Appendix 1 Emissions Inventory Support MemorandumWood Furniture Manufacturing1 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 Furnitu re (Surface Coating) Maximum Achievable Control Technology (MACT) source category.

BACKGROUND

Section 112 of the Clean Air Act (CAA) establ ishes a two-stage regu latory process to address emissions of hazardous air pollutants ( HAPs) from stationary sources. In the first stage, section 112(d) requires the Environmental Protecti on Agency (EPA) to develop technology-based standards for categories of industrial sour ces. In the second stage, known as the residual risk stage, section 112( f)(2) requires EPA to a ssess the health and

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

additional risk reductions are ne cessary to protect public health with an ample margin of safety or to prevent adverse environmenta l 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 star ting point for this assessment. Using the process MACT code, 1 a subset of the NEI was developed that contained facility, process, and emissions da ta 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 re sults and the modeled

NEI dataset. EPA made revisi ons to the assigned MACT code s 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 assess ment in June of 2009, and EPA evaluated the facility-wide risks for Wood Furniture facilit ies 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 corresp onding to MACT source categories with stationary major and area source data.2 State and local agencies in June of 2010. A local agency id entified one closed facility which was removed from the NEI. EPA perfor med 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 subs equently four facilities we re removed from the dataset because they had closed or no longer manu factured wood furniture. Updated emission estimates were provided for the remaining faci lities. Additional revi sions 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.