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November 23, 2010 

MEMORANDUM

TO: Dave Guinnup, Leader 

 Sector Based Assessment Group 

FROM: Kaye Whitfield, Project Lead 

Risk and Technology Review - National Emission Standards for Hazardous Air 

Pollutants (NESHAP) for Wood Furniture Manufacturing Operations 

SUBJECT: Acute Effects Factor for Wood Furniture Manufacturing Operations 

Section 112(f)(2) of the Clean Air Act (CAA) directs EPA to assess the risk remaining 

(residual risk) after the application of maximum achievable control technology (MACT) 

standards under section 112(d). EPA is to promulgate more stringent standards for a category or 

subcategory of sources subject to MACT standards under section 112(d) if promulgation of such 

standards is necessary to protect public health with an ample margin of safety or to prevent 

(taking into consideration various factors) adverse environmental effects. 

In an effort to streamline the process of making residual risk decisions, EPA plans to 

address residual risk and perform a technology review simultaneously for multiple source 

categories. The first part of this approach is to compile and review (and update with facilityspecific data collected by EPA in some cases) readily available source category emissions data 

from the 2002 National Emissions Inventory, and to conduct preliminary risk assessments. 

The risk assessment will include both chronic and acute inhalation risks. The acute 

assessment accounts for the maximum potential short term emission rates for the industry. This 

is done by comparing the average annual hourly emissions (total annual reported emissions 

divided by the total number of hours that surface coating operations are conducted) in an 

operating year with the maximum hourly emissions for surface coating operations at a given 

facility based on the highest allowable (e.g., operating permit limit) or achievable (e.g., 

equipment or other limitation) production capacity. 

Based on the information we had readily available, we calculated the acute factor for 

formaldehyde and for total HAP. For formaldehyde, the maximum (hourly) acute factor 
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calculation was based on the facility with the highest reported formaldehyde emissions and the 

highest risk (HQ > 1), Kitchen Kompact, Jeffersonville, IN. The facility provided MSDS, 2009 

usage data for their coatings, and maximum production capacity. This information is 

summarized in Table 1. This facility is representative of the cabinet manufacturing industry 

sector; but, it may not be representative of the remaining sectors in this source category. 

Table 1. 2009 Coating Data from Kitchen Kompact a, b, c 

Annual 

Usage 

(gal) 

Maximum Annual 

Production Coating 

Usage (gal)1

Coating 

Density 

(lb/gal) 

Formaldehyde 

Content 

(%) 

Total HAP 

Content (%) 

Sealer 56,595 256,000 7.5 0.3 7 

Topcoat 73,686 332,000 7.6 0.4 21 

Total 130,281 588,000 ---- --- --- 1

 Maximum production rate = 2,000 units per hour. 

Per the owner of the company a, the maximum hourly production throughput for the 

facility is 2,000 units per hour. Typical operating hours are 2,000 hours per year (10 hours per 

day, 4 days per week, and 50 weeks per year). Based on information provided by the owner, the 

volume of coating necessary to produce 2,000 units per hour is 332,000 gallons of topcoats and 

256,000 gallons of sealers. The maximum hourly coating usage is calculated, as follows: 

Max Hourly Topcoat Usage = 332,000 gal / 2,000 hours = 166 gal/hour 

Max Hourly Sealer Usage = 256,000 gal / 2,000 hours = 128 gal/hour 

Formaldehyde Maximum Hourly Acute Factor Calculationd

 

Max Hourly Formaldehyde Emission Rate: 

To calculate the maximum hourly formaldehyde emission rate, we used formaldehyde 

contents of 0.4% (by weight) for topcoats and 0.3% (by weight) for sealers, based on the 

facility’s Part 70 operating permitc

, multiplied by the maximum production capacity and density: 

Topcoat Æ (166 gal/hr) x (7.6 lb/gal) x (0.4%) = 5 lb formaldehyde/hr 

Sealer Æ (128 gal/hr) x (7.5 lb/gal) x (0.3%) = 3 lb formaldehyde/hr 

All Coatings (combined) Æ (5 lb/hr) + (3 lb/hr) = 8 lb formaldehyde/hr

Average Hourly Formaldehyde Emission Rate: 

The average hourly emission rate was determined by using 2009 coating data supplied by 

the facility. While typical operating hours are 2,000 hours (10 hours per day, 4 days per week, 

and 50 weeks per year), the facility owner indicated that 2009 was not typical in that production 

levels and associated coating operations (hours) were down ~20% (e.g., 80% of typical 

production levels).b

 To calculate the typical or average hourly emission rate of formaldehyde 
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emitted by the facility during 2009 coating operations, we calculated the total amount of annual 

formaldehyde emissions, and then divided by 1,600 hours (or 80% of 2,000 hours): 

Topcoat Æ (73,686 gal) x (7.6 lb/gal) x (0.4%) = 2,240 lb formaldehyde 

Sealer Æ (56,595 gal) x (7.5 lb/gal) x (0.3%) = 1,273 lb formaldehyde 

All Coatings (combined) Æ (2,240 lb) + (1,273 lb) = 3,513 lb formaldehyde 

 (3,513 lbs formaldehyde) / (1,600 hrs/yr) = 2 lb formaldehyde/hr 

Formaldehyde Max Hourly Acute Factor: 

We then calculated the maximum hourly acute factor based on the maximum and average 

hourly emission rates of formaldehyde, using the above information: 

Max Acute Factor = (8 lb formaldehyde/hr) / (2 lb formaldehyde/hr) = 4 

Total HAP Maximum Hourly Acute Factor Calculationd

Max Hourly Total HAP Emission Rate: 

We then calculated the maximum hourly emission rate of total HAP, using the individual 

coating densities, along with the total HAP content by weight. 

Topcoat Æ (166 gal/hr) x (7.6 lb/gal) x (21.0%) = 265 lb HAP/hr 

Sealer Æ (128 gal/hr) x (7.5 lb/gal) x (7.0%) = 67 lb HAP/hr 

All Coatings (combined) Æ (265 lb/hr) + (67 lb/hr) = 332 lb total HAP/hr 

Average Hourly Total HAP Emission Rate: 

To calculate the typical or average hourly emission rate of total HAP emitted by the 

facility during 2009 coating operations, we calculated the total amount of annual total HAP 

emissions, and then divided by 1,600 hours (or 80% of 2,000 hours): 

Topcoat Æ (73,686 gal) x (7.6 lb/gal) x (21%) = 117,600 lb HAP 

Sealer Æ (56,595 gal) x (7.5 lb/gal) x (7%) = 29,600 lb HAP 

All Coatings (combined) Æ (117,600 lb HAP) + (29,600 lb HAP) = 147,200 lb HAP

(147,200 lbs total HAP) / (1,600 hrs/yr) = 92 lb total HAP/hr 

 
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Maximum Hourly Acute Factor for Total HAP: 

We then calculated the maximum hourly acute factor based on the maximum and average 

hourly emission rates of total HAP, using the above information: 

Max Acute Factor Total HAP = (332 lb HAP/hr) / (92 lb HAP/hr) = 4 

a

 Contact Report for Kitchen Kompact in Jeffersonville, Indiana. October 5, 2010. 

b

 Contact Report for Kitchen Kompact in Jeffersonville, Indiana. October 12, 2010. 

c

 Part 70 Operating permit renewal issued July 20, 2006 for Kitchen Kompact in Jeffersonville, 

Indiana from Indiana Department of Environmental Management. 

d All calculated values rounded to nearest whole number.