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© 1996 SBEAP 


Wood Furniture Makers

Compliance Options and Regulatory Requirements under the Clean Air Act:
A Guide for Small Businesses

 

Prepared by the Kansas Small Business Environmental Assistance Program

 

WHAT IS SBEAP?

The Clean Air Act Amendments of 1990 affect many small businesses that previously were unregulated. As a result, Congress mandated that every state provide free nonregulatory technical assistance to its small businesses. In Kansas, this assistance is provided by the Small Business Environmental Assistance Program (SBEAP). All SBEAP services are completely confidential, nonregulatory, and free.
SBEAP provides guidance in compliance and technical matters to businesses that otherwise would not have access to such help because of financial constraints. SBEAP emphasizes assistance designed to diminish the burden of compliance. Its staff can introduce you to pollution prevention practices such as changes in product design, substitution of materials, process optimization, waste minimization, and recycling.
SBEAP operates independently of the Kansas Department of Health and Environment (KDHE), but coordinates with the agency to ensure that SBEAP’s interpretation of Kansas air quality regulations is consistent with KDHE’s intent.
The consortium operating SBEAP is composed of the University of Kansas’ Center for Environmental Education and Training (CEET), Kansas State University’s Pollution Prevention Institute (PPI), and Wichita State University’s Center for Technology Application (CTA).

Acknowledgments

This pamphlet was written by Julie Peters and edited by Felice Stadler. Jean Waters, Tim Piero, and Dennis Murphey made significant contributions. Special thanks to David Tweedie for reviewing the pamphlet.
This pamphlet was prepared by the Kansas Small Business Environmental Assistance Program. SBEAP is funded through a contract with the Kansas Department of Health and Environment.

 


CONTENTS

Introduction .

Compliance Options Work Practice Standards Recordkeeping Requirements
Reporting Requirements
State Permit Requirements
Preventing Pollution in Your Wood Shop Definitions

Appendix One: Volatile Hazardous Air Pollutants

Appendix Two: Pollutants Excluded from Use in Cleaning and Washoff Solvents

Resources

Where to Find Help .



 

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INTRODUCTION


Overview


Kansas businesses that manufacture wood products face new clean air regulations. A U.S. Environmental Protection Agency (EPA) standard—the National Emissions Standard for Hazardous Air Pollutants (NESHAP)—is part of a national effort to curb chemical emissions threatening human health and the environment.
The standard requires the application of maximum achievable control technology (MACT) to meet emission limits; for this reason, the NESHAP commonly is referred to as a MACT standard.
This pamphlet provides an overview of your compliance requirements. A list of definitions for terms used begins on page 25. Note that not all aspects of the standard (such as test methods) are included. If you would like more information or assistance about your compliance requirements, contact the Kansas Small Business Environmental Assistance Program at 800-578-8898.

Who is Affected?


The new MACT standard sets emission limits and specifies work practices that minimize emissions from the storage, transfer, and application of coatings and solvents. Your business must comply with the standard if you manufacture any of the wood products listed below and have the potential to emit 10 tons of a single hazardous air pollutant (HAP) or 25 tons of a combination of HAPs annually. Standard Industrial Classification (SIC) codes are in parentheses:
Material Safety Data Sheets (MSDS) provide information on the chemical content and concentration of solvent in your materials. The standard applies to all finishing materials (such as stains, sealers, enamels, and thinners), adhesives, and strippable spray booth coatings.

Who is Exempt?

The rule does not apply to businesses that:
Businesses must keep records on site to demonstrate that they are meeting the usage and emission criteria.
Also exempt are incidental wood manufacturers who use less than 100 gal/ month of finishing materials or adhesives in the manufacture of wood furniture or wood furniture components.
You are considered an incidental manufacturer if you are a major source that manufactures products other than wood furniture or wood furniture components (for example, an aircraft manufacturer who has a wood shop). However, these facilities will have to maintain purchase or usage records for coatings and adhesives to demonstrate that they are incidental wood furniture manufacturers.

 

Where to Turn
For general information, fact sheets, Kansas AIRLines newsletter, or other SBEAP publications: SBEAP Resource Center at KU 913-864-3968 For assistance with audits, technical information, or permits: SBEAP Technical Assistance at KSU 800-578-8898 If you have a complaint, a question, or are unsure of whom to call: Office of the Public Advocate 800-357-6087 (in Topeka, 296-0669)

 

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COMPLIANCE OPTIONS


If you produce wood furniture and are affected by this rule, you must comply with emission limits set for each step in the wood furniture manufacturing process. The rule sets emission limits for volatile hazardous air pollutants (VHAPs). See Appendix One for a list of VHAPs. Many ways are available to comply with the finishing and gluing limits. However, you must use compliant spray booth materials in the cleaning process. Table 1 summarizes emission limits and lists the compliance options for finishing and gluing. Monitoring, recordkeeping, and reporting responsibilities vary, depending on the compliance method chosen.

Compliance and Monitoring Procedures

After reviewing options and emission limits, your business must choose a compliance approach. As with many EPA rules, your monitoring responsibilities are considerably fewer if you choose a compliance option that does not require the use of control equipment. For instance, using compliant coatings substantially minimizes your monitoring and recordkeeping requirements. Monitoring requirements for each compliance option are outlined below, as well as procedures for demonstrating initial and ongoing compliance.

Finishing

Compliance Option A. Weighted average
Record the VHAP and solids content for each finishing material used in your facility. Look on your certified product data sheet (CPDS).
Using the first month’s usage data, calculate the average lb VHAP/lb solids for all finishing materials, as applied, using the following equation:

Where:

E  =  Emission limit (lb VHAP/lb solids)

M  =  lb solids/month (for each finishing material)

C  =  lb VHAP/lb solids (for each finishing material)

S  =  lb VHAP/lb solvent (for each solvent added)

W  =  lb solvent/month (added to finishing material)

[Note that M1 is one material used, M2 is another material, etc., through MN for however many different materials used.]


Table 1—Emission Limits

Emission Point Existing Source (lb VHAP/lb solids as applied)* New Source (lb VHAP/lb solids as applied)


Finishing Operations:

Compliance Option A. Weighted Average
Compliance Option B. Compliant Coatings
      Stains
      Washcoats
      Sealers
      Topcoats
      Basecoats
      Enamels
      Thinners (maximum percent HAP)
Compliance Option C. Control Device
Compliance Option D. Combination of A, B, and C



1.0

  
1.0
1.0a
1.0
1.0
1.0a
1.0a
10 percent
1.0b
1.0



0.8

  
1.0
0.8a
0.8
0.8
0.8a
0.8a
10 percent
0.8b
0.8

All Cleaning Operations:

(lb VOC/lb solids)** Strippable Spray Booth Material
0.8 0.8

Gluing Operations:

Compliance Option A. Weighted Average Method not available. Choose Option B or Option C. Compliance Option B. Compliant Contact Adhesives
     Aerosol adhesives and contact adhesives      applied to nonporous substrates
     Foam adhesives subject to flame test
     All other contact adhesives
Compliance Option C. Control Device

 

 

 

 


No limitc

 

1.8
1.0
1.0d

 

 

 

 


No limitc

 

0.2
0.2
0.2d

* lb VHAP/lb solids means pound of volatile organic HAP per pound of solids as applied.
** lb VOC/lb solids means pound of volatile organic compounds per pound of solids as applied.
a. If washcoats, basecoats, and enamels are purchased premade, they may not contain more than 1 lb VHAP/lb of solids; thinners may not contain more than 10 percent HAP by weight. If they are formulated on site, they must be formulated using compliant finishing materials (those that meet the limits specified in this table) and thinners containing no more than 3 percent HAP by weight.
b. The control device must operate at a sufficient efficiency so that no more than 1 pound (for existing sources) or 0.8 pound (for new sources) of VHAP is being emitted per pound of solids used.
c. There is no limit on the VHAP content of these adhesives.
d. The control device must operate at a sufficient efficiency so that no more than 1 pound (for existing sources) or 0.2 pound (for new sources) of VHAP is being emitted per pound of solids used.

Step One. For each finishing material you use monthly, multiply mass of solids (lb solids/ month) times its VHAP content (lb VHAP/lb solids):

      lb solids/month x lb VHAP/lb solids = lb VHAP/month for finishing materials
               (MN )                    (CN )

Step Two. For each solvent you add to a finishing material monthly, multiply its VHAP content (lb VHAP/lb solvent) times the amount of solvent used (lb solvent/month):

      lb VHAP/lb solvent x lb solvent/month = lb VHAP/month for solvent added
                 (SN )                         (WN )

Step Three. Add the results from step one and two for all finishing materials and added solvents, then divide by the total solids used per month for all finishing materials

      (M1 + M2 + ... + MN ).

To demonstrate initial compliance, submit an initial compliance status report that includes the results of the averaging calculation for the first month following your compliance date. The emission limit should be less than or equal to the established limits listed in Table 1.
To demonstrate ongoing compliance, you must perform the same calculation monthly.
Your semiannual compliance report will include the monthly averaging calculation, signed by an official of your company, stating that you are meeting the prescribed emission limit.
If you exceed the set emission limit, you are out of compliance for each day of the month, unless you can attribute the exceedance to a particular day or days.

Compliance Option B.
Compliant coatings

Make a list of each regulated finishing material and the quantity used by your facility. Record the VHAP and solids content, as reported on the CPDS.
If you purchase premade materials, make sure the coatings meet the limits listed in Table 1 and thinners contain no more than 10 percent HAP by weight.
If you formulate washcoats, basecoats, and enamels on site, use finishing materials containing no more than 1 lb VHAP/lb solids and a thinner containing no more than 3 percent HAP by weight.
To demonstrate initial compliance, submit an initial compliance status report stating that you are using compliant stains, washcoats, basecoats, enamels, sealers, topcoats, and thinners (maintain CPDS for all materials).
To demonstrate ongoing compliance, submit a signed compliance certification that states you have used compliant coatings during the entire reporting period.
You are out of compliance if you use a noncompliant coating.

Continuous coaters using Option B may choose between two methods for demonstrating initial and ongoing compliance:

Continuous Coaters—Method One
To demonstrate initial compliance, submit an initial compliance status report stating that you are using compliant coatings and compliant thinners.
To demonstrate ongoing compliance, submit a signed compliance certification stating that you used compliant coatings and thinners during the entire reporting period. If you used noncompliant coatings, identify the days on which you used them and explain why you used them.
You are out of compliance if you use a noncompliant coating.

Continuous Coaters—Method Two
To demonstrate initial compliance, submit an initial compliance status report stating that you are using compliant coatings, showing that viscosity is an appropriate operating parameter, monitoring the viscosity of the coating in the reservoir, and using compliant thinners.
To demonstrate ongoing compliance, submit a compliance certification stating that you used compliant coatings and thinners each day and that the viscosity of the coating in the reservoir was not less than the viscosity of the initial coating. The initial coating is the coating initially mixed and placed in the reservoir for any day in the reporting period. Continuously monitor the viscosity, or measure the initial viscosity and measure each time after adding solvent. Maintain records of solvent additions.
You are out of compliance if the coating’s viscosity in the reservoir is less than the viscosity of the initial coating or the coatings exceed the limits listed in Table 1.

 


Table 2—Control Devices

Control Device Operating Parameters
Thermal Incinerator

Catalytic Incinerator Fixed catalyst bed

Fluidized catalyst bed


Carbon Adsorber



Other

Minimum combustion temperature.

Minimum gas temperature up and downstream from bed.


Minimum gas temperature upstream from bed plus pressure drop across catalyst bed.

Total regeneration mass stream flow and carbon bed temperature after each regeneration, or the concentration level of organic compounds exiting the adsorber.

Establish your own (see text).

Compliance Option C.
Control device
Identify and submit operating parameters that will be monitored to demonstrate compliance with the emission limits. See Table 2 for example operating parameters.
Conduct a performance test and calculate the overall control efficiency to show that you meet the emission limits listed in Table 1. For more information on performance testing, contact SBEAP.
Demonstrate ongoing compliance by continuously measuring and recording the values of site-specific operating parameters, which you establish during the initial performance test. If you exceed the emission limits, submit an excess emission report and a summary report.
If you use a control device not listed in Table 2, submit a description of the equipment with test data verifying its performance capabilities, as well as operating parameters that will be monitored to demonstrate ongoing compliance.

Compliance Option D.
Combination of Options A, B, and C
If you choose this option, you are required to follow all applicable requirements listed under each separate compliance option.

Cleaning

All cleaning operations
Use strippable spray booth coatings with no more than 0.8 lb VOC/lb solids (see Table 1). Maintain copies of CPDS for each strippable spray booth material used.
Submit an initial compliance status report stating that you are using compliant strippable spray booth coatings.
To demonstrate ongoing compliance, submit a signed compliance certification stating that you used compliant coatings during the entire reporting period.

Gluing

Compliance Option A.
Weighted average
You cannot use this method for contact adhesives. Use Option B or Option C.

Compliance Option B.
Compliant materials
Use compliant materials that will meet the VHAP content for contact adhesives listed in Table 1.
To demonstrate initial compliance, submit an initial compliance status report stating that you are using compliant contact adhesives.
To demonstrate ongoing compliance, submit a signed compliance certification stating that you used compliant contact adhesives during the entire reporting period.
You are out of compliance if the VHAP content of your contact adhesives exceeds the limits listed in Table 1.

Compliance Option C.
Control device
Meet all requirements listed under compliance Option C for Finishing.

 

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WORK PRACTICE STANDARDS

In addition to meeting emission limits, you must comply with work practice standards at each step in the wood furniture manufacturing process. Your business is responsible for writing a Work Practice Implementation Plan to ensure compliance with the work practice requirements. This plan must be kept on site and must include documentation on conventional air spray gun usage, an inspection and maintenance plan, an operator training program, a solvent accounting system, and a formulation assessment plan. In addition, the MACT standard outlines specific housekeeping requirements for line cleaning, gun cleaning, and washoff operations. You have to maintain records such as logs to demonstrate your adherence to these requirements. The housekeeping requirements are presented in the form of a checklist. Other elements of the Work Practice Implementation Plan are detailed after the checklist.

Housekeeping Requirements

Conventional Air Spray Gun Use

The MACT standard restricts the use of conventional air spray guns; however, they may be used in a few instances. If you use conventional air spray guns, you must keep records showing the total amount of finishing materials used and the percentage of coatings applied with these guns. You may use conventional air spray guns when:

Inspection and Maintenance Plan

At a minimum, do a monthly leak inspection of all equipment used to transfer or apply finishing materials, adhesives, or solvents.
Record the date and results of each leak inspection and any repairs made.
Initial repairs should be made within five days and final repairs should be made within 15 days. If new equipment is required to replace leaking equipment, it must be installed within three months.

Operator Training Program

Train all current employees within six months of the compliance date and conduct annual refresher training. New employees must be trained upon hire.
Maintain a list by name and job description of all current personnel who require training.
Maintain a list of subjects and lesson plans to be covered at the initial and annual refresher training courses. Topics must include application techniques, appropriate cleaning and washoff procedures, appropriate equipment setup, and appropriate management of cleaning wastes.
Document successful completion of each training session; there is no single prescribed method for documenting training.

Solvent Accounting System

Record monthly the quantity and type of solvent used for washoff and cleaning.
Record monthly the number of pieces washed and reasons why washing is required.
Record monthly the quantity of spent material generated from each washoff and cleaning operation.
Indicate whether materials are recycled on site, disposed off site, or both.

Formulation Assessment Plan

Identify any VHAPs from Table 3 that your facility uses in finishing operations.
Establish a baseline level for each VHAP listed in Table 3; this level will be the highest annual usage from 1994, 1995, or 1996.
Track annual usage of each VHAP.
If after November 1998 annual usage of a VHAP exceeds its baseline level, write to the Kansas Department of Health and Environ- ment (KDHE) describing the increase and explaining the reason for the increase. Several conditions are outlined in the rule that will relieve you from further action unless you are out of compliance with any other VHAP regulation.
If you use a chemical after November 1998 for which you have not established a baseline level, you are required to keep your VHAP usage below the EPA-established de minimus levels listed in Table 3.

 


Table 3—VHAPs of Potential Concern

Chemical Name CAS No.* De Minimus Levels (tons/yr)
Dimethyl Formamide
Formaldehyde
Methylene Chloride
2-Nitropropane
Isophorone
Styrene Monomer
Phenol
Diethanolamine
2-Methoxyethanol
2-Ethoxyethyl Acetate
68122
50000
75092
79469
78591
1000425
108952
11422
109864
111159
1.0
0.2
4.0
1.0
0.7
1.0
0.1
5.0
10.0
5.0

*Chemical Abstract Services number.

 

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RECORDKEEPING REQUIREMENTS

Your recordkeeping responsibilities are outlined in Table 4. You must keep all records for five years. Documentation required to Recordkeeping Requirements demonstrate initial and ongoing compliance is outlined under “Compliance Options”.


Table 4—Recordkeeping Requirements


Compliance Option


Recordkeeping

All Owners
  1. For each finishing material, thinner, and contact adhesive, keep copies of CPDS and document content of VHAPs in lb VHAP/lb solids, as applied.
  2. For each strippable spray booth coating, keep CPDS and document content of VOCs in lb VOC/lb solids, as applied.
  3. Information submitted with initial compliance status report and semiannual reports.
Finishing Operations
Option A. Weighted Average

 

Option B. Compliant Coatings (2, 3, and 4 only apply to continuous coaters)

 

 

Option C. Control Device

 


Option D. Combination


  1. Copy of monthly averaging calculation.
  2. Data on coatings and thinners used to perform calculation.
  1. Copy of semiannual compliance certification.
  2. Solvent and coating additions to the continuous coater reservoir.
  3. Viscosity measurements.
  4. Data showing that viscosity is an appropriate operating parameter for demonstrating compliance.
  1. Calculations showing that the control efficiency meets limits shown in Table 1.
  2. Operating parameter values.
  3. Semiannual compliance reports.
Requirements from A, B, and C.
Cleaning Operations
Requirement

Copy of semiannual compliance certification.
Gluing Operations
Option A. Weighted Average

Option B. Compliant Coatings

Option C. Control Device


Option not available. Choose Option B or   Option C.

Copy of semiannual compliance certification.
  1. Calculations showing that the overall control efficiency meets limits listed in Table 1.
  2. Operating parameter values.
  3. Semiannual compliance reports
Work Practice Standards
Requirement
Records associated with fulfilling Work Practice Implementation Plan, including:
  1. Housekeeping Logs
  2. Conventional Air Spray Gun Usage Logs
  3. Inspection and Maintenance Plan
  4. Operator Training Program
  5. Solvent Accounting System
  6. Formulation Assessment Plan

 

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REPORTING REQUIREMENTS

If you are affected by this MACT standard, you must comply with the following reporting requirements. These requirements are some- what minimized if you use compliant materials to meet emission limits. Table 5 lists compliance dates and Table 6 summarizes the requirements of the Clean Air Act General Provisions. Table 7 outlines requirements specific to the wood furniture rule, while Table 8 outlines the requirements of the initial notification report.
The MACT standard applies to major wood furniture manufacturing sources. Area sources are exempt from the standard.

Definitions for Major and Area HAP Sources

Major Source

Under this MACT standard, a major source is one that emits or has the potential to emit 10 tons of a single hazardous air pollutant (HAP) or 25 tons of a combination of HAPs annually. See “State Permit Requirements,”, for discussion on “potential-to-emit.” Note that there are two different compliance dates for major sources (see Table 5).

Area Source


Under this MACT standard, an area source is one that uses less than or equal to 250 gal/ month, or 3,000 gal/rolling 12-month period of coating, gluing, cleaning, and washoff materials, provided that these materials account for at least 90 percent of the source’s annual HAP emissions from wood furniture manufacturing operations.


Table 5—Compliance Dates

Source Type Compliance Date
Major Existing Sources*
    emitting less than 50 tons of HAP in 1996
    emitting 50 tons or more of HAP in 1996
Area sources (existing) that become major
Area sources (new) that become major
New major sources**



12/07/98
11/21/97

One year after change in status
Immediately after change in status
12/07/95 or upon startup

* Existing Source—A source in operation before December 7, 1995.
** New Source—A source constructed or reconstructed after December 7, 1995.


 


Table 6—Requirements of General Provisions


Requirement


Due Date

Existing Sources:
Submit Initial Notification Report (see Table 8)

New Sources:
Notification of anticipated startup
Notification of actual startup
Notification of compliance status

Sources using control devices:
Operation and Maintenance Plans (includes startup, shutdown, and malfunction plans)
Notification of performance test
Completion of performance test
Site-specific test plan
Report of performance test results
Startup, shutdown, and malfunction reports
Excess emissions and summary report*


September 7, 1996


30–60 days prior to startup
15 days after startup
60 days after demonstrating compliance (compliance must be demonstrated upon startup)

By the compliance date (see Table 5)

60 days prior to test
180 days after compliance date
60 days prior to test
60 days after test
Semiannually
Semiannually


* If your facility has excess emissions, quarterly reporting is required for at least one year after the exceedance and until a written request to reduce reporting frequency is approved.

Send original reports to:
Harish Agarwal
Chief, Air Compliance and Planning
Bureau of Air and Radiation
KDHE
Building 283, Forbes Field
Topeka, KS 66620-0001
Send copies to:
William A. Spratlin
Director of Air, RCRA, and Toxics
U.S. EPA, Region 7
726 Minnesota Avenue
Kansas City, KS 66101


Table 7—Specific Requirements

Requirements for All Sources

Due Date

Initial Compliance Status Report:
  • Calculations to demonstrate compliance with emission limits
  • Work practice implementation plan (see Table 4 for components of plan)
  • Performance test results (control device users only)

 

Sources not using a control device: 60 days after compliance date (see Table 5).

Sources using a control device: 60 days after performance test results.

Continued Compliance Status Report:
  • Calculations (if using averaging approach)
  • Compliance certification (if using compliant coatings, contact adhesives, and strippable spray booth materials)
  • Certification that work practice standards are being followed
  • Quantity of cleaning and washoff solvent that is used monthly when out of compliance, and a description of methods used to come into compliance

 

Semiannually, with first report due 30 days after first six-month period; subsequent reports due 30 days after each six-month period.

 


Table 8—Initial Notification Report

Contents—Requirements for All Sources

Due Date

Name and address of owner or operator
Address of wood furniture manufacturing facility Compliance date (see Table 5)
Brief description of facility and identification of air emissions sources
Declaration of major or area source status

September 7, 1996

 

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STATE PERMIT REQUIREMENTS

If you are a major source of hazardous air pollutants, you are required to get a Class I air operating permit from the Kansas Department of Health and Environment (KDHE). A major source emits or has the potential to emit 10 tons of a single HAP or 25 tons of a combination of HAPs. Potential-to-emit means maximum amount of air pollution your facility could possibly emit if it operated at 100 percent of design capacity; all equipment was operated 24 hours per day, 365 days per year; and no pollution control equipment was being used. Therefore, while your actual emissions may fall below the major source thresholds for HAPs, your potential emissions could classify you as a major source.
If your actual emissions are above the major source thresholds, you have to get a Class I permit. However, if your actual emissions are below these thresholds, but your potential emissions are above, you may be able to apply for a Class II permit. Class II permit applications are relatively simple, and they provide an opportunity for you to avoid the rigor, complexity, and expense of a Class I permit application.
The Class II permit puts a federally enforceable limit on your facility’s potential-to- emit (PtE). This means that the limits are practicable (possible and workable) and provable (requiring some recordkeeping and reporting). Examples of this include:

Under the Class II permit program, KDHE has developed a simplified process called the “permit-by-rule.” This allows certain industries to limit their potential emissions through some operational restrictions and recordkeeping. The permit-by-rule is an option for solvent evaporative sources, such as wood furniture manufacturers.

Table 9 illustrates the available permit options, depending on your actual and potential air emissions. If you determine that you need to apply for a permit, whether it be Class I or Class II, contact KDHE. If you need help calculating your air emissions to determine which permit may apply to you, contact SBEAP.



Table 9—Kansas Air Permits

Source Type Class I Permit Class II Permit
Major Source
(actual emissions > major source levels)*

N/A
Major Source
(potential emissions > major source levels, actual emissions < major source levels)


(or limit PtE)
Area Source
(potential and actual emissions < major source levels)

N/A N/A

* > means greater than, < means less than.

 

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PREVENTING POLLUTION IN YOUR WOODSHOP

Pollution prevention techniques can help you reduce emissions and save money while helping you comply with the MACT standard.
Generally speaking, one single technique or technology will not be adequate to achieve the level of performance required by the Clean Air Act. A combination of approaches is generally the best way to meet your requirements. The following section provides ideas for implementing pollution prevention practices in your facility. These practices can help reduce air emissions, hazardous waste generation, and worker exposure to toxic materials. Applicable pollution prevention techniques include:

Improving Operation and Maintenance

Equipment Setup

Simple modifications in your equipment setup often can result in more efficient use of raw materials. Make improvements to your operation and maintenance procedures that reduce emissions and waste, and result in cost savings.

Operator Training

You can train your employees to improve product quality and use materials more efficiently in several areas. Some operators produce high-quality finishes but are poorly trained in reducing material use. Differences caused by the painter’s skill level with a single gun type often are greater than differences between gun types. A skilled operator will adjust for the type of coating being applied, atmosphere conditions, the size and shape of the object being coated, and the spray equipment being used. Proper coating techniques should be reinforced with periodic training.
Throughout all training, emphasize the benefits of waste reduction and energy conservation. Discuss the safety and health hazards associated with the equipment and material uses, and how employees can protect themselves and prevent accidents.

Spray Guns

Equipment Cleaning

Managing Inventory

Too much inventory or lack of inventory control can lead to wasted materials, either through using more than needed or purchasing material that deteriorates before use. Managing inventory can reduce costs for unneeded materials, reduce waste disposal costs, increase floor space, and reduce risks associated with storing hazardous materials.

Substituting Materials

The wood furniture MACT standard allows for the use of low VHAP coatings and cleaning solutions. Work closely with suppliers to identify substitutes for raw materials containing solvents.

High Solids Coatings

High solids coatings are solvent-borne coatings that are at least 50 percent solids in content.

Waterborne Coatings

Waterborne coatings contain water as well as some solvent. They are used in the industry on open-pore and lighter-colored woods.

UV-Curable Coatings

UV-curable coatings can be 100 percent reactive liquids, and require UV light for curing. They are already being used in the industry.

Alternative Cleaners

Additional opportunities exist for reducing waste from the use of cleaning solutions. Alternative cleaning solutions are available that contain small quantities of solvent. One alternative being used in the industry is n- methyl pyrrolidone, a water-soluble, biodegradable solvent that generates fewer emissions, is nonflammable, and can be cleaned using soap and water.

 

Modifying the Production Process

A more technical pollution prevention activity is modifying your production process. This includes substituting or modifying equipment, increasing automation, or redesigning or reformulating your end product. Begin making modifications in the equipment used to apply coatings to your wood surfaces.
Invest in equipment that increases transfer efficiency. A few options are available, all of which have been shown to reduce VOC and HAP emissions, raw material use, and waste from overspray. The following spray systems are alternatives to conventional air spray guns.

High Volume/Low Pressure (HVLP) Spray Equipment

HVLP spray guns operate at low pressure, such as 10 lb/square inch (psi), compared to 30–90 psi with conventional spray guns. HVLP spray guns are effective for both solvent- and water-borne materials and increase transfer efficiency up to 40–70 percent.

Airless Spray Equipment

Airless spray systems atomize the coating by increasing the coating’s fluid pressure (ranges from 500–6,500 psi) without introducing a pressurized air flow. Transfer efficiency ranges from 35–65 percent.


Case Study

Thomson Crown Wood Products Conversion to HVLP Spray Equipment

Thomson Crown manufactures wood and wood-finished television cabinets. Cabinet parts were coated using air-assisted airless spray guns (high air pressure up to 55 psi), causing poor transfer efficiency and generating large amounts of VOC emissions. The company purchased HVLP spray guns to replace existing guns.

Cost—$21,350
Waste reduction—13,300 gal/year
Savings—$137,448
Payback period—Less than one year

Air-Assisted Airless Spray Equipment

These systems combine compressed air atomization with airless atomization. About 85 percent of the coating is atomized by fluid pressure (150–800 psi), and 15 percent is atomized by air pressure (5–30 psi) supplied at the nozzle. Transfer efficiency can range from 40–70 percent.

Case Study

Solvent Recovery and Reuse
Ethan Allen Furniture

The company installed a solvent distillation unit to recover solvents and reduce hazardous waste generation. A 7-gallon batch still, which is run twice daily, recovers 5 gallons of reusable solvent for every 7 gallons of cleanup waste.

Cost—$4,500
Waste reduction—1,900 lb/year
Savings—$3,200/year
Payback period—Less than two years


Recovering, Recycling, and Reusing Materials

Many opportunities exist for you to recycle finishing materials on site. On-site recycling reduces the amount of waste to be treated and disposed of, and reduces costs associated with disposal and compliance requirements. It also reduces the amount of new materials needed, thereby generating additional cost savings.

 

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DEFINITIONS

A complete set of definitions applicable to the wood furniture manufacturing MACT standard can be found in the Code of Federal Regulations: 40 CFR part 63.801.

Aerosol adhesive An adhesive dispensed from a pressurized container as a suspension of fine particles in gas.

Affected source A wood furniture manufacturing facility that is engaged, either in part or in whole, in the manufacture of wood furniture or wood furniture components and that is located at a plant site that is a major source.

Alternative method Any method of sampling and analyzing for an air pollutant that is not a reference or equivalent method but has been demonstrated to produce results adequate for determining compliance.

Area source Under this MACT standard, a source that uses less than or equal to 250 gal/month, or 3,000 gal/rolling 12- month period of coating, gluing, cleaning, and washoff materials, provided that these materials account for at least 90 percent of the source’s annual hazardous air pollutant emissions. Area sources are exempt from this MACT standard.

As applied The HAP and solids content of the coating or contact adhesive that is actually used for coating or gluing the substrate, after any materials have been added in-house for thinning.

Baseline conditions The conditions that exist prior to an affected source implementing controls, such as a control system.

Capture device A hood, enclosed room, floor sweep, or other means of collecting solvent emissions or other pollutants into a duct so that the pollutant can be directed to a pollution control device such as an incinerator or carbon adsorber.

Capture efficiency The fraction of all organic vapors generated by a process that is directed to a control device.

Certified Product Data Sheet (CPDS) Documentation furnished by coating or adhesive suppliers or an outside laboratory that provides the HAP content by percent weight of a finishing material, contact adhesive, or solvent.

Coating solids The part of the coating that remains after the coating is dried or cured.

Compliant coating/contact adhesive A finishing material, contact adhesive, or strippable booth coating that meets the emission limits specified in Table 1 of this pamphlet.

Contact adhesive An adhesive that is applied to two substrates, dried, and mated under only enough pressure to result in good contact. The bond is immediate and sufficiently strong to hold pieces together without further clamping, pressure, or airing.

Continuous coater A finishing system that continuously applies finishing materials onto furniture parts moving along a conveyer. Finishing materials that are not transferred to the part are recycled to a reservoir. Several application methods can be used with a continuous coater, including spraying, curtain coating, roll coating, dip coating, and flow coating.

Continuous compliance The affected source is meeting the emission limitations and other requirements at all times, and is fulfilling all monitoring and recordkeeping provisions of the rule to demonstrate compliance.

Control device Equipment that reduces the quantity of a pollutant emitted to the air. The device may destroy or secure the pollutant for subsequent recovery.

Control device efficiency The ratio of the pollutant released by a control device and the pollutant introduced to the control device.

Control system The combination of capture and control devices used to reduce emissions to the atmosphere.

Conventional air spray A spray coating method in which the coating is atomized by mixing it with compressed air and applied at an air pressure greater than 10 lb/ square inch.

De minimus levels Emission levels established by the U.S. EPA for hazardous air pollutants. Emissions below the de minimus levels are not regulated by the Clean Air Act.

Equipment leak Emission of volatile hazardous air pollutants from pumps, valves, flanges, or other equipment used to transfer or apply coatings, adhesives, or organic solvents.

Equivalent method Any method of sampling and analyzing for an air pollutant that has been demonstrated to have a consistent and quantitatively known relationship to the referenced method.

Foam adhesive A contact adhesive used for gluing foam to fabric, foam to foam, and fabric to wood.

Incidental wood furniture manufacturer A major source that is primarily engaged in the manufacture of products other than wood furniture or wood furniture components and that uses no more than 100 gal/month of finishing material or adhesives in the manufacture of wood furniture or wood furniture components. Incidental wood furniture manufacturers are facilities that manufacture small quantities of furniture primarily for on-site use. Sources falling under this definition are exempt from the standard. However, these facilities will have to maintain records of coating and adhesive usage to demonstrate that they are incidental wood furniture manufacturers.

Incinerator An enclosed combustion device that thermally oxidizes volatile organic compounds to carbon monoxide and carbon dioxide and water.

Major source Under this MACT standard, a source that has the potential to emit 10 tons of a single hazardous air pollutant (HAP) or 25 tons of a combination of HAPs annually. Major sources must comply with all provisions of this MACT standard, including obtaining an air operating permit from the state of Kansas. Under the Clean Air Act and the Kansas Air Quality Act, a major source is defined as one that emits or has the potential to emit annually 10 tons of a single HAP; 25 tons of a combination of HAPs; or 100 tons of nitrogen oxides, sulfur oxides, carbon monoxide, or particulate matters smaller than 10 microns.

Material Safety Data Sheet (MSDS) Documentation required for hazardous materials that identifies certain reportable hazardous ingredients, safety and health considerations, and safe handling procedures. These documents are furnished to the user by the supplier or manufacturer.

Noncompliant coating/contact adhesive A finishing material, contact adhesive, or strippable spray booth coating that has a VHAP content (or VOC content for the strippable booth coating) greater than the emission limits listed in Table 1.

Nonporous substrate A surface that is impermeable to liquids. Examples include metal, rigid plastic, flexible vinyl, and rubber.

Operating parameter value A minimum or maximum value established for a control device or process parameter that, if achieved by itself or in combination with one or more operating parameter values, determines that an owner or operator has complied with an applicable emission limit.

Overall control efficiency The efficiency of a control system, expressed as a percentage, calculated by multiplying the capture and control device efficiencies.

Rolling 12-month period The time period that includes the previous 12 months of operation.

Storage containers Vessels or tanks, including mix equipment, used to hold finishing, gluing, cleaning, or washoff materials.

Strippable spray booth material A coating that: (1) is applied to a spray booth wall to provide a protective film to collect overspray during finishing operations; and (2) reduces or eliminates the need to use organic solvents to clean spray booth walls.

Substrate The surface onto which a coating or contact adhesive is applied.

Washcoat A transparent special- purpose finishing material having a solids content of 12 percent by weight or less.

Washoff operations Operations in which organic solvent is used to remove coating from wood furniture or a wood furniture component.

Wood furniture manufacturing operations The finishing, gluing, cleaning, and washoff operations associated with the production of wood furniture or wood furniture components.

 

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APPENDIX ONE

Volatile Hazardous Air Pollutants

Chemical Name CAS No.
0-Xylene
95476
1,1,2,2-Tetrachloroethane
79345
1,1,2-Trichloroethane
79005
1,1-Dimethylhydrazine
57147
1,2,4-Trichlorobenzene
120821
1,2-Dibromo-3-chloropropane
96128
1,2-Diphenylhydrazine
122667
1,2-Epoxybutane
106887
1,2-Propylenimine (2-Methyl aziridine)
75558
1,3-Butadiene
106990
1,3-Dichloropropene
542756
1,3-Propane sultone
1120714
1,4-Dichlorobenzene
106467
1,4-Dioxane (1,4-Diethyleneoxide)
123911
2-Acetylaminofluorine
53963
2-Chloroacetophenone
532274
2-Nitropropane
79469
2,2,4-Trimethylpentane
540841
2,3,7,8-Tetrachlorodibenzop-dioxin
1746016
2,4-Dinitrophenol
51285
2,4-Dinitrotoluene
121142
2,4-Toluenediamine
95807
2,4,5-Trichlorophenol
95954
2,4,6-Trichlorophenol
88062
2,4-D (2,4-Dichlorophenoxyacetic acid, including salts and esters)
94757
3,3’-Dichlorobenzidine
91941
3,3’-Dimethoxybenzidine
119904
3,3’-Dimethylbenzidene
119937
4-Aminobiphenyl
92671
4-Dimethylaminoazobenzene
60117
4-Nitrobiphenyl
92933
4-Nitrophenol
100027
4,4’-Methylenebis (2-chloroaniline)
101144
4,4’-Methylenedianiline
101779
4,4’-Methylenediphenyl diisocyanate (MDI)
101688
4,6-Dinitro-o-cresol, and salts Acetalaldehyde
75070
Acetamide
60355
Acetonitrile
75058
Acetophenone
98862
Acrolein
107028
Acrylamide
79061
Acrylic acid
79107
Acrylonitrile
107131
Allyl chloride
107051
Aniline
62533
Benzene
71432
Benzidine
92875
Benzotrichloride
98077
Benzyl chloride
100447
beta-Propiolactone
57578
Biphenyl
92524
Bis(2-ethylhexyl)phthalate (DEHP)
117817
Bis(chloromethyl) ether
542881
Bromoform
75252
Caprolactam
105602
Carbon disulfide
75150
Carbon tetrachloride
56235
Carbonyl sulfide
463581
Catechol
120809
Chloroacetic acid
79118
Chlorobenzene
108907
Chloroform
67663
Chloromethyl methyl ether
107302
Chloroprene
126998
Cresols (isomers and mixture)
1319773
Cumene
98828
DDE (1,1-Dichloro-2,2-bis (p-chlorophenyl) ethylene)
72559
Diazomethane
334883
Dibenzofuran
132649
Dibutylphthalate
84742
Dichloroethyl ether (Bis(2-chloroethyl) ether)
111444
Diethanolamine
111422
Diethyl sulfate
64675
Dimethyl phthalate
131113
Dimethyl sulfate
77781
Dimethylcarbamoyl chloride
79447
Epichlorohydrin (1-Chloro-2,3-epoxypropane)
106898
Ethyl acrylate
140885
Ethyl carbamate (Urethane)
51796
Ethyl chloride (Chloroethane)
75003
Ethylbenzene
100414
Ethylene dibromide (Dibromoethane)
106934
Ethylene dichloride (1,2-Dichloroethane)
107062
Ethylene glycol
107211
Ethylene oxide
75218
Ethylenethiourea
96457
Ethylidene dichloride (1,1-Dichloroethane)
75343
Formaldehyde
50000
Glycol ethers b
0
Hexachloro-1,3-butadiene
87683
Hexachlorobenzene
118741
Hexachloroethane
67721
Hexamethylene-1,6-diisocyanate
822060
Hexamethylphosphoramide
680319
Hexane
110543
Hydrazine
302012
Hydroquinone
123319
Isophorone
78591
m-Cresol
108394
m-Xylene
108383
Maleic anhydride
108316
Methanol
67561
Methyl bromide (Bromomethane)
74839
Methyl chloride (Chloromethane)
74873
Methyl chloroform (1,1,1-Trichloroethane)
71556
Methyl ethyl ketone (2-Butanone)
78933
Methyl iodide (Iodomethane)
74884
Methyl isobutyl ketone (Hexone)
108101
Methyl isocyanate
624839
Methyl methacrylate
80626
Methyl tert-butyl ether
1634044
Methylene chloride (Dichloromethane)
75092
Methylhydrazine
60344
N,N-Dimethylaniline
121697
N,N-Dimethylformamide
68122
N-Nitroso-N-methylurea
684935
N-Nitrosodimethylamine
62759
N-Nitrosomorpholine
59892
Napthalene
91203
Nitrobenzene
98953
o-Anisidine
90040
o-Cresol
95487
o-Toluidine
95534
p-Cresol
106445
p-Phenylenediamine
106503
p-Xylene
106423
Phenol
108952
Phosgene
75445
Phthalic anhydride
85449
Polychlorinated biphenyls (Aroclors)
1336363
Polycyclic Organic Mattera
0
Propionaldehyde
123386
Propoxur (Baygon)
114261
Propylene dichloride (1,2-Dichloropropane)
78875
Propylene oxide
75569
Quinone
106514
Styrene
100425
Styrene oxide
96093
Tetrachlorethylene (Perchloroethylene)
127184
Toluene
108883
Toluene-2,4-diisocyanate
584849
Trichloroethylene
79016
Triethylamine
121448
Trifluralin
1582098
Vinyl acetate
108054
Vinyl bromide
593602
Vinyl chloride
75014
Vinylidene chloride (1,1-Dichloroethylene)
75354
Xylenes (isomers and mixture)
1330207
a Includes organic compounds with more than one benzene ring, and which have a boiling point greater than or equal to 100 degrees Celsius
b Includes mono- and di- ethers of ethylene glycols and triethylene glycol; R-(OCH2 CH2 )RR-OR where:
    n=1, 2, 3
    R=alkyl or aryl groups
    R’=R, H, or groups which, when removed, yield glycol ethers with the structure
    R-(OCH2 CH2 )N -OH.
    Polymers are excluded from the glycol category.

 

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APPENDIX TWO

Pollutants Excluded from Use in Cleaning and Washoff Solvents


Chemical Name CAS No.
1,1-Dimethyl hydrazine
57147
1,2-Dibromo-3-chloropropane
96128
1,2-Diphenylhydrazine
122667
1,2-Propylenimine (2-Methyl aziridine)
75558
1,2:7,8-Dibenzopyrene
189559
1,3-Butadiene
106990
1,3-Dichloropropene
542756
1,3-Propane sultone
1120714
1,4-Dichlorobenzene(p)
106467
1,4-Dioxane (1,4-Diethyleneoxide)
123911
2-Acetylaminoflourine
53963
2-Nitropropane
79469
2,3,7,8-Tetrachlorodibenzo-p-dioxin
1746016
2,4-Dinitrotoluene
121142
2,4-Toluene diamine
95807
2,4,6-Trichlorophenol
88062
3,3’-Dichlorobenzidine
53963
3,3’-Dimethoxybenzidine
119904
3,3’-Dimethylbenzidine
119937
4,4’-Methylene bis (2-chloroaniline)
101144
4,4’-Methylenedianiline
101779
4-Aminobiphenyl
92671
7,12-Dimethylbenz (a)anthracene
57976
Acetaldehyde
75070
Acetamide
60355
Acrylamide
79061
Acrylonitrile
107131
Aniline
62533
Antimony trioxide
1309644
Arsenic and inorganic arsenic compounds
99999904
Benz(c)acridine
225514
Benzene
71432
Benzidine
92875
Benzo (a) pyrene
50328
Benzo(a)anthracene
56553
Benzo(b)fluoranthene
205992
Beryllium compounds
7440417
Beryllium salts Bis(2-ethylhexyl)phthalate (DEHP)
117817
Bis(chloromethyl)ether
542881
Bromoform
75252
Cadmium compounds Captan
133062
Carbon tetrachloride
56235
Chlordane
57749
Chlorobenzilate
510156
Chloroform
67663
Chromium compounds (hexavalent) Chrysene
218019
Coke oven emissions
99999908
DDE (1,1-p-chlorophenyl 1-2 dichloroethylene)
72559
Dibenz(ah)anthracene
53703
Dichloroethyl ether (Bis(2-chloroethyl)ether)
111444
Dichlorvos
62737
Diethyl sulfate
64675
Dimethyl carbamoyl chloride
79447
Dimethyl formamide
68122
Dimethyl aminoazobenzene
60117
Epichlorohydrin
106898
Ethyl acrylate
140885
Ethyl carbamate (Urethane)
51796
Ethylene dibromide (1,2-Dibromethane)
106934
Ethylene dichloride (1,2-Dichloroethane)
107062
Ethylene oxide
75218
Ethylene thiourea
96457
Formaldehyde
50000
Heptachlor
76448
Hexachlorobenzene
118741
Hexamethylphosphoramide
680319
Hydrazine
302012
Indeno(1,2,3-cd)pyrene
193395
Lindane (hexachlorcyclohexane, gamma)
58899
Methyl hydrazine
60344
Methylene chloride (Dichloromethane)
75092
N-Nitroso-N-methylurea
684935
N-Nitrosodimethylamine
62759
N-Nitrosomorpholine
59892
Nickel refinery dust Nickel subsulfide
12035722
o-Anisidine
90040
o-Toluidine
95534
Pentachlorophenol
87865
Polychlorinated biphenyls (Aroclors)
1336363
Propoxur
114261
Propylene dichloride (1,2-Dichloropropane)
78875
Propylene oxide
75569
Selenium sulfide (mono and di)
7488564
Styrene oxide
96093
Tetrachloroethylene (Perchloroethylene)
127184
Toxaphene (chlorinated camphene)
8001352
Trichloroethylene
79016
Vinyl bromide (bromomethene)
593602
Vinyl chloride
75014

 

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RESOURCES

Accomplishments of North Carolina Industries—Case Summaries, “Wood Office Furniture Manufacturer Coats with Air-assisted Airless Spray Guns to Reduce Overspray and VOC Emissions,” Steelcase, Inc. Raleigh, N.C.: North Carolina Dept. of Natural Resources, July 1989.

Guidebook of Environmental Solutions for Small Businesses, Resource Dynamics Corporation. Vienna, Va., August 1993.

Pollution Prevention in the Finishing of Wood Furniture—A Resource Manual and Guide, Waste Reduction Assistance Program, Virginia Department of Environmental Quality. Richmond, Va.: Virginia Department of Environmental Quality, October 1993.

Wood Furniture Industry Waste Reduction Opportunities (Draft), Center for Environmental Research, Tennessee Valley Authority Waste Management, August 1994.

Wood Furniture Waste Reduction Opportunities, Doland-Friss Assoc., Preventative Environmental Management, and Radian Corp. U.S. EPA Center for Environmental Research Information/Tennessee Valley Authority Waste Management, August 1994.

 

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WHERE TO FIND HELP

Air emissions calculations (SBEAP)
800-578-8898

Air permits and emissions calculations (KDHE)
913-296-1593

Hazardous waste (KDHE)
913-296-1600

MACT compliance assistance—free and nonregulatory (SBEAP)
800-578-8898

Paint disposal and recycling (KDHE)
913-296-1600

Pollution prevention (KDHE)
913-296-6603

Recycling (KDHE)
913-296-1540

Stormwater (KDHE)
913-296-5557

Technical assistance—free and nonregulatory (SBEAP)
800-578-8898

VOC emissions (KDHE)
913-296-1548

Water pollution (KDHE)
913-296-5500

 

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