MEMORANDUM

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

FROM: Nicholas Swanson, EPA/OAR/OAQPS/NRG

DATE: August 17, 2011

SUBJECT: EPA Meeting with Kitchen Cabinet Manufacturers Association (KCMA) 

and Select Representatives

1. Introduction

On August 17, 2011, at the request of the Kitchen Cabinet Manufacturers 

Association (KCMA), EPA hosted a meeting at the EPA offices of RTP, NC. The purpose 

of the meetings was to allow KCMA to ask clarification questions about potential issues 

regarding the December 21, 2010 proposed Risk and Technology Review (RTR) of the 

National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Wood 

Furniture Manufacturing Operations. 

2. Date and Location

August 17, 2011

U.S. Environmental Protection Agency

109 TW Alexander Drive

Durham, NC 27709

3. Attendees

Name Affiliation

Dick Titus Kitchen Cabinet Manufacturers Association

Willard Robertson Masterbrand Cabinets

John Gahm Kitchen Kompact

Steve Byron Masco Cabinetry

Robin Dunkins EPA

Jim Hirtz EPA
Nicholas Swanson EPA

Tina Ndoh EPA

Kaye Whitfield EPA

4. Summary of Meeting

The meeting began at approximately 11:00 AM with introductions. The EPA thanked 

everyone for attending and reiterated that copies of the meeting agenda, presentations, 

and a meeting summary would be placed in the docket for transparency purposes. Any 

comments and suggestions that stakeholder made were based as informative, and 

because this meeting is outside of the public comment period EPA is under no 

obligation to adhere and acknowledge any suggestions. 

a. Mr. Titus Gives Background and Current State of Technology (agenda 

seen as Attachment 1)

i. Indicates that KCMA desires to use NAS risk assessment on 

formaldehyde

ii. States conventional spray ban is unwarranted

iii. Asserts that 400 pound/year formaldehyde limit is arbitrary

1. Mr. Roberson and Mr. Titus participated in the Reg Neg 

process to establish this number in the 1995 Wood Furniture 

NESHAP and stated that this number was not implemented 

for a concrete baseline.

iv. States that there have been 56 consecutive months of negative 

growth

1. No prospects of changing

2. Previous to the 56 months, the industry saw 127 months of 

positive growth

v. Asserts that 389 facilities have closed in the 56 months with more 

expected to shut down

vi. Explains international competition and the economy (specifically 

the housing market recession) are hurting the industry

vii. Indicates that a majority of companies of are not using conventional 

spray guns, but banning them prohibits a level of flexibility (see 

Attachment 2 for email showing numbers)

viii. Thinks that some of the calculations from proposal were skewed

1. Cost estimates for changing spray technology were low

2. Cost estimates for coating changes were low
3. The acute multiplier does not reflect the current state of the 

industry (there are no companies and never have been that 

have run 24 hours/day, seven days a week).

ix. Describes that the amount of formaldehyde in coatings is 

dependent on the facility’s operations. All use compliant coatings.

b. Would not meet MACT; under 1% typical.Mr. Robertson describes 

conventional spray and how it effects his company

i. Reiterates that he was part of the Reg Neg for the 1995 NESHAP for 

Wood Furniture Manufacturing Operations

1. He was very satisfied with the outcome and compromise of 

the 1995 NESHAP

ii. States that his company has shut down 7 facilities in the past 3.5 

years

iii. Many of his facilities use HVLP and air assisted airless spray guns

iv. He uses 4 different high solid content coatings

1. HVLP do not work well with high solid content coatings

v. Indicates that HVLP and air-assisted don’t give the flexibility for 

special coatings that conventional spray does

1. His company represents three high-end manufacturers: 

Omega; Dynasty; Decorá

2. Spray quality and finish make a big difference, especially 

with high-end products

3. Conventional spray tends to have the nicest finish

vi. States that where applicable his company uses HVLP guns

1. Makes good business sense to preserve exemptions

c. Mr. Titus further discussed the effects of conventional spray on the 

industry

i. He provides a letter from David D. Rothermel describing the use of 

StyleCraft’s use of conventional spray and the necessity of it. (See 

Attachment 3)

1. Ms. Whitifield inquires about the size of style craft 

2. Mr. Titus states that there are probably 20-25 employees

3. Mr. Swanson asks if they are a major or area source and 

reiterates that this Risk and Technology Review is only for 

major sources and that this conversation should only include 

discussion of major sources.
ii. Thinks that U.S. will lose the high-end market to other countries if 

they are not allowed to use conventional spray

iii. States that using conventional spray allows for use of high solids

coatings. 

d. Mr. Robertson continued to describe the state of the industry in his 

opinion

i. (move to Titus presentation) States that 200 days/year at 8 

hours/day is a much better estimate of working hours than 

running facilities 24 hours/day, 7 days/week

ii. (move to Byron presentation) Says that polyurethane coatings are 

twice as expensive as standard conversion varnishes

iii. Provides a presentation on formaldehyde limits (Attachment 4)

1. Gives general overview of 1995 NESHAP and RTR proposal 

for Wood Furniture Manufacturing and Operations

2. Mr. Titus provides a data sheet on formaldehyde 

(Attachment 5)

iv. Describes conventional spray

1. He describes spray technologies as seen in the presentation

2. States that for air-assisted spray, a fluid pump is necessary 

that adds an additional $2000 for switching from 

conventional to air-assisted spray

3. Air-assisted spray does not have the same quality as 

conventional spray in some instances

4. (move to Byron presentation) Low volume, low pressure 

guns often do not spray fast enough (enough volume at rate 

for spray lines)

e. Mr. Byron described the current state of the industry with add-on control 

devices (see presentation in Attachment 6)

i. Shows a video of how KraftMaid Cabinetry functions. This facility 

is part of the MASCO Cabinetry name.

1. This facility has fast line speeds using conventional spray 

guns. All overspray is routed to an RTO. 

2. Without the use of conventional spray guns, this facility 

would not be able to function because of the speed and 

volume of spray.

3. RTOs have 98-99% destruction efficiency 

a. The state they are located in requires 95%
4. Half the heat generated in the RTO is from natural gas with 

the other half from overspray

f. Mr. Hirtz of the EPA explains the process of how risk is calculated and 

examined.

g. Mr. Gahm explains why the 400 pound limit for formaldehyde is 

unwarranted and how it effects his facility

i. Explains that to lower formaldehyde concentration to a level that 

would be below 400 pounds/year would incur significant costs

1. Costs of new coatings

2. New coatings will bring different line configurations

3. Costs for addition of ovens

ii. Mr. Gahm’s facility is unique in the size, speed and contains all 

facets of operation under one facility roof

iii. Mentions that all information from each coating is found on 

certified product data sheets (CPDS)
Attachment 1

Attachment 2
Attachment 3
Attachment 4

Attachment 5
Attachment 6