Visit the following web page for updated information on this rule: EPA Air Toxics Website: Rule and Implementation Information for Wood Furniture Manufacturing Operations.

Background

The Clean Air Act as amended in 1990 established the basis for the Environmental Protection Agency (EPA) to set new requirements for hazardous air pollutants (HAPs). The EPA has promulgated a Maximum Available Control Technology (MACT) standard for the wood furniture manufacturing industry. The MACT, a nationwide standard, applies to 188 toxic chemicals listed in the Clean Air Act as HAPs.

Affected Sources

This MACT standard applies only to major sources in the wood furniture manufacturing industrial classification codes found below in Table 1. A major source of HAPs is one that emits or has the potential to emit 10 tons per year (tpy) of an individual HAP or 25 tpy of a combination of all HAPs per year. Potential to Emit means your ability to emit a pollutant or pollutants taking into account the maximum design capacity of your equipment and your facility - manufacturing operations are considered to be taking place 365 days per year, 24 hours per day. Emission control equipment may reduce the amount of "potential" emissions.

Table 1. Wood Furniture Categories Affected by Final MACT

SIC 7641 Wood Furniture Refinishing and Restoration is not included as affected sources.

Exemptions

If your facility qualifies for one of the following exemptions you can be classified as an area source and will not be subject to Title V Federal Operating Permits. Each of the exemptions will require that you keep and maintain records providing proof of your exemption for a period of five (5) years. Also, at least 90% of your plant wide emissions must be associated with the manufacture of wood furniture for these exemptions to apply. The exemptions are as follows:

• You can be exempt if you are using or agree to use no more than 250 total gallons per month or 3,000 gallons per rolling 12-month period of finishing materials, adhesives, cleaning solvents and washoff solvents.
• You are exempt if you are using more than 250 gal/month or 3000 gal/yr if you use materials that contain no more than 5 tons of any one HAP per rolling 12 month period or no more than 12.5 tons of any combination of HAPs per rolling 12 month period, including materials from other emission sources not associated with the manufacture of wood furniture.
• You are also exempt if you are an "Incidental" Wood Furniture Manufacturing facility. These sources use no more than 100 gal/month of wood furniture coatings and adhesives, but are major due to other unrelated operations at the facility, i.e., operations not included in the SIC codes for the wood furniture industry.

Approach

The MACT regulates emissions of HAPs from all applicable wood furniture surface coating operations nationwide (see Table 1 above).

The MACT standard contains numerical emission limits for surface coating operations including finishing, contact adhesive, and peelable spray booth coating (see Table 2). Finishes include stains, washcoats, basecoats, fillers, sealers, glazes, highlighters, enamels and topcoats.

The MACT also contains work practice standards (see Table 4) which will reduce waste and evaporation of HAPs through the implementation of good housekeeping measures such as keeping containers of materials closed, periodic training of operators who use solvent and/or coatings, and performing periodic inspections to locate and repair of leaking equipment. In addition, the rule requires use of spray equipment which is believed to be more efficient in applying coatings and requires accounting procedures for the quantity of solvent used for cleaning and washoff, the number of times each piece of equipment is washed off, and the reason for the washoff. These practices will help focus attention on quality control issues that result in the minimization of HAP and volatile organic compound emissions.

Compliance Schedule

• The MACT Standard was proposed on December 6, 1994. On December 7, 1995, the final MACT was adopted.
• Sources emitting more than 50 tpy of HAPs have until November 21, 1997 to comply with the final rule.
• Sources emitting less than 50 tpy of HAPs have until December 7, 1998 to comply with the final rule.

Compliance Methods

Compliance with the MACT Standard can be achieved by using compliant coatings; that is, either non-HAP coatings or those meeting the limits shown in Table 2. High-solids coatings and water-based coatings have fewer Volatile Organic Compounds (VOCs) and HAPs and are becoming more available. Although add-on control may also be used to meet the standards, the use of less solvent and fewer toxics in coatings and finishes is preferred (and may be more economical).

The basic methods for complying with the standards for finishing operations are the use of low HAP materials or control devices such as incinerators. For cleaning operations, the basic method of complying with the standards are based on the use of low-VOC strippable coatings for spray booths.

Limits for MACT

"As applied" means after the coating has been thinned or diluted with additional solvent (which is usually done at the furniture manufacturing facility). The "as applied" value for the HAP or VOC can be calculated from the manufacturers data (e.g., for the case of VOC, Test Method 24 data) and the quantity of VOC which was added to the coating.

• Existing Finishing Operations:
  1.0 lb of HAP per pound of solid as applied.
• New Finishing Operations:
  0.8 lbs of HAP per pound of solid as applied. 1.0 lb of HAP per pound of solid as applied for stains. Max % HAP for thinners is 10%.
• Peelable Spray Booth Coating:
  0.8 lb of VOC per lb for both existing and new sources.
• Existing Contact Adhesive:
  1.8 lbs of HAP per pound for foam adhesives that meet flammability tests and 1.0 lbs of HAP per pound for all other adhesives. There are no VHAP limits for aerosol adhesives and for contact adhesives applied to nonporous substrates.
• New Contact Adhesive Operations:
  0.2 lbs per pound for most adhesives and foams and no VHAP content limits on aerosol adhesives and contact adhesives applied to nonporous substrates.

A summary of all of the MACT limits can be found in Table 2.

Table 2. Summary of Final MACT Emission Limit

Work Practice Standards

In addition to numerical standards, the rule minimizes evaporative emissions through work practices covering storage, transfer, and applications in finishing, contact adhesive, cleaning, and washoff operations. These practices include employee training, inspection and maintenance, and housekeeping measures (such as "containers should be closed when not in use").

Table 3. Summary of Work Practice Standards for the MACT

The work practice standards apply to both existing and new major sources. Air guns will be allowed only in the following instances:

• when used in conjunction with coatings less than 1.0 lb VOC/lb of solids
• for touch up and repair under limited conditions
• when spray is automated
• when add-on controls are used
• if the cumulative application is less than 5% of total gallons of coating applied
• if the permitting agency determines other application technology is economically or technically infeasible.

Reporting and Housekeeping

All facilities will be required to keep records and provide periodic reports to the air pollution control agency. Records should be maintained and consolidated in one location for convenient review by regulatory officials. The recordkeeping requirements associated with the proposed rule are summarized in Table 5.

For more complete compliance information refer to the final rule or contact one of the following:

Environmental Protection Agency
Paul Almodovar, (919) 541-0283 - Rule Author
Alice Chow, (215) 566-2144 or 1-800-438-2474 - US EPA Region III

For more information, visit the following page in the VA SBAP web site:

• Resources By Industry Sector: Furniture Manufacturers & Finishers index

SOURCE:
The VA Office of Small Business Assistance would like to thank the NC Small Business Assistance Program Ombudsman, Edythe McKinney, and her staff for the development of this fact sheet and their work in the Regulatory Negotiation Process in the development of this standard.