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 pollutant (HAP) emission sources for the Wood 

Furniture Manufacturing Operations source category. This analysis 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 practices, 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. These technology-based standards are often referred to as maximum 

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

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

(6) REVIEW AND REVISION. – The 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 often than every 8 years. 
1.2 Description of the Source Category and MACT Standard1

 The Wood Furniture Manufacturing Operations MACT source category consists of 

facilities engaged in the manufacture of wood furniture or wood furniture components. The 

industry encompasses the application 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, lockers, and other wood furniture not included in one of the above 

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

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

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

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

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

finishing material is applied, the coated or stained wood substrate typically enters a flashoff area 

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

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

evaporation of the volatile solvents continues. 

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

of adhesives are used in the industry: hot melts (which are not a source of VHAP emissions), 

polyvinyl acetates (PVA), urea-formaldehyde (UF resins), and contact adhesives. Of these 

adhesives, only contact adhesives applied to porous 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-solvency-rated solvents to dissolve resins into 

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

VHAP that evaporate when the solvent is exposed to the air and are 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 specifications 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 emission 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 emissions from finishing, cleaning, gluing, and 

washoff operations are compliant coatings and work practices. Facilities can apply finish coating 

materials that have VHAP content levels (on a coating 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 washoff tanks. Destructive control devices such as 

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

but are not often used in this industry. 

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

750 major source facilities were affected by the rule. Affected facilities are major sources that 

manufacture wood furniture or wood furniture components. 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 NESHAP (40 CFR part 63, subpart QQQQ). 

 The wood furniture NESHAP contains provisions 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 washoff materials at the 

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

63.800(b)(1)-(2)). The amount of finishing materials, adhesives, cleaning solvents, and washoff 

solvents must account for at least 90 percent of annual HAP emissions at the plant site (40 CFR 

63.800(b)(1)). The wood furniture NESHAP contains a similar provision for 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 facilities must keep records 

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

contains a provision excluding a major source facility from other provisions of the NESHAP if 

the facility is primarily engaged 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 furniture 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); 

1.0a 0.8a

(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 

1.0a

1.0a b

1.0a

1.0a

1.0a b

1.0a b

10.0 

1.0a

0.8a b

0.8a

0.8a

0.8a b

0.8a b

10.0

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

(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 

NAd NAd

 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 1.0e 0.2e

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 table 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 formulated using compliant finishing materials, 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 Standardsa (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 work 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 controls 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 equipment 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 alternative that could be broadly applied that 

was not identified and considered during MACT development. 

 Table 3 summarizes the practices, processes, and control technologies considered during 

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

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

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

RACT/BACT/LAER Clearinghouse (section 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 Manufacturing MACT standards were promulgated 

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

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

spray booths. EPA has developed Control Techniques 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-Duty Truck Assembly Coatings (subpart IIII), 

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

(subpart QQQQ). 

2.1.1 California Wood Furniture Manufacturing Regulations 

The Antelope Valley Area Air Quality Management District restricts application 

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

pressure (HVLP) sprayers or other application 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 inside 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 feet 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 control is used which has an effectiveness equal to or 

 greater than the equipment 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 this 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. Control Techniques Guidelines for Miscellaneous Metal and 

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

Triangle Park, NC. EPA-453/R-08-003. September. 
The Bay Area Air Quality Management District 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 Requirements from California Regulation 8-32
2.1.2 EPA CTGs for Subsequent Regulations

Flat wood paneling (wood building products) (2006), controls include low VOC coatings, 

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

Recommended add-on controls include oxidizers and solvent recovery systems that achieve 90 

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

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

wash off solvent accounting system; (3) collecting 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 include electrodeposition coatings, use of reciprocators or robot 

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

booth water wash (overspray particles), dry filters or dry electrostatic precipitator. Alternate 

control technologies include condensation, biofiltration, and UV oxidation, but these 

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

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

manufacturing facilities, and thus no additional costs. The work practices recommended were 

estimated to result in net cost savings by reducing 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 containers or pipes. Equipment substitution includes electrostatic 

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

effectiveness of these controls was estimated 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 coatings, miscellaneous metal and plastic parts 

coatings, and wood building products coatings source categories. 

All of these standards identify VOC or VHAP limits for 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 rate with add-on controls. All of the source 

category standards also require work practice activities that reduce emissions. 
These work practice requirements include additional requirements to convey organic 

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

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

coating standards include specific emission-reduction activities for coating 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 facilitate cleaning, using 

parts cleaners to clean spray-booth equipment). 

 

2.2 RACT/BACT/LAER Clearinghouse

 Under EPA's New Source Review (NSR) program, 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 emissions will increase by a significant amount, may 

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

company to minimize air pollution emissions increases 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 Available Control Technology, is required on sources in 

areas that are not meeting national 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) are determined on a case-by-case basis, 

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

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

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

information among permitting agencies and to aid 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 control permit determinations that can help 

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

to help permit applicants and reviewers make 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 pollutants 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 about 35 facilities with wood surface coating 

activities through the RBLC search. The search results included 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 control 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 sprayers, high volume low pressure (HVLP) application, 

rollercoaters; 

• Good work practices, proper spraying techniques; 

• Regenerative thermal oxidizer (RTO), Catalytic oxidizer; and 

• Filters, baghouse. 

2.3 Internet Research

 An internet search was conducted to determine if any significant technological 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 environmental 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/industry/indsectinfo.asp?INDSECT=14

Purdue University’s Clean 

Manufacturing Technology 

Institute (CMTI) 

https://engineering.purdue.edu/CMTI/Technology_Transfer/ 

Woodweb – Woodworking 

Industry Information 

Knowledge Base 

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

 No distinctly different technologies were uncovered through this search. Emission 

reductions are being achieved through reformulation of coatings, cleaners, and adhesives; 

improvements in spray gun transfer efficiency; training of coating 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 consulted throughout the RTR process for Wood 

Furniture Manufacturing Operations. These include the American Home Furnishings Alliance 

(AHFA), Business and Institutional Furniture Manufacturers Association (BIFMA), and Kitchen 

Cabinet Manufacturers Association (KCMA). The trade group members did not cite any new 

developments in practices, processes, or control technologies for the wood furniture industry. 
ATTACHMENT 1

INFORMATION FROM THE RACT/BACT/LAER CLEARINGHOUSE AND CALIFORNIA BACT DA

Facility Name State

Permit date

(RBLC)

Process

Name Pollutant

Control

Method

Emission

Limit

enforced? Ot

Norcraft Companies,

LLC VA 3/29/2007

SprayBooth for

Cabinets VOC

Proper spray

techniques Yes

Norcraft Companies,

LLC VA 3/29/2007

SprayBooth for

Cabinets VOC

High solids

coatings Yes

Wellborn Cabinets,

Inc. AL 2/13/2007

Glazebooth,Tonerbooth,Sealerbooth VOC

Low VOCcoating Yes SIP require

Armstrong CabinetProducts PA 8/10/2009

OverheadLine VOC Paint filter Yes

Conestoga Wood

Specialties PA 7/28/2009

LaboratorySpraybooth VOC

Low VOCcoating Yes

Sacramento Cabinet &

Millwork CA 2/27/2007

Wood Flat

StockCoating VOC

Low VOCcoating Yes

Emissions aState perm

Yorktowne Cabinetry

Inc PA 8/29/2005

WoodFinishing VOC

Good workpractices Yes SIP require

Capital Cabinet

Corporation NV 4/16/2007

Surfacecoating VOC

Low VOC

coating Yes SIP require

Capital Cabinet

Corporation NV 4/16/2007

Surfacecoating VOC

Low VOC

coating Yes SIP require
Facility Name State

Permit date

(RBLC)

Process

Name Pollutant

Control

Method

Emission

Limit

enforced? Ot

Capital Cabinet

Corporation NV 4/16/2007

Surfacecoating HAP

Low VHAP

coatings Yes SIP require

Sauder Woodworking

Co. OH 7/1/2005 Laminator VOC Yes

SIP requirefrom formaNo photoch

material wa

lamination 

Merillat Corporation,

Plant 14 VA 3/11/2004

WoodFinishing VOC

Good workpractices Yes

MasterbrandCabinets, Inc IN 5/24/2004

SprayBooth for

Cabinets HAP

Control device

(RTO) NESHAP re

MasterbrandCabinets, Inc IN 5/24/2004

SprayBooth for

Cabinets VOC

Control device

(RTO) Yes

Feathers Custom

Wood Products CA 9/3/2003

Coatingoperation VOC

Low VOCcoating Yes

Feathers Custom

Wood Products CA 9/3/2003

Coatingoperation VOC

High transfer

equipment Yes

Stanley Furniture VA 10/25/2000

Surfacecoating VOC

Limit on VOC

throughput Yes

Marsh Furniture

Company NC 3/12/2004

Surfacecoating;

hangingline VOC

VOC limits for

coating Yes

VOC limits 

& exempt s

stains = 7.2topcoats=5basecoats/enamels=5

fillers=5.0; booth prep
Facility Name State

Permit date

(RBLC)

Process

Name Pollutant

Control

Method

Emission

Limit

enforced? Ot

Marsh Furniture

Company NC 3/12/2004

Surfacecoating;

flat line VOC

VOC limits for

coating Yes

VOC limits 

& exempt s

stains = 7.2topcoats=5basecoats/enamels=5fillers=5.0; 

booth prep

Masterbrand Cabinets NC 3/12/2004

Tonerspraybooths VOC

Low VOCcoating Yes Gallon coat

Masterbrand Cabinets NC 3/12/2004

Stain spraybooths VOC

Low VOC

coating Yes Gallon coat

Masterbrand Cabinets NC 3/12/2004

Pre‐seal

booths VOC

Low VOC

coating Yes Gallon coat

Masterbrand Cabinets NC 3/12/2004

Sealerbooths VOC

Low VOCcoating Yes Gallon coat

Masterbrand Cabinets NC 3/12/2004

Topcoatbooths VOC

Low VOCcoating Yes Gallon coat

* Data from RBLC report for NAICS beginning with 337; report downloaded 7/1/10