbera J.
27     Hall, R.E.                    1981
28     Sundstrom, Lars              1981
29     Hall, Robert E.; DeAngelis,     1980
       Daryl G.
         Standard Test Method for Determining the
         Heat Output Range and Maximum Burn
         Cycle Duration, Residential Wood-Fired
         Closed Combustion-Chamber Heating
         Appliances

         Status of Canadian Standard for Efficiency
         and Emissions of Domestic Wood-Fired
         Appliances

         Overview of Control Strategies for
         Residential Wood Combustion

         Residential Wood Combustion in Sweden —
         Environmental Aspects and Regulations
         Institutional and Regulatory Approaches to
         Control Residential Wood Burning
         Emissions

         EPA's Research Program for Controlling
         Residential Wood Combustion Emissions

         Method for Measuring Heat Output and
         Efficiency on Wood Heating Appliances and
         Results from Tests on Ten Woodstoves and
         Fireplaces

         EPA's Research Program for Controlling
         Residential Wood Combustion Emissions
                         OMNI Environmental Services, Inc., Beaverton, OR
                         Canadian Combustion Research Laboratory, ERL/CANMET,
                         Energy, Mines & Resources Canada, Ottawa, Canada
                         Proceedings of the 77th Annual Air Pollution Control Association
                         Conference, San Francisco, CA (84-70.1)

                         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

                         Proceedings of the Wood Heating Seminars  1980/1981, Wood
                         Heating Alliance, Washington DC, p. 271
                         Proceedings of the Wood Heating Seminars 1980/1981, Wood
                         Heating Alliance, Washington DC, pp. 44-63

                         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

                         Journal of the Air Pollution Control Association, Vol. 30, No. 8,
                         pp. 862-867

-------
                        U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
  CATEGORY #6 — GENERAL  OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS
#             AUTHOR           DATE

1      Anonymous                1994
Tiegs, Paul E.; Vaughan,      1993
Patrick; Bighouse, Roger D.
Walsh, Debra; Warren,       1993
Sarah; Zweidinger, Roy; et
al.
Broome, F.                  1992
Bushway, Stephen           1992
CONEG Policy Research      1992
Center
Myren, A., Jr.               1992
Barnett, Stockton G.          1991
                TITLE

Fuelwood Plant Demonstrates Use of Clean,
Renewable Fuel for Heating and Cooling

Spillage of Combustion Byproducts from
Woodstoves Operated in Negative Pressure
Environments

Mutagenicity of Indoor Air in Boise, Idaho
and Roanoke, Virginia
The Development of Clean-Burning
Noncatalytic Manufactured Fireplaces
The New Woodburner's Handbook — A
Guide to Safe, Healthy & Efficient
Woodburning

Pamphlet — How to Burn Wood Right —
Choosing and Using Your Wood Stove in
Today's Environment

The Development of the Clean Burning
Inside-Out Flame in Noncatalytic
Woodstoves
Report to the City of Fresno, California on
the Implications of a Project that Measured
Masonry Fireplace and Heater Emissions in
Homes
                                                                                               PUBLICATION INFORMATION

                                                                              Arbor Day, Nebraska City, NE, p. 7
                                                                                    OMNI Environmental Services, Beaverton, OR; Prepared for
                                                                                    Bonneville Power Administration, Resource Management
                                                                                    Residential Department (DE-AP79-92BP60576-M001)

                                                                                    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

                                                                                    Transactions of the A&WMA/EPA International Specialty Conference,
                                                                                    PM10 Standards  and Nontraditional Paniculate Source Controls,
                                                                                    Volume II, TR-22; Published by Air & Waste Management Association,
                                                                                    Pittsburgh, PA, pp. 585-588 (ISBN 0-923204-09-1)

                                                                                    Capitol City Press Fast Printing, Storey Communications, Inc.,
                                                                                    Pownal, VT
                                                                                    CONEG Policy Research Center, New York State Energy Research
                                                                                    and Development Authority
                                                                                    Transactions of the A& WMA/EP A International Specialty Conference,
                                                                                    PM10 Standards and Nontraditional Paniculate Source Controls,
                                                                                    Volume II, TR-22; Published by Air & Waste Management Association,
                                                                                    Pittsburgh, PA, pp. 589-592 (ISBN 0-923204-09-1)

                                                                                    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, CA

-------
                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
         CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS
#             AUTHOR

9      California Air Resources
       Board
10     Melcon. Daniel
11     Harden, Albert; Hyytiainen,
       Heikki

12     Evans, Robert I; Milne,
       Thomas A.
13     Greene, William T.
 14    Greene, William T.;
       Simons, Carl A.; Houck,
       James E.
15     Highsmith, V. Ross
16     Peacock, Richard D.

17     Wilson, Pamela L.; Funck,
       James W.; Avery, Robert B.
 DATE

1991



1989


1988


1988



1988




1988




1988
1987

1987
                TITLE

Woodburning Handbook — How to Burn
More Efficiently in Your Stove or Fireplace
and Produce Less Air Pollution
                 PUBLICATION INFORMATION

California Air Resources Board, Sacramento, CA
Pellet Primer — An Introduction to Heating   Biomass Publications of America, Portland, OR
with Wood Pellets
Finnish Fireplaces — Heart of the Home
Relevancy of Wood Pyrolysis Chemistry to
Wood Stove Emissions
Cost/Benefit Analysis of Mitigation
Measures for Minimizing Environmental
Impacts of Residential Wood Combustion,
Task F — Final Report

Mitigation Measures for Minimizing
Environmental Impacts  from Residential
Wood Combustion, Task E — Final Report
Influence of Residential Wood Combustion
Emissions on Indoor Air Quality of Boise,
Idaho Residences
Building Book Ltd., Finland
Chemical Conversion Research Branch, Solar Energy Research
Institute, Golden, CO; Presented at the 1988 American Chemical
Society National Summer Meeting, Denver, CO

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)

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)

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, VTP-10, Pittsburgh, PA, pp. 804-813
(EPA-600/9-88-015) (NTIS PB90-225863)
Wood Heating Safety Research: An Update   Fire Technology, Vol. 223, No. 4, pp. 229-312
Fuelwood Characteristics of Northwestern
Conifers and Hardwoods — Research
Bulletin 60
Forest Research Laboratory, College of Forestry, Oregon State
University, Corvallis, OR

-------
                                  U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
            CATEGORY #6 — GENERAL  OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS

   #             AUTHOR
DATE
    18     Chase, Craig L.              1986
    19     Harris, Robert A.; McMinn,   1986
          James W.; Payne, Fred A.

    20     Humphreys, Mallory P.       1986
   21     OMNI Environmental        1986
          Services, Inc.
   22     Canadian Wood Energy       1985
          Institute

>   23    Hartman, M.W.; Rives,       1985
£         G.D.
   24     Ontario Task Force           1985


   25     Turbak, Gary                1984


   26     Portland, The City of         1983


   27     U.S. Environmental          1983
          Protection Agency

   28     Allen, John M.              1982
                TITLE

Pacific Northwest and Alaska Bioenergy
Program Glossary

Calculating and Reporting Changes in Net
Heat of Combustion of Wood Fuel

Residential Wood Combustion Impacts on
Indoor Carbon Monoxide and Suspended
Particulates
         Compendium of Environmental and Safety
         Regulations and Programs Affecting
         Residential Wood Heating Appliances
                  PUBLICATION INFORMATION

U.S. Government Interagency Program, Department of Energy,
Bonneville Power Administration, Portland, OR

Forestry Products Journal, Vol. 36, No. 6, pp. 57-60
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)

OMNI Environmental Services, Inc., Beaverton, OR; Prepared for
the Bonneville Power Administration, Portland, OR
         Conference Proceedings of the Firewood 85    Canadian Wood Energy Institute
         Literature Review and Survey of Emissions
         from Residential Wood Combustion and
         Their Impact


         Report of the Ontario Task Force on
         Residential Wood Heat Safety

         New Technologies Fight — Wood-Stove
         Pollution

         Woodstoves — Installation and Use —
         Portland, OR

         Pamphlet — Wood Stove Features and
         Operation Guideline for Clean Air

         Techniques for Achieving More Complete
         Combustion in Wood Stoves
                                         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)

                                         Prepared for the Minister of Energy, Toronto, Ontario, Canada
                                         Popular Science, December 1984, pp. 90-92
                                         The City of Portland, Portland, OR
                                         U.S. Environmental Protection Agency, Research and Development
                                         (EPA-600/D-83-112)

                                         Proceedings of the Residential Wood & Coal Combustion —
                                         Specialty Conference, the Air Pollution Control Association,
                                         Louisville, KY, pp. 2-24

-------
                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
         CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS
>
o
#             AUTHOR

29     Harriett, Stockton G.




30     Bortz, Paul

31     Busha, William; Morris,
       Stephen

32     Flagler, Gordon


33     Martin, Werner



34     Miller, D.P.



35     Neulicht, Roy M.
36
Osborne, Michael C.
37     Traynor, Gregory W.
38     Anonymous

39     Bendersky, Charles
                            DATE

                           1982
1982

1982


1982


1982



1982



1982



1982



1982
                           1981

                           1981
                          TITLE
                                                                                                          PUBLICATION INFORMATION
                                               The Effects of Stove Design and Control      Proceedings of the Institute of Gas Technology Symposium
                                               Mode on Condensible Paniculate Emissions,  for Energy from Biomass and Waste VI Meeting, Lake Buena
                                               Flue Pipe Creosote Accumulation and the     Vista, FL, pp. 283-322
                                               Efficiency of Woodstoves in Homes

                                               Getting More Heat from Your Fireplace
                                     The Book of Heat — A Four Season Guide
                                     to Wood and Coal Heating

                                     The North American Wood Heat Handbook
                                     European Activities in Solid Fuel Fired
                                     Heating
                                     Indoor Exposure to Carbon Containing
                                     Particulates and Vapors in Homes which
                                     Use Wood for Heating

                                     Impact of Residential Wood Combustion
                                     Appliances on Indoor Air Quality
                                               Residential Wood & Coal Combustion
                                               Indoor Air Pollution from Portable
                                               Kerosene-Fired Space Heaters, Wood-
                                               Burning Stoves, and Wood-Burning
                                               Furnaces

                                               Fireplaces and Woodstoves

                                               Results of the DOE Think Shop on
                                               Residential Wood Combustion
Garden Way Publishing, Charlotte, VT

The Stephen Greene Press, Brattleboro, VT, Lexington, MA
(Rev. ed. of: The Book Of Heat (1948))

Charles Scribner's Sons, New York, NY (Rev. ed. of:
The Canadian Wood Heat Book (1979))

Proceedings of the Residential Wood & Coal Combustion —
Specialty Conference, the Air Pollution Control Association,
Louisville, KY, pp. 89-114

Proceedings of the Residential Wood & Coal Combustion —
Specialty Conference, the Air Pollution Control Association,
Louisville, KY, pp. 281-295

Proceedings of the Residential Wood & Coal Combustion —
Specialty Conference, the Air Pollution Control Association,
Louisville, KY, pp. 240-252

Proceedings of the Residential Wood & Coal Combustion —
Specialty Conference, the Air Pollution Control Association,
Louisville, KY, p. 1

Proceedings of the Residential Wood & Coal Combustion —
Specialty Conference, the Air Pollution Control Association,
Louisville, KY, pp. 253-263
                                                   Time-Life Books Inc., Chicago, IL

                                                   Proceedings of the Wood Heating Seminars 1980/1981, Wood
                                                   Heating Alliance, Washington DC, p. 275

-------
                                  U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
            CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS

   #             AUTHOR
DATE
   40     Cohen, Maurice             1981
   41     Earl, William L.             1981
   42     Faista, Michael B.;           1981
          Davidovits, Paul
   43     Harper, Jerome P.            1981
   44     Hayden, A.C.S.; Braaten,     1981
>         R.W.
tji
    45    Knight, D. Karen            1981
   46     Linstrom, Olle               1981
   47     Morstead,H.                1981
   48     Osborne, Michael C.         1981
                TITLE

The Woodcutters Companion — A Guide to
Locating, Cutting, Transporting, and
Storing Your Own Firewood

An Investigation of Wood Pyrolysis Using
Solid State 13C Nuclear Magnetic
Resonance
         Formation of Submicron Ash Particles in
         Coal Combustion
         Residential Wood Heating Efficiency and
         Emissions — An Overview

         Efficient Wood Stove Design and
         Performance

         Wood Heat Emission
         Gasification/Combustion of Wood
                  PUBLICATION INFORMATION

Rodale Press, Emmaus, PA
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

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

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, p. 276

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, pp. 16-43

Proceedings of the Wood Heating Seminars 1980/1981, Wood
Heating Alliance, Washington DC, pp. 73-86

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

Center for Research & Development in Masonry, Calgary,
Alberta, Canada
         Fireplace Technology in an Energy
         Conscious World

         The Inter-Government Research and         Proceedings of the 1981 International Conference on Residential
         Development Program for Residential Wood   Solid Fuels, Environmental Impacts and Solutions, Portland, OR;
         Combustion                              Published by Oregon Graduate Center, Beaverton, OR (1982),
                                                  pp. 17-33

-------
                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
         CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS
#             AUTHOR           DATE

49     Shafizadeh, Fred             1981
50     Shelton, Jay W.              1981
51     Stegmeir, PaulB.            1981
52     Thornton, Mark M; Malte,    1981
       Philip C.
53     Toynbee, Peter A.            1981
54     Trivett, Gordon S.; Al-        1981
       Taweel, Adel M.; Bond, W.
       Terence; MacKay, David
       M.

55     Harrington, Geri             1980
56     Newcomb, Wilburn, W.       1980
57     Oregon State University       1980
       Extension Service
                TITLE

Chemistry of Pyrolysis and Combustion of
Wood
Wood Heating System Design Conflicts and
Possible Resolutions
Wood Energy — From the Forest to the
Furnace
Combustion Rate of Model Wood Volatiles
Domestic Coal Firing in Smokeless Zones
Fluidized Bed Combustion on the Domestic
Scale
Fireplace Stoves, Hearths, & Inserts — A
Coal- & Wood-Burner's Guide & Catalog

Wood Stove Handbook
                  PUBLICATION INFORMATION

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

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

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

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

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

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

Harper & Row, Publishers, New York, NY
Theodore Audel & Co., A Division of Howard W. Sams & Co., Inc.,
Indianapolis, IN
Fuelwood Facts — Extension Circular 1023   Oregon State University Extension Service, Corvallis, OR

-------
                              U.S. Environmental Protection Agency Residential Wood Combustion Technology Review Categorical Reference List
         CATEGORY #6 — GENERAL OR UNCLASSIFIED RESIDENTIAL WOOD BURNING DOCUMENTS
#             AUTHOR

58    U.S. Department of Energy

59    Shelton, Jay. W.

60    Adkins, Jan

61    Soderstrom, Neil


62    Twitchell, Mary


63    Vivian, John

64    Harrington, Geri

65    Ross, Bob; Ross, Carol


 66   Shelton, Jay W.


67    Vivian, John

68    Gay, Larry

69    Gay, Larry

70    Havens, David


71    Young, Harold E.



72    Mingle, J.G.; Boubel, R.W.


73    Anonymous
 DATE

1980

1979

1978

1978


1978


1978

1977

1976


1976


1976

1974

1974

1973


1971



1968
                TITLE

Heating with Wood

Wood Heat Safety

The Art and Ingenuity of the Woodstove

Heating Your Home with Wood


Wood Energy — A Practical Guide to
Heating with Wood

The New, Improved Wood Heat (Reprint)

The Wood Burning Stove Book

Modern and Classic Woodburning Stoves
and the Grass Roots Energy Revival

The Woodburner's Encyclopedia — Wood
as Energy

Wood Heat
                                                         PUBLICATION INFORMATION

                                        U.S. Department of Energy, Washington, DC (DOE/CS-0158)

                                        Garden Way Publishing, Charlotte, VT

                                        Everest House Publishers, New York, NY

                                        Popular Science, Harper & Row; Published by Book Division,
                                        Times Mirror Magazines, Inc., New York, NY

                                        Garden Way Publishing, Charlotte, VT


                                        Rodale Press, Emmaus, PA (Rev. ed. Of: Wood Heat (1976))

                                        Macmillan Publishing Co., Inc., New York, NY

                                        Overlook Press, Woodstock, NY


                                        Vermont Crossroads Press, Waitsfield, VT
                                        Rodale Press, Emmaus, PA

The Oregon Woodcutting and Heating Book   Garden Way Publishing, Charlotte, VT (Rev. ed. of: Heating With Wood)

The Complete Book of Heating with Wood    Garden Way Publishing, Charlotte, VT

                                        Harpswell Press, Brunswick, ME
The Woodburners Handbook — Rekindling
an Old Romance

Preliminary Estimates of Bark Percentages
and Chemical Elements in Complete Trees
of Eight Species in Maine

Proximate Fuel Analysis of Some Western
Wood and Bark
Undated   Wood Heating Handbook
                                        Forestry Products Journal, Vol. 21, No. 5, pp. 56-59
                                        Wood Science, Vol. 1, No. 1, pp. 29-36
                                        Prepared for the Great Lakes Regional Biomass Energy Program,
                                         Council of Great Lakes Governors, Madison, WI

-------
                           U.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        No Publication Information Listed, pp. 55-62
                                        Millions of Homes

-------
                                     Appendix B

                              Summary of Expert Interviews

                                   Table of Contents
List of Experts Interviewed	B-l

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-l 13

                                     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-l 1
6     Method 28 - Burn Rate Weighted Probabilities for Calculating Weighted Average . . B-l2
      Emission Rate Based on 43 Homes in Waterbury, VT, Glens Falls, NY, and
      Portland, OR
                                         A-iii

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                              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 Kl AOG
CANADA
interviewed February 26, 1998

Mr. Daniel Henry
Vice President
Aladdin Steel Products, Inc.
401 N. Wynne  Street
Colville, WA99114
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 Bur en
Technical Director
Hearth Products Association
1601 North Kent Street, Suite 1001
Arlington, VA 22209
interviewed January  14, 1998
                                         A-l

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                 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 (densifiedandwax 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 paniculate 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 BTUwax 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-2

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

       1.10   Default 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 ofcordwood. 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-3

-------
       4.1    Are the emissions and efficiencies for the in-home use of pellet stoves shown in
             Tables 1 and2 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 (oldvs 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 calculated
                                          A-4

-------
             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 (YHC) 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 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?

       10.2   Should 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-5

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       11.1   Optimum wood moisture for low paniculate 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 paniculate 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 paniculate
             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?

12.2   Should 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-6

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                              Table 1
Emission Factor Reduction Potential, in Mass/Unit Mass Dry Wood Burned,
      for Various Alternatives to Conventional Stoves and Cordwood
Appliance
Conventional
Non-Catalytic
Catalytic
Pellet
Masonry Heater
Conventional with
densified fuel
Particulate Emission Factor
Ib/ton
37
12
13
4
6
25
g/kg
18.5
6
6.2
2
3
14
reduction
%
-
68
65
89
84
24
                                A-7

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                                                         Table 2
                         Effective Pollutant Reduction Potential, in Mass/Thermal Unit Heat Delivered,
                                 of Various Alternatives to Conventional Stoves and Cordwood
Appliance
Conventional
Non-Catalytic
Catalytic
Pellet
Masonry Heater
Conventional
with densified
fuel
Efficiency
%
54
68
72
78
58
57
Heat
Content
(BTU/lb)
8,800
8,800
8,800
8,500
8,800
8,800
Mass particulate emission/delivered heat
Ib/MBTU
3.89
1.14
1.02
0.31
0.59
2.79
g/MJ
1.68
0.49
0.44
0.13
0.25
1.20
reduction
%
-
71
74
92
85
27
td
oo

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                                Table 3
Emission Factor Reduction Potential, in Mass/Unit Mass Dry Wood Burned,
     for Various Alternatives to Conventional Fireplaces and Cordwood
Appliance
Fireplace
Fireplace with
wax logs
Non-Catalytic
Insert
Catalytic Insert
Pellet Insert
Particulate Emission Factor
Ib/ton
25
21
12
13
4
g/kg
12.5
10.5
6
6.5
2
reduction
%
-
16(70%)a
65
89
84
        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

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                                                         Table 4
                          Emission Factor Reduction Potential, in Mass/Thermal Unit Heat Delivered,
                               of Various Alternatives to Conventional Fireplaces and Cordwood
Appliance
Fireplace
Fireplace with
wax logs
Non-Catalytic
Insert
Catalytic Insert
Pellet Insert
Efficiency
%
7
8
68
72
78
Heat
Content
(BTU/lb)
8,800
15,000
8,800
8,500
8,500
Mass particulate emission/delivered heat
Ib/MBTU
19.86
8.75
1.14
1.02
0..31
g/MJ
8.55
3.76
0.49
0..44
0..13
reduction
%
-
56
94
95
98
td
o

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                                                      Table 5
                           Comparison of ISO 13336 (Draft) with EPA Methods 28, 5G, and 5H
Test Method
ISO 13336
EPA 28
EPA5G
EPA5H
Emission
Sampling
Technique
dilution tunnel
N/Aa
dilution tunnel
direct flue
Fuel Spacing
0.75 inches
1.5 inches
N/A
N/A
Fuel Species
many including
coal
Douglas fir
N/A
N/A
Efficiency
calorimeter
room
N/A
N/A
N/A
Reporting Units
gram/kilogram
grams/hour
weighted average
N/A
N/A
td
                   N/A = Not Applicable

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                                                      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
Glens Falls, NY
Portland, OR
HDDa
HDD
HDD
= 7953
= 7547
= 4691
td
to
                       DOE/EIA-0321(93)
Wood cords burned from December 1992 through November 1993 by HDD
HDD
>7000
5500-7000
4000-5499
<4000

Millions of Cords
7.0
5.6
6.7
8.0
27.4 total
                   HDD = Heating degree days

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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
             emission reduction may 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 (densifiedandwax 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 tons

                                         A-13

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              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 paniculate emissions. How big an effect can this have?

Response:    No comment.
1.6    Approximately one half of the paniculate 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
       BTUwax 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 and2 reasonable?

       No comment.
1.9    The OMNI staff feels the emissions per unit of heat delivered (e.g., Ib/MBTU or g/MJ) is
       a more appropriate way to rank the performance of wood burning appliances than
       emission factors (Ib/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-14

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1.10   Default 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 was more accurate in 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 paniculate emissions. —  What designs and technologies are
       available? What retrofit options are there?

Response:     No comment.
                                          A-15

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2.3    The use of wax fire logs reduces emissions over the use ofcordwood. 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
       and2 reasonable?
Response:    These are all that we've got, but we must remember that the 'n' value, the number
                                          A-16

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              of data points used here, is very small 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 a piecemeal fashion, 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 choose not to 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 than
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              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 paniculate 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.
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       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 (YHC) 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?

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 Jive 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 is
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              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 CrestedButte,
       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 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:     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 is
              fundamental, but it's probably also useful in terms of all the others, all the non-
              catalysts.
10.2   Should a stress test be made part of the certification process ?
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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?
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       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.
12.2   Should 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.
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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 (densifiedandwax 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.

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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
       BTUwax 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 and2 reasonable?

Response:    No comment.
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1.9    The OMNI staff feels the emissions per unit of heat delivered  (e.g., Ib/MBTU or g/MJ) is
       a more appropriate way to rank the performance of wood burning appliances than
       emission factors (Ib/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.
1.10   Default 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 always
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              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 paniculate 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 way, fire logs reduces emissions over the use ofcordwood. 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.
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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
       and2 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 many
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             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.
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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 (YHC) 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?
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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.
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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 Jive 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 CrestedButte,
       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.
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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:     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.
10.2   Should 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 paniculate 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
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       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 paniculate
       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.
12.2   Should 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.
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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 (densifiedandwax 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.
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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
       BTUwax 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 and2 reasonable?

Response:    I have no direct knowledge.
1.9    The OMNI staff feels the emissions per unit of heat delivered (e.g., Ib/MBTU or g/MJ) is
       a more appropriate way to rank the performance of wood burning appliances than
       emission factors (Ib/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 appliances
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              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.
1.10   Default 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.
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2.2    There appear to be only a few practical design or technology options for fireplaces that
       will potentially mitigate paniculate 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 ofcordwood. 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.
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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
       and2 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'd
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              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.  Within
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             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 (YHC) 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?

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 curves
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             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.
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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 non-
             functioning 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 CrestedButte,
       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 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:     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?
10.2   Should a stress test be made part of the certification process ?
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Response:    Unless you can make an airtight case that a stress test is good predictor of long-
             term 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 paniculate 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 feel
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             that all stoves need maintenance on a regular basis.
12.2   Should 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).
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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 (densifiedandwax logs) a credible emission reduction
       strategy? See Tables 1 & 2 .

Response:    Potentially yes.
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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
       BTUwax 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 and2 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., Ib/MBTU or g/MJ) is
       a more appropriate way to rank the performance of wood burning appliances than
       emission factors (Ib/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 an
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              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.
1.10   Default 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 inserts


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       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?
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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 ofcordwood. 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, versus
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              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
       and2 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.
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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.
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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 (YHC) 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?

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 techniques
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             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?
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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 CrestedButte,
       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.
10.2   Should 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 paniculate emissions seems to be in the 18% to 20%
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       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.
12.2   Should 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 yes
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             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 (non-
catalyst) 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).
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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 in-
             situ 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't
             believe catalyst technology has reached its peak potential and I don't think non-
             catalytics have either.
1.4    Is the use of manufactured fuel (densifiedandwax 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.

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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
       BTUwax 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 and2 reasonable?

Response:    I don't know.
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1.9    The OMNI staff feels the emissions per unit of heat delivered (e.g., Ib/MBTU or g/MJ) is
       a more appropriate way to rank the performance of wood burning appliances than
       emission factors (Ib/ton or g/kg) or emission rates (g/hr). — Comments?

Response:     I agree.
1.10   Default 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 paniculate emissions. — What designs and technologies are
       available?  What retrofit options are there?

Response:     In 1991 or 1992,1 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.
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              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 ofcordwood. 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 out
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              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
       and2 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 replaced
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       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 draff—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 verify
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             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 paniculate 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.
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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 (YHC) 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?

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 the
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             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
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 they
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             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 Jive 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 CrestedButte,
       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 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: See response to 10.2
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10.2   Should 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 they
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             don't.
12.2   Should 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.
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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 non-
             catalytic 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 (densifiedandwax 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 par ticulate emissions occur during the kindling phase for
      non-catalytic wood stoves and more than half for catalytic wood stoves. Are there


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       improvements in technology that can mitigate this problem? Can specially designed high
       BTUwax 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 and2 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., Ib/MBTU or g/MJ) is
       a more appropriate way to rank the performance of wood burning appliances than
       emission factors (Ib/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.
1.10   Default 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 warranty
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              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 paniculate 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 ofcordwood. 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?
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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
       and2 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.
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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 paniculate 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 (YHC) 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?
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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 produce
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       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 CrestedButte,
       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 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:    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.
10.2   Should 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 paniculate 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?
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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.
12.2   Should 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.
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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 (densifiedandwax 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.

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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
       BTUwax 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 and2 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., Ib/MBTU or g/MJ) is
       a more appropriate way to rank the performance of wood burning appliances than
       emission factors (Ib/ton or g/kg) or emission rates (g/hr). — Comments?

Response:     I agree with you.
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1.10   Default 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 paniculate emissions. —  What designs and technologies are
       available? What retrofit options are therel
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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 ofcordwood. 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 I
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             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
       and2 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 yet
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             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.
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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 (YHC) 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?

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?
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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, radio
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             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 CrestedButte,
       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 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:    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.
10.2   Should 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 know
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             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.
12.2   Should 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 to

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              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.
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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—non-
              catalytics?

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 4-1/2 gram 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 4-1/2 grams 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?
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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 (densifiedandwax 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 or
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             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 paniculate 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
       BTUwax 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's
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              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 and2 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., Ib/MBTU or g/MJ) is
       a more appropriate way to rank the performance of wood burning appliances than
       emission factors (Ib/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.
1.10   Default 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 !/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,
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              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 paniculate 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 way, fire logs reduces emissions over the use ofcordwood.  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, with
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             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 off/replaces 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
       and2 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?
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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 air-
             to-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 the
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              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.)
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             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 paniculate 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 1-5 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.
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       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 (YHC) 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?

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 !/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, because
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             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 CrestedButte,
       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
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       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 very
       high temperatures over a one to two week period to predict long-term durability under in-
       home use.  Is this a reasonable approach?
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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.
10.2   Should 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.
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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 non-
             catalytic stove by very much, things go downhill very quickly. I think pellet stoves
             should be kicked in there too.
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12.2   Should 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.
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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 various

                                         A-103

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       densities can reduce paniculate 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 paniculate 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
       BTUwax 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 and2 reasonable?

Response:    No comment.
                                         A-104

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1.9    The OMNI staff feels the emissions per unit of heat delivered (e.g., Ib/MBTU or g/MJ) is
       a more appropriate way to rank the performance of wood burning appliances than
       emission factors (Ib/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.
1.10   Default 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-105

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2.2    There appear to be only a few practical design or technology options for fireplaces that
       will potentially mitigate paniculate 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 ofcordwood. 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-106

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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
       and2 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 today
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             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 characteristics
                                        A-108

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       (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 paniculate 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 (YHC) 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?

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-109

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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 CrestedButte,
       CO showed that emissions from some catalytic stoves became appreciably worse even
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       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 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:    No.
10.2   Should 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 this
                                         A-lll

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       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.
12.2   Should 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.
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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.
                                         A-113

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                                    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-l




Summary of Committee Comments	C-2
                                        C-iii

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Attendees to Solid Fuel Technical Committee Meeting

                                   Testing Services
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, HP A

• Michael Van Buren, Technical Director,
  HPA

• Denny Kingery, Product Engineer,
  Heatilator

• Wayne Terpstra, Vice President of
  Technical Services, Heatilator

• Rick Curkeet, Chief Engineer, Intertek
                                   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-l

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            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 ofwoodstove combustion and emission control technologies.

       1. I 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 uncertainly 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, whereas


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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 concerns 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.

       7.5 For non-catalytic stoves the heat retention adjustment with refractory material of
       various densities can reduce paniculate 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 paniculate 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
       BTUwax logs be used to achieve a fast start and reduce kindling phase emissions?
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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.,  Ib/MBTU or
       g/MJ) is a more appropriate way to rank the performance of wood burning appliances
       than emission factors (Ib/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? Should
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       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.

       7.77 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 efficiency


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of 3 0-40%.

       2.2 There appear to be only a few practical design or technology options for fireplaces
       that will potentially mitigate paniculate 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 ofcordwood.  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 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?

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 woodstove


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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 and2 reasonable'?

Table 1 information comes from Klamath Falls and Medford, as well as estimates by OMNI staff.

Jerry Whitfield stated that comparing paniculate 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 ofpellet
       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.)  Do you 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 is
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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 paniculate 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 data
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       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 of the 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 (YHC) is defined as a constant in the air-
       to-fuel ratio calculations in Method28A.  The molefraction of hydrocarbons in the vapor
       phase will vary significantly with fuel and combustion conditions. Should hydrocarbon
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       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 of 8/12/97 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 factor
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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 ofEPA-certifiedwoodstoves 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 very
       high temperatures over a one to two week period to predict long-term durability under in-
       home 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.
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11.    Feasibility of developing separate emission factors for dry and wet wood and for soft-
wood and hardwood species classes.

       11.1 Optimum wood moisture for low paniculate 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.

       77.2 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.

       72.2 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.

       72.3 What would the key elements of routine maintenance be?

This varies from model to model, and is covered in each individual owner's manual.
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