7 /1 8 /2013 1 

### M E M ORA N D U M

Date: September 16, 2013

TO: Docket No. EPA

- HQ

- OAR

- 2012

- 0510: National Emissions Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production

FROM: Kaye Whitfield, EPA/OAQPS/SPPD

SUBJECT: Draft Development of the RTR Emissions Dataset for the Flexible Polyurethane Foam Production Source Category

The purpose of this memorandum is to describe how the set of data used to perform risk

modeling for the Flexible Polyurethane Foam (FPUF) Production source category was

developed

. Sectio n 1 provides background information on the FPUF Production source

category

. Section 2 describes the list of facilities included in the emissions data set used for the

EPA’s risk assessment for the source category . Section 3 discusses the development of the

emissions data set s used to perform risk modeling for the FPUF Production source category and

to perform facility

- wide risk modeling

.

1.0 BACKGROUND

The NESHAP (or MACT rule) for FPUF Production was promulgated on October 7,

1998, (6 3 FR 53980) and codified at 40 CFR part 63, subpart III. The FPUF MACT standard

applies to each new and existing FPUF or rebond foam process that produces FPUF or rebond

foam, and is located at a contiguous, major source plant site. Requirements of the FPU F MACT

standard are the same for new and existing sources

. Foam fabrication processes are specifically

excluded.7 /1 8 /2013 2 

### There are three different types of foam production processes included in the FPUF

production source category: Slabstock, molded, and rebond polyurethane foam production.

Slabstock foam products are primarily used in furniture seat cushions and bedding materials.

Molded foam is typically used in automotive seats, packaging, and a range of specialty products.

Rebond foam is commonly used as car pet padding and in cushions for school bus seats. Rebond

foam production is often co

- located at facilities with slab stock foam production operations

.

All FPUF is produced by mixing three major ingredients: polyol polymer, isocyanate, and

water. The polyol is either a polyether or polyester polymer with hydroxyl end groups. Other

ingredients are often added to modify the polymer, and catalysts are used to balance the principal

foam production reactions. Slabstock flexible polyurethane foam production someti mes employs

an auxiliary blowing agent ( ABA ) , which impacts foam properties, including density and

firmness.

The HAP emission sources at FPUF production facilities depend on the type of foam

being produced. Previously, many slabstock foam production facilities used HAP

- based ABA,

and the primary HAP emission point for these facilities was the foam production line

, due to

HAP ABA emissions. In recent years, all slabstock production facilities subject to the FPUF

Production MACT standar ds have discontinued use of H AP

- based ABAs, and therefore, the

foam production line is no longer a primary HAP emissions point. Other HAP emission sources

at slabstock foam production facilities include storage vessels and equipment leaks. At molded

and r ebond foam facilities, the primary HAP emission sources are storage vessels and equipment

leaks. Other HAP emission sources at molded and rebond facilities include production lines and

the use of adhesives to repair foam.

Due to the discontinuation of HAP ABA use by the industry, the primary HAP s emitted

currently are diisocyanates (either 2,4

- toluene diisocyanate (TDI) or 4,4'

- m ethylene diphenyl

diisocyanate (MDI)), which are essential reactants in the production of FPUF. However, neither

TDI nor MDI are emitted in large quantities from foam production facilities, as they react almost

completely with the water, polyol, and catalysts. Diethanolamine

, a HAP additive used in some

specialty foams also is emitted from one facility.7 /1 8 /2013 3 

### 2 .0 RISK ASSESSMENT FACILITY LIST

The EPA conducted a risk assessment that provided estimates of the cancer MIR posed

by the HAP emissions from each source in the source category, the HI for chronic exposures to

HAP with the potential to cause noncancer health effects, and t he hazard quotient (HQ) for acute

exposures to HAP with the potential to cause noncancer health effects. The docket for the

rulemaking contains “ Draft Residual Risk Assessment for the Flexible Polyurethane Foam

Production Source Category ” which provides mo re information on the ri sk assessment inputs and

models. T he risk assessment was performed using a set of 13 facilities, listed in Table 1.

The facilities in the data set were selected from a larger list of facilities compiled from

multiple sources including EPA’s Envirofacts database and National Emissions Inventory (NEI).

The primary means of identification of foam production facilities was via North American

Industry Classification System (NAICS) codes. The NAICS code associated with the FPUF

Production industry is 32615, or “ Urethane and Other Foam Product (except Polystyrene)

Manufacturing .” However, this NAICS code is broader than just the FPUF industry, and also

includes the product ion of rigid foams, vacuum formed foams, insulation, and packaging

materials, which are not part of the FPUF Production s ource c ategory

. Some data sources also

included area sources, which are not subject to Subpart III. Because of these factors, facilities

meeting the following criteria were removed from the larger facility list:

• Area sources,

• Facilities not producing flexible polyurethane foam, and

• Facilities no longer in operation.

Multiple information sources were consulted to make these determinations, including

EPA’s Envirofacts database ( www.epa.gov/enviro/ ), contacts with State and local environmental

agencies, and other online resources including compan y websites . Details on facilities removed

from the modeling file are included in Appendix A of this memo.7 /1 8 /2013 4 

### Table 1. Flexible Polyurethane Foam Production RTR Facility List

FACILITY NAME CITY STATE

Premier Foam Inc. Newnan GA

Foamex L.P. Auburn IN

Foamex, L.P. Ft. Wayne IN
U S Dept Of Energy

- Kansas City Plant Kansas City MO

Chromcraft Furniture Senatobia MS

Flexible Foam Products Inc Tupelo MS

Foamex International, Inc. Cornelius NC

Hickory Springs Manufacturing Conover NC

Bridgestone Apm Company

- Foam Products Upper Sandusky OH

Invacare Corporation Elyria OH

Chestnut Ridge Foam Inc Latrobe PA

Foamex Lp/Corry Corry PA

IAC Strasburg L LC Strasburg VA



### 3.0 FLE X IBLE POLYURETHANT FOAM PRODUCTION SOURCE CATEGORY

RISK MODELING DATASET

To develop the FPUF Production so urce category data set, e missions and emissions

release parameter data (e.g., release height, release velocity, emission release point latitude and

longitude coordinates) w ere compiled from several EPA em issions inventory databases: The

2005 National Emissions Inventory (NEI), the 2008 Emissions Inventory System (EIS), and the

2009 and 2010 Toxics Release Inventory (TRI)

. For some facilities, emissions data w ere

available from a CAA section 114 surveys EPA issued in late 2011.

Data w ere not available from all sources for each facility, and some data sources

provided more detail than others. Given this, it was necessary to compile data from multiple

sources to prepare a data set best representing the emissi ons from the selected list of facilities.

Our approach for c ompiling the modeli ng data set is described below.7 /1 8 /2013 5 

### 3.1 Selection of D ata S ources

Where CAA Section 114 survey data were available

, these data were used in the modeling

file and supersede d any other available data . This is because the CAA Section 114 survey

specifically requested recent emissions data and associated release parameters from only the

processes included in the FPUF Production source category

. Table 2 shows the origin of the data

used for each of the facilities in the modeling dataset.

Table 2 . Flexible Polyurethane Foam Production Dataset Source of Data

FACILITY NAME CITY STATE FPUF DATASET SOURCE

Premier Foam Inc. Newnan GA TRI /NEI

Foamex L.P. Auburn IN CAA Section 114 Survey

Foamex, L.P. Ft. Wayne IN CAA Section 114 Survey

U S Dept Of Energy

- Kansas City Plant Kansas City MO EIS

Chromcraft Furniture Senatobia MS MSDEQ

Flexible Foam Products Inc Tupelo MS MSDEQ

Foamex International, Inc. Cornelius NC CAA Section 114 Survey

Hickory Springs Manufacturing Conover NC CAA Section 114 Survey

Bridgestone Apm Company

- Foam Products Upper Sandusky OH EIS

Invacare Corporation Elyria OH EIS

Chestnut Ridge Foam Inc Latrobe PA TRI /NEI

Foamex Lp/Corry Corry PA CAA Section Survey

IAC Strasburg Llc Strasburg VA NEI/EIS



### If no ICR data were available, data from the 2005 NEI and 2008 EIS were used. EIS data

w ere given preference over NEI data because EIS data are more recent, but NEI data were also

used in order to ensure that all facilities and emission points reported were included in the

category modeling file. If NEI data included pollutants or emission points not present in the EIS

dataset, the NEI data were added to those from EIS to be conservative and ens ure no source

category emissions were missed.

In general, available T RI data w ere not given preference over the EIS or NEI data because

TRI does not provide emission release point information such as category emissions, stack, and

fugitive parameters, and geographical coordinates of individual release points

. O nly facility

- wide7 /1 8 /2013 6 

### emissions data and site coordinates a re available in TRI

, and thus it would have been necessary

to make assumptions r egarding the source category of TRI emissions, apportion the facility

- wide

data among emission points, and develop emissions release parameters for those emissions

. TRI

emissions data w ere used for two facilities

. For one facility, no other source category emissions

data were available. For the other facility, data more recent than the NEI or EIS w ere used to

reflect current operations at the source

.

3.2 Selection of P ollutants and E mission P oints

After compiling the available emissions and emissions release parameter data for the 13

FPUF production facilities, further refinements to the data were made to include only the FPUF

production source category HAP data. First, c riteria pollutants were remo ved from the dataset

. Next, MACT codes and source c lassification codes ( SCC ) were used to identify emissions not in

the source category for removal from the modeling file

.

N EI data w ere filtered by MACT code where it was reported

. MACT codes were not present

in the EIS data. Data associated with MACT code 1314 (Flexible Polyurethane Foam

Production) w ere retained

, and data associated with other MACT codes were removed . The

MACT code of “not a MACT process” for some emission points w as changed to 1314 if the

pollutant profile (i.e., either TDI or MDI) and SCC suggested that the emissions belonged in the

source category.

SCCs were used in t he EIS dataset to r emove processes not in the source category

. Emission

points with SCCs clearly unrelated to the source category were removed (e.g., boilers, engines,

surface coating, stripping/cleaning, etc.)

. Remaining emissions points were retained to ensure a

conservative profile, including points with SCCs of “miscellaneous” or “not classified”

.

In addition to quality assurance (QA) of the emission processes, we also checked the

coordinates of every emission source in the dataset through visual observations using tools such

as Google Earth and ArcView . Where coordinates were found to be incorrect, we identified and

corrected them to the extent possible. We also performed QA of the emissions release parameters7 /1 8 /2013 7 

### to identify any outliers. Where data were outside the normal range for that data point type, w e

investigated the outliers to ensure the validity of the data and made corrections where needed.

For most emissions release points, the data source of the emissions release parameters was the

original source of data ( e.g. , NEI, EIS

, CAA Section 114 survey data ) . For a few emissions

release points, the emissions release parameters were missing . The emissions release parameters

used for these cases are discussed in section 3.3.

3.3 Specific Revisions to Individual Facilities

For some facilities where spec iated HAP emissions from FPUF production processes

were not available, or where questions arose regarding the presence of pollutants not expected

from foam production processes, we contacted Stat e Air Quality agencies to obtain more current

inventory data. Documentation of these contacts are included in “Documentation of

Communications with Industry and Regulatory Agency Contacts for the Flexible Polyurethane

Foam Industry” in the docket for the FPUF RTR

. For other faci lities, TRI data w ere used and

assumptions regarding the emissions release parameters were made. A brief summary of actions

taken for each of these facilities follows:

a) Chromcraft Furniture, Senatobia, MS : Only VOC emissions were present for the foam

produ ction emissions points at this facility in the EIS and NEI , and no emissions of HAP

associated with FPUF processes were present in TRI

. The Mississippi Department of

Environmental Quality (MS DEQ) was contacted to obtain more current emissions data

,

and e m ission release parameters from EIS associated with VOC emissions from FPUF

Production p rocesses were used.

b) Flexible Foam Products, Tupelo, MS : EIS data included pollutants not expected from a

foam production process. We contacted MS DEQ to obtain more current inventory data

. The MS DEQ information showed that the pollutants in question were not emitted from

processes associated with the FPUF Production source category. These emissions were

not included in the category dataset. FPUF emissions in the EIS data were updated using7 /1 8 /2013 8 

### 2011 emissions values in the MS DEQ inventory , and the EIS e mission release

parameters for these emission points were retained.

c) IAC Strasburg, Strasburg, VA : EIS data included pollutants not expected to be emitted

from a foam production process. The Virginia Department of Environmental Quality ( VA

DEQ ) was contacted to obtain more current inventory data . The VA DEQ data showed

that the pollutants in question were not released from processes associated with the FPUF

Production source category

. These emissions were not included in the category dataset.

d) Premier Foam, Newnan, GA : We contacted the Polyurethane Foam Association (PFA) to

determine if any U

. S

. slabstock foam producers us e HAP ABA. PFA indicated that no

sla bstock producers use HAP ABA. The 2005 NEI data for Premier F oam included

several tons per year of methylene chloride emissions, which indicate d that they were

using methylene chloride as an ABA during 2005

. To reflect current operations, the more

recent H AP data from the 2011 TRI were used with emission release parameters from the

2005 NEI . The only HAP reported in TRI for the facility was TDI, and it was assumed

that all TDI emissions are from FPUF P roduction

.

e) Chestnut Ridge Foam, Latrobe, PA : Neither NEI nor EIS contained any speciated HAP

data for this facility. TRI HAP data were used in the modeling file. TRI reported

emissions of TDI and “diisocyanates

. ” The diisocyanates emissions were assigned to

FPUF Production processes. NEI default emis sion release parameters for MACT code

1314 (foam production) were used in the modeling file

.

3.4 Facility

- Wide Emissions Dataset

A dataset representing facility

- wide emissions was also developed. This dataset consists

of HAP emissions from all processes at the 13 FPUF production facilities, including the data

described above for the FPUF P roduction source category emissions, as well as all HAP emitted

from non

- FPUF Production processes. Because 2008 EIS data were not available for all of these

facilities, 2005 NEI data w ere used for all 13 facilities for consistency. The facility

- wide7 /1 8 /2013 9 

### emissions dataset was created by adding non

- FPUF source category e mission points in the 2005

NEI dataset to the FPUF Production source category dataset.

Chromium compounds a re a significant contributor to increased cancer risk, but the level

of risk largely depends on the oxidation state (species) of the compounds. The two most common

chromium species are hexavalent chromium (Cr +6 

### ) and trivalent chromium (Cr +3 

### ). EPA has

class ified Cr +6 

### and its compounds as known human carcinogens, while Cr +3 

### is not classified as to

its human carcinogenicity. Consequently, determining the percentage of total chromium that is

Cr +6 

### vs. Cr +3 

### is a major factor in estimating the level of risk from chromium exposure. As part of

facility

- wide modeling, elemental chromium (CAS number 7440473) emissions were reported at

two facilities from natural gas boilers and at one facility from electric arc f urnaces. Default

chromium speciation profiles were used for the 2013 risk modeling file to generate estimates of

Cr +6 

### (pollutant code 18540299) and Cr +3 

### (pollutant code 16065831). The default chromium

speciation profile used in whole facility modeling for natural gas boilers is 4% Cr +6 

### and 96%

Cr +3 

### . The default chromium speciation profile used in whole facility modeling for electric arc

furnaces is 12% Cr +6 

### and 88% Cr +3



### .

3.5 MACT

- Allowable Emissions Dataset

The available emissions data in the MACT dataset include estimates of the mass of HAP

emitted during the specified annual time period. In some cases, these “actual” emission levels are

lower than the emission levels a facility is allowed to emit and still comply with the MACT

standards. The emissions lev el allowed to be emitted by the MACT standards is referred to as the

“MACT

- allowable” emissions level. This represents the highest emissions level that could be

emitted by facilities without violating the MACT standards. A dataset representing MACT

allowab le emissions was also developed. Details of the development of this dataset are available7 /1 8 /2013 10 

### in the docket for this rulemaking, in the document titled, MACT

- Allowable Emissions for the

Flexible Polyurethane Foam Production Source Category

.7 /1 8 /2013 11 

## Appendix A

Fa cilities removed from list of

Flexible Polyurethane Foam Production Major Sources7 /1 8 /2013 12 

## Table A

- 1: Facilities removed from list of

Flexible Polyurethane Foam Production Major Sources

PLANT NAME CITY ST Reason For Removal

3M Austin Center Austin TX Research Facility, as per permit

AEROJET

- GENERAL CORP East Camden AR Not a flexible foam facility, not subject to III in permit.

AMERICAN EXCELSIOR SHEBOYGAN WI Area Source, per EPA Envirofacts Database

AMERICAN SEATING

COMPANY GRAND RAPIDS MI Area Source, not subject to III in permit.

ASSOCIATED RUBBER INC/QUAKERTOWN QUAKERTOWN PA Area Source, per EPA Envirofacts Database

ATP MANUFACTURING, LLC RI Area Source, per EPA Envirofacts Database

AUTOMOTIVE COMPONENTS

HOLDINGS LLC SALINE

PLANT Saline MI Not a flexible foam facility, not subject to III in permit.

BLACHFORD INC IL Area Source, per EPA Envirofacts Database

BURKART FOAM INC Cairo IL Permanently closed, per IL EPA

BW FREEMAN INC. MO Area Source, per EPA Envirofacts Database

CAMBRO MANUFACTURING

COMPANY Huntington Beach CA Not a flexible foam facility, not subject to III in permit.

CARPENTER CO. ELKHART IN Area Source, Subject to OOOOOO per permit.

CARPENTER CO. Richmond VA Area Source, per EPA Envirofacts Database

CARPENTER CO. Fogelsville PA Area Source, per EPA Envirofacts Database

CARPENTER CO. Lakeland FL Area Source, per EPA Envirofacts Database

CARPENTER CO. CONOVER NC Area Source, per EPA Envirofacts Database

CARPENTER CO. Russelville KY Area Source, per EPA Envirofacts Database

CARPENTER CO. TUPELO MS Area Source, per EPA Envirofacts Database

CARPENTER CO. Temple TX Area Source, per EPA Envirofacts Database

CARPENTER CO. Riverside CA Area Source, per EPA Envirofacts Database

Cartex Corp IL Area Source, per EPA Envirofacts Database

CARTEX CORP/FAIRLESS

HILLS PA Area Source, per EPA Envirofacts Database

CELLOFOAM NORTH

AMERICA INC FL Area Source, per EPA Envirofacts Database

CHARISMA

MANUFACTURING CO RI Area Source, per EPA Envirofacts Database

COLLINS & AIKMAN

AUTOMOTIVE INTERIORS FARMINGTON NH Permanently closed, per NH DEP

COLLINS & AIKMAN

COLUMBIA OPERATIONS MO Area Source, per EPA Envirofacts Database

COMCAST URETHANE MI Area Source, per EPA Envirofacts Database

CONTINENTAL CLEANERS ARVADA CO Not a flexible foam facility, dry cleaners

COVANCE LABORATORIES

INC. MADISON WI Not a flexible foam facility, medical lab

CREST FOAM IND INC NJ Area Source, per EPA Envirofacts Database7 /1 8 /2013 13 PLANT NAME CITY ST Reason For Removal

DART CONTAINER

CORP/LEOLA LEOLA PA Not a flexible foam facility, makes foam cups & food packaging

DTR INDUSTRIES, INC. MIDWAY TN Not a flexible foam facility, not subject to III in permit.

E

- A

- R SPECIALTY

COMPOSITES SBU AEARO NEWARK DE Area Source, not subject to III in permit.

FAIRMONT CORP CARPET

CUSHION PLANT IL Area Source, per EPA Envirofacts Database

FIRESTONE BLDG PROD

/YOUNGWOOD PLT YOUNGWOOD PA Area Source, per EPA Envirofacts Database

FLEX FOAM DIVISION PHOENIX AZ Area Source, per EPA Envirofacts Database

FLEXIBLE FOAM PRODS INC OH Area Source, per EPA Envirofacts Database

FLEXIBLE FOAM PRODUCTS

INC CO Area Source, per EPA Envirofacts Database

FLEXIBLE FOAM PRODUCTS

INC TERRELL TX Area Source, not subject to III in permit.

FOAM DESIGN, INC. Lexington KY Area Source, Subject to OOOOOO per permit.

FOAM FABRICATORS, INC. CA Area Source, per EPA Envirofacts Database

FOAM MOLDERS &

SPECIALTIES INC CA Area Source, per EPA Envirofacts Database

FOAMEX Elkhart IN Area Source, per EPA Envirofacts Database, Owner states facility is closed

FOAMEX LP CONOVER NC Owner states facility is permanently closed

FOAMEX CARPET CUSHION

INC. TX Area Source, per EPA Envirofacts Database

FOAMEX INTERNATIONAL TX Area Source, per EPA Envirofacts Database

FOAMEX INTERNATIONAL

INC San Bernardino CA Owner states facility is permanently closed

FOAMEX INTERNATIONAL

INCORPORATED Milan TN Permanently closed as per AFS

FOAMEX L P PLANT 3 TN Area Source, per EPA Envirofacts Database

FOAMEX L.P. CA Owner states facility is permanently closed

FOAMEX LP VERONA MS Permanently closed as per AFS

FOAMEX LP Eddystone PA Area Source, per EPA Envirofacts Database, Owner states facility is closed

FOAMEX

- A DIV OF KIHI CA Owner states facility is permanently closed

FUTURE FOAM INC ORLANDO FL Area Source, not subject to III in permit.

FUTURE FOAM INC WI Area Source, per EPA Envirofacts Database

FXI EAST

RUTHERFORD NJ Area Source, per EPA Envirofacts Database

FXI Kent WA Area Source, per EPA Envirofacts Database

FXI Orange CA Area Source, per EPA Envirofacts Database

FXI San Leandro CA Area Source, per EPA Envirofacts Database

FXI Santa Teresa NM Area Source, per EPA Envirofacts Database

FXI VERONA MS Area Source, per EPA Envirofacts Database

G & T IND INC/ALLENTOWN

DIV ALLENTOWN PA Area Source, per EPA Envirofacts Database7 /1 8 /2013 14 PLANT NAME CITY ST Reason For Removal

G3 BOATS

- LEBANON LEBANON MO Not a flexible foam facility, boat manufacturer

GENERAL FELT IND /FOAMEX PA Area Source, per EPA Envirofacts Database

GENERAL FOAM CORP IL Area Source, per EPA Envirofacts Database

Genpak Corporation AL Area Source, per EPA Envirofacts Database

GOODYEAR TIRE & RUBBER

CO OH Area Source, per EPA Envirofacts Database

HERMAN MILLER INC MI Area Source, per EPA Envirofacts Database
Hickory Springs Manufacturing Corp. Americus GA Area Source, per EPA Envirofacts Database

Hickory Springs Manufacturing Corp. Commerce CA Area Source, per EPA Envirofacts Database

Hickory Springs Manufacturing Corp. Ft. Smith AR Area Source, per EPA Envirofacts Database

Hickory Springs Manufacturing Corp. Portland OR Area Source, per EPA Envirofacts Database

Hickory Springs Manufacturing Corp. VERONA MS Area Source, per EPA Envirofacts Database

INTEGRAM

- ST LOUIS

SEATING MO Not a flexible foam facility, makes aerosol packaging

INTERTEC SYSTEMS INC Bardstown KY Area Source, not subject to III in permit.

Invacare Elyria OH Permanently Closed, per EPA Envirofacts

Database

JOHNSON CONTROLS

HOOVER AUTO MO Area Source, per EPA Envirofacts Database

JOHNSON CONTROLS INC PLYMOUTH MI Area Source, per EPA Envirofacts Database

JOHNSON CONTROLS INC CA Area Source, per EPA Envirofacts Database

JOHNSON CONTROLS INC. OH Area Source, per EPA Envirofacts Database

JOHNSON CONTROLS,INC.

AUTOMOTIVE SYSTEMS PULASKI TN Area Source, Subject to OOOOOO per permit.

LCC BAYPORT LYONDELL PASADENA TX Not a flexible foam facility, chemical plant making ethylene oxide, etc.
Lear Corporation Hoover MI Area Source, per EPA Envirofacts Database

Lear Corporation Hebron OH Area Source, per EPA Envirofacts Database

Lear Corporation Selma AL Area Source, per EPA Envirofacts Database

LEGGETT & PLATT PA Area Source, per EPA Envirofacts Database
Leggett & Platt, Urethane Foam

Division IL Area Source, Subject to OOOOOO per permit.

LEON PLASTICS

INCORPORATED GRAND RAPIDS MI Not a flexible foam facility, not subject to III in permit.

LIFE LIKE PRODUCTS

- CHESAPEAKE AVE. Baltimore MD Permanently closed as per AFS

LITTON GUIDANCE AND CONTROL SYSTEMS (teledyne) Newbury Park CA Permanently closed

MATTHEWS INTERNATIONAL

CORP. BUENA PARK CA Permanently closed, per SC AQMD Database

MH Corp Livonia MA Permanently Closed, per EPA Envirofacts

Database

MILSCO MFG.

- RED GRANITE WI Area Source, not subject to III in permit.7 /1 8 /2013 15 PLANT NAME CITY ST Reason For Removal

MOUNTAIN VIEW

FABRICATING INC MO Area Source, per EPA Envirofacts Database

NORTH CAROLINA FOAM IND

INC DALTON FOAM DIV GA Area Source, per EPA Envirofacts Database

NORTH CAROLINA FOAM

INDS. DIV. OF BMC NC Area Source, per EPA Envirofacts Database

Nu

- Foam Products, Inc. TN Area Source, per EPA Envirofacts Database

OLYMPIC PRODS NC Area Source, per EPA Envirofacts Database

PERRY CHEMICAL & MFG CO

INC IN Permanently closed as per AFS

PERRY TECH CO INC (DBA KERN FOAM PRODS ) NJ Area Source, per EPA Envirofacts Database

PMC INC GENERAL FOAM

CORP DIV EAST

RUTHERFORD NJ Area Source, per EPA Envirofacts Database

RAS Industries Charleroi PA Not a flexible foam facility, architectural rigid

foam

RELIANCE UPHOLSTERY SUPPLY CO Carpet Cushion Gardena CA Permanently closed, per SC AQMD Database

RENOSOL CORP MI Area Source, per EPA Envirofacts Database

ROCKMONT IND INC CO Area Source, per EPA Envirofacts Database

Rogers Foam Morrisville PA Area Source, per EPA Envirofacts Database,

State indicates closed

ROYAL SPA CORP IN Area Source, per EPA Envirofacts Database

SCOTT PORT

- A

- FOLD INC OH Area Source, per EPA Envirofacts Database

SCOTTDEL INC OH Area Source, per EPA Envirofacts Database

SEARS MFG CO IA Area Source, per EPA Envirofacts Database

STERLING CHEMICALS TEXAS CITY TX Not a flexible foam facility, chemical plant making plasticizers, etc.

SUPERIOR PRODUCT SALES

INC Plantersville MS Permanently closed as per AFS

TRI

- CON INDUSTRIES LTD LINCOLN NE Area Source, not subject to III in permit.

TYCO HEALTHCARE

KENDALL ORISKANY

FALLS NY Permanently closed, permit discontinued 2011 per NY DEC

UNIVERSAL URETHANE INC NV Area Source, per EPA Envirofacts Database

WARVEL PRODUCTS INC.

- NORTH CAROLINA LINWOOD NC Permanently closed as per AFS

WOODBRIDGE CORP Whitmore Lake MI Permanently Closed, per EPA Envirofacts

Database

WOODBRIDGE CORPORATION WI Area Source, per EPA Envirofacts Database

WOODBRIDGE

CORPORATION

- KANSAS CITY

FOAM DIV MO Area Source, per EPA Envirofacts Database

WOODBRIDGE FOAM Romulus MI Area Source, not subject to III in permit.

WOODBRIDGE FOAM CORP Lithonia GA Area Source, Subject to OOOOOO per permit.
Woodbridge Foam Fabricating,

Inc. TN Area Source, per EPA Envirofacts Database

WOODBRIDGE GROUP Saint Peters MO Area Source, not subject to III in permit.