### August 24, 2010

MEMORANDUM

TO: Docket No.: EPA-HQ-OAR-2010-0786

FROM: Kaye Whitfield, Project Lead

Risk and Technology Review (RTR) - National Emission Standards for

Hazardous Air Pollutants (NESHAP) for Wood Furniture Manufacturing

Operations

SUBJECT: Developments in Practices, Processes, and Control Technologies for Wood

Furniture Manufacturing Operations

The purpose of this memorandum is to identify any developments in practices, processes,

and control technologies for hazardous air po llutant (HAP) emission sources for the Wood

Furniture Manufacturing Operations source category. This analys is is part of EPA’s review

efforts in accordance with section 112(d)(6) of the Clean Air Act.

Section 1 provides background information on section 112(d)(6), the Wood Furniture

Manufacturing Operations source category, and the requirements of the national emission

standards for HAP (NESHAP) that address emissions from this category. Section 2 discusses the

exploration of developments in pr actices, processes, and control technologies that have occurred

since the original development of these NESHAP.

1.0 BACKGROUND

1.1 Section 112(d)(6)

Section 112 of the Clean Air Act required EPA to establish technology-based standards

for listed source categories. Th ese technology-based standards are often referred to as maximum

achievable control technology, or MACT, standa rds. Section 112 also contains provisions

requiring EPA to revisit these standards. Specifically, paragraph 112(d)(6) states:

(6) REVIEW AND REVISION. – Th e Administrator shall review,

and revise as necessary (taking into account developments in practices,

processes, and control technologies ), emission standards promulgated

under this section no less of ten than every 8 years.

### 1.2 Description of the Source Category and MACT Standard 1



### The Wood Furniture Manufactur ing Operations MACT sour ce category consists of

facilities engaged in th e manufacture of wood furniture or wood furniture components. The

industry encompasses the applicatio n of any protective, decorative, or functional coating to wood

furniture or wood furniture components. This source category includes wood kitchen cabinets,

wood residential furniture, upholstered residential and office furniture, wood office furniture and

fixtures, partitions, shelving, locker s, and other wood furniture not included in one of the above

categories. The coatings contain volatile or ganic compounds (VOC) and volatile hazardous air

pollutants (VHAP) which evaporat e and can contribute to ground-level ozone and air pollution.

Finishing, gluing, cleaning, and washoff operations are the four proces ses that take place

during wood furniture manufacturing that result in VHAP emissions. Finishing materials include

stains, basecoats, washcoats, glazes, fillers, seal ers, highlights, enamels, and topcoats. After a

finishing material is applied, th e coated or stained wood substrat e typically enters a flashoff area

where the more volatile solvents (including VHAP) evaporate and th e finishing material begins

to cure. The wood substrate then enters an oven where curing of the finishing material and

evaporation of the volatil e solvents continues.

Gluing operations occur at most, but not all, wood furniture facilities. Four major types

of adhesives are used in the i ndustry: hot melts (which are no t a source of VHAP emissions),

polyvinyl acetates (PVA), urea-for maldehyde (UF resins), and c ontact adhesives. Of these

adhesives, only contact adhesives applied to por ous substrates are covered by the NESHAP. The

VHAP contained in contact adhesives varies according to the solvent used.

Cleaning activities include the use of high-solv ency-rated solvents to dissolve resins into

the coating mix and to remove dried coatings. These industrial solvents sometimes contain

VHAP that evaporate when the solv ent is exposed to the air and ar e subsequently discharged to

the atmosphere via ventilation air.

The washoff process uses solvent to remove cured coating. This process is used when

finished furniture does not meet speci fications and requires refinishing.

The Wood Furniture Manufacturing Operations MACT standard was originally proposed

in the Federal Register on December 6, 1994 (59 FR 62652) and promulgated on December 7,

1995 (60 FR 62930). The MACT rule consists of work practice standards, recordkeeping

requirements, reporting requirements, and emi ssion limits for finishing operations, contact

adhesives, and strippable spray booth coatings. Summaries of emission limits and work practice

requirements are provided in Tables 1 and 2.

1 U.S. Environmental Protection Agency. 1996. Guideline Series, Control of Volatile Organic Compound

Emissions from Wood Furniture Manufacturing Operations. U.S. EPA, Office of Air and Radiation, Emission

Standards Division, Research Triangle Park, NC. EPA/453/R-96/007. April.

### Typical control options used to reduce em issions from finishing, cleaning, gluing, and

washoff operations are compliant co atings and work practices. Faci lities can apply finish coating

materials that have VHAP content levels (on a coa ting type basis) at or below the emission limits

established in the NESHAP. Work practices include inspection and maintenance plans to

prevent leaks as well as using covers on washo ff tanks. Destructive control devices such as

thermal oxidizers are allowed by the NESHAP as co mpliance alternatives to compliant coatings

but are not often used in this industry.

When the MACT rule for this source cat egory was promulgated in 1995, approximately

750 major source facilities were aff ected by the rule. Affected f acilities are major sources that

manufacture wood furniture or wood furniture co mponents. In some instances, wood furniture

manufacturing operations may be co-located with operations subject to other NESHAP, such as

the surface coating of metal furniture NESHAP (40 CFR part 63, subpart RRRR) and the surface

coating of wood building products NES HAP (40 CFR part 63, subpart QQQQ).

The wood furniture NESHAP contains provision s for a facility to limit its emissions and

thereby qualify as an area source not subject to the wood furniture NESHAP. Facilities are not

subject to the NESHAP if they use no more than 250 gallons per month or no more than 3,000

gallons per rolling 12-month period of coating, gluing, cleaning, and was hoff materials at the

facility, including materials used for source ca tegories other than wood furniture (40 CFR

63.800(b)(1)-(2)). The amount of finishing materi als, adhesives, cleani ng solvents, and washoff

solvents must account for at leas t 90 percent of annual HAP emissi ons at the plant site (40 CFR

63.800(b)(1)). The wood furniture NESHAP contains a similar provision fo r facilities that use

no more than 4.5 Mg of any one HAP or no more than 11.4 Mg of any combination of HAP per

rolling 12-month period (40 CFR 63.800(b)(3). Qualifying faci lities must keep records

documenting that these criteria are met (40 CF R 63.800(a)). The wood furniture NESHAP also

contains a provision excluding a major source facil ity from other provisio ns of the NESHAP if

the facility is primarily engage d in the manufacture of products other than wood furniture or

wood furniture components and uses no more than 100 gallons per month of finishing material or

adhesives in the manufacture of wood furn iture or wood furniture components (40 CFR

63.801(a)).

### Table 1: Summary of Emissions Limits (40 CFR 63.802(a)(1))

Emission point Existing source New source

Finishing Operations

(a)Achieve a weighted average VHAP content across all coatings

(maximum kg VHAP/kg solids [lb VHAP/lb solids], as applied); 1.0 a 0.8 a

(b)Use compliant finishing materials (maximum kg VHAP/kg solids [lb

VHAP/lb solids], as applied);

- stains

- washcoats

- sealers

- topcoats

- basecoats

- enamels

- thinners (maximum % VHAP allowable); or 1.0 a

1.0 a b

1.0 a

1.0 a

1.0 a b

1.0 a b

10.0 1.0 a

0.8 a b

0.8 a

0.8 a

0.8 a b

0.8 a b

10.0

(c)As an alternative, use control device; or 1.0 c 0.8 c

(d)Use any combination of (a),(b), and (c) 1.0 0.8

Cleaning Operations

Strippable spray booth material (maximum VOC content, kg VOC/kg solids

[lb VOC/lb solids]) 0.8 0.8

Contact Adhesives

(a)Use compliant contact adhesives (maximum kg VHAP/kg solids [lb

VHAP/lb solids], as applied) based on following criteria

i.For aerosol adhesives, and for contact adhesives applied to nonporous

substrates NA d NA d

ii.For foam adhesives used in products that meet flammability requirements 1.8 0.2

iii.For all other contact adhesives (including foam adhesives used in

products that do not meet flammability requirements); or 1.0 0.2

(b)Use a control device 1.0 e 0.2 e

a The limits refer to the VHAP content of the coating, as applied.

b Washcoats, basecoats, and enamels must comply with the limits presented in this ta ble if they are purchased

premade, that is, if they are not formulated onsite by thinning other finishing materials. If they are

formulated onsite, they must be fo rmulated using compliant finishing ma terials, i.e., those that meet the

limits specified in this table, and thinners containing no more than 3.0 percent VHAP by weight.

c The control device must operate at an efficiency that is equivalent to no greater than 1.0 kilogram (or

0.8 kilogram) of VHAP being emitted from the affected emission source per kilogram of solids used.

d There is no limit on the VHAP content of these adhesives.

e The control device must operate at an efficiency that is equivalent to no greater than 1.0 kilogram (or

0.2 kilogram) of VHAP being emitted from the affected emission source per kilogram of solids used.

### Table 2. Summary of Work Practice Standards a 

### (40 CFR 63.803)

EMISSION SOURCE WORK PRACTICE

Finishing Operations

Transfer equipment leaks Develop written inspection and maintenance plan to address and prevent

leaks. The plan must identify a minimum inspection frequency of 1/month.

Storage containers, including

mixing equipment When such containers are used for VHAP or VHAP-containing materials,

keep covered when not in use.

Application equipment Discontinue use of conventional air spray guns. b

Finishing materials Demonstrate that usage of VHAP of potential concern have not increased

except as allowed by proposed standards; document in the formulation

assessment plan.

Cleaning Operations

Gun/line cleaning -Collect cleaning solvent into a closed container.

-Cover all containers associated with cleaning when not in use.

Spray booth cleaning Do not use solvents except as allowed by the rule.

Washoff/general cleaning -Do not use chemicals that are listed in Table 4 of the rule in concentrations

subject to MSDS reporting, as required by OSHA.

-Keep washoff tank covered when not in use.

-Minimize dripping by tilting and/or rotating part to drain as much solvent as

possible and allowing sufficient dry time.

-Maintain a log of the quantity and type of solvent used for washoff and

cleaning, as well as the quantity of waste solvent shipped offsite, and the

fate of this waste (recycling or disposal).

-Maintain a log of the number of pieces washed off, and the reason for the

wash off.

Miscellaneous

Operator training All operators shall be trained on proper application, cleanup, and equipment

use. The training program shall be written and retained onsite.

Implementation plan Develop a plan to implement these wo rk practice standards and maintain

onsite.

a The work practice standards apply to both existing and new major sources.

b Conventional air spray guns will be allowed only in any of the following instances;

- when they are used to apply finishing materials that emit less than 1.0 kg VOC per kg solids used;

- touchup and repair under limited conditions;

- when spray is automated;

- when add-on cont rols are employed;

- if the cumulative application is no more than 5 percent of the total gallons of finishing material applied; or

- if the permitting agency determines that it is economically or technologically infeasible to use other application

technologies.

### 2.0 PRACTICES, PROCESSES, AND CONTROL TECHNOLOGIES

For the purpose of this exercise, EPA considered a “development” to be:

• Any add-on control technology or other equipmen t that was not identified and considered

during MACT development,

• Any improvements in add-on control technology or other equipment (that was identified

and considered during MACT development) that could result in significant additional

emission reduction,

• Any work practice or operational procedure that was not identified and considered during

MACT development, and

• Any process change or pollution prevention alte rnative that could be broadly applied that

was not identified and consider ed during MACT development.

Table 3 summarizes the practices, processes, and control technologi es considered during

the development of the MACT standard. This is followed by descriptions of the searches for

developments since that time. The specific informa tion sources that were consulted in this effort

included EPA regulatory efforts conducted subseque nt to these rulemakings (section 2.1), EPA’s

RACT/BACT/LAER Clearinghouse (s ection 2.2), and contacts with the industry (section 2.3).

Table 3. Summary of Practices, Processes, and Control Technologies Identified and

Considered During Wood Furniture MACT Development

Source Category/

Emission Source Practices, Processes, and Control Technologies

Finishing operations Compliant finishing materials

Finishing operations Add-on control devices

Cleaning operations Strippable spray booth material with lower VOC content

Contact adhesives Compliant contact adhesives

Contact adhesives Add-on control devices

Finishing operations,

cleaning operations Work practice standards

### 2.1 Subsequent Regulatory Development Efforts

As noted above, the Wood Furniture Manufact uring MACT standards were promulgated

on December 7, 1995. Since that time, state regulatory agencies, notably those in California,

have developed stricter and mo re specific standards for wood furniture, flat wood paneling, and

spray booths. EPA has developed Control Tec hniques Documents (CTGs) for VOC emissions

from Flat Wood Paneling Coatings (2006) 2 

### , Automobile and Light-Duty Truck Assembly

Coatings (2008) 3 

### , and Miscellaneous Metal and Plastic Parts Coatings (2008) 4 

### . EPA has also

promulgated NESHAPs for Automobile and Light-Dut y Truck Assembly Coatings (subpart IIII),

Miscellaneous Metal and Plastic Parts Coatin gs (subpart MMMM), and Wood Building Products

(subpart QQQQ).

2.1.1 California Wood Furniture Manufacturing Regulations

The Antelope Valley Area Air Quality Mana gement District re stricts application

equipment to minimize emissions. California Ru le 481 limits application to high volume-low

pressure (HVLP) sprayers or other app lication methods of similar efficiency:

(a) A person shall not use or operate any spray painting or spray coating equipment unless

one of the following conditions is met:

(1) The spray coating equipment is operated in side a control enclosure which shall be

exhausted only through filters at a design face velocity not less than 100 feet per

minute nor greater than 300 f eet per minute, or through a water wash system designed

to be equally effective for the purpose of air pollution control.

(2) Coatings are applied with electrostatic and/or airless spray equipment. (Also

recommended in Waste Reduction Guide.)

(3) A method of application or c ontrol is used which has an effectiveness equal to or

greater than the equipmen t specified in subsection (a)(1) or (a)(2) of this rule.

(b) The provisions of this rule shall not apply to:

Any control enclosure connected to an external air pollution control device with a control

efficiency equivalent to the filters specified in subsection (a)(1) of th is rule and which has

been approved by the Executive Officer.

2 U.S. Environmental Protection Agency. 2006. Control Techniques Guidelines for Flat Wood Paneling Coatings.

U.S. EPA, Office of Air and Radiation, Sector Policies and Program Division, Research Triangle Park, NC. EPA

453/R-06-004. September.

3 U.S. Environmental Protection Agency. 2008. Control Techniques Guidelines for Automobile and Light-Duty

Truck Assembly Coatings. U.S. EPA, Office of Air and Radiation, Sector Policies and Program Division, Research

Triangle Park, NC. EPA-453/R-08-006. September.

4 U.S. Environmental Protection Agency. 2008. Cont rol Techniques Guidelines for Miscellaneous Metal and

Plastic Parts Coatings. U.S. EPA, Office of Air and Ra diation, Sector Policies an d Program Division, Research

Triangle Park, NC. EPA-453/R-08-003. September.

### The Bay Area Air Quality Management Distri ct has adopted more stringent VHAP limits

under California Regulation 8-32, which came into effect in July 2010. Such state enforced

limits on VOC content in wood coatings have been used successfully. VOC limits enforced by

California Regulation 8-21 are shown in Table 4.

Table 4. Summary of Coating Requiremen ts from California Regulation 8-32

### 2.1.2 EPA CTGs for Subsequent Regulations

Flat wood paneling (wood building products) (2 006), controls include low VOC coatings,

ultraviolet cure and electron beam cure coa tings, add-on controls, and work practices.

Recommended add-on controls incl ude oxidizers and solvent rec overy systems that achieve 90

percent control efficiency. Work practices in clude: (1) frequent visual inspections for all

equipment used to transfer or apply coatings, adhesives, or organic so lvents; (2) cleaning and

wash off solvent accounting system; (3) coll ecting and containing all VOCs when cleaning

coating lines and spray guns; and (4) using low-VOC or low-vapor pressure cleaning materials.

Cost effectiveness, in 2005 dollars, was estimated to be $1,900/ton VOC reduction for interior

paneling/tileboard and $2,600/ton VOC reduction for exterior siding.

Auto and light-duty truck assembly coating ( 2008) controls are similar to miscellaneous

plastic and metal parts, and in clude electrodeposition co atings, use of reci procators or robot

application devices, hybrid control systems usi ng a concentrator followed by an oxidizer, spray

booth water wash (overspray partic les), dry filters or dry electros tatic precipitator. Alternate

control technologies include condensation, biofiltrati on, and UV oxidation, but these

technologies are not currently being used by the industry. Th e September, 2008 CTG for this

source category recommends no new control measures for auto and light-duty truck

manufacturing facilities, and t hus no additional costs. The wo rk practices recommended were

estimated to result in net cost savings by reduc ing the amount of coatings and cleaning materials

that are used.

Surface coating of miscellaneous metal and plastic parts (2008) recommends product

substitution/reformulation, work practice procedures, and equipment substitution. Product

substitution includes: powder coatings, waterborne coatings , higher solids coatings, and

ultraviolet coatings. Work practice changes include waste reduction, storage of coatings,

thinners, and wastes in closed containers, covers on mixing containers, minimizing spills,

conveying materials in closed cont ainers or pipes. Equipment s ubstitution include s electrostatic

and HVLP spray equipment. Controls include oxidation, adsorption, and absorption. The cost

effectiveness of these controls was es timated to be $1,758/ton of VOC reduction.

2.1.3 EPA NESHAP for Similar Sources

During the 15 years after promulgation of the wood furniture manufacturing MACT

standards, EPA promulgated NESHAP for similar surface coating processes under the

automobile and light-duty truck assembly coa tings, miscellaneous metal and plastic parts

coatings, and wood building products coatings source categories.

All of these standard s identify VOC or VHAP limits fo r surface coating materials and

allow for compliance through one of the following: compliant coatings, an overall emission rate

without add-on controls, or an overall emission ra te with add-on contro ls. All of the source

category standards also require work pract ice activities that reduce emissions.

### These work practice requirements include additional requirements to convey organic

VHAP-containing coating material s in closed containers or through pipes and mixing organic

VHAP-containing coating ma terials only in closed containers. The auto and light truck surface

coating standards include specific emission-redu ction activities for co ating line purging and

flushing, for limiting emissions from spray booth operations, spray booth equipment, and areas

around spray booths (e.g., use of masking materials in spray-booths to faci litate cleaning, using

parts cleaners to clean spra y-booth equipment).

2.2 RACT/BACT/LAER Clearinghouse

Under EPA's New Source Review (NSR) pr ogram, which generally does not address

HAP emissions, a company planning to build a new major source plant or modify an existing

major source plant such that air pollution emi ssions will increase by a significant amount, may

have to obtain an NSR permit. The NSR perm it is a construction permit which requires the

company to minimize air pollution emissions incr eases by changing the process to prevent air

pollution and/or installing air pollution control equipment.

The terms "RACT," "BACT," and "LAER" are acronyms for different program

requirements. RACT, or Reasonably Availabl e Control Technology, is required on sources in

areas that are not meeting nati onal ambient air quality standards (i.e., non-attainment areas).

BACT, or Best Available Control Technology, is required on major new or modified sources in

clean areas (i.e., attainment areas). LAER, or Lowest Achievable Emission Rate, is required on

major new or modified sources in non-attainment areas.

BACT and LAER (and sometimes RACT) ar e determined on a case-by-case basis,

usually by State or local permitting agenci es. EPA established the RACT/BACT/LAER

Clearinghouse, or RBLC, to provide a central data base of ai r pollution technology information

(including past BACT and LAER decisions contained in NSR permits) to promote the sharing of

information among permitting agencies and to ai d in future case-by-case determinations.

However, data in the RBLC are not limited to sources subject to RACT, BACT, and LAER

requirements. Noteworthy prevention and control technology decisions and information may be

included even if they are not related to past RACT, BACT, or LAER decisions. 5



### The RBLC contains over 5,000 air pollution cont rol permit determinations that can help

identify appropriate technologies to mitigate most air pollutant emission streams. It was designed

to help permit applicants and reviewers ma ke pollution prevention and control technology

decisions for stationary air pollution sources, and includes data submitted by several U.S.

territories and all 50 States on over 200 different air pollutant s and 1,000 industrial processes.

5 Technology Transfer Network: Clean Air Technology Center. RACT/BACT/LAER Clearinghouse Basic

Information. Available: http://www.epa.gov/ttn/catc/rblc/htm/welcome_eg.html . Accessed 10/29/07.

### In order to identify the most relevant determinations, the RBLC was searched for

facilities with processes under the RBLC process codes for wood products/furniture surface

coating, and flatwood paneling surface coating. No additional facilities were identified by

related NAICS and SIC codes. We identified ab out 35 facilities with wood surface coating

activities through the RBLC searc h. The search results includ ed the following data fields:

• Facility Name, County, and State

• Pollutant Name

• Process Description

• Control Technology and Emission Limit

• Estimated Percent Efficiency of Control

The search results included the following process descriptions:

• Drying ovens

• Flow coating

• Spray booth

• Spray line

• Roll coating

• Wipe stain

The following processes, practices, and cont rol technologies were found in the RBLC for

the Wood Furniture Manufacturing source category. More detailed results of the search are

presented in Attachment 1.

• Reduced VOC or VHAP in coating formulation;

• UV curable coatings;

• High transfer efficiency sp rayers, high volume low pre ssure (HVLP) application,

rollercoaters;

• Good work practices, proper spraying techniques;

• Regenerative thermal oxidizer (R TO), Catalytic oxidizer; and

• Filters, baghouse.

2.3 Internet Research

An internet search was conducted to determin e if any significant te chnological advances

have been made in controlling emissions from wood furniture manufacturing. Articles, reports

and case studies about pollution prevention and controls were identified from:

• On-line industry journals and trade group web sites;

• EPA’s Environmental Technology Verification (ETV) program;

• State Agency technical assistance and pollution prevention resources; and

• University-based sites for environmen tal studies and clean manufacturing.

Some of the web sites identified in this search are listed in Table 5.

### Table 5. Web Sites

Site Name Site Address

American Home Furnishings

Alliance www.ahfa.us

EPA Environmental Technology

Verification (ETV) http://www.epa.gov/etv/vt-ppc.html

North Carolina Department of

Environment and Natural

Resources’s P2Pays http://wrrc.p2pays.org/industr y/indsectinfo.asp?INDSECT=14

Purdue University’s Clean

Manufacturing Technology

Institute (CMTI) https://engineering.purdue.e du/CMTI/Technology_Transfer/

Woodweb – Woodworking

Industry Information

Knowledge Base http://www.woodweb.com/KnowledgeBase/KBIndex.html

No distinctly different technologies were uncovered th rough this search. Emission

reductions are being achieved th rough reformulation of coatin gs, cleaners, and adhesives;

improvements in spray gun transf er efficiency; training of co ating operators; recycling of

cleaning solvent; and using closed coating dispensing systems. Many of these alternatives

provide financial benefits.

2.4 Correspondence with Industry

Industry trade organizations have been c onsulted throughout the RTR process for Wood

Furniture Manufacturing Operations. These include the American Home Furnishings Alliance

(AHFA), Business and Institutional Furniture Ma nufacturers Association (BIFMA), and Kitchen

Cabinet Manufacturers Associati on (KCMA). The trade group me mbers did not cite any new

developments in practices, processes, or cont rol technologies for the wood furniture industry.ATTACHMENT 1INFORMATION FROM THE RACT/BACT/LAER CLEARINGHOUSE AND CALIFORNIA BACT DATABASEFacilityNameStatePermitdate(RBLC)ProcessNamePollutantControlMethodEmissionLimitenforced?OtherCommentsNorcraftCompanies,LLCVA3/29/2007SprayBoothforCabinetsVOCProperspraytechniquesYesNorcraftCompanies,LLCVA3/29/2007SprayBoothforCabinetsVOCHighsolidscoatingsYesWellbornCabinets,Inc.AL2/13/2007Glazebooth,Tonerbooth,SealerboothVOCLowVOCcoatingYesSIPrequirementArmstrongCabinetProductsPA8/10/2009OverheadLineVOCPaintfilterYesConestogaWoodSpecialtiesPA7/28/2009LaboratorySprayboothVOCLowVOCcoatingYesSacramentoCabinet&MillworkCA2/27/2007WoodFlatStockCoatingVOCLowVOCcoatingYesEmissionsarestrictlyenforcedbyStatepermitYorktowneCabinetryIncPA8/29/2005WoodFinishingVOCGoodworkpracticesYesSIPrequirementCapitalCabinetCorporationNV4/16/2007SurfacecoatingVOCLowVOCcoatingYesSIPrequirementCapitalCabinetCorporationNV4/16/2007SurfacecoatingVOCLowVOCcoatingYesSIPrequirementFacilityNameStatePermitdate(RBLC)ProcessNamePollutantControlMethodEmissionLimitenforced?OtherCommentsCapitalCabinetCorporationNV4/16/2007SurfacecoatingHAPLowVHAPcoatingsYesSIPrequirementSauderWoodworkingCo.OH7/1/2005LaminatorVOCYesSIPrequirement;VOCemissionsfromformaldehyde‐basedresins.Nophotochemicallyreactivematerialwasallowedinthelaminationprocess.MerillatCorporation,Plant14VA3/11/2004WoodFinishingVOCGoodworkpracticesYesMasterbrandCabinets,IncIN5/24/2004SprayBoothforCabinetsHAPControldevice(RTO)NESHAPrequirementMasterbrandCabinets,IncIN5/24/2004SprayBoothforCabinetsVOCControldevice(RTO)YesFeathersCustomWoodProductsCA9/3/2003CoatingoperationVOCLowVOCcoatingYesFeathersCustomWoodProductsCA9/3/2003CoatingoperationVOCHightransferequipmentYesStanleyFurnitureVA10/25/2000SurfacecoatingVOCLimitonVOCthroughputYesMarshFurnitureCompanyNC3/12/2004Surfacecoating;hanginglineVOCVOClimitsforcoatingYesVOClimits(lbVOC/gal,minusH2O&exemptsolvents):transparentstains=7.2;sealers=6.2;topcoats=5.5;basecoats/primers=6.4;enamels=5.6;edgecoats=5.0;fillers=5.0;boothcoater=4.0;boothprep,stripper=6.8.FacilityNameStatePermitdate(RBLC)ProcessNamePollutantControlMethodEmissionLimitenforced?OtherCommentsMarshFurnitureCompanyNC3/12/2004Surfacecoating;flatlineVOCVOClimitsforcoatingYesVOClimits(lbVOC/gal,minusH2O&exemptsolvents):transparentstains=7.2;sealers=6.2;topcoats=5.5;basecoats/primers=6.4;enamels=5.6;edgecoats=5.0;fillers=5.0;boothcoater=4.0;boothprep,stripper=6.8.MasterbrandCabinetsNC3/12/2004TonersprayboothsVOCLowVOCcoatingYesGalloncoatingappliedMasterbrandCabinetsNC3/12/2004StainsprayboothsVOCLowVOCcoatingYesGalloncoatingappliedMasterbrandCabinetsNC3/12/2004Pre‐sealboothsVOCLowVOCcoatingYesGalloncoatingappliedMasterbrandCabinetsNC3/12/2004SealerboothsVOCLowVOCcoatingYesGalloncoatingappliedMasterbrandCabinetsNC3/12/2004TopcoatboothsVOCLowVOCcoatingYesGalloncoatingapplied* Data from RBLC report for NAICS beginning with 337; report downloaded 7/1/10