September 27, 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 Operations 

SUBJECT: Cost Analyses for Control Options 

The purpose of this memorandum is to present estimated emissions reductions, costs, and cost 

effectiveness of control options for surface coating operations at wood furniture facilities subject 

to MACT subpart JJ. Costs were estimated for the use of a regenerative thermal oxidizer (RTO) 

system installed on a wood furniture coating booth, and for the use of lower VOC coatings. 

The costs in this memo are based on two cost analysis reports. In 2003, the Indiana Department 

of Environmental Management (IDEM) conducted a Best Available Control Technology 

(BACT) analysis on the MasterBrand Cabinets, Inc. facility in Ferdinand, Indiana.1 In 2009, the 

Bay Area Air Quality Management District (BAAQMD) of California analyzed compliance 

costs of Regulation 8-32, which mandated lower coating limits for wood furniture coatings.2

 

 

1

 Indiana Department of Environmental Management. Title V Significant Source Modification (Major PSD/EO). 

MasterBrand Cabinets, Inc. 2003. http://permits.air.idem.in.gov/13893f.pdf. Accessed August 2, 2010. Pages 52-

62. 

2

 Bay Area Air Quality Management District. Regulation 8, Rule 32; Wood Products Coatings Staff Report. 2009. 

http://www.baaqmd.gov/~/media/Files/Board%20of%20Directors/2009/Board%20of%20Directors%20080509%20

Agenda%20Pkt.ashx. Accessed August 11, 2010. Pages 137-166. 

1 
I. MASTERBRAND CABINETS, INC. 

The facility is located in Ferdinand, Indiana, and manufactures kitchen cabinets. The 

volatile organic compound (VOC) BACT analysis evaluated 4 types of add-on control 

technologies: thermal oxidation, catalytic incineration, flare, and carbon adsorption. 

Only thermal oxidation was found to be technologically feasible for wood cabinet 

operations and was used in the cost analysis. Catalytic incineration was not considered 

feasible due to the fact that the catalyst is often not compatible with the coatings used by 

wood furniture finishing operations. Flares were not considered to be feasible due to the 

fact that they work best with >13,000 ppm, which is higher than typical wood furniture 

surface coating operations. Carbon adsorption was not considered feasible because it 

does not work as effectively when more than one VOC is in the airstream. Wood 

furniture coatings rarely contain a single VOC and wood furniture coating operations use 

more than one coating type and all the coatings are not likely to have the same single 

VOC component. 

The cost analysis included the use of a regenerative thermal oxidizer (RTO), and a partial 

enclosure constructed on the spray booths. The facility currently has three types of 

finishing lines: stain, sealer, and topcoat booths; toner booths; and touch-up booths. All 

cabinets are coated with stain, sealer, and topcoats, leading to a high volume emission 

stream with consistent concentrations and air flow. The other two types of booths were 

evaluated separately because they are only used intermittently. The results of the cost 

evaluations are shown in Table 1. 

Table 1. Cost Analysis for MasterBrand Cabinets in Ferdinand, Indiana 

2 
II. BAY AREA AIR QUALITY MANAGEMENT DISTRICT (BAAQMD) 

On July 29, 2010, the BAAQMD met to review Regulation 8, Rule 32: Wood Products 

Coatings, which regulates VOC emissions from the wood products manufacturing 

industry by setting standards for application techniques and the amount of VOC in 

coatings that can be used in surface preparation, coatings application, and cleanup for the 

manufacture of wood products, including furniture, bathroom vanities, kitchen cabinets, 

picture frames, outdoor speakers, architectural millwork, and other wood products. 

The proposed amendments to Rule 8-32 reduce VOC limits for some types of coatings 

used on the three types of wood products subject to VOC limitations in the rule: general 

wood products; wood furniture, custom cabinetry and custom architectural millwork; and 

custom furniture. The lower VOC limits became effective July 1, 2010, and provided for 

alternative standards for each type of high-solids coating based on grams VOC per gram 

of coating solid. 

The proposed BAAQMD amendments reduce VOC emissions by at least 0.45 tons per 

day, representing a 30 percent reduction in current emissions. The most significant costs 

of implementation are higher coating costs. A few manufacturers would need to add 

additional drying trays or ventilation during damp and cool winter months. Cost 

effectiveness of the proposed amendments is estimated to range in costs from $7,000 to 

$26,000 per ton of VOC reduced; $7,000 to $22,000 per ton depending on the costs of 

new coatings only, and up to $26,000 if additional drying facilities are required. 

The Board determined that a VOC cost effectiveness of $15,000 per ton was within a 

reasonable range to be acceptable.

3 
III. WOOD FURNITURE RISK ASSESSMENT COST ANALYSES 

Multiple control cost options were evaluated for wood furniture operations. The options 

include the use of add-on control equipment and the use of lower VHAP coatings. All of 

the costs were based on the two cost analyses in Parts I and II of this memo. This section 

explains how the analyses were adapted for the two different kinds of control. 

A. Regenerative thermal oxidizer 

Based on the cost analysis for MasterBrand Cabinets in Ferdinand, Indiana, the only addon control that was considered potentially applicable for wood furniture operations was 

the regenerative thermal oxidizer. All other add-on control options are not compatible 

with wood furniture coatings or emission characteristics. 

There are two type of coating operations that were evaluated for add-on control 

equipment. The first type of operation is more automated with steady coating rates. This 

type of operation is less common in wood furniture manufacturing. At this time, only 

three wood furniture manufacturing facilities are controlled by RTO. For our cost 

analysis, we assumed the operations include all three spray booth options in Table 1, 

using a weighted average based on the amount of VOC removed. 

The second type of operations is less automated and more intermittent. This type of 

operation is more common in wood furniture manufacturing. For that analysis, we 

assumed the operations would most closely resemble the intermittent operations from the 

touch-up booths. 

The cost analyses needed a few changes to work for the risk analysis. First, the 

MasterBrand Cabinets analysis was based on VOC. Second, the costs are based on 2003 

dollars. 

The amount of VHAP was estimated based on EPA’s Toxics Release Inventory.3

 In 

2003, 54% of the MasterBrand Cabinets VOC emissions were classified as VHAP. The 

Marshall and Swift Index was used to convert the costs in 2003 to a 2010 basis.4

 In 

2003, the Index was 1,123.6, and 1,515.1 in the first quarter of 2010. Table 2 show

emissions and costs expected for both options. 

s the 

 

3

Toxics Release Inventory. http://www.epa.gov/enviro/html/tris/index.html. 

4

 Marshall and Swift Index. Chemical Engineering. April 2010. 

4 
5 

 

B. Compliant Coatings 

Based on the cost analysis by the Bay Area Air Quality Management District, this 

analysis is for the cost of lower VOC coatings, assuming that the NESHAP was revised 

to match the requirements of Regulation 8-32. These lower VOC limits for wood 

furniture are shown as Table 3. 

The only update that was required for the analysis was to convert the VOC to VHAP. In 

terms of VOC, the cost effectiveness was determined to be about $20,000/ton VOC. 

Based on EPA case studies, VOC content of wood furniture coatings are typically 50% 

HAP5

, so $10,000/ton VOC converts to approximately $20,000/ton VHAP. 

Additional work practice standards were also evaluated. Work practice standards include 

cleaning up spills as soon as possible and keeping containers of volatile materials closed 

when not being used. The reduction in emissions is low and costs are difficult to 

estimate. The complete control cost analysis for wood furniture operations is shown in 

Table 5. 

C. Conclusions 

Overall, the annual costs for wood furniture control options range from $589,000 to $1.7 

million and VHAP reductions range from 9 to 128 tons per year of VHAP. These 

estimates lead to cost effectiveness ranging from $20,000 per ton of VHAP to $65,000 

per ton of VHAP.

5

 Wood Coating Case Studies by Company. http://www.epa.gov/ttn/atw/wood/low/casebyco.html. Accessed 

August 2010. 
Table 2. Control Options using RTO as an add-on control 

Control Option VOC 

Removed 

(tpy) 

Total Annual Cost 

($) 

2003 basis 

Cost 

Effectiveness 

($/ton VOC) 

HAP 

Removed 

(tpy) 

Total Annual C

($) 

2010 basis 

Finishing operations on automated, higher speed coating lines 237 $1,904,148 $8,034 128 $2,566,790 Finishing operations on automated, higher speed coating lines 

16 $436,614 $26,554 9 $588,745 
Table 3. Regulation 8-32-303 
Table 4. Control Option using Lower VOC coatings 

Control Option VOC Removed (tpy) Total Annual Cost 

($) 

Cost Effectiveness 

($/ton VOC) 

HAP 

Removed 

(tpy) 

Lower VOC Coatings 112 $1,687,500 $15,000 56 

Table 5. Costs of Control Options for Wood Furniture Coating Operations (per facility basis) 

Type of facility Control Option Number of Affected Facilities Emission reduction (TPY VHAP)a Capital costs ($million)a Annu

co

($milli

Finishing operations on automated, higher speed coating lines 

RTO <10 128b $10.3c $2.

Finishing operations on lower speed or intermittent lines RTO 375 9d $3.0c $0.5All finishing operations 

Lower coating limits 

(California Rule 8-32) 385 0.22e $0.03c $0.0

Revise and/or add work 

practices 385 <5% (est) No data No 

Flare Unlikely to be used 

High inlet concentration requirement (>13,000 p

Catalytic Incineration Unlikely to be used. 

Furniture coatings are often incompatible with the c

Carbon Adsorption Unlikely to be used Not effective on streams with multiple VOC 

a These estimates are on a per-facility basis. b Cost Evaluation of MBCI in Ferdinand, Indiana. Control Scenario: using all 3 types of booths . c Assumed that capital costs are 4 times annual operating costs. Estimated from reference e. d Cost Evaluation of MBCI in Ferdinand, Indiana. Control Scenario: Touch-Up Booths. e Bay Area Air Quality Management District. Regulation 8, Rule 32; Wood Products Coatings Staff Report. July 23, 2009.