1 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 Furnitu re Manufacturing Operations

SUBJECT: Acute Effects Factor for W ood Furniture Manufacturing Operations Section 112(f)(2) of the Clean Air Act (CAA) directs EPA to assess the risk remaining (residual risk) after the applic ation 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 protec t public health with an ample margin of safety or to prevent (taking into consideratio n various factors) advers e environmental effects.

In an effort to streamline the process of making residual risk decisions, EPA plans to address residual risk and perform a technol ogy review simultaneously for multiple source categories. The first part of this approach is to compile and review (a nd 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 chr onic 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 opera tions are conducted) in an operating year with the maximum hourly emissi ons 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 ava ilable, we calculated the acute factor for formaldehyde and for total HAP. For formal dehyde, the maximum (hourly) acute factor2 calculation was based on the faci lity with the highest reported formaldehyde emissions and the highest risk (HQ > 1), Kitche n 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 repr esentative of the cabinet manufacturing industry sector; but, it may not be repres entative of the remaining sect ors 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 produ ction throughput for the facility is 2,000 units per hour. Typical ope rating 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 un its per hour is 332,000 gall ons of topcoats and 256,000 gallons of sealers. The maximum hourly coating usage is calculated, as follows: Max Hourly Topcoat Usage = 332,0 00 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 Calculation d Max Hourly Formaldehyde Emission Rate: To calculate the maximum hourly formaldehyde emission rate, we used formaldehyde contents of 0.4% (by weight) for topcoats a nd 0.3% (by weight) for sealers, based on the facility’s Part 70 operating permit c , multiplied by the maximum producti on 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 determ ined by using 2009 coating data supplied by the facility. While typical operating hours are 2,000 hours (10 hour s per day, 4 days per week, and 50 weeks per year), the facility owner indica ted that 2009 was not ty pical 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 averag e hourly emission rate of formaldehyde3 emitted by the facility during 2009 coating operations , we calculated the total amount of annual formaldehyde emissions, and then divi ded 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 Calculation d Max Hourly Total HAP Emission Rate: We then calculated the maximum hourly emi ssion rate of total HAP, using the individual coating densities, along with th e 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 cal culated 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/hr4 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 Komp act 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.