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 propose d 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

Durha m, NC 27709

3. Attendees

Name Affiliation

Dick Titus Kitchen Cabinet Manufacturers Association

Willard Rober t son Masterbrand Cabinets

John Gahm Kitchen Kompact

Steve Byron Masco Cabinetry

Robin Dunkins EPA

Jim Hirtz EPANicholas Swanson EPA

Tin a 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 place d 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 o f 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 i nternational competition and the econo my (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 t hat some of the calculations from proposal were skewed

1. Cost estimates for changing spray technology were low

2. Cost estimates for coating changes were low3. The acute multiplier does not reflect the current state of the industry (there are no companies and nev er 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. Rober t son describes

conve ntional 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 shu t 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; D ecorá

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 d escribing 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 (A ttachment 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 p resentation

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% d estruction 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 EP A 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 p ounds/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. M entions that all information from each coating is found on certified product data sheets (CPDS)Attachment 1Attachment 2Attachment 3Attachment 4Attachment 5Attachment 6