Regulatory Information vhap FAQs
What is a VHAP?
· EPA regulates 189 toxic chemicals as Hazardous Air Pollutant (HAP)
· 189 List includes non-volatile compounds, such as heavy metals (lead, mercury, etc.)
· A VHAP is a volatile hazardous air pollutant
Who regulates VHAPs?
· Federal and State Environmental Agencies only
o Environmental Protection Agency (EPA)
o State Department of Environmental Protection (DEP), or DEC, or DNR
How are VHAPs regulated?
· EPA developed standards under the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for specific manufacturing industries.
· Subpart JJ regulates the Wood Furniture Manufacturing Industry.
· Emission limit set for contact adhesives for the following two categories of major source:
o Existing facilities - 1.0 lb VHAP per lb Solid
o New facilities – 0.2 lb VHAP per lb Solid
What does “major source” mean?
· EPA defines facilities based on emissions as either major or minor
· Major source is a facility that emits:
o > 10 tons per year of one HAP (roughly, assuming 40% HAP, 7600 gal adhesives or 138 drums)
o > 25 tons per year of the aggregate HAP
What is a “wood furniture manufacturing” company?
· Wood Furniture – any product made of wood, a wood product such as ratten or wicker, or an engineered wood product such as particleboard that is manufactured under any of the following standard industrial classification codes (SIC) – 2434, 2511, 2512, 2517, 2519, 2521, 2531, 2541, 2599 or 5712.
· Wood Furniture Component – means any part that is used in the manufacture of wood furniture. Examples include, but are not limited to, drawer sides, cabinet doors, seat cushions, and laminated tops.
· Wood Furniture Manufacturing Operations – the finishing, gluing, cleaning
regulatory information
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