CMTI/WOOD CABINET SMALL BUSINESS INITIATIVE

June 1996

POLLUTION PREVENTION OPPORTUNITY ASSESSMENT REPORT

INTRODUCTION

The Indiana Clean Manufacturing Technology and Safe Materials Institute (CMTI) has begun a small business, wood cabinet industry initiative to reduce the use of hazardous air pollutants (HAPs). Thus far, approximately one dozen, small wood cabinet manufacturers are collaborating with the Institute. The objective of the initiative is to

Indiana's wood cabinet industry is highly fractionated. Several large companies (500 to 800 employees) operate in the state and command the lion's share of the new home and/or retro-fit market. However, the industry also includes hundreds of small custom cabinet companies which employ 40 or fewer people. It is the small companies which will face the most dramatic change during the next twelve to eighteen months, due to the phase-in of the new Title V Clean Air Act air permitting regulations.

The numerous small wood cabinet companies within the state have never before been regulated. The previous air permit pollutant thresholds pertained to companies with the potential-to-emit (PTE) 100 tons of VOC. This regulatory threshold was so high that many small wood cabinet companies were considered "insignificant" sources and were not regulated. The new Title V air permit threshold levels are 10 tons PTE of any one HAP and/or 25 tons of any combination of HAPs. The air regulation's lower PTE threshold now may affect even small companies (10-40 employees). Therefore, numerous, small wood cabinet manufacturers are now working in collaboration with the Institute to reduce HAPs and, as a result, minimize their regulatory exposure.

MANUFACTURING PROCESS

The wood cabinet companies typically design, construct, and finish-coat custom cabinets for private residential and/or business use. The shops are small, but very efficient at converting raw lumber into fine custom kitchen and den cabinets. Typically, a cabinet is constructed prior to receiving the beautifying and protecting finish coating. Stains are often hand-wiped to allow deep penetration into the wood cabinet's surface while the sealer and varnish or lacquer coats are spray-applied to the piece.

ENVIRONMENTAL ISSUES

The industry finishes cabinets with a variety of stains and varnish systems. Traditionally, these finish coating systems have been formulated with hazardous air pollutants, such as xylene, toluene, MIBK, methyl ethyl ketone, ethyl benzene, etc. Small wood cabinet companies can often emit nearly ten tons of the more ubiquitous HAPs, such as xylene. Smaller-sized wood cabinet companies (10-12 employees) can often emit as many as 2.5 tons of HAPs. Actual emissions at these HAP levels can easily lead to PTE levels which exceed applicable Title V, HAP regulatory thresholds. P2 PROJECT

The Institute, working collectively with approximately a dozen, small wood cabinet manufacturers, instructs the companies in the calculation of actual and PTE emissions. "What if" scenarios are calculated using spreadsheets. These scenarios demonstrate the HAP reduction potential which can be achieved by switching to HAP-compliant and/or HAP-free coatings. The spreadsheet "What if" impact analysis allows the Institute/company team to choose the coatings which result in the greatest HAP reduction, thereby identifying the most effective HAP-compliant alternatives. The company then performs in-house coating tests to qualify the coatings for use and to analyze which (if any) changes need to be incorporated. These trouble-shooting changes may be the adoption of increased spraygun tip sizes, dry-time changes, cleaning solvent changes, etc. Thus far, the Institute/company teams have found little-to-no, serious difficulty in converting to HAP-compliant coatings.

The "What if" scenario spreadsheets serve a dual purpose. First, they help the companies select the most serious HAP-emitting coatings and target them for replacement. Second, the spreadsheets form the basis of a HAP and VOC usage inventory tracking system. The companies must institute the tracking system in order to prove compliance with the new air regulations in the event that the Indiana Department of Environmental Management (IDEM) should request air pollutant emission records from the companies.

POTENTIAL ENVIRONMENTAL AND COST BENEFITS

Once the companies have successfully converted to HAP-compliant and/or HAP-free coatings, the following emission reductions typically occur:

Chemical Use Reduction %

On a collective, aggregate basis, (for the dozen companies) hazardous air pollutant emissions are reduced by the following amounts:

Chemical Use Reduction (lbs.)

Total lbs. 33,450

Experience indicates that the new HAP-compliant coatings are economically competitive with traditional coatings and insignificant cost increases are incurred.

The Institute's assistance, with regard to HAP emission reduction and permit regulations, is estimated to save each company between $2500 and $3500 in consulting and permit regulation costs. On an aggregate basis (for the dozen companies), this assistance results in an overall, estimated, one-time cost savings of $36,000.

CONCLUSION

The wood cabinet initiative currently involves, approximately, a dozen small companies. The total, projected HAP emission reduction is estimated to be 33,450 pounds. In addition to the reductions achieved with HAPs, the companies involved in the initiative dramatically reduce their odds of falling under the full range of requirements of the new 1990 air pollutant regulations. Most of the companies are able to reduce their actual emissions of HAPs to such an extent that PTE emission levels are below the Title V thresholds. This could mean that the companies may be exempt from the air permit regulations. The Institute hopes that this initiative will, at least, double in size by late summer of 1996. If this occurs, an average of 60,000 pounds of HAP emissions could be eliminated in just this small group of companies.