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 Environmental ProtecfjoFT
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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON, D.C. 20460
                                                                         THE ADMINISTRATOR
Message from the Administrator

Over the past 25 years, our nation has made tremendous progress in protecting public health and
our environment while promoting economic prosperity. Businesses as large as iron and steel
plants and businesses as small as the dry cleaner on the corner have worked with EPA to find
ways to operate cleaner, cheaper, and smarter. As a result, we no longer have rivers catching on
fire. Our skies are clearer. American environmental technology and expertise are in demand
throughout the world.

The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.

Within the past two years, the Environmental Protection Agency undertook its Sector Notebook
Project to compile, for a number of key industries, information about environmental problems and
solutions, case studies and tips about complying with regulations. We called on industry leaders,
state regulators, and EPA staff with many years of experience in these industries and with their
unique environmental issues. Together with notebooks for 17 other industries, the notebook you
hold in your hand is the result.

These notebooks will help business managers to better understand their regulatory requirements,
learn more about how others in their industry have undertaken regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.

I encourage you to use this notebook to evaluate and improve the way that together we achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that ~ in industry after industry, community after community —
environmental protection and economic prosperity go hand in hand.
                                               Carol M. Brown
          Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)

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Wood Furniture and Fixtures
Sector Notebook Project
                                                      EPA/310-R-95-003
                EPA Office  of Compliance
                  Sector  Notebook  Project

           Profile  of  the  Wood  Furniture  and
                      Fixtures  Industry
                            September 1995
                          Office of Compliance
             Office of Enforcement and Compliance Assurance
                  U.S. Environmental Protection Agency
                       401 M St., SW (MC 2221-A)
                         Washington, DC 20460
                          for sale by the U.S. Government Printing Office
                   Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
                              ISBN 0-16-048270-4
SIC Code 25
      September 1995

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Sector Notebook Project
Wood Furniture and Fixtures
This report is one in a series of volumes published by the U.S. Environmental
Protection  Agency (EPA) to provide information of general interest regarding
environmental issues associated with specific industrial sectors.  The documents
were developed under contract by Abt Associates (Cambridge, MA), and Booz-
Allen & Hamilton, Inc. (McLean, VA). This publication may be purchased from
the Superintendent of Documents, U.S. Government Printing Office.  A listing of
available Sector Notebooks and document numbers is included at the end of this
document.
All telephone orders should be directed to:

      Superintendent of Documents
      U.S. Government Printing Office
      Washington, DC 20402
      (202) 512-1800
      FAX (202) 512-2250
      8:00 a.m. to 4:30 p.m., EST, M-F
Using the form provided at the end of this document, all mail orders should be
directed to:

      U.S. Government Printing Office
      P.O. Box 371954
      Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as
public and academic libraries, Federal, State, local, and foreign governments, and
the media. For further information, and for answers to questions pertaining to
these documents, please refer to the contact names and numbers provided
within this volume.
Electronic versions of all Sector Notebooks are available on the EPA Enviro$en$e
Bulletin  Board and via Internet on the  Enviro$en$e World  Wide Web.
Downloading procedures are described in Appendix A of this document.
September 1995
            SIC Code 25

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                                     Sector Notebook Contacts

The Sector Notebooks were developed by the EPA's Office of Compliance. Particular questions regarding the
Sector Notebook Project in general can be directed to:

         Seth Heminway, Sector Notebook Project Coordinator
         US EPA, Office of Compliance
         401 M St., SW (2223-A)
         Washington, DC 20460
         (202) 564-7017 fax (202) 564-0050
         E-mail: heminway.seth@epamail.epa.gov

Questions and comments regarding the individual documents can be directed to the appropriate specialists listed
below.
Document Number
EPA/310
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-

EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
-R-95-001.
-R-95-002.
-R-95-003.
-R-95-004.
-R-95-005.
-R-95-006.
-R-95-007.
-R-95-008.
-R-95-009.
-R-95-010.
-R-95-011.
-R-95-012.
-R-95-013.
-R-95-014.
-R-95-015.
-R-95-016.
-R-95-017.
-R-95-018.

•R-97-001.
•R-97-002.
-R-97-003.
-R-97-004.
R-97-005.
•R-97-006.
•R-97-007.
•R-97-008.
•R-97-009.
•R-97-010.
EPA/310-B-96-003.
   Industry

 Dry Cleaning Industry
 Electronics and Computer Industry
 Wood Furniture and Fixtures Industry
 Inorganic Chemical Industry
 Iron and Steel Industry
 Lumber and Wood Products Industry
 Fabricated Metal Products Industry
 Metal Mining Industry
 Motor Vehicle Assembly Industry
 Nonferrous Metals Industry
 Non-Fuel, Non-Metal Mining Industry
 Organic Chemical Industry
 Petroleum Refining Industry
 Printing Industry
 Pulp and Paper Industry
 Rubber and Plastic Industry
 Stone, Clay, Glass, and Concrete Industry
 Transportation Equipment Cleaning Ind.

*Air Transportation Industry
 Ground Transportation Industry
* Water Transportation Industry
 Metal Casting Industry
 Pharmaceutical Industry
 Plastic Resin and Man-made Fiber Ind.
 *Fossil Fuel Electric Power Generation Ind.
 * Shipbuilding and Repair Industry
 Textile Industry
 *Sector Notebook Data Refresh, 1997

 Federal Facilities
Contact

Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Keith Brown
Suzanne Childress
Jane Engert
Keith Brown
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott  Throwe
Virginia Lathrop

Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally  Sasnett
Rafael Sanchez
Suzanne Childress
Belinda Breidenbach
Seth Heminway

Jim Edwards
Phone (202)

564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-7124
564-7018
564-5021
564-7124
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057

564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-7018
564-7022
564-7017

564-2461
*Currently in DRAFT anticipated publication in September 1997
This page updated during June 1997 reprinting

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Wood Furniture and Fixtures
Sector Notebook Project
                      WOOD FURNITURE AND FIXTURES
                                 (SIC 25)
                            TABLE OF CONTENTS
                                                                     Page
LIST OF EXHIBITS	vii, viii
LIST OF ACRONYMS	ix,x
I.     INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT	1
      LA.      Summary of the Sector Notebook Project	1
      I.E.      Additional Information	2
n.    INTRODUCTION TO THE WOOD FURNITURE AND FIXTURES INDUSTRY	4
      II.A.     Introduction, Background, and Scope of the Notebook	4
      II.B.      Characterization of the Wood Furniture and Fixtures Industry...6
               II.B.l.   Industry Size and Geographic Distribution	6
               II.B.2.   Product Characterization	10
               E.B.3.   Economic Trends	11
m.    INDUSTRIAL PROCESS DESCRIPTION	13
      IH.A.     Industrial Processes in the Wood Furniture and Fixtures
               Industry	13
               HI.A.1.  Drying	13
               ni.A.2.  Machining	15
               HI.A.3.  Assembly	16
               in.A.4.  Pre-finishing	17
               ni.A.5.  Coating Application	17
               m.A.6.  Finishing	19
      ffi.B.     Raw Material Inputs and Pollution Outputs	24
               HI.B.1.  Drying	24
               ffl.B.2.  Machining	26
               UI.B.3.  Assembly	26
               EI.B.4.  Pre-finishing	26
               EI.B.5.  Coating Application	27
SIC Code 25
                                   IV
      September 1995

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Sectot Notebook Project
                                              Wood Furniture and Fixtures
IV.
V.
VI.
                      WOOD FURNITURE AND FIXTURES
                                 (SIC 25)
                       TABLE OF CONTENTS (CONT'D)
                                                                     Page
         III.B.6.    Finishing	28
         III.B.7.    Cleanup Operations	30

ni.C.     Management of Chemicals in Wastestream	34

CHEMICAL RELEASE AND TRANSFER PROFILE	36

IV.A.    EPA Toxic Release Inventory for the Wood Furniture and
         Fixtures Industry	39

IV.B.     Summary of the Selected Chemicals Released	44

IV.C.     Other Data Sources	49

IV.D.    Comparison of Toxic Release Inventory Between Selected
         Industries	50

POLLUTION PREVENTION OPPORTUNITIES	53

V.A.     Identification of Pollution Prevention Activities in Use and
         Environmental and Economic Benefits of Each Pollution
         Prevention Activity	54

V.B.     Pollution Prevention Case Studies	60

SUMMARY OF FEDERAL STATUTES AND REGULATIONS	64

VI.A.    General Description  of Major Statutes	64

VLB.     Industry-specific Regulatory Requirements	79

VI.C.     Pending and Proposed Regulatory Requirements	81
September 1995
                                                          SIC Code 25

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Wood Furniture and Fixtures
                                                Sector Notebook Project
                     WOOD FURNITURE AND FIXTURES
                                (SIC 25)
                       TABLE OF CONTENTS (CONT'D)
                                                                   Page
VII.   COMPLIANCE AND ENFORCEMENT HISTORY	86

      VILA.   Furniture and Fixtures Industry Compliance History	90

      VII.B.   Comparison of Enforcement Activity Between Selected
              Industries	92

      Vn.C.   Review of Major Legal Actions	97

              VH.C.1.  Review of Major Cases	97

              VTI.C.2.  Supplemental Environmental Projects	97

VIII.  COMPLIANCE ACTIVITIES AND INITIATIVES	98

      VTH.A.  Sector-related Environmental Programs and Activities	98

      VHI.B.  EPA Voluntary Programs	99

      Vffl.C.  Trade Association/Industry Sponsored Activity	104

              VTH.C.l.  Environmental Programs	104

              VDI.C.2.  Summary of Trade Associations	104

DC.
CONTACTS/ACBCNOWLEDGMENTS/RESOURCE MATERIALS/
BIBLIOGRAPHY	
                                                                    .108
SIC Code 25
                            VI
September 1995

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Sector Notebook. Project
                   Wood Furniture and Fixtures
                       WOOD FURNITURE AND FIXTURES
                                  (SIC 25)
                               EXHIBITS INDEX

                                                                       Page
Exhibit 1    Facility Size Distribution of Household Furniture Manufacturers..6
Exhibit 2    Facility Size Distribution of Wood Furniture Manufacturers	7
Exhibit 3    Geographic Distribution of the Furniture and Fixtures Industry	8
Exhibit 4    Geographic Distribution of the Wood Furniture and
            Fixtures Industry	9
Exhibit 5    Top Ten Wood Furniture Manufacturers - 1990	10
Exhibit 6    Chemical Components of Pigments Found in Paint	21
Exhibit 7    Flow Diagram for Wood Furniture Manufacturing	23
Exhibit 8    Relative VOC Emissions	29
Exhibit 9    Inputs and Outputs of Wood Furniture Manufacturing
            Facilities	31,32,33,34
Exhibit 10   Source Reduction and Recycling Activity for (SIC 25)	35
Exhibit 11   Top 10  TRI Releasing Furniture Manufacturing
            Facilities (SIC 25)	40
Exhibit 12   Top 10 TRI Releasing Furniture and Fixtures Facilities	40
Exhibit 13   TRI Reporting Furniture Manufacturing Facilities
            (SIC 25) by State	41
Exhibit 14   Releases for Furniture Manufacturing Facilities (SIC 25) in
            TRI, by Number of Facilities	41,42
Exhibit 15   Transfers  for Furniture Manufacturing Facilities (SIC 25) in
            TRI, by Number of Facilities	43
Exhibit 16   Pollutant  Releases (Short Tons/Year)	49
Exhibit 17   Summary of 1993 TRI Data	,	51
Exhibit 18   Toxic Release Inventory  for Selected Industries	52
Exhibit 19   Pollution  Prevention Matrix	58,59, 60
Exhibit 20   Ethan Allen Pollution Prevention Case Study Summary	63
Exhibit 21   Impacts of Environmental Statutes on the Wood Furniture
            Manufacturing Industry	76, 77, 78, 79
Exhibit 22   Summary of Proposed MACT Emission Limit	84
Exhibit 23   Summary of Work Practice Standards for the MACT and CTG	85
Exhibit 24   Five Year Enforcement and Compliance Summary for  the
            Furniture Industry	91
Exhibit 25   Five Year Enforcement and Compliance Summary for
            Selected Industries	93
September 1995
Vll
                               SIC Code 25

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Wood Furniture and Fixtures
                     Sector Notebook Project
                      WOOD FURNITURE AND FIXTURES
                                 (SIC 25)
                         EXHIBITS INDEX (CONT'D)

                                                                     Page
Exhibit 26   One Year Enforcement and Compliance Summary for
            Selected Industries	94
Exhibit 27   Five Year Inspection and Enforcement Statute for
            Selected Industries	95
Exhibit 28   One Year Inspection and Enforcement Summary by Statute for
            Selected Industries	96
SIC Code 25
Vlll
                           September 1995

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Sector Notebook: Project
                 Wood Furniture and Fixtures
                     WOOD FURNITURE AND FIXTURES
                                (SIC 25)
                            LIST OF ACRONYMS
AFS -       AIRS Facility Subsystem (CAA database)
AIRS -      Aerometric Information Retrieval System (CAA database)
BIFs -       Boilers and Industrial Furnaces (RCRA)
BOD -       Biochemical Oxygen Demand
CAA -       Clean Air Act
CAAA -     Clean Air Act Amendments of 1990
CERCLA-   Comprehensive Environmental Response, Compensation and
            Liability Act
CERCLIS -   CERCLA Information System
CFCs -       Chlorofluorocarbons
CO-        Carbon Monoxide
COD -       Chemical Oxygen Demand
CSI -        Common Sense Initiative
CWA -      Clean Water Act
D&B -       Dun and Bradstreet Marketing Index
ELP-        Environmental Leadership Program
EPA -       United States  Environmental Protection Agency
EPCRA -    Emergency Planning and Community Right-to-Know Act
FIFRA -     Federal Insecticide, Fungicide, and Rodenticide Act
FINDS -     Facility Indexing System
HAPs -      Hazardous Air Pollutants (CAA)
HSDB -      Hazardous Substances Data Bank
IDEA -      Integrated Data for Enforcement Analysis
LDR -       Land Disposal Restrictions (RCRA)
LEPCs -      Local Emergency Planning Committees
MACT -     Maximum Achievable Control Technology (CAA)
MCLGs-    Maximum Contaminant Level Goals
MCLs-      Maximum Contaminant Levels
MEK -       Methyl Ethyl Ketone
MSDSs -    Material Safety Data Sheets
NAAQS -   National Ambient Air Quality Standards (CAA)
NAFTA -   North American Free Trade Agreement
NCDB -     National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP -       National Oil and Hazardous Substances Pollution Contingency
            Plan
NEIC -      National Enforcement Investigation Center
NESHAP -   National Emission Standards for  Hazardous Air Pollutants
NO2~       Nitrogen Dioxide
NOV -      Notice of Violation
September 1995
IX
                             SIC Code 25

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Wood Furniture and Fixtures
Sector Notebook Project
                      WOOD FURNITURE AND FIXTURES
                                (SIC 25)
                        LIST OF ACRONYMS (CONT'D)

NOx -       Nitrogen Oxide
NPDES -    National Pollution Discharge Elimination System (CWA)
NPL -       National Priorities List
NRC -      National Response Center
NSPS -      New Source Performance Standards (CAA)
OAR -      Office of Air and Radiation
OECA -      Office of Enforcement and Compliance Assurance
OPA -       Oil Pollution Act
OPPTS -     Office of Prevention, Pesticides, and Toxic Substances
OSHA -     Occupational Safety and Health Administration
OSW -      Office of Solid Waste
OSWER -    Office of Solid Waste and Emergency Response
OW -        Office of Water
P2-         Pollution Prevention
PCS -        Permit Compliance System (CWA Database)
POTW -     Publicly Owned Treatments Works
RCRA -      Resource Conservation and Recovery Act
RCRIS -     RCRA Information System
SARA -     Superfund Amendments  and Reauthorization Act
SDWA -     Safe Drinking Water Act
SEPs-       Supplementary Environmental Projects
SERCs -     State Emergency Response Commissions
SIC -        Standard Industrial Classification
SO2-        Sulfur Dioxide
TOC -       Total Organic Carbon
TRI -        Toxic Release Inventory
TRIS -      Toxic Release Inventory System
TCRIS -     Toxic Chemical Release Inventory System
TSCA -      Toxic Substances Control Act
TSS -        Total Suspended Solids
UIC -        Underground Injection Control (SDWA)
UST -       Underground Storage Tanks (RCRA)
VOCs -      Volatile Organic Compounds
SIC Code 25
      September 1995

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Sector Notebook Project
Wood Furniture and Fixtures
                  WOOD FURNITURE AND FIXTURES
                               (SIC 25)
I.      INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

I.A.    Summary of the Sector Notebook Project

            Environmental policies based upon comprehensive analysis of air,
            water, and  land pollution are an inevitable and logical supplement
            to  traditional  single-media   approaches  to  environmental
            protection.   Environmental regulatory agencies  are beginning to
            embrace comprehensive, multi-statute solutions  to  facility
            permitting,  enforcement   and   compliance   assurance,
            education/outreach, research, and regulatory development issues.
            The  central concepts driving the new  policy direction are that
            pollutant releases to each environmental medium (air, water, and
            land) affect each other, and that environmental strategies must
            actively identify and address these inter-relationships by designing
            policies for the "whole" facility. One way to achieve a whole facility
            focus is  to  design  environmental policies for similar  industrial
            facilities. By doing so, environmental concerns that are common to
            the manufacturing  of similar  products can be addressed  in  a
            comprehensive manner.  Recognition of the need to  develop the
            industrial  "sector-based" approach within  the EPA  Office  of
            Compliance led to the creation of this document.

            The  Sector Notebook  Project  was initiated by the  Office  of
            Compliance within the Office of Enforcement  and  Compliance
            Assurance (OECA) to provide its staff and managers with summary
            information for eighteen specific industrial sectors.  As other EPA
            offices,  States, the regulated community, environmental groups,
            and  the public became  interested in this project, the scope of the
            original project  was  expanded.    The  ability  to  design
            comprehensive,  common  sense  environmental  protection
            measures for  specific  industries is dependent on knowledge of
            several inter-related  topics.  For the purposes of this project, the key
            elements chosen for inclusion are: general industry information
            (economic  and geographic); a description of industrial  processes;
            pollution outputs;  pollution prevention opportunities;  Federal
            statutory and regulatory framework; compliance history; and a
            description of partnerships  that have been  formed between
            regulatory agencies, the regulated community, and the public.
 September 1995
                                                                 SIC Code 25

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Wood Furniture and Fixtures
Sector Notebook Project
            For any given industry, each topic listed above could alone be the
            subject of a lengthy volume.   However, in order to produce a
            manageable document, this project focuses on providing summary
            information for each topic.  This format provides the reader with a
            synopsis  of each  issue,  and references where more  in-depth
            information is available.  Text within each profile was researched
            from a variety of sources, and was usually condensed from more
            detailed sources pertaining to specific topics.  This approach allows
            for a wide coverage of activities that can be further explored based
            upon the citations and references listed at the end of this profile.  As
            a check on the information included, each notebook went through
            an external review  process. The Office of Compliance  appreciates
            the efforts of all those that participated in this process and enabled
            us to develop more complete, accurate, and up-to-date  summaries.
            Many of those who reviewed this notebook are listed as contacts in
            Section IX and  may be sources of additional information.  The
            individuals and groups on this list do not necessarily concur  with
            all statements within this  notebook.
I.B.     Additional Information

Providing Comments

            OECA's Office of Compliance plans  to periodically review and
            update the notebooks and will make these updates available both in
            hard  copy and electronically.  If you  have any comments  on the
            existing notebook, or if you  would  like  to  provide additional
            information, please send a hard copy and computer disk to the EPA
            Office of Compliance, Sector Notebook  Project, 401 M St., SW (2223-
            A), Washington, DC 20460.  Comments can also be uploaded to the
            Enviro$en$e Bulletin Board or the Enviro$en$e World Wide  Web
            for general access to all users of the system.  Follow instructions in
            Appendix A for accessing these data systems.  Once you have logged
            in, procedures for uploading text are available from the on-line
            Enviro$en$e Help  System.

Adapting Notebooks to Particular Needs

            The scope of the existing notebooks reflect an approximation of the
            relative national occurrence of facility  types that occur within each
            sector.  In many instances, industries within  specific geographic
            regions or States may have unique characteristics that are not  fully
            captured in these profiles. For this reason, the Office of Compliance
            encourages State  and  local  environmental agencies and other
            groups  to supplement or re-package  the information included in
SIC Code 25
       September 1995

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Sector Notebook Project
Wood Furniture and Fixtures
            this notebook to include more specific industrial and regulatory
            information that may be available.  Additionally, interested States
            may  want to supplement the "Summary of  Applicable Federal
            Statutes  and  Regulations"  section  with   State  and  local
            requirements.  Compliance or technical assistance providers may
            also want to  develop the "Pollution  Prevention" section in more
            detail. Please contact the appropriate specialist listed on the opening
            page of this notebook if your office is interested in assisting us in the
            further development of the  information or  policies addressed
            within this volume.

            If you  are interested in assisting in the development of new
            notebooks for sectors not covered in  the original eighteen, please
            contact the Office of Compliance at 202-564-2395.
 September 1995
                                                                   SIC Code 25

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Wood Furniture and Fixtures
Sector Notebook Project
n.      INTRODUCTION TO THE WOOD FURNITURE AND FIXTURES INDUSTRY

            This  section provides background  information  on  the size,
            geographic  distribution,  employment,  production, sales, and
            economic condition of the Wood Furniture and Fixtures industry.
            The type of facilities  described  within the document  are also
            described in terms of their Standard Industrial Classification (SIC)
            codes.  Additionally, this section contains a list of the largest
            companies in terms of sales.
 H.A.   Introduction, Background, and Scope of the Notebook

            The furniture and fixtures industry encompasses companies that
            manufacture  household,  office,  store,  public building,  and
            restaurant furniture and fixtures.  These practices correspond to the
            Standard  Industrial Classification (SIC)  code 25 created by  the
            Bureau of the Census to track the movement of goods and services
            within the economy. Although it is difficult to determine the exact
            number of facilities that fall within SIC code 25, 1987 Census data
            indicate  that  there  were   approximately  11,000   furniture
            manufacturing facilities in operation (complete 1992 Census data
            were not available).

            SIC 25, Furniture and Fixtures, consists of the  following five three-
            digit industry groups:

                  SIC 251  -  Household Furniture
                  SIC 252  -  Office Furniture
                  SIC 253  -  Public Building and Related Furniture
                  SIC 254  -  Partitions, Shelving,  Lockers,  and Office and
                              Store Fixtures
                  SIC 259  -  Miscellaneous Furniture and Fixtures.

            The  following discussion focuses on SIC 251 because a majority of
            the wood furniture manufacturing facilities fall  into this  SIC code
            and the facilities in this SIC  code  tend  to be the most heavily
            regulated. The Bureau of the Census estimates that in 1992, 256,000
            people were employed by the household  furniture manufacturing
            sector (SIC 251) of the furniture industry, a decline of approximately
            10 percent from 1987.  The 1993 value of shipments for these firms
            exceeded  $22 billion,  representing an  increase of approximately
            seven percent over the previous  year.  Sales  from the household
            furniture manufacturing industry were expected to rise by four
            percent in 1994.
SIC Code 25
       September 1995

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Sector Notebook Project
Wood Furniture and Fixtures
            The household furniture manufacturing industry (SIC 251) consists
            of producers of wood furniture (SIC 2511), accounting for 42 percent
            of household furniture  industry  shipments in 1993; upholstered
            furniture (SIC 2512), accounting for 30 percent of shipments; metal
            furniture (SIC 2514), accounting for ten percent of shipments; and
            miscellaneous furniture  (SIC  2517 and 2519),  accounting for  four
            percent of shipments.

            This industry is comprised of the production of many different
            types  of products including wood household furniture,  metal
            household  furniture, mattresses, machine cabinets, shelving, and
            lockers.   Because the items produced  vary greatly  in design
            depending upon the type of material used, style, price, and final use,
            the different types of machinery used  in the various phases  of
            production  can reach into the hundreds or even thousands.   This
            diversity of  products provides a challenge for most manufacturers.

            Production lines for assembling furniture are costly, and because of
            this most manufacturers do not supply an exceptionally large range
            of items.  To combat this problem, many  firms  specialize their
            production processes, allowing facilities to fill a specific niche in the
            market while still retaining flexibility in their  manufacturing area.
            Manufacturers   may specialize  depending on  the  product
            manufactured, the  product  group, or the  production  process.
            Specialization has also allowed manufacturers to focus on quality by
            more carefully monitoring the entire production process, from raw
            material to finished product.

            Because SIC 25 covers such a diverse group of products, much of
            this profile  will concentrate on the wood  furniture manufacturing
            industry as defined by the following SIC codes:

                   SIC 2511 -  Wood Household Furniture, Except
                              Upholstered
                   SIC 2512 -  Wood Household Furniture, Upholstered
                   SIC 2517 -  Wood Television, Radio, Phonograph, and
                              Sewing Machine Cabinets
                   SIC 2521 -  Wood Office Furniture
                   SIC 2531 -  Public Building and Related Furniture
                   SIC 2541 -  Wood Office and Store Fixtures, Partitions,
                              Shelving, and Lockers.

            All discussions on production processes and applicable regulations
            will be limited to activities covered by these four-digit SIC codes.
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II.B.    Characterization of the Wood Furniture and Fixtures Industry

            The discussion of the characterization of the wood furniture and
            fixtures industry is divided into the following four topics:  industry
            size and  geographic distribution, profile of the top ten furniture
            manufacturers, characterization of products, and economic health
            and outlook.
II.B.l.   Industry Size and Geographic Distribution

            Variation in facility counts occur across data sources due to many
            factors,  including reporting and definitional  differences.  This
            document does not attempt to reconcile these differences, but rather
            reports the data as they are maintained by each source.

Size Distribution

            According  to 1987  Census data, approximately  63  percent  of
            household furniture  manufacturing facilities (SIC 251)  have fewer
            than 20  employees.  Approximately 53 percent of facilities within
            this  SIC  code  produce  wood  household  furniture,  while
            approximately 20 percent produce upholstered household furniture.
            Exhibit  1 provides a distribution by facility size  for household
            furniture manufacturing facilities.
                                 Exhibit 1
      Facility Size Distribution of Household Furniture Manufacturers
Type of Furniture Facility
Wood Household
SIC: 2511
Upholstered Household
SIC: 2512
Metal Household
SIC: 2514
Mattresses and Bedsprings
SIC: 2515
Wood Television and Radio
Cabinets
SIC: 2517
Household Furniture (misc.)
SIC: 2519
Total
Facilities
with 1 to 19
employees
2,084
574
207
504
44
126
3,539
Facilities with
20 to 99
employees
573
358
123
282
22
38
1,396
Facilities with
100 or more
employees
291
218
88
53
14
13
677
Total
2,948
1,150
418
839
80
177
5,612
                   Source: 1987 Census of Manufacturers Industry Series.
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             According to  information contained  in EPA's October 1991 draft
             guidelines  for  the  Control  of  Volatile   Organic   Compound
             Emissions  from   Wood   Furniture   Coating   Operations,
             approximately 86 percent of the wood furniture industry (SIC codes
             2434, 2511, 2512, 2517, 2519, 2521, 2531, and 2541) have fewer than 50
             employees.  Approximately 37 percent of facilities in this listing are
             wood household furniture manufacturers, while approximately 34
             percent are wood kitchen cabinet manufacturers.  Exhibit 2 provides
             a breakdown by facility size for the wood furniture manufacturers.
                                 Exhibit 2
         Facility Size Distribution of Wood Furniture Manufacturers
Type of Furniture Facility
Wood Kitchen Cabinets
SIC: 2434
Wood Household Furniture,
except upholstered
SIC: 2511
Wood Household Furniture,
upholstered
SIC: 2512
Wood Television, Radios,
Phonograph, and Sewing
Machine Cabinets
SIC: 2517
Household Furniture, not
elsewhere classified
SIC: 2519
Wood Office Furniture
SIC: 2521
Public Building and Related
Furniture
SIC: 2531
Wood Office and Store Fixtures,
Partitions, Shelving, and
Lockers
SIC: 2541
Total
Facilities
with 1 to 49
employees
3,460
2,466
782
61
150
505
381
1,672
9,477
Facilities
with 50 to 249
employees
218
344
292
11
22
113
95
184
1,279
Facilities with
250 or more
employees
35
138
76
8
5
31
15
10
318
Total
3,713
2,948
1,150
80
177
649
491
1,866
11,074
       Source: EPA Draft Guidelines for the Control of Volatile Organic Compound Emissions from
                          Wood Furniture Coatin? Operations.
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Geographic Distribution

            According to 1987 Census data, of the estimated 11,000 furniture
            manufacturing  facilities (SIC 251), approximately 17 percent are
            located in California.   North Carolina is home to approximately
            seven percent of these  facilities, even though four of the top ten
            facilities are located in this State.  Exhibit 3 provides a geographic
            distribution of the number of furniture and fixtures manufacturers
            (State totals are based on the number of facilities per State with 150
            or more employees in a  given industry sector).

                                 Exhibits
       Geographic Distribution of the Furniture and Fixtures Industry
                   Source: 1987 Census of Manufacturers Industry Series.
            Information contained in EPA's draft guidelines for the Control  of
            Volatile  Organic  Compound  Emissions  from  Wood  Furniture
            Coating  Operations  shows  that of the estimated 10,757  wood
            furniture manufacturing facilities (SIC codes 2434, 2511, 2512, 2517,
            2519, 2521, 2531, and 2541) approximately 17 percent are located in
            California. Although more facilities are located in California, the
            largest furniture manufacturing facilities and those responsible for
            producing the  highest  volume of furniture are located in  North
            Carolina.  Exhibit 4 provides a geographic distribution  of the wood
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            furniture manufacturing industry (information is not available for
            Alaska, Delaware, Hawaii,  Montana,  Washington D.C.,  and
            Wyoming).
                                 Exhibit 4
    Geographic Distribution of Wood Furniture Manufacturing Facilities
        Source: EPA Draft Guidelines for the Control of Volatile Organic Compound Emissions from
                         Wood Furniture Coatinv Operations.

             According to a 1990 ranking by total  annual sales of the top 300
             wood furniture manufacturing facilities in Furniture Design and
             Manufacturing  Magazine,  Masco  Corporation  is the largest
             residential wood furniture manufacturer, with annual sales of $1.2
             billion.    Steelcase, Inc.  is the  largest  manufacturer  of wood
             off ice/institutional  furniture, with  annual  sales  of $1.8 billion.
             Exhibit  5 provides a breakdown of the top ten manufacturers of
             residential wood furniture and wood off ice/institutional  furniture
             (sales figures are based on 1988 and  1989 data and are estimates in
             some instances).
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               Tot
              Exhibit 5
Ten Wood Furniture Manufacturers - 1990
Rank I Name of Manufacturer
Annual Sales,
$ million
Residential Furniture
1
2
3
4
5
6
7
8
9
10
Masco Corporation
Interco
Ohio Mattress Company
La-Z-Boy Chair Company
Bassett Furniture Industries, Inc.
Ladd Furniture
Simmons USA
Thomasville Furniture Industries, Inc.
Mohasco Corporation
Klaussner Furniture Industries
1,200
1,100
700
553
466
450
425
417
400
250
Office/Institutional Furniture
1
2
3
4
5
6
7
8
9
10
Steelcase, Inc.
Herman Miller, Inc.
Hanworth, Inc.
HON Industries, Inc.
Kimball International, Inc.
Knoll International
Allsteel, Inc.
Virco Manufacturing Corporation
Westinghouse Furniture Systems
Shelby William Industries, Inc.
1,800
793
>500
500
475
275
220
183
170
169
                   Source: Furniture Design and Manufacturing Magazine.
H.B.2.   Product Characterization
             The furniture and fixtures industry, as defined by SIC 25,
             manufactures a wide variety of products, including wood and
             metal furniture, mattresses, draperies, public seating (i.e.
             stadium seats and bleachers), lockers, and restaurant furniture.
             Because this profile focuses on the wood furniture portion of the
             industry (SIC codes 2511,2512,2517,2521,2531, and 2541), the
             product characterization of the profile is limited in scope.
             Products covered under the relevant  four-digit SIC codes include
             wood household furniture, such as beds, tables, chairs,
             bookshelves; wood television and radio cabinets; wood office
             furniture such as cabinets, chairs, and desks; and wood office and
             store fixtures and partitions, such as bar fixtures, counters,
             lockers, and shelves.
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II.B.3. Economic Trends
            According to the American Furniture Manufacturers Association
            (AFMA), wood furniture comprises approximately 50 percent of all
            furniture shipments  nationally.   Following a steady  decline
            beginning in 1989,  the furniture industry experienced moderate
            increases in 1992 and 1993.  This is in part attributed to the fact that
            private housing starts increased for the second consecutive year and
            the value of new residential construction rose an estimated  seven
            percent.  This rise in home sales and residential construction figures
            translated into  a five percent increase  in furniture shipments in
            1993.  Employment in the furniture and  fixtures industry increased
            by two percent in 1993 following a five year decline.

            Wood furniture manufacturers' profits did not rise by as much as
            the increased shipments would suggest.  Major increases in lumber
            prices, over 30 percent for softwood in approximately one year,
            significantly gouged profits in 1993.  A similar rise in hardwood
            prices occurred in early 1992. Although lumber prices may fluctuate
            mildly, they are not expected to fall to the reduced levels of 1991 or
            early 1992.

            In 1993, wood furniture accounted for 48 percent of total furniture
            exports,  followed by upholstered  furniture (19 percent),  metal
            furniture  (10 percent),  plastic  furniture (four  percent), and
            mattresses and  bedsprings  (three percent).   Although overall U.S.
            household furniture  exports increased five percent to $1.2 billion in
            1993, imports rose more than  14 percent in  the same time period.
            The resulting $2.3 billion  furniture  and fixtures  industry  trade
            deficit mimicked that of 1989.  However,  U.S.  exports increased
            almost 150 percent from 1989 through 1993 while imports increased
            only 25  percent in  the  same time period.  As foreign markets
            become increasingly important to U.S. manufacturers of household
            furniture, attention is being focused on international agreements to
            ease trade restrictions. For example, many furniture manufacturers
            favored  the North  American Free  Trade Agreement  (NAFTA).
            Under this  agreement,  Mexico,  a  major importer of  American
            home furniture, will immediately eliminate taxes on 21 percent of
            all imports  of U.S. household furniture,  with additional reductions
            to follow.
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            The real value of U.S. shipments of household furniture is expected
            to increase by four percent to an estimated $23 billion in 1994 due to
            improvements in the economy and consumer confidence.  Over the
            next five years, household furniture  shipments  are  expected to
            increase three to five percent annually.   This prediction relies
            primarily  upon  increases  in  product prices rather than overall
            furniture units produced.
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HI.      INDUSTRIAL PROCESS DESCRIPTION

            This section describes the major industrial processes within the
            Wood Furniture and Fixtures industry, including the materials and
            equipment  used,  and the processes  employed.   The  section  is
            designed for those interested in gaining a general understanding of
            the industry, and for those interested in the inter-relationship
            between  the industrial  process  and  the topics described in
            subsequent  sections of this profile —  pollutant outputs, pollution
            prevention  opportunities,  and Federal regulations.   This  section
            does not  attempt  to replicate published engineering information
            that is available for this industry.  Refer to Section IX for a list of
            reference documents that are available.

            This section specifically contains a description of commonly used
            production  processes, associated raw materials,  the byproducts
            produced  or  released,  and the  materials either  recycled or
            transferred  off-site.  This  discussion, coupled  with  schematic
            drawings of the identified processes, provide a concise description of
            where wastes may be produced  in the process.  This section also
            describes the potential fate (air, water, land) of these waste products.
III.A.   Industrial Processes in the Wood Furniture and Fixtures Industry

            The  following description of production processes focuses on the
            manufacturing of wood furniture.  The primary input for wood
            furniture manufacturing is  raw lumber,  and  the production
            processes include steps such as drying, sawing, planing, sanding,
            gluing, and finishing.  Each of these activities is described below.
III.A.I.  Drying

            Some  furniture  manufacturing  facilities may  purchase  dried
            lumber, but others perform drying on-site.  Drying of raw lumber is
            accomplished by using a drying kiln or oven, fired by a boiler.
            According  to  EPA document AP-42,  furniture manufacturing
            facilities generally burn wood  waste (from  later stages of the
            production process)  in  boilers to heat the drying  kilns and to
            alleviate possible  solid waste  disposal problems. The following
            boiler firing configurations are used for burning wood waste:  Dutch
            oven;  fuel cell  oven;  spreader  stoker; suspension-fired;  and
            fluidized bed combustion.  The primary outputs of burning wood
            waste in boilers are point-source emissions to the atmosphere.  A
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            more detailed discussion of all material inputs and pollution
            outputs will be covered in the following section.
Types of Boilers
            One common type of boiler used in smaller operations is the Dutch
            oven.  This unit is widely used because it can burn fuels with very
            high moisture content.  Wood waste is used as fuel and is fed into
            the oven through an  opening in the top  of a refractory-lined
            furnace.  The fuel accumulates  in a cone-shaped pile on a flat or
            sloping grate. Combustion is accomplished in two stages:  1) drying
            and gasification, and 2) combustion of gaseous products.  The first
            stage takes place in the primary furnace, which is separated from the
            secondary furnace chamber by a bridge wall.   Combustion is
            completed in the secondary chamber before gases enter the boiler
            section.

            In the  fuel cell oven, fuel is  dropped onto suspended fixed grates
            and is fired  in a pile.  Unlike the Dutch oven, the refractory-line
            fuel cell also uses combustion  air preheating and  positioning of
            secondary and tertiary  air  injection ports  to improve boiler
            efficiency.   Because  of  their overall  design and operating
            similarities,  fuel cell  and Dutch oven boilers  have comparable
            emission characteristics.

            The most common firing method employed for wood-fired boilers
            larger than 45,000 kg/hr steam generation rate is the spreader stoker.
            With this boiler, wood enters the furnace through a  fuel chute and
            is spread either pneumatically or mechanically across the furnace,
            where small pieces  of  the  fuel  burn while in  suspension.
            Simultaneously, larger pieces of fuel are spread in a thin, even bed
            on a stationary or moving grate.  The burning is accomplished in
            three stages in a single  chamber:   1) moisture evaporation; 2)
            distillation and burning of volatile matter; and 3) burning of  fixed
            carbon. This type of operation has a fast response to load changes,
            has improved combustion  control, and can be operated  with
            multiple fuels. Natural gas or oil is often fired in spreader stoker
            boilers as auxiliary fuel.  This is done  to maintain constant steam
            when the wood waste supply fluctuates and to provide more steam
            than can be generated from the wood waste alone.

            The suspension-firing boiler can be used for wood combustion, and
            differs from a spreader  stoker in that small-sized fuel (normally less
            than 2 mm) is blown into the boiler and combusted by supporting it
            in air rather than on fixed grates.   Rapid changes  in combustion
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            rate, and therefore steam generation rate, are possible because the
            finely divided fuel particles burn very quickly.

            A recent  development  in wood  firing  is  the  fluidized  bed
            combustion boiler.   A  fluidized bed consists  of  inert particles
            through which  air is blown so  that the bed  behaves as a fluid.
            Wood waste enters in the space  above the bed and burns both in
            suspension and in the bed.  Because of  the  large thermal mass
            represented by hot inert bed particles, fluidized beds can handle
            dirty fuels (up to  30  percent inert material). Wood fuel is burned
            faster in a fluidized bed than on a grate due to its immediate contact
            with hot bed material. As a result, combustion is rapid and results
            in nearly  complete combustion of the organic matter, minimizing
            unburned organic compound emissions.
III.A.2.  Machining
            Once the lumber is dried, it is sawed into a shape of the approximate
            dimensions of the final furniture part, such as a table leg or a chair
            rung.  Sawing across the grain in called crosscutting, and sawing
            parallel with the grain is referred to as ripping. Types of power saws
            used in furniture manufacturing include circular saws, band saws,
            scroll saws, radial saws, and portable handsaws.

            After sawing, the surfaces of the wood which will be flat  in the final
            product are planed.  Planing involves shaving one surface of wood
            by using a wide edged blade or blades called a planer. The type of
            power planer usually used  in this manufacturing process is  the
            jointer  or  jointer planer, which consists of blades fastened to  a
            rotating cutterhead.  The primary outputs  from  the sawing and
            planing processes are wood chips.

            The design of some furniture  pieces requires that certain wooden
            parts be bent. This production step follows the planing process and
            usually involves the application of pressure in conjunction with a
            softening agent and  increased atmospheric pressure. While soaking
            wood in water alone does increase its plasticity, the combination of
            heat and steam does increase  further the plasticity of wood.  The
            actual bending is accomplished by compressing the wood into the
            desired shape and then drying  it to remove excess moisture. Drying
            after bending is accomplished in much the same way as the drying
            of raw lumber, in drying kilns using boilers to generate heat.
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EI.A.3.  Assembly
            Wood furniture can either be finished (coated) and then assembled,
            or   assembled   and  then   finished.     Residential   and
            off ice/institutional furniture manufactured in the U.S. is generally
            made up of irregularly shaped, curved components, and for ease of
            production is assembled and then finished. Cabinets manufactured
            in the U.S., however, are frequently finished before assembly.

            After the wood parts have been planed and, if necessary, bent, they
            are assembled to form one furniture part, such as a tabletop.  The
            assembly process usually involves the use of adhesives (either
            synthetic  or natural) in  conjunction  with other joining methods,
            such as nailing.  The wood furniture manufacturing industry uses
            adhesive  formulations containing  solvents  (typically used for
            upholstered wood furniture) and hot melts or polyvinyl acetate
            (typically used for non-upholstered wood furniture).  According to a
            representative of Masco Corporation, the vast majority of adhesives
            used to assemble non-upholstered wood furniture are hot melts or
            polyvinyl acetate. The amount of adhesives  used depends on the
            type of product.

            The next step in the production process is the application of veneer.
            Veneer  is a thin piece of wood  of  uniform thickness which is
            usually rotary-cut from  a bolt of wood using a lathe.  Not all
            furniture manufacturing  involves  the application of veneer.  The
            production of veneer falls under SIC code 24 (lumber and wood
            products).  The  veneer is applied  to  the  furniture part using
            adhesives, some of which require the use of heat and/or pressure.
            While not a significant source of releases, gluing operations and the
            use  of  adhesives  for assembly and veneer are a  source  of
            atmospheric solvent releases.

            After veneer application or furniture assembly, the furniture part is
            sanded  to ensure that its surface is as smooth as possible for the
            finishing stages  of the production process.  Sanding is usually
            accomplished by a disk, belt, or roller sanding machine using either
            open- or closed-coated sand paper.   For open-coated sand paper,
            approximately 50 to 70 percent of the paper surface  is coated  with
            abrasive.   For closed-coated  sand paper, the paper  surface is
            completely covered with abrasive.  Closed-coated sand paper is
            generally used  in operations requiring higher removal rates.  The
            sanding process  can  also be  employed at other  stages of the
            production process, such as prior to the application of veneer or
            between the application  of several  coats of varnish during the
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            finishing process.  The  primary outputs from, sanding are wood
            p articulates.
III.A.4.  Pre-finishing
            After initial sanding, an even smoother  surface  is attained by
            spraying, sponging, or dipping the furniture part with water, which
            causes the fibers of the wood to swell and "raise." After the surface
            is dried, a solution of glue or resin is applied and allowed to dry,
            causing the  raised fibers to become more brittle.  The raised  fibers
            are then sanded down to form a particularly smooth surface. The
            primary outputs from second sanding are wood and glue or resin
            p articulates.

            Because certain types of wood contain rosin (a naturally occurring
            resin) which can interfere with the effectiveness of certain finishes,
            a process known as derosination may be employed.  Derosination is
            accomplished by applying a mixture of acetone and ammonia  to the
            surface of the wood.  Spent acetone and ammonia are the primary
            outputs from derosination.

            Once the unwanted  rosin is removed from the wood,  a process
            known as bleaching is used to lighten the color of the wood  when
            the natural  color  is darker than that of the stain  or finish  to be
            applied.  The  process entails spraying, sponging,  or dipping the
            wood  into a bleaching agent, such as hydrogen peroxide.   Spent
            bleaching agents  are the primary  outputs  of this step of the
            production process.
III.A.5.  Coating Application
            There are various coating application techniques used by the wood
            furniture manufacturing industry for applying finishing  coatings.
            The  two principal  methods are  flatline finishing and spray
            application.  Flatline  finishing is used  only to coat truly  flat
            furniture parts and cannot be used for curved pieces, preassembled
            pieces, or pieces with many recesses.  Although, spray application is
            the most commonly-used method to finish these furniture parts,
            brushing and dipping can also be used.

            The two principal ways of performing flatline finishing are  roll
            coating and curtain coating.  Roll coating  involves the transfer of
            coating material by a roller or series of rollers, while curtain coating
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            involves passing the furniture part through a cascade, or curtain, of
            coating material.

            The methods used to spray apply coatings include air, airless, air-
            assisted airless, high-volume low-pressure  (HVLP), electrostatic,
            and the UNICARB®  spray system.  The conventional air spray
            technique uses compressed air to atomize the coating materials as
            they are being sprayed, by forcing them through a small opening at
            high pressure.  The liquid coating is not mixed with air before
            exiting  the nozzle.  Air-assisted airless spray uses an airless spray
            unit with a compressed air jet to finalize the breakup of the coating
            material.

            HVLP spraying involves the use  of a high volume of air delivered
            at low  pressure to atomize the coating  material into  a pattern of
            low-speed particles.  The use of low pressure can result in decreased
            overspray, which translates into less coating usage and less volatile
            organic compound (VOC) emissions.

            Electrostatic spraying has long been used in  the metalworking and
            automobile industries to  coat  metal  products.   In the  wood
            furniture industry, electrostatic spraying  has somewhat limited use,
            mostly by cabinet and chair manufacturers. This finishing process is
            performed by spraying negatively-charged coating particles onto
            positively-charged wood products. If the wood piece  has a sufficient
            moisture content,  it  can be electrostatically  sprayed  without
            pretreatment.   However,  some wood must be pretreated  to allow
            the piece  to  hold  a  positive charge.   The material used  for
            pretreatment often contains VOCs.

            The UNICARB® system is a relatively new system for spray coating
            developed  by Union Carbide. A coating normally contains both
            coalescing  (slow-evaporating)  and  diluent  (fast-evaporating)
            solvents. The UNICARB® technology replaces the diluent solvents
            with liquid carbon dioxide. The  carbon  dioxide/coalescing solvent
            coating mixture is used to coat the wood with an airless spray gun.
            When the coating leaves the spray nozzle, the carbon dioxide in the
            mixture immediately flashes, and the coating material, which still
            contains coalescing  solvents, continues enroute to  the piece and
            cures in the conventional way.  As of June  1991, the UNICARB®
            system  was being tested in several coatings applications, but was not
            yet being used commercially in any production coating operation.
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III.A.6.  Finishing
            The finishing of wood  furniture  can be subdivided into two
            different categories, interior finishing (furniture for indoor use) and
            exterior finishing (furniture for outdoor use), although the actual
            production processes  involved  are fairly  similar.   The  main
            difference between interior and exterior finishing is the type of
            coating material applied, not the  application processes.   The
            following discussion  outlines the production processes involved in
            interior finishing; exterior finishing will be mentioned only when
            the process differs from that of interior finishing.

            Wood finishing processes include coating, drying, and sanding the
            furniture  in a series  of steps which are repeated until the desired
            final appearance  is achieved.   While in  small facilities the
            assembled furniture is  sometimes moved  between finishing
            stations manually, in most facilities  the furniture is moved along
            the  finishing  line mechanically by tow-lines,  overhead  chain
            conveyors, and  other conveyors including belt, roller,  and slat
            conveyors.  Tow-lines, chains or cables mounted in or on the floor,
            move a pallet, on which the assembled piece of furniture  rides
            along the finishing line.   The  pallets  can rotate and can  be
            automatically disengaged from and  reengaged to the  tow-line to
            allow for pauses, as needed.  Some facilities move the furniture on
            pallets that are hung from overhead chain conveyors.   Many
            facilities  use a  combination of these  methods to transport the
            furniture  along the finishing line.

            Many of the finishing  application  methods use relatively high
            concentrations  of VOCs  which  volatilize when the coating is
            applied.  For example, solvents are used in the stains, paints, and
            finishes as well as in the inks used to print simulated wood  grain
            onto plywood and particleboard.  In addition, solvents are used in
            cleanup operations (i.e., to remove overspray from spray booths and
            to  rinse solvent-based finishes from spray lines  and equipment
            between color changes).  The primary outputs from the following
            finishing  applications are point-source  and fugitive air emissions,
            as well as wood and coating material particulates.

            Staining  involves  the  application  of a clear colorant which
            adds initial color, evens out color, and  accents without hiding the
            natural  wood  grain. Stains  usually  consist of transparent or
            semitransparent color solids (typically less  than five percent by
            volume)  suspended  in  a volatile liquid solution with  a certain
            amount  of  a nonvolatile  binder,  which facilitates spreading,
            penetration, and fixation of color.   Commonly-used stains, all of
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            which are  used in conjunction  with organic solvents, include:
            nongrain-raising, dye-type, no-wipe, and toners.

            Nongrain raising stains are dye-type stains which are intended to
            give clarity  and depth to the wood finish. Dye-type stains consist of
            dyes that are completely dissolved in methanol. No-wipe stains are
            pigmented  stains, containing a small amount  of oil, pigment, and
            solvent, that are sprayed on and not wiped off. No-wipe stains are
            used to accent the wood grain, provide color uniformity and color
            retention.   Toners  are stains  that contain nitrocellulose or vinyl
            binders,  dissolved in solvent.  Toners are not wiped, and are often
            pigmented.

            After staining, a washcoat, consisting of 2 to  13 percent solids by
            volume,  is applied to  the furniture piece.  Washcoating is used to
            aid in adhesion,  assist in filling or color uniformity, and partially
            seal the wood from subsequent staining operations.  Washcoat also
            prepares the  wood  surface  for  another sanding  after  stain
            application. Some facilities buy sealer in bulk, and  dilute their
            sealer to make washcoat.  There are three main types of washcoat
            materials:   standard nitrocellulose; vinyl or modified vinyl; and
            vinyl-modified/"conversion" types.  Advantages of nitrocellulose
            washcoats include quick drying, easy sanding, and clarity. Vinyl and
            vinyl-modified washcoats consist of nitrocellulose  and vinyl and
            provide  better toughness and adhesion than pure nitrocellulose
            washcoats; however, some clarity is sacrificed.  The "conversion" or
            precatalyzed-type  washcoats also  provide  good  adhesion and
            toughness, and are good for open pore woods. Because they react in
            place, they  are impervious to solvents contained in subsequently
            applied sealers and topcoats.

            Fillers are  applied  to the wood surface to  produce  a smooth,
            uniform  surface  for later stages in  the finishing process.  Fillers,
            which consist of colorless or covering pigments, can be combined
            with stains or other pigments and  are usually dispersed in a vehicle
            of drying oils,  synthetic  resins,  and  thinners based on organic
            solvents.  Fillers  are usually supplied as heavily pigmented, high-
            solids, low-VOC materials,  which  are reduced  on the job.  As
            supplied, solids contents of  fillers are  in the 75 percent solids by
            volume range.  Once reduced, the solids contents usually range
            from 10 percent to 45 percent by volume.  Fillers are usually spray
            applied, then wiped into the wood.

            Sealing, which is completed after staining and either before or after
            filling, consists of applying one or many coats of sealer. Sealers are
            usually a nitrocellulose-based lacquer, although vinyl  or  vinyl-
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            modified sealers and catalyzed sealers are also available and provide
            advantages similar to those of the washcoat counterparts.  The
            primary purposes of sealers are to provide adhesion, make sanding
            more effective, and to seal the wood and establish a foundation for
            further coating applications.  Solids contents of sealers  typically
            range from ten to 30 percent by volume.

            For outdoor furniture, instead of,  or in addition to, the filling and
            sealing processes,  the wood surface  is treated through a process
            known  as priming.   Priming treatments commonly used  for
            outdoor wooden furniture include the application of fungicide and
            water-repellent.

            One alternative to staining is painting.  The process for  applying
            paints  is  similar  to  that  of applying stains or other  finishes,
            although the chemical composition of paints differs from the other
            finishes. Paint is a viscous fluid, usually consisting of a binder or
            vehicle, a pigment, a solvent or a thinner, and a drier. Pigments are
            insoluble in the coating material and are deposited onto the wood
            surface as  the vehicle dries.  The chemical composition of a pigment
            varies according to its  color as illustrated in Exhibit 6.
                                 Exhibit 6
             Chemical Components of Figments Found in Faint
Pigment Color
White
Red
Orange
Brown
Yellow
Green
Blue
Purple
Black
Chemical Components
Titanium dioxide, white lead, zinc oxide
Iron oxides, calcium sulf ate, cadmium
selenide
Lead chromate-molybdate
Iron oxides
Iron oxides, lead chromate, calcium sulfide
Chromium oxide, copper, phosphotungstic
acid, phosphomolybdic acid
Ferric ferrocyanide, copper
Manganese phosphate
Black iron oxide
              Source: McGraw-Hill Encyclopedia of Science and Technology. 1987.

             After the furniture part has been stained or painted, a topcoat, such
             as varnish or  shellac, is applied in one of the final stages of the
             finishing process.  Topcoats provide a clear coat whose function is to
             protect the color coats, enhance the beauty of the furniture, and
             provide a durable final finish.  Typical solids contents range from 13
             to 30 percent solids by  volume.   There are  four categories of
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            topcoats:  standard nitrocellulose topcoats; acrylic topcoats; catalyzed
            topcoats;  and conversion varnishes.

            Nitrocellulose lacquers provide the best clarity, pick up little dirt,
            dry quickly, and are easy to wipe off and repair.  Acrylic lacquers are
            used over white  or  pastel  finishes as protection from  common
            household cleaning  products.  They can  also  be applied  over
            nitrocellulose topcoats for color retention.  The  clarity of acrylic
            lacquers is not as good as the nitrocellulose lacquers.  Catalyzed
            topcoats are available in one- and two-pack form.  The one-pack
            coatings are precatalyzed, and contain nitrocellulose resins and a
            small  amount of urea  resin.   Because  only a small  amount of
            catalyst is added, it can take up to three to four weeks  after
            application until the  coating is completely cured, although it dries
            to the  touch much sooner.  The shelf life of precatalyzed coatings is
            more than six months.  Conversion varnishes do not dry as quickly
            as nitrocellulose topcoats, and are difficult to spot repair,  with
            washoff also being difficult  or impossible.  Conversion varnishes,
            like two-pack coatings, have a limited pot life.

            The  two-pack coatings consist of two packs,  one containing urea or
            melamine-based resins, and the other containing the catalyst.  The
            two  components are  mixed before use.  More catalyst is added to
            two-pack catalyzed coatings, so cure time is short (on the order of
            minutes or hours).  Two-pack catalyzed coatings have a  limited pot
            life after mixing (from one  day to more than a week).

            In the U.S., lacquers (mostly nitrocellulose-based) are  used  by
            approximately 75 percent of the wood furniture industry; mostly by
            residential furniture  manufacturers.  Nitrocellulose lacquers have
            been used in the residential  wood furniture  industry for many
            years; they are easy to use, quick drying, and easy to repair.

            Approximately 15 percent of the wood furniture industry, primarily
            the cabinet and  off ice/institutional furniture  manufacturers, use
            conversion coatings (mostly acid-catalyzed coatings). Cabinets and
            off ice/institutional furniture require the chemical and  mechanical
            resistance offered by  catalyzed  finishes.  As of October 1991,
            polyurethane and  unsaturated  polyester  and unsaturated
            polyacrylate coatings  have  had limited use in the United  States.

            Rubbing, polishing,  and  cleaning  are  the  final steps of  the
            production process.   Rubbing consists  of  the application of  an
            abrasive in conjunction with a lubricant to level or dull the luster.
            Polishing consists of the application  of soft abrasives or possibly
            only waxy ingredients to increase the gloss.  The furniture parts are
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              then ready for shipment and sale  after  a final assembly stage, if
              appropriate (i.e.,  attaching table legs  to a  table top).   Exhibit 7
              illustrates the steps of the wood furniture manufacturing process.

                                     Exhibit 7
               Flow Diagram for Wood Furniture  Manufacturing	
    Raw
    Lumber
                                    Interior  [Washcoating |  ™"Q^ s
                                    inishing L   i      I     ^^-^
   Source: Process Flow Diagram for Franklin Furniture of Greeneville, Tennessee found in Pollution Prevention
                         Ovtions in Wood Furniture Manufacturing. 1992.
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III.B.    Raw Material Inputs and Pollution Outputs

            The following discussion of raw material  inputs and  pollution
            outputs is organized along the same lines as the production process
            description.  While there are solid waste and process wastewater
            implications for the wood furniture manufacturing industry, the
            vast majority  of  outputs from this  industry are air emissions
            resulting from the solvent-intensive finishing operations.
IH.B.1.  Drying

            The major emissions of concern from drying the raw lumber using
            wood boilers is particulate matter (PM), although other pollutants,
            particularly carbon monoxide (CO) and organic compounds, may be
            emitted in significant  quantities if the boiler is in poor operating
            condition.  The type and amount of the emissions depend on a
            number of variables, including the composition of the waste fuel
            burned, the degree  of fly ash reinjection employed, and furnace
            design and operating condition.

            The composition of  wood waste depends largely on the industry
            from  which it originates.  Furniture manufacturing generates a
            clean, dry wood waste (e.g., 2 to 20 weight percent moisture)  which
            produces  relatively low particulate emission levels when properly
            burned.  However, other operations, such as pulp manufacturing,
            produce great quantities of bark which may contain a much higher
            weight percent moisture, possibly causing bark  boilers to emit
            considerable particulate matter  to the atmosphere unless they are
            well controlled.

            Furnace design and operating conditions are particularly important
            when firing wood waste.  Because of the high moisture content that
            may be present in wood waste, a larger than usual area of refractory
            surface is often necessary to dry the fuel before combustion. In
            addition, sufficient secondary air must be supplied over the fuel bed
            to burn  the volatiles  that  account for most  of  the combustible
            material in the waste.  When proper drying conditions do not exist,
            or  when  secondary combustion is  incomplete,  the combustion
            temperature is lowered, and  increased PM, CO, and organic
            compound  emissions  may result.   Short-term  emissions can
            fluctuate with significant  variations in fuel moisture content.

            Fly ash reinjection, which is commonly used with larger boilers to
            improve  fuel efficiency, has a considerable effect on PM emissions.
            Because  a fraction of the collected fly  ash is reinjected  into the
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            boiler, the dust loading from the furnace and, consequently, from
            the collection device increase significantly per unit of wood waste
            burned.   More recent boiler  installations typically separate the
            collected particulate into large and small fractions in sand classifiers.
            The smaller particles, mostly inorganic ash and sand, are sent to ash
            disposal.

            The four  most  common  control  devices used  to  reduce  PM
            emissions  from wood-fired boilers  are mechanical collectors,  wet
            scrubbers, electrostatic precipitators (ESPs), and fabric filters.

            Fabric filters  (i.e., baghouses) and  ESPs are  employed when
            collection  efficiencies above 95 percent are required.   However,
            fabric  filters have  had limited applications to wood-fired boilers.
            The principle drawback to fabric filtration, as perceived by potential
            users,  is a fire danger arising from the collection of combustible
            carbonaceous fly ash.  Steps can be taken to reduce this hazard,
            including the installation of a mechanical collector upstream of the
            fabric filter to remove large burning particles of fly ash.

            Emissions of nitrogen oxides  (NOX) from wood-fired boilers are
            lower  than those from coal-fired boilers due to the lower nitrogen
            content of wood and the lower combustion  temperatures which
            characterize wood-fired boilers.

            According to the AFMA document Integrated Waste Management
            Program Applicable to  the On-site  Management of  Certain Non-
            hazardous  Wood Product Finishing  Wastes, dated May 1993, the
            operating temperatures of boilers used by this industry are sufficient
            to adequately  combust the chemical constituents of wood product
            finishing waste (i.e., sawdust mixed with dust  from the various
            coating materials  used in  furniture finishing operations such as
            dried lacquer chips). Based on its interpretation of hazardous waste
            as defined in 40 CFR 261.21(a)(2), the AFMA determined that wood
            product  finishing waste was acceptable for combustion in a boiler.
            The State  of North Carolina Department of Environment, Health,
            and Natural Resources initially disagreed with this interpretation.
            However,  according to the AFMA, the Director of the Division of
            Solid Waste Management, in a March 9, 1994 meeting, approved the
            AFMA's interpretation.
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  LB.2.  Machining
            The primary outputs from the sawing and planing processes are
            wood chips and sawdust, which are used as fuel in boilers for other
            furniture production processes. Wood chips  may also be sold to
            manufacturers of other wood-based products, such as pulp and
            paper mills.  Because no coating materials have been applied to the
            furniture prior to machining, the particles are almost  completely
            composed  of wood, unlike  outputs from later sandings which
            contain particles of finishing material as well as wood particles.
HI.B.3.  Assembly
            Adhesives can be either natural or synthetic in origin and typically
            contain solvents.  Commonly used adhesive formulations contain
            solvents such  as  methyl isobutyl ketone, methyl  ethyl ketone,
            xylene, toluene, and 1,1,1-trichloroethane.  Solvents are also used to
            clean  adhesive  application equipment  such  as  spray guns.
            Adhesives used to apply veneer can differ from adhesives used for
            assembly and  usually include  phenolics, ureas, melamines,
            polyvinyl resin  emulsions,  hot  melts, contacts,  and  mastics.
            Application  of some of the above-mentioned adhesives requires the
            use of heat and/or pressure.  Solvent release  from the use of
            adhesives during assembly  and veneer  application (either  as a
            product carrier or cleaning agent) can be significant.

            According to  a representative of Masco Corporation, the wood
            furniture industry  primarily uses hot melts or polyvinyl acetate
            which do not contain volatile organic compounds  and therefore
            have little or no emissions implications.  Wood chips and sawdust
            are outputs of the sanding  performed  after  the assembly  and
            application of veneer.
HI.B.4. Pre-finishing
            Typical outputs of the pre-finishing steps of the  manufacturing
            process are spent solvents from the derosination process and spent
            bleaching agents from the bleaching process.  Derosination entails
            the application of  ammonia and acetone to  remove the natural
            resin in the wood.  The outputs from this step are, therefore, spent
            ammonia and acetone, as well as  any of the  naturally-occurring
            resin removed by this process.  Bleaching agents typically used by
            the wood furniture industry include hydrogen peroxide, sodium
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            bisulfite, sodium  hyposulfite,  sodium  perborate,  oxalic acid,
            potassium permanganate, and sodium or calcium hypochlorite.
III.B.5.  Coating Application
            In the wood furniture industry, coatings are usually applied in spray
            booths, using various types of spray application equipment.  The
            booths generally do not have any temperature or humidity control,
            and are maintained at ambient conditions. Often, both manual and
            automatic  spray booths are equipped with  dry filters, typically a
            paper material, to control particulates. In the past, water curtains
            had been used to control particulates.  However, since the spent
            water had to be disposed of as a hazardous waste, and as hazardous
            waste disposal costs increased, the cost effectiveness of water curtain
            filtration decreased.  Therefore, most of the new and modified spray
            booths in the wood furniture industry that use filters are equipped
            with dry filters. Some water-wash spray booths are still in use.

            Recirculating  a portion of  the  exhaust from the  spray booth
            increases the  concentration  of VOCs  in the exhaust air leaving the
            spray booth  and discharged to an  end-of-pipe  control system.
            According to  a document  entitled  Demonstration  of Paint Spray
            Booth Air  Recirculation and Flow Partitioning:   Design Validation,
            the concept of recirculation was patented by John Deere Corporation
            in 1979, but a  large segment of the coating  industry mistakenly
            believed that this practice  was prohibited by OSHA regulations.
            During approved recirculation practices, equal portions of fresh  air
            and recirculated air are pumped back  into the booth.  One advantage
            of using recirculation is the  decreased exhaust flow volume emitted
            to the atmosphere and decreased capitol and operating costs of the
            VOC control system.  A joint EPA and U.S. Air Force research and
            development program developed these emissions control concepts
            for hazardous air pollutants (HAPs).

            There are two types of add-on control devices, technologies used to
            capture  pollutants from  point-source air emissions:  combustion
            control devices and recovery devices. Combustion control devices
            are  used to  destroy contaminants, converting them primarily to
            carbon dioxide and water.  Combustion control devices used by the
            furniture industry  include  thermal incineration, with recuperative
            and regenerative heat recovery, and catalytic incineration.

            Recovery  devices  are used  to collect VOCs prior to their  final
            disposition.   One  recovery device is carbon  adsorption used in
            conjunction with regeneration of the carbon bed by steam or hot air.
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            By using either steam  or hot air, the VOCs  may be recovered or
            disposed of following regeneration.

            Thermal incineration is a process by which waste gas is brought to
            adequate temperature, and held at that temperature for a sufficient
            time for the organic compounds in the waste gas to oxidize.

            Catalytic incineration is comparable to thermal incineration in that
            VOCs are heated to  a temperature sufficient for oxidation to occur.
            However, with catalytic incineration, the temperature required for
            oxidation is considerably lower than that required  for  thermal
            incineration because a  catalyst  is used  to promote oxidation of
            contaminants.   Platinum is the  most  widely used catalyst;
            palladium is also commonly used.  Because the metals  used as
            catalysts are expensive, only a thin film is applied to the supporting
            substrate. A commonly used substrate is ceramic.
ffl.B.6.  Finishing
            The primary outputs  of the finishing steps of the manufacturing
            process include solvent emissions to the atmosphere, as well as
            spent solvents, and particles of wood and coating materials applied
            to the furniture.   Solvents or thinners typically used in paints
            include toluene or xylene.  Rubbing and polishing, performed after
            finishing, require the use of materials containing lubricants, such as
            detergents and petroleum-based thin oils, and  abrasives, such as
            pumice, tripoli, and diatomaceous earth.  Because wood  furniture
            finishing  is a  solvent-intensive process, the primary  outputs are
            spent solvents  and solvent emissions.

            Flashoff areas  are areas that are  either between spray booths, or
            between a spray booth and an oven, in which solvent is allowed to
            volatilize from the coated piece.  While some  flashoff areas  have
            forced air circulation  and are referred to as forced-flashoff areas,
            most flashoff areas do not have a separate exhaust.  The  length of
            flashoff areas  varies  significantly by facility,  and even  within a
            facility, depending on  whether the coating will be cured in an oven.
            A flashoff area that is  not followed by an oven  is often longer than
            one that is located in between a booth and an oven.

            Ovens are used between some coating steps to cure the coating  prior
            to the next step in the finishing sequence.  Many types of ovens are
            used in the wood furniture industry. Most are steam-heated using
            either a wood- or coal-fired boiler; others are gas-fired.  Infrared or
            ultraviolet ovens are also used, but their use in the wood furniture
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             industry is limited at this time. Oven temperatures can range from
             less than 38 to 121 degrees Celsius depending on the type of coating
             used, the piece being coated, and  the oven residence time.  The
             exhaust rate from ovens also varies,  and can range between 21.2 and
             425 cubic meters per minute.

             Exhibit 8 contains  the relative VOC emissions for three different
             model plants: a residential furniture manufacturing facility  using a
             long finishing sequence (consisting  of a total of three or more stain
             applications; a single application of wash coat, filler, sealer, and
             highlight;  and two or three  topcoat applications);  a residential
             furniture manufacturing  facility  using a short finishing  sequence
             (consisting of two stain applications, one application  of  washcoat
             and  sealer, and two topcoat applications);  and an off ice/cabinet
             manufacturing facility using a short finishing sequence (consisting
             of one application of stain, sealer, and topcoat).  The relative VOC
             emissions are presented as a percent of each coating applied for each
             model plant.
                                   Exhibit 8
                           Relative VOC Emissions
Type of plant
Stain
Washcoat
Filler
Wiping stain/glaze
Sealer
Highlight
Topcoat
Total
Furniture long
26 percent
4 percent
3 percent
8 percent
18 percent
1 percent
40 percent
100 percent
Furniture short
28 percent
4 percent
...
	 	
32 percent
...
36 percent
100 percent
Office/cabinet
32 percent
.._
...
	
32 percent
...
36 percent
100 percent
          Source: EPA Draft Guidelines for the Control of Volatile Organic Compound Emissions
                         from Wood Furniture Coatin? Operations.
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III.B.7.  Cleanup Operations
            Solvent-borne nitrocellulose lacquers are  the predominant type of
            coatings used by the wood furniture industry today.  The resins in
            such  coatings are relatively "difficult"  to dissolve, so  a high-
            solvency-rated  solvent  must  be  used in  their  formulation.
            Similarly, thinning of these coatings requires the use of the same
            solvent  or one  with  equivalent  solvency.   This  solvent is
            generically referred to as "lacquer thinner."  The current practice is
            to use lacquer thinner for  both incidental thinning of premixed
            coatings and for cleanup of the coatings.  Advantages of the lacquer
            thinner include its compatibility with the finishing materials  and
            the ease with which it removes cured nitrocellulose lacquers.

            In  wood-coating operations,  industrial solvents  are  used
            predominantly for cleaning application equipment.   In addition,
            cleanup solvent can also be used to  clean out piping, clean booths
            and rails, strip cured coatings from wood parts or machinery,  and
            periodically clean centralized  coating  storage  and  distribution
            (pump room) equipment.

            Application equipment must be  cleaned every time there is a color
            change, and usually before the equipment is to be idle for a period of
            time (e.g., at  the end of the day).  For spray  coating application,
            equipment cleaned with solvents includes spray  guns,  feed lines,
            and coating reservoirs (where applicable).  In the case of roll coating
            operations, the rollers and spray bar nozzles  must be  cleaned
            periodically to maintain application quality as well as prior to color
            changes.

            Spray guns have traditionally been cleaned by sending pure solvent
            from the coating reservoir through the  gun, and  atomizing the
            solvent into the booth ventilation system.   Recognizing that  this
            results in significant emissions  of solvent, some operators cut off
            the atomizing air  to the spray gun and pump  the cleanup solvent
            through the gun into a container. This procedure can work if the
            gun is the type that does not depend on  the flow of the atomizing
            air to  pump the coating (or cleanup  solvent)  through  the
            mechanism.   Alternately, cleanup may involve soaking the entire
            gun in solvent.  This  guards  against the possibility  that small
            amounts of coating inadvertently missed during the cleaning  will
            cure and clog the small orifices of the gun. Cleanup solvent is often
            reused  within a facility, and eventually recycled in-house or  sent
            out for recycling/disposal.  Exhibit  9 provides an overview of the
            material inputs and pollution outputs for each  step of the wood
            furniture manufacturing process.
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                                    Exhibit 9
        Inputs and Outputs of Wood Furniture Manufacturing Facilities
Process
Material Input
Air Emissions
Process Wastes
Other Wastes
Drying
Ovens/Drying
Kilns (boilers
covered below)
Raw lumber
Emissions,
including water
and possible
chemicals used in
pretreatment of
raw lumber


Machining
Sawing/Planing/
Sanding
Bending/Drying
(boilers covered
below)
Dried lumber
Lumber
Wood chips,
sawdust
Emissions,
including water
and possible
chemicals used in
pretreatment of
raw lumber
Wood chips,
sawdust

Wood chips,
sawdust

Assembly
Gluing/Veneer
Application
Sanding
Hot melts, polyvinyl
acetate, solvent-
based adhesives (e.g.,
methyl isobutyl
ketone, methyl ethyl
ketone, xylene,
toluene, 1,1,1-
trichloroethane)
Assembled furniture
Solvent emissions
(e.g., methyl
isobutyl ketone,
methyl ethyl
ketone, xylene,
toluene, 1,1,1-
trichloroethane)
Wood chips,
sawdust

Wood chips,
sawdust
Spent solvent-
based adhesives
(e.g., methyl
isobutyl ketone,
methyl ethyl
ketone, xylene,
toluene, 1,1,1-
trichloroethane)
Wood chips,
sawdust
Pre-finishing
Watering/Sanding
Derosination
Assembled furniture,
water, adhesives,
resins
Ammonia, acetone

Solvent emissions
(e.g., acetone)
Wood chips,
sawdust,
adhesive, and
resin particles
Spent acetone,
ammonia,
natural resin
from wood
Wood chips,
sawdust,
adhesive, and
resin particles
Spent acetone,
ammonia,
natural resin
from wood
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                                Exhibit 9 (cont'd)
         Inputs and Outputs of Wood Furniture Manufacturing Facilities
Process
Material Input || Air Emissions
Process Wastes
Other Wastes
Pre-finishing (continued)
Bleaching
Bleaching agents
(e.g., hydrogen
peroxide, sodium
bisulfite, sodium
hyposulfite, sodium
perborate, oxalic
acid, potassium
permanganate,
sodium or calcium
hypochlorite)

Spent bleaching
agents (e.g.,
hydrogen
peroxide, sodium
bisulfite, sodium
hyposulfite,
sodium perborate,
oxalic acid,
potassium
permanganate,
sodium or calcium
hypochlorite)
Spent bleaching
agents (e.g.,
hydrogen
peroxide, sodium
bisulfite, sodium
hyposulfite,
sodium perborate,
oxalic acid,
potassium
permanganate,
sodium or calcium
hypochlorite)
Finishing
Staining
Washcoating
Filling
Mineral spirits,
alcohol, solvents,
pigments (e.g., iron
oxides, lead
chromate, calcium
sulfate, cadmium
selenide)
Nitrocellulose-based
lacquers, acrylic
lacquers, varnish,
shellac,
polyurethane,
solvents
Pigments (e.g., iron
oxides, lead
chromate, calcium
sulfate, cadmium
selenide), stains,
drying oils, synthetic
resins, solvent-based
thinners
Solvent
emissions
Solvent
emissions
Solvent
emissions



Pigment wastes
(e.g., iron oxides,
lead chromate,
calcium sulfate,
cadmium
selenide), solvent
wastes
Spent solvents,
nitrocellulose-
based lacquers,
acrylic lacquers,
varnish, poly-
urethane, and
shellac
Spent solvents,
stains, drying
oils, synthetic
resins, thinners,
and pigments
(e.g., iron oxides,
lead chromate,
calcium sulfate,
cadmium
selenide)
SIC Code 25
32
September 1995

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Sector Notebook Project
                Wood Furniture and Fixtures
                                Exhibit 9 (cont'd)
        Inputs and Outputs of Wood Furniture Manufacturing Facilities
Process || Material Input || Air Emissions
Process Wastes
Solid Wastes
Finishing (continued)
Sealing





Priming

Painting













Topcoat Application






Sanding (occurs
intermittently
between each of the
above finishing
applications)



Rubbing/Polishing




Nitrocellulose-based
lacquers, acrylic
lacquers, varnish,
shellac, solvents,
polyurethane

Fungicide, water-
repellent
Toluene, pigments
(e.g., titanium
dioxide, iron oxides,
lead chromate),
epoxy-ester resins,
aromatic
hydrocarbons, glycol
ether, halogenated
hydrocarbons, vinyl
acetate, acrylic




Denatured alcohols,
resins, shellac,
petroleum distillates,
toluene, disocyanate



Finished piece of
furniture






Lubricants,
detergents,
petroleum-based thin
oils, pumice, tripoli,
diamaceous earth
Solvent
emissions






Solvent
emissions (e.g.,
toluene)











Solvent
emissions (e.g.,
toluene)




Particles that
include wood,
adhesive,
resin,
nitrocellulose
lacquer, paint,
stain, filler,
and sealer


































Particles that
include wood,
adhesive, resin,
nitrocellulose
lacquer, paint,
stain, filler,
and sealer






Spent solvents,
nitrocellulose-
based lacquers,
acrylic lacquers,
varnish, shellac,
polyurethane


Spent solvents
(e.g., toluene),
pigments (e.g.,
titanium dioxide,
iron oxides, lead
chromate),
epoxy-ester
resins, aromatic
hydrocarbons,
glycol ether,
halogenated
hydrocarbons,
vinyl acetate,
acrylic
Spent denatured
alcohols, resins,
shellac,
petroleum
distillates,
toluene,
disocyanate
Particles that
include wood,
adhesive, resin,
nitrocellulose
lacquer, paint,
stain, filler, and
sealer

Spent lubricants,
detergents, oils



September 1995
33
SIC Code 25

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Wood Furniture and Fixtures
                  Sector Notebook Project
                              Exhibit 9 (cont'd)
        Inputs and Outputs of Wood Furniture Manufacturing Facilities
Process
Material Input
Air Emissions
Process Wastes
Solid Wastes
Cleanup Operations
Brush Cleaning/
Spray Gun Cleaning








Boilers
Boilers



Acetone, toluene,
petroleum distillates,
methanol, methylene
chloride,
isopropanol, mineral
spirits, alcohols





Wood and coating
material particulates
from the finishing
process
Solvent
emissions (e.g.,
acetone,
toluene,
methanol,
methylene
chloride)



Spent solvents
(e.g., acetone,
toluene,
methanol,
methylene
chloride),
mineral spirits,
alcohols,
petroleum
distillates
Spent solvents
(e.g., acetone,
toluene,
methanol,
methylene
chloride),
mineral spirits,
alcohols,
petroleum
distillates

Boiler ash
particulates






Boiler ash



            Source: Pollution Prevention Options m Wood Furniture Manufacturing. 1992.
III.C  Management of Chemicals in Wastestream

            The Pollution Prevention Act of 1990  (EPA) requires  facilities to
            report information about the management of TRI chemicals in
            waste and efforts made to eliminate or reduce those quantities.
            These data have been  collected annually in Section 8 of the TRI
            reporting Form R beginning with the 1991 reporting year.  The data
            summarized below cover the years 1992-1995  and is meant to
            provide a basic understanding of the quantities of waste handled by
            the industry, the methods typically used to manage this waste, and
            recent trends in these methods. TRI waste management data can be
            used to assess trends in source reduction within  individual
            industries and  facilities, and for specific TRI  chemicals.   This
            information could  then  be used  as  a  tool  in  identifying
            opportunities  for  pollution prevention compliance assistance
            activities.

            While the quantities  reported for  1992 and 1993 are estimates of
            quantities already managed, the quantities reported for  1994 and
            1995 are projections only.  The EPA requires these projections to
            encourage facilities to consider future waste generation and source
            reduction of those quantities as well as movement up the waste
SIC Code 25
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September 1995

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Sector Notebook Project
               Wood Furniture and Fixtures
            management  hierarchy.     Future-year  estimates   are  not
            commitments that facilities reporting under TRI are required to
            meet.

            Exhibit 10 shows that the furniture and fixtures industry managed
            about 47 million pounds of production-related waste (total quantity
            of TRI chemicals in the waste from routine production operations)
            in 1993 (column B).  Column C reveals  that of this production-
            related waste, 98 percent was either transferred off-site or released to
            the environment.  Column C is calculated  by dividing the total TRI
            transfers  and releases by the total quantity of production-related
            waste.  In other words, about one percent of the industry's TRI
            wastes were managed on-site  through  recycling, energy recovery, or
            treatment as  shown in columns D,  E and F, respectively.   The
            majority  of waste that  is released or transferred  off-site  can be
            divided into portions that are recycled off-site, recovered  for energy
            off-site,  or treated off-site as shown in columns G,  H,  and I,
            respectively.   The  remaining portion of the  production-related
            wastes (90.6 percent), shown in column J, is either released to  the
            environment  through direct discharges to air, land, water, and
            underground injection, or it is disposed off-site.

            From the yearly data presented below  it is  apparent  that the portion
            of TRI wastes reported as recycled on-site  has remained steady and
            the portions treated or managed through energy recovery orv-site
            have decreased slightly between 1992 and 1995 (projected).
                                  Exhibit 10
              Source Reduction and Recycling Activity for SIC 25
A
Year
1992
1993
1994
1995
B
Production
Related
Waste
Volume
(106lbs.)
44
47
44
44
C
% Reported
as Released
and
Transferred
100%
98%
—
—
D

F
On-Site
%
Recycled
0.66%
0.70%
0.76%
0.73%
% Energy
Recovery
0.00%
0.02%
0.00%
0.00%
% Treated
0.57%
0.42%
0.46%
0.46%
G
ii
I
Off-Site
%
Recycled
2.32%
2.38%
2.47%
2.60%
% Energy
Recovery
6.55%
5.10%
4.60%
5.19%
%
Treated
0.90%
0.80%
0.78%
0.72%
J
Remaining
Releases
and
Disposal
89.35%
90.58%
90.93%
90.31%
 September 1995
35
                                                                   SIC Code 25

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Wood Furniture and Fixtures
                  Sector Notebook Project
IV.     CHEMICAL RELEASE AND TRANSFER PROFILE

            This section is designed to provide background information on the
            pollutant releases that are reported by this industry.  The best source
            of comparative pollutant  release information is the Toxic Release
            Inventory System (TRI).  Pursuant to the Emergency Planning and
            Community Right-to-Know Act, TRI includes self-reported facility
            release  and transfer data for over 600 toxic chemicals.  Facilities
            within SIC Codes 20-39 (manufacturing industries)  that have more
            than 10 employees, and  that are above weight-based reporting
            thresholds are required to report TRI on-site releases and off-site
            transfers.  The information presented within the sector notebooks is
            derived from the most recently available (1993) TRI reporting year
            (which then included 316 chemicals), and focuses primarily on the
            on-site  releases reported by  each sector.  Because TRI requires
            consistent reporting regardless of sector, it  is an excellent tool for
            drawing comparisons across industries.

            Although  this  sector notebook does  not  present  historical
            information regarding TRI chemical releases over time, please note
            that in general, toxic chemical releases have been declining. In fact,
            according to the 1993 Toxic Release Inventory Data Book, reported
            releases dropped by 42.7% between 1988 and 1993. Although on-site
            releases have decreased, the total amount of reported toxic waste
            has not declined because the amount of toxic chemicals transferred
            off-site  has increased.  Transfers have increased from 3.7 billion
            pounds in 1991 to 4.7 billion pounds in 1993.  Better management
            practices have led to increases in off-site transfers of toxic chemicals
            for recycling.   More detailed information  can be obtained from
            EPA's annual  Toxics Release  Inventory Public Data Release book
            (which is  available through the EPCRA Hotline at 1-800-535-0202),
            or directly from the Toxic Release Inventory System database (for
            user support call 202-260-1531).

            Wherever possible, the sector notebooks present TRI data as the
            primary indicator of chemical  release within each  industrial
            category.  TRI data provide the type, amount, and media receptor of
            each chemical released or transferred.  When other  sources of
            pollutant  release data have been obtained, these data have  been
            included to augment the TRI information.
SIC Code 25
36
September 1995

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Sector Notebook Project
               Wood Furniture and Fixtures
TRI Data Limitations

            The reader should keep  in  mind  the following limitations
            regarding TRI data.  Within some sectors, the majority of facilities
            are not subject  to TRI  reporting because they are not considered
            manufacturing industries, or because they are below TRI reporting
            thresholds.  Examples are the mining, dry cleaning, printing, and
            transportation equipment cleaning sectors. For these sectors, release
            information from other  sources has been included.

            The reader  should also be aware that TRI "pounds released" data
            presented  within  the  notebooks  is  not equivalent to a  "risk"
            ranking for  each industry.  Weighting each pound of release equally
            does not factor in the relative toxicity  of  each chemical  that is
            released. The Agency is in the process of developing an approach to
            assign toxicological weightings to each chemical released so that one
            can differentiate between pollutants with significant differences in
            toxicity.  As a preliminary indicator of the environmental impact of
            the  industry's most  commonly released chemicals, the notebook
            briefly summarizes  the toxicological properties  of  the top five
            chemicals (by weight) reported by each industry.

Definitions Associated With Section IV Data Tables

General Definitions

            SIC Code — the  Standard Industrial Classification (SIC) is a statistical
            classification standard used for  all establishment-based  Federal
            economic statistics.  The SIC codes facilitate  comparisons between
            facility and industry data.

            TRI Facilities — are manufacturing facilities that have 10 or more
            full-time employees and are above established chemical throughput
            thresholds.   Manufacturing  facilities are defined as facilities  in
            Standard Industrial Classification primary codes 20-39.  Facilities
            must submit  estimates for  all chemicals that  are on the EPA's
            defined list  and  are above throughput  thresholds.

Data Table Column Heading Definitions

            The following  definitions are  based upon standard definitions
            developed  by  EPA's  Toxic Release  Inventory  Program.  The
            categories below represent the possible pollutant destinations that
            can be reported.
September 1995
37
SIC Code 25

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Wood Furniture and Fixtures
                  Sector Notebook Project
            RELEASES — are an on-site discharge of a toxic chemical to the
            environment.  This includes emissions to the air, discharges to
            bodies of water, releases at the facility to land, as well as contained
            disposal into underground injection wells.

            Releases to Air (Point and Fugitive Air Emissions) — Include all air
            emissions from  industry activity.  Point emissions occur through
            confined air streams  as found in stacks, ducts,  or pipes.   Fugitive
            emissions  include losses from equipment leaks, or evaporative
            losses from impoundments, spills, or leaks.

            Releases to  Water (Surface Water Discharges) - encompass any
            releases going directly to streams, rivers, lakes, oceans,  or  other
            bodies  of water.  Any estimates for stormwater runoff  and non-
            point losses must also be included.

            Releases to Land — includes disposal of waste  to on-site  landfills,
            waste  that is land  treated or incorporated  into soil,  surface
            impoundments,  spills, leaks, or waste piles.  These activities must
            occur within the facility's boundaries for inclusion in this category.

            Underground Injection — is a contained release of a fluid into a
            subsurface well for the purpose of waste disposal.

            TRANSFERS — is a transfer of toxic chemicals in wastes to a facility
            that is geographically  or  physically  separate from  the facility
            reporting  under TRI.   The  quantities reported  represent a
            movement of the chemical away from the reporting facility. Except
            for off-site transfers for disposal, these quantities do not necessarily
            represent entry of the chemical into the environment.

            Transfers to POTWs — are wastewaters transferred through pipes or
            sewers to a publicly  owned treatments works (POTW). Treatment
            and chemical removal  depend  on  the  chemical's nature and
            treatment methods used.  Chemicals not treated  or destroyed by the
            POTW are generally  released to surface waters or landfilled within
            the sludge.

            Transfers  to Recycling - are sent off-site for the purposes of
            regenerating  or  recovering still valuable materials.   Once  these
            chemicals have been recycled,  they may  be  returned to  the
            originating facility or sold commercially.

            Transfers  to  Energy Recovery — are wastes combusted  off-site in
            industrial furnaces for energy recovery. Treatment of a chemical by
            incineration is not considered to be  energy recovery.
SIC Code 25
38
September 1995

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Sector Notebook Project
               Wood Furniture and Fixtures
            Transfers to Treatment — are wastes moved off-site  for either
            neutralization,  incineration, biological destruction,  or physical
            separation.   In  some  cases, the chemicals are not destroyed but
            prepared  for further waste management.

            Transfers to Disposal — are wastes taken to another facility for
            disposal  generally as  a  release  to land  or  as  an  injection
            underground.
IV.A.   Toxic Release Inventory for the Wood Furniture and Fixtures
            Industry

            Exhibits 13-15 illustrate the TRI releases and transfers for the entire
            furniture  and fixtures industry  (SIC 25).  For the  industry  as a
            whole,  solvents (such as toluene, methanol, xylene, methyl ethyl
            ketone, and acetone) comprise the largest number of TRI releases.
            The large number  of solvent releases,  both  fugitive and point
            source  emissions,  result from the solvent-intensive finishing
            processes  employed by this industry.  In  addition to being used as
            vehicle carriers,  solvents are  also used to clean the  coatings
            application equipment.

            The TRI database contains a detailed compilation of self-reported,
            facility-specific chemical releases.  The top  reporting facilities for
            this sector are listed below.  Facilities that have reported only the
            SIC codes covered under this notebook appear in Exhibit 11. Exhibit
            12  contains additional facilities  that have reported the SIC code
            covered within this  report, and one or more SIC codes that are not
            within the scope of this notebook.  Therefore,  Exhibit 12 includes
            facilities that conduct multiple operations — some that are under
            the scope of this notebook, and some that are not.   Currently, the
            facility-level data do not allow pollutant releases to be broken apart
            by industrial process.
September 1995
39
SIC Code 25

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Wood Furniture and Fixtures
                     Sector Notebook Project
                                       Exhibit 11
         Top 10 TRI Releasing Furniture Manufacturing Facilities (SIC 25)
Rank
1
2
3
4
5
6
7
8
9
10
Total TRI
Releases in
Founds
1,277,737
831,751
723,669
700,675
688,907
662,695
661,059
642,385
639,345
502,582
Facility Name
Broyhill Furniture Ind., Inc. Complex
Broyhill Furniture Ind., Inc., Lenoir
Furn. & Occas.
Singer Furniture Co.
Korn Ind., Inc.
Lane Co., Inc.
Okla Homer Smith Furniture Co., Inc.
Stanley Furniture Co.
J. D. Bassett Mfg. Co.
Peters-Revington Furniture
Bassett Superior Lines
City
Lenoir
Lenoir
Lenoir
Sumter
Altavista
Fort Smith
Stanleytown
Bassett
Delphi
Bassett
State
NC
NC
NC
sc
VA
AR
VA
VA
IN
VA
                      Source: U.S. EPA, Toxics Release Inventory Database,
                                       Exhibit 12
               Top 10 TRI Releasing Furniture and Fixtures Facilities
SIC Codes
2522, 2542,
2521
2511
2542,2541
2511
2522, 2542,
2521
2511
2511
2511
2511
2511
Total TRI
Releases in
Pounds
1,321,283
1,277,737
939,055
831,751
809,096
723,669
700,675
688,907
662,695
661,059
Facility Name
Steelcase Inc.
Broyhill Furniture Ind.
Complex
Radix, Inc.
Broyhill Furniture Ind., Inc.
Lenoir Furn. & Occas.
Steelcase Inc.
Singer Furniture Co.
Korn Ind., Inc.
Lane Co., Inc.
Okla Homer Smith
Furniture Co., Inc.
Stanley Furniture Co.
City
Grand Rapids
Lenoir
Goodwater
Lenoir
Kentwood
Lenoir
Sumter
Altavista
Fort Smith
Stanleytown
State
MI
NC
AL
NC
NI
NC
SC
VA
AR
VA
                      Source:  U.S. EPA, Toxics Release Inventory Database, WV6.

Note: Being included on  this  list does not mean that the release is associated with  non-compliance
      with environmental laws.
SIC Code 25
40
September 1995

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Sector Notebook Project
                Wood Furniture and Fixtures
                                     Exhibit 13
        TRI Reporting Furniture Manufacturing Facilities (SIC 25) by State
State
AL
AR
AZ
CA
CO
CT
PL
GA
IA
IL
IN
KS
KY
MA
ME
MI
MN
MO
Number of
Facilities
7
8
2
23
2
1
3
5
3
2
27
3
4
6
2
6
5
5
State
MS
NC
NE
NH
NY
OH
OK
OR
PA
SC
TN
UT
VA
VT
WA
WI
wv

Number of
Facilities
3
92
2
1
14
4
2
3
9
5
13
2
32
3
3
10
1

                    Source:  U.S. EPA, Toxics Release Inventory Database, 2933.
                                     Exhibit 14
  Releases for Furniture Manufacturing Facilities (SIC 25) in TRI, by Number
                   Facilities (Releases reported in pounds/year)
                                     of
Chemical Name
Toluene
Methanol
Xylene (Mixed Isomers)
Methyl Ethyl Ketone
Acetone
N-Butyl Alcohol
Methyl Isobutyl Ketone
Glycol Ethers
1,1,1 -Trichloroethane
Ethylbenzene
Isopropyl Alcohol
(Manufacturing)
Dichloromethane
Formaldehyde
Styrene
Di(2-Ethylhexyl) Phthalate
# Facilities
Reporting
Chemical
247
178
174
166
115
99
55
26
25
21
11
6
6
6
4
Fugitive
Air
1456881
908347
742449
439743
282555
151616
206847
68627
262643
120246
9747
102811
30226
2744
255
Point Air
10541044
8166501
5085471
4241878
3157999
2208962
1293417
413901
1334203
241345
278413
43894
1086
42252
12458
Water
Discharges
5
10
5
5
5
5
5
0
0
0
0
0
0
0
0
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
70819
7347
14064
21507
28328
13531
58491
0
4900
0
0
0
0
0
0
Total
Releases
12068749
9082205
5841989
4703133
3468887
2374114
1558760
482528
1601746
361591
288160
146705
31312
44996
12713
Average
Releases
per
Facility
48861
51024
33575
28332
30164
23981
28341
18559
64070
17219
26196
24451
5219
7499
3178
 September 1995
41
                                                                          SIC Code 25

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Wood Furniture and Fixtures
                     Sector Notebook Project
                                 Exhibit 14 (cont'd)
  Releases for Furniture Manufacturing Facilities (SIC 25) in TRI, by Number of
                    Facilities (Releases reported in pounds/year)
Chemical Name
Ethylcnc Glycol
1,2,4-Trimethylbenzene
Trichlorocthylenc
Barium Compounds
Manganese
Melhylenebis
(Phenylisocyanate)
Naphthalene
Aluminum Oxide (Fibrous
Form)
Ammonia
Chromium
Copper
Cumene
Dibutyl Phthalate
Diethyl Sulfatc
Lead
Maleic Anhydride
Nickel
Phenol
Sulfuric Acid
Vinyl Acetate
Totals
# Facilities
Reporting
Chemical
4
4
3
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
313
Fugitive
Air
616
2159
1600
0
251
10
6
11
250
250
250
6
6
869
250
0
250
1
0
1
4,792,523
Point Air
26576
39987
41781
0
3
0
113
224
17000
0
0
114
110
16516
0
0
0
19
0
1163
37,206,430
Water
Discharges
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
40
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
0
0
0
518
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
219,505
Total
Releases
27192
42146
43381
518
254
10
119
235
17250
250
250
120
116
17385
250
0
250
20
0
1164
42,218,498
Average
Releases
per
Facility
6798
10537
14460
259
127
5
60
235
17250
250
250
120
116
17385
250
0
250
20
0
1164
134,883
                     Source: U.S. EPA, Toxics Release Inventory Database, 1993.
SIC Code 25
42
September 1995

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Sector Notebook Project
                 Wood Furniture and Fixtures
                                     Exhibit 15
 Transfers for Furniture Manufacturing Facilities (SIC 25) in TRI, by Number of
                   Facilities (Transfers reported in pounds/year)
Chemical Name
Toluene
Methanol
Xylene (Mixed
Isomers)
Methyl Ethyl Ketone
Acetone
N-Butyl Alcohol
Methyl Isobutyl Ketone
Glycol Ethers
1,1,1 -Trichloroethane
Ethylbenzene
Isopropyl Alcohol
(Manufacturing)
Dichloromethane
Formaldehyde
Styrene
Di(2-Ethylhexyl)
Phthalate
Ethylene Glycol
1,2,4-
Trimethylbenzene ,
Trichloroethylene
Barium Compounds
Manganese
Methylenebis
(Phenylisocyanate)
Naphthalene
Aluminum Oxide
(Fibrous Form)
Ammonia
Chromium
Copper
Cumene
Dibutyl Phthalate
Diethyl Sulfate
Lead
Maleic Anhydride
Nickel
Phenol
Sulfuric Acid
Vinyl Acetate
Totals
# Facilities
Reporting
Chemical
247
178
174
166
115
99
55
26
25
21
11
6
6
6
4
4
4
3
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
313
POTW
Discharges
3737
2114
2869
1540
1030
531
260
0
0
255
499
0
250
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13,085
Disposal
48124
33630
43912
38830

250
1925

5905
31500








750
















204,826
Recycling
400040
162308
83315
176031
281800
40077
7812
7455

17979



8520



1331

















1,186,668
Treatment
117454
25295
43768
57181
33469
26163
67211
1284

165
330
10430




0


















382,750
Energy
Recovery
746458
387147
212406
530621
304307
81491
63094
43794
5608
10363
28509
4000

131
1625

3393


















2,422,947
Total
Transfers
1315821
610494
386270
804953
620606
148762
140552
52533
11513
60262
29338
14430
250
8651
1625
0
3393
1331
750
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4,211,534
Average
Transfers
per
Facility
5327
3430
2220
4849
5397
1503
2555
2021
461
2870
2667
2405
42
1442
406
0
848
444
375
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13,455
                     Source: U.S. EPA, Toxics Release Inventory Database, 1993.
September 1995
43
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Wood Furniture and Fixtures
                   Sector Notebook Project
IV.B.   Summary of the Selected Chemicals Released
             The following is a synopsis of current scientific toxicity and fate
             information for the top chemicals (by weight) that facilities within
             this sector self-reported as released to the environment based upon
             1993 TRI data.  Because this section is based upon self-reported
             release data,  it does  not  attempt to  provide  information on
             management practices employed by the sector to reduce  the release
             of these  chemicals.    Information regarding pollutant release
             reductions over time may be available from EPA's TRI  and 33/50
             programs, or directly from the industrial trade associations that are
             listed in Section IX of this document.  Since these descriptions are
             cursory, please consult the sources referenced below for a more
             detailed description of both the chemicals described in this section,
             and the chemicals that appear on the full list of  TRI  chemicals
             appearing in Section IV.A.

             The brief descriptions provided below were taken  from the 1993
             Toxics  Release  Inventory Public Data Release (U.S.  EPA,  1994), the
             Hazardous Substances Data Bank (HSDB),  and the Integrated Risk
             Information System  (IRIS),  both  accessed via  TOXNET1.  The
             information contained  below  is based upon exposure assumptions
             that have been conducted using standard scientific  procedures. The
             effects listed  below must be taken in context of these exposure
             assumptions that are more fully explained  within  the full chemical
             profiles in HSDB.
1 TOXNET is a computer system run by the National Library of Medicine that includes a number of
toxicological databases managed by EPA, National Cancer Institute, and the National Institute for
Occupational Safety and Health. For more information on TOXNET, contact the TOXNET help line
at 1-800-231-3766. Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research
Information System),  DART (Developmental and Reproductive  Toxicity Database),  DBIR
(Directory of Biotechnology Information Resources), EMICBACK (Environmental Mutagen
Information Center Backfile), GENE-TOX (Genetic  Toxicology), HSDB (Hazardous Substances
Data Bank), IRIS (Integrated Risk Information System),  RTECS (Registry of Toxic Effects of
Chemical Substances),  and TRI (Toxic Chemical Release Inventory). HSDB contains chemical-
specific information on manufacturing and use,  chemical and physical properties,  safety and
handling, toxicity and biomedical effects, pharmacology,  environmental  fate  and exposure
potential, exposure standards and regulations, monitoring and analysis methods, and additional
references.
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               Wood Furniture and Fixtures
Toluene
            The top TRI releases for the furniture and fixtures industry (SIC 25)
            as a whole, include:

            Toluene
            Methanol
            Xylene
            Methyl ethyl ketone
            Acetone
            N-butyl alcohol
            1 1,1-trichloroethane
            Dichloromethane.

            Summaries of some of these chemicals follow.
            Toxicity. Inhalation or ingestion of toluene can cause headaches,
            confusion, weakness, and memory loss.  Toluene may also affect the
            way the kidneys and liver function.

            Reactions of toluene (see environmental fate) in the atmosphere
            contribute  to the formation of ozone in the lower  atmosphere.
            Ozone can  affect the respiratory system,  especially in sensitive
            individuals such as asthma or allergy sufferers.

            Some studies have shown that unborn animals were harmed when
            high levels of toluene were inhaled by their mothers, although the
            same effects were not seen when the mothers were fed large
            quantities of toluene.  Note that these results may reflect similar
            difficulties  in humans.

            Carcinogenicity.  There is currently no evidence to suggest that this
            chemical is carcinogenic.

            Environmental  Fate.  The majority of releases of toluene to land
            and  water will evaporate.   Toluene may also be  degraded by
            microorganisms.  Once volatized, toluene in the lower atmosphere
            will  react with other atmospheric components contributing to the
            formation of ground-level ozone and other air pollutants.

            Physical Properties. Toluene is a volatile organic chemical.
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Wood Furniture and Fixtures
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Methanol
            Toxicity.  Methanol is readily absorbed from the gastrointestinal
            tract and the respiratory tract, and is toxic to humans in moderate to
            high doses.  In the body, methanol is converted into formaldehyde
            and formic acid.  Methanol is excreted as formic acid.  Observed
            toxic effects at high dose levels  generally include central nervous
            system damage and blindness. Long-term exposure to high levels of
            methanol via inhalation cause liver and blood damage in animals.

            Ecologically, methanol is expected to have low toxicity to aquatic
            organisms.   Concentrations lethal  to half the organisms of a test
            population  are expected to exceed 1 mg methanol per liter water.
            Methanol is not likely to persist in water or to bioaccumulate in
            aquatic organisms.

            Carcinogenicity. There is currently no evidence to suggest that this
            chemical is  carcinogenic.

            Environmental  Fate.  Liquid methanol  is likely to evaporate when
            left exposed. Methanol reacts in air to produce formaldehyde which
            contributes  to the formation of air pollutants. In the atmosphere it
            can react with other atmospheric chemicals or be washed out by
            rain.  Methanol is readily degraded by microorganisms in soils and
            surface waters.

            Physical Properties. Methanol is  highly flammable.
Xvlene (Mixed Isomers)
            Toxicity. Xylenes are rapidly absorbed into the body after inhalation,
            ingestion, or skin contact. Short-term exposure of humans to high
            levels of xylenes  can  cause  irritation of the skin, eyes, nose, and
            throat, difficulty  in breathing, impaired  lung function, impaired
            memory, and possible  changes in the liver and  kidneys. Both short-
            and long-term exposure to  high concentrations can  cause effects
            such as headaches,  dizziness, confusion, and  lack  of muscle
            coordination. Reactions of xylenes (see environmental fate) in the
            atmosphere contribute  to the formation of  ozone in the lower
            atmosphere. Ozone can affect the respiratory  system, especially in
            sensitive individuals such as asthma or allergy sufferers.

            Carcino genicity. There is currently no evidence to suggest that this
            chemical is carcinogenic.
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               Wood Furniture and Fixtures
            Environmental Fate.  The majority of releases to land and water
            will  quickly  evaporate,  although   some  degradation  by
            microorganisms will occur.

            Xylenes  are moderately mobile in soils  and  may leach  into
            ground water, where they may persist for several years.

            Xylenes are volatile organic chemicals.  As such, xylenes  in the
            lower atmosphere will react with other atmospheric components,
            contributing to the formation of ground-level ozone and other air
            pollutants.
Methyl Ethvl Ketone
Acetone
            Toxicity.   Breathing moderate amounts of methyl ethyl ketone
            (MEK) for  short periods of time can cause  adverse effects on the
            nervous system ranging from  headaches, dizziness,  nausea, and
            numbness in the fingers and toes to unconsciousness.  Its vapors are
            irritating to the skin, eyes,  nose, and throat and can damage the
            eyes.  Repeated exposure to moderate to high amounts  may cause
            liver and kidney effects.

            Carcinogenicity. No agreement exists over the carcinogenicity  of
            MEK. One source believes MEK is a possible carcinogen in humans
            based on limited animal evidence.  Other sources believe that there
            is  insufficient  evidence to  make any statements about  possible
            carcinogenicity.

            Environmental  Fate. Most of the MEK released to the environment
            will end  up in  the atmosphere.   MEK can  contribute to the
            formation of air pollutants in  the lower atmosphere.  It can be
            degraded by microorganisms living in water and soil.

            Physical Properties. Methyl ethyl ketone is a  flammable liquid.
            Toxicity.   Acetone is irritating  to  the  eyes, nose, and throat.
            Symptoms of exposure to large quantities of acetone may include
            headache, unsteadiness, confusion, lassitude, drowsiness, vomiting,
            and respiratory depression.

            Reactions  of  acetone  (see  environmental fate)  in  the lower
            atmosphere contribute to the formation of ground-level ozone.
            Ozone (a major component of urban smog) can affect the  respiratory
September 1995
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Wood Furniture and Fixtures
                  Sector Notebook Project
            system, especially  in sensitive  individuals such  as  asthmatics or
            allergy sufferers.

            Carcinogenicity.  There is currently no evidence to suggest that this
            chemical is carcinogenic.

            Environmental  Fate.   If released into water, acetone will be
            degraded by microorganisms or will evaporate into the atmosphere.
            Degradation by microorganisms  will  be the primary  removal
            mechanism.

            Acetone is  highly  volatile, and once it reaches the troposphere
            (lower atmosphere), it will react with other gases, contributing to
            the formation of ground-level ozone and other air pollutants. EPA
            is reevaluating acetone's reactivity in  the lower atmosphere to
            determine whether  this contribution is significant.

            Physical  Properties. Acetone is a  volatile  and flammable organic
            chemical.

            Note:  Acetone  was removed from the list of TRI chemicals on June
            16,  1995 (60  FR  31643) and  will  not  be reported for  1994 or
            subsequent years.
1,1,1-Trichloro ethane
            Toxicity. Repeated contact of 1,1,1-trichloroethane (TCE) with skin
            may cause serious skin cracking and infection. Vapors cause a slight
            smarting  of the eyes  or  respiratory system if present in high
            concentrations.

            Exposure to high concentrations of TCE causes reversible mild liver
            and kidney dysfunction, central nervous system depression, gait
            disturbances, stupor, coma, respiratory depression, and even death.
            Exposure to lower concentrations of TCE  leads to light-headedness,
            throat irritation, headache, disequilibrium, impaired coordination,
            drowsiness, convulsions and  mild changes in perception.

            Carcinogenicity. There is currently no evidence to suggest that this
            chemical is carcinogenic.

            Environmental  Fate. Releases of TCE to  surface water or land will
            almost entirely volatilize.  Releases to air may be transported long
            distances and may partially  return to earth in rain.  In the  lower
            atmosphere, TCE degrades  very  slowly by photooxidation and
SIC Code 25
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September 1995

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Sector Notebook. Project
               Wood Furniture and Fixtures
            slowly diffuses to the upper atmosphere where photodegradation is
            rapid.

            Any TCE that does not evaporate from soils leaches to groundwater.
            Degradation in soils and water is slow.  TCE does not hydrolyze in
            water, nor does it significantly bioconcentrate in aquatic organisms.
IV.C.   Other Data Sources
            The Aerometric Information  Retrieval System (AIRS) contains a
            wide range of information related  to  stationary sources  of  air
            pollution, including the emissions of a number of air pollutants
            which may be of concern within a particular  industry.  With the
            exception of volatile organic compounds  (VOCs), there is little
            overlap  with the  TRI  chemicals reported  above.   Exhibit  16
            summarizes annual releases of carbon  monoxide (CO), nitrogen
            dioxide (NC>2), particulate matter of 10 microns or less (PM10), total
            particulates  (FT),  sulfur  dioxide  (SC>2), and volatile organic
            compounds (VOCs).

                                 Exhibit 16
                     Pollutant Releases  (Short Tons/Year)
Industry
U.S. Total
Metal Mining
Nonmetal Mining
Lumber and Wood
Products
Wood Furniture and
Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc. Plastic
Products
Stone, Clay, Glass, and
Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Electronics
Motor Vehicles, Bodies,
Parts, and Accessories
Dry Cleaning
CO
97,208,000
5,391
4,525
123,756
2,069
624,291
8,463
. 166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
367
35,303
101
NO2
23,402,000
28,583
28,804
42,658
2,981
394,448
4,915
108,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
1,129
23,725
179
PMio
45,489,000
39,359
59,305
14,135
2,165
35,579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
207
2,406
3
PT
7,836,000
140,052
167,948
63,761
3,178
113,571
1,031
39,082
44,860
36,877
5,355
171,853
83,017
22,490
3,136
293
12,853
28
SO2
21,888,000
84,222
24,129
9,149
1,606
341,002
1,728
182,189
132,459
648,153
29,364
339,216
238,268
373,007
4,019
453
25,462
152
voc
23,312,000
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
309,058
140,741
30,262
82,292
27,375
102,186
4,854
101,275
7,310
Source U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
September 1995
49
SIC Code 25

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Wood Furniture and Fixtures
                  Sector Notebook Project
IV.D.   Comparison of Toxic Release Inventory Between Selected Industries

            The following information is  presented  as  a  comparison  of
            pollutant release and transfer data across industrial categories.  It is
            provided to give a general sense  as to the relative scale of releases
            and transfers within each sector profiled under this project.  Please
            note that the following table does not contain releases and transfers
            for industrial categories that are  not included in this project, and
            thus cannot be used to draw conclusions regarding the total release
            and transfer amounts that are reported to TRI.  Similar  information
            is available within the annual TRI Public Data Release book.

            Exhibit 17 is a graphical representation of a summary  of the 1993
            TRI data for  the Wood Furniture and Fixtures Industry and  the
            other sectors profiled in separate notebooks.  The bar graph presents
            the  total TRI  releases and total transfers on the left axis and  the
            triangle points show the average releases per facility on the right
            axis. Industry sectors are presented in the order of increasing total
            TRI releases.  The graph is based on the data shown in Exhibit 18
            and is  meant  to  facilitate comparisons  between the relative
            amounts of releases, transfers, and releases per facility  both  within
            and between these sectors. The reader should note, however, that
            differences in the  proportion  of facilities captured by  TRI exist
            between industry sectors.  This can be a factor of poor SIC matching
            and relative differences in the number of facilities reporting  to TRI
            from the various sectors.   In the case of the Wood Furniture and
            Fixtures  Industry, the  1993  TRI data  presented here covers  313
            facilities. These facilities listed SIC 25, Wood  as a primary SIC code.
SIC Code 25
50
September 1995

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Sector Notebook Project
                  Wood Furniture and Fixtures
                  (SUOIJJTUI) spunoj
                            I
                                                                                    .3
September 1995
51
SIC Code 25

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Wood Furniture and Fixtures
                     Sector Notebook Project
















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SIC Code 25
52
September 1995

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Sector Notebook Project
               Wood Furniture and Fixtures
V.      POLLUTION PREVENTION OPPORTUNITIES

            The best way to reduce pollution is to prevent it in the first place.
            Some  companies  have   creatively  implemented  pollution
            prevention techniques that improve efficiency and increase profits
            while at the same time minimizing environmental impacts.  This
            can be done in many ways such as reducing material inputs, re-
            engineering  processes   to   reuse  by-products,  improving
            management  practices, and  employing substitution  of toxic
            chemicals.  Some smaller facilities are able to actually get below
            regulatory  thresholds just by  reducing pollutant releases through
            aggressive  pollution prevention policies.

            In order to encourage these approaches, this section provides both
            general  and company-specific descriptions of some  pollution
            prevention advances that  have been implemented within  the
            Wood  Furniture and Fixtures  industry.  While the  list is  not
            exhaustive, it does provide core information that can be used as the
            starting  point  for facilities interested  in beginning  their  own
            pollution prevention projects.  When possible, this section provides
            information from real activities that can, or are being implemented
            by this sector —  including  a  discussion of associated costs,  time
            frames, and expected rates of return.  This section also provides the
            context (in terms of type of industry and/or type of process affected)
            in which the  pollution prevention  technique can  effectively be
            used.

            The  following  discussion  of pollution  prevention  initiatives is
            based mainly on the EPA  document  Pollution Prevention  Options
            in Wood Furniture Manufacturing and identifies those steps in the
            manufacturing process for which pollution prevention initiatives
            can and  have been implemented. Exhibit 19 provides examples of
            process modification, material substitution, waste reduction, and
            recycling options for finishing and gluing operations.  The  EPA
            document from which this exhibit was developed does not indicate
            the methods used to compute cost savings.
September 1995
53
SIC Code 25

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Wood Furniture and Fixtures
                  Sector Notebook Project
V.A.    Identification of Pollution Prevention Activities in Use and
        Environmental and Economic Benefits of Each Pollution Prevention
        Activity

            Pollution prevention techniques and processes currently used by
            the wood furniture and fixtures industry can be grouped into the
            following general categories:

                  Production planning and sequencing
                  Process or equipment modification
                  Raw material  substitution or elimination
                  Loss prevention and housekeeping
                  Waste segregation and separation
                  Solvent recycling
                  Training and supervision.

            Each of these categories is discussed below briefly. Refer to Exhibit
            19 for specific pollution prevention techniques and associated costs,
            savings, and  other information.

            Production planning  and sequencing is used to ensure that only
            necessary  operations are performed and that no operation is
            needlessly  "undone" by a following operation.  One example is to
            sort out reject  parts prior to  painting or finishing.   A second
            example is to reduce the  frequency of cleaning equipment by
            staining or painting all products of the same color at the same time.
            A third example is to schedule batch processing of lighter shades of
            paint prior to darker shades of paint so that equipment need not be
            cleaned between batches.

            Process  or  equipment modification is used  to reduce the amount of
            waste generated. Manufacturers can change to a paint application
            technique that is more efficient than spray gun systems,  such as
            airless and air-assisted airless systems, electrostatic spray systems, or
            flat line finishing.

            Several technologies currently in the development  stage  could
            potentially  apply  to  the  wood  furniture industry.    These
            technologies  are in  the  areas of  spray booth design and curing
            methods.  The spray booth designs discussed in this section include
            the Classic System Campbell Spray Booth and the Mobile  Zone.
            Both designs seek to reduce the volume of air exhausted.

            Classic  Systems has developed the Campbell spray booth, which the
            company indicates  can  reduce  the  volume of exhaust  air by
SIC Code 25
54
September 1995

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Sector Notebook Project
               Wood Furniture and Fixtures
            approximately 80 percent. The basic design of the Campbell spray
            booth involves the use of air curtains; the worker stands outside of
            the booth and sprays through  the  air  curtain.  The  air curtain
            provides  a barrier between the worker and the solvent emissions
            inside the booth resulting from coating the piece.  A pilot system
            has been built, and a full-scale system has been designed.

            Mobile Zones Associates has developed  a device which,  when
            installed on a spray booth, enables the worker(s) to spray coatings
            from a partially enclosed mobile work platform.  The worker stands
            inside a "cab," the movement of which is controlled from inside the
            cab by the worker.  Within the Mobile Zone cab, fresh ventilating
            air passes across the painter from an  open "moving window" at his
            rear.   The  remaining section of the  mobile  work  platform is
            ventilated using recirculated  air.  The Mobile Zone design contrasts
            with a conventional spray booth, in  which the entire length  of the
            booth is supplied with fresh ventilating air.

            Ultraviolet (UV)-curable  coatings are  frequently used by flatline
            furniture  coating operations.  Since the pieces are flat,  curing in a
            conventional  UV-cure oven is  straightforward.   Although UV-
            curable coatings are also applied to case goods (nonflat pieces), the
            UV-curing process with such pieces is more difficult. In order for a
            UV-curable coating to cure, all coating  must be exposed to the UV-
            light.  The lamps in the UV-oven must be situated  to ensure
            exposure  to all areas  of the case goods, including recessed  areas,
            carvings, etc.  The UV-lamp locations would need to be set for each
            type of case good depending on its configuration.  Because furniture
            manufacturers typically produce many different types of case  goods
            on a single line at any time, realignment of the UV-lamps for each
            type of case  good is not feasible.  However,  if a manufacturer
            produces  a single piece continuously  for a length of time, the  lamps
            could be arranged for that configuration. Then, after the lamps are
            adjusted,. another type of piece could be produced for  a length of
            time.

            Biofiltration is a control technology  which  sends contaminated
            exhaust  air through  a biofilter  for contaminant  removal.  The
            biofilter consists of organic matter, such  as tree bark and compost,
            the pores of which are filled with water.  Biologically active micro-
            organisms are present, partly free-floating  in the water and  partly
            attached to the organic matter.

            Raw  material  substitution or elimination is  the replacement of
            existing raw materials with other materials that produce less waste,
            or a non-toxic waste.  Some examples include substituting water-
September 1995
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SIC Code 25

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Wood Furniture and Fixtures
                  Sector Notebook Project
            based finishes for solvent-based finishes or replacing volatile liquid
            finishes with electrostatically-applied powder finishes.

            Volatile organic compound (VOC) emissions  from wood furniture
            finishing  operations (primarily the hazardous air described  in
            Section IV.B.) can be reduced by reformulating coating materials so
            that they  contain  fewer VOCs.   Currently, in wood furniture
            finishing  operations, VOC  emissions result from the application
            and subsequent evaporation of finishing materials. Efforts are being
            made  to  reformulate  the finishing materials used in the wood
            furniture industry so that they contain fewer VOCs.

            Waterborne finishing materials are currently being used by some
            furniture  manufacturers.   The potential  exists for waterborne
            coatings to be used by all segments of the wood finishing industry.
            However,  the  waterborne coatings currently  available are better
            suited  to certain applications than others. For example:

            •     Open  pore woods are  considered  easier  to finish with
                  waterborne coatings than filled pores

            •     Darker woods sometimes appear cloudy when finished with
                  waterborne coatings, though the clarity has improved over
                  the last ten years

            •     Waterborne  finishes  do  not  have  the  rubbability  of
                  nitrocellulose lacquers and the finish  is therefore not  as
                  glossy where a glossy finish is required

            •     Waterborne coatings may require a modified drying method
                  (increased airflow and temperature).


            Ultraviolet (UV)-curable coatings are currently used  in various
            segments  of the wood finishing industry. UV-curable coatings can
            be applied using spray equipment, roll coaters, or curtain coaters.
            Therefore, the potential exists for UV-curable coatings to  be used on
            case good as well as flat pieces, and progress in this direction has
            been made.  However, as mentioned previously, curing  of  the
            three-dimensional pieces remains difficult because all of  the coating
            materials  must be exposed to the  UV radiation.  Problems arise in
            curing of recessed surfaces that do not get direct exposure to  the
            radiation.  Many studies are being conducted so that UV-curable
            materials may experience more widespread use in the future.

            Polyurethane coatings  are  used in some segments of the wood
            finishing industry.  Polyurethane materials can be spray  applied, or
            applied by curtain or roll coat, and are cured in the conventional
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            manner.  Polyurethane coatings are characterized by a high-gloss
            look, which may not be desirable to certain segments of the wood
            furniture industry.  Other limitations that prevent its widespread
            use include the need for a clean room environment, the short pot
            life (one to six hours), and the difficulty in repairing.

            Polyester coatings are  similar to polyurethanes in their uses and
            their limitations.  The film properties of the polyester coatings are
            good; they provide good build and good chemical, mechanical, and
            heat resistance.  However, application requires a clean room
            environment  which  can be very expensive and difficult  to
            maintain.

            Loss  prevention  and  housekeeping   is  the performance  of
            preventive  maintenance   and  equipment  and  materials
            management so as to minimize opportunities for leaks, spills,
            evaporative losses, and other releases of potentially toxic chemicals.
            For example, spray guns can be cleaned by submerging only the
            front end  of the gun  in the  cleaning  solvent;  or  routine
            maintenance of spray gun equipment can prevent equipment from
            breaking down and leaking.

            Waste segregation and separation involves avoiding the mixture  of
            different types of wastes  and avoiding the mixture of hazardous
            wastes with non-hazardous wastes.  This makes  the  recovery  of
            hazardous wastes easier by minimizing the number  of different
            hazardous  constituents in a  given waste stream.  Also, it prevents
            the contamination of non-hazardous wastes.  Specific  examples
            include segregating spent solvents by solvent types, and segregating
            non-hazardous paint solids from hazardous paint solvents and
            thinner s.

            Solvent  recycling is the use or reuse of a waste as an ingredient  or
            feedstock  in the production process on-site.  Recycling in which a
            waste is recovered and reused in the production process on-site  as
            an input is a form of pollution prevention.  One example is the use
            of a small on-site still to recycle xylene or lacquer thinner.

            Training   and  supervision  provides   employees  with  the
            information and the incentive  to minimize waste generation  in
            their  daily  duties.  This might include ensuring that employees
            know and practice proper and efficient use of tools and supplies,
            and that they are aware of, understand, and support the company's
            pollution prevention goals.
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                                     Exhibit 19
                           Pollution Prevention Matrix
Process
Application
of finish and
pre-finish
coatings
Pollution Prevention Process
Process Modification
Implement alternatives to compressed
air spray gun systems including:
1. Airless and air assisted airless
2. Electrostatic spray systems
3. Flat line finishing
Material Substitution
Substitution of solvent-based inks
with water-based inks
Waste Reduction
Replace water-based paint booth
filters with dry filters. Dry filters
will double paint booth life and allow
more efficient treatment of
wastewater.
Process Modification
Train spray gun operators in proper
spray techniques to minimize coating
waste generation
Economic and Environment
Savings and Benefits
• Material consumption
reduction: 15%
• Annual cost savings:
$55,000
• Waste volume from
spray booth cleanup
reduction: 50%
• Annual cost savings:
$150,000
• Waste savings/
reduction from wiping
stain compared to
conventional spray
units: 25%
• Annual savings in
total coating costs:
20-30%
• Waste savings/
reduction in VOCs:
25%
• Annual cost savings in
raw materials:
$75,000
• Annual cost savings in
disposal costs:
$37,000
• Annual cost savings:
$1,500
• Waste savings/
reductions: 3,000
gallons/year
• Annual cost savings:
$50,000 to $70,000
• Finishing material
required reduction:
8-10%
Payback
Period
Payback
period: 1
year
Payback
period: 2
years
Payback
period: 2
years
Information
not available
Information
not available
Information
not available
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                                Exhibit 19 (cont'd)
                           Pollution Prevention Matrix
Process
Application
of finish and
pre-finish
coatings
(continued)
Pollution Prevention Process
Recycling
Recycle spent solvents with recovery
units including:
1. Small on-site solvent recovery
still to recycle spent lacquer
thinner
2. Small in-house still to recycle
methylene chloride
3. In-house still to recycle xylene
4. Batch distillation unit to recover
xylene from paint equipment
cleaning
5. Batch distillation to recover
isopropyl acetate generated
during equipment cleaning
6. Recovery system for solvents
contained in air emissions
7. Small solvent recovery still to
recover spent paint thinner from
spray gun cleaning and excess
paint batches
Economic and Environment
Savings and Benefits
• Annual cost savings:
$5,700
• Incentive was to
avoid RCRA liability
related to disposal
Information not
available
• Annual savings:
$5,000
Information not available
• Annual savings:
$1,000
• Capital investment
for a 15-gallon
capacity still: $6,000
• Annual savings in new
thinner: $3,600
• Annual disposal
savings: $5,400
• Waste savings/
reduction: 75% (745
gallons of thinner
recovered from 1,003
gallons)
• Product/waste
throughput
information: 1,500
gallons of spent
thinner processed per
year
Payback
Period
Payback
period: 1
year
Payback
period: 2
years
Payback
period: 13
months
Payback
period: 13
months
Payback
period: 2
years
Information
not available
Payback
period: less
than one year
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                             Exhibit 19 (cont'd)
                        Pollution Prevention Matrix
Process
Application
of finish and
pre-finish
coatings
(continued)
Equipment
cleaning
Pollution Prevention Process
8. Solvent recovery system to
recover and reuse spent methyl
ethyl ketone.
Process Modification
Flush equipment first with dirty
solvent before final cleaning with
virgin solvent and use cleanup solvents
in formulation of subsequent batches of
paint
Economic and Environment
Savings and Benefits
• Annual savings:
$43,000
• MEK recovery rate:
20 gallons/day
(reflecting a 90%
reduction in waste)
• Waste savings/
reduction: 98%
• Paint cleanup solvents
reduction: from 25,000
to 400 gallons
Payback
Period
Information
not available
Information
not available
            Source: Pollution Prevention Options in Wood Furniture Manutactunny, 1M2.
V.B.    Pollution Prevention Case Studies

            Henredon Furniture Industries, located in California, applies stains
            and other finishes to chairs,  benches, and a variety of other
            furniture items.   Because the  conventional  spray  guns  that
            Henredon had been using were not meeting current regulations for
            VOC emissions, the  company researched  the feasibility  of high-
            volume low-pressure  (HVLP) spray guns.

            Henredon tested guns by a variety of manufacturers to find those
            that best fit their needs. The HVLP guns ultimately selected operate
            on air pressures from 7 to 10 psi, which is within the definitions set
            by California's South Coast Air Quality Management District.  The
            lower pressure results in less overspray and more efficient use of
            material.

            The new HVLPs  increased  efficiency such that average  material
            usage was reduced by 13  to  15 percent.  Employee  training on
            application techniques was also conducted to improve efficiency.
            The  new guns  improved product  quality without  slowing
            production rates.  Henredon is currently using the HVLP  guns to
            apply lacquers, sealers, and stains at three plant locations.

            Henredon saves  approximately  18,512  gallons  of raw  material
            annually by using the more efficient guns.  These savings equate to
            a reduction in VOC emissions of 126,060 pounds per year.
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            Purchase and installation cost between $350  and $500 per gun.
            Henredon figures to save approximately $119,673 per year in raw
            material usage, for an average payback period of 3.5 months.

            Thomson  Crown Wood Products,  Inc.,  manufactures  wood
            television cabinets.   Parts of these cabinets were sprayed with
            finishing materials by an air-assisted airless spray gun, resulting in
            the production  of VOCs  and a  large paint waste stream.  To
            ameliorate this  problem,  Crown Wood proposed to test high-
            volume low-pressure (HVLP) spray guns and evaluate their success
            in reducing these waste streams.

            Through  in-house, on-line production  testing,  Crown  Wood
            reviewed four different HVLP spray guns using penetrating stain
            (no-wipe), glaze, sap stain, equalizer, toner, shade, and water-based
            black paint.  An  HVLP spray gun manufactured by one company
            gave excellent performance during the penetrating stain and regular
            glaze applications.  This gun was also highly recommended by the
            sprayers for its size, weight, triggering, and cleaning ease.  However,
            because the sprayer did not hold a specific spray pattern very well, it
            could not be used for heavier finishes. Instead, an HVLP spray gun
            manufactured by another manufacturer, which also received good
            ratings by the sprayers, gave much  more consistent coverage and
            spray pattern for  the water-based black, sap stain, equalizer, shade,
            and toner finishes.

            With the new HVLP spray guns, Crown  Wood has experienced
            material reductions of 65 percent for  equalizer, 65 percent for stain,
            54 percent for toner, 35 percent for glaze, 35 percent for no-wipe, and
            53 percent for water-based black finishes.   These reductions total
            over 13,300 gallons per year, which also results in reductions in
            VOCs and paint waste.

            A total of $137,448 per year is the estimated savings from purchasing
            the new spray guns.  Costs associated with paint waste  reduction
            have  not been determined, but  a  reduction  in the amount  of
            clean-up waste was evident. The cost of the project was $21,350.

            In July 1992, Crown Wood  altered  its printing process room to
            incorporate the lay-down or roll-on finishing top and end panels of
            the outside cabinet.  With this process modification, 60 percent of
            the spraying operation is now diverted to the printing room.  Along
            with  paint  waste and  VOC discharges,  this  new  application
            procedure reduced finishing purchases by 50 percent.
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            Ethan  Allen, Inc.,  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.

            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.

            Three  main  components of the coating operation generate  the
            hazardous waste:   overspraying 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.

            •     A fabricated, sloped  polyethylene-lined trough replaced
                  absorbent 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

            •     Polyethylene 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.
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             •      The racks used to transport material on the conveyor system
                   are  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 seven-
                   gallon batch still, which is run  twice daily, recovers five
                   gallons of reusable solvent for every seven gallons of cleanup
                   waste.

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

                                  Exhibit 20
            Ethan Allen Pollution Prevention Case Study Summary
Process
Metal Filters
Lacquer and
Sealer Recycle
Polyethylene
Trough
HVLP Spray
Guns (12 guns @
$250)
Polyethylene
Pallet Covers
Rack Cleaning
Solvent
Distillation
Total
Capitol
Investment, $
7,000
1,500
400
3,000
2,050
200
4,500
$68,650
Waste Reduction,
Ibs/year
10,000
2,300
6,100
Material Use Reduction:
Sap Stain 27%
Sealer 20%
Lacquer 11%
3,700
1,900
1,900
25,900
Savings,
$/year
48,125
6,150
38,430
Material Use Savings:
15,000 to 20,000
7,450
8,250
3,200
$129,465
             Source: North Carolina Department
                              Pollution
of Environment, Health, and Natural Resources
Prevention Program.
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VI.     SUMMARY OF FEDERAL STATUTES AND REGULATIONS

            This section discusses the Federal statutes and regulations that may
            apply to this sector.  The purpose of this section is to highlight, and
            briefly describe the applicable Federal requirements, and to provide
            citations for more  detailed information.   The three following
            sections are included.

            •     Section IV.A contains a general overview of major statutes
            •     Section  IV.B contains a  list of regulations specific to this
                  industry
            •     Section  IV.C  contains  a  list of pending  and proposed
                  regulations

            The  descriptions within Section IV are intended solely for general
            information. Depending upon the nature or scope of the activities
            at a particular facility, these summaries may or may not necessarily
            describe  all applicable environmental requirements.  Moreover,
            they do not constitute formal interpretations or clarifications of the
            statutes and regulations.  For further information,  readers should
            consult the Code  of Federal Regulations  and other state or  local
            regulatory agencies. EPA Hotline contacts are also provided for each
            major statute.
VI.A. General Description of Major Statutes

Resource Conservation And Recovery Act

            The  Resource Conservation And Recovery Act  (RCRA) of 1976
            which amended  the Solid  Waste Disposal Act,  addresses solid
            (Subtitle D) and  hazardous (Subtitle  C) waste management
            activities. The  Hazardous and Solid Waste Amendments (HSWA)
            of 1984 strengthened RCRA's waste management provisions and
            added Subtitle I, which governs underground storage tanks (USTs).

            Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR
            Parts 260-299) establish  a "cradle-to-grave"  system  governing
            hazardous waste from the point of generation to disposal.  RCRA
            hazardous wastes  include the specific  materials  listed  in  the
            regulations  (commercial chemical products, designated with  the
            code "P" or "U"; hazardous wastes from specific industries/sources,
            designated with the code  "K"; or hazardous wastes  from non-
            specific sources, designated with the code "F") or materials which
            exhibit  a hazardous waste  characteristic (ignitibility, corrosivity,
            reactivity, or toxicity and designated with the code "D").
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            Regulated entities that generate hazardous waste are subject to
            waste  accumulation, manifesting, and recordkeeping standards.
            Facilities that treat, store, or dispose of hazardous waste must obtain
            a permit, either from EPA or from a State agency which EPA  has
            authorized  to  implement the  permitting  program.   Subtitle C
            permits contain general facility standards such as contingency plans,
            emergency procedures, recordkeeping and reporting requirements,
            financial assurance  mechanisms, and  unit-specific  standards.
            RCRA also  contains provisions (40 CFR  Part  264  Subpart S and
            §264.10) for  conducting corrective actions which govern the  cleanup
            of releases  of hazardous  waste or constituents from solid waste
            management units at RCRA-regulated facilities.

            Although RCRA  is a Federal statute, many States  implement  the
            RCRA program.   Currently, EPA has delegated its authority to
            implement various provisions of RCRA to 46 of the 50 States.

            Most RCRA requirements  are not industry specific but apply to  any
            company that transports, treats, stores, or disposes of hazardous
            waste. Here are some important RCRA regulatory requirements:

            •     Identification of Solid and Hazardous Wastes (40 CFR Part
                  261) lays out the procedure every generator should follow to
                  determine  whether the  material  created is considered  a
                  hazardous waste, solid waste, or is exempted from regulation.

            •     Standards  for Generators of Hazardous  Waste (40 CFR Part
                  262)  establishes  the  responsibilities of hazardous waste
                  generators including  obtaining an  ID number, preparing a
                  manifest, ensuring  proper packaging and labeling,  meeting
                  standards for waste accumulation units, and recordkeeping
                  and  reporting requirements.   Generators can accumulate
                  hazardous waste for up to 90 days (or 180 days depending on
                  the amount of waste generated) without obtaining a permit.

            •     Land Disposal Restrictions (LDRs) are regulations prohibiting
                  the disposal  of  hazardous waste  on  land without prior
                  treatment.   Under  the LDRs (40 CFR 268),  materials must
                  meet land disposal restriction  (LDR) treatment standards
                  prior to  placement in a  RCRA land disposal unit (landfill,
                  land  treatment unit,  waste pile, or surface  impoundment).
                  Wastes subject to the LDRs include  solvents, electroplating
                  wastes, heavy metals, and acids. Generators of waste subject
                  to the LDRs must  provide  notification of  such to  the
                  designated TSD facility to ensure proper treatment  prior to
                  disposal.
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            •     Used Oil Management Standards (40 CFR Part 279) impose
                  management  requirements  affecting  the   storage,
                  transportation, burning, processing, and re-refining of the
                  used oil.   For parties that  merely  generate  used  oil,
                  regulations establish  storage  standards.   For  a  party
                  considered a used oil marketer (one who generates and sells
                  off-specification used oil  directly to  a used oil  burner),
                  additional tracking and paperwork requirements must be
                  satisfied.

            •     Tanks and Containers used to store hazardous waste with a
                  high  volatile  organic concentration must meet emission
                  standards under RCRA.  Regulations (40 CFR Part 264-265,
                  Subpart CC) require generators to test the waste to determine
                  the concentration of the waste, to satisfy tank  and container
                  emissions standards,  and to inspect and monitor regulated
                  units. These regulations apply to all facilities who store such
                  waste, including generators  operating under the  90-day
                  accumulation rule.

            •     Underground Storage Tanks (USTs) containing  petroleum
                  and hazardous substance are  regulated under Subtitle I of
                  RCRA.  Subtitle I regulations  (40 CFR Part 280) contain tank
                  design  and  release  detection  requirements, as  well  as
                  financial responsibility  and corrective  action  standards for
                  USTs.   The UST  program  also  establishes increasingly
                  stringent  standards,  including upgrade requirements for
                  existing tanks, that must be met by 1998.

            •     Boilers and Industrial Furnaces (BIFs) that use or burn fuel
                  containing hazardous waste must comply with strict design
                  and operating standards. BIF regulations (40 CFR Part 266,
                  Subpart  H)  address  unit design,  provide  performance
                  standards, require emissions monitoring, and restrict the type
                  of waste that may be burned.

            EPA's  RCRA/Superfund/UST Hotline, at (800) 424-9346,  responds
            to   questions  and distributes  guidance  regarding  all  RCRA
            regulations.  The RCRA Hotline operates weekdays from 8:30 a.m.
            to  7:30 p.m., EST,  excluding  Federal holidays.

Comprehensive Environmental Response, Compensation, And  Liability Act

            The Comprehensive Environmental  Response, Compensation, and
            Liability Act (CERCLA), a 1980 law commonly known as Superfund,
            authorizes EPA to respond to releases, or threatened releases, of
            hazardous substances that may endanger public health, welfare, or
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            the environment.  CERCLA also  enables  EPA to force  parties
            responsible for environmental contamination to clean it up or to
            reimburse the Superfund for response costs incurred by EPA.  The
            Superfund Amendments and Reauthorization Act (SARA) of 1986
            revised various sections of CERCLA, extended the taxing authority
            for the Superfund, and created a free-standing law,  SARA Title III,
            also known as the Emergency Planning and Community Right-to-
            Know Act (EPCRA).

            The CERCLA hazardous substance release reporting regulations (40
            CFR Part 302) direct the person in charge of a facility to report to the
            National Response Center (NRC) any environmental release of a
            hazardous substance  which exceeds  a  reportable quantity.
            Reportable quantities are defined and listed in 40 CFR § 302.4. A
            release report may trigger a response by EPA, or by one or more
            Federal or State emergency response authorities.

            EPA implements hazardous substance responses according to
            procedures outlined in the National Oil and Hazardous Substances
            Pollution Contingency Plan  (NCP)  (40 CFR Part 300).  The NCP
            includes provisions for permanent cleanups, known as remedial
            actions, and  other cleanups  referred to  as "removals."   EPA
            generally  takes  remedial  actions only at  sites  on the National
            Priorities List (NPL),  which currently includes approximately 1300
            sites.  Both EPA and states  can act at other sites;  however, EPA
            provides responsible parties the  opportunity to conduct removal
            and remedial actions and encourages  community involvement
            throughout the Superfund response process.

            EPA's RCRA/Superfund/UST Hotline,  at (800)  424-9346, answers
            questions  and references  guidance pertaining  to  the  Superfund
            program.  The CERCLA Hotline operates weekdays from 8:30  a.m. to
            7:30 p.m.,  EST, excluding Federal holidays.

Emergency Planning And Community Right-To-Know Act

            The Superfund Amendments and Reauthorization Act (SARA) of
            1986 created  the Emergency Planning and Community Right-to-
            Know Act (EPCRA, also known as  SARA Title  III), a  statute
            designed  to  improve community access  to information  about
            chemical hazards and to facilitate the development of chemical
            emergency response plans by State and local governments. EPCRA
            required  the establishment of  State  emergency response
            commissions  (SERCs),  responsible  for  coordinating certain
            emergency response activities and for  appointing local emergency
            planning committees (LEPCs).
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            EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish
            four types of reporting  obligations for facilities  which store or
            manage specified chemicals:

                  EPCRA §302 requires facilities to notify the SERC and LEPC of
                  the presence of any "extremely hazardous substance" (the list
                  of such substances is in 40 CFR Part 355, Appendices A and B)
                  if it has such substance in excess of the substance's threshold
                  planning  quantity, and  directs the facility  to  appoint an
                  emergency response coordinator.

            •     EPCRA §304 requires the facility to notify the SERC and the
                  LEPC in  the event of a release exceeding  the reportable
                  quantity  of a CERCLA hazardous substance or an EPCRA
                  extremely hazardous substance.

            •     EPCRA §§311 and  312 require a facility at which a hazardous
                  chemical,  as defined by the Occupational Safety and Health
                  Act, is present in an amount exceeding a specified threshold
                  to submit to the  SERC, LEPC, and  local fire  department
                  material safety data sheets (MSDSs) or lists  of  MSDSs and
                  hazardous chemical inventory forms  (also known as Tier  I
                  and II forms).  This information helps the local  government
                  respond in the event of a spill or release of the chemical.

            •     EPCRA §313  requires manufacturing facilities included in SIC
                  codes 20 through 39, which have ten or more employees, and
                  which manufacture, process, or use specified chemicals in
                  amounts   greater than threshold  quantities, to submit an
                  annual toxic chemical release report.  This report, commonly
                  known as the Form R, covers releases and transfers of toxic
                  chemicals to various facilities and environmental media, and
                  allows EPA to compile the national Toxic Release Inventory
                  (TRI) database.


            All information submitted pursuant to EPCRA  regulations is
            publicly accessible, unless protected by a trade secret claim.

            EPA's EPCRA  Hotline, at (800)  535-0202,  answers questions and
            distributes  guidance  regarding   the  emergency   planning  and
            community  right-to-know  regulations.    The EPCRA  Hotline
            operates  weekdays  from  8:30 a.m.  to  7:30  p.m.,  EST, excluding
            Federal holidays.
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Clean Water Act
            The primary objective of the Federal Water Pollution Control Act,
            commonly referred to as the Clean Water Act (CWA), is to restore
            and maintain the chemical, physical, and biological integrity of the
            nation's  surface  waters.   Pollutants  regulated under the CWA
            include "priority" pollutants, including various  toxic pollutants;
            "conventional" pollutants, such as biochemical  oxygen  demand
            (BOD), total  suspended solids (TSS), fecal coliform, oil and grease,
            and pH;  and  "non-conventional"   pollutants, including  any
            pollutant not identified as either conventional or priority.

            The CWA regulates both direct and indirect discharges.   The
            National Pollutant Discharge Elimination  System (NPE>ES)
            program  (CWA  §402)  controls direct discharges into navigable
            waters.   Direct discharges or "point source" discharges are from
            sources such as pipes and sewers.  NPDES permits, issued by either
            EPA or an authorized State (EPA has presently  authorized forty
            States to  administer the NPDES program), contain industry-specific,
            technology-based and/or water quality-based limits, and establish
            pollutant  monitoring and reporting requirements.  A facility that
            intends to discharge into the nation's waters must obtain a permit
            prior to initiating its discharge. A permit applicant must provide
            quantitative  analytical data identifying the types  of  pollutants
            present in the facility's effluent. The permit will then set forth the
            conditions and  effluent limitations under which a facility may
            make a discharge.

            A NPDES permit may also include discharge limits based on Federal
            or State water quality criteria or standards, that were designed  to
            protect designated uses of surface waters, such as supporting aquatic
            life or recreation.   These standards,  unlike the  technological
            standards,  generally do  not  take  into  account   technological
            feasibility or costs.  Water quality criteria and standards vary from
            State to State, and site to site, depending on the  use classification  of
            the receiving body of water.   Most States  follow EPA guidelines
            which propose aquatic life and human health criteria for many  of
            the 126 priority pollutants.

            Storm Water Discharges

            In 1987 the  CWA was amended  to  require EPA  to  establish a
            program to  address  storm water  discharges.   In response, EPA
            promulgated  the  NPDES  storm  water permit  application
            regulations.   Storm water discharge  associated with industrial
            activity means the discharge from any conveyance which is used for
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            collecting and conveying storm water and which is directly related
            to manufacturing, processing or raw materials storage areas at an
            industrial plant (40 CFR 122.26(b)(14)).  These regulations require
            that facilities with the following storm water discharges apply for a
            NPDES permit: (1) a discharge associated with industrial activity; (2)
            a discharge from a large or medium municipal storm sewer system;
            or (3) a discharge which EPA or the State determines to contribute to
            a violation of a water quality standard or is a significant contributor
            of pollutants to waters of the United States.

            The term "storm water discharge associated with industrial activity"
            means  a storm water discharge  from  one of 11  categories of
            industrial activity defined at 40 CFR 122.26. Six of the categories are
            defined  by SIC codes  while the  other  five are identified through
            narrative descriptions  of the regulated industrial activity.   If the
            primary SIC  code of the facility is one of those identified in the
            regulations,  the  facility is subject  to the  storm water permit
            application requirements. If any activity  at a facility is covered by
            one of the  five narrative categories,  storm water discharges from
            those areas where the activities  occur  are subject to storm  water
            discharge permit application requirements.

            Those facilities/activities that are subject to storm water discharge
            permit  application requirements  are  identified below.    To
            determine whether a particular  facility falls within one of these
            categories, the regulation should be consulted.

            Category i: Facilities subject to  storm water effluent guidelines, new
            source performance standards, or  toxic pollutant effluent standards.

            Category ii: Facilities classified as SIC 24-lumber and wood products
            (except wood kitchen  cabinets); SIC  26-paper and allied products
            (except paperboard containers and  products); SIC 28-chemicals  and
            allied products (except drugs and paints); SIC 29-petroleum refining;
            and SIC 311-leather tanning and finishing.

            Category iii:  Facilities classified as  SIC  10-metal mining; SIC 12-coal
            mining; SIC  13-oil  and gas extraction; and SIC  14-nonmetallic
            mineral mining.

            Category iv:   Hazardous  waste treatment,  storage, or disposal
            facilities.

            Category v: Landfills, land application sites,  and open dumps  that
            receive or have received  industrial wastes.
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            Category vi:  Facilities classified as SIC 5015-used motor vehicle
            parts; and SIC 5093-automotive scrap and waste material recycling
            facilities.

            Category vii:  Steam electric power generating facilities.

            Category viii:  Facilities classified as SIC 40-railroad transportation;
            SIC  41-local  passenger  transportation;  SIC 42-trucking  and
            warehousing (except public warehousing and storage); SIC 43-U.S.
            Postal Service; SIC 44-water transportation; SIC 45-transportation by
            air; and SIC 5171-petroleum bulk storage stations and terminals.

            Category ix: Sewage treatment works.

            Category x: Construction activities  except operations that result in
            the disturbance of less than five acres of total land area.

            Category xi: Facilities classified as SIC 20-food and kindred products;
            SIC 21-tobacco products; SIC 22-textile mill products; SIC 23-apparel
            related products;  SIC 2434-wood kitchen cabinets manufacturing;
            SIC 25-furniture and fixtures; SIC 265-paperboard containers and
            boxes; SIC 267-converted paper and paperboard products; SIC 27-
            printing, publishing,  and allied industries; SIC 283-drugs; SIC 285-
            paints, varnishes, lacquer,  enamels, and allied products; SIC 30-
            rubber and plastics; SIC 31-leather and leather products (except
            leather and tanning and finishing);  SIC  323-glass products; SIC 34-
            fabricated metal products (except fabricated structural metal); SIC 35-
            industrial  and commercial machinery  and computer  equipment;
            SIC 36-electronic and other electrical equipment and components;
            SIC 37-transportation equipment (except ship and boat building and
            repairing);  SIC  38-measuring,  analyzing,  and  controlling
            instruments; SIC 39-miscellaneous  manufacturing industries; and
            SIC 4221-4225-public warehousing and storage.

            Pretreatment Program

            Another type of discharge that is regulated by the  CWA is one that
            goes  to a publicly-owned treatment works (POTWs). The national
            pretreatment program (CWA §307(b)) controls the indirect discharge
            of pollutants to POTWs by "industrial users."  Facilities regulated
            under §307(b) must meet certain pretreatment standards.  The goal
            of the pretreatment program is to protect  municipal  wastewater
            treatment plants from damage that may occur when hazardous,
            toxic, or other wastes are discharged into a sewer system and to
            protect the quality of sludge generated by these plants.  Discharges to
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            a POTW are regulated primarily by the POTW itself, rather than the
            State or EPA.

            EPA has developed technology-based standards for industrial users
            of POTWs.  Different standards apply to existing and new sources
            within  each  category.   "Categorical"  pretreatment  standards
            applicable to an industry on a nationwide basis are developed by
            EPA.  In addition, another kind of pretreatment standard, "local
            limits," are developed by the POTW in order to assist the POTW in
            achieving the effluent limitations in its NPDES permit.

            Regardless of whether a State is authorized to implement either the
            NPDES or  the pretreatment program,  if it develops  its own
            program, it may enforce requirements more stringent than Federal
            standards.

            EPA's  Office of Water,  at (202) 260-5700, will direct  callers with
            questions about the CWA to the appropriate EPA office.   EPA also
            maintains  a bibliographic database of Office of Water  publications
            which  can  be accessed  through  the Ground Water  and  Drinking
            Water resource center, at  (202) 260-7786.
Safe Drinking Water Act
            The Safe Drinking Water Act (SDWA) mandates that EPA establish
            regulations  to  protect human health  from contaminants  in
            drinking water.   The  law authorizes EPA to develop national
            drinking water standards and to create a joint Federal-State system
            to ensure compliance with these standards. The SDWA also directs
            EPA to protect underground sources of drinking water through the
            control of underground injection of liquid wastes.

            EPA  has  developed  primary and secondary  drinking  water
            standards under its SDWA authority.  EPA and authorized States
            enforce  the  primary  drinking  water  standards, which  are,
            contaminant-specific concentration limits  that apply  to certain
            public drinking water supplies.  Primary drinking water standards
            consist of maximum contaminant level goals  (MCLGs), which are
            non-enforceable health-based goals, and maximum contaminant
            levels (MCLs), which are enforceable limits set as close to MCLGs as
            possible, considering cost and feasibility of attainment.

            The SDWA Underground Injection Control (UIC) program (40 CFR
            Parts 144-148) is a  permit program which protects underground
            sources of drinking water by  regulating five classes of injection
            wells.  UIC permits include design, operating,  inspection, and
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               Wood Furniture and Fixtures
            monitoring requirements.  Wells used to inject hazardous wastes
            must also comply with RCRA corrective action standards in order
            to be granted a RCRA permit, and must meet applicable RCRA land
            disposal restrictions  standards.   The  UIC permit  program is
            primarily State-enforced, since EPA has authorized all but a  few
            States to administer the program.

            The  SDWA also provides for a Federally-implemented Sole Source
            Aquifer program, which  prohibits Federal  funds  from  being
            expended on projects  that may contaminate the sole  or principal
            source  of  drinking water for a  given area, and  for  a  State-
            implemented Wellhead Protection program, designed to protect
            drinking water wells and drinking water recharge areas.

            EPA's Safe  Drinking  Water Hotline, at  (800) 426-4791,  answers
            questions and  distributes guidance pertaining to SDWA standards.
            The  Hotline  operates  from 9:00  a.m.  through  5:30  p.m., EST,
            excluding Federal  holidays.
Toxic Substances Control Act
            The Toxic Substances Control Act (TSCA) granted EPA authority to
            create a regulatory framework to collect data on chemicals in order
            to evaluate, assess, mitigate, and control risks which may be posed
            by their manufacture, processing, and use.  TSCA provides a variety
            of control methods to prevent chemicals from posing unreasonable
            risk.

            TSCA standards may apply at any point during a chemical's life
            cycle.   Under TSCA §5, EPA  has established an  inventory of
            chemical substances. If a chemical is not already on the inventory,
            and  has not been excluded by TSCA, a premanufacture notice
            (PMN) must be submitted to EPA prior to manufacture or import.
            The  PMN must identify the chemical and   provide available
            information on health and environmental  effects. If available data
            are not sufficient to evaluate the chemical's effects, EPA can  impose
            restrictions pending  the development of information on its health
            and  environmental effects.  EPA can also restrict significant new
            uses of chemicals based upon factors such as the projected volume
            and use of the chemical.

            Under TSCA §6, EPA can ban the manufacture or distribution in
            commerce, limit the use, require labeling, or place other restrictions
            on chemicals that pose  unreasonable  risks.  Among the chemicals
            EPA regulates under §6 authority are  asbestos,  chlorofluorocarbons
            (CFCs), and poly chlorinated biphenyls (PCBs).
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            EPA's TSCA  Assistance  Information  Service,  at (202) 554-1404,
            answers  questions  and distributes guidance  pertaining  to  Toxic
            Substances Control  Act standards.  The  Service operates from 8:30
            a.m. through 4:30 p.m.,  EST, excluding Federal holidays.
 Clean Air Act
            The Clean Air Act (CAA) and its amendments, including the Clean
            Air Act Amendments (CAAA) of 1990, are designed to "protect and
            enhance the nation's  air resources so as to promote the public
            health and welfare and the productive capacity of the population."
            The CAA consists of six sections, known as Titles, which direct EPA
            to establish national standards for ambient air quality and for EPA
            and the States to implement, maintain, and enforce these standards
            through a  variety  of mechanisms.   Under the CAAA,  many
            facilities will be required to obtain permits for the first time.  State
            and local governments oversee, manage, and enforce many  of the
            requirements of  the CAAA.  CAA  regulations appear at 40 CFR
            Parts 50-99.

            Pursuant to Title I of  the  CAA, EPA has  established  national
            ambient air quality standards (NAAQSs) to limit levels of "criteria
            pollutants," including carbon monoxide,  lead, nitrogen  dioxide,
            particulate matter, ozone, and sulfur dioxide.  Geographic areas that
            meet  NAAQSs for  a given pollutant are classified as attainment
            areas; those that do  not meet NAAQSs are classified  as non-
            attainment areas. Under §110 of the CAA, each State  must develop
            a  State  Implementation Plan  (SIP)  to  identify  sources  of air
            pollution and to determine what reductions are required to meet
            Federal air quality standards.

            Title I also authorizes EPA to establish New  Source Performance
            Standards  (NSPSs),  which are  nationally  uniform  emission
            standards for  new stationary  sources falling within  particular
            industrial  categories.  NSPSs are based  on the pollution control
            technology available to that category of industrial source but allow
            the affected industries the flexibility to devise a cost-effective  means
            of reducing emissions.

            Under  Title I, EPA  establishes and  enforces National  Emission
            Standards for  Hazardous Air  Pollutants (NESHAPs),  nationally
            uniform standards  oriented  towards  controlling particular
            hazardous air  pollutants (HAPs).   Title III  of the CAAA further
            directed EPA to develop a list of sources that emit any of 189  HAPs,
            and to develop regulations for these categories of sources. To date
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                Wood Furniture and Fixtures
            EPA has  listed 174 categories and developed a schedule for the
            establishment of emission standards.  The emission standards will
            be  developed  for  both new  and existing sources  based,  on
            "maximum achievable control technology" (MACT). The MACT is
            defined as the control technology achieving the maximum degree
            of reduction  in the emission of the HAPs, taking into account cost
            and other factors.

            Title II of the CAA pertains to mobile sources, such as cars, trucks,
            buses, and planes.  Reformulated gasoline, automobile pollution
            control devices, and vapor recovery nozzles on gas pumps are a few
            of the mechanisms EPA  uses to regulate mobile air emission
            sources.

            Title IV establishes a sulfur  dioxide emissions program designed  to
            reduce the formation of acid rain.  Reduction of sulfur dioxide
            releases will be obtained by granting to certain  sources limited
            emissions allowances, which, beginning in 1995, will be set below
            previous levels of sulfur  dioxide releases.

            Title V of the CAAA of 1990 created a permit program for all "major
            sources" (and certain other sources) regulated under the CAA.  One
            purpose of the operating permit is to include in a single document
            all air emissions requirements that apply to a given facility. States
            are developing the permit programs in accordance with guidance
            and regulations from EPA.  Once a State program  is approved by
            EPA, permits will be issued and monitored by that State.

            Title VI is intended  to protect stratospheric ozone  by phasing out
            the manufacture of ozone-depleting chemicals and restrict their use
            and distribution.  Production of Class I  substances, including 15
            kinds of chlorofluorocarbons (CFCs), will be phased out entirely by
            the year 2000, while  certain hydrochlorofluorocarbons (HCFCs) will
            be phased out by 2030.

            EPA's  Control  Technology   Center,  at (919)  541-0800, provides
            general  assistance  and  information  on   CAA  standards.    The
            Stratospheric  Ozone Information  Hotline,  at  (800)  296-1996,
            provides general information about regulations promulgated  under
            Title VI of the CAA, and EPA's  EPCRA Hotline, at  (800) 535-0202,
            answers questions  about  accidental release prevention  under  CAA
            §112(r).   In   addition, the  Technology Transfer  Network  Bulletin
            Board System  (modem access  (919) 541-5742)) includes recent  CAA
            rules,  EPA guidance  documents, and updates of EPA activities.
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            Exhibit  21 provides an overview  of  the statues  and  certain
            regulations  applicable  to  the wood furniture  manufacturing
            industry. The information contained in this matrix is based on data
            from  the  American  Furniture  Manufacturers   Association
            document,  Environmental Guide for the Furniture Industry.
                                  Exhibit 21
   Impacts of Environmental Statutes on the Wood Furniture Manufacturing
                                  Industry
Statute &
Section
Drying
(ovens, boilers)
Machining
(sawing,
planing,
sanding)
Assembly
(gluing,
veneer
application)
Pre-finishing/
Finishing
(all coating
applications)
Cleanup/
Shipping
(cleanup,
equipment
maintenance,
warehousing)
Resource Conservation and Recovery Act
Section 6921
(3)(A)
(Hazardous
Waste)
Section 6941
(Solid
Waste)
State /Local
Regulations
Section 6991
(USTs)
Boiler water
treatment
chemicals may
be regulated
Non-hazardous
boiler ash may
be regulated
Underground
fuel tanks may
be regulated
N/A
Wood waste
maybe
regulated
N/A
Unused
commercial
chemical
products may
be regulated
Wood and
adhesive
waste may be
regulated
Adhesive and
solvent under-
ground storage
tanks may be
regulated
Unused
commercial
chemical
products and
potentially
ignitable non-
liquid wastes
are likely to be
regulated
N/A
Solvent under-
ground storage
tanks are
likely to be
regulated
Solvent cleanup
solutions,
burning of
potentially
ignitable
wastes, and
chemical
storage and
spills may be
regulated
Equipment
maintenance
materials may
be regulated
N/A
Comprehensive Environmental Response, Compensation, and Liability Act
CERCLA
N/A
N/A
N/A
Potential spill
and disposal
problems are
likely to occur
Potential spill
and disposal
problems may
occur
                 Source: AFMA Environmental (jUiae for me turmture industry.
 SIC Code 25
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                  Wood Furniture and Fixtures
                                 Exhibit 21 (cont'd)
   Impacts of Environmental Statutes on the Wood Furniture Manufacturing
                                      Industry
Statute &
Section
Drying
(ovens, boilers)
Machining
(sawing,
planing,
sanding)
Assembly
(gluing,
veneer
application)
Pre-finishing/
Finishing
(all coating
applications)
Cleanup/
Shipping
(cleanup,
equipment
maintenance,
warehousing)
Emergency Planning and Community Right-to-Know Act, SARA Title III
Sections
301-303
Section 304
Sections
311-312
Section 313
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Adhesives
maybe
regulated
Adhesives
spills may be
regulated
Adhesives
maybe
regulated
Emissions
from solvent-
based
adhesives
may be
regulated
Finishing
materials are
likely to be
regulated
Finishing
materials
spills are
likely to be
regulated
Finishing
materials are
likely to be
regulated
Hazardous
finishing
materials are
likely to be
regulated
Finishing and
maintenance
materials are
likely to be
regulated
Maintenance
materials
spills may be
regulated
Finishing and
maintenance
materials are
likely to be
regulated
Hazardous
chemical
emissions
disposal may
be regulated
Clean Water Act
Wastewater
Discharge
Permitting
Program
SPCC
Planning
Wastewater
discharge from
boilers,
compressors,
cooling water,
and drying kiln
condensate may
be regulated
N/A
N/A
N/A
Adhesive
wash and
water
discharge
maybe
regulated
Adhesive
management
maybe
regulated
Wastewater
discharge from
water-wash
spray booths
and rag
laundering are
likely to be
regulated
Finishing oil
management is
likely to be
regulated
N/A
Storage and use
of fuels and
lube oils may be
regulated
                   Source: AFMA Environmental Guide for the Furniture Industry.
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                               Exhibit 21 (cont'd)
   Impacts of Environmental Statutes on the Wood Furniture Manufacturing
                                    Industry
Statute &
Section
Drying
(ovens, boilers)
Machining
(sawing,
planing,
sanding)
Assembly
(gluing,
veneer
application)
Pre-finishing/
Finishing
(all coating
applications)
Cleanup/
Shipping
(cleanup,
equipment
maintenance,
warehousing)
Clean Water Act (continued)
Storm Water
Discharge
Permitting
Program
Wood storage
maybe
regulated
Wood
particulates
in runoff are
likely to be
regulated
Adhesive
storage may
be regulated
Finishing
materials
management is
likely to be
regulated
Fuel and
maintenance
chemical
management
and material
storage may be
regulated
Clean Air Act
Section 7411
(NSPS)
Section 7411
(New Source
Review)
Section 7411
(Control
Techniques
Guidelines)
Section 7501
(Nonattain-
ment Areas)
Section 7412
(Hazardous
Air
Pollutants)
Section 7410
(a)(2)
(Operating
Permits
Program)
May apply to
certain boilers
Permit required
before
construction of
new source
N/A
Sources in CO,
SO2, NOX, O3
(VOC), PM10, or
Pb nonattain-
ment areas may
be subject to
additional
requirements
N/A
Permit required
for all major
and certain non-
major sources
N/A
Permit
required
before
construction of
new source
N/A
Sources in
PM10
nonattainmen
t areas may be
subject to
additional
requirements
N/A
Permit
required for
all major and
certain non-
major sources
N/A
Permit
required
before
construction of
new source
N/A
N/A
Currently
being
finalized;
scheduled for
release in
November,
1995
Permit
required for
all major and
certain non-
major sources
N/A
Permit required
before
construction of
new source
Draft form
scheduled for
release in
August, 1995
Sources in O3
(VOC) and
PM10
nonattainment
areas may be
subject to
additional
requirements
Currently being
finalized;
scheduled for
release in
November, 1995
Permit required
for all major
and certain non-
major sources
N/A
Permit required
before
construction of
new source
N/A
N/A
N/A
Permit required
for all major
and certain non-
major sources
 SIC Code 25
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                Wood Furniture and Fixtures
                             Exhibit 21 (cont'd)
   Impacts of Environmental Statutes on the Wood Furniture Manufacturing
                                  Industry
Statute &
Section
Drying
(ovens, boilers)
Machining
(sawing,
planing,
sanding)
Assembly
(gluing,
veneer
application)
Pre-finishing/
Finishing
(all coating
applications)
Cleanup/
Shipping
(cleanup,
equipment
maintenance,
warehousing)
Clean Air Act (continued)
Section 7411
(Enhanced
Monitoring)
Certain boilers
may be subject
to enhanced
monitoring
requirements
depending on
the magnitude
of emissions
Large
operations
may be subject
to enhanced
monitoring
requirements
Sources may
be subject to
enhanced
monitoring
requirements
depending on
the
magnitude of
emissions
Sources may be
subject to
enhanced
monitoring
requirements
depending on
the magnitude
of emissions
N/A-
Spill Reporting
Spill
Reporting
Boiler fuels
maybe
regulated
N/A
Adhesives
and solvents
maybe
regulated
Toxic finishing
materials are
likely to be
regulated
Maintenance
chemicals and
oils may be
regulated
                 Source: AFMA Environmental Guide for the Furniture Industry.
VLB.   Industry-specific Regulatory Requirements

Clean Air Act CCAA)

            The Clean Air Act as amended in 1990 established the basis for the
            EPA to set new requirements for hazardous air pollutants (HAPs)
            that apply to emissions of 189 toxic chemicals listed in the Clean Air
            Act.   EPA  recently proposed  Maximum  Available Control
            Technology  (MACT)  standards  for  the  wood  furniture
            manufacturing industry.

            In addition,  the Agency  is  developing  a  control  techniques
            guideline (CTG) for the industry to reduce the emissions of VOCs.
            While a CTG is not a rule, States generally follow the CTG guidance
            in developing rules  for facilities located in  ozone non-attainment
            areas and the ozone transport region.  A preliminary draft model
            rule containing  a preview  of the reasonably available control
            technologies  (RACT)  that will be recommended in the draft CTG
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            has been made publicly available for the wood furniture industry.
            A more detailed discussion of both the draft CTG and the MACT
            standards can  be found  in  the  following  section pertaining to
            pending regulatory requirements.

            The Economic Incentive Program (EIP) rules, promulgated on April
            7,  1994 (59  FR 16690), provide  general  information  on using
            innovative strategies to meet the Clean Air Act requirements,
            including RACT.  (The RACT applicability threshold for this model
            rule is 10 tons  for a wood furniture facility located in an extreme
            ozone nonattainment area and 25 tons per year for a wood furniture
            facility located in a  marginal, moderate, serious, or severe ozone
            nonattainment area or in the ozone transport region; EPA Method
            24 is used as the basis for evaluating VOC data on coatings). The EIP
            rule contains a range of options for States to use in incorporating
            economic incentives and/or  innovative strategies into their State
            Implementation Plans (SIPs).

Resource Conservation and Recovery Act (RCRA)

            The Resource Conservation and Recovery Act (RCRA) regulates the
            generation,  transportation,  treatment, storage,  and disposal of
            hazardous waste.  Although the furniture industry does not tend to
            generate listed hazardous wastes, it may produce characteristic
            hazardous wastes.  The wood furniture manufacturing industry
            uses many solvents.  Spent  solvents and solvent still bottoms are
            often characterized  as  hazardous wastes.   In addition, furniture
            manufacturing facilities may generate ignitable or toxic  wastes.
            Many wastes generated from the  use of paints, wood treatments,
            stains, varnishes, and adhesives may be ignitable or might fail the
            Toxicity Characteristic Leaching Procedure (TCLP) test.

            If a facility generates 100 kilograms or more of hazardous waste (or
            one kilogram of acutely hazardous waste)  per month, it may be
            subject to accumulation time limits, storage restrictions,  personnel
            training requirements, manifesting, and land disposal restrictions
            for these wastes.

Emergency Planning and Community Right-to-Know Act (EPCRA)

            Furniture manufacturers may store extremely hazardous substances
            (EHS) and hazardous chemicals. If so, facilities would be subject to
            the  emergency  planning  and  hazardous chemical   inventory
            provisions of  EPCRA.   If  they  release an  EHS  or  a CERCLA
            hazardous substance such as toluene or acetone, they may need to
            report it under the emergency release reporting requirements of
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               Wood Furniture and Fixtures
            SARA Title III. The Toxic Chemical Release Inventory affects only
            relatively large furniture companies that use toxic chemicals, such
            as toluene disocyanate or methylene chloride, above 10,000 pounds
            annually.
Clean Water Act (CWA)
            The  Clean Water Act (CWA)  regulates  discharges of various
            pollutants into the surface waters of the U.S. or to publicly owned
            treatment works (POTWs).  The  effluent provisions of 40 CFR Part
            429,  Subpart L,  regulate facilities which conduct wood finishing
            activities such as staining and dipping, and  require that sources not
            discharge untreated process wastewater into navigable waters.

            CWA regulations also regulate wood furniture manufacturers both
            with water wash spray booths (40 CFR Part 429, Subpart P) and
            without wash spray booths (40 CFR 429 Subpart O). Both Subparts
            require that sources not discharge process wastewater pollutants
            directly into  navigable waters.   Both effluent limitations greatly
            restrict the amount of effluent from process  wastewaters which may
            be released into POTWs and require monitoring and recordkeeping
            activities.    For sources  discharging  to POTWs,  Subpart  P
            requirements are similar to those in Subpart O with the exception
            that pH levels and levels of solids that settle are regulated for the
            best practicable technology requirements.
VI.C.   Pending and Proposed Regulatory Requirements

            Information contained in this section was  obtained from the Fact
            Sheet on  the Proposed MACT and CTG for  the  Wood  Furniture
            Finishing Industry developed and distributed by the Small Business
            Ombudsman of North Carolina.  The Clean Air Act as amended in
            1990 established the basis for the EPA to set new requirements for
            HAPs and to develop control techniques guidance  (CTG) to reduce
            VOC emissions.  The  EPA recently proposed a MACT standard for
            the wood furniture manufacturing industry, which applies  to 189
            toxic chemicals listed  in the Clean Air Act as HAPs. To help States
            meet the ambient air quality standard for ozone, the Agency is also
            developing a CTG for  the industry to reduce emissions  of VOCs.

            The  MACT and CTG are concerned with two different types of
            emissions.  The MACT will regulate emissions of HAPs from all
            wood furniture surface coating  operations nationwide.  The CTG
            will address emissions of VOCs from wood furniture  finishing,
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            cleaning, and washoff operations at facilities located in ozone non-
            attainment areas or in the ozone transport region.

            The MACT  standard will apply to  "major sources" in the wood
            furniture  manufacturing industry.  A major source is one  that
            emits or has the potential to emit  10  tons per year (tpy) of an
            individual HAP or 25 tpy of a combination of HAPs per year.  The
            recommended application of the CTG is for sources that emit or
            have the  potential to  emit  10 tpy of VOCs in an extreme non-
            attainment area and 25 tpy per year of VOCs in any other ozone
            non-attainment area and in the ozone transport region.

            Sources using or agreeing to use no more that 250 total gallons per
            month,  or 3,000 gallons per rolling 12-month period, of finishing,
            contact adhesives, and cleaning materials are not major sources and
            are exempted from the MACT standard.

            The MACT standard proposes  numerical emission limits  for surface
            coating operations including finishing, gluing, and peelable spray
            booth coating.  Finishes include stains, washcoats, basecoats, fillers,
            sealers, glazes, highlighters,  enamels, and topcoats.   The CTG
            preliminary  draft proposes numeric emissions limits for finishing
            and cleaning operations and for strippable booth coatings.

            In addition  to numeric emissions limits, the MACT standard and
            CTG propose work practice standards  that include inspection and
            maintenance of equipment,  good housekeeping practices such as
            closed tops on solvent and mixing containers, procedures to account
            for solvent use, and some limitations  on the use  of conventional
            air spray guns, promoting the use of more efficient spray guns.

            A source may be affected by both the MACT and CTG. For example,
            if a wood furniture manufacturer  is located  in  an ozone non-
            attainment area, uses VOCs and potentially emits greater than 25
            tons per year of total  VOC emissions, and is a major  source for
            HAPs, the facility would be subject to both requirements.

            The following  implementation/compliance  schedule  is proposed
            with respect to the MACT and CTG:

            •     A preliminary  draft  model rule to reduce VOCs  was
                  distributed to  State and  local air agencies in June  1994.  This
                  preliminary rule contains emission limits based on RACT for
                  reducing VOCs.  RACT  requirements may vary among states
                  and local governments as  some will  set  more stringent
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                  requirements  to accommodate their specific  air  quality
                  problems.

            •     Under a court-ordered  deadline, the MACT standard  was
                  proposed November 21,  1994.   November  1995 is  the
                  scheduled date for final adoption.

            •     Sources emitting more than 50  tpy of HAPs will have until
                  November 21, 1997 to comply with the final rule.

            •     Sources  emitting less  than 50  tpy of  HAPs  will have
                  approximately three years to comply with the final rule. This
                  date will probably be November  1998.

            Compliance  with the  MACT standard  can be  achieved with
            compliant coatings; that is, either non-HAP coatings or those
            meeting the limits, such as 1.0 Ib of HAP per pound of solid. High-
            solids coatings and water-based  coatings have  fewer VOCs  and
            HAPs, and are becoming more readily available.  Although add-on
            control may  also be used  to meet the standards, the use of  less
            solvent and fewer toxics in coatings and finishes is likely to be the
            route most manufacturers  take towards compliance (and may be
            more economical).

            The basis for  the recommended standards for finishing operations is
            the  use  of  low-HAP materials  or control  devices such  as
            incinerators.  For cleaning  operations, the standards are based on
            use of low-VOC strippable coatings for spray booths.

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

            Exhibits 22 and 23 provide an overview of the proposed MACT
            emissions  limits and work practice standards for the MACT and
            CTG. This information was obtained from the Fact Sheet on the
            Proposed MACT and  CTG for  the  Wood  Furniture Finishing
            Industry.
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                                           Exhibit 22
                      Summary of Proposed MACT Emission Limit
Emission Point
Finishing Operations
(1) Achieve a weighted average HAP content across all
coatings (maximum Ib VHAP/lb solids)
(2) Use compliant finishing materials (maximum Ib
VHAP/lb solids)
- stains
- washcoats
- sealers
- topcoats
- basecoats
- enamels
- thinners (maximum percent HAP allowable)
(3) As an alternative, use add-on control device
(4) Use a combination of (2) and (3)
Cleaning Operations
Strippable spray booth material (max VHAP content = Ib
VOC/lb solids)
Contact Adhesive Operations
(1) Use compliant contact adhesives (max VHAP content, as
applied (Ib VHAP/lb solids)
(i) For foam adhesives used in products that meet
flammability requirements
(ii) For all other adhesives (including foam adhesives
used in products not meeting flammability
requirements); or
(2) Use a control device
Existing
Source

1.0a

1.0a
1.0a'b
1.0a
1.0a
1.0a'b
1.0a'b
10.0
1.0C
1.0

0.8


1.8
1.0
1.0d
New Source

0.8a

1.0a
0.8a'b
0.8a
0.8a
0.8a'b
0.8a'b
10.0
0.8C
0.8

0.8


0.2
0.2
0.2d
         Source: Fact Sheet on the Proposed MACT and CTGfor the Wood Furniture Hmsmng industry.

a  The limits refer to the HAP content of the coating as applied.
b  Compliant washcoats, basecoats, and enamels must be used if they are purchased premade; that is, they are not
   formulated on-site by thinning other finishing materials. If they are formulated on-site, they must be formulated
   with compliant finishing materials and thinners containing no more than three percent HAP by weight.
c  The control device must operate at an efficiency equivalent to no greater than 1.0 Ibs. (or 0.8 Ibs.) of HAP being
   emitted from the affected emission  source per pound of solids used.
d  The control device must operate at an efficiency that is equivalent to no more than 1.0 Ibs. Volatile HAP
   (VHAP) emitted from the affected emission point per pound of solids used.
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                    Wood Furniture and Fixtures
                                          Exhibit 23
      Summary of Work Practice Standards for the Proposed MACT and CTG
Emission Source
Finishing Operations
Transfer Equipment Leaks
Storage containers
including mixing
equipment
Application equipment
Finishing materials
Work Practice

• Develop written inspection and maintenance plan to address and
repair leaks. The plan must identify a minimum inspection
frequency of one per month and procedures for addressing
malfunctions.
• When such containers are used for VOC- or HAP-containing
materials, keep covered when not in use.
• Limit use of conventional air spray guns and encourage .use of more
efficient technology.
• Demonstrate usage of HAPs of potential concern have not
increased except as allowed by the standards; document in the
formulation assessment (MACT only).
Cleaning Operations
Gun/line cleaning
Spray booth cleaning
Wash-off tanks/ general
cleaning
• Collect cleaning solvent into a closed container.
• Cover all containers associated with cleaning when not in use.
• Do not use solvents unless cleaning conveyors or metal filters.
• Do not use chemicals that are known, probable, or possible
carcinogens, as identified in section 112(g), in concentrations
subject to MSDS reporting, as required by OSHA (MACT only).
• Keep wash tank covered when not in use.
• Minimize dragout by tilting and/or rotating part to drain as
much solvent as possible and allowing sufficient time to dry.
• Maintain log of the quantity ^and type of solvent used for .
washoff cleaning as well as the quantity of waste shipped off
site and the fate of this waste (recycling or disposal).
• Maintain a log of the number of pieces washed off and the reason
for washoff.
Miscellaneous
Operator training
Implementation plan
• All operators shall be trained on proper application, cleanup,
and equipment use.
• The training program shall be written and retained on site.
• Develop a plan to implement work practice standards.
• Maintain plan on site.
         Source:  Fact Sheet on the Proposed MACT and CTG for the Wood Furniture Finishing Industry.

The work practice standards apply to both existing and new major sources. Air guns will be allowed only in the
following instances:
           when used in conjunction with coatings less than 1.0 Ib. VOC/lb. of solids
           for touch up and repair under limitedconditions
           when spray is automated
           when add-on controls are used
           if the cumulative application is less than 5 percent of total gallons of coating applied.
           if the permitting agency determines other application technology is economically or technically
           unfeasible.
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VII.    COMPLIANCE AND ENFORCEMENT HISTORY

Background

            To  date, EPA has focused much of its attention on measuring
            compliance with specific environmental statutes.   This approach
            allows the  Agency to track compliance with the Clean Air Act, the
            Resource Conservation and Recovery Act, the Clean Water Act, and
            other environmental statutes.  Within the last several years, the
            Agency has  begun to  supplement single-media  compliance
            indicators  with  facility-specific,  multimedia   indicators  of
            compliance.   In doing so, EPA is in a better  position to  track
            compliance with all statutes at the facility level, and within specific
            industrial sectors.

            A major step  in building the capacity to compile multimedia data
            for industrial  sectors was the creation of EPA's Integrated Data for
            Enforcement Analysis (IDEA) system.  IDEA has  the capacity to
            "read into" the Agency's single-media databases, extract compliance
            records, and match the records to  individual facilities.  The IDEA
            system can match Air, Water, Waste, Toxics/Pesticides/EPCRA,
            TRI, and Enforcement Docket  records for  a given  facility, and
            generate a list of historical permit,  inspection, and  enforcement
            activity. IDEA also has the capability to analyze data by geographic
            area and corporate holder. As the  capacity to generate multimedia
            compliance data improves, EPA will make available more in-depth
            compliance and enforcement information.  Additionally, sector-
            specific measures of success for compliance assistance efforts are
            under development.

Compliance and Enforcement Profile Description

            Using inspection, violation, and  enforcement data from the IDEA
            system, this section provides information regarding the historical
            compliance and enforcement activity of this  sector.   In order to
            mirror the facility universe reported in the Toxic Chemical Profile,
            the data reported within  this section consists of  records only from
            the TRI reporting  universe.  With  this decision, the selection
            criteria are consistent across sectors with certain exceptions.  For the
            sectors that do not normally report to the TRI program, data have
            been provided from EPA's Facility  Indexing System (FINDS) which
            tracks facilities in all media databases. Please note, in this section,
            EPA does  not attempt to  define the actual number of  facilities that
            fall within  each sector.  Instead, the section portrays the records of a
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             subset of facilities within the sector that are well defined within
             EPA databases.

             As a  check on the relative size of the full sector universe, most
             notebooks contain  an estimated number of facilities within the
             sector according  to the Bureau of Census (See Section II).  With
             sectors dominated by small businesses, such as  metal finishers and
             printers, the reporting universe within the EPA databases may be
             small  in comparison to Census data. However, the group selected
             for inclusion in this data analysis section should be consistent with
             this sector's general make-up.

             Following this introduction is  a list defining  each data column
             presented within  this  section.    These values represent  a
             retrospective summary of inspections and enforcement actions, and
             solely reflect EPA, State, and local compliance  assurance  activities
             that have been entered into EPA databases. To identify any changes
             in trends,  the EPA ran  two data queries,  one for the past five
             calendar years (August 10, 1990 to August 9, 1995) and the  other for
             the most recent twelve-month period (August 10, 1994 to August 9,
             1995).   The five-year analysis gives an average  level of activity for
             that period for comparison to the more recent activity.

             Because most inspections focus  on single-media requirements, the
             data queries presented in this section are taken from single media
             databases.  These  databases do not  provide  data on  whether
             inspections are State/local or EPA-led. However, the table  breaking
             down  the  universe of violations  does give the  reader  a crude
             measurement of the EPA's and States' efforts  within each media
             program.  The presented data illustrate the variations across regions
             for  certain sectors.2    This  variation may  be attributable  to
             State/local data entry  variations, specific geographic concentrations,
             proximity to population centers, sensitive ecosystems, highly toxic
             chemicals used in production, or historical noncompliance. Hence,
             the exhibited data do  not rank regional performance or necessarily
             reflect which regions may have the most compliance problems.
2  EPA Regions include the following States: 1 (CT, MA, ME, RI, NH, VT); 2 (NJ, NY, PR, VI); 3
(DC, DE, MD, PA, VA, WV); 4 (AL, FL, GA, KY, MS, NC, SC, TN); 5 (IL, IN, MI, MN, OH, WI); 6
(AR, LA, MM, OK, TX); 7 (IA, KS, MO, NE); 8 (CO, MT, ND, SD, UT, WY); 9 (AZ, CA, HI, NV,
Pacific Trust Territories); 10 (AK, ID, OR, WA).
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Compliance and Enforcement Data Definitions

General Definitions

            Facility Indexing System (FINDS) — this system assigns a common
            facility number to EPA single-media permit records.  The FINDS
            identification number allows EPA to compile and review all permit,
            compliance, enforcement, and pollutant release data for any given
            regulated facility.
            Integrated  Data for Enforcement  Analysis  (IDEA) —  is a data
            integration  system that  can  retrieve information from the major
            EPA program office databases.  IDEA uses the FINDS identification
            number  to  "glue together" separate data  records from EPA's
            databases.  This is done to create a "master list" of data records for
            any given facility.  Some of the data systems accessible through
            IDEA are: AIRS (Air Facility Indexing and Retrieval System, Office
            of Air and Radiation), PCS (Permit  Compliance System,  Office of
            Water), RCRIS (Resource Conservation and Recovery  Information
            System, Office of Solid Waste), NCDB (National  Compliance Data
            Base, Office of Prevention,  Pesticides,  and  Toxic Substances),
            CERCLIS   (Comprehensive   Environmental   and  Liability
            Information System, Superfund),  and  TRIS  (Toxic  Release
            Inventory System).  IDEA  also contains information from outside
            sources such as Dun and  Bradstreet and the Occupational Safety and
            Health Administration (OSHA).  Most data queries displayed in
            notebook Sections IV and VII were conducted using IDEA.

Data Table Column Heading Definitions

            Facilities in Search - are based on the universe of TRI  reporters
            within the listed SIC code range. For industries not covered under
            TRI reporting requirements, the notebook uses the FINDS universe
            for executing data queries.  The SIC code range selected for each
            search is defined by each notebook's selected SIC  code  coverage
            described in Section n.

            Facilities Inspected — indicates the level of EPA and State agency
            facility inspections for the facilities in this data search. These values
            show what percentage of the facility universe is inspected in a 12 or
            60  month period.  This column does not count non-inspectional
            compliance  activities such  as  the review  of facility-reported
            discharge reports.

            Number of Inspections  — measures  the total number of inspections
            conducted in this sector. An inspection event is counted each time
            it is entered into a single  media database.
 SIC Code 25
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            Average Time Between Inspections — provides an average length of
            time, expressed in months, that a compliance inspection occurs at a
            facility within the defined universe.

            Facilities with One or More Enforcement Actions ~ expresses the
            number  of facilities that were party to at least  one enforcement
            action  within the defined time period.  This category is broken
            down further into Federal and State actions.  Data are obtained for
            administrative, civil/judicial, and criminal enforcement actions.
            Administrative actions include Notices of Violation (NOVs).  A
            facility with  multiple enforcement actions is only counted once in
            this  column (facility with 3 enforcement actions counts  as 1).  All
            percentages that  appear are referenced to the number of facilities
            inspected.

            Total  Enforcement Actions  ~  describes  the total number  of
            enforcement  actions identified for an industrial  sector across all
            environmental statutes.   A  facility with multiple enforcement
            actions  is counted multiple  times (a facility with  3 enforcement
            actions counts as 3).

            State Lead  Actions  — shows  what percentage  of  the  total
            enforcement  actions are taken by State and local  environmental
            agencies.  Varying levels of use by States of EPA data systems may
            limit the volume of actions  accorded State enforcement activity.
            Some States extensively report enforcement activities into EPA data
            systems, while other States may use their own data systems.

            Federal  Lead Actions ~ shows what percentage  of the total
            enforcement actions are taken by the U.S. EPA. This value includes
            referrals from State agencies.  Many of these actions result from
            coordinated or joint State/Federal efforts.

            Enforcement to Inspection Rate — expresses how often enforcement
            actions result from inspections. This value is a ratio  of enforcement
            actions to inspections, and is presented for comparative purposes
            only. This measure is a rough indicator of the relationship between
            inspections and  enforcement.   This measure  simply  indicates
            historically how  many enforcement actions can be attributed  to
            inspection activity.  Related inspections  and enforcement actions
            under the Clean Water Act (PCS), the Clean Air Act (APS) and the
            Resource Conservation  and Recovery Act  (RCRA) are included in
            this  ratio.  Inspections and actions from the TSCA/FIFRA/EPCRA
            database are  not factored into this ratio because most of the actions
            taken under these programs are not the result of facility inspections.
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            This ratio does not account for enforcement  actions arising from
            non-inspection compliance monitoring activities (e.g., self-reported
            water discharges) that can result in enforcement action within the
            CAA, CWA and RCRA.

            Facilities with One or More Violations Identified — indicates the
            number  and percentage of inspected facilities having a violation
            identified in one of the following data categories:  In  Violation or
            Significant  Violation Status (CAA);  Reportable Noncompliance,
            Current  Year Noncompliance,  Significant Noncompliance (CWA);
            Noncompliance  and Significant Noncompliance (FIFRA, TSCA,
            and EPCRA); Unresolved Violation and Unresolved High Priority
            Violation (RCRA).   The values presented for this column reflect the
            extent of noncompliance within the measured time frame, but  do
            not  distinguish  between  the severity of the noncompliance.
            Percentages within this column can exceed  100 percent because
            facilities can be  in violation status  without being inspected.
            Violation status  may be  a  precursor to an enforcement action, but
            does not necessarily indicate that an enforcement action will occur.

            Media Breakdown of Enforcement Actions and Inspections — four
            columns identify  the  proportion   of total inspections  and
            enforcement actions  within EPA  Air, Water,  Waste,  and
            TSCA/FIFRA/EPCRA databases.  Each column is a percentage of
            either the "Total Inspections," or the "Total Actions" column.
VILA.  Furniture and Fixtures Industry Compliance History

            Exhibit  24 provides  a Regional breakdown of the  five  year
            enforcement  and  compliance  activities  for  the furniture and
            fixtures industry. Region IV conducted approximately 68 percent of
            the inspections of furniture manufacturing facilities performed in
            the United States.  This large percentage is due to the concentration
            of furniture manufacturers in the Southeastern U.S., specifically in
            North Carolina.
SIC Code 25
90
September 1995

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Sector Notebook Project
                   Wood Furniture and Fixtures






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91
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Wood Furniture and Fixtures
                  Sector Notebook Project
VII.B.       Comparison of Enforcement Activity Between Selected
            Industries

            Exhibits 25-28  contain summaries  of the  one and five year
            enforcement  and compliance  activities for  the  furniture and
            fixtures industry, as well  as for other selected industries.  As
            indicated in Exhibits 25 and 26,  the furniture and fixtures industry
            has  a low  enforcement  to inspection rate  compared  to  other
            industries.  Exhibits 27 and 28 provide a breakdown of inspection
            and  enforcement activities  by statute.  Of all the  furniture and
            fixtures  industry inspections,  approximately 52  percent  were
            performed under the Clean Air Act, while approximately 45 percent
            were conduced under RCRA. The large percentages of CAA and
            RCRA inspections for this industry are due to the VOC emissions
            and  spent finishing materials resulting from the solvent  intensive
            processes used by this industry.
SIC Code 25
92
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Wood Furnitt«e and Fixhires
                                           Sector Notebook Project
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                                                  Wood Furniture and Fixtures
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 SIC Code 25
                                 96
                                 September 1995

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Sector Notebook Project
               Wood Furniture sand Fixtures
VII.C.   Review of Major Legal Actions

            This section provides summary information about major cases and
            supplemental enforcement  projects that pertain  to  the Wood
            Furniture and Fixtures Industry.  Information in this  section is
            provided by the Office of Enforcement and Compliance Assurance
            and  EPA's Enforcement Accomplishments Report.

VII.C. 1.     Review of Major Cases

              As indicated in EPA's  Enforcement  Accomplishments  Report,
            FY1991, FY1992, FY1993 publications, two significant enforcement
            actions were resolved between 1991 and  1993 for the furniture and
            fixtures industry, involving RCRA violations.   One of the RCRA
            enforcement cases also included CWA violations.  The companies
            against which the cases were brought include  a school furniture
            manufacturer and a furniture refinisher.

            Of the  two actions  involving RCRA violations, one  was  a civil
            action for  penalties and injunctive relief  against  the  school
            furniture manufacturer.  The action was based on  29 RCRA and
            significant CWA violations discovered  by EPA inspectors.  The
            violations resulted primarily from the use of  two unlined surface
            impoundments as part  of  a  waste water treatment facility.  The
            second  case involving RCRA violations was against a furniture
            refinisher and resulted in a conviction  on four counts of illegal
            disposal of hazardous waste and imposition of a jail  sentence.  The
            hazardous waste consisted primarily of furniture stripping solvents.

VII.C.2.     Supplemental Environmental Projects

            SEPs are compliance agreements that reduce a facility's stipulated
            penalty in return for an  environmental project that exceeds the
            value of  the  reduction.   Often, these projects  fund  pollution
            prevention  activities that  can significantly reduce the  future
            pollutant loadings of a facility. The yearly Regional updates and the
            Enforcement Accomplishments  Reports,  FY1991,  FY1992,  and
            FY1993 did not  provide information on  any SEPs entered into by
            furniture or fixture manufacturing facilities.
September 1995
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Wood Furniture and Fixtures
                  Sector Notebook Project
VIII.  COMPLIANCE ACTIVITIES AND INITIATIVES

            This section highlights the activities undertaken by this industry
            sector  and public agencies to voluntarily improve the sector's
            environmental performance.   These  activities  include  those
            independently initiated by industrial trade associations.  In this
            section, the notebook  also contains a listing and  description of
            national and regional trade associations.
VIII.A.  Sector-related Environmental Programs and Activities

            One major sector-related environmental research project has been
            undertaken at the Furniture and  Manufacturing and Management
            (FMM)  Center  at North Carolina State University  (NCSU),
            organized in 1991 as an outgrowth the Furniture Manufacturing
            and Management curriculum, which began in 1948. The mission of
            the FMM Center is three-fold:

            •     To  conduct  applied  research  on manufacturing and
                  engineering issues for the benefit of the furniture industry;

            •     To  carry  out an  extension program providing ongoing
                  technical assistance and technology transfer in support of the
                  furniture industry.  Extension services focus on the areas of
                  upholstery   furniture  manufacturing,  case  goods
                  manufacturing, and environmental management;

            •     To educate engineers with specific knowledge of furniture
                  manufacturing.


            The  Environmental Program of the FMM  Center is divided into
            applied  research activities  and extension services.   Research
            activities  are related to the industry  in  general rather  than a
            particular company.  Currently, the FMM Center has two ongoing
            research projects related to environmental issues:

            •     Development of environmental recordkeeping software and
                  a computerized tracking system  for chemical usage and
                  emission reporting;

            •     Exploration  of  a biofiltration  project,  a  method for
                  destruction of VOC and  HAP emissions from  finishing
                  operations.

            The following  project, requested by  the U.S. EPA,  may  be
            undertaken in the near future:
SIC Code 25
98
September 1995

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Sector Notebook. Project
               Wood Furniture and Fixtures
            •     Use of very low  VOC/HAP coatings for wood finishing
                  processes as a pollution prevention option for complying
                  with the MACT and CTG.

            The purpose of  the  environmental extension program  is  to
            promote cooperation between the furniture industry and the FMM
            Center.   Activities  include providing  technical assistance and
            advisory guidance, conducting literature searches, acting as liaison,
            and providing training, and other requested services, including:

            •     Quarterly  environmental   forum  for  environmental
                  managers and engineers in the furniture industry

            •     Information dissemination,  including free  computerized
                  literature searches
                  Technical  assistance  on  an individual
                  including short-term consultations

                  Workshops and training.
                     company basis,
            In addition to the  FMM  initiatives, the North Carolina Small
            Business Ombudsman has been active in increasing  awareness
            about  the  proposed MACT  and CTG for the wood furniture
            finishing industry by issuing a  fact sheet.  The Small Business
            Ombudsman and some of  the larger trade associations have also
            been involved in other compliance-related initiatives (see Section
            vm.c.i.).
VIII.B.  EPA Voluntary Programs
33/50 Program
            The "33/50 Program" is EPA's voluntary program to reduce toxic
            chemical releases and transfers of 17 chemicals from manufacturing
            facilities.  Participating  companies pledge to reduce their toxic
            chemical releases and transfers by 33 percent as of 1992 and by 50
            percent as of 1995 from the 1988  baseline year.  Certificates of
            Appreciation have been given to participants who  met their 1992
            goals.  The list of chemicals includes 17 high-use chemicals reported
            in the Toxics Release Inventory.

            Of the 17 chemicals covered by the  33/50 Program,  11 are used by
            and are outputs of the wood furniture manufacutring industry. All
            but three of these eleven chemicals are solvents which are sued
September 1995
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Wood Furniture and Fixtures
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            throughout furniture production,  particularly  in  the finishing
            stages of the process.

            Exhibit 28 lists those companies participating in the 33/50 program
            that reported under SIC code 25 to TRI. Many of the participating
            companies listed multiple SIC codes (in no particular order), and are
            therefore likely to  conduct operations  in  addition  to  Wood
            Furniture and  Fixtures Industry.  The table shows the number of
            facilities within each company that are participating in the 33/50
            program; each company's total 1993 releases and transfers of 33/50
            chemicals; and the percent reduction in these chemicals since 1988.

            According  to  EPA,  359  furniture manufacturing  companies
            comprise the potential 33/50 universe.  Of those companies, 31 or
            8.64 percent are participating in the program, which is less than the
            average for all  industries of 14 percent participation.
                                  Exhibit 28
    Wood Furniture and Fixtures Facilities Participating in the 33/50 Program
Parent Facility name
Armstrong World Industries
Bassclt Superior Lines
Best Chairs Inc.
Geiger Group Inc
Hamilton Industries Inc
Haworth Inc
Heidelberg Cement Inc
Itr Industries Inc
Joyce International Inc (De)
Klipsch & Associates Inc
La-Z-Boy Chair Company
Lozier Corporation
Madix Inc
Marmon Group, Inc
Mascotech
North American Philips Corp
Oklahoma Fixture Co.
Scely Pine Furniture Inc.
Shuford Industries Inc
Silver Furniture Co Inc
Parent City
Lancaster
Bassett
Ferdinand
Atlanta
Two Rivers
Holland
Allentown
Deer Park
New York
Indianapolis
Monroe
Omaha
Terrell
Chicago
Taylor
New York
Tulsa
Berkeley
Springs
Hickory
Knoxville
ST
PA
VA
IN
GA
WI
MI
PA
NY
NY
IN
MI
NE
TX
EL
MI
NY
OK
wv
NC
TN
SIC Codes
2511
2511
2511
2521
2521
•2522, 2521
2511
2511
2541
2517, 2519,
3651
2511
2542, 2541
2542, 2541
2541
2511
2517
2541
2511
2511
2511
# of
Participating
Facilities
11
12
1
1
1
2
1
1
2
1
7
2
1
1
17
1
2
1
3
1
1993
Releases
and
Transfers
(Ibs.)
1,109,350
2,063,109
51,700
45,078
31,875
194,050
119,957
34,882
118,847
11,521
572,153
186,715
623,805
1,092,218
3,163,830
1,281,928
236,975
22,996
1,613,303
73,705
%
Reduction.
1988 to
1993
*
50
***
81
7
50
*
*
25
#
**
85
55
1
35
50
***
***
58
45
 SIC Code 25
                                       100
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Sector Notebook Project
                Wood Furniture and Fixtures
                                 Exhibit 28
    Wood Furniture and Fixtures Facilities Participating in the 33/50 Program
                                  (cont'd)
Parent Facility name
Steelcase Inc
Suba Mfg. Inc
Thomson Consumer Electronics
W. J. Roscoe Co.
White Consolidated Industries
Parent City
Grand Rapids
Benicia
Indianapolis
Akron
Cleveland
ST
MI
CA
IN
OH
OH
SIC Codes
2522, 2542,
2521
2541
2517
2851, 2891,
2517
3585, 2542,
2541
# of
Participating
Facilities
5
1
1
1
1
1993
Releases
and
Transfers
(Ibs.)
2,042,735
5,949
2,110,314
40,051
808,298
%
Reduction
1988 to
1993
20
25
43
50
81
* = not quantifiable against 1988 data.
** = use reduction goal only.
*** = no numerical goal.
Environmental Leadership Program
Project XL
            The Environmental  Leadership  Program  (ELP)  is  a national
            initiative piloted by EPA and State agencies in which facilities have
            volunteered   to   demonstrate   innovative  approaches  to
            environmental management and compliance.  EPA has selected 12
            pilot projects at industrial facilities  and Federal installations which
            will demonstrate the principles of  the  ELP program.  These
            principles  include:     environmental  management  systems,
            multimedia compliance assurance,  third-party  verification of
            compliance, public  measures  of  accountability,  community
            involvement, and mentoring programs. In return for participating,
            pilot participants receive public recognition and are given a period
            of  time to  correct  any  violations  discovered  during  these
            experimental projects. (Contact: Tai-ming Chang, ELP Director, 202-
            564-5081 or Robert Fentress, 202-564-7023)
            Project  XL was initiated in March 1995  as  a part of President
            Clinton's  Reinventing Environmental Regulation initiative.  The
            projects seek to achieve cost effective environmental benefits  by
            allowing  participants to replace or modify existing regulatory
            requirements  on  the  condition  that  they  produce  greater
            environmental benefits.   EPA  and  program participants will
            negotiate  and sign a Final Project  Agreement, detailing specific
            objectives that the regulated entity shall satisfy.  In exchange, EPA
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Wood Furniture and Fixtures
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            will allow the participant a certain degree of regulatory flexibility
            and may  seek  changes  in underlying  regulations  or  statutes.
            Participants are encouraged to seek stakeholder support from local
            governments, businesses, and environmental groups.   EPA  hopes
            to  implement  fifty pilot projects in  four categories including
            facilities, sectors, communities, and government agencies regulated
            by EPA.  Applications will be accepted on a rolling basis and projects
            will move to implementation within six months  of their selection.
            For additional information regarding  XL Projects,  including
            application procedures and criteria, see the May 23, 1995 Federal
            Register Notice, or contact Jon Kessler at  EPA's Office of  Policy
            Analysis (202) 260-4034.
Green Lights Program
            EPA's Green Lights program was initiated in 1991 and has the goal
            of preventing pollution by encouraging U.S. institutions to use
            energy-efficient lighting technologies.  The program has over 1,500
            participants which include  major corporations; small and medium
            sized businesses; Federal, State and local governments; non-profit
            groups; schools;  universities;  and health  care  facilities.  Each
            participant is required to survey their facilities and upgrade lighting
            wherever it is profitable.  EPA provides technical assistance to the
            participants  through a  decision support  software  package,
            workshops and manuals, and a financing registry.  EPA's Office of
            Air  and Radiation is responsible for operating the Green  Lights
            Program.  (Contact:  Susan Bullard at 202-233-9065 or the  Green
            Light/Energy Star Hotline at 202-775-6650)
WasteWi$e Program
             The WasteWi$e Program was started in 1994 by  EPA's Office  of
             Solid Waste and Emergency Response.  The program is aimed  at
             reducing municipal solid wastes by promoting waste minimization,
             recycling  collection,  and  the manufacturing  and  purchase  of
             recycled products.  As of 1994, the program had about 300 companies
             as members, including a number of major corporations.  Members
             agree to identify and implement actions to reduce their solid wastes
             and must provide EPA with their waste reduction goals along with
             yearly progress reports.  EPA in turn provides technical assistance to
             member companies and allows the use of the WasteWi$e logo for
             promotional purposes.  (Contact: Lynda Wynn, 202-260-0700 or the
             WasteWi$e Hotline at 1-800-372-9473).
 SIC Code 25
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            According to a representative from the Business and Institutional
            Furniture Manufacturers Association (BIFMA), BIFMA has recently
            joined the EPA's Waste Wi$e Program.
Climate Wise Recognition Program
NICE3
            The Climate Change Action Plan was initiated in response to the
            U.S.  commitment to  reduce greenhouse  gas  emissions  in
            accordance with the Climate Change Convention of the 1990 Earth
            Summit. As part of the Climate Change Action Plan, the Climate
            Wise Recognition Program is a  partnership initiative run jointly by
            EPA and the Department  of Energy.  The program is designed to
            reduce greenhouse gas emissions by encouraging reductions across
            all sectors  of the economy, encouraging participation in the full
            range of Climate  Change Action Plan initiatives, and fostering
            innovation.  Participants in the program  are required to identify
            and commit to actions that reduce greenhouse gas emissions.  The
            program, in turn, gives organizations early recognition for their
            reduction commitments;  provides technical  assistance through
            consulting services, workshops, and guides; and provides access to
            the program's  centralized  information  system.   At EPA, the
            program is operated by the Air and Energy Policy Division within
            the Office of Policy Planning and Evaluation.  (Contact:  Pamela
            Herman, 202-260-4407)
            The U.S. Department  of  Energy and EPA's  Office of Pollution
            Prevention are jointly  administering a grant program called The
            National  Industrial  Competitiveness  through  Energy,
            Environment, and Economics (NICE^).  By providing grants of up
            to 50  percent of the total project cost,  the program  encourages
            industry to reduce industrial waste at its source and become more
            energy-efficient and cost-competitive through waste minimization
            efforts. Grants are used by industry to design, test, demonstrate, and
            assess the feasibility of new processes and/or equipment with the
            potential to reduce pollution  and increase energy efficiency.   The
            program is open to  all industries;  however, priority  is given to
            proposals from participants  in the pulp and paper, chemicals,
            primary metals, and petroleum and coal products sectors.  (Contact:
            DOE's Golden Field Office, 303-275-4729)
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VIII.C  Trade Association/Industry Sponsored Activity

            The following discussion will provide an overview of the larger
            trade associations representing the wood furniture
            manufacturing industry, with contact names, addresses, and
            summaries of activities undertaken by the associations to
            heighten their member companies' awareness of environmental
            regulations and compliance issues.
VDI.C.l.    Environmental Programs

            The larger trade associations with  member companies from the
            wood furniture  manufacturing  industry  have  undertaken
            campaigns to educate further their membership on environmental
            regulations  and compliance issues.   The  American Furniture
            Manufacturers  Association (AFMA),  in conjunction  with  3M
            Environmental Engineering, Akzo Nobel,  and Radian Corporation,
            has developed an industry  compliance notebook and training
            course to inform facility managers of  environmental regulations
            which could apply to their manufacturing operations.   Similarly,
            Business  and Institutional Furniture Manufacturers Association
            (BIFMA),  AFMA,  and  the  Kitchen Cabinet  Manufacturers
            Association (KCMA) have already conducted four training seminars
            on the draft CTG and MACT standards for the  wood furniture
            industry  and how  to  comply with the new requirements.   In
            addition, AFMA, BIFMA,  KCMA,  and  the  National  Paint and
            Coatings Association were the primary industry trade  association
            representatives in the lengthy regulatory negotiation process with
            EPA and other interested parties on the CTG and MACT standards.
VHLC.2.    Summary of Trade Associations
            American Furniture Manufacturers
            Association (AFMA)
            P.O. Box HP-7
            High Point, NC 27261
            Phone:  (910)884-5000
            Fax: (910)884-5303	
Members: 336
Staff: 14
             Founded in 1984, this trade association includes manufacturers
             seeking to provide a unified voice for the furniture industry and to
             aid in the development of personnel.  The group provides market
             research  data, industrial relations  services,  costs and operating
             statistics, and general management and information services.  The
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                 Wood Furniture and Fixtures
             AFMA has annual meetings and publishes a membership directory
             once a year.
             Business and Institutional Furniture
             Manufacturers Association (BIFMA)
             2680 Horizon Drive S.E., Suite A-l
             Grand Rapids, MI 49546
             Fax: (616)285-3765
          Members: 221
          Staff: 6
          Budget: $700,000
          Contact: Russell Coyner, Exec. Dir.
          Phone: (616)285-3963
            This trade association consists of firms that manufacture furniture
            intended  for use in  offices, public  spaces,  and  non-live-in
            institutions (including seating and  space divider manufacturers).
            BIFMA  is involved in  industry relations, government relations,
            and maintains  and provides industry information  and statistics.
            The group conducts annual management conferences and publishes
            an annual membership directory,  a bimonthly newsletter,  and
            various statistical reports for its membership.
Futon Association International (FAI)
P.O. Box 6548
Chico, CA 95927-6548
Phone: (916)534-7833
Toll free: (800) 327-3262
Fax: (916)534-7875
Members: 450
Staff: 2
Contact: Timothy Jacobs,
Executive Director
            The FAI includes manufacturers, suppliers,  wholesalers, and
            retailers of futons.  This trade association facilitates contact and
            communication  within the futon industry and keeps members
            informed of changes in the bedding  industries codes, laws, and
            regulations.  The FAI annually hosts a Futon EXPO and publishes
            periodic  bulletins,  membership  directories,  and a  quarterly
            document entitled Updates.
September 1995
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Wood Furniture and Fixtures
          Sector Notebook Project
             Grand Rapids Area Furniture Manufacturers
             Association (GRAFMA)
             4362 Cascade Road, S.E., Suite 113
             Grand Rapids, MI 49506
             Phone: (616)942-6225
             Fax: (616)942-1730	
Members: 56
Staff: 2
Budget: $97,000
Contact:  Carol Kooistra,
        Executive Director
             This association  consists  of furniture manufacturers  located in
             western Michigan.   The  organization  conducts wage  surveys,
             compiles  statistics,  sponsors  periodic  seminars  on  furniture
             technology,  and publishes brochures,  newsletters,  and  the
             document entitled Roster.
             International Home Furnishings Marketing
             Association (IHFMA)
             P.O. Box 5687
             High Point, NC 27262
             Phone:  (910)889-0203
             Fax:  (910)889-7460       	
Members: 55
Staff:  2
Contact: Richard Barentine,
        Executive Director
             Founded in 1955, this furniture manufacturers' group works to
             create a  cooperative business  environment.  The IHFMA holds
             semiannual meetings in North Carolina and publishes  various
             brochures and pamphlets.
             International Wholesale Furniture
             Association (IWFA)
             P.O. Box 2482
             164 S. Main Street, Suite 404
             High Point, NC 27261
             Phone:  (910)884-1566    	
Members: 127
Staff:  2
Contact: Sonny Berry,
        Executive Director
             The IWFA consists mainly  of wholesalers of home furniture but
             also  includes  some supplier  firms that  manufacture  products
             offered  for sale by  wholesale-distributor members.   This trade
             association hosts semiannual banquets and  publishes a monthly
             newsletter entitled National Wholesale Furniture Association and
             an annual publication Who's Who  in Furniture  Distribution.
 SIC Code 25
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                                             Wood Furniture and Fixtures
IX.
CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY
For further information on selected topics within the furniture and fixtures
industry, a list of publications is provided below:
General Profile	

Encyclopedia of Associations, 27th ed., Deborah M. Burek, ed., Gale Research Inc.,
Detroit, Michigan, 1992.

Enforcement  Accomplishments  Report,  FY  1991,  U.S.  EPA,  Office  of
Enforcement (EPA/300-R92-008), April 1992.

Enforcement  Accomplishments  Report,  FY  1992,  U.S.  EPA,  Office  of
Enforcement (EPA/230-R93-001), April 1993.

Enforcement  Accomplishments  Report,  FY  1993,  U.S.  EPA,  Office  of
Enforcement (EPA/300-R94-003), April 1994.

Standard Industrial  Classification  Manual, Office of Management and Budget,
1987.

1992  Toxic  Release  Inventory  (TRI) Public Data  Release, U.S.  EPA,  Office of
Pollution Prevention and Toxics, April 1994. (EPA/745-R94-001)

U.S. Industrial Outlook 1994 - Household Consumer Durables,  Department of
Commerce.

1987 Census of Manufacturers, Industry  Series:  Household Furniture, Bureau of
the Census.  (MC87-I-25A)

1992  Census of Manufacturers, Preliminary Report Industry Series:   Household
Furniture, Bureau of the Census, May 1994. (MC92-I-25A(P))
Process Descriptions	

Draft Guidelines for the  Control of Volatile  Organic Compound Emissions from
Wood  Furniture Coating  Operations, U.S. EPA, Office of Air and Radiation,
October 1991.

EPA Document AP-42  -  Compilation of Air Pollutant Emission Factors

McGraw-Hill Encyclopedia of Science  & Technology, 6th ed., vols. 5, 6, 11, 13, 14,
16, 18,19, McGraw-Hill Book Company, New York, New York, 1987.
September 1995
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                                 Sector Notebook Project
Regulatory Profiles
Draft Control Techniques Guidelines (CTGs)  -  Appendix B:   Preliminary  Draft
Model Rule for Wood Furniture Finishing  and Cleaning Operations, U.S. EPA.

Environmental  Guide for the Furniture Industry,  AFMA, 3M  Environmental
Engineering, Akzo Nobel, Radian Corporation, Research Triangle Park, North
Carolina, 1994.

Furniture/Wood Manufacturing and Refinishing, U.S. EPA,  RCRA Fact Sheet.
(EPA/530-SW-90-027c)
Pollution Prevention	

Pollution  Prevention  Options  in  Wood   Furniture  Manufacturing,  A
Bibliographic  Report, U.S. EPA, Office of Pollution Prevention and  Toxics,
February 1992. (EPA/560/8-92/001C)
Contacts*
Name

Rosalyn Hughes
David Stout
Gary Bell
Stan Payne
Ronald Pridgeon

John Cullen
Larry Runyan

Bob Naboicheck
Sholeh Azar
Bob McCrillis

Bob Marshall
Madeliene  Strum
Paul Eisele
Organization

U.S. EPA, Region IV (inspector)
Broyhill Corporation
La-Z-Boy Chair Company
Bassett Furniture
NC Department of Environment,
Health, and Natural Resources
Masco Corporation
American Furniture Manufacturers
Association
Futon Association International
NC State University
U.S. EPA, Office of Research and
Development
U.S. EPA, OECA
U.S. EPA, RTP
Masco Corporation
Telephone

404-347-2904
704-758-3111
313-242-1444
703-629-6000
919-571-4000

313-274-7400
910-884-5000

203-549-2000
919-515-6400

919-541-2733
202-564-7021
919-541-2383
313-274-7400
   Many of the contacts listed above have provided valuable background information and comments during the
   development of this document. EPA appreciates this support and acknowledges that the individuals listed do
   not necessarily endorse all statements made within this notebook.
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Sector Notebook Project
                              IVood Furniture and Fixtures
Name

Edyth McKinney

John Lank
Organization

Small Business Ombudsman,
North Carolina
U.S. EPA, Region IV (inspector)
Telephone
800-829-4841
404-347-7603
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                                APPENDIX A
      INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK

          Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web.  The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics.  The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.

ACCESS THROUGH THE ENVIRO$EN$E WORLD WIDE WEB

      To access this Notebook through the EnviroSenSe World Wide Web, set your World Wide
      Web Browser to the following address:


      http://eS.inel.gov/OCCa - then select "EPA Sector Notebooks"

      Of after 1997, (when EPA plans to have completed a restructuring of its web site) set
                      your web browser to the following address:


      WWW.epa.gOV/OeCa -  then select the button labeled  Gov't and Business
                                     The Notebook will be listed.

      HOTLINE NUMBER FOR E$WWW:  208-526-6956

      EPA E$WWW MANAGERS: Louis Paley 202-564-2613
                                Myles Morse 202-260-3151
(This page updated June 1997)
Appendix A

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           United States Government
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055-000-00521-4
055-000-00522-2
055-000-00523-1
055-000-00524-9
055-000-00525-7
055-000-00526-5
055-000-00527-3
055-000-00528-1
• 055-000-00529-0
055-000-00514-1
Sjf^sss^^^-^soi&fi^i^sss^x^iss^s^^iv^ -"-T^^'ja^aus?'^' • -
Published in 1995 Title
Dry Cleaning Industry, 1 04 pages
Electronics and Computer Industry, 160 pages
Fabricated Metal Products Industry, 164 pages
Inorganic Chemical Industry, 136 pages
Iron and Steel Industry, 1 28 pages
Lumber and Wood Products Industry, 136 pages
Metal Mining Industry, 148 pages
Motor Vehicle Assembly Industry, 1 56 pages
Nonferrous Metals Industry, 140 pages
Non-Fuel, Non-Metal Mining Industry, 1.08 pages
Organic Chemical Industry, 152 pages
Petroleum Refining Industry, 160 pages
Printing Industry, 1 24 pages
Pulp and Paper Industry, 156 pages
Rubber and Plastic Industry, 1 52 pages
Stone, Clay, Glass and Concrete Industry, 1 24 pages
Transportation Equipment Cleaning Industry, 84 pages
Wood Furniture and Fixtures Industry, 1 32 oaaes
Lr£xSfc>,c,i?i
Price
Each
$ 6.50
11.00
11.00
9.00
8.00
9.00
10.00
11.00
9.00
6.50
11.00
11.00
7.50
11.00
11.00
7.50
5.50
8.00
.^t&Ji^Kf
Total I
Price
I

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• i
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Qty.










Stock Number
055-000-00570-2
055-000-00571-1
055-000-00572-9
055-000-00573-7
055-000-00574-5
055-000-00575-3
055-000-00576-1
055-000-00577-0
055-000-00578-8
055-000-00579-6
Published in 1997 Title
Air Transportation Industry, 90 pages
Ground Transportation Industry, 130 pages
Water Transportation Industry, 90 pages
Metal Casting Industry, 1 50 pages
Pharmaceutical Manufacturing Industry, 147 pages'
Plastic Resin & Man-made Fiber Industry, 1 80 pages
Fossil Fuel Electric Power Generation Industry, 160 pages
Shipbuilding and Repair Industry, 1 20 pages
Textile Industry, 1 30 pages
Sector Notebook Data Refresh -1 997, 21 0 pages
Price
Each
$ 7.50 .
.10.00
7.50
13.00
13.00
15.00
14.00
9.50
10.00
17.00
Total for Publications
Total i
Price i
i
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I
 The total cost of my order is
                                _. Price includes regular shipping and handling and is subject to change.
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Mail to: Superintendent of Documents
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