BAY AREA AIR QUALITY
    MANAGEMENT DISTRICT
January 26, 1999

Dear City Official:

The Board of Directors of the Bay Area Air Quality Management District has approved a model ordinance to reduce wood smoke from fireplaces. If adopted by a local community, the ordinance would require that fireplaces in new or remodeled construction be either EPA certified, pellet stoves or natural gas units. The ordinance does not ban fireplaces.

I am enclosing a packet of information on the model ordinance, including the ordinance, the resolution adopted by the Board of Directors, a fact sheet and a compilation of health studies on particulate matter. I hope you will review this information and consider bringing it to your city or county for adoption, particularly if your community has an existing wood smoke problem.

The Air District is concerned with wood burning because fireplaces and wood stoves generate 40 percent of the particulate matter in the Bay Area during the winter months. Of greatest concern are the fine particles, which can lodge deep in the lungs causing permanent lung damage and increasing mortality. The model ordinance would reduce the particulate pollution generated by a traditional fireplace by 75 percent for an EPA certified stove and 99 percent for a natural gas unit. Burning wood also generates carbon monoxide, nitrogen dioxide, volatile organics and toxic air pollutants.

The Bay Area meets the present federal health standard for particulate matter. However, we routinely violate the stricter California state standard. Because of increasing health studies on the dangers of fine particulate matter, the EPA recently promulgated a stricter federal standard that will become effective in 2002. It is unclear whether the Bay Area will meet the new EPA standard for fine particulate matter without additional controls.

The model wood smoke ordinance can be adopted as a whole or you may consider adopting only those provisions that are most applicable to your community. Air District staff are available to assist you. Please call Luna Salaver at (415) 749-5196 if you have questions about the ordinance or to request that an Air District representative meet with your community to discuss it.

Thank you for your consideration and for your efforts to make the Bay Area a cleaner and healthier place to live.

Sincerely,

(Signed)
Ellen Garvey
Executive Officer/
Air Pollution Control Officer

939 ELLIS STREET * SAN FRANCISCO, CALIFORNIA 94109 * (415) 771-6000 * FAX (415) 928-8560

A MODEL ORDINANCE PERTAINING
TO THE REDUCTION OF AIR POLLUTION BY REGULATING THE
NEW CONSTRUCTION OR REPLACEMENT OF WOODBURNING APPLIANCES

5BE IT ORDAINED BY the City or County of

[________________________________]:

WHEREAS, the State Air Resources Board (ARB) adopted a particulate matter (PM10) Ambient Air Quality Standard (AAQS) in December, 1982, and levels for the PM IO AAQS were selected pursuant to California Code of Regulations Title 17 Section 70200 to protect the health of people who are sensitive to exposure to fine particles; and

WHEREAS, research indicates that woodsmoke is a significant contributor to PM10 levels that pose significant health risks; and

WHEREAS, the [_______________] desires to lessen the risk to life and property from air pollution from woodbuming appliances; and

WHEREAS, the [_______________] finds that the proposed regulation will significantly reduce the increase in particulate emissions from future installation and construction activities; and,

WHEREAS, the [_______________] finds a need exists to adopt regulations which apply to woodbuming combustion emissions; and

The [_______________] Code shall be amended by adding the following:

APPLICABILITY: This ordinance shall apply within the limits of the [city, county] of [_______________] as specified herein.

All wood burning appliances installed in new residential units or woodburning appliances being added to or replacing woodbuming appliances in existing residential units shall comply with this Ordinance.

All woodbuming appliances installed in new commercial buildings or woodbuming appliances being added to or replacing woodbuming appliance in existing commercial buildings shall comply with this ordinance. Commercial buildings shall include, but not be limited to, hotels and restaurants.

Gas fireplaces shall be exempt from this ordinance. However, the conversion of a gas fireplace to burn wood shall constitute the installation of a woodbuming appliance and shall be subject to the requirements of this ordinance.

A woodbuming appliance shall comply with this ordinance if (1) it is reconstructed, (2) additions, alterations, or repairs are made to the appliance that require opening up immediately-adjacent walls, or (3) the residential unit or commercial building in which the appliance is located is renovated, and the renovation includes opening up walls immediately adjacent to the appliance.

DEFINITIONS:

1. "Bay Area Air Quality Management District" means the air quality agency for the San Francisco Bay Area pursuant to California Health and Safety Code Section 40200.

2. "E.P.A." means United States Environmental Protection Agency.

3. "E.P.A. certified wood heater" means any wood heater that meets the standards in Title 40, Part 60, Subpart AAA, Code of Federal Regulations in effect at the time of installation and is certified and labeled pursuant to those regulations.

4. "Fireplace" means any permanently installed masonry or factory-built woodbuming appliance, except a pellet-fueled wood heater, designed to be used with an air-to-fuel ratio greater than or equal to 35 to 1.

5. "Garbage means all solid, semi-solid and liquid wastes generated from residential, commercial and industrial sources, including trash, refuse, rubbish, industrial wastes, asphaltic products, manure, vegetable or animal solids and semi-solid wastes, and other discarded solid and semi-solid wastes.

6. "Gas fireplace" means any device designed to burn natural gas in a manner that simulates the appearance of a woodbuming fireplace.

7. "Paints" means all exterior and interior house and trim paints, enamels, varnishes, lacquers, stains, primers, sealers, undercoatings, roof coatings, wood preservatives, shellacs, and other paints or paint-like products.

8. 'Paints solvents" means all original solvents sold or used to thin paints or to clean up painting equipment.

9. 'Pellet-fueled wood heater" means any woodbuming appliance that operates exclusively on wood pellets.

10. "Solid fuel" means wood or any other non-gaseous or non-liquid fuel.

11. "Treated wood" means wood of any species that has been chemically impregnated, painted or similarly modified to improve resistance to insects or weathering.

12. "Waste petroleum products" means any petroleum product other than gaseous fuels that has been refined from crude oil, and has been used, and as a result of use, has been contaminated with physical or chemical impurities.

13. "Woodbuming appliance" means fireplace, wood heater, or pellet-fired wood heater or any similar device burning any solid fuel used for aesthetic or space-heating purposes.

GENERAL REQUMENTS: It shall be unlawful to:

1 Use any woodbuming appliance when the Bay Area Air Quality Management District issues a "Spare the Air Tonight" warning and when an alternate approved heat source is available.

2. Install a woodbuniing appliance that is not one of the following: (1) a pellet-fueled wood heater, (2) an EPA certified wood heater, or, (3) a fireplace certified by EPA should EPA develop a fireplace certification program.

3. Use any of the following prohibited fuels in a woodbuming appliance.

ENFORCEMENT: Any person who plans to install a woodbuming appliance must submit documentation to the [building department of city or county] demonstrating that the appliance is a pellet-fueled wood heater, an EPA certified wood heater, or a fireplace certified by EPA should EPA develop a fireplace certification program.
Any person violating any of the provisions of this Ordinance shall be deemed guilty of a misdemeanor and upon conviction shall be punishable as provided by law.

IF ANY SECTION, subsection, sentence, clause or phrase or word of this ordinance is for any reason held to be unconstitutional by a court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this ordinance. The [_____________] of the [______________] hereby declares that it would have passed and adopted this ordinance and all provisions thereof irrespective of the fact that any one or more of said provision be declared unconstitutional.

INTRODUCED and ordered Posted/Published this [______] day of [__________] ADOPTED this [______] day of [______] by the following vote:

AYES:

NOES:

ABSTAIN:

ATTEST:

_____________________________

p:\general\boardmem\modord

_____________________________

APPROVED AS TO FORM

_____________________________

Bay Area Air Quality Management District
939 Ellis Street
San Francisco, CA 94109

November 2, 1998

TO: CHAIRPERSON JOHNSON AND MEMBERS OF THE AD HOC COMMITTEE ON WOODSMOKE

FROM: EXECUTIVE OFFICER

: SUBJECT: FIREPLACE "EQUIVALENCE" IN THE MODEL ORDINANCE

Executive Summary

At its August 27, 1998 meeting, the BAAQMD Board of Directors Ad Hoc Committee on Woodsmoke considered a draft model woodsmoke ordinance that could be adopted by Bay Area cities and counties. The ordinance would apply to the installation or replacement of wood-burning devices within a locality adopting the ordinance.

In developing specific language for the model ordinance, the Committee asked staff to (1) determine whether it is possible to establish a particulate matter (PM) certification standard for fireplaces that is "equivalent" to the standard for woodstoves found in EPA's wood heater new source performance standards (NSPS) and (2) if so, provide language for incorporating this "equivalence" into the model ordinance being considered by the committee.

To respond to committee's request, staff conducted an extensive review of the technical literature on fireplace emissions; met with Mr., Paul Tiegs of OMNI Environmental Services, Inc., the company that has done all fireplace testing for compliance with the State of Washington fireplace standard; and discussed fireplace emissions and standards with other air quality agency staff. This memorandum addresses the committee's request and conveys the following staff findings and recommendations:

Findings

Recommendations

A revised model ordinance incorporating these recommendations is attached.

Fireplace "Equivalence"

The NSPS - Emission Rates vs. Emission Factors

In 1988, EPA adopted New Source Performance Standards (NSPS) for woodstoves (1). EPA projected that the NSPS would reduce woodstove emissions by about 70 percent (1). However, the EPA standards apply to only a small subset of wood-burning devices in common usage. By carefully defining and limiting the applicability of the standard to small woodstoves, EPA was able to set an emission rate limit which prohibits particulate emissions greater than 7.5 grams per hour.

An emission rate limit Like the one in the EPA standard is somewhat unusual in air pollution control. Most emission Limits are concentration limits (e.g. 15 ppm NOX for a gas turbine), emission factor limits (e.g. grams of VOC per gallon of coating applied), or control requirements (e.g. reduce emissions by 90%). These three types of limits do not impose any restriction on the size of an operation (e.g. a turbine, a coating line, or other operation). They simply require that emissions, regardless of overall amount, meet the limits or restrictions.

An emission rate limit, like the one in the EPA NSPS, has a tendency to require different levels of control depending on the size of the source. A small source might produce 7.5 grams per hour of emissions without controls and would therefore require no additional controls. A large source on the other hand, might produce emissions far greater than 7.5 grams per hour, thus requiring significant combustion controls like staged combustion or post-combustion controls like a catalyst.

For the woodstove NSPS, EPA limited applicability to small sources by defining an "affected facility" as a wood heater (woodstove) with (1) an air to fuel ratio of less than 35 to 1, (2) a firebox volume of less than 20 cubic feet, (3) a minimum burn rate of less than 5 kilograms per hour (kg/hr), and (4) a weight of less than 800 kilograms (1). It then set an emission rate standard that could be met by stoves using combustion air controls or catalysts. At the time, EPA recognized that such an emission rate standard had no useful application beyond the narrow universe it had defined, but argued that the standard allowed woodstove-to-woodstove comparisons, which was all it sought (2).

Fireplaces

The NSPS does not apply to fireplaces or other devices that do not meet the definition of "affected facility" in the NSPS (1).

There are four types of wood-burning devices that are commonly called "fireplaces" and that are not subject to the woodstove NSPS:

There are two types of devices commonly called fireplaces that are subject to the woodstove NSPS or, in the case of some pellet-burning devices with air to fuel ratios greater than 35 to 1, that can meet the NSPS emission limits:

In addition to the above wood-burning devices, there are two types of gas-burning devices that are called "fireplaces." They are not subject to the NSPS.

Fireplace Emissions

EPA compiles emission factors for sources of air pollution in a document called AP-42. The AP-42 emission factors are used by local and state agencies in calculating emission inventories, The AP-42 particulate emission factor for wood-burning fireplaces is 17.3 grams per kilogram of wood burned (3).

EPA's emission factors are based on limited data. Given the significance of fireplace emissions in many local PM emission inventories, it is surprising how few studies have examined fireplace emissions. The following table (derived from Jaasma (4) with data adding two more recent studies) sets forth results from the available fireplace studies.

STUDYYEARNO. of FIREPLACESAVERAGE FUELING RATEAVERAGE PM EMISSION FACTOR (g/kg)AVERAGE PM EMISSION RATE (g/hr)
Reitz (5)199317.98.679.7
Jaasma (6)199213.3*10*32**
Jaasma (4)199263.71344
Colorado/Shelton (7)198713.51553
Dasch (8)198224.1833***
ARB (9)1980215.733518***
EPA/PEDCo (10)197925.121107***
EPA (11)197517.31076

Notes

The more recent studies listed above involved explanation or validation of emission test methods. Because dry fuel, generally dimensional lumber, was used, the emission factors and rates are probably lower than they would be in real-world fireplace use. However, though there is limited data, the more recent studies indicate that fireplace particulate emissions under test conditions appear to be about 50 grams per hour and about 12 grams per kilogram of wood burned.

In the June, 1998 issue of HPA Journal, a quarterly journal published by the Hearth Products Association, Dr. James Houck, vice president of Omni Environmental Services, Inc. states that "... the typical emission rate of a simple open radiant fireplace is about 60 g/hr"." Omni has done all of the compliance testing to date for the Washington State fireplace method.

In a meeting with District staff on October 8, 1998, Paul Tiegs, also of Omni, discussed fireplace emissions. In a paper he prepared to summarize information on fireplaces, Mr. Tiegs stated:

Comparison of Fireplace Emissions to Woodstove Emissions

In addressing fireplaces in the model ordinance, it is important to know how emissions from fireplaces and woodstoves compare. To compare particulate emissions between fireplaces and EPA-certified woodstoves, it is useful to know how the two are typically used in the Bay Area. Very few homes in the Bay Area rely solely on wood as a heating fuel. According to the 1990 census 41696 Bay Area units rely on wood for heat. given an estimated 300,000 woodstoves in the Bay Area, most woodstove use is for recreation and auxiliary heating. Though the District has no survey data on this point, it is reasonable to assume that typical woodstove use is heating a living area for an evening starting at 5:00 pm and ending at midnight.

There are an estimated 1 million to 1.5 million fireplaces in the Bay Area. Although there is also no survey data for Bay Area fireplace use, a Colorado survey and a survey by Dennis Jaasma at Virginia Polytechnic Institute indicate that the typical fireplace fire lasts for 4 hours (6). Based on these assumptions, the table below compares emissions from typical fireplace use and typical woodstove use. Note that emission factors and rates for both woodstoves and fireplaces are based on laboratory testing. Actual emissions in real-world use may be greater for both woodstoves and fireplaces. Emissions from pellet heaters and gas fireplaces are included for comparison.

DEVICEEMISSION FACTOR (G/KG)EMISSION RATE (G/HR)LENGTH OF EVENING USEPM EMISSIONS IN A TYPICAL EVENING OF USE
Wood-burning fireplace12504200
Certified woodstove7.37.5752.5
Certified Pellet heater2.1177
Gas fireplacen/a0.0770.5

Note

Fireplace proponents occasionally claim that fireplaces burn "cleaner" than woodstoves. There is an element of truth in this. Though they produce more particulate pollution in typical use, some fireplaces can burn more cleanly than some woodstoves if you look at emission factors rather than emission rates. In addition, fireplaces can also produce significantly lower polycyclic aromatic hydrocarbon (PAH) emissions than even the cleanest certified woodstoves (except for certified pellet heaters). PAHs are a subgroup of polycyclic organic matter (POM). POM is regulated under the federal Clean Air Act as a hazardous air pollutant and by the State of California as a Toxic Air Contaminant. A number of PAHs are carcinogenic. The EPA emission factor for all fireplace POM is 0.008 Fares per kilogram of wood burned (3), For certified catalytic stoves, however., the PAH emission factor is 0.20 grams per kilogram and for certified non catalytic stoves, it is 0.25 grams per kilogram (14). Even allowing for the difference in burn rates, fireplaces can be cleaner than woodstoves for PAH. However, as noted earlier, emission rates for combined particulate matter are much higher for fireplaces. Note that pellet heaters burn more cleanly than fireplaces or woodstoves and have a PAH emission factor of 0.0001 grams per kilogram (14) and gas fireplaces are significantly cleaner than any wood-burning device.

"Equivalence' - G/Kg vs. G/Hr

The use of the term "equivalence" in describing the Washington State fireplace standard or other proposed fireplace standards is unfortunate and misleading. Despite their similarities, fireplaces and woodstoves are not equivalent devices. Woodstoves are lowburn-rate devices with burn rate controlled by restrictions on combustion air. The average of the four bum rates used in EPA test procedures used for wood stoves is 1.03 kg per hour. Woodstoves typically have thermal efficiencies (a measure of the ability of a device to transform fuel into heat) of 60-70% and are used for heating.

Fireplaces are high-burn-rate devices (i.e. they burn a lot more wood in an hour than woodstoves) that have unrestricted combustion air. Fireplaces generally have burn rates of about 3 kg per hour and low thermal efficiency (7-11%). They are generally not used as heaters and are instead used for aesthetic or recreational reasons.

As discussed above, fireplaces produce much more particulate pollution per hour than woodstoves, largely because of their higher bum rates. As a result, fireplaces cannot compete with woodstoves on an emission rate basis in grams per hour.

Origins of the Washington Fireplace Standard

A 1994 law directed the State of Washington's Department of Ecology to establish statewide emission performance standards for wood stoves and fireplaces (16). The law Stated that factory-built fireplaces were to meet the EPA NSPS standards "... or equivalent standard that may be established by the state building code council by rule" and were to be tested using a method developed by the council. The council was also directed to develop design standards for masonry fireplaces that achieved emission reductions similar to those achieved by factory-built fireplaces.

The Washington Building code Council was thus faced with a legislative mandate to develop an "equivalent" standard for devices (fireplaces) than cannot possible meet the EPA standard. The essential problem with this legislatively-mandated "equivalence" is the difference in the burn rates (and emission). Because fireplaces burn much more wood per hour than certified woodstoves, they cannot meet an emissions rate limit for woodstoves. To get around this problem, the council used the AP-42 emission factor for certified woodstoves of 7.3 grams per kilogram. This became the Washington state limit for fireplaces.

Air pollution standards are normally developed in a manner very different from that used to derive the "Washington standard. The first step in setting a standard is to determine the type and magnitude of typical emissions from the source. The second step is then to identify control technologies and the degree of emission reduction achievable by each technology. The final step is to set a standard based on a chosen technology, taking into account the availability, cost, and environmental impacts of the technology (17).

For the woodstove NSPS limit, for example, EPA identified specific control technologies, including combustion controls and catalysts, that are proven means of reducing particulate emissions (1). It then set a standard based on emission reductions achievable using those controls. The Washington state limit, on the other hand, does not result from such an examination. Instead the standard is purely the result of the legislative mandate. It simply translates an emission rate for woodstoves into an emission factor and then applies it to fireplaces.

As a result of the failure to set a standard based on control technologies, the Washington standard appears not to draw a line between clean and dirty fireplace technologies. It appears only that small fireplaces tend to make the list while larger ones do not. since evidence indicates that emissions factors vary with fueling rate (6)=, small fireplaces would tend to have lower emission factors and would therefore tend to pass the Washington emission factor standard. This tendency appears to be borne out in the limited testing done for the Washington standard (18). Thus, it may be that the only effect of the Washington standard is to screen our large fireplaces.

Are There Cleaner Fireplaces?

In setting a fireplace emission standard, the question should be, "Are there any technologies for reducing emissions?" At present the answer is "Possibly, but only the extremely wealthy can afford them." According to Dr. Dennis Jaasma, a national expert on fireplace emissions and testing:

Several "fireplaces" on the Washington list use identified control technologies, either combustion air controls of catalysts, to reduce particulate emissions. However, these units are EPA-certified woodstove "fireplaces". Most of the units on the list, however, are "builder boxes" of conventional design with no control technologies. Two cast masonry systems on the list, the Buckley Rumford and Frisch-Rosin systems, for which emission reduction claims have been made, performed more poorly than a conventional masonry fireplace in tests by Dr. Jaasma(20).

In discussions with District staff, Paul Tiegs admitted that he did not know whether there is a cleaner-burning fireplace(18). He said that some extremely wealthy homeowners in Aspen, Colorado, which has strict woodsmoke controls, have installed electrostatic precipitators in masonry fireplaces. Electrostatic precipitators are extremely expensive both to install and to operate. Dr. Jaasma has apparently worked on an afterburner for fireplaces, but, according to Tiegs, there are significant difficulties with such an approach.

Washington Test Method

To certify fireplaces, Washington State adopted a test method developed by its Building Code Council(21). The method is the only adopted regulatory fireplace test method in the nation.

After review of the test method, discussion with Mr. Tiegs, and discussions with staff from other California air districts, staff feel that the Washington method is sound in most respects. However, staff have identified two potential problems with the method.

The first problem is that the sampling protocol allows sampling to continue well after a fire is out. This is because the method requires sampling to begin when the temperature of the flue gas is 25 degrees F. higher than the ambient temperature and end when the temperature of the flue gas returns to this level. Especially with masonry systems, the result may be a multi-hour period at the end of the test when the masonry is still radiating retained heat, no combustion is occurring, and samples are of clean air. Although this extended sampling period should not affect a test result expressed as an emission factor (i.e. in terms of grams of PM per kilogram of wood burned), it has the effect of lowering the calculated burn rate (i.e. kilograms of wood burned per hour), since no more wood is burned during the extended period. If this lower burn rate is then used to convert the emission factor into and emission rate:

it will result in a lower emission rate than would be the case if the burn rate were calculated for the shorter period when the burning is actually occurring. this produces misleading emission rate results.

The second problem with the test method id that inadequate data exists to demonstrate the repeatability of test results for a particular fireplace when tested by the same lab or by different labs. As noted, only 14 fireplaces have been tested, and all test were conducted by OMNI Laboratories in Oregon. Without repeated testing of fireplaces by OMNI and by other laboratories, nothing can be said about whether different labs would produce the same ranking of fireplaces by emission levels. Such repeatability of results is important for a fireplace test method(20).

The Northern Sonoma County APCD is now working on a test method that may minimize or eliminate the problems associated with the lengthened test period of the Washington State method(22). Northern Sonoma currently proposes to end sampling when flue gas oxygen returns to a level that indicates active burning has ended. Northern Sonoma also currently plans testing to verify test repeatability.

Recommendations

Based on the analysis summarized above, staff make the following recommendations:

1. The model ordinance should not include "equivalence" language for fireplaces.

Discussion: As discussed at length above, fireplaces and woodstoves are not equivalent devices. fireplace emissions are significantly higher than woodstove emissions and only appear similar when viewed on an emission factor basis. There are no reasonably-available emission control technologies available for fireplaces as there are for woodstoves.

2. The model ordinance should not reference the Washington State fireplace standard or test method.

Discussion: The Washington State standard, unlike the NSPS, is not the result of an analysis of emissions and available control technologies, with the setting of a standard that favors clean technologies over dirty technologies. Instead, the Washington standard is the result of a legislative-mandated equivalence. The fundamental problem with the standard is the lack of any reasonably-available control technologies for fireplaces. "The test method appears to include an appropriate test protocol but the test termination procedure produces misleading emission rate results. Repeatability of test results has not been demonstrated.

3. The model ordinance should require that all devices be EPA-certified units or pellet heaters, or be gas-burning devices. where gas units are installed, provisions should prohibit conversion to non-complying wood-burning devices.

Discussion: Most fireplaces now installed in new construction are "builder boxes". The requirement that wood-burning devices be EPA-certified would mean that builders who want to install wood-burning devices or pellet heaters would have to install EPA-certified zero clearance "woodstove" fireplaces ("EPA fireplaces"). The aesthetic differences between builder boxes and EPA fireplaces are minor. The major difference is cost. The higher costs of EPA fireplaces would reduce builder profits. Gas burning fireplaces would be less costly and more environmentally desirable than wood-burning devices. Where builders install gas appliances, the model ordinance should prohibit conversion to wood-burning devices not allowed under the ordinance.

A copy of suggested changes to the model ordinance to incorporate recommendations is attached.

References

[not complete]
Snowden, W.D., D.A. Alguard, G.A. Swan5on, =d W.E. Stolberg. 1975. Source Sampling .Resi4dential Fir,-placesfor Emission Factor Development. Research T@gle Park, NC: U. S. EPA, Pubt. No. EPA 450/3-76-010. 12. Houck, J.E. 1998. "It's Win-Wia: New Hearth Product Sales Can Be Part of the Solution for New Air @ty Regulations." HPA Journal 2(2); 10-18. 13. Houck, J.E. and P. Tiegs, P.F-. 1998. "Fireplace Use and Tectmology Review." Paper presented to Bay Area Air Q=4ty M=agement District staff, October 8, 1998, 14. U.S. Environmen@ Protection Ageucy. 1996. " 1. IO Residentw Wood Stoves." AP-42, @mpilation OfAirPdllutantEminion Factors: (Extc@ Combustion Souices), 5th ed. Research Tnangle P@ N-C.- USEPA. 15. U.S. Eavirownental Prot@on Agency. 1998. "1.4 Na@ @ Combustion." AP-42, Compilation ofair Pollutant Emission Factors. (Exte@ Combustion Sources), 5th ed. Research T@gle Park-, N.C.; USEPA. 16, Re@ed Code of Washington section 70.94.457. 17. See, e.g., California Health and Safety Code s@ou 40406 de@g "best available retrofit control technology." 18. Tiegs, P.E. Presentation to Bay Area Air @lity Management District staff, October 8, 1998. 19. W@ou State Department of Ecology, "Certified Woodstoves, Authorized Fireplaces and Other Solid Fuel Buming Devices." List maintained by DOE Air Q=hty Pro@ i-@ed October 2, 1998. Olympia: Washington DOE. 20. Stern, C.H., D. R- J and M.R- @ion. 1993. "Masonry Fireplace Emissions Test Method; Repeatability and Sensitivity to Fuelwg Protocol." Environ. Mon. Assess. 25. 51-64. 21. "Washington State Standard Test Method for Particulate Emissions from Fireplaces." Washington Uniform Building Code Standard 31-2, Washington Adminitrative Code 51-30-31200 section 31.200. 22. Northern Sonoma County Air Pollution Control District. 1997. Testing Protocolfor ParticWate Emissions)'rom Masonry Fireplaces. Draft test method dated December 10, 1997. H@dsbuyg, California: NSCAPCD.

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