MEMORANDUM

DATE: August 3, 2011

SUBJECT: Updated Formaldehyde Emissions from Select Wood Furniture

Manufacturers

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

TO: Docket No.: EPA

- HQ

- OAR

- 2010

- 0786

As an outgrowth of the public comment s submitted on th e proposed Wood Furniture Manufacturing RTR (subpart JJ) amendments

, EPA made inquiries to a few facilities to inquire about their current emissions of formaldehyde associated with wood furniture manufacturing operations . This action was taken to get bett er insight o n how emissions data for some of the highest formaldehyde emitting facilities has changed since 2005. If there had been a change , a further discussion ensued about the cause. The facilities contacted and their corresponding 2010 formaldehyde (H CHO) emissions are listed below in Table 1. The data obtained in Table 1 was supplied via telephone conversations with the facility or the facility’s environmental contractor. Because this data is unverified

, it is treated as general and useful information , but corresponding values for facilities have not been updated in databases. There are two facilities for which updated emissions information was not provided : 1) Ellinger’s Agitized was deemed to not be a wood furniture facility and is not in this source category ; t hey produce wooden bowls and other kitchen supplies and thus, updated emissions data is not relevant to this rule making ; and 2) Plywood Cabinet Plant is actually a part of the Republic Industries Inc. facility and any emissions are considered to be for Republic Industries. This still show s the trend that facilities have drastically reduced emissions of formaldehyde from 2005 to 2010. From the data provided by these facilities, it shows that most have reduced emissions to less than 400 pounds o f formaldehyde/year. There are a few contributing factors to this reductions in emissions. First, many wood furniture manufacturers have reduced the concentration of formaldehyde in their coatings, effectively reducing formaldehyde emissions. Second, the e conomic climate has affected many of the facilities ’ production levels

. With a decrease in production, there will be less coating used and then less emitted

. Specific responses are included in Attachment 1.Table 1

Facility Name 2005 NEI HCHO Emission s (tpy) 2010

HCHO Emissions (tpy) * Type of Wood

Furniture Manufacturer

Alabama Inter

- Forest Corporation 1.35 0.1 C abinetry Bertch Cabinet Manufacturing Inc. Legacy Div 0.75 0.037 C abinetry Ellinger ’s Agitized Wood Products 0.414 n/a Kitchen Supplies Kitchen Kompact 1.008 0.8285 C abinetry Legacy Cabinets 1.1 0.0009 C abinetry Plywood Cabinet Plant 1.377 n/a C abinetry Republic Industries Inc 0.677 0.111 C abinetry Stanley Furniture Company 0.633 0.070395 H ome furnishings
Thomasville Furniture

- Lenoi r Plant 0.48 0.023 H ome furnishings
Tru

- Wood Cabinets Inc 0.14 0.06 C abinetry *All updated emissions data is self reported through conversations via telephoneAttachment 1

Alabama Inter

- Forest Corporation

According to our data from the National Emissio n Inventory (NEI) in 2005

, your emissions based on your coatings was 1.35 tpy.

What is your actual amount of emissions of formaldehyde from the past year?

Facility representative did not have information in front of him, but said that it was just about 0. 1 tons.

Bertch Cabinet Manufacturing

According to our data from the National Emission Inventory (NEI) in 2005

, your emissions based on your coatings was 0.75 tpy.

What is your actual amount of emissions of formaldehyde from the past year?

72 lb per year

Do you use low

- (<1%) or no

- formaldehyde coatings?

Yes

How much coating (volume) is used in a year?

21.3 tons & 15.7 tons & 10.3 tons = 47.3 tons = 94

, 600 pounds ~ 12

, 613 gallons

Legacy Cabinets

According to our data from the National Emission Inventory (NEI) in 2005

, your emissions based on your coatings was 1.1 tpy.

What is your actual amount of emissions of formaldehyde from the past year?

ADEM reporting for last year

– 0.0009 TPY

Do you use low

- (<1%) or no

- formaldehyde coatings?

Most coatings don’t have HCHO but was not given a number

How much coating (volume) is used in a year?

In December:

8

, 799 gallons coatings 89 gallons of adhesive 550 gallons cleaning solvent

Approx in a year:105

, 600 gal coating 1

, 068 gal adhesive 6
, 600 gal of cleaning so lvent

Total: 113268 gallons of applicable coatings

Republic Industries Inc. (includes Plywood Cabinet Plant)

According to our data from the National Emission Inventory (NEI) in 2005

, your emissions based on your coatings was 0.677 tpy.

What is your actual amount of emissions of formaldehyde from the past year?

222 lbs/year at 40% of capacity

Stanley Furniture Company

According to our data from the National Emission Inventory (NEI) in 2005

, your emissions based on your coatings was 0.633 tpy.

What is your actual amount of emissions of formaldehyde from the past year?

140.79 pounds of HCHO last year

Do you use low

- (<1%) or no

- formaldehyde coatings?

No formaldehyde in finish coating; 0.1% & 0.5% in contact adhesives

Thomasville Furniture

– Lenoir facility

What is your actual amount of emissions of formaldehyde from the past year?

331 pounds (46 lbs from gluing and rest from combustion sources)

Which coatings used contain formaldehyde? Only contact adhesives amounting to 46 pounds last year

Tru

- wood cabinet s
What is your actual amount of emissions of formaldehyde from the past year?

120 pounds HCHO from 2010

Do you use low

- (<1%) or no

- formaldehyde coatings?

0.018 lb/gal HCHO max content in coating (assume a density of ~8lbs/gal for the coating  0.018lb HC HO/gal coating = 0.225% HCHO in coating

What types of coatings contain formaldehyde?

Found mostly in Topcoats and sealers