Appendix 1 

Emissions Inventory Support Memorandum 
Wood Furniture Manufacturing 
1

MEMORANDUM 

TO: Anne Pope, EPA 

FROM: Darcy Wilson, ERG 

DATE: August 25, 2010 

SUBJECT: Emissions Data Used in Residual Risk Modeling for Wood Furniture 

(Surface Coating) 

The purpose of this memorandum is to provide information on the RTR database used in 

estimating residual risk for the Wood Furniture (Surface Coating) Maximum Achievable 

Control Technology (MACT) source category. 

BACKGROUND 

Section 112 of the Clean Air Act (CAA) establishes a two-stage regulatory process to 

address emissions of hazardous air pollutants (HAPs) from stationary sources. In the first 

stage, section 112(d) requires the Environmental Protection Agency (EPA) to develop 

technology-based standards for categories of industrial sources. In the second stage, 

known as the residual risk stage, section 112(f)(2) requires EPA to assess the health and 

environmental risks that remain after sources come into compliance with MACT. If 

additional risk reductions are necessary to protect public health with an ample margin of 

safety or to prevent adverse environmental effects, EPA must develop standards to 

address these remaining risks. As part of this second stage, data were gathered to assess 

the residual risks from the Wood Furniture MACT source category. 

EMISSIONS DATA USED IN RESIDUAL RISK MODELING 

The 2005 National Emissions Inventory (NEI) data served as the starting point for this 

assessment. Using the process MACT code,1 a subset of the NEI was developed that 

contained facility, process, and emissions data for each facility in the Wood Furniture 

(MACT code 0716) source category. The risks associated with wood furniture facilities 

were modeled, and EPA performed an in-depth review of the risk results and the modeled 

NEI dataset. EPA made revisions to the assigned MACT codes for Source Classification 

Codes (SCCs) not subject to the NESHAP and identified closed facilities, and re-modeled 

the data set. 

 

Risks associated with facilities covered by the Wood Furniture (Surface Coating) MACT 

standard were released in the initial 2005 NATA risk assessment in June of 2009, and 

EPA evaluated the facility-wide risks for Wood Furniture facilities using the 2005 NEI 

data and risk assessment results that were released in the 2005 NATA Risk Preview with 

 

1

 Assigning data with MACT codes allows EPA to determine reductions attributable to the MACT 

program. The NEI associates MACT codes corresponding to MACT source categories with stationary 

major and area source data. 
2

State and local agencies in June of 2010. A local agency identified one closed facility 

which was removed from the NEI. EPA performed an in-depth review of the emissions 

data for high-risk facilities identified in the NATA modeling. Each of the high-risk 

facilities was contacted, and subsequently four facilities were removed from the dataset 

because they had closed or no longer manufactured wood furniture. Updated emission 

estimates were provided for the remaining facilities. Additional revisions were made to 

the NEI for wood furniture manufacturers based on trade association contacts (e.g., 

identification of closed facilities, facility address corrections). EPA also corrected 

additional locational coordinates, confirmed that synthetic minor sources were included 

as subject to the NESHAP. The updated NEI with these revisions was then re-modeled, 

and these revisions were included in the risk analyses. EPA then identified two additional 

facilities that had closed (NEIMS1713 and NEICAT$12782); these were included in the 

risk analyses, but will be removed from the dataset before promulgation.