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Division of Pollution Prevention and Environmental Assistance NC Department of Environment, Health, and Natural Resources

The North Carolina Division of Pollution Prevention and Environmental Assistance provides free, non-regulatory technical assistance and education on methods to eliminate, reduce, or recycle wastes

before they become pollutants or require disposal.

Telephone DPPEA at (919) 715-6500 or 800-763-0136 or e-mail [email protected] for assistance with any of your waste reduction concerns.

North Carolina Department of Environment, Health, and Natural Resources

~ ~ ~~~~~

Keys to Environmental Compliance for Wood Furniture Manufacturers

Contents, continued

I. Overview of Environmental Regulations

I. Overview of Environmental Regulations:

I. Overview of Environmental Regulations Introduction

Over the last 25 years, environmental requirements have grown in number and complexity. The requirements designed to protect human health and the environment are often difficult to understand. Environmental stewardship may actually improve if regulations are simpler and if cost-effective compliance options are identified. It is in this vein that key regulatory requirements are summarized.

This section presents an overview of the North Carolina Hazardous Waste, Water Quality, Occupational Safety and Health, and Air Quality Programs as they relate to the wood products and wood furniture businesses and industries. The information is by no means a complete review of all applicable regulations, nor should it take the place of future reviews or interpretations of regulations. All environmental regulations undergo periodic change. This manual represents the most up-to-date, accurate overview of the current requirements the authors can present at this time.

All environmental program use specific definitions and acronyms or abbreviations for brevity and clarity. Definitions of terms and acronyms used in this manual and workshop are provided in Appendix C.

Wood Furniture Manual I-1 August 1996

I. Overview of Environmental Regulations: Hazardous Waste Management

Hazardous Waste Management

Management of all waste is an important responsibility. The type of waste produced or generated determines treatment and waste management requirements. The creator or generator of the waste is responsible for the waste from the ‘cradle to the grave’, regardless of who is controlling or transporting it. The CERCLA regulations allow potentially responsible parties to be held liable for remedation and monitoring of contaminated sites. Therefore, ensuring proper handling and disposal is important.



The materials and the process operations used determine hazardous waste requirements. Tables I-3, I-4, and 1-5 show areas and coatings or chemicals that need scrutiny.



Table 1-5: Hazardous Wastes Commonly Generated in Furniture Manufacturing


I. Overview of Environmental Regulations: EPA Identification Numbers

EPA Identification Numbers

Many businesses and industries will need to obtain an EPA Identification Number. This number is used on shipping manifests to track hazardous waste from the ‘cradle-to-the grave.’

Conditionally Exempt Small Quantity Generators (CESQGs) are not required to apply for an EPA Identification number to ship hazardous waste. However, some disposal companies may require an EPA ID before transporting or disposing of the waste. If a CESQG has an EPA ID Number, it must be used on all manifests.

Small and Large Quantity Generators (SQGs and LQGs) must notify the Division of Waste Management (DWM) of hazardous waste generation and obtain an EPA ID Number. The Hazardous Waste Section in the DWM assigns the EPA ID Number. Jim Edwards at 91 9-733-2178, ext. 209, is the contact.

If yon move or sell or lease your business, you and the new owner or renter must notify the DWM of the changes.

Store hazardous waste in closed, well kept containers.

Clearly mark/label the containers as “Hazardous Waste.”.

Keep good records of the wastes you produce, where they are, and who carried them away or how you disposed of them.

Mixing of wastes should be avoided. Generally adding a hazardous waste to a non-hazardous waste makes the whole mixture a hazardous waste, although there are exceptions.

Reduce, Reuse, Recycle - Practice Waste Minimization and Pollution Prevention.

Land or landfill disposal of hazardous waste is prohibited. Contact the local town, City or county landfill authority for local restrictions.


I. Overview of Environmental Regulations: Superfund Amendments and Reauthorization Act

Superfund Amendments and Reauthorization Act: SARA Title III and the Emergency Planning and Community Right-to Know Act - EPCRA

These laws specify requirements for chemicals processed, used, or stored on site. This information helps local communities plan for emergencies and improve safety. The following is a summary of the requirements.

Emergency Planning for Chemical Releases

Hazardous Chemical Inventory Reporting

Emergency Notification for Chemical Toxic Chemical Release Reporting Releases

Note: A consolidated list of chemicals by Chemical Abstract Number [CAS] applies to SARA, CERCLA, and RCRA for Disaster Planning, Recordkeeping, and Local Notification.

Definitions

RQ = Reportable Quantity

Hazardous Substance = OSHA definition of physical or health hazard

EHS = Extremely Hazardous Substance (366 listed)

TPQ = Threshold Planning Quantity - A list by chemical of specific amounts.

The “List of Lists”

[A Consolidated List of Chemicals Subject to Reporting With a Thresholds Rule]

Because so many different lists of chemicals were developed by various government agencies, EPA finally adopted a ‘List of Lists’ rule. The chemicals on the lists changes periodically. The EPCRA Hotline at 1- 800-535-0202 can provide updates. The following is a synopsis of the rule.

The chemicals used that are listed Flammable threshold is 10,000 and their threshold quantity pounds determine applicability. Explosive threshold is 5,000 pounds 77 acutely toxic substances 63 flammable gases, liquids, high explosives

118,000 facilities affected across the us.


I. Overview of Environmental Regulations:

The EPCRA program can be avoided by assuring that no “hazardous chemical” equal to or greater than 10,000 pounds (and that no “extremely hazardous substance” equal to or greater than 500 pounds, or the chemical’s Threshold Planning Quantity, whichever is lower) is kept on hand at any time.

Records are important. Keep good purchase and use records and account for any losses (difference).

Water Quality

Introduction

The Water Quality requirements are designed to ensure proper stewardship of the waters of the state to aid in protecting human health and the environment. Responsibility for regulating industrial process wastewater is shared among a number of state and local agencies. The following sections and Table 6 summarizes regulatory requirements to which furniture and woodworking operations may be subject.

Indirect Discharge of Wastewater to a Sanitary Sewer

Most industrial facilities discharge their wastewater into the local sanitary sewer system where it flows to a Publicly Owned Treatment Works (POW for treatment. The POW may designate the facility a Significant Industrial User (SIU) and require it to obtain a sewer use permit (also called a pretreatment permit). The purpose of the sewer use permit is to regulate the volume and nature of the influent to the POTW such that the POW is able to comply with its permit limits and maintain sludge quality. Generally, POW’S will designate a facility an SIU if the facility meets any of the following conditions:

The facility discharges 25,000 gallons per day or more of industrial wastewater to the sewer,

The discharge constitutes 25% or more of the total allowable flow of the POW,

The facility falls under a categorical pretreatment standard according to federal regulation, or

The POW determines that the industrial discharge jeopardizes its ability to comply with permit limits or sludge (biosolids) quality.

The sewer use pennit will include pollutant-specific limits that the industrial facility must not exceed. Many plants have to pretreat wastewater to some extent before introducing it to the sewer in order to meet the discharge limits imposed by the POW.

Exceeding a discharge limitation in a pretreatment permit may not result in a fine. Instead, the POW may levy a surcharge on the facility to cover the cost of extra treatment that the POTW must invoke to reduce the contaminant levels in wastewater from the facility. Surcharges can be a significant cost to facilities.

In the infrequent case that the POW does not have a state approved pretreatment program, the state Division of Water Quality will regulate the indirect discharge.


I. Overview of Environmental Regulations: Indirect Subsurface Discharge of Wastewater to a Septic Tank

Indirect Subsurface Discharge of Wastewater to a Septic Tank

In some cases it is allowable to discharge industrial process wastewater to an on-site subsurface wastewater treatment system. On-site wastewater disposal is regulated by the county health department through an on-site wastewater disposal permit. The state Division of Environmental Health must approve all industrial subsurface disposal systems, however.

On-Site Wastewater Reuse

Wastewater may be reused on-site as industrial process water (e.g., using glue washwater as make-up water for glue batches), noncontact cooling water, fireprotection, and other non-potable uses. In cases of potential for human contact (e.g., lawn irrigation), a reuse permit may be required from the Division of Water Quality. Any company interested in exploring water reuse opportunities should contact the Division of Water Quality.

Land Application of Wastewater

Depending on the nature of the wastewater stream and the availability of suitable land, it may be possible to apply the wastewater to land. A non-discharge permit is required in this instance from the state Division of Water Quality.

Direct Discharge of Wastewater to a Surface Water Body

If a facility is located in an area not served by a sanitary sewer and if it can demonstrate that it has no other feasible alternative, it may be allowed to discharge its treated wastewater to a surface water body. For direct discharge, a NPDES (National Pollutant Discharge Elimination System) permit is needed. NPDES permits are issued by the state Division of Water Quality. As for sewer use permits described above, NPDES permits specify limitations that the discharge cannot exceed.

Process wastewater can occur at a number of locations in the wood furniture plant. Table 1-6 outlines possible areas of concern to wood products and wood furniture businesses.

Table I-6: Water Quality Areas of Possible Concern to Wood Products and Wood Furniture Businesses


I. Overview of Environmental Regulations: Stormwater Permits


http://h4a.int

I. Overview of Environmental Regulations: Spill Prevention Control and Countermeasures Plan

The Stormwater Pollution Prevention Plan must include the following:

- Site Plan.

- Stormwater Management Plan.

- Spill Prevention and Response Plan.

- Preventive Maintenance/Good Housekeeping Plan.

- Training Schedules.

The Division of Water Quality has developed a guidance manual to help facilities prepare stormwater pollution prevention plans.

Recommendations for Reducing Stormwater Pollution

Spill Prevention Control and Countermeasures Plan

A Spill Prevention Control and Countermeasures (SPCC) Plan is required for oil or hazardous materials storage greater than the following:

- 1,320 gallons total all containers and tanks above ground.

- 660 gallons in any one tank or container above ground.

- 42,000 gallons total all underground storage.

Note: Oil is defined as fuels, lube oil, finishing oils, and any other oil or oily sludge.

The SPCC Plan can remain on-site

Table 1-7: Water Quality Permitting Requirements:


I. Overview of Environmental Regulations: OSHA

OSHA

Introduction

The OSHA program seeks to ensure that all health and safety hazards at businesses are eliminated. The goal is safe and healthful working conditions. This section does not discuss all the OSHA requirements but addresses those primarily related to environmental management. A safe workplace is important to you and your emplovees.

OSHA regulations covering Hazardous Materials Management concern fire protection and physical Safety.

Flammable and combustible liquids pose fire hazards. At least three government agencies have jurisdiction over fire safey issues. The U.S. DOT, EPA, and OSHA have regulations on fire safety for the wood products and wood furniture industry. The National Fire Protection Association (NFPA) has developed standards that most local agencies and fire departments have adopted. Regulations are enforced by the EPA, OSHA, state and local fire marshals, and local fire departments.

The most stringent of OSHA's requirements for handling flammable and combustible liquids concern the Class I flammable liquids, e.g., those with flashpoints at or below 100° F. Chemicals with flashpoints between 100' F and 140' F are Class 11 combustible liquids. Class III covers chemicals with flashpoints above 140' F. Table 1-7 presents a comparison of the EPA, OSHA DOT terminology for flammable liquids.

Table I-8. Flammable Liquids Comparison

I-12 August 1996 Wood Furniture Manual

I Overview of Environmental Regulations: OSHA

The publication, "A Guide to OSHA for Small Businesses in North Carolina," produced by the Division of Occupational Safety and Health, NC Department of Labor, is an excellent resource for small businesses (see Resources Guide).

Wood Furniture Manual I - 13 August 1996

I. Overview of Environmental Regulations: Air Quality

Air Quality

Introduction

Air Quality requirements are designed to protect the outside air we breathe. Inside air requirements related to employee health are regulated by OSHA. The 1990 Clean Air Act Amendments (CAAA) placed more requirements on industry, particularly on small businesses. Many of these requirements focus on reducing or eliminating hazardous air pollutants. Table I-9 indicates the impacts of the CAAA to wood products and wood furniture business and industry.

Table I-9: The Clean Air Act and Wood Products/Wood Furniture Businesses


I. Overview of Environmental Regulations: The Wood Furniture Finishing NESHAP

The Wood Furniture Finishing NESHAP

The new National Emission Standard for Hazardous Air Pollutants (NESHAP) for the wood furniture finishing industry will affect almost every business and industry that manufactures wood furniture. The Maxi" Available Control Technology (MACT) developed through a regulatory negotiation that included EPA, industrial, environmental, regulatory, and pollution prevention representatives contains achievable standards in pounds of volatile hazardous air pollutants (VHAPs) per pound of solids for finishing coatings, cleaning, and contact adhesives (glues). A major part of the NESHAP is a work practice standard that contains specific requirements. The NESHAP also specifies the monitoring, recordkeeping and reporting requirements that facilities in the wood furniture manufacturing industry must meet.

Applicability of the NESHAP

The furniture NESHAP applies to each facility that manufactures wood furniture or wood furniture

Clean Air Act. A major source is one which emits or has the potential to emit 10 or more tons of any individual HAP or 25 or more tons of any combination of HAPS. According to the regulation, wood furniture is any product made of wood or wood products such as rattan, wicker, or particleboard that is manufactured under one of the following Standard Industrial Classification (SIC) codes:

components and is a major source of hazardous air pollutant (HAP) emissions as defined by Title III of the

SIC Description

2434 Wood Kitchen Cabinets

2511

2512 Wood Household Furniture, Upholstered

2517

Wood Household Furniture, Except Upholstered

Wood Television, Radio, Phonograph, and Sewing Machine Cabinets

2519

2521 Wood Office Furniture

Household Furniture, Not Elsewhere Classified

2531

254 1

2599

Public Building and Related Furniture

Wood office and Store Fixtures, Partitions, Shelving, and Lockers

Furniture and Fixtures, Not Elsewhere Classified

5712 Furniture Stores

Wood furniture components are any parts used in the manufacture of wood furniture and include such items as drawer sides, cabinet doors, seat cushions and laminated tops.

The affected source is defined as the entire facility where wood furniture or component manufacturing takes place. Both new and existing sources are covered by the regulation. Sources which began construction or operation after December 6,1994, are classified as new while sources operating on or prior to that date are classified as existing sources. New sources are required to control emissions to a level equal to that achieved by the best performing similar source in its industrial category. Existing sources are subject to an emission limit representing the average level of control of the top 12% of sources in that industry.

Wood Furniture Manual I- 15 August 1996

I. Overview of Environmental Regulations: Exemptions

Exemptions

Because of the nature of the materials and equipment traditionally used in the manufacture of wood furniture, most sources are considered to be major sources of HAP emissions. However, the regulation provides three mechanisms by which furniture facilities can be considered area sources, i.e. sources with potential to emit less than 10/25 tons of HAP per year and not be subject to the emission limits and other requirements of the regulation. These sources are subject only to recordkeeping requirements to verify that they are area sources.

A facility qualifies to be considered an area source if the annual total gallons of finishing materials, adhesives, cleaning solvents, and washoff solvents account for 90% of the total HAP emissions at the

1. The source uses no more than 250 gallons total of coating, gluing, cleaning, and washoff materials per month.

2. The source uses no more than 3000 gallons total of coating, gluing, cleaning, and washoff materials per rolling 12-month period.

facility and either of the following two criteria are met.

A third option for a facility is provided in the NESHAP. This option is available to sources that have 90% of the plant-wide HAP emissions per rolling 12-month period associated with wood furniture or component manufacturing. If such a source uses materials that contain no more than 5 tons of any single HAP per rolling 12-month period or no more than 12.5 tons of any combination of HAP per rolling 12-month period, the source is considered an area source with respect to the NESHAP and does not have to meet the emission limitations that apply to major sources.

In addition to the three mechanisms provided in the regulation, another means for a facility to be considered an area source for purposes of complymg with the NESHAP is to take permit limitations to bring the facility-wide potential HAP emissions below the 10- and 25-ton thresholds. Limits could be placed on hours of operation or other enforceable parameters that can then be used in calculating a facility’s potential to emit. Such restrictions are negotiated between the facility and the permittmg authority. In North Carolina, the air permitting authority has established an exclusionary rule under which facilities can consider their potential emissions to be equivalent to uncontrolled actual emissions. This rule, 15A NCAC 2Q .0803, can be used in North Carolina to determine emissions to compare to the 10/25 tons of HAP per year major source level for determining whether the NESHAP applies.

A facility that is a major source that primarily manufactures products other than wood furniture or components is considered an “incidental wood furniture manufacturer" if the facility uses no more than 100 gallons of finishing material or adhesives per month for manufacture of wood furniture or wood furniture components. Incidental wood furniture manufacturers must keep purchase or usage records that demonstrate usage of less than 100 gallons, but they are not subject to any other NESHAP requirements.

The Standards and Compliance Options

While the affected source is defined as the entire facility, the standard focuses on the surface coating operations within the facility boundary. The affected operations for which there are emission limits are the finishing, gluing, cleaning, and washoff operations. These limits and associated compliance options are summarized in Table 1-10 below.

The NESHAP is designed to offer maximum flexibility to the source by providing several compliance options, thus allowing the source to choose the most effective means to meet the applicable emission limits. The standards limit the allowable volatile HAP content of the coatings and generally are measured in pounds of volatile HAP per pound of solids in the coating.


I. Overview of Environmental Regulations: The Standards and Compliance Options

Table 1-10. Emission Limits Summary

Facilities can meet the standard by using any of the following approaches:

1. Averaging

With the averaging option, a facility calculates the average volatile hazardous air pollutant (VHAP) content for all finishing materials used at the facility using the following equation.

Mc: Mass of solids in finishing material monthly, lb. solids/month

Cc: HAP content of finishing material as applied, lb. VHAP/lb. solids

S: VHAP content of solvent, weight fraction W: Amount of solvent added during month, lbs.

To be in compliance, a value of E no greater than 1.0 must be maintained. Additional discussion on calculating E is in Section IV of this manual.


I Overview of Environmental Regulations: The Combination Option

2. Compliant Coatings

Under the compliant coatings option, facilities must use coatings and thinners that meet the specified VHAP content limits. If coatings are formulated on site, compliant coatings must be used and the thinner used must have a VHAP content of no more than 3 percent by weight.

3. Control Device

The third alternative for meeting the emission limits that apply to finishing operations is to use an air pollution control device to collect and reduce emissions of volatile HAPS. Devices such as thermal incinerators, catalytic incinerators with fixed-bed catalysts, or a fluidized bed or a carbon adsorber might be used. If the control device option is chosen, performance tests must be run on the control equipment using specified EPA methods. To ensure compliance, parameters reflecting the performance of the device must be monitored at a specified frequency.

The Combination Option

The final compliance alternative is the use of any combination of the averaging, compliant coatings, and control device options.

Work practice techniques are discussed in detail in Section III of this manual. The formulation assessment plan is a part of the work practices. It identifies the VHAP of potential concern (see Appendix B) being used and establishes a baseline usage level of each VHAP as the highest usage during 1994, 1995, or 1996. This plan also tracks annual usage of each VHAP of potential concern. If after November of 1998, the annual usage of one of the VHAPs of potential concern exceeds the baseline, the NESHAP requires the owner/operator to provide an explanation to the permitting authority as to the reason the increase occurred. Acceptable reasons for the increase specified in the NESHAP include:

- Exceedance is less than 15% above baseline.

- Usage is below the de minimis in the rule.

- Source is in compliance with state air toxics regulations.

- Source of VHAP is a finishing material with < 1 lb VOC/lb solids as applied.

If the reason for the increase is not one of the acceptable explanations in the NESHAP, the owner/operator meets with the permitting authority to evaluate practical and reasonable technology-based solutions for reducing the usage.

Recordkeeping Requirements

Recordkeeping plays a key role in implementation of this NESHAP. Not only must an owner or operator of a furniture facility keep records to demonstrate that it is in compliance, but owners and operators that are area sources as defined by the rule must maintain records on site in order to verify their status and be treated as area sources. All affected sources must maintain the following records:

- Certified Product Data Sheets (CPDS) for each material.

- VHAP content of each material, as applied, in lb VHAP/lb of solids.

- VOC content of shippable booth coating, as applied, in lb VHAP/lb solids.

- Work Practice Implementation Plan.

Certified product data sheets are documentations similar to material safety data sheets (MSDS) furnished by the coatings supplier or an outside lab for each finish, adhesive, or solvent. The CPDS provides the HAP content by weight as determined by EPA method 3 1 1, the solids content by weight, and the density per EPA method 24 for each coating.


I. Overview of Environmental Regulations: Reporting Requirements

Other records must be kept depending upon the compliance option chosen. Table I-11 summarizes the recordkeeping requirements.

Table I-11. Recordkeeping

Recordkeeping requirements, calculations, and techniques are discussed further in Section II of this manual.

Reporting Requirements

Periodically owners must submit reports to the implementing agency that indicate their compliance status. These reports are listed in Table 1-12 along with the associated deadlines.

Wood Furniture Manual I- 19 August 1996

I. Overview of Environmental Regulations: Compliance Deadlines _______ ~~ ~~~~ -

Table 1-12. Reporting Deadlines

promulgated under Part 63. Reports to be submitted to the “Administrator” should be submitted to the Division of Air Quality. Initial Notifications may be submitted with the facility’s Title V permit application or to the appropriate regional office. Other reports required by the NESHAPs should be submitted to the appropriate DAQ regional office. A map of the state indicating the air quality regions and their corresponding mailing address is included in Section VIII: Resources and Contacts. Sample forms are found in Appendix F.

Compliance Deadlines

Depending upon its status, a facility is allowed 2 to 3 years from the date the NESHAP was published in the Federal Register to come into compliance with the applicable requirements as shown in Table 1-13.

Table I-13, Compliance Schedule


The NC Division of Aior Quality (DAQ) has been delegated authority to implement the NESHAPs

11. Recordkeeping and Reporting Requirements

II. Recordkeeping and Reporting Requirements: Hazardous Waste Recordkeeping and Reporting

11. Recordkeeping and Reporting Requirements

Introduction

Recordkeeping requirements are often confusing and time consuming for businesses. However, the records can be used to document environmental and safety compliance and reduce or eliminate some regulatory requirements. Purchase and use records are essential. Records of reuse, recycled materials, ‘wasted quantities’, and disposed quantities are very helpful. Many requirements are based on amount used or accumulated. In addtion to required recordkeeping for reporting, it is important to maintain records to serve as supporting evidence of exemption or compliance and good faith efforts to maintain a facility’s exempt status or demonstrate compliance. This section summarizes the requirements for each of the environmental areas covered in this workshop. Table II-1 shows the probable impact of requirements on each process area.

Table II-1. Recordkeeping and Reporting Requirements

Hazardous Waste Recordkeeping and Reporting

The RCRA regulations are contained in three main parts of the federal standards

Subtitle C: Hazardous Waste

Subtitle D: Solid Waste

Subtitle I: Underground Storage Tanks (USTs)

Subtitle C regulates hazardous waste management and disposal. Recordkeeping and reporting requirements are shown in Table 11-2.

Subtitle D regulates solid waste management. Solid waste regulations may vary by local or state authority. Prior to shipment, waste characteristics and the disposal site should be determined. Records of the deteminations should be kept. Other records will be specified by the controlling authority, town, city, county or state.

Subtitle I regulates USTs containing oils or hazardous substances. Tanks aboveground with hazardous waste are covered by Subtitle C. A tank is considered underground if 10% of its total volume (tank + piping) is underground. The UST recordkeeping and reporting requirements are summarized in Table II-3.

SARA/Title III/EPCRA recordkeeping and reporting requirements are outlined in Table II-4.

Wood Furniture Manual II-1 August 1996

II. Recordkeeping and Reporting Requirements: UST Recordkeeping and Reporting Requirements

Table II-3. UST Recordkeeping and Reporting Requirements


II.. Recordkeeping and Reporting Requirements: SARA/Title III/EPCRA Recordkeeping and Reporting


II.. Recordkeeping and Reporting Requirements: Water Quality Recordkeeping and Reporting

Water Quality Recordkeeping and Reporting

The Water Quality records and reporting that may affect the wood furniture and wood finishing businesses are a result of wastewater direct discharge, spill prevention plans, and stormwater discharge.

The wastewater NPDES permit contains specific requirements for treatment, control, monitoring records retention, and reporting. All these are site- and wastewater-characteristic dependent.

The required documentation for a direct discharge includes Discharge Monitoring Reports (DMRs) and Best Management Practices (BMP) Plans. Indirect dischargers to a local sewage treatment plant or a POTW

Wood Furniture Manual II - 5 August 1996

II. Recordkeeping and Reporting Requirements: Wastewater Recordkeeping and Reporting

keep records and send reports to the facility. The Water Quality recordkeeping and reporting requirements are listed in Table 11-5.

Spill prevention plans require good engineering and a SPCC Plan to address any fuel or chemical storage Spill prevention requirements are listed in Table 11-6.

Stormwater discharge requires site evaluation, inspections, sampling, and a stormwater pollution prevention plan. The requirements are listed in Table II-7.

Table II-5: Wastewater Recordkeeping and Reporting


II. Recordkeeping and Reporting Requirements: Stormwater Reports and Recordkeeping

Table II-6: Spill Prevention Control and Countermeasures (SPCC)

Table II-7: Stormwater Reports and Recordkeeping


II. Recordkeeping and Reporting Requirements: Air Quality Recordkeeping and Reporting

OSHA Recordkeeping and Reporting

Specific OSHA recordkeeping and reporting requirements are not extensive, but evidence of compliance with OSHA standards often means documenting employee training and self-inspections or reviews.

OSHA does require Log No. 200 for occupational injuries and illnesses and Log No. 100 for other injuries and illnesses. Also training and audit records are to be kept on site for review during any OSHA inspection.

DOT Recordkeeping and Reporting

The Department of Transportation (DOT) regulates transport and handling of hazardous materials and hazardous waste. The Unintentional Releases and Discharge Report is required within 30 days of discovery for any release event during transport. In addition, Drivers Duty Records and Qualification Files must be maintained.

Air Quality Recordkeeping and Reporting

The North Carolina Air Quality Section has developed preliminary guidance for recordkeeping and reporting to track air emissions. These guidelines may not be applicable where regulations or procedures specify requirements. However, absent any specificity, they should be used unless there is a strong reason to change them.

Table II-8: Air Quality General Guidelines for Recordkeeping and Reporting


II. Recordkeeping and Reporting Requirements: Air Quality Recordkeeping and Reporting

Table II-9. Air Quality Recordkeeping and Reporting Requirements


II. Recordkeeping and Reporting Requirements: Wood Furniture NESHAP Recordkeeping and Reporting

Recordkeeping and Reporting for the Wood Furniture NESHAP - MACT

Introduction

The new NESHAP Standard requires records and reporting for many businesses. The complexity varies from annual records to twice-per-year HAP reporting. In general the recordkeeping consists of the following:

1. A list of each chemical material with VHAPs subject to the standard.

2. The VOC, VHAP, and solids content of each material.

3. A Work Practice Implementation Plan maintained on site.

4. Records of all calculations.

5. Record of semi-annual Continuous Compliance Reports.

6. Maintenance of all records for 5 years.

The reports required after initial notification depend on the source category: exempt, area, small major, or large. The required reports are listed below in bold type and suggested reporting forms are provided in Appendix F.

Exempt Businesses Recordkeeping and Reporting

If a facility is exempt from the standard and uses less than the 250 gallons per month and/or 3,000 gallons a year, an Initial Notification Form is not required. It is important to keep records for 5 years to prove this exemption to inspectors. A suggested form for recording use of materials is provided in Appendix F. The date to begin to keep the validating 12-month records is December 17, 1998.

Area Sources (<10/25 TPY of VHAP/VHAPs but not Exempt) Recordkeeping and Reporting

An Initial Notification Form is required, and records should be kept for 5 years. Facilities should check with the Regional office periodically after initial notification to learn if anything more is needed.

Small Major Sources (<50 TPY of VHAPs) Recordkeeping and Reporting

Initial Notification Form and semi-annual Continuous Compliance Report (twice per year) reporting is required but has been delayed for one year beyond the requirements for medium and large Major Sources. The Initial Compliance date is December 1, 1998, and the Initial Compliance Report is due by February 1, 1999. Also, a Work Practice Implementation Plan must be prepared and maintained by February 5,1999. Semi-annual reporting using the Continuous Compliance Report starts July 30, 1999, and reports are due for every succeeding 6 months within 30 days after the end of the period The work practice plan requires that a baseline record for ten specific VHAPs of potential concern (VHAP-


II. Recordkeeping and Reporting Requirements: Wood Furniture NESHAP Recordkeeping and Reporting

PC) for 1994, 1995, and 1996 be established. After November 1998, facilities are required to report the times they remained below or exceeded the baseline. Records are required to be kept for 5 years.

Large Major Sources (50 TPY or greater of VHAPs) Recordkeeping and Reporting

Initial Notification Form and semi-annual Continuous Compliance Report (twice per year) reporting is required. The Compliance date is November 27,1997, and the Initial Compliance Report is due by January 20, 1998. Also, a Work Practice Implementation Plan must be prepared and maintained by January 20,1998. Semi-annual reporting using the Continuous Compliance Report starts June 30, 1998, and reports are due for every succeeding 6-months within 30 days after the end of the period. The work practice plan requires that a baseline record for ten specific VHAPs of potential concem (VHAP- PC) for 1994, 1995, and 1996 be established. After November 1998, facilities are required to report the times they remained below or exceeded the baseline. Records are required to be kept for 5 years.

Source Growing Into a New Major Source (>10/25 TPY of VHAPs) Recordkeeping and Reporting

Initial Notification Form and semi-annual Continuous Compliance Report (twice per year) reporting is required. The Compliance date is one year after becoming a Major Source. The Initial Compliance Report is due 60 days after the compliance date, and a Work Practice Implementation Plan must be prepared and maintained by that date. Semi-annual reporting using the Continuous Compliance Report starts 7 months after the compliance date, and reports are due for every succeeding 6-months within 30 days after the end of the period. Records are required to be kept for 5 years.

Table II-10. Recordkeeping Requirements for the New NESHAP - MACT


II. Recordkeeping and Reporting Requirements: Calculating Emissions

Table Ell: Reporting Requirements for the New NESHAP-MACT

Calculating Emissions

The complexity of requirements often makes businesses uncertain if an air permit is needed and if there are other requirements. This section will help determine the air requirements that may affect a wood products or wood furniture business. Certain basic information is required to determine whether an air permit is needed or whether an operation may be subject to environmental requirements:

Regulations: Those that are applicable and particularly those that help.

Insignificant activities that are not regulated.

Uses and Emissions: A specific inventory.

Calculation of Emissions: Emission factors and material balances.

Actual Potential Emissions: for coatings actual equals potential.

Exemptions: By Type (Category) and Size (Production).

Thresholds: Major Title V, Synthetic Minor, and Small.


II. Recordkeeping and Reporting Requirements: Specific Regulations Exempting Small Emitters

Some Key Regulations

Boilers: Wood Fired, Gas-Fired, and Oil-Fired Boilers. Emissions allowed are expressed in pounds per million Btu.

Woodworking (sawing, planing, sanding, etc): Requires “Adequate Control” (change expected).

Painting Stripping, Coating Operations: Specific limits are in the MACT , and

Miscellaneous VOCs - Photochemically Reactive Solvents: 40 pounds per day or 85% control

Visible Emissions: 40% for equipment manufactured before July 1, 1971, and 20% for equipment manufactured after July 1, 1971.

Title V Applicability: Thresholds

Criteria Pollutants - 100 TPY Each HAP - 10 TPY Combined HAPS - 25 TPY

Potential = Actual Rule (800 Rule)

Insignificant Activities: Categories deemed insignificant: - Maintenance on buildings or equipment - Periodic upkeep includes painting, cleaning, and repair. - Housekeeping activities - Washing, resurfacing floors, roof repair, janitorial activities. - Use of office supplies, copying machines or blue printing equipment and chemicals. - Fire fighting equipment and chemicals. - Air conditioning, refrigeration, ventilation, comfort heaters. - Fuel oil or gas storage tanks and tanks with inorganic liquids. - Water and wastewater treatment processes. - Vehicle used on site with internal combustion engines: fork lifts, trucks, etc. - Lab equipment and lab operations that are non-production. - Replacement equipment - Like for like. - Exempt Operations - Category and Size Exemptions.

Specific Regulations Exempting Small Emitters

For the wood finishing industry in North Carolina, a special provision is in the regulations. This exemption applies to paint spray booths or other painting or coating operations. It states that any spray booth without air pollution control devices (water wash and other filters that are an integral part of the paint spray booth are not considered air pollution control devices) located at a business with site-wide actual emissions of

(1) VOCs <5 tons per year (2) Photochemically reactive VOCs <40 pounds per day

does not need a permit if the facility does not need an air permit for any other reason.

Another exemption (i.e., does not need a permit) covers any source without an air pollution control device with potential of no more than 5 tons per year of each regulated pollutant, hazardous air pollutants below the applicable de minimus rate, and whose emissions would not violate any applicable standard.

An ‘Exclusionary Rule’ allows all ‘coating operations’ to base calculation of emissions on materials use and also provides that potential emissions are equal to actual emissions based on use records. Therefore, note that when ‘potential’ is encountered, substitute ‘actual’ and use records. The only drawback to this rule is that it requires an annual accounting and reporting to the state.


II. Recordkeeping and Reporting Requirements: Emissions Inventory

Any facility without an air pollution control device whose actual emissions of criteria pollutants are each less than

5 tons per year is exempt from an Air Quality Permit.

Emissions Inventory

Use records can be used to determine emissions, that is, to make an emission inventory. An emission inventory is critical for determining air requirements. The process is made easier with a process flow diagram that tracks materials use and product movement through the manufacturing processes. (See example on the next page.) A process flow diagram requires the following steps:

1. Identify and label or number the emission sources (origin) and emission points (stack, vent, fugtive, etc.).

2. Find the input amounts of raw materials and the output products - including any waste by-products - and emissions for each source and point of emissions.

3. List all raw materials and the amount used of each. 4. List all products and associate products with raw materials. 5. Find emission factors or decide on a material balance method to calculate emissions. 6. Calculate pollutants [TSP (100) and HAP, combined HAPS, and total VOCs] for each source. 7. Summarize or total each HAP, all combined HAPS, total VOCs, and each criteria pollutant for the

entire site.


II. Recordkeeping and Reporting Requirements: Determine the Exemptions

Figure II-1. Flow Diagram (Simple example of a facility)

Determine the Exemptions

It is critical to know the size and capacity of boilers, tanks, and emergency generators. There are exemptions for the smaller ones. Some sources are exempt because of their small size.

Examples of Exempt Sources

Boilers: Existing gas <10 million Btu per hour and oil <10 million Btu per hour

Storage tanks: Aboveground < 1100 gal; Underground < 2500 gal With true Vapor Pressure, no more than 10.8 psi at 70° F

Emergency generators: < 310 kW or 460 hp natural gas-fired < 830 kW or 1150 hp LP gas-fired < 270 kW or 410 hp diesel-fired

See Appendlx C: Determining Air Emissions and Requirements

Key Point: For coating, printing, solvent cleaning, and printing operations, the actual emissions = the potential emissions.

II- 15 August 1996 Wood Furniture Manual

1

III. Work Practices

III. Work Practices: Recordkeeping and Reporting

III. Work Practices Introduction

The wood furniture NESHAP contains many pollution prevention provisions including the work practice standards that require more efficient application technologies as well as training of operators and adoption of good housekeeping and maintenance practices. The work practice standard within the wood furniture MACT specifically addresses fishing operations, cleaning and washoff, and operator training. The standards require a written inspection and maintenance plan and an implementation plan. General housekeeping practices such as covering solvent containers when not in use to limit evaporative losses are also included in the regulation. As the work practice standards severely limit the use of conventional air spray guns, they thus encourage the use of more efficient coating transfer technologies such as high- volume, low-pressure (HVLP) and air assisted airless (AAA) spray guns.

An essential part of the work practice standards is the provision for operator training. The work practice standards also restrict the solvents used for washoff and require the use of a log book to track the amount of solvent used for washoff. Many companies have already instituted work practice standards into their operations to improve quality and reduce the amount of waste and rework required. The work practice standards are a key component of the overall strategy for reducing emissions of the various VHAPs used in the manufacture of wood furniture. Table III-1 summarizes many of the work practice standard requirements.

Recordkeeping and Reporting

Proper maintenance of records is an important aspect for those facilities regulated under the NESHAP. All facilities will be required to maintain records to demonstrate compliance with the work practice standards. Table III-2 shows an example list of the recordkeeping requirements necessary for compliance with the work practice standards. Each regulated facility must submit an initial compliance report no later than 60 days following the compliance date. Following submittal of the initial report, a semi-annual compliance report must be submitted no later than 30 days after the end of the first 6-month period following the compliance date and no later than 30 days after the end of each subsequent 6-month period.

Wood Furniture Manual III-1 August 1996

III. Work Practices: Work Practice Requirements

Table III-1: Work Practice Requirements

Wood Furniture Manual III-2 August 1996

III. Work Practices: Work Practice Recordkeeping Requirements

Table III-2: Work Practice Recordkeeping Requirements

III-3 August 1996 Wood Furniture Manual

IV. Compliance Options

IV. Compliance Options: Reformulation: Compliant Coatings

IV. Compliance Options Options include use of reformulated compliant coatings, averaging (allowed across all finishes only), use of control or incineration equipment, and implementation of reductions through work practices. Not all coatings can be reformulated [made high solids or with reduced VHAPs, for example]. Work needs to begin now to learn the options that are feasible or best for specific operations; the time for decisions will be coming soon. A combination of options may be the best choice.

Reformulation: Compliant Coatings

Introduction

Use of reformulation may be an option for some companies, especially for those in ‘attainment areas.’. Most companies in attainment areas will not be subject to new VOC regulations and, therefore, will have more flexibility to reformulate with solvents with VOCs that are not listed as HAPs. At present, although all parts of North Carolina are in attainment status, this could change if ambient violations are measured; it is wise, therefore, to stay alert to any change. The advantages and disadvantages of reformulation should be weighed very carefully when a compliance strategy is chosen.

Advantages

Reformulation often involves lower up-front cost compared to control equipment.

In most cases, reformulation does not require significant operational changes.

Reformulation may reduce emissions that must be reported under EPCRA.

Reformulation may allow a company to avoid HAP regulations by reducing HAP emissions below the threshold levels.

Disadvantages Coatings costs may increase.

Product performance may be compromised.

Reformulation may not provide a long-term solution if additional solvents are added to the HAP list.

Information about safe handling and use of alternative substances may be less extensive.

In particular, reformulation may be difficult or impossible in certain applications. Companies that must comply with both HAP and VOC regulations will need to reformulate to reduce emissions of the solvents on the HAPs list and total solvents used/emitted. This reformulation can be achieved in some cases by a switch to a higher solids content, but that change may lead to unacceptable coating performance. Also, because some of the most commonly used HAPs solvents are very efficient solvents, reformulations to reduce the HAPs may actually increase the VOC emissions.

Compliant Coatings

The NESHAP provides a list of emission limits for compliant finishing, cleaning, and gluing materials used in the manufacture of wood products. The emission limits are stated as a maximum ratio of lb of VHAP per lb of solids as applied. New sources that have commenced construction on or after December 6, 1994, must meet more stringent emission limits than existing sources. The NESHAP limits the volatile HAP content of all finishing materials including: stains, washcoats, sealers, topcoats, basecoats, enamels, and

Wood Furniture Manual IV-1 August 1996

IV. Compliance Options: Water-Based Coatings

thinners. Each facility is required to maintain the certified product data sheets for each coating listed in the NESHAP and any thinners that are used.

The NESHAP allows manufacturers to use averaging of coating emissions from the various finishing materials to meet the standard. The VHAP contents of all finishing materials used over a monthly period should be no greater than 1.0 lb VHAP/lb solids and 0.8 lb VHAP/lb solids for existing and new facilities, respectively. As these limits are applicable to the coatings as applied, the VHAP contribution of the thinners must be taken into account. These new requirements and the compliance schedule associated with the NESHAP have resulted in significant activity by coatings suppliers to formulate, test, and evaluate coating systems which meet these new stringent requirements. Several companies began developing low VHAP water-based coating systems following the adoption of South Coast Air Quality Management District (SCAQMD) Rules 1104 and 1136, which required reductions of VOC emissions from wood products manufacturing operations. Three main types of compliant coatings might be used by the wood furniture industries to meet the standard: water-based, high solids and Ultraviolet Light (UV) curable coatings.

Water-Based Coatings

Water-based coatings are typically higher in solids content than the traditional nitrocellulose-based coatings but differ in that a part of the base is water. Some plants may use a complete water-based finishing system while others may use water-based coatings for only a portion of their finishing operations.

There are three types of water-based polymer systems:

1. Emulsions or Aqueous Dispersions, which consist of particles of a high-molecular-weight resin

2. Colloidal Dispersions, which consist of very fine particles of resin partially soluble suspended in

3. Water Reducible Resins, which are a resin soluble in water or a blend of a water miscible solvent.

Emulsion coatings do not penetrate porous substrates such as wood very well and are typically used as house paints.

Table IV-1: Advantages and Disadvantages of Water-Based Coatings

uniformly dispersed in water,

water, and

IV-2 August 1996 Wood Furniture Manual

lV. Compliance Options: High-Solids Coatings

High-Solids Coatings

Although no standard definition exists, high-solids coatings typically refer to coatings with above 80% solids content by weight, while higher solids coatings are those that contain solids content of greater than the typical 30 to 40% in traditional coatings.

To reach a high-solids content, most suppliers use low-molecular-weight resins to obtain satisfactory properties because a direct increase in solids with standard high-molecular-weight solvent would result in an unacceptable increase in viscosity.

Often the lower molecular weight resins give an unacceptable dry film under normal curing times; therefore, additives are used to enhance crosslinking of the resins during curing.

Table IV-2: Advantages and Disadvantages of High Solid Coatings

Advantages

Ultraviolet Light (UV) Cured Coatings

UV curing requires high-intensity light to initiate free radical crosslinking reactions or cationic polymerization reactions in a fast, relatively cool process.

UV-cured coatings have very low VHAP content and a solids content of 85 to 100%.

A mercury-electrode arc lamp, which is the most commonly used UV source, can be easily installed in most existing production lines.


IV. Compliance Options: Compliant Coatings Recordkeeping and Reporting Requirements

Table IV-3: Advantages and Disadvantages of W Coatings

Compliant Coatings Recordkeeping and Reporting Requirements

An important requirement for those facilities that decide to use the compliant coatings approach is proper maintenance of records. All facilities will be required to maintain records to demonstrate compliance with the compliant coating emission standards. Table IV-4 is an example list of the recordkeeping requirements necessary for the compliant coatings approach and work practice standards. Each regulated facility must submit an initial compliance report no later than 60 days following the compliance date. Following submittal of the initial report, a semi-annual compliance report must be submitted no later than 30 days after the end of the first 6-month period following the compliance date and no later than 30 days after the end of each subsequent 6-month period.

Table IV-4. Compliant Coatings Recordkeeping Requirements


IV. Compliance Options: Averaging

References

1. Environmental Protection Agency. “Guide to Clean Technology: Organic Coating Replacements.”

2, American Furniture Manufacturers Association, et al. “A Complete Guide to the

3. Akzo Coatings, Inc. “Useful Facts and Figures.” 4th Edition.

4. North Carolina Small Business Ombudsman’s Office. “Final MACT (NESHAP)

5. North Carolina Office of Waste Reduction. “Overview of Coating Technologies.” June 1993.

Averaging

Averaging is a viable option to consider. The flexibility of a monthly average, allowed by the NESHAP, is significant. A weighted average of all pound of VHAP per pound of solid as applied. New operations must meet a 0.8 pound of VHAP per pound of solid weighted monthly average.

The equation for both existing and new operations is as follows:

EPA/625/r-94/006. September 1994.

CTG and NESHAP.” 1995. Wood Furniture

for the Wood Furniture Finishing Industry.”

finishing coatings used each month must meet a standard of 1.0

Demonstrating Compliance

The use and percent by weight data comes from purchase records and product data sheets or Material Safety Data Sheets. In place of working through the formula given above, a table will be used. Certified data product sheets for each finishing material and all thinners used should be kept. Records of the following should be kept: the amount and the percent solids and VHAPS of each finishing material and thinning material in pounds used each month. The following is an example of a company using the averaging approach to comply with the standard.

Example 1: The Averaging Approach is selected by an example existing company that has changed to higher solids coatings for sealers and topcoats but needs to keep high-solvent stains to achieve the desired finish.

Wood Furniture Manual IV - 5 August 1996

IV. Compliance Options: Add - On Control Equipment

Table IV-5: Data and Calculation Table

Using the materials use and weight percent information, we could have used the formula after calculating the individual Es for each coating. These are shown in the last row.

E = (40.2) (2) + (523.6) (0.44) + (109) (0.37) + (0.18) (1386) /(40.2 + 523.6 + 109 ) = ( 80.4 + 230.4 + 40.3 + 249.5 ) / (672.8) = 600.61672.8 = 0.89

This company is in compliance because E = < 1.8. If this were a new company it would not be in compliance with the E < 0.8 standard.

Keep copies of information and calculations, as well as the certified product data sheets and record of use of materials for 5 years.

Add - On Control Equipment

Add-on control equipment may be a good option for large, automated finishing systems. Incineration, carbon absorption or scrubbing of high-volume, low-concentration air streams is feasible but not very cost effective. High up-front cost is usually the deciding factor.

The EPA regulations prescribe procedures to determine compliance when the above known control devices are used. Capture efficiency of VHAPS is the result of control efficiency. The calculations are complicated and will not be covered in this manual. Facilities planning to use an add-on control device should contact the appropriate Regional Office (see Resources at the end of this manual) or EPA. The regulations allow any other control device as long as it demonstrates control efficiency greater or equal to those above.


V. Application Techniques for Spray Operators

V. Application Techniques for Spray Operators: Equipment Setup and Adjustment

V. Application Techniques for Spray Operators In typical spray coating operations, three factors are paramount: production, quality, and cost. One activity that has a positive effect on these factors is proper operation and maintenance of spray equipment. As shown in Table V-1, good operating practices also play a critical role in the efficient use of coating materials by reducing air emissions and solid and hazardous waste generation.

Table V-1. Production and Environmental Impacts of Poor Spray Techniques

The following sections overview tips for good operation and maintenance of spray equipment.

Equipment Setup and Adjustment

Good operation begins with proper equipment setup and adjustment. Four factors to consider in setting up equipment are the viscosity of the coating material, air and fluid pressure, the shape and size of the spray pattern, and the proper positioning of the workpiece.

Viscosity. Generally, less viscous coating materials are easier to atomize and can be atomized at lower pressures. Two ways to control viscosity are by dilution with a solvent and heating. Heating the coating material to the desired viscosity instead of diluting it with solvent can give not only comparable atomization but also lower potential for VOC emissions.

Air and fluid Pressure. To minimize overspray, blowback or bounce back, and worker exposure, fluid pressure should be no higher than necessary to provide good atomization. A slower particle speed reduces the impact of the particle onto the part surface and increases the opportunity for even coating distribution and a smooth finish.

Spay Pattern. The spray pattern should be optimized to the workpiece size, shape, and orientation. Slender pieces should be coated with a narrow pattern while a larger pattern can be used for wider pieces.

Workpiece Positioning.

- The piece to be finished should be positioned such that spraying is as comfortable as possible for the operator. If the operator must strain or reach to spray the part, spray technique and quality are likely to suffer. The operator also needs to be able to see the piece well in order to aim the spray gun appropriately; thus, a clear line of sight and proper lighting of the work area is essential.

- Workpieces should be mounted such that they can be rotated and tilted. The operator should not need to move around the piece and, thus, inadvertently tangle hoses that can then damage the finish of the workpiece.

Wood Furniture Manual V-1 August 1996

V. Application Techniques for Spray Operators: Operator Spray Techniques

- Where possible, pieces should be positioned close together so that overspray from one piece will fall onto another.

Operator Spray Techniques

A very small investment in spray operator training can pay huge dividends in reducing the time and profit lost in product rework, spray booth cleanup, and excess coating usage. Operators that are well trained on proper spray techniques can also help assure good finish quality and efficient use of material. Operators should be trained to use proper gun position, arm motion, triggering, and overlap techniques.

Gun Position

- The recommended distance from the Spray gun to the workpiece depends on the type of spray

Table V-2: Recommended Distance to Part for Various Gun Types

gun to be used. Table 2 lists recomended distance for several general gun types. A dry dry spray, uneven coverage, and decreased transfer efficiency may result if the gun is held too far from the workpiece, while runs and sags may occur if the gun is held too closely to the piece.

- To minimize uneven paint coverage, the operator should hold the gun as perpendicular to the workpiece as possible.

Arm motion.

- To help ensure that the gun is perpendicular to the workpiece, the operator should move the gun in a sweeping arm motion rather than pivot the wrist, which causes the gun to tilt. If the gun is tilted, the coating will be applied unevenly. A gun held at a 45 degree angle can result in a spray loss of approximately 65 percent.

- For long pieces, the operator should make strokes of 18 to 36 inches in order to maintain the gun in a nearly perpendicular position

Triggering the Gun Proper triggering reduces material usage and finish defects. The gun should be triggered with each stroke. The stroke should be started before the trigger is pulled, and the trigger should be released before the end of the stroke. This method produces a fathering effect for more even coverage, conserves paint, and reduces material buildup at the beginning and end of each stroke. Proper triggering can save an estimated l cm3 of paint per stroke, which amounts to about 52 gallons per month and $6,000 per year (at $10 per gallon). This saving assumes six strokes per part and two parts per minute, 420 minutes per shift (Source: DeVilbiss Literature).

Overlap. Strokes should overlap by 50 percent. A good rule of thumb to obtain 50 percent overlap is to aim the gun at the edge of the last stroke.

Wood Furniture Manual V-2 August 1996

V. Application Techniques for Spray Operators: Special Techniques for Specific Workpiece Configurations

Special Techniques for Specific Workpiece Configurations

Some workpiece configurations require specific spray techniques. The following sections outline techniques for coating flat panels, edges, inside and outside comers, and slender and round parts. If possible, the operator should spray the more difficult locations first, e.g., comers, edges.

Flat Panels. To reduce overspray on a flat panel, the operator should use a banding technique. In banding, the operator applies a vertical stroke on each end of the panel and completes the remainder of the piece with horizontal strokes. This method reduces paint usage and overspray.

Edges and Outside Corners.

- A banding technique should also be used on the edges of workpieces such as tables. If the operator aims the spray gun at the leading comer of the part, both the edge and the surface are banded.

Similarly, outside comers of pieces such as boxes should be sprayed straight on to band the adjoining surfaces.

Inside Comers. If space allows, inside comers should be sprayed as if the workpiece is two separate flat panels. This technique involves vertical banding for both sides of the comer. If the comer is sprayed straight on, thicker coatings will be applied on the edges of the pattern than in the comer itself.

Slender and Narrow Round Parts.

-

-

Slender pieces should be coated with a narrow horizontal pattern or a vertical pattern. For a vertical pattern, the gun speed should be increased to account for the additional time that a particular portion of the part is in the pattern. Gun motion should always be lengthwise to the part.

- A narrow horizontal spray pattern and three or more strokes should be used for round pieces. If a slender piece such as a table leg is part of a larger object and it is not feasible to adjust the pattern size, it may be possible to partially trigger some spray guns to reduce the pattern size. The operator should be careful in applying this technique as incomplete atomization may result.

Large Round Parts. Round objects of large diameter should be sprayed as for a flat surface but with shorter strokes.

Planning for Efficient Spray Operations It is usually helpful for spray operators to rehearse techniques and strokes before beginning work on a new piece. Planning will enable the operator to use fewer strokes, which will reduce paint use/overspray and fatigue and produce a higher quality finish.

Many companies find it effective for a finishing supervisor or team to study each piece before it is sent to the production line to determine the most efficient spraying procedure. Each operator is then trained to use the preferred technique. This approach also continuously reminds the operator of proper techniques.

It is important that if an operator discovers a way to improve the technique, it should be shared with the supervisor or team to help others.

Troubleshooting for Wood Furniture Spraying Operations

The problems commonly seen at the repair station are usually the result of improper adjustment of equipment or dirt contamination of the workpiece or spray application equipment. Several examples of

Wood Furniture Manual V - 3 August 1996

V. Application Techniques for Spray Operators: Troubleshooting for Wood Furniture Spraying Operations

common surface finish and application problems are listed below as well as the possible causes and prevention suggestions to minimize profit losses due to rework and repairs.

Table V-3. Surface Finish Problems

V-4 August 1996 Wood Furniture Manual

V. Application Techniques for Spray Operators: Troubleshooting for Wood Furniture Spraying Operations


V. Application Techniques for Spray Operators: Spray Gun Maintenance Tips

Spray Gun Maintenance Tips

As the troubleshooting tips show, a majority of the spray application and surface finish problems result from contamination in the fluid or air nozzles in the spray gun. Therefore, it is economically beneficial to maintain spray application equipment properly in order to minimize the amount of washoff and refinishing. Spray gun manufacturers recommend simple daily maintenance as well as a periodic overhaul. The maintenance tips below focus on the daily gun service recommended to produce consistent quality results in spray applications.

Recommended Spray Gun Maintenance

1. Remove air node and tip and soak these parts in thinner to clean out any contamination. Do not soak the spray gun completely in thinner as such immersion tends to cause residual paint or lacquer particles to migrate to the fluid and air orifices and clog nodes or transfer the dirt to the part. Also, by removing all the necessary lubricant and dry out the packing, the solvent will cause the gun to “spit and leak.”

2. Clean air and fluid nozzles as required with a hair bristle brush which has been dipped in thinner. Do not use metal pins or wires to clean out nozzle orifices. Reaming out the small holes in the tip with any hard object (wire, nail, etc.) could permanently damage the tip by enlarging the orifices and adversely affecting the spray pattern.


V. Application Techniques for Spray Operators: Repair and Refinishing

3. After cleaning is completed and the nozzles are reinstalled in the gun, the next step is proper lubrication. The needle valve just ahead of the trigger should be coated with just a drop of lightweight oil. Also, the trigger screw and air valve stems just behind the gun trigger should be lubricated.

4. Periodically, all internal screw threads and springs should be lubricated with a light grease or petroleum jelly. The side port control and fluid control screws should be coated as well as the fluid needle spring. Silicone-based lubricants should be avoided as they tend to cause “fisheyes” once transferred to the workpiece.

Repair and Refinishing

The work practice standards of the wood furniture MACT require operator training as well as the adoption of good maintenance practices. The work practice standards also restrict the solvents used for washoff and require the use of a log to track the amount of solvent used for washoff. Many companies have already instituted work practice standards into their operations to improve quality and reduce the amount of wastes and rework required. The worksheet shown in Table V-5 is the Repair Worksheet currently used by a wood furniture manufacturer in North Carolina. The worksheet allows a shop to track the amount of rework and the causes of refinishing. This worksheet can be used as a tool for companies to identify the processes that may need to be examined or modified in order to limit material and profit losses that result from scrapping or rework of parts.

Table V-5. Repair Worksheet


V. Application Techniques for Spray Operators: Repair and Refinishing

Summary

The techniques presented in this section show that improved operation and maintenance of spray equipment can reduce raw material usage, air emissions, and hazardous waste generation. A conservative estimate of the savings in a finishing operation through improved operating techniques would be 10 percent or more of coating material purchases. Good managers cannot overlook savings of this magnitude, especially when they consider that proper techniques also improve product quality and reduce environmental concerns.

References

1. “Airless Spray Techniques.” Graco, Inc. (FMP 568) 2. “Improving the Bottom Line With OMXTM.” ITW DeVilbiss. 3. “Operator Techniques.” Binks Manufacturing Company. 4. “The Efficient Utilization of Material in the Finishing Room.” DeVilbiss. (F 4) 5. “Air Spray Basics.” Graco, Inc. 6. Akzo Coatings, Inc. “Useful Facts and Figures.” 4th Edition. 7. Binks Manufacturing Company. “Air Operated Spray Equipment.” Binks Training Division.

8. DeVilbiss Ransburg. "Wood Furniture Finishing Equipment Guide”. August 1993. 9. Hund, J. “HOW to Maintain a Spray Gun.” Wood and Wood Products. November 1995.

January 1990.

10. Mattson, Ross. “Conventional Air-Atomized and HVLP Guns: Tips,.” Presented at Paintcon ‘93: Finish World Class. 1993. (FMP 1215)

V-8 August 1996 Wood Furniture Manual

V. Application Techniques for Sprag Operators: Summary

11. Muir, Glen. “Airless and Air-Assisted Guns: Tips,” Presented at Paintcon ‘93: Finish World

12. North Carolina Pollution Prevention Pays Program. Accomplishments of North Carolina

13. Roobol, N. “Industrial Painting: Principles and Practices.” Hitchcock Publishing Co. 1991.

Class. 1993. (FMP 1213)

Industries: Case Summaries. January 1987.


VI. Solid Waste Management

VI. Solid Waste Management: Economic Aspects of Waste Reduction

VI. Solid Waste Management Introduction

Solid waste management is an issue for every manufacturer in the United States, but few may be aware of the changes in the solid waste management landscape and the ways these changes will affect their operations and costs. When Subtitle D of the Resource Conservation and Recovery Act was finalized in 1992, it made the practice of landfilling more environmentally protective - and more expensive. As part of implementing Subtitle D, North Carolina will require any solid waste landfill in operation on or after January 1,1998, to be lined with an impermeable synthetic membrane. The cost of constructing these “high tech” landfills is driving many local governments out of the landfill business. Instead, they are opting to operate transfer stations to aggregate solid wastes for shipment to larger regional waste management facilities that have taken advantage of economy of scale to construct lined landfills. Most solid waste generators will feel the impact of this transition through higher tipping fees.

Source reduction and recycling practices can help manufacturers avoid these increasing costs by helping to minimize the quantity of solid waste destined for disposal. This section outlines some specific source reduction ideas for furniture operations and discusses ways to set up programs to recycle waste materials common to the furniture industry.

Economic Aspects of Waste Reduction

Waste reduction is clearly beneficial to the environment, but it can also improve a company’s bottom line. The economic benefits of waste reduction are sometimes obscured by the up-front costs of implementing a program. However, if a company considers the costs avoided through waste reduction (e.g., reduced tipping fees and hauling charges), the impact on the bottom line is more favorable.

Source Reduction

Product Transportation. A large percentage of waste from furniture operations results from transport of materials or work-in-progress from plant to plant or station to station. One option for reducing waste from such operations is to work with suppliers and sister plants to select packaging materials and containers that can either be reused to package the finished product or used multiple times in the transport operation. Example strategies include:

Heavy duty corrugated containers or Bigelows in place of pallets and stretch wrap for interplant transport of goods.

Durable plastic bags sized for reuse as packagmg for a final product.

Collecting and reusing comer protection blocks.

Many companies use foam sheets to protect items during transport, but because foam tends to retain sawdust, it is less desirable for reuse. An alternative may be paper or smooth plastic that can be reused or shipped with the product.

Material Receiving. Companies often fail to recognize their power as customers to influence their suppliers. Many companies now require raw material suppliers to take back empty containers or to supply reusable ones. Companies should similarly specify that suppliers either take back pallets or provide pallets that can be used for product shipment or recycled, as discussed below.

Raw material quality testing is also a valuable waste reduction tool. A small investment in physical and rudimentary chemical testing for substrates, adhesives, and finishing material can pay huge dividends. Such tests can help avoid lost time, materials, and energy and waste generation from processing off-spec materials.

Wood Furniture Manual VI - 1 August 1996

VL Solid Waste Management: Recycling

Recycling

Successful recycling requires coordination of three steps: collection, processing, and marketing. Marketing provides the foundation for the program and should be addressed first. Recycling markets help transform wastes into commodities that can be used to make a new product. Thus, just as furniture manufacturers need quality material with which to make furniture, recycling markets want clean, predictable supplies of material that meet their specifications.

Various directories - including the yellow pages - and local and state waste reduction offices can help identify markets for recyclable materials. The North Carolina Division of Pollution Prevention and Environmental Assistance (DPPEA) publishes a Directory of Markets for Recyclable Materials that thousands of companies and communities have used to identify outlets for materials. Once markets or recycling services are secure and once any necessary processing steps are identified and put in place, collection can begin. Table VI-1 outlines basic recycling considerations for common discards.

Successful recycling programs depend on employee involvement. In-plant recycling collection systems that blend with the existing flow of work and materials help maximize involvement. Education and promotion are important and can be facilitated by employee work teams and simple award systems.

Table VI-1: Opportunities for Solid Waste Recycling

Wood Furniture Manual VI - 2 August 1996

VL Solid Waste Management: Facilitating Customer Recycling

Facilitating Customer Recycling

Much of the solid waste associated with furniture operations is passed along to customers in the form of packagmg. In cases where the manufacturer distributes the product to retailers or customers, boxes and other packing material can be returned on the empty truck to be recycled or reused. Similarly, retailers can handle packagmg from customer deliveries and take advantage of the strong market conditions for plastics and corrugated cardboard. Many manufacturers facilitate customer recycling by providing specific instructions for recycling the packagmg.

Assistance Available

Most states have programs similar to the North Carolina Division of Pollution Prevention and Environmental Assistance that offer free waste reduction technical assistance. Interested parties should call (919) 715-6500 for assistance or referral to other state programs.

References

1. “Clean Air Compliance for Wood Furniture Manufacturers.” Draft manual. C. Steinmetz,

2. “Environmental Guide for the Furniture Industry.” American Furniture Manufacturers Association,

3. “Impact of Environmental Regulations.” G. Currier and R. Matejka, Akzo Nobel Coatings, Inc.

4. 40 CFR Part 63, Subpart JJ: National Emission Standards for Wood Furniture Manufacturing

5. Tennessee Center for Industrial Services. 1996.

University of

3M, and Akzo Nobel. Prepared by Radian Corporation.

1994.

Operations. U.S. Environmental Protection Agency. 1995.

Wood Furniture Manual VI-3 August 1996

Cost Avoidance Analysis A Tool for Evaluating Waste Reduction Options.

Cost Avoidance Analysis can be a very useful tool in determining the economic benefits of a solid waste reduction program for an industry or business. Cost avoidance analysis involves determining the full range of charges associated with handling a company’s wastes, from container rental to hauling to tipping fees. This full cost picture can then be used to evaluate the net “bottom line” impact of a chosen set of waste reduction options.

Companies may hesitate to implement source reduction or recycling because of up-front costs or service charges. However, cost avoidance analysis may show that a waste reduction program has a quick pay-back or can help reduce even greater costs of waste handling, hauling, and disposal. In short, cost avoidance analysis, especially when coupled with a full facility waste assessment, can help identify opportunities for greater efficiency and increased profitability.

The following diagram shows the components of a cost avoidance analysis. Not every cost line item identified below may be relevant to every company. Some companies may also find that they have other types of costs not included in the boxes.

I. Assess Total Current Waste Disposal costs II. Assess Total Proposed Waste Reduction Costs III. Assess Cost Avoidance Effects of Waste Reduction IV. Assess Revenues and Other Benefits from Waste Reduction V. Use Totals from Steps I through IV to complete the cost

STEPS IN DOING A COST AVOIDANCE ANALYSIS:

avoidance picture

I. WASTE DISPOSAL COSTS A. Waste container costs (purchase, rental)

D. Disposal fees (tipping fees)

____ B. In-house waste handling costs _____ C. Hauling costs _____

____

TOTAL: A+B+C+D =

II. WASTE REDUCTION COSTS E. Waste reduction capital expenditures F. Waste reduction operational costs G. Recycling hauling costs H. Process modifications or other changes

TOTAL: E+F+G+H =

III. COST AVOIDANCE EFFECTS OF WASTE REDUCTION

I. Avoided waste container rental or purchase J. Avoided in-house waste handling costs K. Avoided waste hauling costs L. Avoided disposal costs (e.g.tipping fees)

TOTAL: I+J+K+L =

IV. REVENUES AND OTHER WASTE REDUCTION BENEFITS

M. Revenues from the sale of recyclables N. Value of tax and other incentives O. Improved Efficiencies in Production P. Reduced Purchases and Inventory Costs

TOTAL: M+N+O+P =

To make accurate comparisons, all costs in the analysis should be put on the same time frame (e.g., month, year). Companies that contract out to handle their solid wastes may find that many of the itemized costs included above are “collapsed” into a single item on an invoice. Companies that want to do a cost avoidance analysis may need to ask waste handlers or haulers to report costs broken out by item and by each service time. Completing an accurate cost avoidance analysis may also require that different departments within a company (e.g., management, accounting, maintenance, line supervisors and employees, etc) spend time together “brainstorming” and accounting for all waste expenses. Companies may also want to consider other types of factors as they consider implementing waste reduction programs such as any long term liabilities associated with disposal.

Cost Avoidance Success Stories:

The positive effect of waste reduction programs on the competitiveness and profitability of businesses and industries is well documented. Numerous case studies demonstrate the success of these programs in avoiding a whole range of expenses and thus improving the efficiency and cost effectiveness of company operations. Cost avoidance analysis can be a key tool in helping any company identify and evaluate the impact of waste reduction initiatives. Here are some quick examples of cost savings resulting from waste reduction programs:

THOMSON CROWN WOOD PRODUCTS - Mocksville, NC Alternative Packaging for Interplant Shipment

An employee team at Thomson Crown Wood Products analyzed its procedures for packing sub- assemblies for transport to its sister facility in Indianapolis. The team found that packing the parts in reusable Bigelow packs instead of on shrink-wrapped pallets would reduce shipping space requirements and packaging disposal costs. The company estimated the change could reduce the number of shipments by 19% and eliminate 6,000 pallets and associated wrap per year for annual savings of $111,000.

CROWN CRAFTS, INC - Roxboro, NC Plant-wide Recycling Program

Crown Crafts implemented a comprehensive recycling program targeting corrugated cardboard, cardboard tubes, cloth, metal scraps, and other wastes. It reduced its solid waste disposal by 94 percent, or 808 tons per year, which helped the company avoid $27,500 in disposal costs. The company also made $91,000 from the sale of its recyclable materials.

Tips in doing Cost Avoidance Analysis

VII. Resources and Contacts

VII. Resources and Contacts:

VII. Resources and Contacts

Wood Furniture Manual VII-1 August 1996


Wood Furniture Manual VII-2 August 1996


Wood Furniture Manual VII - 4 August 1996

VIII. Financial Analysis of Compliance Alternatives

VII. Wood Furniture Coatings Title V: Financial Analysis of Alternatives for Complying with the NESHAP

VIII. Wood Furniture Coatings Title V

Financial Analysis of Alternatives for Complying with the NESHAP

This section presents a case study of the Example Finishing Company, which finishes wood furniture with coatings from four suppliers. The company has a Title V permit and is subject to the MACT. Table 1 is a summary for Plant No. 1 of April 1996 of VOC and HAP coating usages, and Table 2 is a summary of calculations of emissions from coatings supplied by Supplier 2 for the same period. Below is a series of alternatives for meeting the MACT requirements:

1. Review Table VIII-1, the Plant No. 1 summary sheet. Note that the Lbs VHAP/bs Solids (E) for this plant is too high. Remember that VHAPs and not VOCs are used in the NESHAP evaluation. Methanol is known to be the largest single VHAP for this plant.

2. In this case, the E number for the plant is 1.33, , which is higher than the required 1.0. If the VHAPs could be reduced by 19,828 Lbs (80,628-60,800), i.e., 12.5% of the total VHAPs, the E would be reduced to 1.0.

Table VIII-1. Example Finishing Company Plant No. 1 VOC and HAP Usages - April 1996

Suppliers 2 and 4 have Es above 1.0, while Suppliers 1 and 3 are below 1.0. Supplier 4 is small compared to Supplier 2, especially for the particular coatings that contribute the VHAPs that cause the plant-wide E to be above 1.0.

3. Review Table VIII-2, the Monthly Air Emission Calculations for Supplier 2. Four of the coatings are above 1.0, while only one is just below 1.0. As Coating 2 has the highest E at 37.50, it could be the first candidate for evaluation.

The costs of coatings are in the 5 to 10% range of total manufacturing costs.

4. There are a series of possible solutions to this situation. Some could involve reformulations, some could involve equipment, some could involve employee training, etc. The following sequence of evaluations generally starts with the no-capital cost alternatives and progresses through the rising, although sometimes very profitable, higher capital cost alternatives.

Solution No. 1: Change Suppliers

If Suppliers 1 or 3 have acceptable substitutes for those of Supplier 2, at comparable prices, consider switching suppliers.

Wood Furniture Manual VIII-1 August 1996

VIII. Wood Furniture Coatings Title V: Financial Analysis of Alternatives for Complying with the NESHAP

Solution No. 2: Switch to Compliant Coatings

If compliant coatings were available to replace all or an adequate number of the current coatings, a switch would be an "easy" solution, but coating costs could be 10 to 30% higher. Higher costs may mean that Example Finishing would have to raise furniture prices; thus, the actions taken by competitors may or may not restrict the use of compliant coatings.

Solution No. 3: Reformulations

The monthly summary sheets show that Supplier 2 contributed a major portion to the VHAP problem. If Supplier 2 could reduce its VHAPs by the entire 19,828 lbs, while holding the pounds of solids constant, the entire problem would be solved. If this approach does not work out, Supplier 1 would be reviewed next. Coating 2 from Supplier 2, which has an E of 37.50, is 90% methanol. If ethanol (which is not a VHAP) could be substituted for methanol in Coating 2, VHAPs would be reduced by 14,376 lbs; and although E would be improved, it would not be down to 1.0. Solution No. 3 would be an "easy" partial fix, but as ethanol costs significantly more than methanol, the prices of the coatings would probably be raised.

Coatings 1 and 4 are both major contributors to the VHAP loadings and should be carefully analyzed for possible VHAP reductions. If they contain significant amounts of methanol, the ethanol alternative may be viable. Acetone, also a light non-VHAP, may be a viable alternative.

Solution No. 4: Switch to Waterbome Coatings

At least a couple companies have expended the time and effort to convert some of their operations to waterbome coatings. Capital costs ranged from as little as $20,000 to over $100,000. Reported savings ran as high as a 30-percent reduction in coating costs with payouts as quick as 2 to 3 months.

Waterbome coatings are not inexpensive alternatives, at least initially. However, those who have fought their way through the change have reported a very good return on investment (ROI). Consequently, those who have made this change and found it to be profitable could convert more of their operations to waterbome and eventually develop a lower cost competitive edge.

Solution No. 5: Switch to Higher Solids Coatings

Higher solids coating may be higher cost, slower drying, and may have an odor; but they should still be considered.

Solution No. 6: Switch to Ultraviolet-Cured Coatings

For the ultraviolet-cured coatings, solids are very high, i.e., in the 85-100% range. Lbs VOCs/Lbs Solids are in the very low 0.1 range. These coatings require a new type of equipment.

Solution No. 7: Higher Transfer Efficiencies

The transfer efficiencies of the standard air guns (high pressure) are usually in the 30% to 40% range. That is to say, 60 to 70% of the solids in the coatings do not get on the wood. Obviously, the amounts of various coatings used could be dramatically reduced if the transfer efficiencies could be raised significantly. They can: by carefully targeted employee training and/or by changing to more efficient equipment.

HVLPs and Airless Guns have raised the transfer efficiencies into the 60 to 70% range. HVLP guns cost from about $300 to $500. Companies that have converted have reported coating savings of 13 to 65% with payouts in 3 to 8 months.


VIII. Wood Furniture Coatings Title V: Tax Incentives

This alternative could save a company money in coating costs and perhaps lower usages below the Title V levels. If this amount of reduction cannot be obtained, efficiency improvements will still significantly lower costs, although they may not reduce the E value.

Solution No. 8: Control Equipment

Incinerators

Carbon Absorbers

Solution No. 9: Combinations

Any and all of the above.

Tax Incentives

Smog Hogs

Concentrators

Accelerated depreciation: 60 months vs. 84 months or more.

No state franchise tax (0.15%) on new pollution prevention equipment

No county personal property tax

A major CPA firm has calculated these tax savings at about 5% on the investment, i.e., if a project has been evaluated at a 12% ROI, the tax incentives could raise it to 17%.


Appendix A: Air Pollutants

Appendix A: Air Pollutants Part 1 VHAPS Alphabetized

Appendix A

APPENDIX A - Air Pollutants

Part 1 - VHAPs Arranged Alphabetically

Wood Furniture ManuaI August 1996 A - 1

Appendix A: Air Pollutants Part 1 WHAPS Alphabetized

Appendix A

Wood Furniture Manual A-2 August 1996


Appendix A

Wood Furniture Manual A- 3 August 1996


Appendix A



Appendix A

Footnotes:

a IncIudes mono- and di-ethers of ethylene glycol, diethylene glycols and triethylene glycol; R-(OCH2CH2)RR-OR where:

n = 1,2, or 3, R = alkyl or aryl groups R'= R, H, or groups which, when removed, yield glycol ethers with the structure:

R-(OCH2CH2), - OH. Polymers are excluded from the glycol category.

Includes organic compounds with more than one benzene ring, and which have a boiling point greater than or equal to 100°C.

A-5 August 1996 Wood Furniture Manual

Appendix A: Air Pollutants Part 1 VHAPS by CAS No.

Appendix A

VHAP's - Arranged by CAS Number

Wood Furniture Manual A - 6 August 1996


Appendix A



Appendix A

Wood Furniture Manual A - 10 August I996

Appendix A: Air Pollutants Part 2 Solvents Excluded - Alphabetized

Appendix A

Part 2 - Pollutants Excluded From Use In Cleaning And Washoff Solvents

Arranged Alphabetically

August 1996 Wood Furniture Manual A-11


Appendix A


Appendix A: Air Pollutants Part 2 Solvents Excluded - by CAS

Appendix A

Part 2 - Pollutants Excluded From Use In CIeaning And Washoff Solvents

August 1996 Wood Furniture Manual A-14


Appendix A


Appendix B: VHAPS of Potential Concern

Appendix B: VHAPs of Potential Concern Part 2 - EPA Listed "Non-threshold" Pollutants

Appendix B

Wood Furniture Manual B - 2 August 1996

Appendix B: VHAPs of Potential Concern Part 2 - EPA Listed “Non-threshold” Pollutants

Appendix B


Appendix B: VHAPs of Potential Concern Part 2 - EPA Listed “High Concern” Pollutants

Appendix B


Appendix B: VHAPs of Potential Concern Part 2 - EPA Listed “Unrankable” Pollutants

Appendix B


Appendix C: Definitions. Acronyms

Appendix C: Definitions


Air-assisted airless (AAA) spray guns are a type of gun with pressure not as high as with the HVLP gun, but higher than conventional air spray guns.

Act means the Clean Air Act (42 U.S.C. 7401 et seq., as emended by Pub. L. 101-549, 104 Stat. 2399).

Actual emissions means the actual rate of emissions of a pollutant, but does not include excess emissions from a malfunction, or startups and shutdowns associated with a malfunction. Actual emissions shall be calculated using the source’s actual operating rates, and types of materials processed, stored, or combusted during the selected time period.

Acutely Hazardous Waste is a waste defined by EPA to cause immediate danger of life, health, or the environment upon exposure. These wastes carry a “P---” waste code number.

Adhesive means any chemical substance that is applied for the purpose of bonding two surfaces together other than by mechanical means. Under this subpart. adhesives shall not be considered coatings or finishing materials. Products used on humans and animals, adhesive tape, contact paper, or any other product with an adhesive incorporated onto or in an inert substrate shall not be considered adhesives under this subpart.

Administrator means the Administrator of the United States Environmental Protection Agency or his or her authorized representative (e.g., a State that has been delegated the authority to implement the provisions of this part).

Aerosol adhesive means an adhesive that is dispensed from a pressurized container as a suspension of fine solid or liquid particles in gas.

Affected source, for the purposes of this part, means the stationary source, the group of stationary sources, or the portion of a stationary source that is regulated by a relevant standard or other requirement established pursuant to section 112 of the Act. Each relevant standard will define the “affected source” or the purposes of that standard. The term “affected source,” as used in this part, is separate and distinct

from any other use of that term in EPA regulations such as those implementing title IV of the Act. Sources regulated under part 60 or part 6 1 of this chapter are not affected sources for the purposes of part 63.

For this standard, affected source means 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 as defined in 40 CFR part 63.2, excluding sources that meet the criteria established in Sec. 63.800(a), (b) and (c) of this subpart.

Wood Furniture Manual C - 1 August 1996


Alternative emission limitation means conditions established pursuant to sections 112(I)(~) or 112(I)(6) of the Act by the Administrator or by a State with an approved permit program.

Alternative emission standard means an alternative means of emission limitation that, after notice and opportunity for public comment, has been demonstrated by an owner or operator to the Administrator's satisfaction to achieve a reduction in emissions of any air pollutant at least equivalent to the reduction in emissions of such pollutant achieved under a relevant design, equipment, work practice, or operational emission standard, or combination thereof, established under this part pursuant to section 112(h) of the Act.

Alternative method means any method of sampling and analyzing for an air pollutant that is not a reference or equivalent method but has been demonstrated to the Administrator's satisfaction to, in specific cases, produce results adequate for a determination of compliance. As applied means the HAP and solids content of the coating or contact adhesive that is actually used for coating or gluing the substrate. It includes the contribution of materials used for in-house dilution of the coating or contact adhesive.

Alternative test method means any method of sampling and analyzing for an air pollutant that is not a test method in this chapter and that has been demonstrated to the Administrator's satisfaction, using Method 301 in Appendix A, 40 CFR Part 63, to produce results adequate for the Administrator's determination that it may be used in place of a test method specified in this part.

Approved permit program means a State permit program approved by the Administrator as meeting the requirements of part 70 of this chapter or a Federal permit program established in this chapter pursuant to title V of the Act (42 U.S.C. 7661).

Area source means any stationary source of hazardous air pollutants that is not a major source as defined in this part.

Attainment applies to the state and designated areas of the state. Attainment for an area or state means that territory has ambient air quality that meets the National Ambient Air Quality Standards (NAAQS) for Criteria Air Pollutants and ozone. Nonattainment means the territory is not meeting the NAAQS or ozone limit. See also Maintenance Area.

Basecoat means a coat of colored material, usually opaque, that is applied before graining inks, glazing coats, or other opaque finishing materials, and is usually topcoated for protection.

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



Best Management Practices (BMP) Plan means a plan based on study and past history to minimize or eliminate water pollutants in wastewater discharges.

Board foot (BdFt) is a unit of measure for wood and lumber. One (1) BdFt is 1 inch by 12 inch by 12 inches. It is a 1x12 one foot long.

Building enclosure means a building housing a process that meets the requirements of a temporary total enclosure. EPA Method 204E is used to identify all emission points from the building enclosure and to determine which emission points must be tested. For additional information see Guidelines for Determining Capture Efficiency, January 1994. Docket No. A-93-10, Item No. IV-B-1.

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

Capture efficiency means the fraction of all organic vapors generated by a process that are directed to a control device.

Carbon Monoxide (CO) is a ‘Criteria Air Pollutant’ emitted from internal combustion engines and large fossil fuel boilers.

CERCLA - See Comprehensive ...

Certified product data sheet (CPDS) means documentation furnished by coating or adhesive suppliers or an outside laboratory that provides the HAP content of a finishing material, contact adhesive, or solvent., by percent weight, measured using the EPA Method 3 1 1 (as promulgated in this subpart), or an equivalent or alternative method (or formulation data if the coating meets the criteria specified in Sec. 63.805(a)); the solids content of a finishing material or contact adhesive by percent weight, determined using data from the EPA Method 24, or an alternative or equivalent method (or formulation data if the coating meets the criteria specified in Sec. 63.805(a)); and the density, measured by EPA Method 24 or an alternative or equivalent method. Therefore, the reportable HAP content should represent the maximum aggregate emissions potential of the finishing material, adhesive, or solvent in concentrations greater than or equal to 1.0 percent by weight or 0.1 percent for HAP that are carcinogens, as defined by the Occupational Safety and Health Administration Hazard Communication Standard (29 CFR part 1910), as formulated. The purpose of the CPDS is to assist the affected source in demonstrating compliance with the emission limitations presented in Sec. 63.802.

Note: Because optimum analytical conditions under EPA Method 311 vary by coating, the coating or adhesive supplier may choose to include on the CPDS the optimum analytical conditions for analysis of the coating, adhesive, or solvent using EPA Method 3 1 1. Such information may include, but not be limited to, separation column, oven temperature, carrier gas, injection port temperature, extraction solvent, and internal standard.



Clean Air Act (CAA) means the federal law that authorizes and requires the control of air pollution from stationary sources or facilities.

Cleaning operations means operations in which organic solvent is used to remove coating materials or adhesives from equipment used in wood furniture manufacturing operations.

Clean Water Act (CWA) is the federal act to allow the regulation of water preservation and improvement.

Coating means a protective, decorative, or functional film applied in a thin layer to a surface. Such materials include, but are not limited to, paints, topcoats, varnishes, sealers, stains, washcoats, basecoats, enamels, inks, and temporary protective coatings.

Coating application station means the part of a coating operation where the coating is applied, e.g., a spray booth.

Coating operation means those activities in which a coating is applied to a substrate and is subsequently air-dried, cured in an oven, or cured by radiation.

Coating solids (or solids) means the part of the coating which remains after the coating is dried or cured; solids content is determined using data from the EPA Method 24, or an equivalent or alternative method.

Code of Federal Register (CFR) means the national register in which federally adopted regulations are published.

Commenced means, with respect to construction or reconstruction of a stationary source, that an owner or operator has undertaken a continuous program of construction or reconstruction or that an owner or operator has entered into a contractual obligation to undertake and complete, within a reasonable time, a continuous program of construction or reconstruction.

Compliance date means the date by which an affected source is required to be in compliance with a relevant standard, limitation, prohibition, or any federally enforceable requirement established by the Administrator (or a State with an approved permit program) pursuant to section 1 12 of the Act.



Compliance plan means a plan that contains all of the following:

(1) A description of the compliance status of the affected source with respect to all applicable requirements established under this part;

(2) A description as follows:

(i) For applicable requirements for which the source is in compliance, a statement that the source will continue to comply with such requirements;

(ii) For applicable requirements that the source is required to comply with by a future date, a statement that the source will meet such requirements on a timely basis;

(iii) For applicable requirements for which the source is not in compliance, a narrative description of how the source will achieve compliance with such requirements on a timely basis;

(3) A compliance schedule, as defined in this section; and

(4) A schedule for the submission of certified progress reports no less frequently than every 6 months for affected sources required to have a schedule of compliance to remedy a violation.

Compliance schedule means:

(1) In the case of an affected source that is in compliance with all applicable requirements established under this part, a statement that the source will continue to comply with such requirements; or

(2) In the case of an affected source that is required to comply with applicable requirements by a future date, a statement that the source will meet such requirements on a timely basis and, if required by an applicable requirement, a detailed schedule of the dates by which each step toward compliance will be reached; or

(3) In the case of an affected source not in compliance with all applicable requirements established under this part, a schedule of remedial measures, including an enforceable sequence of actions or operations with milestones and a schedule for the submission of certified progress reports, where applicable, leading to compliance with a relevant standard, limitation, prohibition, or any federally enforceable requirement established pursuant to section 1 12 of the Act for which the affected source is not in compliance. This compliance schedule shall resemble and be at least as stringent as that contained in any judicial consent decree or administrative order to which the source is subject. Any such schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the applicable requirements on which it is based.


Compliant coating/contact adhesive means a finishing material, contact adhesive, or strippable booth coating that meets the emission limits specified in Table 3 of this subpart.

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) is the act in which the federal government provides emergency response to releases of hazardous substances and action to cause clean up of abandoned hazardous waste sites. The regulations are in 40 CFR 300, and are sometimes referred to as SARA Title 111.

Conditionally Exempt Small Quantity Generator (CESQG) is a hazardous waste generator that generates less than 100 kg of hazardous waste (or less than 1 kg of acutely hazardous waste) in a calendar month and accumulated less than 1,000 kg at any one time.

Construction means the on-site fabrication, erection, or installation of an affected source.

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

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

Continuous emission monitoring system (CEMS) means the total equipment that may be required to meet the data acquisition and availability requirements of this part, used to sample, condition (if applicable), analyze, and provide a record of emissions.

Continuous monitoring system (CMS) is a comprehensive term that may include, but is not limited to, continuous emission monitoring systems, continuous opacity monitoring systems, continuous parameter monitoring systems, or other manual or automatic monitoring that is used for demonstrating compliance with an applicable regulation on a continuous basis as defined by the regulation.

Continuous opacity monitoring system (COMS) means a continuous monitoring system that measures the opacity of emissions.



Continuous parameter monitoring system means the total equipment that may be required to meet the data acquisition and availability requirements of this part, used to sample, condition (if applicable), analyze, and provide a record of process or control system parameters.

Control device means any equipment that reduces the quantity of a pollutant that is emitted to the air. The device may destroy or secure the pollutant for subsequent recovery. Includes, but is not limited to, incinerators, carbon adsorbers, and condensers.

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

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

Conventional air spray means 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 pounds per square inch (gauge) at the point of atomization. Airless and air assisted airless spray technologies are not conventional air spray because the coating is not atomized by mixing it with compressed air. Electrostatic spray technology is also not considered conventional air spray because an electrostatic charge is employed to attract the coating to the workplace.

Criteria Air Pollutants is a short list of air pollutants designated for monitoring and control because of their health effects. they are TSP, PM-10, SO2 , NOx, VOC, CO, and lead.

Data quality objective (DQO) approach means a set of approval criteria that must be met so that data from an alternative test method can be used in determining the capture efficiency of a control system. For additional information, see Guidelines for Determining Capture Efficiency, January 1994. (Docket No. A-93- 10, Item No. IV-B-1).

Day means a period of 24 consecutive hours beginning at midnight local time, or beginning at a time consistent with a facility's operating schedule.

Department of Transportation (DOT) is the agency regulating the transport of materials.

Direct Discharge means the addition of any pollutant or combination of pollutants to water of the state (US).



Discharge Monitoring Reports (DMRs) means the reports of wastewater monitoring required by a direct discharge NPDES permit.

Disposed offsite means sending used organic solvent or coatings outside of the facility boundaries for disposal.

Division of Air Quality (DAQ) means the air pollution regulatory agency in North Carolina.

Division of Emergency Management is the lead state agency in the Department of Crime Control and Public Safety the provides emergency response coordination on a state level.

Division of Pollution Prevention and Environmental Assistance (DPPEA) is the new name of the Office of Waste Reduction. The Office of the Small Business Ombudsman has joined this division also.

Division of Waste Management (DWM) is the North Carolina regulatory agency for solid and hazardous waste management. The Hazardous Waste Section is in DWM.

Division of Water Quality (DWQ) is the surface water pollution regulatory agency in North Carolina.

DOT - See Department of Transportation.

Effective date means:

(1) With regard to an emission standard established under this part, the date of promulgation in the

(2) With regard to an alternative emission limitation or equivalent emission limitation determined by the

Federal Register of such standard; or

Administrator (or a State with an approved permit program), the date that the alternative emission limitation or equivalent emission limitation becomes effective according to the provisions of this part. The effective date of a permit program established under title V of the Act (42 U.S.C. 7661) is determined according to the regulations in this chapter establishing such programs.

Emission means the release or discharge, whether directly or indirectly, of HAP into the ambient air.

Emission standard means a national standard, limitation, prohibition, or other regulation promulgated in a subpart of this part pursuant to sections 112(d), 112(h), or 112(f) of the Act.



Emissions averaging is a way to comply with the emission limitations specified in a relevant standard, whereby an affected source, if allowed under a subpart of this part, may create emission credits by reducing emissions from specific points to a level below that required by the relevant standard, and those credits are used to offset emissions from points that are not controlled to the level required by the relevant standard.

Emergency Planning and Community Right-to-know Act (EPCRA) of 1986 includes the emergency planning and chemical reporting requirements established under SARA Title III (See SARA).

Enamel means a coat of colored material, usually opaque, that is applied as a protective topcoat over a basecoat, primer, or previously applied enamel coats. In some cases, another finishing material may be applied as a topcoat over the enamel.

Environmental Protection Agency (EPA) is the federal environmental regulatory agency.

EPA ID number is the number assigned by EPA or it's designee (NC has a delegated program and the Hazardous Waste Section issues the numbers to applicants) to each hazardous waste generator, transported, and treatment, disposal facility.

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

Equivalent method means any method of sampling and analyzing for an air pollutant that has been demonstrated to the Administrator's satisfaction to have a consistent and quantitatively known relationship to the reference method, under specific conditions.

EPA means the United States Environmental Protection Agency.

Equivalent emission limitation means the maximum achievable control technology emission limitation (MACT emission limitation) for hazardous air pollutants

that the Administrator (or a State with an approved permit program) determines on a case-by-case basis, pursuant to section 112(g) or section 112(J) of the Act, to be equivalent to the emission standard that would apply to an affected source if such standard had been promulgated by the Administrator under this part pursuant to section 112(d) or section 112(h) of the Act.

Excess emissions and continuous monitoring system performance report is a report that must be submitted periodically by an affected source in order to provide data on its compliance with relevant emission limits, operating parameters, and the performance of its continuous parameter monitoring systems.



Existing source means any affected source that is not a new source.

Exclusionary Rule [Rule 2Q 0.800] is a rule that allows certain types of industry and business by specific category to opt for using ‘actual = potential’, based on materials use or throughput. The ‘wood coating or finishing’ is one of the categories in the rule.

Extremely Hazardous Substance (EHS) is any of 366 listed hazardous substances specified in Section 302 as chemicals that are considered to be a potential threat and require reporting when total quantities exceed the Threshold Planning Quantity (TPQ) or 500 pounds, which is lower [40 CFR 355].

Facility is used interchangeably with Source by the federal EPA, though sometimes point source is used to designate a stack or vent.

Facility as defined by North Carolina is the entire plant. And source is an identifiable part of the process, such as a stack or vent.

F-listed wastes are hazardous wastes the are from non-specific sources. The furniture industry generates a variety of F-listed wastes. [Solvents before used with 10% MEK fused for degreasing would be classified as F005.

Federally enforceable means all limitations and conditions that are enforceable by the Administrator and citizens under the Act or that are enforceable under other statutes administered by the Administrator. Examples of federally enforceable limitations and conditions include, but are not limited to:

(1) Emission standards, alternative emission standards, alternative emission limitations, and equivalent emission limitations established pursuant to section 112 of the Act as amended in 1990;

(2) New source performance standards established pursuant to section 111 of the Act, and emission standards established pursuant to section 112 of the Act before it was amended in 1990;

(3) All terms and conditions in a title V permit, including any provisions that limit a source’s potential to emit, unless expressly designated as not federally enforceable;

(4) Limitations and conditions that are part of an approved State Implementation Plan (SIP) or a Federal Implementation Plan (FIP);



(5) Limitations and conditions that are part of a Federal construction permit issued under 40 CFR 52.21 or any construction permit issued under regulations approved by the EPA in accordance with 40 CFR part 51;

(6) Limitations and conditions that are part of an operating permit issued pursuant to a program approved by the EPA into a SIP as meeting the EPA’s minimum criteria for Federal enforceability, including adequate notice and opportunity for EPA and public comment prior to issuance of the final permit and practicable enforceability;

(7) Limitations and conditions in a State rule or program that has been approved by the EPA under subpart E of this part for the purposes of implementing and enforcing section 1 12; and

(8) Individual consent agreements that the EPA has legal authority to create.

Finishing material means a coating used in the wood furniture industry. Such materials include, but are not limited to, stains, basecoats, washcoats, enamels, sealers end topcoats.

Finishing operation means those operations in which a finishing material is applied to a substrate and is subsequently air-dried, cured in an oven, or cured by radiation.

Fixed capital cost means the capital needed to provide all the depreciable components of an existing source.

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

Formulation Assessment Plan (FAP) is means of tracking use of VHAPs by establishing ‘baselines’, and seeking to reduce the highest emitted VHAPs, giving special consideration to the VHAP-PCs (VHAPs of Potential Concern).

Fugitive emissions means those emissions from a stationary source that could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening. Under section 112 of the Act, all fugitive emissions are to be considered in determining whether a stationary source is a major source.

Gluing operation means those operations in which adhesives are used to join components, for example, to apply a laminate to a wood substrate or foam to fabric.



HAP or HAPs - See below.

Hazardous air pollutant (HAP) means any air pollutant listed in or pursuant to section 112(b) of the Act. There are presently 189 HAPs listed.

Hazardous Waste is a hazardous material that is classified as hazardous under the criteria for listed waste and/or hazardous characteristics of ignitability, reactivity, corrosivity, and toxicity. Generally it is any liquid or solid material that is (or contains) a chemical listed as a hazardous material. There are many lists and many substances considered hazardous by various federal and state agencies.

High-volume, low-pressure (HVLP) is a designation for a spray gun that is different from the conventional air spray guns.

Incidental wood furniture manufacturer means 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 gallons per month of finishing material or adhesives in the manufacture of wood furniture or wood furniture components.

Incinerator means, for the purposes of this industry, an enclosed combustion device that thermally oxidizes volatile organic compounds to CO and CO2. This term does not include devices burning municipal or hazardous waste material.

Indirect Discharge means the introduction of pollutants to a POTW.

Issuance of a part 70 permit will occur, if the State is the permitting authority, in accordance with the requirements of part 70 of this chapter and the applicable, approved State permit program. When the EPA is the permitting authority, issuance of a title V permit occurs immediately after the EPA takes final action on the final permit.

Janitorial maintenance means the upkeep of equipment or building structures that is not directly related to the manufacturing process, for example, cleaning of restroom facilities.

Large Quantity Generator (LQG) is a generator who generates more than 1,000 kg of hazardous waste (or more than 1 kg of acutely hazardous waste) in a calendar month, or accumulates more then 6,000 kg of hazardous waste at any one time.

Lead (Pb) is one of the “Criteria Air Pollutants”.



List of Lists is a consolidated chemical subject to reporting under Title III of SARA, also known as EPCRA. It was prepared and issued as EPA 560/4-92-011, “Title III List Of Lists”, by EPA January 1992. It was prepared to help firms handling chemicals determine whether they need to submit reports under sections 302, 304 or 3 13 of Title III .

Lesser quantity means a quantity of a hazardous air pollutant that is or may be emitted by a stationary source that the Administrator establishes in order to define a major source under an applicable subpart of this part.

Local Emergency Planning Committee (LEPC) means the local planning group mandated by EPCRA to be responsible for planning and implementing emergency actions before, during, and after emergencies.

Lower confidence limit (LCD) approach means a set of approval criteria that must be met so that data from an alternative test method can be used in determining the capture efficiency of a control system. For additional information, see Guidelines for Determining Capture Efficiency, January 1994. (Docket No. A-93-10, Item No. IV-B-1).

Maintenance Area means an area or territory that has been nonattainment in the past, but has achieved attainment by meeting the NAAQS and now is being watched closely [more ambient monitoring is done than in an attainment area].

Major source means any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants, unless the Administrator establishes a lesser quantity, or in the case of radionuclides, different criteria from those specified in this sentence.

Malfunction means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.

Manifest is the shipping document originated and signed by the generator in accord with 40 CFR, Part 262.

Material safety data sheet (MSDS) means the documentation required for hazardous chemicals by the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (29 CFR Part 19 10) for a solvent, cleaning material, contact adhesive, coating, or other material that identifies select reportable hazardous ingredients of the material, safety and health considerations, and handling procedures.



Maximum Achievable Control Technology (MACT) is the best emission control for sources of HAPs. For existing sources the MACT is based on the best-performing 12% of sources for categories comprising 30 or more sources, or on the best-performing 5 sources for categories comprising fewer than n 30 sources.

Mixture rule is a simple rule that in-a-nut-shell means the following:

any listed waste + any solid waste = MORE listed waste

NSPS - See New Source Performance Standards

National Ambient Air Quality Standards (NAAQS) means the individual concentration standards that apply to the ‘Criteria Air Pollutants’ and ozone. Ambient air monitoring is performed by the DAQ.

National Emission Standard for Hazardous Air Pollutants (NESHAP) is a technology-based standard of performance prescribed for HAPs from certain stationary source categories under Section 1 12 of the CAA. The NESHAP for wood furniture manufacturing is found in 40 CFR 63, Subpart JJ.

[You can secure an electronic copy of the wood furniture manufacturing operations NESHAP by going to ftp://ttnftp.rtpnc.epa.gov/e-drive/caaa/rsr/ and downloading the file named “prereg.zip” to your computer...]

[EPA made this 81 Kb Zip Compressed Data file containing the preamble and the regulation available on Nov 27, 1996, thereby preceding the December 7, 1995, date of publication in the Federal Register. You will need to insert the publication date at appropriate places noted in the document.]

National Pollutant Discharge Elimination System (NPDES) means the program

for issuing, modifying, revoking, and reissuing, terminating, monitoring, and enforcing permits, and imposing and enforcing pretreatment requirements, under Section 307,402,3 18, and 405 of the CWA.

Navigable waters are defined as “water of the US” which are defined in 40 CFR Section 122.2 to include all waters affected by commerce, tidal waters, and intrastate rivers, lakes, streams, (whether flowing or not), wetlands, mudflats, sloughs, and natural ponds that could be used for recreational, fishing, or industrial purposes.

New source means any affected source the construction or reconstruction of which is commenced after the Administrator first proposes a relevant emission standard under this part.


ftp://ttnftp.rtpnc.epa.gov/e-drive/caaa/rsr


New Source Performance Standards (NSPS) are specific process control or air cleaning equipment requirements imposed on new sources of specific categories of industry.

Nitrogen Oxides (NoX) is oxides of nitrogen, one of the ‘Criteria Air Pollutants’ emitted from internal combustion engines and some industrial processes, such as nitric acid manufacturing and phosphoric acid processes.

Noncompliant coating/contact adhesive means a finishing material, contact adhesive, or strippable booth coating that has a VHAP content (VOC content for the strippable booth coating) greater than the emission limitation presented in Table 3 of this subpart.

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

Normally closed container means a container that is closed unless an operator is actively engaged in activities such as emptying or filling the container.

Occupational Health and Safety Act (OSHA) is the federal act designed to protect employees in the workplace.

Occupational Health and Safety Division is the health and safety regulatory agency in North Carolina in the Department of Labor.

Oil is defined fuels, lube oil, finishing oils, and any other oily sludge.

One-hour period, unless otherwise defined in an applicable subpart, means any 60-minute period commencing on the hour.

Ombudsman means a spokesman or advocate for someone or something.

Operating parameter value means 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 other operating parameter values, determines that an owner or operator has complied with an applicable emission limit.

Opacity means the degree to which emissions reduce the transmission of light and obscure the view of an object in the background. For continuous opacity monitoring systems, opacity means the fraction of incident light that is attenuated by an optical medium.



Organic solvent means a volatile organic liquid that is used for dissolving or dispersing constituents in a coating or contact adhesive, adjusting the viscosity of a coating or contact adhesive, or cleaning equipment. When used in a coating or contact adhesive, the organic solvent evaporates during drying and does not become a part of the dried film.

Overall control efficiency means the efficiency of a control system, calculated as the product of the capture and control device efficiencies, expressed as a percentage.

Owner or operator means any person who owns, leases, operates, controls, or supervises a stationary source.

Ozone is not a designated air pollutant. It is formed by photochemical reactions to produce the ground- level ‘LA smog’. NOx and VOCs are participants in the reaction.

P-listed waste originates from acutely hazardous commercial products.

PM-10 - See ‘Particulate Matter”

PSD - See Prevention of Significant Deterioration

Part 70 permit means any permit issued, renewed, or revised pursuant to part 70 of this chapter.

pay back is the Return On Investment (ROI) realized from a capital investment. Pay back time is the time it takes to pay off debts and recover losses and start making a profit.

Particulate Matter 10 microns or less (PM-10) is a ‘Criteria Air Pollutant’; it is the size of particulates inhaled that ‘stick’ to cause respiratory health problems.

Performance audit means a procedure to analyze blind samples, the content of which is known by the Administrator, simultaneously with the analysis of performance test samples in order to provide a measure of test data quality.

Performance evaluation means the conduct of relative accuracy testing, calibration error testing, and other measurements used in validating the continuous monitoring system data.



Performance test means the collection of data resulting from the execution of a test method (usually three emission test runs) used to demonstrate compliance with a relevant emission standard as specified in the performance test section of the relevant standard.

Permanent total enclosure means a permanently installed enclosure that completely surrounds a source of emissions such that all emissions are captured and contained for discharge through a control device. For additional information, see Guidelines for Determining Capture Efficiency, January 1994. (Docket No. A-93-10 Item No. IV-B-I).

Permit modification means a change to a title V permit as defined in regulations codified in this chapter to implement title V of the Act (42 U.S.C. 7661)~

Permit program means a comprehensive State operating permit system established pursuant to title V of the Act (42 U.S.C. 7661) and regulations codified in part 70 of this chapter and applicable State regulations, or a comprehensive Federal operating permit system established pursuant to title V of the Act and regulations codified in this chapter.

Permit revision means any permit modification or administrative permit amendment to a title V permit as defined in regulations codified in this chapter to implement title V of the Act (42 U.S.C. 7661).

Permitting authority means:

(1) The State air pollution control agency, local agency, other State agency, or other agency authorized by the Administrator to carry out a permit program under part 70 of this chapter; or

(2) The Administrator, in the case of EPA-implemented permit programs under title V of the Act (42 U.S.C. 7661).

Potential to emit means the maximum capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the stationary source to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable.

Pretreatment means the reduction of the amount of pollutants, the elimination of pollutants, or the alteration of the nature of pollutant properties in wastewater prior to discharging such into a POTW. The reduction or alteration may be obtained by physical, chemical, or biological processes: process changes; or by other means.



Prevention of Significant Deterioration (PSD) is a program to regulate the control to be imposed on ‘significant increases’ in air pollutants by a plant resulting from new or modified sources.

Publicly Owned Treatment Works (POTW) are local sanitary and industrial sewer treatment facilities. The treatment works are owned by the state or a municipality. This includes any devices and systems used in the storage, treatment, recycling, and reclamation of municipal sewage or industrial wastes of a liquid nature. It also includes sewers, pipes and other conveyances if the move wastewater to the POTW.

K-listed waste is waste from industry-specific sources. [K040 is wastewater treatment sludge from phenate production].

Reconstruction means the replacement of components of an affected or a previously unaffected stationary source to such an extent that:

(1) The fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be

(2) It is technologically and economically feasible for the reconstructed source to meet the relevant

required to construct a comparable new source; and

standard(s) established by the Administrator (or a State) pursuant to section 112 of the Act. Upon reconstruction, an affected source, or a stationary source that becomes an affected source, is subject to relevant standards for new sources, including compliance dates, irrespective of any change in emissions of hazardous air pollutants from that source.

Recycled onsite means the reuse of an organic solvent in a process other than cleaning or washoff.

Reference method means any method of sampling and analyzing for an air pollutant that is published in Appendix A of 40 CFR part 60.

Regulation promulgation schedule means the schedule for the promulgation of emission standards under this part, established by the Administrator pursuant to section 112(e) of the Act and published in the Federal Register.

Relevant standard means:

(1) An emission standard;

(2) An alternative emission standard;

(3) An alternative emission limitation; or

(4) An equivalent emission limitation established pursuant to section 112 of the Act that applies to the stationary source, the group of stationary sources, or the portion of a stationary source regulated by such standard or limitation.



A relevant standard may include or consist of a design, equipment, work practice, or operational requirement, or other measure, process, method, system, or technique (including prohibition of emissions) that the Administrator (or a State) establishes for new or existing sources to which such standard or limitation applies. Every relevant standard established pursuant to section 1 12 of the Act includes subpart A of this part and all applicable appendices of this part or of other parts of this chapter that are referenced in that standard.

Reportable Quantity (RQ) is a specific amount of any listed substance that is the threshold for requirements for that substance.

Research or laboratory facility means any stationary source whose primary purpose is to conduct research and development to develop new processes and products where such source is operated under the close supervision of technically trained personnel and is not engaged in the manufacture of products for commercial sales in commerce except in a deminimis manner.

Resource Conservation and Recovery Act (RCRA) is the federal regulatory framework for hazardous waste management requirements for generators, transporters, or owners and operators of treatment, storage, or disposal facilities.

Responsible official means one of the following:

(1) For a corporation: A president, secretary, treasurer, or vice president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision-making functions for the corporation, or a duly authorized representative of such person if the representative is responsible for the overall operation of one or more manufacturing, production, or operating facilities and either:

(i) The facilities employ more than 250 persons or have gross annual sales or expenditures exceeding $25 million (in second quarter 1980 dollars); or

(ii) The delegation of authority to such representative is approved in advance

by the Administrator.

(2) For a partnership or sole proprietorship: a general partner or the proprietor, respectively.

(3) For a municipality, State, Federal, or other public agency: either a principal executive officer or ranking elected official. For the purposes of this part, a principal executive officer of a Federal agency includes the chief executive officer having responsibility for the overall operations of a principal geographic unit of the agency (e.g., a Regional Administrator of the EPA).



(4) For affected sources (as defined in this part) applying for or subject to a title V permit: "responsible official" shall have the same meaning as defined in part 70 or Federal title V regulations in this chapter (42 U.S.C. 7661), whichever is applicable.

Return On Investment (ROI) is the 'payback' for some capital investment.

Run means one of a series of emission or other measurements needed to determine emissions for a representative operating period or cycle as specified in this part.

SIC - See Standard Industrial Classification..

SO2 - See Sulfur Dioxide.

Sealer means a finishing material used to seal the pores of a wood substrate before additional coats of finishing material are applied. Special purpose finishing materials that are used in some finishing systems to optimize aesthetics are not sealers.

Shutdown means the cessation of operation of an affected source for any purpose.

Significant Industrial User (SIU) means an indirect discharger wastewater containing one or more pollutants that need some pretreatment discharging to the POTW. A pretreatment permit may be required for sewer use.

Six-minute period means, with respect to opacity determinations, any one of the 10 equal parts of a one-hour period.

Small facility is the same as 'area source', not a Title V [large] facility.

Small Quantity Generator (SQG) is a generator who generates more the 100 kg and less than 1,000 kg of hazardous waste in a calendar month, or who accumulates more than 1,000 kg and less than 6,000 kg of waste at one time. If more the 1 kg of acutely hazardous waste is generated in a calendar month the LQG requirements apply.

Solvent means a liquid used in a coating or contact adhesive to dissolve or disperse constituents and/or to adjust viscosity. It evaporates during drying and does not become a part of the dried film.

Wood Furniture Manual C -20 August 1996


Spill Event means a discharge of oil in harmful quantities into or upon the navigable waters of the United States or adjoining shorelines.

Spill Prevention Control and Countermeasures (SPCC) Plan is a containment plan for above ground tanks above certain size containing oil..

Stain means any color coat having a solids content by weight of no more than 8.0 percent that is applied in single or multiple coats directly to the substrate. It includes, but is not limited to, non-grain raising stains, equalizer stains, prestains, sap stains, body stains, no-wipe stains, penetrating stains, and toners.

Standard conditions means a temperature of 293 K (68°F) and a pressure of 101.3 kilopascals (29.92 in. Hg).

Standard Industrial Classification (SIC) is a system of classifying every industrial and commercial activity by the product or service. It is sometimes referred to as the SIC Code.

Startup means the setting in operation of an affected source for any purpose.

State means all non-Federal authorities, including local agencies, interstate associations, and State-wide programs, that have delegated authority to implement: (1) The provisions of this part and/or (2) the permit program established under part 70 of this chapter. The term State shall have its conventional meaning where clear from the context.

State Emergency Response Commission (SERC) is the state-level group or agency established to provide emergency response planning and coordination on a state level. This agency in North Carolina is the Division of Emergency Management in the Department of Crime Control and Public Safety.

Stationary source means any building, structure, facility, or installation which emits or may emit any air pollutant.

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

Stormwater Pollution Prevention Plan (SPPP) is a site-specific plan to alleviate or eliminate the stormwater ‘run-off that occurs during and after a rain event.



Strippable spray booth material means a coating that:

(1) Is applied to a spray booth wall to provide a protective film to receive Overspray during finishing operations;

(2) Is subsequently peeled off and disposed; and

(3) By achieving (1) and (2), reduces or eliminates the need to use organic solvents to clean spray booth walls.

Source in EPA language means the same as ‘facility’ and EPA uses the terms interchangeably; but in North Carolina a source is a unit or identifiable part of the process at the ‘facility’ and a facility in North Carolina means the entire plant site..

Substrate means the surface onto which a coating or contact adhesive is applied (or into which a coating or contact adhesive is impregnated).

Sulfur Dioxide (SO2) is a gaseous ‘Criteria Air Pollutant’ emitted from combustion of fossil fuels and other industrial processes, such as petroleum distillation and sulfuric acid manufacturing.

Superfund Amendment and Reauthorization Act (SARA) of 1986 is an act passed to amend and reauthorize programs established in CERCLA. SARA Title III established emergency response systems and chemical inventory and use reporting requirements. This portion of SARA was given the name Emergency Planning and Community Right-to-know Act (EPCRA).

Surcharge is levied on a system user by the POTW authority for the user exceeding the pollutant- specific limits on the indirect discharge.

Synthetic minor [a ‘medium-sized’] facility refers to a non-Title V facility that elects to impose controls or limitations on the process air emissions to avoid Title V applicability. Such a facility will be issued a synthetic minor permit with requested limits.

TSP - See ‘Total Suspended Particulate’



Temporary total enclosure means an enclosure that meets the requirements of Sec. 63.805(e)(1)(I) through (iv) and is not permanent, but constructed only to measure the capture efficiency of pollutants emitted from a given source. Additionally, any exhaust point from the enclosure shall be at least four equivalent duct or hood diameters from each natural draft opening. For additional information, see Guidelines for Determining Capture Efficiency, January 1994. (Docket No. A-93- 10, Item No. IV-B-1).

Test method means the validated procedure for sampling, preparing, and analyzing for an air pollutant specified in a relevant standard as the performance test procedure. The test method may include methods described in an appendix of this chapter, test methods incorporated by reference in this part, or methods validated for an application through procedures in Method 301 of Appendix A, 40 CFR 63.

Title V permit means any permit issued, renewed, or revised pursuant to Federal or State regulations established to implement title V of the Act (42 U.S.C. 7661). A title V permit issued by a State permitting authority is called a part 70 permit in this part.

Thinner means a volatile liquid that is used to dilute coatings or contact adhesives (to reduce viscosity, color strength, and solids, or to modify drying conditions).

Threshold Planning Quantity (TPQ) is the quantity by weight of an Extremely Hazardous Substance (EHS) that triggers reporting under Section 302 and 311/312.

Topcoat means the last film-building finishing material that is applied in a finishing system.

Total Suspended Particulate (TSP) means ‘Criteria Air Pollutant’ that is particulate matter less than or equal to 100 microns aerodynamic diameter.

Touchup and repair means the application of finishing materials to cover minor finishing imperfections.

Treatment, storage, and disposal facility (TSDF) is a hazardous waste treatment/storage/disposal facility.

U-listed waste comes from hazardous commercial products.

Underground Storage Tank (UST) means a tank or combination of tanks (including connected underground pipes) that are used to contain an accumulation of a regulated substance. The volume of the tank(s) including the volume of the connected underground pipes must me 10 percent or more beneath the surface of the ground..



UV Light - See below.

Ultraviolet (UV) Light is a means of drying and curing a coating on substrates.

VHAP means any volatile hazardous air pollutant listed in Table 2 to Subpart JJ.

(In this manual. we list VHAPs from Table 2 in Appendix A - Part 1.)

VHAP of potential concern (VHAP-PC) means any VHAP from the nonthreshold, high concern, or unrankable list in Table 6 of this subpart. (In this manual. we list VEHAP of potential concern from Table 6 in Appendix B. - Part 2.)

Viscosity is a specific scientific term that defines the ‘flow’ of a material, such as a finish or coating.

Visible emission means the observation of an emission of opacity or optical density above the threshold of vision.

Volatile organic compound (VOC) means any organic compound which participates in atmospheric photochemical reactions, that is, any organic compound other than those which the Administrator designates as having negligible photochemical reactivity. A VOC may be measured by a reference method, an equivalent method, an alternative method, or by procedures specified under any rule. A reference method, an equivalent method, or an alternative method, however, may also measure nonreactive organic compounds. In such cases, the owner or operator may exclude the nonreactive organic compounds when determining compliance with a standard. For a list of compounds that the Administrator has designated as having negligible photochemical reactivity, refer to 40 CFR part 5 1.10.

Washcoat means a transparent special purpose finishing material having a solids content by weight of 12.0 percent by weight or less. Washcoats are applied over initial stains to protect, to control color, and to stiffen the wood fibers in order to aid sanding.

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

Waste minimization standards are in the Hazardous Waste Section rules and require businesses to seek ways to reduce, recycle or eliminate hazardous waste.

Work Practice Implementation Plan is a site-specific plan to reduce or eliminate HAP(s) by introducing ‘workpractices’, pollution prevention activities and measures.



Wood furniture means any product made of wood, a wood product such as rattan or wicker, or an engineered wood product such as particleboard that is manufactured under any of the following standard industrial classification codes: 2434, 2511, 2512 ,2517, 2519, 2521, 2631, 2641, 2699, or 6712.

Wood furniture component means any part that is used in the manufacture of wood furniture. Examples include, but are not limited to, drawer sides, cabinet doors, seat cushions, and laminated tops.

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


Appendix D: Determining Air Emissions and Requirements

Appendix D: Determining Air Emissions and Requirements: 1. Hazardous Air Pollutants - Wood Furniture Finishing

Appendix D: Determining Air Emissions and Requirements

1. Hazardous Air Pollutants - Wood Furniture Finishing

Exemptions

The MACT provides an exemption to sources using or agreeing to use no more than 250 total gallons per month or 3,000 total gallons per rolling 12-month period of all finishing materials, adhesives, cleaning solvents and washoff solvents.

Determine whether the facility is exempt by the following procedure:

Use purchase records for: 1. Finishing coatings. 2. Adhesives.

4. Washoff solvents. Find the maximum monthly use and the maximum rolling 12-month totals for each. Add all four usages; determine if the total is greater than 250 gallons per month or 3,000 gallons per 12-months.

3. Cleaning solvents

If totals are less than the 250 or 3,000 gallons, the facility is exempt; however, records should be maintained to prove facility is below the cutoffs. Records should be kept for 5 years.

If totals are greater then the 250 gallons per month or the 3,000 gallons per 12-months, the facility still may be exempt. Another cutoff is provided, but actual emissions of HAPs must be calculated. The exemption is for actual emissions of HAPS less than 5 TPY for a single HAP and less than 12.5 TPY for all HAPS. The list of 189 HAPs is in Appendix C.

Suppliers of coatings can provide some help. Most suppliers have spreadsheets showing the amount of coating purchased and the amount of each HAP in the coating. This job is simplified by some suppliers who provide a complete report of purchased HAPS and VOCs.

To determine actual HAP emissions:

First, make a quick calculation to determine if the facility is close to exemption. Assume that all coatings purchased for the year are used. If no single HAP is greater than 5 TPY and the total of combined HAPs is less than 12.5 TPY, the facility is exempt. If one of these is not true, the calculation will need to be refined.

Determine the ‘inventory’ for the representative year [purchased plus (+) on hand less (-) used equals (=) left in inventory]. Calculate the single and combined HAPs and compare to the 5/12.5 TPY cutoffs.

If the facility is exempt, with less than 5 TPY of actual use for any single HAP and less than 12.5 TPY of all HAPS combined, keep the records of the calculations, purchases and inventories for 5 years to prove the exemption. If the facility is very close to the cutoffs, be sure you have used a ‘representative maximum use’ year and will not exceed the 5/12.5 TPY any time soon.

If the facility is not exempt, the MACT applies

Wood Furniture Manual D - 1 August 1996

Appendix D: Determining Air Emissions and Requirements: Sample Calculations

Sample Calculations

The following example will help in the calculation of HAP or VOC Use/Emissions:

TIP: The comparison is easier if hourly maximum emissions are calculated to compare to thresholds If an hourly rate of emissions cannot be determined, the chart below will help.

Use the MSDS for each coating to determine the constituents or ingredients in the coating by CAS number that appears on the list of 189 HAPS. The ingredients on the HAP list are those that must be inventoried. Also needed are density or specific gravity, percent VOC or percent volatiles, and percent HAPs [all by weight percent] to calculate emissions. If this information is not on the MSDS or a report from the supplier, request it.

This example used is for illustration only. It is a furniture manufacturing plant that does some staining and some finishing. The inventory is kept monthly. The existing inventory system provides the use of coatings monthly in gallons. The coating supplier furnished information about the coatings used. All percents are percents by weight. Many more stains and finishes may be used. The example calculations are for only one of each. NOTE: S.g. = Specific gravity

Example Coatings

stain 1: S.g.=1.2 % volatiles = 85% VOC % = 75% VOC % = 80% HAP 1 (toluene) = 60% HAP 1 (toluene) = 60% HAP 1 = 15% HAP 2 (xylene) = 20% HAP 2 = 30%

HAP 5 = 25%

Washcoat 1 : S.g. = 1.1 Topcoat 1 : Density = 8.5 Lb/Gal

Equations to be used for calculations

1. Coating Use (lbs) = Coating S.g. x 8.34 lb/gal x Coatmg Use (gal)

or

Coatmg Use (lbs) = Coating Density (lb/gal) x Coating Use (gal)

2. VOC Use (lbs) = VOC % by weight x 100 x Coating Use (1bs)

or

VOC Use (lbs) = % Volatiles by weight x Coating Use (lbs)

3. HAP Use (lbs) = HAP % by weight x 100 x Coatmg Use (lbs)

An example table listing the items needed to help with the inventory process follows.



Table D-1. Example Table for Results [Coating Use information is from the Monthly Inventory.]

Sample Calculations For Stain 1, Washcoat 1 and Topcoat 1 Only

1. Coating Use Calculations

stain 1: 1.2 S.g. x 8.34 lb/gal x 30 gal = 300.24 lbs

Washcoat 1: 1.1 S.g. x 8.34 1b/gal x 10 gal = 91.74 1bs

Topcoat 1: 1.0 S.g. x 8.34 lb/gal x 20 gal = 166.80 1bs

2. VOC Use Calculations

Stain 1: VOC Use (1bs) = 85% x 100 x 300.24 1bs = 255.20 lbs

Note: The use of % volatiles yields a worst-case estimate for VOCs because the coating may contain water or exempt VOCs, which are volatile. The next calculation uses % VOC.

Washcoat: VOC Use (lbs) = 75% x 100 x 91.74 Ibs = 68.81 Ibs

The use of % VOC yields a more accurate calculation for VOCs.

Topcoat 1: VOC Use (lbs) = 80% x 100 x 166.80 lbs = 133.44 lbs



3. HAPs Use Calculations

HAP 1 (from Stain 1, Washcoat 1 and Topcoat 1)

HAP 1 = [60% x 100 x 300.24 lbs] + [60% X 100 X 91.74 lbs] + [15% X 100 X 166.80 lbs] = 180.14 lbs + 55.05 lbs + 25.02 lbs = 260.21 lbs of HAP 1

HAP 2 (from Stain 1 and Topcoat 1)

HAP2 = [20% x 100 x 300.24 lbs] + [30% x 100 x 166.80 Ibs]

= 60.05 lbs + 50.04 lbs = 110.09 lbs of HAP 2

HAP 5 (from Topcoat 1 only)

HAP5 = 25% x 100 x 166.801 lbs = 41.70 lbs of HAP 5

Complete the Example Table

Table D-1. Example Table of Results

The total VOCs and the total combined HAPS can be summed by addding the vertical columns.

The Individual HAPs can be added up for each coating.

Nates: 1. For Annual Report, add 12 months of HAP 1, and so on. 2. To estimate annual use/emissions, multiply by 12.


Total VOCs Total HAPs

Appendix D: Determining Air Emissions and Requirements: Determining Permit, Title V, and HAPs Applicability

Report of HAPs for the Month

HAP 1 Use = 260.21 lbs/2000 lb/ton = 0.130 Ton HAP 2 Use = 110.09 lbs/2000 lb/ton = 0.055 Ton HAP3 Use = notcalculated HAP4 Use = notcalculated HAP 5 Use = 41.70 lbs/2000 lb/ton = 0.021 Ton HAP6 Use = notcalculated

Total HAPS = 0.206 Ton

Total Estimated Annual (12 month) Emissions The total VOC actual use is 457.45 lb/mo x 12

Determining Permit, Title V, and HAPs Applicability

The actual or potential emissions [use] of any air pollutant exceeding the threshold determines permit and other requirements. Thresholds are based on annual numbers. Potential emissions are ‘ramped up’ from actual emissions. Potential emissions are calculated as if the facility operates 24 hours per day every day of the year. In North Carolina, coating operations are allowed to use actual maximum use of VOCs and HAPs to represent potential emissions. It is necessary to determine the annual emissions or use of VOCs and HAPS

to determine if the facility is exempt or needs a small, medium (synthetic minor), or a large major source Title V permit.

Actual and Potential Emissions

= 12 x 0.206 Ton = 2.47 Tons = 5489.4 lb/2000 lb/ton = 2.75 TPY

Potential emissions are calculated as if the facility operates 24 hours per day for 365 days per year. 24 hours x 365 days = 8,760 hours per year Potential emissions = actual emissions per hour x 8,760 hours/year

For coating cleaning, and printing operations, a break is allowed by regulation: Actual = Potential

A North Carolina Air Regulation that has a weight rate allowable can be used as the potential emissions.

A bottleneck can be used to limit potential emissions.

The potential for Title V applicability is determined without or before any control equipment.

Determination of potential emissions is important in order to be able to compare them to the thresholds to see if the facility can qualify for a small or exempt status, or even if it needs to apply for a permit.

- Threshold for major status for TSP(100) and VOC is 100 tons per year. Exempt threshold is 5 TPY.

- Threshold for each HAP is 10 tons per year and for combined HAPs is 25 tons per year.

In the example, not all the use/emissions were calculated. For the present example case, assume the total combined HAPs actual use is 824 lbs or 0.412 tons/month and the actual used VOC is 900 lbs or 0.45 tons/month. The 12-month totals would be as follows:

Actual HAPs = 4.944 TPY with Potential = 14.83 TPY

Actual VOCs = 5.4 TPY with Potential = 16.2 TPY

Note: this plant with actual emissions of less than 5 tons of total combined HAPs would qualify for the

A North Carolina rule allows actual use/emissions to be called potential. Thus, in North Carolina,


Appendix D: Determining Air Emissions and Requirements: TThresholds Thresholds

MACT/NESHAP exemption. However, the just over 5 TPY of VOCs would require a permit for a small facility.

Thresholds

Title V Major Facility - Potential Emissions without/before control

10 TPY single HAP 25 TPY combined HAPs

100 TPY VOC, TSP(100) and other criteria pollutants

Synthetic Minor or Conditional Major Facility - limited by time, pollution control, or Limited process operations to less than the Title V thresholds 10/25 and 100 TPY.

Small Facility - Less than the thresholds without the need for limits Between 5 and 100 TPY for the criteria pollutants and less than 10/25 TPY for the HAPS.

Exempt Facility - Less than 5 TPY for criteria pollutants and less the 10/25 TPY thresholds for HAPS or less if established by EPA.

Most owners and operators are accustomed to workmg in gallons, not tons per year. To help with understanding the thresholds, convert gallons used to pounds and use the following:

Table D-2. Thresholds


Appendix D: Determining Air Emissions and Requirements: Thresholds

A quick calculation can be made to see if the plant is even close to any threshold.

Example: 40 gallons of all coatings is the most used in a week (40 hours).

Calculate the worst possible case.

Note: Assume all the total gallons are 100% VOCs and all this VOC is a single HAP.

From the MSDS, select the worst coating, i.e., the one with the highest VOC. Highest VOCs = 6 lbs/gal

Multiply 40 gallons used x 6 lbs/gal of VOCs, alias HAP = 240 lbs of VOC and HAP used. This is the worst case of VOCs/HAP actually used for the week. Compare this to the weekly threshold values in the table above. The 240 lbs is more than the 192 lbs/wk, thus indicating a permit is required. A more refined analysis may be beneficial. Investigate further and refine the analysis.

Again, assume 40 gallons of all coating used in a week, but now break it down by type and constituents.

Stain Used = 6 gal. Sealer Used = 4 gal. Topcoat Used = 10 gal. Filler Used = 20 gal.

Assume all the VOCs are a single HAP (the worst case again!), but use the pounds-per-gallon information. This is more accurate than assuming 100% is VOC or HAPs.

Compare this 138 lb/week again to the threshold of 192 lb/week that requires a permit and discover this calculation shows that a permit is not required. The refined analysis has helped.

If the facility still exceeds the threshold, the calculation can be further refined by calculating the individual HAPs. This procedure allows use of the higher (481 lbs/week) threshold for multiple HAPs and the 192 lbs/week for each individuals HAP rather than the ‘assumed’ one.

TIP: An accurate inventory of the maximum use of coatings will make the calculations apply better to your real situation and allow you feel comfortable with the resulting conclusions.

Once the annual emissions are determined and compared to the thresholds for VOCs and HAPs and the exempt status or permit size determined, the recordkeeping and reporting requirements can be determined.

North Carolina TAPs Regulations

North Carolina also has regulations and permit requirements for toxic air pollutants (TAPs). The list of TAPs is similar but not identical to the HAPs list. The applicability of the TAPs program occurs when changes are made that significantly increase one or more of the TAPs above a threshold value. Threshold values exist for each listed chemical.


Appendix D: Determining Air Emissions and Requirements: 2. Criteria Air Pollutants for Wood Furniture

This manual does not discuss the NC TAPS requirements. If you have questions about this program, contact the appropriate Regional office or the Office of the Small Business Ombudsman (see Section VII: Resources and Contacts).

2. Criteria Air Pollutants for Wood Furniture

Wood furniture operations may include sawing, planing, and sanding. A boiler may be used to power drying kilns. The emissions of particulates and other ‘criteria’ pollutants may approach or exceed thresholds that determine permit and other requirements. The criteria pollutants are:

PM-10 (Particulate Matter 10 microns and less) TSP (Total Suspended Particulate

SO2 (Sulfur Dioxide) NOx (Nitrogen Oxides) Ozone CO Lead

Sources of particulates could be uncontrolled, (i.e., a chipper with wood by-product conveyed or blown into a trailer), or controlled by a cyclone, multicyclone, or baghouse. Wood waste may be used for a wood boiler which emits TSP and PM-10 through a stack.

Regulated Particulates, Particle Size, and Emission Factors

Emission factors for regulated particulates exist for some sources of particulates. Some particle size information exists for wood by-product or waste. These factors and information are based on tests conducted by EPA, North Carolina Air Quality, and furniture or wood products manufacturers in North Carolina. These factors may change as more information is collected.

TIP: Particle size distribution information is very useful and can reduce the ‘estimated emissions,’ which are based on ‘worst case’ or the 'high end' of current and published factors.

Particle Size information helps prevent chunks of wood to be considered TSP. North Carolina has defined TSP as particles with an aerodynamic diameter less than or equal to 100 microns. This size is based on the ability of the ambient air monitoring device used to monitor TSP, and this device collects TSP only below 100 microns. EPA has decided to allow only PM-10 to be considered when Title V and Permit Fees applicability is determined, but the North Carolina Regulations are based on TSP [PM- 100]. Very little particle size information exists for wood product sources. The following table is the present situation. The percent regulated is the percent of total collected/measured woodwaste that is PM-100 or PM-10 or less and the only part of woodwaste or byproduct wood regulated.


Appendix D: Determining Air Emissions and Requirements: Sample Calculations for Particulates

Table D 3: Regulated Particulates

Sample Calculations for Particulates

TIP: Finding pounds per hour will help with calculations.

Example Operation

1. Bark collected at 1 trailer is 30,000 pounds every 10 hour day = 3,000 1bs./h. 2. Rough Sawn Sawdust collected by 1 trailer is 21,000 pounds in 5 (10 hour) = 420 1bs./h. 3. Chips collected at 1 trailer is 20,000 pounds ever 2 (10 hour) days = 1,000 1bs./h. 4. Planer shavings are generated at 1 trailer (24,000 lb) each day (10 hrs) = 2400 lb/h 5. Annually 23.6 million Bd.Ft. are steam dried in the two kilns or air dried in sheds. 6. A 8.37 million Btu natural gas boiler is used to generate steam for the kiln drying process. Particulate Emissions are from:

1. debarking 2. sawing, 3. chipping 4. planing 5. wood fired boiler.

Calculations of the part of bark, sawdust. chips and shavings considered regulated air pollutants.

Note: This does not include the use of any controls or control equipment yet! If a cyclone is used, the lb/hr emission calculated is the wood going to the cyclone. If the wood is mechanically conveyed or blown, the lb/h calculated is the amount of the wood considered a potential air pollutant.

None of the wet bark being conveyed or transferred is considered a regulated air pollutant. All emissions from debarking transferring and shipping of the bark are considered insignificant.

For sawing, the State Air Quality Section (AQS) has decided that 18% of sawdust is a potential air pollutant. For the example, 0.18 x 420 lb/h = 76 lb/h is considered an air pollutant.

For chips from a wood chipper to reduce slabs, ends, and trims, the Air Quality Section recommends 0.56% of the wood shavings be considered an air pollutant. Contact with the AQS has indicated that this factor is usable for wood hogs or chippers. Thus for the example, the part of chips considered a potential air


Appendix D: Determining Air Emissions and Requirements: Sample Calculations for Particulates

pollutant is as follows: 0.0056 x 1000 lb/h = 5.6 lb/hr is considered an air pollutant.

For planer shavings, the factor is zero (0) for “green wood.” Green wood is defined as wood with a moisture content of 19% or greater. For “dry wood,” the Air Quality Section has decided that 2.6% of the shavings from wood planing is an air pollutant. Thus, if as in the example the wood planed is “dry,” the air pollutants to be considered would be 0.026 x 2400 lb/hr = 62.4 lb/h .

The emissions from the wood processing before or without control emissions

= the sum of all 4 above = about 144 lb/h.

The boiler particulate emissions need to be added to this particulate from woodworking operations. A great deal is known about boiler emissions. A computer emissions calculations spreadsheet is available to calculate all boiler emissions based on the use of wood; number 2, 5 or 6 oil; or natural gas. An example of the natural gas boiler and a wood-fired boiler emissions spreadsheet is attached. The before or without control emission of particulate from the spreadsheet for the natural gas boiler is 0.10 lb/hr. The total particulate emissions before control for the entire site is

144 lb/h + 0.10 lb/h = 144.1 lb/h.

The purpose for getting the before-control total of 144 lb/h is to calculate the Potential Emissions.

Potential Emissions determine whether the facility is considered a small or large facility. Potential emissions are calculated as if the facility operated without any controls 24 hr/day and 365 day/year, emitting the calculated 144 lb/h for 8,760 hr/year = 1,261,440 lb/yr. Dividing by 2000 lb/ton, the potential emissions are about 631 tons per year (TPY).

The potential emissions of about 631 TPY is above the 100 TPY that defines a Major Facility. However, if cyclone controls are applied and/or limitations taken such as “operation will be no more than 3,000 hrs/year,” this mill can avoid major classification and become a medium-size facility, i.e., Synthetic Minor Facility.

The example operation has cyclones on the chipper and planner operations. These cyclones are at least 85% efficient (emitting only 15%). By agreeing to accept a condition to use the cyclones reduces the TPY potential emissions. Also, agreeing to operate less than 8,760 hours per year will reduce the potential emissions.

The wet sawdust is conveyed by a paddle conveyor because it is wet, and the conveyor slowly dumps the sawdust into a trailer. The estimated drop/transfer point emission factor accepted is 0.115 lb/ton or 0.0000575 lb/lb. (This will need to be justified on form D 6 of the permit application). Thus, the sawdust emission is 0.0000575 lb/lb x 420 lb/h = .024 lb/h. If the sawdust is blown into a trailer, the emission factor is much higher, i.e., about 120 lb/h (0.06 lb/lb) because of the entrainment of small dust particles in the air. In this case, the example sawdust emission would be 0.06 lb/lb x 420 lb/hr = 25.2 lb/hr.


After-control Particulate Emissions

The actual with cyclone controls emission of particulates from wood processes is as follows:

sawdust + cyclone x uncontrolled + cyclone x uncontrolled =

paddle conveyed emission chips emissions emission shavings emissions

0.024 lb/h + (0.15 x 5.6 1b/h) + (0.15 x 62.4 1b/h) =

(0.024 + 0.8 + 9.4 ) lb/h = 10.2 lb/hr

and for the blown sawdust the with-controls emissions would be

25.21 lb/hr + 0.8 lb/hr + 9.41 lb/hr = 35.4 1b/hr

The potential emissions of 144.1 lb/hr is reduced to (10.2 lb/hr + 0.1) x 8760 hr/yr = 90,228 lb/yr or about 45 TPY by applying the controls. In this example, where 45 TPY is the result, this is well below the 100 TPY threshold without significant restrictions on hours of operation; thus, by simply agreeing to use existing control equipment will be enough to qualify as a Synthetic Minor (medium size) Facility.

The potential using blown factor is 35.4 lb/hr x 8760 = 310,104 lb/yr or about 155 TPY

For this case where sawdust is blown, the 155 TPY still i s above the 100 TPY threshold. So some further limit is needed. If the hours of operation are limited to no more than 1.5 shifts per day, or 60 hours per week (3,000 hours/year), the potential emission is 3000/8760 = 0.34 of the 155 TPY.

0.34 x 155 TPY = about 54 TPY, well below the 100 TPY threshold; and this is enough to qualify as a Synthetic Minor Facility. Agreeing to using the cyclones and operating no more than 3,000 hours per year will qualify for a Synthetic Minor permit and allow for some growth.

After-Control Particulate Emissions

For calculating controlled emissions, simply multiply the ‘before control’ actual emissions by

100 minus the efficiency expressed as a fraction. For example an 85% efficient cyclone would emit (1 - 85) = 0.15 of the ‘before emissions’. A 99.5% efficient bag filter will emit only 0.005 of the actual ‘before control’ emissions it ‘sees’. These calculations will be useful when deciding on which synthetic minor condition to use to avoid Title V Major status.

Sample Calculation for VOCs

VOC (Volatile Organic Compounds) are emitted from drying wood either air drying or kiln drying.

The example is 23.6 million (23,600,000) Board Feet dried each year. The VOC emission factor is 3.04 lb of VOC per 1000 Bd Ft for pine [0.3 lb of VOC per 1000 Bd Ft for hardwood] . The VOC emissions for our example facility are:

3.04 x 23,600,000 Bd Ft (from the usage records) = 71,744 lb of VOC/year for pine = 35.9 TPY

For hardwood the calculation would result in 7,080 lb of VOC/year for hardwood = 3.5 TPY

In either case, the VOC emissions need to be added to the VOCs from coating and finishing to get a site VOC emission number.


Appendix D: Determining Air Emissions and Requirements:

Appendix E: Case Studies

Appendix E: Case Studies: Ethan Allen, Inc., Old Fort, NC

Appendix E: Case Studies

Ethan Allen, Inc., Old Fort, NC

Background

Ethan Allen, Inc., of Old Fort, NC, manufactures dining and bedroom furniture. Coating procedures in the finishing operations produced approximately 37,000 pounds of hazardous waste annually. To reduce the quantity and disposal cost of this waste, the company made the equipment substitutions and cleanup changes discussed below.

Employee Waste/Cost Reduction Activities

Some of the modifications resulted directly from employee suggestions. The company implemented a cost reduction program to facilitate employee involvement in waste/cost reduction activities. Employees submit waste/cost reduction ideas, which are evaluated by a cost reduction committee, and valid suggestions are assigned for savings calculations.

Waste Reduction Activities

Three main components of the coatings operation generate the hazardous waste: overspray collection systems, material transport systems, and equipment cleanup procedures.

Overspray Collection Systems

Metal filters replaced paper/cardboard filters for all the coating operations. The metal filters are cleaned in a tank in which solvent is circulated with a diaphragm pump. The waste solvent/coating mix is distilled, and only the overspray is drummed for disposal. The cleaning solvent is reused. The metal filters used for lacquer and sealer overspray are hand wiped, and the dust is sent off site for recycling to Histrand Chemicals, Inc.

A fabricated, sloped polyethylene-lined trough replaced absorbent and wood shavings used to catch overspray. In the wiping stain booths, the trough is squeezed into a pan, and only the liquid overspray is drummed for disposal.

High-volume; low-pressure (HVLP) spray guns replaced conventional air-assisted spray gun equipment. As a result, the quantity of overspray to be filtered is reduced, and spraying efficiency is increased. Also, each operator is required to attend an annual technical training session. Training is provided by a representative of the spray gun manufacturer.

Material Transport Systems

Polyethelyene covers replaced cardboard covers for pallets used to transport products through coating operations. The overspray is peeled off the polyethylene cover and drummed for disposal.

The racks used to transport material on the conveyor system are now cleaned periodically during the boiler watchman’s free time. Thus, the employee’s time is utilized, and the racks can be reused. This procedure lengthens the life of the racks, which must be cleaned or disposed of as a solid hazardous waste.

Cleanup Operations

A solvent distillation unit was installed to recover usable 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.

Wood Furniture Manual E - 1 August 1996

Appendix E: Case Studies: Waste Reduction

Waste Reduction

These equipment substitutions and changes in cleanup procedures resulted in the elimination of 25,900 pounds of hazardous waste annually for a estimated cost savings of $129,465 per year. The following chart lists the process, cost of implementation, quantity of waste reduction, and annual cost savings.

Table E-1. Ethan Allen, Inc., Waste Reduction Activities

Contact

Mickey O’Keefe, Plant Engineer (704) 668-7686.


Appendix E: Case Studies: Case Study: Henredon Furniture Industries, Morganton, NC

Case Study: Henredon Furniture Industries, Morganton, NC

Background

As a high-end furniture manufacturer, Henredon Furniture Industries applies stains and other finishes to chairs, benches, and other furniture pieces. To comply with State and Federal air toxic and volatile organic compound (VOC) emission standards, Henredon embarked upon a two-phase research and development effort to reduce its materials usage and emissions via increased coating transfer efficiency and implementation of wood coatings with low volatile content. Henredon also installed metal baffle-type filters to replace paper/cardboard filters.


Henredon completed the first phase of its waste reduction effort through installation of high- volume, low-pressure (HVLP) spray and air-assisted airless equipment in all finishing facilities. Employees were trained in the new application techniques. Throughout the equipment conversion and subsequent training activities, Henredon maintained product quality and production levels.

Phase two of Henredon’s efforts to reduce emissions involved the evaluation and implementation of alternative coatings. The company determined that a hybrid system comprising conventional stains and wash coats and waterborne glazes, sealers, and topcoats would be most suitable. The conventional stains and washes control excessive grain disruption and provide a sealed base adequate for the subsequent waterborne finish. Henredon initiated this conversion on the occasional production line, through which it eventually fed 25 percent of the plant’s production. Concurrently, Henredon is developing waterborne versions for 90 percent of the facility’s finishes.

Waste Reduction

Compared to conventional spray equipment, the HVLP/air-assisted airless conversion resulted in a 13- to 20-percent reduction in materials usage for stains, lacquers, glazes, and sealers. Complete implementation of the two initiatives will result in an overall reduction in emissions of 73 percent. Because the metal baffle-type filters have a 10-year service life compared to the service life of one week for the paper/cardboard filters, the switch to metal filters has nearly eliminated the facility’s paped/cardboard filter waste stream.

Annual Savings/Payback

With capital investment of $12,380 and $70,806, respectively, annual savings for the two phases amount to $84,450 with a payback of 1.2 to 2 months. Annual purchase and disposal costs to fit a single booth with paper filters was $5,594 while purchase and installation costs for the new metal filters is $687 per booth. The cleaning cost per metal filter is $2 per month. The payback period of 8.14 weeks for the metal filters does not include labor savings.

Below is a summary of the Phase I and Phase II programs.


Appendix E: Case Studies: Annual Savings/Payback

Table E-2. Pollution Prevention Activities: Henredon Furniture Industries

Contact

Joe Harrill, Manager, Safety, Health, and Employee Development, (704) 437-5261

Wood Furniture Manual E-4 August 1996

Appendix E: Case Studies: Case Study: Thomson Crown Wood Products, Mocksville, NC

Case Study: Thomson Crown Wood Products, Mocksville, NC

Background

Thomson Crown Wood Products, a dvision of Thomson Consumer Electronics, manufactures wood and wood-finished television cabinets and storage units for audio equipment.


Thomson employees, who participate in the company’s Quality Leadership Process (QLP), have played a key role in reducing the facility’s water use and hazardous and solid waste generation. Teams of employees are trained in a 16-week process that focuses on instruction in “Quality Problem Solving and Statistical Process Control.” After completing the course, each five-member team addresses an in-house operational problem that is detrimental to personnel safety, quality, or cost.

The Hustlers Team implemented a new glue application system to eliminate glue defects from top and end panels on television cabinets. Thomson was losing approximately 6 of every 71 TV cabinets to glue dispensing and application problems. Glue was previously dispersed from a 55- gallon drum into I-gallon and then into 1-pint application containers. With the newly installed Schneeberger LK system, glue is now pumped from a central glue barrel through a PVC piping network to individual application stations. unlike the tips in the application bottles which clogged, this system delivers a steady flow of glue through the nozzle. This modification has enhanced product quality on all cabinets; nearly eliminated rejects due to glue dispensing and application problems; eliminated labor associated with glue cleanup; reduced glue use; and eliminated glue bottle, pan, tip, cleanup rag, and plastic bag waste streams.

The Hazardous Five Team developed a process for recycling water-based waste generated in the facility’s roll-on printing operations. The roll-off from the coating operations in the print room contains solids from the various finishes. The print line process was modified to pump this water- based waste from the print area to a colloidal separator (flocculation/clarification tank), which consists of an open tank with an agitator to disperse a flocking agent throughout the solution. Paint and finisling materials coagulate and settle as a solids layer, which is separated from the water and filter pressed. This material has been characterized as non-hazardous for sanitary landfill disposal. The water is reused to refill the 250-gallon water-wash spray booth tank.

The Millroom Madness Team implemented a process change on the Heian router that turns a square foot of medium density fiberboard (MDF) cut from the speaker panel into a shelf for the same television cabinet.

The OOC/Fineliners Team began addressing the problem of glue rejects from the end panel assembly line. Thomson was losing an average of 2 1 fully assembled and finished end panels per day to the landfill because of glue defects resultmg from handling along the assembly line. The OOC/Fineliners implemented a process change in which end panels are glued at each builder‘s station instead of along a conveyor. This change has reduced the annual number of glue rejects to zero.

The Mix-ups Team received a 1991 Pollution Prevention Program Challenge Grant of $10,000 to research and implement the use of high-volume, low-pressure (HVLP) spray guns along its coating lines. Thomson evaluated four HVLP guns with penetrating stain (no wipe), glaze, sap stain, equalizer, toner, shade, and water-based black paint. Ease of use (triggering and cleaning), weight, transfer efficiency, coating quality, and compatibility with the black water-based material were key judgment criteria. The Kremlin HVLP gun was rated best of the four in size, weight, triggering, and cleaning ease and significantly reduced materials use. The paint spray gun met coating


Appendix E: Case Studies: Waste Reduction Activities

specifications when used with the penetrating stain and glaze, and it did hold a specific spray pattern with the other coatings. The Graco HVLP gun received good-to-excellent operator ratings; it also reduced materials use and met coverage and spray pattern specifications with the sap stain, equalizer, toner, shade, and water-based black applications.

In July 1992, Thomson altered its print room process to laying down or rolling-on of finishes for all top and end panels of cabinets. It successfully diverted 60 percent of its spraying operations from the finish room to this roll-on process in the print room and reduced materials use by 50 percent. This process modification reduced air emissions to 0.38 pounds per gallon of applied coating, which is below the regulatory cut-off of 1 pound per gallon.

Thomson has been evaluating a hybrid waterbome finishing system using Can-Am Turbo Spray Equipment to apply waterbome sealers and topcoats over solvent-borne stain and washcoats. This hybrid system can be used on rounded and molded parts. The company has taken additional steps to ensure successful system implementation including (1) replacing carbon steel and galvanized lines and equipment with plastic or stainless steel for corrosion-resistance, (2) maintaining storage areas to prevent freezing of the waterbome finishes, and (3) increasing oven temperature from 1 10 to 145 F to cure the hybrid coatings. Although use of the hybrid waterbome coatings has required additional training, spray gun operators prefer them because of exposure to solvent vapors is reduced.

Table E-3. Thomson Crown Wood Waste Reduction Activities

Ms. Pat Grabble, QLP Coordinator, (704) 634-8693


Contact

Appendix F: Forms

Appendix F: Forms Material Use

Example Material Use Record

From To

Wood Furniture Manual F -1 August 1996

Appendix F: Forms Initial Notification Report

Initial Notification Report [As required by 40 CFR Part 63, Subpart A,

Section 63.9(b), The General Provisions]

Applicable Rule: 40 CFR Part 63, Subpart JJ--NESHAP for Major Sources of Wood Furniture Manufacturing Operations

Wood Furniture Manual F - 2 August 1996

Appendix F: Forms Initial Notification Report

(Signiture Optional)


Appendix F: Forms Initial Compliance Status Report

Initial Compliance Status Report

Applicable Rule; 40 CFR Part 63, Subpart JJ--NESHAP for Wood Furniture Manufacturing Operations


Appendix F: Forms Continuous Compliance Demonstration Report

Continuous Compliance Demonstration Report Applicable Rule; 40 CFR Part 63, Subpart JJ--NESHAP for

Wood Furniture Manufacturing Operations


Appendix F: Forms Notification of Construction/Reconstruction



Notification of Construction/Reconstruction Applicable Rule: 40 CFR Part 63, Subpart JJ--NESHAP for

Wood Furniture Manufacturing Operations

The company named below plans to:



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