1 of 9 

### ENCLOSURE 1 INFORMATION COLLECTION REQUEST FOR Flexible Polyurethane Foam Production

We are conducting this I nformation C ollection R equest (ICR) to assist the EPA Administrator in developing emission standards for Flexible Polyurethane Foam under Clean Air Act (CAA) section 112. We are sending this ICR to you under the authority of Section 114 of the CAA.

BACKGROUND:

We are required by s ectio n 112(f)(2) of the Clean Air Act (CAA) to assess the risk remaining (residual risk) eight years after the application of maximum achievable control technology (MACT) standards under section 112(d). If we find the residual risk fails to protect public heal th with an ample margin of safety or to prevent (taking into consideration various factors) adverse environmental effects , we are required to promulgate more stringent standards

. T he Flexible Polyurethane Foam MACT standard was promulgated in October 1998 ( see 63 FR 53980). We are preparing to initiate our residual risk review. Please note this survey is for flexible polyurethane foam production only and does not cover flexible polyurethane foam fabrication, other than identifying if flexible polyurethan e foam fabrication is conducted as a co

- located operation.

S ection 114(a) of the CAA give s us the authority to require you to provide us with information for the following purposes:

1. Developing or assisting in the development of the following:

a. State implementation plans (§§ 110 and 111(d)); b. New Source Performance Standards (NSPS) (§ 111);

c. National Emissions Standards for Hazardous Air Pollutants (NESHAP) (§ 112); d. Solid waste combustion or other related solid waste regulations (§ 129); 2. Determining whet her any person is in violation of any standards or requirements developed under the authorities cited above; or 3. Carrying out any provision under the CAA (except certain provisions under Title II).

The Administrator may require that those persons identified above do the following so the Administrator may have the information necessary for the items listed in #1

- 3:

 make reports;

 establish and maintain records;

 install, use, and maintain monitoring equipment, and use audit procedures, or methods;

 sample emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as we shall prescribe);

 keep records on control equipment parameters, production variables or other indirect da ta when direct monitoring of emissions is impractical;

 submit compliance certifications in accordance with section 114(a)(3); and

 provide such other information as we may reasonably require.2 of 9



### We seek information on existin g f lexible p olyurethane f

oam pro duction sources in this survey in order to collect information needed to conduct the residual risk review required by section 112 of the Act

.

DIRECTIONS FOR COMPLETING THIS SURVEY :

You must complete and return this survey by December 6, 2011. You must identify clearly any response(s) that you consider to be confidential business information (CBI). Any responses not so identified will be included in a publicly available database. You may r efer to Enclosures

, 3, 4, 5, and 6 to learn how we wil l treat CBI a s well as what information you may be asked to submit later to substantiate a claim of confidentiality.

DEFINITIONS: For the purposes of this ICR only, use the following defin itions : Auxiliary blowing agent, or ABA, means a low

- boiling point liquid added to assist foaming by generating gas beyond that resulting from the isocyanate

- water reaction.

Flexible polyurethane foam means a flexible cellular polymer containing urea and carbamate linkages in the chain backbone produced by reacting a diisocyanate, polyol, and water. Flexible polyurethane foams are open

- celled, permit the passage of air through the foam, and possess the strength and flexibility to allow repeated distortion or compression under stress with essentia lly complete recovery upon removal of the stress.

Flexible polyurethane foam process means the equipment used to produce a flexible polyurethane foam product. For the purpose of this survey, the flexible polyurethane foam process includes raw material sto rage; production equipment and associated piping, ductwork, etc.; and curing and storage areas.

HAP ABA means methylene chloride, or any other HAP compound used as an auxiliary blowing agent.

Initial startup means the first time a new or reconstructed af fected source begins production of flexible polyurethane foam.

Rebond foam means the foam resulting from a process of adhering small particles of foam (usually
scrap or recycled foam) together to make a usable cushioning product. Various adhesives and bon ding processes are used. A typical application for rebond foam is for carpet underlay.

Rebond foam process means the equipment used to produce a rebond foam product. For the purpose of this subpart, the rebond f oam process includes raw material storage; p roduction equipment and associated piping, ductwork, etc.; and curing and storage areas.

Recovery device means an individual unit of equipment capable of and used for the purpose of recovering chemicals for use, reuse, or sale. Recovery devices include, but are not limited to, carbon adsorbers, absorbers, and condensers.

Slabstock flexible polyurethane foam means flexible polyurethane foam that is produced in large continuous buns that are then cut into the desired size and shape.3 of 9



### Slabstock flexible pol

yurethane foam production line includes all portions of the flexible polyurethane foam process from the mixhead to the point in the process where the foam is completely cured.

Storage vessel means a tank or other vessel that is used to store diisocyanate or HAP ABA for use in the production of flexible polyurethane foam. Storage vessels do not include vessels with capacities smaller than 38 cubic meters (or 10,000 gallons).

CONFIDENTIAL BUSINESS INFORMATION (CBI) :
Please indicate if any CBI is included in this survey response:  Y N

Flexible Polyurethane Foam Production Survey Form4 of 9



### PART I. OWNER INFORMATION

For questions 3 through 5, provide a separate Part I form for each facility , if you own or operate more than one facility

. 1 . Name of Legal Owner : FXI

a. Address: 1400 North Providence Road, Suite 2000
b. City: Media

c. State: Pennsylvania
d. Zip: 19063
e. County: Delaware

2 .Facility Name: FXI

– Fort Wayne Facility

3

. Complete street address of facility (physical location):

a. Address: 3000 Commercial Road
b. City: Fort Wayne

c. State: Indiana
d. Zip: 46809
e. County: Allen f. Longitude and Latitude coordinates [ in decimal degrees with five significant figures to the right of the decimal place (e.g., 38.2794 1

, - 85.64371) ] :

_ 41.007287
, - 85.17694

_______

4

. Facility Contact:
a. Name (First Name, Last Name): J oe Bertolini

b. Title: Corporate Technical Director
c. Telephone Number: (

610 ) 256

- 9744 Ext

_______ d. Fax Number: ( )

_ e. E

- mail address : jbertolini @fxi.com

f. Primary NAICS code for the facility____ 326150

_ ______________________

5. Flexible Polyurethane Foam Production

We believe that you own or operate a facility that engages in production of slabstock, molded or rebond f

lexible p olyurethane f

oam

. If you believe that this survey does not pertain to you, please indicate your reason below:

 Plant is permanently shut down. Please also identify the date the Foam Production plant was shut down and what steps were taken to close the Foam Production plant. Include date the permit was inactivated.5 of 9



### ________________________________ ________________________________ ___________

________________________________ ________________________________ ___________

________________________________ ________________________________ ___________

 No slabstock, rebond, or molded flexible polyurethane foam production plant is located at this facility.

If you do not operate a flexible polyurethane foam production plant (i.e., you check either box for question 5 ), w e will review that information and respond as to whether you need to complete any other part of the survey

Please mail, fax, or e

- mail Part I to:

U.S. EPA Mailroom

Attn: Sharon Nizich

Mail Code: D24 3

- 0 4 Research Triangle Park, NC 27711

Phone: 919 541 2825

Fax: 919 541

- 5450

Email address : Nizich.sharon@epa.gov6 of 9



### PART II. GENERAL FACILITY INFORMATION

1

. Please provide the following general information for each flexible polyurethane foam production p lant:

a. Number of employees at the facility where the flexible polyurethane foam production is located: 171 (as of November 2011)

b. Number of employees at the parent company, organization or institution (e.g. municipality, university, etc.) that owns the facility: 1
, 869 (as of November 2011)

c. Is the legal owner a small entity as defined by the Regulatory Flexibility Act ?

Refer to the Small Business Administration’s Size Standards at:

http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf

 Y  N  Unknown

[insert the following if applicable]

d. Any other co

- located operations and if so, what type of operation?

FXI

– Fort Wayne operates foam fabrication operations subject to 40 CFR Part 63, Subpart MMMMM

– National Emission Standards for Hazardous Air Pollutants: Flexible Polyurethane Foam Fabrication Operations. These co

located operations this MACT standard are not addressed anywhere in this ICR.

e. Are any operations on site subject to federal and State emission standards and if yes, which standards?

The facility operates under the Indiana Department of Environmental Management (IDEM) Title V Operating Permit No. T033

- 27321

- 00225 and is subject to t

he following emission standards:

326 IAC 2

- 7

- 5(1)

– Emission Limitations and Standards

326 IAC 6

- 3

-

2

– Particulate Emission Limitations for Processes with Process Weight Rates Less than One Hundred (100) Pounds per Hour

326 IAC 5

- 1

– Opacity

326 IAC 4

- 1 and IAC 13

- 17

- 9

– Open Burning

326 IAC 4

-

2 and 326 IAC 9

- 1

-

2

– Incineration

326 IAC 6

- 4

– Fugitive Dust Emissions

326 IAC 1

- 7

– Stack Height

326 IAC 14

- 10 and 326 IAC 18 and 40 CFR 61, Subpart M

– Asbestos

326 IAC 8

- 1

- 6

– Volatile Organic Compounds7 of 9



### 326 IAC 6

- 3

-

2

– Particulate

326 IAC 1

- 6

- 3 and 326 IAC 2

- 6

- 5(13)

– Preventative Maintenance

326 IAC 20

-

22 Flexible Polyurethane Foam Production

40 CFR Part 63 Subpart A

– National Emission Standards for Hazardous Air Pollutants

40 CFR Part 63, Subpart III

– Nat ional Emissions Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production

f. Is the facility a major source or area source? Major sources are all activities located on contiguous area under common control where the aggregate potential to emit for the activities exceeds ten (10) tons per year of a single HAP or twenty

- five (25) tons per year of a combination of HAPs.

FXI

– Fort Wayne Facility is a major source of HAP

.

g. Type of plant . Check all that apply.

 Molded Flexible Polyurethane Foam

 Slabstock Flexible Polyurethane Foam

 Rebond Foam Production

h. Please list information concerning storage tanks at this facility, including size, contents, estimated emissions of emitted pollutants, and piping charact eristics. Utilize a flow diagram if necessary. See Appendix A

- Table 1 and Figure 1 of CBI Submittal

2. Please provide a flow diagram of the process units associated with the flexible polyurethane foam production process at your facility. Label each pr ocess unit and emission point with a unique identification code and complete the table below.

The flow diagram should display an identification code for streams entering (raw materials/feedstocks ) and exiting the process unit (product streams), and emission streams. The flow diagram should also display an identification code for add

- on control devices and streams entering and exiting the add

- on control devices. Where applicable, include in

- proces s streams, waste streams, wastewater streams, and emission release points in the flow diagram

.

Identification code Description of item submitted with survey response PL

- 01 a Periplex pour line with integral mix chamber . See Appendix A

- Figure 1

PL

- 01b Ester pour line with integral mix chamber . See Appendix A

– Figure 2

TDI Tank TA TDI Tank TA (25,000 gallon tank) See Appendix A

- Figures 1 and Figure 28 of 9



### TDI Tank TB TDI Tank TB (32,000 gallon tank) See Appendix A

- Figure 1 and Figure 29 of 9



### 3

. List Federal air pollution control regulations applicable to each process unit.

Process unit name Process unit identification code Federal air pollution control regulation

Flexible Slabstock Polyurethane Foam Manufacturing Process PL01 (Includes PL

01a and PL

- 01b) 40 CFR Part 63 Subpart III

### Enclosure 2

2010 2009 2008 2010 2009 2008

(a) Production quantities of the PL-01a and PL-01b are aggregated. Foam production is not specified by production line.

(b) Note that feedstock volume of TDI is not tracked by individual tank. Therefore, annual feedstock amounts may reflect other HAP feedstock tanks which do not meet the definition of storage vessel (i.e. 10,000 gallons) for purposes of this ICR. 

### gallons N/A N/A N/A Submitted as CBI Submitted as

CBI Submitted as CBI board feet 1,721 1,414 1,962

TDI Tank TA, TDI
Tank TB (b) 

### TDI Tank TA, TDI Tank TB 5,398,597 4,512,026 6,113,577

Periphlex Pour Line, Ester Pour

Line PL-01a, PL-01b (a) 

### Process unit name Production Amount Production units (e.g., gallons, pounds) 

### PART III. FEEDSTOCK, RAW MATERIAL, AND PRODUCTION INFORMATION 1. Please complete the following table for production information for each process unit.

Average time each product was manufactured (hours)
Process unit name

### Enclosure 2

2010 2009 2008
TDI Tank TA, TDI Tank TB TDI 80/20 lbs 5,398,597 4,512,026 6,113,577

TDI 65/35 lbs 2,002,001 1,458,171 1,945,088

MDI lbs 209,596 202,448 597,849

(a) The process unit names for vessels containing MDI and TDI 65/35 have not been indicated as these tanks do not meet the criteria as storage vessels (i.e. 10,000 gallons) for the purpose of this ICR. 

### 2. Please complete the following table for Raw Materials/feedstocks entering each process unit. Include only HAP-containing feedstock.

N/A (a) 

### Process unit name Raw

material/feedstock Raw

material/feedstock Raw material/feedstock

### Enclosure 2

Raw material products/feedstock Auxiliary Blowing Agents Chemical Compounds % of each chemical compound (a)



### TDI 80/20 N/A 2,4-Toluene Diisocyanate (TDI) 80

TDI 65/35 N/A 2,4-Toluene Diisocyanate (TDI) 65

MDI N/A Methylene Diphenyl Diisocyanate (MDI) 59 (a) Percentages of the HAP contents for each of the feedstocks were derived from FXI's MSDS for these products. 

### 3. Provide composition information for feedstock/raw materials.

### Enclosure 2

Adhesive Name HAP Contained HAP Content (wt%) Annual Usage (lbs)

FXI - Fort Wayne does not use or have adhesives which contain HAP. 4. Are any HAP-containing adhesives utilized in repair of foam as part of the production process? No

### Enclosure 2a

Hours Per (e.g.,

week, month, year)

PL-01a Submitted as

CBI Submitted as

CBI Submitted as CBI

PL-01b Submitted as

CBI Submitted as

CBI Submitted as CBI

TDI Tank TA Submitted as CBI Submitted as

CBI Submitted as CBI 25,000 gallons

TDI Tank TB Submitted as CBI Submitted as

CBI Submitted as CBI 32,000 gallons Submitted as CBI

Submitted as CBI 9,000,000 Board Feet Submitted

as CBI

Submitted as CBI Owner Name: FXI, Inc

. _______________________________ Facility Name: FXI - Fort Wayne Facility

Process Unit ID: PL-01a, PL01b, Tank TA, Tank TB

PART IV. GENERAL FLEXIBLE POLYURETHANE FOAM PRODUCTION INFORMATION

Process unit ID Year unit

originally
installed Original capital

cost of unit(s) Remaining useful life

of unit Maximum design

capacity (e.g., lbs/day) Please complete the following questions for each Flexible Polyurethane Foam Production process unit. You are not expected to generate new information for this survey. Only supply data that are readily available to you.

Typical unit operation 1. Please provide the following information for each Flexible Polyurethane Foam Production process unit:

a. Provide general information for each process unit

### Enclosure 2a

Owner Name: FXI, Inc. __________________________ Facility Name: FXI - Fort Wayne Facililty

Process Unit ID: PL-01a, PL-01b, Tank TA, Tank TB

PL-01a
PL-01b
TDI Tank TA
TDI Tank TB Submitted as CBI air pollution control trains. b. Provide information on upgrades to each flexible polyurethane foam production process unit and associated

Description of upgrades made to air pollution control
devices associated with the Description of upgrades made to the process unit Year(s) upgrade was
made Process unit ID Year(s) upgrade was
made

### Enclosure 2a

Process Unit ID Total operating and

maintenance costs 2008 2009 2010

PL-01a Submitted as CBI Submitted as

CBI Submitted as

CBI

PL-01b Submitted as CBI Submitted as

CBI Submitted as

CBI Submitted as CBI c. Using the format on this page, include operating and maintenance cost information for each process unit. Definitions for different types of costs are taken from EPA Air Pollution Control Cost Manual at http://epa.gov/ttn/catc/products.html#cccinfo Owner Name: _ FXI, Inc. Facility Name: __ FXI - Fort Wayne Facility

Process Unit ID: PL-01a

### Enclosure 2a

2. Include yearly emissions information in the following table (include source of information).

Emission
Point Process Unit ID HAP Pollutant Tons per year
2006 Tons per year

2007 Tons per year

2008 Tons per year

2009 Tons per year

2010
Fugitive TDI Tank TA, TDI Tank TB 2,4-Toluene Diisocyanate 0.0025 0.0290 0.0290 0.0080 0.0102

Stack PL-01a, PL-01b, 2,4-Toluene Diisocyanate 0.0255 0.0550 0.0750 0.1560 0.1929

Fugitive Tanks (a) 

### 4,4'-Methylenediphenyl Diisocyanate 0.0025 0.0025 0.0025 0 0

Stack PL-01a, PL-01b 4,4'-Methylenediphenyl Diisocyanate 0.0160 0.0020 0.0025 0.0055 0.0056

(a) Tanks containing MDI do not meet the definition of a storage vessel (i.e. 10,000 gallons) for the purposes of this ICR. 

### unit. Owner Name: FXI, Inc. ________________________________ Facility Name: FXI - Fort Wayne Facility
Process Unit ID: PL-01a, PL-01b, TDI Tank TA, TDI Tank TB

Include storage tanks or any auxiliary equipment on site, per unit ID and label each as type of

(b) Additional footnote submitted as CBI.

### Enclosure 2a

No emissions tests on process units were conducted during the last five (5) years.

e. Submit a copy of the test reports. f. For pollutants measured with continuous emissions monitoring systems (CEMS), please submit a copy of the most recent Relative Accuracy Test Audit (RATA) for the last 30 day period including those days where manual testing was
conducted. Owner Name: FXI, Inc. _________________________________ Facility Name: FXI - Fort Wayne Facility Process Unit ID: ___________________________

3. Provide information on each emission test conducted at each specific process unit. Please copy this page and provide the following information for each test conducted at anytime in the last 5 years.

a. Identify the Process Unit ID: ___________________________________ b. Describe emission release point(s) that were tested: __________________________________________________ c. Date of test: ______________________________________ d. Specify the test method(s) used: ___________________________________________________________________

_________________________________________________________________________________________________

### Enclosure 2a

Operating cost
information 2008 2009 2010
Control device ID: Total operating costs Electricity costs

Wastwater treatment

costs Fuel costs

Water costs Waste disposal costs Process unit operating
labor costs Monitoring, recordkeeping, and reporting

Other (please describe):

________________

Other (please describe):

________________ __________________________________________________________________________________ j. Use the following table to provide the annual cost for operating and maintenance of each
control device. __________________________________________________________________________________

i. List the elements that are included in the installed cost estimate in question IV.5.h (e.g., ductwork, piping, foundation/supports, site preparation): __________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________ h. Original installed cost of the control device (capital cost of the control plus installation cost): b. Does the process unit have a control device that reduces air pollution : _____ Yes _____ No

c. Describe the release point(s) that are being controlled (e.g., equipment or unit operation where the release point is located): __________________________________________________

__________________________________________________________________________________

__________________________________________________________________________________

__________________________________________________________________________________

__________________________________________________________________________________

d. Type of control device: _____________________________________________________________

e. Year installed: _____________________________________________________________________

f. Manufacturer: _____________________________________________________________________

g. Model No: ________________________________________________________________________ a. Process Unit ID: _____________________________________________________________________ Owner Name: FXI, Inc. Facility Name: FXI - Fort Wayne Facility
Process Unit ID: Tank TA, and TB

______________

4. For each flexible polyurethane foam production process unit, provide the following information regarding air pollution control devices. Please copy this page and provide the following information for each unit:

Submitted as CBI

### Enclosure 2a

Process unit ID Measures or modification made to
minimize emissions Estimated emission reduction (lb/yr)

Tank TA, Tank TB Tanks vent to a carbon canister < 1 Owner Name: FXI, Inc. Facility Name: FXI - Fort Wayne Facility

Process Unit ID: Tanks TA, Tank TB

5. For each process unit identify measures (e.g., annual tune-ups or burners, good combustion practices, pollution prevention measures, or any other emission control approaches that reduce HAP emissions) or modifications made to the process unit to reduce emissions:

### Enclosure 2a

Emission reduction technique descriptions Pollutants affected Reduction efficiency

________________________ _______________________ ____________________

________________________ _______________________ ____________________

________________________ _______________________ ____________________

________________________ _______________________ ____________________

________________________ _______________________ ____________________

________________________ _______________________ ____________________ Owner Name: FXI, Inc. _______________________________ Facility Name: _ FXI - Fort Wayne Facility

_____________________________________________________________________________

c. At what frequency is parameter monitoring done? ______________________________________________

d. Describe initial and ongoing parameter monitoring quality assurance/control:

___________________________________________________________________________________________ reduce emissions, such as substitutions or product reformulation.

a. Complete for each emission reduction technique utilized that is not a control device.

b. What parameters are monitored to ensure operation of the emission reduction technique? 6. Other emission reduction techniques. Include any information about changes made in raw material usage to Process Unit ID: PL-01a, PL-01b

Submitted as CBI

___________________________________________________________________________________________

e. At what frequency is parameter monitor quality assurance/control (e.g., calibration) performed?

7. Please submit a copy of any cost information you have for the modification or emission reduction method (other than add-on control devices) listed above. ___________________________________________________________________________________________

___________________________________________________________________________________________

f. What is annual parameter monitoring cost?

___________________________________________________________________________________________

### Enclosure 2a

Emission source(s) causing

event Description of

event Permit

conditions
exceeded (Y/N) Date of

Event Duration

of each

event (hours) Was the event

covered by a contingency plan for controlling
emissions? (Y/N) Estimates

of
emissions during

event (pounds) Basis for

emissions
estimate Any monitoring data or

control system parameter monitoring collected during event? (Y/N) a. Please indicate number of times over the last 3 years that a shutdown and start-up event has occurred: ____________________________________________

b. Complete the following table for each shutdown and start-up event occurring over the last three years. Owner Name: FXI, Inc. _____________________________ Facility Name: FXI - Fort Wayne Facility Process Unit ID: ___________________________

8. Please provide the following information for each process unit during start-up and shutdown operation:

Submitted as CBI

### Enclosure 2a

c. Please list the procedures that are followed or any activities that occur during start-up and shutdown at this process unit to minimize emissions (e.g., turn off unit, monitor pressure):

d. Is the emission profile of the flexible polyurethane foam production unit different during start-up and shutdown than during normal operating conditions? _____ Yes __ ___No

e. If the answer to Part IV 9.d. is yes, please explain, in detail, how and why emissions are different

__________________________________________________________________________________ Owner Name: FXI, Inc. __________________ Facility Name: FXI - Fort Wayne Facility

Process Unit ID: PL-01a, PL-01b

Submitted as CBI

of the flexible polyurethane foam production process unit.

k. Are you required to submit periodic and immediate start-up and shutdown reports (either stand-alone or constrained within the periodic excess emissions report) to your permitting authority? _______________________________________________________________________________

i. What were the test conditions at the time of testing ? ________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

j. Please submit a copy of any test data you have conducted during any start-up or shutdown _______________________________________________________________________________ __________________________________________________________________________________

f. Do you have test data that show emissions during start-up or shutdown? __ Yes __ No

g. If yes, when and why did you conduct such testing? __________________________________

_______________________________________________________________________________

_______________________________________________________________________________

h. Please identify the emissions test method(s) used during start-up or shutdown.

_______________________________________________________________________________

_______________________________________________________________________________

### Enclosure 2a



### Longitude Latitude

1 Submitted as CBI Submitted as

CBI Submitted as CBI Submitted as CBI Submitted as CBI Submitted as CBI

2 Submitted as CBI Submitted as

CBI Submitted as CBI Submitted as CBI Submitted as CBI Submitted as CBI

3 Submitted as CBI Submitted as

CBI Submitted as CBI Submitted as CBI Submitted as CBI Submitted as CBI

4 Submitted as CBI Submitted as

CBI Submitted as CBI Submitted as CBI Submitted as CBI Submitted as CBI

5 Submitted as CBI Submitted as

CBI Submitted as CBI Submitted as CBI Submitted as CBI Submitted as CBI

9 Submitted as CBI Submitted as

CBI Submitted as CBI

10 Submitted as CBI Submitted as

CBI Submitted as CBI

11 Submitted as CBI Submitted as

CBI Submitted as CBI

12 Submitted as CBI Submitted as

CBI Submitted as CBI

19 Submitted as CBI Submitted as

CBI Submitted as CBI

21 Submitted as CBI Submitted as

CBI Submitted as CBI

22 Submitted as CBI Submitted as

CBI Submitted as CBI

23 Submitted as CBI Submitted as

CBI Submitted as CBI

24 Submitted as CBI Submitted as

CBI Submitted as CBI

25 Submitted as CBI Submitted as

CBI Submitted as CBI

26 Submitted as CBI Submitted as

CBI Submitted as CBI PL-01a

PL-01b Height of release point (feet) Exit of velocity of vent

release point (feet/second) Exit temperature of vent/flue gas (F)

Submitted as CBI Diameter of release point (feet) Owner Name: FXI, Inc. ______________________ Facility Name: FXI - Fort Wayne Facility
Process Unit ID: PL-01a, PL01b

9. Stack Release Parameters for Emission Points Please provide the following information for all emission release points for use in risk modeling



### Location of release point (decimal degrees, minimum 5 digits beyond

decimal) Emission
Point Process Unit ID

### Height of release
point (a) 

### Release Height (a) 

### Angle of
Rotation

Longitude Latitude (ft) (ft) x (length, ft) y (width, ft) (degrees)

Fugitive Building
Emissions Tank TA,

Tank TB Submitted

as CBI Submitted

as CBI Submitted as

CBI Submitted as CBI Submitted as CBI Submitted

as CBI Submitted

as CBI

been given. 

### Owner Name: FXI, Inc. Facility Name: FXI, Fort Wayne Facility

10. Non point releases. Please include a listing of fugitive releases, including the following information per release point. Please include "no releases" if this question does not apply. Notes on modeling data definitions are below.



### Dimension of Source Location of release point (decimal degrees, minimum 5 digits beyond decimal)

Emission
Point Process Unit

ID

(a) Since no direct ventiliation of the tank farm building exists, the building was treated as a fugitive source and (0.5) x the building height has

### Enclosure 2a

Not available

Not available b. Please list the pollutants that the scrubber is intended to reduce or remove. Owner Name: FXI, Inc. _________________ Facility Name: FXI - Fort Wayne Facility Process Unit ID: ___________________________

11. Scrubber

a. Does the flexible polyurethane foam production process unit have a scrubber?

_____ Yes __

___ No Submitted as CBI

k. Mist eliminator: _____ Yes _____ No _______________________________________________________________________________

_______________________________________________________________________________

c. Type of scrubber: _______________________________________________________________

d. Design pollutant-laden gas inlet flow rate: ______acfm

e. Design pollutant-laden gas inlet temperature: ________ o 

### F

f. Scrubbing medium (describe): ____________________________________________________

g. Influent scrubbing medium pH: ___________________________________________________

h. Effluent scrubbing medium pH: ___________________________________________________

i. Scrubber water flow: _________________________________________________ gals/min (?)

j. Scrubber pressure drop (across each scrubber--provide units): _________________________

_______________________________________________________________________________

n. What control devices are upstream of the scrubber? _________________________________

o. What control devices are downstream of the scrubber? ______________________________ l. Average outlet gas temperature for each scrubber: ________________________________ o 

### F

m. Please describe the source and quality of the water fed to the scrubber (e.g., effluent water with a total solids content of _____): _________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

### Enclosure 2a

Process Unit ID: Tank TA, Tank TB

Legal Owner Name: Facility Name:

Process Unit ID: Process Unit ID for controlled processes: Stack or Vent Height (ft) Stack or Vent Diameter (ft) Manufacturer/Model Original Installation Date Gas flow rate to condenser (acfm) Inlet gas temperature ( o 

### F)

Compound Name
Volume Fraction Compound Name
Volume Fraction Compound Name
Volume Fraction Compound Name
Volume Fraction

Describe any plans to replace or upgrade the adsorber Owner Name: FXI, Inc. ____________________ Facility Name: FXI - Fort Wayne Facility

12. Carbon Adsorber Please include a copy of this table for each carbon adsorber controlling emissions from flexible polyurethane foam production process unit.

CARBON ADSORBER

Organic compounds in inlet gas stream

Vendor guarantee on adsorber efficient (attach copy) Describe preventative maintenance procedures and frequency

List all monitoring methods used, including parameters and frequency Submitted as CBI

### Enclosure 2a



### Longitude Latitude 1 -85.175934° 41.007378° ≈ 22-24 8.9 80 3.7 2 -85.175934° 41.007333° ≈ 22-24 32.2 80 2.9 3 -85.175937° 41.007136° ≈ 22-24 16.9 80 4.2 4 -85.175936° 41.007028° ≈ 22-24 44.5 80 4.2 5 -85.175924° 41.006939° ≈ 22-24 7.4 80 3.7 9 -85.175878° 41.007284° ≈ 22-24 10 -85.175874° 41.007187° ≈ 22-24
11 -85.175874° 41.007160° ≈ 22-24
12 -85.175872° 41.006982° ≈ 22-24 19 -85.175882° 41.007395° ≈ 22-24
21 -85.176472° 41.008344° ≈ 22-24
22 -85.176471° 41.008264° ≈ 22-24 23 -85.176475° 41.008223° ≈ 22-24
24 -85.176484° 41.008161° ≈ 22-24 25 -85.176469° 41.007965° ≈ 22-24 26 -85.176461° 41.007799° ≈ 22-24 Owner Name: FXI, Inc. ______________________ Facility Name: FXI - Fort Wayne Facility
Process Unit ID: PL-01a, PL01b

9. Stack Release Parameters for Emission Points Please provide the following information for all emission release points for use in risk modeling



### Location of release point (decimal degrees, minimum 5 digits beyond

decimal) Emission
Point Process Unit ID

PL-01a

PL-01b Height of release point (feet) Exit of velocity of vent

release point (feet/second) Exit temperature of vent/flue gas (F)

Not available Diameter of release point (feet)

### Height of release point

(a) 

### Release Height (a) 

### Angle of
Rotation

Longitude Latitude (ft) (ft) x (length, ft) y (width, ft) (degrees)

Fugitive Building
Emissions Tank TA,

Tank TB -85.176306° 41.007313° 10 10 45 75 92

been given. 

### Dimension of Source Location of release point (decimal degrees, minimum 5 digits beyond decimal) Emission
Point Process Unit

ID

(a) Since no direct ventiliation of the tank farm building exists, the building was treated as a fugitive source and (0.5) x the building height has 

### Owner Name: FXI, Inc. Facility Name: FXI, Fort Wayne Facility

10. Non point releases. Please include a listing of fugitive releases, including the following information per release point. Please include "no releases" if this question does not apply. Notes on modeling data definitions are below.

## I NDIANA 

## D EPARTMENT OF 

## E NVIRONMENTAL 

## M ANAGEMENT
We Protect Hoosiers and Our Environment.
Mitchell E. Daniels Jr. 100 North Senate Avenue
Governor Indianapolis, Indiana 46204 (317) 232-8603 Thomas W. Easterly Toll Free (800) 451-6027
Commissioner www.idem.IN.gov

Page 1 of 2 FNTV-PMOD.dot 1/2/08

Recycled Paper An Equal Opportunity Employer Please Recycle TO: Interested Parties / Applicant

DATE: May 26, 2011

RE: Foamex Innovations / 003-30247-00225

FROM: Matthew Stuckey, Branch Chief Permits Branc h Office of Air Quality


## Notice of Decision: Approval – Effective Immediately

Please be advised that on behalf of the Commissioner of the Department of Environmental Management, I have issued a decision regarding the enclosed matter. Pursuant to IC 13-17-3-4 and 326 IAC 2, this permit modification is effective immediately, unless a petition for stay of effect iveness is filed and granted, and may be revoked or modified in accordance with the provisions of IC 13-15-7-1.

If you wish to challenge this decision, IC 4-21.5-3-7 an d IC 13-15-7-3 require that you file a petition for administrative review. This petition may include a request for st ay of effectiveness and must be submitted to the Office Environmental Adjudication, 100 North Senate Avenue, Government Center North, Suite N 501E, Indianapolis, IN 46204, within eighteen (18) days of the mailing of this notice . The filing of a petition for administrative review is complete on the ear liest of the following dates that apply to the filing: (1) the date the document is delivered to the Office of Environmental Adjudication (OEA); (2) the date of the postmark on the envelope contai ning the document, if the document is mailed to OEA by U.S. mail; or (3) The date on which the document is deposited with a private carrier, as shown by receipt issued by the carrier, if the document is sent to the OEA by private carrier.

The petition must include facts demonstrating that you are either the applicant, a person aggrieved or adversely affected by the decision or otherwise entitled to review by law. Please identify the permit, decision, or other order for which you seek review by permit number, name of the applicant, location, date of this notice and all of the following: (1) the name and address of the person making the request; (2) the interest of the person making the request; (3) identification of any persons repres ented by the person making the request; (4) the reasons, with particularity, for the request; (5) the issues, with particularity, proposed for considerations at any hearing; and (6) identification of the terms and conditions wh ich, in the judgment of the person making the request, would be appropriate in the case in question to satisfy the requirements of the law governing documents of the type issued by the Commissioner.Pursuant to 326 IAC 2-7-18(d), any person may petition the U.S. EPA to object to the issuance of a Title V operating permit or modification within sixty (60) days of the end of the forty-five (45) day EPA review period. Such an objection must be based only on issues that were raised with reasonable specificity during the public comment period, unless the petitioner demonstrates that it was impractible to raise such issues, or if the grounds for such objection arose after the comment period.

To petition the U.S. EPA to object to the iss uance of a Title V operating permit, contact:

U.S. Environmental Protection Agency 401 M Street Washington, D.C. 20406

If you have technical questions regarding the enclos ed documents, please contact the Office of Air Quality, Permits Branch at (317) 233-0178. Calle rs from within Indiana may call toll-free at 1-800-451- 6027, ext. 3-0178.

Enclosures FNTV-PMOD.doc 3/27/08Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 3 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

Compliance Requirements [326 IAC 2-1.1-11] C.8 Compliance Requirements [326 IAC 2-1.1-11]

Compliance Monitoring Requirements [ 326 IAC 2-7-5(1)][326 IAC 2-7-6(1)] C.9 Compliance Monitoring [326 IAC 2-7-5(3)][326 IAC 2-7-6(1)] C.10 Reserved C.11 Instrument Specifications [326 IA C 2-1.1-11] [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)]

Corrective Actions and Response Steps [326 IAC 2-7-5][326 IAC 2-7-6] C.12 Emergency Reduction Plans [ 326 IAC 1-5-2] [326 IAC 1-5-3] C.13 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68] C.14 Response to Excursions or Exceedan ces [326 IAC 2-7-5] [326 IAC 2-7-6] C.15 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-7-5] [326 IAC 2-7-6]

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

C.16 Emission Statement [326 IAC 2-7-5(3)(C)( iii)][326 IAC 2-7-5(7)][326 IAC 2-7-19(c)] [326 IAC 2-6] C.17 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6] [326 IAC 2-2] [326 IAC 2-3] C.18 General Reporting Requirements [326 IA C 2-7-5(3)(C)] [326 IAC 2-1.1-11] [326 IAC 2-2]

Stratospheric Ozone Protection C.19 Compliance with 40 CFR 82 and 326 IAC 22-1

D.1 FACILITY OPERATION CONDITIONS - FL-02, TR U-01, FPC, FPD, FPE, TRU-02, Loop slitters Emission Limitations and Sta ndards [326 IAC 2-7-5(1)] ................................................................... 28

D.1.1 Volatile Organic Compounds (VOC ) [326 IAC 8-1-6][326 IAC 2-4.1-1] D.1.2 Volatile Organic Compounds [326 IAC 8-1-6] [326 IAC 2-4.1-1] D.1.3 Particulate [326 IAC 6-3-2] D.1.4 Preventive Maintenance Plan [326 IAC 2-7-5(13)]

Compliance Determination Requirements D.1.5 Testing Requirements [326 IA C 2-7-6(1),(6)] [326 IAC 2-1.1-11]

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.1.6 Record Keeping Requirements D.1.7 Rep orting Requirements

D.2 FACILITY OPERATION CONDITIO NS - PL-01c, CL-01 .................................................................. 32 Emission Limitations and Sta ndards [326 IAC 2-7-5(1)]

D.2.1 Volatile Organic Compounds (VOC ) [326 IAC 2-2-3] [326 IAC 8-1-6] D.2.2 Preventive Maintenance Plan [326 IAC 2-7-5(13)] [326 IAC 1-6-3]

Compliance Determination Requirements D.2.3 Volatile Organic Compounds (VOC ) [326 IAC 8-1-4] [326 IAC 8-1-2(a)]

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.2.4 Record Keeping Requirements D.2.5 Rep orting Requirements

D.3 FACILITY OPERATION CONDITIONS - Two (2) 12.6 MMBtu/hr boilers ....................................... 35 Emission Limitations and Sta ndards [326 IAC 2-7-5(1)]

D.3.1 Particulate [326 IAC 6-2-3]Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 4 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

D.3.2 Sulfur Dioxide (SO 2 ) [326 IAC 7-1.1-1] [326 IAC 12-1] D.3.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)]

Compliance Determination Requirements D.3.4 Sulfur Dioxide Emi ssions and Sulfur Content

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.3.5 Record Keeping Requirements D.3.6 Rep orting Requirements

D.4 FACILITY CONDITIONS - Insignifican t Activi ties .........................................................................3 7 Emission Limitations and Sta ndards [326 IAC 2-7-5(1)]

D.4.1 Volatile Organic Compounds (VOC) [326 IAC 8-3-2] D.4.2 Particulate [326 IAC 6-3-2]

SECTION E.1 FACILITY O PERATION CONDITIONS .............................................................................. 39 E.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CF R Part 63, Subpart A] E.1.2 Flexible Polyurethane Foam Productio n [40 CFR Part 63, Subpart III] [326 IAC 20-22] E.1.3 One-Time Deadlines Relating to Flexible Polyurethane Foam Production Notifications [40 CFR Part 63, Subpart III]

SECTION E.2 FACILITY OPER ATION CONDITIONS .............................................................................. 41 E.2.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CF R Part 63, Subpart A] E.2.2 Flexible Polyurethane Foam Fabrication Operations [40 CFR Part 63, Subpart MMMMM] [326 IAC 20-66] E.2.3 One-Time Deadlines Relating to Flexible Polyurethane Foam Production Notifications [40 CFR Part 63, Subpart MMMMM]

Certification...........................

....................................................................................... ........................... 43 Emergency Occurrence Report................................

.................................................................... ......... 44 Semi-Annual Natural Gas Fired Boile r Certification...........................

................................................. 46 Quarterly Reports................................................................................................................................... 47 Quarterly Deviation and Compliance Monitoring Repor t................................................................... 50

Attachment A - NESHAP, Subpart III Attachment B - NESHAP, Subpart MMMMMFoamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 5 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

SECTION A SOURCE SUMMARY

This permit is based on information requested by the Indiana Department of Environmental Management (IDEM), Office of Air Quality (OAQ). The informat ion describing the source contained in conditions A.1 through A.3 is descriptive information and does not constitute enforceable conditions. However, the Permittee should be aware that a physical change or a change in the method of operation that may render this descriptive information obsolete or inac curate may trigger requirements for the Permittee to obtain additional permits or seek modification of this permit pursuant to 326 IAC 2, or change other applicable requirements presented in the permit application.

A.1 General Information [326 IAC 2-7-4(c) ][326 IAC 2-7-5(15)][326 IAC 2-7-1(22)] The Permittee owns and operates a stationary flexible polyurethane foam production and processing plant.

Source Address: 3005 Commercial Road, Fort Wayne, Indiana 46809 General Source Phone Number: (260) 747-7485 SIC Code: 3086 County Location: Allen Source Location Status: Attainm ent for all criteria pollutants Source Status: Part 70 Operating Permit Program Major Source, under PSD Rules Major Source, Section 112 of the Clean Air Act Not 1 of 28 Source Categories

A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)][326 IAC 2-7-5(15)] This stationary source consists of the follo wing emission units and pollution control devices:

(a) One (1) flexible slabstock polyurethane foam manufacturing process (ID No. PL-01), producing a maximum of nine (9) million boar d feet per day of polyurethane foam, consisting of:

(1) One (1) periphlex pour line with integral mix chamber, identified as PL-01a,, constructed in 1986, exhausting through ten (10) stacks (ID Nos. 1-5, 9-12, and 19)

(2) One (1) ester pour line with integral mix chamber, identified as PL-01b, constructed in 1968, exhausting throug h six (6) stacks (ID Nos. 21-26)

(3) One (1) polyurethane foam production line with integral mix chamber, identified as PL-01c, approved in 2010 for construction, exhausting to five (5) stacks (ID Nos. 60-64)

(4) Three (3) foam bun storage areas (Carpet Underlay Mezzanine Bun Grabber Area, South Finishing Mezzanine Bun Gr abber Area, and the Loaf Stacker Area), exhausting through fourteen (14) stacks (ID Nos. 13-15, 17, 18, 20, 27-33, and 49)

Under 40 CFR 63 (NESHAP), Subpart III, PL-01 is considered an existing flexible polyurethane foam or rebond foam process.

(b) One (1) natural gas flame laminator machine (ID No. FL-02), constructed in 1995, with a maximum capacity of 40,000 square feet per hour, with a heat input capacity of 0.35 MMBtu/hr, and exhausting through two (2) stacks (ID Nos. 02-002 and FL2). Under 40 CFR 63 (NESHAP), Subpart MMMMM, the FL -02 is considered an existing flameFoamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 6 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

lamination affected source.

(c) One (1) thermal reticulation unit (ID No. TRU-01), constructed in 1968 and modified in 2007, with a maximum throughput of 87,000 cycles per year, and exhausting through nine (9) stacks (ID Nos. 35-43).

(d) Two (2) natural gas fired boilers (ID Nos. IPB-01 and IPB-02), each constructed in 1968, each rated at 14.6 million (MM) British thermal units (Btu) per hour, using No. 2 distillate fuel oil as back-up fuel, and each exhausti ng through one (1) stack (ID Nos. 45 and 46).

(e) One (1) thermal reticulation unit (ID No. TRU-02), approved for construction in 2007, with a maximum throughput of 87,600 cycles per y ear, exhausting through eight (8) stacks (ID Nos. 52-59)

(f) One (1) thermal reticulation unit, approved in 2011 for construction, identified as TRU-03, with a maximum capacity of 58,800 cycles per year, uncontrolled, and exhausting to eight (8) stacks.

(g) One (1) polyurethane foam coating line, identified as CL-01, approved in 2010 for construction, utilizing flow coat technolog y, exhausting to one (1) stack (ID No. 65)

A.3 Insignificant Activities [326 IAC 2-7-1(21)][326 IAC 2-7-4(c)][326 IAC 2-7-5(15)] This stationary source also includes the follo wing insignificant activities as defined in 326 IAC 2-7-1(21):

(a) Degreasing operations that do not exceed 145 gallons per 12 months, except if subject to 326 IAC 20-6 (cold cleaner degreasing operation with several remote solvent reservoirs). [326 IAC 8-3-2]

(b) The following equipment related to manufacturing activities not resulting in the emission of HAPs: brazing equipment, cutting torches, soldering equipment, welding equipment. [326 IAC 6-3-2]

(c) Trimmers that do not produce fugitive emissions and that are equipped with a dust collection or trim material recovery device such as a bag filter or cyclone. [326 IAC 6-3-2]

(d) Grinding and machining operations controll ed with fabric filters, scrubbers, mist collectors, wet collectors, and electrostatic pr ecipitators with a design grain loading of less than or equal to 0.03 grains per actual cubic foot and a gas flow rate less than or equal to 4000 actual cubic feet per minu te, including the following: deburring, buffing, polishing, abrasive blasting, pneumatic conveying, and woodworking operations. [326 IAC 6-3-2]

(e) TDI storage tanks with activated carbon (T DI emissions less than 1 pound per day and 1 ton per year). [40 CFR 63, Subpart III]

(f) MDI storage tanks with MDI emissions less than 1 pound per day and 1 ton per year. [40 CFR 63, Subpart III]

(g) Polyol storage tanks with VOC emissions less than 3 pounds per hour or 15 pounds per day (one tank has a storage capacity of 30,000 gallons). [326 IAC 12][40 CFR 63, Subpart III]

(h) One (1) felter (FPB) with VOC emissions less than 3 pounds per hour or 15 pounds per day, CO emissions less than 25 pounds per day, and PM emissions less than 5 poundsFoamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 7 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

per hour or 25 pounds per day. [326 IAC 6-3-2]

(i) One (1) skinner with VOC emissions less than 3 pounds per hour or 15 pounds per day, CO emissions less than 25 pounds per day, and NO X and PM emissions less than 5 pounds per hour or 25 pounds per day. [326 IAC 6-3-2]

(j) One (1) hot wire cutter with VOC emissions less than 3 pounds per hour or 15 pounds per day, CO emissions less than 25 pounds per day, and NO X and PM emissions less than 5 pounds per hour or 25 pounds per day. [326 IAC 6-3-2]

(k) Bun cutters. [326 IAC 6-3-2]

(l) BSV slitters. [326 IAC 6-3-2]

(m) One (1) VOC (N-ethylmorpholine) storage tank with VOC emissions less than 3 pounds per hour or 15 pounds per day. [40 CFR 63, Subpart III]

(n) One (1) 20,000 gallon No. 2 fuel oil storage tank with VOC emissions less than 3 pounds per hour or 15 pounds per day. [326 IAC 12]

(o) One (1) 6,000 gallon storage tank containing an organic chemical blend. [326 IAC 8-9-1]

(p) Five (5) felt presses, identified as F PA, FPC, FPD, FPE and FPF with VOC emissions less than 3 pounds per hour or 15 pounds per day, CO emissions less than 25 pounds per day, and PM emissions less than 5 pounds per hour or 25 pounds per day. [326 IAC 6-3-2]

(q) Natural gas-fired combustion sources with heat input equal to or less than ten million (10,000,000) Btu per hour.

(r) The following VOC and HAP storage containers: (1) Storage tanks with capacity less than or equal to 1,000 gallons and annual throughputs less than 12,000 gallons. (2) Vessels storing lubricating oils, hydraulic oils, machining oils, and machining fluids.

(s) Equipment used exclusively for the following: (1) packaging lubricants and greases. (2) filling drums, pails or other packaging co ntainers with lubricating oils, waxes, and
greases.

(t) Application of oils, greases, lubricants or other nonvolatile materials applied as temporary protective coatings.

(u) Cleaners and solvents characterized as follows: (1) having a vapor pressure equal to or less than 2 kPa, 15 mmHg, or 0.3 psi measured at 38 degrees C (100oF); or (2) having a vapor pressure equal to or less than 0.7 kPa, 5 mmHg, or 0.1 psi measured at 20oC (68oF), the use of which for all cleaners and solvents combined does not exceed 145 gallons per 12 months

(v) Closed loop heating and cooling systems.

(w) Infrare d cure equipment.

(x) Activities associated with the treatment of wastewater streams with an oil and greaseFoamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 8 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

content less than or equal to 1% by volume.

(y) Water based adhesives that are less than or equal to 5% by volume of VOCs excluding HAPs. (z) Replacement or repair of electrostatic precip itators, bags in baghouses and filters in other air filtration equipment.

(aa) Heat exchanger cleaning and repair. (bb) Process vessel degassing and cleaning to prepare for internal repairs.

(cc) Paved and unpaved roads and parking lots with public access.

(dd) Blowdown for any of the following: sight glass, boiler, compressors, pumps, and cooling tower.

(ee) Natural gas turbines or reciprocating engines not exceeding 16,000 horsepower for an emergency generator.

(ff) Other emergency equipment as follows: stationary fire pumps.

(gg) Purge double block and bleed valves.

(hh) Mold release agents using low volatile produ cts (vapor pressure less than or equal to 2 kilopascals measured at 38 degrees Celsius).

(ii) Ink handling and applications with VOC emissions less than 3 pounds per hour or 15 pounds per day.

(jj) Amines storage tanks with VOC emissions less than 3 pounds per hour or 15 pounds per day.

(kk) Fire retardant storage tanks with VO C emissions less than 3 pounds per hour or 15 pounds per day.

(ll) One (1) hot roll laminator.

(mm) Prep saws.

(nn) Two (2) Baumer loop slitters using an n-propyl bromide based adhesive.

(oo) Scra p bailers.

(pp) Horizontal slitters with no adhesive usage.

(qq) One (1) dry raw material mix station with PM emissions less than 5 pounds per hour or 25 pounds per day.

A.4 Part 70 Permit Applicability [326 IAC 2-7-2] This stationary source is required to have a Part 70 permit by 326 IAC 2-7-2 (Applicability) because:

(a) It is a major source, as defined in 326 IAC 2-7-1(22);

(b) It is a source in a source category de signated by the United States Environmental Protection Agency (U.S. EPA) under 40 CFR 70.3 (Part 70 - Applicability).Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 9 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

SECTION B GENERAL CONDITIONS

B.1 Definitions [326 IAC 2-7-1] Terms in this permit shall have the definition assigned to such terms in the referenced regulation. In the absence of definitions in the referenced regulation, the applicable definitions found in the statutes or regulations (IC 13-11, 326 IAC 1-2 and 326 IAC 2-7) shall prevail.

B.2 Permit Term [326 IAC 2-7-5(2)][326 IAC 2-1.1- 9.5][326 IAC 2-7-4(a)(1)(D)][IC 13-15-3-6(a)] (a) This permit, T003-27321-00225, is issued for a fixed term of five (5) years from the issuance date of this permit, as determi ned in accordance with IC 4-21.5-3-5(f) and IC 13-15-5-3. Subsequent revisions, modifications, or amendments of this permit do not affect the expiration date of this permit.

(b) If IDEM, OAQ, upon receiving a timely and complete renewal permit application, fails to issue or deny the permit renewal prior to the expiration date of this permit, this existing permit shall not expire and all terms and conditions shall continue in effect, including any permit shield provided in 326 IAC 2-7-15 , until the renewal permit has been issued or denied.

B.3 Term of Conditions [326 IAC 2-1.1-9.5] Notwithstanding the permit term of a permit to construct, a permit to operate, or a permit modification, any condition established in a permit issued pursuant to a permitting program approved in the state implementation pl an shall remain in effect until:

(a) the condition is modified in a subsequent permit action pursuant to Title I of the Clean Air Act; or

(b) the emission unit to which the conditi on pertains permanently ceases operation.

B.4 Enforceability [326 IAC 2-7-7] [IC 13-17-12] Unless otherwise stated, all terms and conditions in this permit, including any provisions designed to limit the source's potential to emit, are enforceable by IDEM, the United States Environmental Protection Agency (U.S. EPA) and by citizens in accordance with the Clean Air Act.

B.5 Severability [326 IAC 2-7-5(5)] The provisions of this permit are severable; a determination that any portion of this permit is invalid shall not affect the validity of the remainder of the permit.

B.6 Property Rights or Exclusive Privilege [326 IAC 2-7-5(6)(D)] This permit does not convey any property ri ghts of any sort or any exclusive privilege.

B.7 Duty to Provide Inform ation [326 IAC 2-7-5(6)(E)] (a) The Permittee shall furnish to IDEM, OAQ, within a reasonable time, any information that IDEM, OAQ may request in writing to determ ine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. Upon request, the Permittee shall also furnish to IDEM, OAQ copies of records required to be kept by this permit.

(b) For information furnished by the Permittee to IDEM, OAQ, the Permittee may include a claim of confidentiality in accordance with 326 IAC 17.1. When furnishing copies of requested records directly to U. S. EPA , the Permittee may assert a claim of confidentiality in accordance with 40 CFR 2, Subpart B.

B.8 Certification [326 IAC 2-7-4(f)][326 IAC 2-7-6(1) ][326 IAC 2-7-5(3)(C)] (a) A certification required by the permit meet s the requirements of 326 IAC 2-7-6(1) if:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 10 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(1) it contains a certification by a "respo nsible official", as defined by 326 IAC 2-7- 1(34), and

(2) the certification states that, based on information and belief formed after reasonable inquiry, the statements and in formation in the document are true, accurate, and complete.

(b) The Permittee may use the attached Certification Form, or its equivalent, with each submittal requiring certification. One (1) certification may cover multiple forms in one (1) submittal.

(c) A "responsible official" is defined at 326 IAC 2-7-1(34).

B.9 Annual Compliance Certif ication [326 IAC 2-7-6(5)] (a) The Permittee shall annually submit a co mpliance certification report which addresses the status of the source’s compliance with the terms and conditions contained in this permit, including emission limitations, standards, or work practices. All certifications shall cover the time period from January 1 to Dece mber 31 of the previous year, and shall be submitted no later than July 1 of each year to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

and

United States Environmental Protection Agency, Region V Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590

(b) The annual compliance certification report re quired by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ on or before the date it is due.

(c) The annual compliance certification report shall include the following:

(1) The appropriate identification of each term or condition of this permit that is the basis of the certification;

(2) The compliance status;

(3) Whether compliance was continuous or intermittent;

(4) The methods used for determining the co mpliance status of the source, currently and over the reporting period consistent with 326 IAC 2-7-5(3); and

(5) Such other facts, as specified in Sect ions D of this permit, as IDEM, OAQ may require to determine the compliance status of the source.Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 11 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

The submittal by the Permittee does require a certification that meet s the requirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

B.10 Preventive Maintenance Plan [326 IAC 2-7- 5(1),(3) and (13)][326 IAC 2-7-6(1) and (6)][326 IAC 1-6-3] (a) A Preventive Maintenance Plan (PMP) meet s the requirements of 326 IAC 1-6-3 if it includes, at a minimum:

(1) Identification of the individual(s) res ponsible for inspecting, maintaining, and repairing emission control devices;

(2) A description of the items or conditions that will be inspected and the inspection schedule for said items or conditions; and

(3) Identification and quantific ation of the replacement pa rts that will be maintained in inventory for quick replacement.

(b) If required by specific condition(s) in Section D of this permit where no PMP was previously required, the Permittee shall pr epare and maintain Preventive Maintenance Plans (PMPs) no later than ninety (90) days a fter issuance of this permit or ninety (90) days after initial start-up, whichever is later, including the following information on each facility:

(1) Identification of the individual(s) res ponsible for inspecting, maintaining, and repairing emission control devices;

(2) A description of the items or conditions that will be inspected and the inspection schedule for said items or conditions; and

(3) Identification and quantific ation of the replacement pa rts that will be maintained in inventory for quick replacement.

If, due to circumstances bey ond the Permittee’s control, the PMPs cannot be prepared and maintained within the above time fram e, the Permittee may extend the date an additional ninety (90) days provided the Permittee notifies:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

The PMP extension notification does not require a certification that meets the requirements of 326 IAC 2-7-6(1) by a "respo nsible official", as defined by 326 IAC 2-7- 1(34).

(c) A copy of the PMPs shall be submitted to IDEM, OAQ upon request and within a reasonable time, and shall be subject to review and approval by IDEM, OAQ. IDEM, OAQ may require the Permittee to revise its PMPs whenever lack of proper maintenance causes or is the primary contributor to an exceedance of any limitation on emissions. PMPs and their submittal do not require a cert ification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible offici al" as defined by 326 IAC 2-7-1(34).Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 12 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(d) To the extent the Permittee is required by 40 CFR Part 60/63 to have an Operation Maintenance, and Monitoring (OMM) Plan for a unit, such Plan is deemed to satisfy the PMP requirements of 326 IAC 1-6-3 for that unit.

B.11 Emergency Provisions [326 IAC 2-7-16] (a) An emergency, as defined in 326 IAC 2-7- 1(12), is not an affirmative defense for an action brought for noncompliance with a federal or state health-based emission limitation.

(b) An emergency, as defined in 326 IAC 2-7-1( 12), constitutes an affirmative defense to an action brought for noncompliance with a technology-based emission limitation if the affirmative defense of an emergency is demonstrated through properly signed, contemporaneous operating logs or other rele vant evidence that describe the following:

(1) An emergency occurred and the Permitt ee can, to the extent possible, identify the causes of the emergency;

(2) The permitted facility was at the time being properly operated;

(3) During the period of an emergency, the Permittee took all reasonable steps to minimize levels of emissions that ex ceeded the emission standards or other requirements in this permit;

(4) For each emergency lasting one (1) hour or more, the Permittee notified IDEM, OAQ, within four (4) daytime business hours after the beginning of the emergency, or after the emergency was discovered or reasonably should have been discovered;

Telephone Number: 1-800-451-6027 (ask for Office of Air Quality, Compliance and Enforcement Branch), or Telephone Number: 317-233-0178 (ask for Compliance and Enforcement Branch) Facsimile Number: 317-233-6865

(5) For each emergency lasting one (1) hour or more, the Permittee submitted the attached Emergency Occurrence Report Form or its equivalent, either by mail or facsimile to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

within two (2) working days of the time when emission limitations were exceeded due to the emergency.

The notice fulfills the requirement of 326 IA C 2-7-5(3)(C)(ii) and must contain the following:

(A) A description of the emergency;

(B) Any steps taken to mitigate the emissions; and

(C) Corrective actions taken.Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 13 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

The notification which shall be submitted by the Permittee does not require a certification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

(6) The Permittee immediately took all re asonable steps to correct the emergency.

(c) In any enforcement proceeding, the Permitt ee seeking to establish the occurrence of an emergency has the burden of proof.

(d) This emergency provision supersedes 326 IA C 1-6 (Malfunctions). This permit condition is in addition to any emergency or upset provision contained in any applicable requirement.

(e) The Permittee seeking to establish the oc currence of an emergency shall make records available upon request to ensure that failure to implement a PMP did not cause or contribute to an exceedance of any limitations on emissions. However, IDEM, OAQ may require that the Preventive Maintenance Pl ans required under 326 IAC 2-7-4(c)(9) be revised in response to an emergency.

(f) Failure to notify IDEM, OAQ by telephone or facsimile of an emergency lasting more than one (1) hour in accordance with (b)(4) and (5) of this condition shall constitute a violation of 326 IAC 2-7 and any other applicable rules.

(g) If the emergency situation causes a deviation from a technology-based limit, the Permittee may continue to operate the affect ed emitting facilities during the emergency provided the Permittee immediately takes a ll reasonable steps to correct the emergency and minimize emissions.

B.12 Permit Shield [326 IAC 2-7-15][326 IAC 2-7-20][326 IAC 2-7-12] (a) Pursuant to 326 IAC 2-7-15, the Permittee has been granted a permit shield. The permit shield provides that compliance with the conditions of this permit shall be deemed compliance with any applicable requirements as of the date of permit issuance, provided that either the applicable requirements are in cluded and specifically identified in this permit or the permit contains an explicit determination or concise summary of a determination that other specifically iden tified requirements are not applicable. The Indiana statutes from IC 13 and rules from 326 IAC, referenced in conditions in this permit, are those applicable at the time the permit was issued. The issuance or possession of this permit shall not alone constitute a defense against an alleged violation of any law, regulation or standard, except for the requirement to obtain a Part 70 permit under 326 IAC 2-7 or for applicable requirements for which a permit shield has been granted.

This permit shield does not extend to applicable requirements which are promulgated after the date of issuance of this permit unless this permit has been modified to reflect such new requirements.

(b) If, after issuance of this permit, it is deter mined that the permit is in nonconformance with an applicable requirement that applied to the source on the date of permit issuance, IDEM, OAQ, shall immediately take steps to reopen and revise this permit and issue a compliance order to the Permittee to ensure expeditious compliance with the applicable requirement until the permit is reissued. The per mit shield shall continue in effect so long as the Permittee is in compliance with the compliance order.

(c) No permit shield shall apply to any permi t term or condition that is determined after issuance of this permit to have been bas ed on erroneous information supplied in theFoamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 14 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

permit application. Erroneous information m eans information that the Permittee knew to be false, or in the exercise of reasonable ca re should have been known to be false, at the time the information was submitted.

(d) Nothing in 326 IAC 2-7-15 or in this pe rmit shall alter or affect the following:

(1) The provisions of Section 303 of the Cl ean Air Act (emergency orders), including the authority of the U.S. EPA under Section 303 of the Clean Air Act;

(2) The liability of the Permittee for any vi olation of applicable requirements prior to or at the time of this permit's issuance;

(3) The applicable requirements of the acid rain program, consistent with Section 408(a) of the Clean Air Act; and

(4) The ability of U.S. EPA to obtain inform ation from the Permittee under Section 114 of the Clean Air Act.

(e) This permit shield is not applicable to any change made under 326 IAC 2-7-20(b)(2) (Sections 502(b)(10) of the Clean Air Ac t changes) and 326 IAC 2-7-20(c)(2) (trading based on State Implementation Plan (SIP) provisions).

(f) This permit shield is not applicable to modifications eligible for group processing until after IDEM, OAQ, has issued the modifi cations. [326 IAC 2-7-12(c)(7)]

(g) This permit shield is not applicable to minor Part 70 permit modifi cations until after IDEM, OAQ, has issued the modifica tion. [326 IAC 2-7-12(b)(8)]

B.13 Prior Permits Superseded [326 IAC 2-1.1-9.5][326 IAC 2-7-10.5] (a) All terms and conditions of permits established prior to T003-27321-00225 and issued pursuant to permitting programs approved into the state implementation plan have been either:

(1) incorporated as originally stated,

(2) revised under 326 IAC 2-7-10.5, or

(3) deleted under 326 IAC 2-7-10.5.

(b) Provided that all terms and conditions are accu rately reflected in this permit, all previous registrations and permits are superseded by this Part 70 operating permit.

B.14 Termination of Right to Operate [326 IAC 2-7-10][326 IAC 2-7-4(a)] The Permittee's right to operate this source term inates with the expiration of this permit unless a timely and complete renewal application is submitt ed at least nine (9) months prior to the date of expiration of the source’s existing permit, cons istent with 326 IAC 2-7-3 and 326 IAC 2-7-4(a).

B.15 Re served

B.16 Permit Modification, Reopening, Revocation and Reissuance, or Termination [326 IAC 2-7-5(6)(C)][326 IAC 2-7-8(a)][326 IAC 2-7-9] (a) This permit may be modified, reopened, revoked and reissued, or terminated for cause. The filing of a request by the Permittee fo r a Part 70 Operating Permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not st ay any condition of this permit.Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 15 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

[326 IAC 2-7-5(6)(C)] The notification by t he Permittee does require a certification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

(b) This permit shall be reopened and revised under any of the circumstances listed in IC 13-15-7-2 or if IDEM, OAQ determines any of the following:

(1) That this permit contains a material mistake.

(2) That inaccurate statements were made in establishing the emissions standards or other terms or conditions.

(3) That this permit must be revised or revoked to assure compliance with an applicable requirement. [326 IAC 2-7-9(a)(3)]

(c) Proceedings by IDEM, OAQ to reopen and revise this permit shall follow the same procedures as apply to initial permit issuanc e and shall affect only those parts of this permit for which cause to reopen exists. Such reopening and revision shall be made as expeditiously as practicable. [326 IAC 2-7-9(b)]

(d) The reopening and revision of this permit, under 326 IAC 2-7-9(a), shall not be initiated before notice of such intent is provided to t he Permittee by IDEM, OAQ at least thirty (30) days in advance of the date this permit is to be reopened, except that IDEM, OAQ may provide a shorter time period in the ca se of an emergency. [326 IAC 2-7-9(c)]

B.17 Permit Renewal [326 IAC 2-7-3][326 IAC 2-7-4][326 IAC 2-7-8(e)] (a) The application for renewal shall be submitted using the application form or forms prescribed by IDEM, OAQ and shall include the information specified in 326 IAC 2-7-4. Such information shall be included in the application for each emission unit at this source, except those emission units included on the triv ial or insignificant activities list contained in 326 IAC 2-7-1(21) and 326 IAC 2-7-1(40). The renewal application does require a certification that meets the r equirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

Request for renewal shall be submitted to:

Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(b) A timely renewal application is one that is:

(1) Submitted at least nine (9) months prio r to the date of the expiration of this permit; and

(2) If the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means , it shall be cons idered timely if received by IDEM, OAQ on or before the date it is due.

(c) If the Permittee submits a timely and complete application for renewal of this permit, the source’s failure to have a permit is not a violation of 326 IAC 2-7 until IDEM, OAQ takes final action on the renewal application, except that this protection shall cease to apply if,Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 16 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

subsequent to the completeness determinati on, the Permittee fails to submit by the deadline specified, pursuant to 326 IAC 2-7-4( a)(2)(D), in writing by IDEM, OAQ any additional information identified as being needed to process the application.

B.18 Permit Amendment or Modification [326 IAC 2-7-11][326 IAC 2-7-12] (a) Permit amendments and modification s are governed by the requirements of 326 IAC 2-7-11 or 326 IAC 2-7-12 whenever the Permittee seeks to amend or modify this permit.

(b) Any application requesting an amendment or modification of this permit shall be submitted to:

Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

Any such application does require a certific ation that meets the requirements of 326 IAC 2-7-6(1) by a "responsible official ", as defined by 326 IAC 2-7-1(34).

(c) The Permittee may implement administr ative amendment changes addressed in the request for an administrative amendment immediately upon submittal of the request. [326 IAC 2-7-11(c)(3)]

B.19 Permit Revision Under Economic Incentives and Other Programs [326 IAC 2-7-5(8)][326 IAC 2-7-12(b)(2)] (a) No Part 70 permit revision or notice shall be required under any approved economic incentives, marketable Part 70 permits, emissi ons trading, and other similar programs or processes for changes that are provided for in a Part 70 permit.

(b) Notwithstanding 326 IAC 2-7-12(b)(1) and 326 IAC 2-7-12(c)(1), minor Part 70 permit modification procedures may be used for Part 70 modifications involving the use of economic incentives, marketable Part 70 permits, emissions trading, and other similar approaches to the extent that such minor Part 70 permit modification procedures are explicitly provided for in the applicable Stat e Implementation Plan (SIP) or in applicable requirements promulgated or approved by the U.S. EPA.

B.20 Operational Flexibility [326 IAC 2-7-20][326 IAC 2-7-10.5] (a) The Permittee may make any change or changes at the source that are described in 326 IAC 2-7-20(b),(c), or (e) without a prior permit revision, if each of the following conditions is met:

(1) The changes are not modifications under any provision of Title I of the Clean Air Act;

(2) Any preconstruction approval required by 326 IAC 2-7-10.5 has been obtained;

(3) The changes do not result in emissions which exceed the limitations provided in this permit (whether expressed herein as a rate of emissions or in terms of total emissions);

(4) The Permittee notifies the:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 17 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

and

United States Environmental Protection Agency, Region V Air and Radiation Division, Regulation De velopment Branch - Indiana (AR-18J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590

in advance of the change by written notific ation at least ten (10) days in advance of the proposed change. The Permittee shall attach every such notice to the Permittee's copy of this permit; and

(5) The Permittee maintains records on-site, on a rolling five (5) year basis, which document all such changes and emission trades that are subject to 326 IAC 2-7-20(b),(c), or (e). The Permi ttee shall make such records available, upon reasonable request, for public review.

Such records shall consist of all information required to be submitted to IDEM, OAQ in the notices specified in 326 IAC 2-7-20(b)(1), (c)(1), and (e)(2).

(b) The Permittee may make Section 502(b)(10) of the Clean Air Act changes (this term is defined at 326 IAC 2-7-1(36)) without a permit revision, subject to the constraint of 326 IAC 2-7-20(a). For each such Section 502(b)(10) of the Clean Air Act change, the required written notification shall include the following:

(1) A brief description of the change within the source;

(2) The date on which the change will occur;

(3) Any change in emissions; and

(4) Any permit term or condition that is no longer applicable as a result of the change.

The notification which shall be submitted is not considered an application form, report or compliance certification. Therefore, the not ification by the Permittee does not require a certification that meets the r equirements of 326 IAC 2-7-6(1) by a “responsible official” as defined by 326 IAC 2-7-1(34).

(c) Emission Trades [326 IAC 2-7-20(c)] The Permittee may trade emissions increases and decreases at the source, where the applicable SIP provides for such emission trades without requiring a permit revision, subject to the constraints of Section (a) of this condition and those in 326 IAC 2-7-20(c).

(d) Alternative Operating Scenarios [326 IAC 2-7-20(d)] The Permittee may make changes at the source within the range of alternative operating scenarios that are described in the terms and co nditions of this permit in accordance with 326 IAC 2-7-5(9). No prior notification of IDEM, OAQ, or U.S. EPA is required.Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 18 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(e) Backup fuel switches specifically addressed in, and limited under, Section D of this permit shall not be considered alternative operating scenarios. Therefore, the notification requirements of part (a) of this condition do not apply.

B.21 Source Modification Requ irement [326 IAC 2-7-10.5] A modification, construction, or reconstructi on is governed by the requi rements of 326 IAC 2.

B.22 Inspection and Entry [326 IAC 2-7-6 ][IC 13-14-2-2][IC 13-30 -3-1][IC 13-17-3-2] Upon presentation of proper identification card s, credentials, and other documents as may be required by law, and subject to the Permittee’s ri ght under all applicable laws and regulations to assert that the information collected by the age ncy is confidential and entitled to be treated as such, the Permittee shall allow IDEM, OAQ, U.S. EPA, or an authorized representative to perform the following:

(a) Enter upon the Permittee's premises where a Part 70 source is located, or emissions related activity is conducted, or where reco rds must be kept under the conditions of this permit;

(b) As authorized by the Clean Air Act, IC 13- 14-2-2, IC 13-17-3-2, and IC 13-30-3-1, have access to and copy any records that must be kept under the conditions of this permit;

(c) As authorized by the Clean Air Act, IC 13-14 -2-2, IC 13-17-3-2, and IC 13-30-3-1, inspect any facilities, equipment (including monito ring and air pollution control equipment), practices, or operations regulated or required under this permit;

(d) As authorized by the Clean Air Act, IC 13-14 -2-2, IC 13-17-3-2, and IC 13-30-3-1, sample or monitor substances or para meters for the purpose of as suring compliance with this permit or applicable requirements; and

(e) As authorized by the Clean Air Act, IC 13- 14-2-2, IC 13-17-3-2, an d IC 13-30-3-1, utilize any photographic, recording, testing, monitori ng, or other equipment for the purpose of assuring compliance with this permit or applicable requirements.

B.23 Transfer of Ownership or O perational Control [326 IAC 2-7-11] (a) The Permittee must comply with the requirements of 326 IA C 2-7-11 whenever the Permittee seeks to change the ownership or operational control of the source and no other change in the permit is necessary.

(b) Any application requesting a change in the ownership or operational control of the source shall contain a written agreement containing a specific date for transfer of permit responsibility, coverage and liability between the current and new Permittee. The application shall be submitted to:

Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

Any such application does require a certific ation that meets the requirements of 326 IAC 2-7-6(1) by a "responsible official ", as defined by 326 IAC 2-7-1(34).

(c) The Permittee may implement administr ative amendment changes addressed in the request for an administrative amendment immediately upon submittal of the request. [326 IAC 2-7-11(c)(3)]Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 19 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

B.24 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-7-5(7)][326 IAC 2-1.1-7] (a) The Permittee shall pay annual fees to IDEM , OAQ within thirty (30) calendar days of receipt of a billing. Pursuant to 326 IAC 2-7-19 (b), if the Permittee does not receive a bill from IDEM, OAQ the applicable fee is due April 1 of each year.

(b) Except as provided in 326 IAC 2-7-19(e), failure to pay may result in administrative enforcement action or revocation of this permit.

(c) The Permittee may call the following telephone numbers: 1-800-451-6027 or 317-233-4230 (ask for OAQ, Billing, Licensi ng, and Training Section), to determine the appropriate permit fee.

B.25 Credible Evidence [326 IAC 2-7-5(3)][326 IAC 2-7-6][62 FR 8314] [326 IAC 1-1-6] For the purpose of submitting compliance certif ications or establishing whether or not the Permittee has violated or is in violation of any condition of this permit, nothing in this permit shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether the Permittee would have been in compli ance with the condition of this permit if the appropriate performance or compliance test or procedure had been performed.Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 20 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

SECTION C SOURCE OPERATION CONDITIONS

Entire Source

Emission Limitations and Sta ndards [326 IAC 2-7-5(1)]

C.1 Particulate Emission Limitations For Proces ses with Process Weight Rates Less Than One Hundred (100) Pounds per Hour [326 IAC 6-3-2] Pursuant to 326 IAC 6-3-2(e)(2), particulate emissions from any process not exempt under 326 IAC 6-3-1(b) or (c) which has a maximum proc ess weight rate less than 100 pounds per hour and the methods in 326 IAC 6-3-2(b) through (d) do not apply shall not exceed 0.551 pounds per hour.

C.2 Opacity [326 IAC 5-1] Pursuant to 326 IAC 5-1-2 (Opacity Limitati ons), except as provided in 326 IAC 5-1-1 (Applicability) and 326 IAC 5-1-3 (Temporary Alternat ive Opacity Limitations), opacity shall meet the following, unless otherwise stated in this permit:

(a) Opacity shall not exceed an average of fo rty percent (40%) in any one (1) six (6) minute averaging period as determined in 326 IAC 5-1-4.

(b) Opacity shall not exceed sixty percent (60% ) for more than a cumulative total of fifteen (15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a continuous opacity monitor) in a six (6) hour period.

C.3 Open Burning [326 IAC 4-1] [IC 13-17-9] The Permittee shall not open burn any material except as provided in 326 IAC 4-1-3, 326 IAC 4-1-4 or 326 IAC 4-1-6. The previous sentence notwithstanding, the Permittee may open burn in accordance with an open burning approval issued by the Commissioner under 326 IAC 4-1-4.1.

C.4 Incineration [326 IAC 4-2] [326 IAC 9-1-2] The Permittee shall not operate an incinerator except as provided in 326 IAC 4-2 or in this permit. The Permittee shall not operate a refuse incine rator or refuse burning equipment except as provided in 326 IAC 9-1-2 or in this permit.

C.5 Fugitive Dust Emissions [326 IAC 6-4] The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or easement on which the source is located, in a manner that would violate 326 IAC 6-4 (Fugitive Dust Emissions). 326 IAC 6-4-2(4) is not federally enforceable.

C.6 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M] (a) Notification requirements apply to each owner or operator. If the combined amount of regulated asbestos containing material (RACM) to be stripped, removed or disturbed is at least 260 linear feet on pipes or 160 square f eet on other facility components, or at least thirty-five (35) cubic feet on all facility co mponents, then the notific ation requirements of 326 IAC 14-10-3 are mandatory. All demolition projects require notification whether or not asbestos is present.

(b) The Permittee shall ensure that a written notification is sent on a form provided by the Commissioner at least ten (10) working days before asbestos stripping or removal work or before demolition begins, per 326 IAC 14- 10-3, and shall update such notice as necessary, including, but not limited to the following:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 21 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(1) When the amount of affected asbest os containing material increases or decreases by at least twenty percent (20%); or

(2) If there is a change in the following:

(A) Asbestos removal or demolition start date;

(B) Removal or demolition contractor; or

(C) Waste disposal site.

(c) The Permittee shall ensure that the notic e is postmarked or delivered according to the guidelines set forth in 326 IAC 14-10-3(2).

(d) The notice to be submitted shall include the information enumerated in 326 IAC 14-10-3(3).

All required notifications shall be submitted to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

The notice shall include a signed certificati on from the owner or operator that the information provided in this notification is correct and that only Indiana licensed workers and project supervisors will be used to implement the asbestos removal project. The notifications do not require a certification t hat meets the requirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

(e) Procedures for Asbestos Emission Control The Permittee shall comply with the applicable emission control procedures in 326 IAC 14-10-4 and 40 CFR 61.145(c). Per 326 IAC 14-10-1, emission control requirements are applicable for any removal or disturbance of RACM greater than three (3) linear feet on pipes or three (3) square f eet on any other facility components or a total of at least 0.75 cubic feet on all facility components.

(f) Demolition and Renovation The Permittee shall thoroughly inspect the affe cted facility or part of the facility where the demolition or renovation will occur for th e presence of asbestos pursuant to 40 CFR 61.145(a).

(g) Indiana Licensed Asbestos Inspector The Permittee shall comply with 326 IAC 14-10 -1(a) that requires the owner or operator, prior to a renovation/demolition, to use an Indiana Licensed Asbestos Inspector to thoroughly inspect the affected po rtion of the facility for the presence of asbestos. The requirement to use an Indiana Licensed Asbesto s inspector is not federally enforceable.

Testing Requirements [326 IAC 2-7-6(1)]

C.7 Performance Testing [326 IAC 3-6] (a) For performance testing required by this permit, a test protocol, except as provided elsewhere in this permit, shall be submitted to:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 22 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

no later than thirty-five (35) days prior to the intended test date. The protocol submitted by the Permittee does not require a certificat ion that meets the r equirements of 326 IAC 2-7-6(1) by a "responsible official " as defined by 326 IAC 2-7-1(34).

(b) The Permittee shall notify IDEM, OAQ of the actual test date at least fourteen (14) days prior to the actual test date. The notificat ion submitted by the Permittee does not require a certification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

(c) Pursuant to 326 IAC 3-6-4(b), all test reports must be received by IDEM, OAQ not later than forty-five (45) days after the completion of the testing. An extension may be granted by IDEM, OAQ if the Permittee submits to IDEM, OAQ a reasonable written explanation not later than five (5) days prior to the end of the initial forty-five (45) day period.

Compliance Requirements [326 IAC 2-1.1-11

C.8 Compliance Requirements [326 IAC 2-1.1-11] The commissioner may require stack testing, monitoring, or reporting at any time to assure compliance with all applicable requirements by issuing an order under 326 IAC 2-1.1-11. Any monitoring or testing shall be performed in acco rdance with 326 IAC 3 or other methods approved by the commissioner or the U. S. EPA.

Compliance Monitoring Requirements [ 326 IAC 2-7-5(1)][326 IAC 2-7-6(1)]

C.9 Compliance Monitoring [326 IAC 2-7-5(3)][326 IAC 2-7-6(1)] Unless otherwise specified in this permit, for all monitoring requirement s not already legally required, the Permittee shall be allowed up to ninet y (90) days from the date of permit issuance or initial start-up, whichever is later, to begin su ch monitoring. If due to circumstances beyond the Permittee's control, any monitoring equipment re quired by this permit cannot be installed and operated no later than ninety (90) days after permit issuance or the date of initial start-up, whichever is later, the Permittee may extend the compliance schedule related to the equipment for an additional ninety (90) days provided the Permittee notifies:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

in writing, prior to the end of the initial ninety ( 90) day compliance schedule, with full justification of the reasons for the inability to meet this date.

The notification which shall be submitted by the Pe rmittee does require a ce rtification that meets the requirements of 326 IAC 2-7-6(1) by a "respons ible official" as defined by 326 IAC 2-7-1(34).

Unless otherwise specified in the approval for t he new emission unit(s), compliance monitoring for new emission units or emission units added through a source modification shall be implemented when operation begins.Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 23 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

C.10 Re served

C.11 Instrum ent Specificatio ns [326 IAC 2-1.1-11] [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] (a) When required by any condition of this permit, an analog instrument used to measure a parameter related to the operation of an air pollution control device shall have a scale such that the expected maximum reading for the normal range shall be no less than twenty percent (20%) of full scale.

(b) The Permittee may request that the IDEM , OAQ approve the use of an instrument that does not meet the above specifications provid ed the Permittee can demonstrate that an alternative instrument specification will adequately ensure compliance with permit conditions requiring the measurement of the parameters.

Corrective Actions and Response Steps [326 IAC 2-7-5][326 IAC 2-7-6]

C.12 Emergency Reduction Plans [326 IAC 1-5-2] [326 IAC 1-5-3] Pursuant to 326 IAC 1-5-2 (Emer gency Reduction Plans; Submission):

(a) The Permittee shall maintain the most recently submitted written emergency reduction plans (ERPs) consistent with safe operating procedures.

(b) Upon direct notification by IDEM, OAQ that a specific air pollution episode level is in effect, the Permittee shall immediately put into effect the actions stipulated in the approved ERP for the appropriate episode level. [326 IAC 1-5-3]

C.13 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68] If a regulated substance, as defined in 40 CFR 68, is present at a source in more than a threshold quantity, the Permittee must comply with the applicable requirements of 40 CFR 68.

C.14 Response to Excursions or Exceedances [326 IAC 2-7-5] [326 IAC 2-7-6] Upon detecting an excursion where a response step is required by the D Section or an exceedance of a limitation in this permit:

(a) The Permittee shall take reasonable response steps to restore operation of the emissions unit (including any control device and associ ated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing excess emissions.

(b) The response shall include minimizing the period of any startup, shutdown or malfunction. The response may include, but is not limited to, the following:

(1) initial inspection and evaluation;

(2) recording that operations returned or are returning to normal without operator action (such as through response by a co mputerized distributio n control system);

or

(3) any necessary follow-up actions to return operation to normal or usual manner of operation.

(c) A determination of whether the Permittee has used acceptable procedures in response to an excursion or exceedance will be based on information av ailable, which may include, but is not limited to, the following:

(1) monitori ng results;Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 24 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(2) review of operation and maintenance procedures and records; and/or

(3) inspection of the control device, as sociated capture system, and the process.

(d) Failure to take reasonable response steps shall be considered a deviation from the permit.

(e) The Permittee shall record the reasonable response steps taken.

C.15 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-7-5][326 IAC 2-7-6] (a) When the results of a stack test performed in conformance with Section C - Performance Testing, of this permit exceed the level s pecified in any condition of this permit, the Permittee shall submit a description of its response actions to IDEM, OAQ, no later than seventy-five (75) days after the date of the test.

(b) A retest to demonstrate compliance shall be performed no later than one hundred eighty (180) days after the date of the test. Should the Permittee demonstrate to IDEM, OAQ that retesting in one hundred eighty (180) days is not practicable, IDEM, OAQ may extend the retesting deadline.

(c) IDEM, OAQ reserves the authority to take any actions allowed under law in response to noncompliant stack tests.

The response action documents submitted pursuant to this condition do require a certification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34).

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

C.16 Emission Statement [326 IAC 2-7-5(3)(C)(iii)][ 326 IAC 2-7-5(7)][326 IAC 2-7-19(c)][326 IAC 2-6] (a) Pursuant to 326 IAC 2-6-3(a)(1), the Permittee shall submit by July 1 of each year an emission statement covering the previous cale ndar year. The emission statement shall contain, at a minimum, the information spec ified in 326 IAC 2-6-4(c) and shall meet the following requirements:

(1) Indicate estimated actual emissions of all pollutants listed in 326 IAC 2-6-4(a);

(2) Indicate estimated actual emission s of regulated pollutants as defined by 326 IAC 2-7-1(32) (“Regulated pollutant, which is used only for purposes of Section 19 of this rule”) from the source, for purpose of fee assessment.

The statement must be submitted to:

Indiana Department of Environmental Management Technical Support and Modeling Section, Office of Air Quality 100 North Senate Avenue MC 61-50 IGCN 1003 Indianapolis, Indiana 46204-2251

The emission statement does require a cert ification that meets the requirements of 326 IAC 2-7-6(1) by a “responsible offici al” as defined by 326 IAC 2-7-1(34).Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 25 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

C.17 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6] [326 IAC 2-2][326 IAC 2-3] (a) Records of all required monitoring data, repo rts and support information required by this permit shall be retained for a period of at l east five (5) years from the date of monitoring sample, measurement, report, or application. These records shall be physically present or electronically accessible at the source lo cation for a minimum of three (3) years. The records may be stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner makes a request for records to the Permittee, the Permittee shall furnish the records to the Commissioner within a reasonable time.

(b) Unless otherwise specified in this permit, for all record keeping requirements not already legally required, the Permittee shall be allowed up to ninety (90) days from the date of permit issuance or the date of initial start-up, whichever is later, to begin such record keeping.

(c) If there is a reasonable possibility (a s defined in 40 CFR 51.165(a)(6)(vi)(A), 40 CFR 51.165(a)(6)(vi)(B), 40 CFR 51.166(r)(6)(vi)(a), and/or 40 CFR 51.166(r)(6)(vi)(b)) that a “project ” (as defined in 326 IAC 2-2-1(qq) and/or 326 IAC 2-3-1(ll)) at an existing emissions unit, other than projects at a source with a Plantwide Applicability Limitation (PAL), which is not part of a “major modification” (as defined in 326 IAC 2-2-1(ee) and/or 326 IAC 2-3- 1(z)) may result in significant emissions increase and the Permittee elects to utilize the “projected actual emissions” (as defined in 326 IAC 2-2-1(rr) and/or 326 IA C 2-3-1(mm)), the Permittee shall comply with following:

(1) Before beginning actual construction of the “project” (as defined in 326 IAC 2-2-1(qq) and/or 326 IAC 2-3- 1(ll)) at an existing emissions unit, document and maintain the following records:

(A) A description of the project.

(B) Identification of any emissions un it whose emissions of a regulated new source review pollutant could be affected by the project.

(C) A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including:

(i) Baseline actual emissions;

(ii) Projected actual emissions; (iii) Amount of emission s excluded under section 326 IAC 2-2-1(rr)(2)(A)(iii) and/or 326 IAC 2-3-1 (mm)(2)(A)(iii); and

(iv) An explanation for why t he amount was excluded, and any netting calculations, if applicable.

(d) If there is a reasonable possibility (as defined in 40 CFR 51.165(a)(6)(vi)(A) and/or 40 CFR 51.166(r)(6)(vi)(a)) that a “project ” (as defined in 326 IAC 2-2-1(qq) and/or 326 IAC 2-3-1(ll)) at an existing emissions unit, other than projects at a source with a Plantwide Applicability Limitation (PAL), which is not part of a “major modification” (as defined in 326 IAC 2-2-1(ee) and/or 326 IAC 2-3- 1(z)) may result in significant emissions increase and the Permittee elects to utilize the “projected actual emissions” (as defined in 326 IAC 2-2-1(rr) and/or 326 IA C 2-3-1(mm)), the Permittee shall comply with following:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 26 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(1) Monitor the emissions of any regulated NSR pollutant that could increase as a result of the project and that is emitted by any existing emissions unit identified in (1)(B) above; and

(2) Calculate and maintain a record of the annual emissions, in tons per year on a calendar year basis, for a period of five (5) years following resumption of regular operations after the change, or for a peri od of ten (10) years following resumption of regular operations after the change if the project increases the design capacity of or the potential to emit that regulated NSR pollutant at the emissions unit.

C.18 General Reporting Requirements [326 IAC 2- 7-5(3)(C)] [326 IAC 2-1.1-11] [326 IAC 2-2] (a) The Permittee shall submit the attached Quarterly Deviation and Compliance Monitoring Report or its equivalent. Any deviation from permit requirements, the date(s) of each deviation, the cause of the deviation, and the response steps taken must be reported except that a deviation required to be report ed pursuant to an applicable requirement that exists independent of this permit, shall be re ported according to the schedule stated in the applicable requirement and does not need to be included in this report. This report shall be submitted not later than thirty (30) days of the end of the reporting period. The Quarterly Deviation and Compliance Monitoring Report shall include a certification that meets the requirements of 326 IAC 2-7-6(1) by a "responsible official" as defined by 326 IAC 2-7-1(34). A deviation is an exceedan ce of a permit limitation or a failure to comply with a requirement of the permit.

(b) The address for report submittal is:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(c) Unless otherwise specified in this permit, any notice, report, or other submission required by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ on or before the date it is due.

(d) Re served

(e) Reporting periods are based on calendar year s, unless otherwise specified in this permit. For the purpose of this permit “calendar year” means the twelve (12) month period from January 1 to December 31 inclusive. (f) If the Permittee is required to comply with the recordkeeping provisions of (d) in Section C - General Record Keeping Requirements for an y “project” (as defined in 326 IAC 2-2-1 (qq) and/or 326 IAC 2-3-1 (ll)) at an exis ting emissions unit, and the project meets the following criteria, then the Permittee shall submit a report to IDEM, OAQ:

(1) The annual emissions, in tons per year , from the project identified in (c)(1) in Section C- General Record Keeping Requirements exceed the baseline actual emissions, as documented and maintained under Section C- General Record Keeping Requirements (c)(1)(C)(i), by a significant amount, as defined in 326 IAC 2-2-1 (xx) and/or 326 IAC 2-3-1 (qq), for that regulated NSR pollutant, andFoamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 27 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(2) The emissions differ from the preconstruction projection as documented and maintained under Section C - General Record Keeping Requirements (c)(1)(C)(ii).

(g) The report for project at an existing emissions unit shall be submitted within sixty (60) days after the end of the year and contain the following:

(1) The name, address, and telephone number of the major stationary source.

(2) The annual emissions calculated in accordance with (d)(1) and (2) in Section C - General Record Keeping Requirements.

(3) The emissions calculated under the actu al-to-projected actual test stated in 326 IAC 2-2-2(d)(3) and/or 326 IAC 2-3-2(c)(3).

(4) Any other information that the Permittee wishes to include in this report, such as an explanation as to why the emissions differ from the preconstruction projection.

Reports required in this part shall be submitted to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(h) The Permittee shall make the information required to be documented and maintained in accordance with (c) in Section C- General Record Keeping Requirements available for review upon a request for inspection by IDEM, OAQ. The general public may request this information from the IDEM, OAQ under 326 IAC 17.1.

Stratospheric Ozone Protection

C.19 Compliance with 40 CFR 82 and 326 IAC 22-1 Pursuant to 40 CFR 82 (Protection of Stratosphe ric Ozone), Subpart F, except as provided for motor vehicle air conditioners in Subpart B, t he Permittee shall comply with applicable standards for recycling and emissions reduction.Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 28 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

SECTION D.1 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)]:

(b) One (1) natural gas flame laminator machine (ID No. FL-02), constructed in 1995, with a maximum capacity of 40,000 square feet per hour, with a heat input capacity of 0.35 MMBtu/hr, and exhausting through two (2) stacks (ID Nos. 02-002 and FL2). Under 40 CFR 63 (NESHAP), Subpart MMMMM, the FL-02 is considered an existing flame lamination affected source.

(c) One (1) thermal reticulation unit (ID No. TRU-01), constructed in 1968 and modified in 2007, with a maximum throughput of 87,000 cycles per year , and exhausting through nine (9) stacks (ID Nos. 35-43).

(e) One (1) thermal reticulation unit (ID No. TRU-02 ), approved for construction in 2007, with a maximum throughput of 87,600 cycles per year, ex hausting through eight (8) stacks (ID Nos. 52- 59)

(f) One (1) thermal reticulation unit, approved in 2011 for construction, identified as TRU-03, with a maximum capacity of 58,800 cycles per year, unc ontrolled, and exhausting to eight (8) stacks.

(The information describing the process contained in this facility descript ion box is descriptive information and does not constitute enforceable conditions.)

Emission Limitations and Sta ndards [326 IAC 2-7-5(1)]

D.1.1 Volatile Organic Compounds [326 IAC 8-1-6] Pursuant to CP 003-5815-00225, issued on August 15, 1996:

(a) The laminated foam production rate for the flame laminator FL-02 shall not exceed 166,000,000 square feet per 12 consecutive m onth period with compliance determined at the end of each month.

(b) VOC emission from FL-02 shall not exce ed 0.0003 pounds per square foot of laminated foam produced.

Compliance with these limits will limit the VOC PTE of FL-02 to less than 25 tons per 12 consecutive month period, and therefore the requirements of 326 IAC 8-1-6 (New Facilities, General Reduction Requirements) do not apply to FL-02.

D.1.2 Volatile Organic Compounds [326 IAC 8-1-6] [326 IAC 2-4.1-1] (a) Pursuant to Significant Source Modification No. 003-25183-00225, issued on December 18, 2007, 326 IAC 8-1-6 (Best Available Contro l Technology (BACT)) and 326 IAC 2-4.1- 1 (Maximum Achievable Control Te chnology (MACT)), the one (1) thermal reticulation unit, identified as TRU-02 shall comply with the provisions of (b)(1) and (2) below.

(b) Pursuant to 326 IAC 8-1-6 (BACT), the one (1) thermal reticulation unit identified as TRU03 shall comply with the provisions of (1) and (2) below.

(1) Maintain the thermal reticulation unit in good working order.

(2) Utilize quality pr ocedures to minimize VOC emissions from this unit. The work practices to be performed on the thermal reticulation unit include the following inspection and preventive maintenance procedures:

(A) The following preventive maintena nce procedures shall be performed on the thermal reticulation unit door.Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 29 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(i) Grease chamber door gear boxes (ii) Grease nonpolymer door linkages. (May possibly be converted to polymer bushing.) (iii) Lubricate shuttle table drive chains and idler bearings (iv) Inspect/maintain oil level in hydraulic reservoir

(B) The following preventive maintena nce procedures shall be performed on the thermal reticulation unit: (i) On an annual basis, remove and replace roof hydrogen and oxygen valves. (ii) Per quality standard, replace floor level hydrogen and oxygen valves.

(C) The following inspections shall be done on the thermal reticulation unit. (i) Check vacuum time and adjust if necessary. (ii) Fuel pressu re check/TPM fuel fill calibration.

(D) The thermal reticulation unit Nash pump shall be lubricated. (i) Grease lube points per quality standard.

(E) The following preventive maintena nce procedures shall be performed on the thermal reticulation unit mechanical vacuum system on a daily basis: (i) Drain the condensed water from the exhaust line into the bucket. (ii) Check the oil level through the side sight glass. (iii) Check for oil flow (sight glass with white ball). (iv) Empty condensate bucket as needed. (v) Check mechanical blower oil level and add as needed. (vi) Check the oil purifier as follows: Check gauge for proper pressure between (20-25 psi). When the purifier pressure exceeds 40 psi, service the unit.

(F) The following preventive maintena nce procedures shall be performed on the Stokes pumps per preventive maintenance frequency: (i) Drain oil, remove side cover. (ii) Remove baffle, remove valves. (iii) Wipe inside of cham ber to remove residue. (iv) Install new or rebuilt valves. (v) Clean baffle and reinstall. (vi) Install side cover with new gasket, if needed. (vii) Refill with oil. (viii) Check V -belts for wear and proper tension, replace if needed. (ix) Check gas ballast valves, replace if needed. (x) Perform preventive maintenance on unit oil purifier per preventative maintena nce specification.

(G) The following preventive maintena nce procedures shall be performed on the mechanical blower per prevent ive maintenance specification: (i) Change air filter. (ii) Check for water leaks. (iii) Check V -belts.

(H) The following preventive maintena nce procedures shall be performed on the chamber pressure transducer per preventive maintenance specification: (i) Remove manometer valve. (ii) Install new or rebuilt valve.Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 30 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(iii) Rebuild, tag and stock valve. (iv) Check calibration of chamber pressure transduce r per preventive maintenance specification.

(I) The following preventive maintena nce procedures shall be performed on the shot pins per preventive maintenance frequency: (i) Check shot pin hydraulic cy linder mount for broken or loose bolts. (ii) Check shot pin hydraulic cylinder assembly plates for torque to chamber. (iii) Check shot pin limit swit ch mounting bolts for tightness.

(J) The following preventive maintena nce procedures shall be performed on the Nash water heat exchanger per preventive maintenance specification: (i) Open, clean and flush all tubes.

(K) Perform fuel fill alarm preventive maintenance monthly per preventive maintenance specification.

(L) Perform flammable fuel detector preventive maintenance per preventive maintenance specification

(M) Perform preventive maintenance procedure on plug purge system per preventive maintenanc e specification: (i) Replace the plug purge valve. (ii) Rebuild, tag and stock valve. (iii) Replace flame arrestor. (iv) Replace plug block. (v) Clean and stock plug block.

(N) Perform thermal reticulation unit cleaning procedure dictated by production schedule: (i) Perform clean type per schedule. (ii) Complete checklist per clean type.

(O) Perform preventive maintenance procedures on the thermal reticulation unit hydraulic system per quality control specifications: (i) Perform oil analysis to determine replacement timing (ii) Maintain fluid level. (iii) Maintain filter.

D.1.3 Particulate [326 IAC 6-3-2] Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the facility listed in the table below are as follows:

Emission Unit ID Process Weight Rate

(tons/hr) Emission Limit (lbs PM/hr)

FL-02 1.0 4.1

The pounds per hour limitation was calculated with the following equation:

Interpolation of the data for the process weight rate up to 60,000 pounds per hour shall be accomplished by use of the equation:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 31 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

E = 4.10 P 0.67 where E = rate of emission in pounds per hour; and P = process weight rate in tons per hour

D.1.4 Preventive Maintenanc e Plan [326 IAC 2-7-5(13)] A Preventive Maintenance Plan is required for FL -02, TRU-01, TRU-02 and TRU-03. Section B - Preventive Maintenance Plan contains the Permitt ee's obligation with regard to the preventive maintenance plan required by this condition.

Compliance Determination Requirements

D.1.5 Testing Requirements [326 IA C 2-7-6(1),(6)] [326 IAC 2-1.1-11] In order to demonstrate compliance with Condition D.1.1(b), the Permittee shall perform VOC testing on the flame laminator (FL-02) not later than five (5) years of the most recent testing. The testing shall be performed utilizing methods as approved by the Commissioner. This test shall be repeated at least once every five (5) years from the date of the last valid compliance demonstration. Testing shall be conducted in ac cordance with the provisions of 326 IAC 3-6 (Source Sampling Procedures). Section C- Pe rformance Testing contains the Permittee's obligation with regard to the performance testing required by this condition.

Record Keeping and Reporting Requiremen ts [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.1.6 Record Keeping Requirements (a) To document the compliance status with Condition D.1.1(a), the Permittee shall maintain a record of the total production of laminated foam per month in square feet for the flame laminator FL-02. Records maintained shall be taken monthly and shall be complete and sufficient to establish compliance with the production limit established in Condition D.1.1(a). Records necessary to demonstrate compliance shall be available within 30 days of the end of each compliance period.

(b) To document the compliance status with C ondition D.1.2, the Permittee shall maintain records of work practice standard activi ties performed for the TRU-02 and TRU-03.

(c) Section C - General Record Keeping Require ments contains the Permittee's obligation with regard to the records required by this condition.

D.1.7 Rep orting Requirements A quarterly summary of the information to document the compliance status with Condition D.1.1(a) shall be submitted using the reporting fo rms located at the end of this permit, or their equivalent, not later than thirty (30) days after t he end of the quarter being reported. Section C - General Reporting Requirements contains the Permit tee's obligation with regard to the reporting required by this condition. The report submitted by the Permittee does require a certification that meets the requirements of 326 IAC 2-7-6(1) by a “responsible offi cial” as defined by 326 IAC 2-7- 1(34).Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 32 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

SECTION D.2 FACILITY OPERATION CONDITIONS

Facility Description [3 26 IAC 2-7-5(15)]:

(a) One (1) flexible slabstock polyurethane foam manufacturing process (ID No. PL-01), producing a maximum of nine (9) million board feet per day of polyurethane foam, consisting of:

(5) One (1) polyurethane foam production line with integral mix chamber, identified as PL01c, approved in 2010 for construction, exhaust ing to five (5) stacks (ID Nos. 60-64)

(f) One (1) polyurethane foam coating line, identif ied as CL-01, approved in 2010 for construction, utilizing flow coat technology, exhaus ting to one (1) stack (ID No. 65)

(The information describing the pr ocess contained in this facility description box is descriptive information and does not constitute enforceable conditions.)

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.2.1 Volatile Organic Compounds (VOC ) [326 IAC 2-2-3] [326 IAC 8-1-6] Pursuant to 326 IAC 2-2-3 (Prevention of Signific ant Deterioration (PSD) Best Available Control Technology (BACT)) and 326 IAC 8-1-6 (VOC BAC T), BACT for the one (1) polyurethane foam production line, identified as PL-01c, and the one (1) polyurethane coating line, identified as CL01, shall be as follows:

(a) The input of VOC to the one (1) polyurethane foam production line shall not exceed 80.8 tons per twelve (12) consecutive month perio d, with compliance determined at the end of each month.

(b) The Permittee shall utilize the following best management practices to minimize VOC emissions from the one (1) polyurethane foam production line:

(1) Use of the lowest VOC-content foam production materials where technically feasible;

(2) Track the quantity of amine catalyst used on a monthly basis;

(3) Store and handle the amine catalyst to minimize fugitive losses; and

(4) Continue to explore options for the production of foam using non-VOC content materials.

(c) The input of VOC to the one (1) polyure thane foam coating line shall not exceed 17.2 tons per twelve (12) consecutive month perio d, with compliance determined at the end of each month.

Compliance with the above shall satisfy the r equirements of both 326 IAC 2-2-3 (PSD BACT) and 326 IAC 8-1-6 (VOC BACT) for the modifica tion constructed under SSM 003-29260-00225.Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 33 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

D.2.2 Preventive Maintenance Plan [326 IAC 2-7-5(13)] [326 IAC 1-6-3] A Preventive Maintenance Plan is required fo r PL-01c and CL-01. Section B - Preventive Maintenance Plan contains the Permittee's obligat ion with regard to the preventive maintenance plan required by this condition.

Compliance Determination Requirements

D.2.3 Volatile Organic Compounds (VOC ) [326 IAC 8-1-4] [326 IAC 8-1-2(a)] Compliance with the VOC usage limitations contained in Condition D.2.1 shall be determined pursuant to 326 IAC 8-1-4(a)(3) and 326 IAC 8- 1-2(a) by preparing or obtaining from the manufacturer the copies of the “as supplied” and “as applied” VOC data sheets. IDEM, OAQ,

reserves the authority to determine compliance using Method 24 in conjunction with the analytical procedures specified in 326 IAC 8-1-4.

Record Keeping and Reporting Requiremen ts [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.2.4 Record Keeping Requirements (a) To document the compliance status with Condition D.2.1(a), the Permittee shall maintain records of the type and quantity of VOC-cont aining catalyst used at PL-01c. Records maintained shall be taken monthly and shall be complete and sufficient to establish compliance with the VOC input limits estab lished in Condition D.2.1. Records necessary to demonstrate compliance shall be available no later than thirty (30) days of the end of each compliance period.

(b) To document the compliance status with Co ndition D.2.1(c), the Permittee shall maintain records in accordance with (1) through (4) below. Records maintained for (1) through (4) shall be taken monthly and shall be complete and sufficient to establish compliance with the VOC usa ge limits esta blished in Co nditi on D.2.1(c). Re cords necessary to demonstrate compliance shall be available no later than thirty (30) days of the end of each compliance period.

(1) The amount of coating material and solvent less water used on monthly basis.

(A) Records sha ll inclu de purchase o rders, invoi ces, environmental data sheets, and material safety data she e ts (MSDS) necessary to ver ify the type and amount used.

(B) Solvent u sage records shall differen tiate betwee n tho se ad ded to coatings and those used as cleanup solvents.

(2) The cleanup solvent usage for each month;

(3) The total VOC usage for each month; and

(4) The weight of VOCs emitted for each compliance period.

(c) Section C - General Record Keeping Require ments contains the Permittee's obligation with regard to the records required by this condition.

D.2.5 Rep orting Requirements (a) A quarterly summary of the information to document the compliance status with Conditions D.2.1(a) and (c) shall be submitt ed no later than thirty (30) days after the end of the quarter being reported.Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 34 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(b) Section C - General Reporting contains the Permittee's obligation with regard to the reporting required by this condition. The r eports submitted by the Permittee do require a certification that meets the requirements of 326 IAC 2-7-6-(1 ) by a “responsible official” as defined by 326 IAC 2-7-1(34).Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 35 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

SECTION D.3 FACILITY OPERATION CONDITIONS

Facility Description [326 IAC 2-7-5(15)]:

(d) Two (2) natural gas fired boilers (ID Nos. IPB-01 and IPB-02), each constructed in 1968, each rated at 14.6 million (MM) British thermal units (B tu) per hour, using No. 2 distillate fuel oil as back-up fuel, and each exhausting thro ugh one (1) stack (ID Nos. 45 and 46).

(The information describing the process contained in this facility descript ion box is descriptive information and does not constitute enforceable conditions.)

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.3.1 Particulate [326 IAC 6-2-3] Pursuant to 326 IAC 6-2-3 (Particulate Limitati ons for Sources of Indi rect Heating) the PM emissions from each boiler shall be limited to 0.73 pounds per MMBtu heat input.

This limitation is based on the following equation:

Pt = C x a x h . 76.5 x Q 0.75 x N 0.25

where

C = 50 u/m 3 Pt = emission rate limit (lbs/MMBtu) Q = total source heat input capacity (MMBtu/hr) (29.2 MMBtu/hr) N = number of stacks (2) a = plume rise factor (0.67) h = stack height (ft) (25)

D.3.2 Sulfur Dioxide (SO2) [326 IAC 7-1.1-1] [326 IAC 7-2-1] Pursuant to 326 IAC 7-1.1 (SO2 Emissions Limitati ons), the SO2 emission rate from each of the boilers shall not exceed five tenths (0.5) pound s per MMBtu heat input when combusting No. 2 distillate fuel oil. Pursuant to 326 IAC 7-2-1, compliance shall be demonstrated on a calendar month average.

D.3.3 Preventive Maintenanc e Plan [326 IAC 2-7-5(13)] A Preventive Maintenance Plan is required for t he two (2) boilers, identified as IPB-01 and IPB02. Section B - Preventive Maint enance Plan contains the Permittee's obligation with regard to the preventive maintenance plan re quired by this condition.

Compliance Determination Requirements

D.3.4 Sulfur Dioxide Emi ssions and Sulfur Content Compliance with Condition D.1.2 shall be det ermined using one of the following options:

(a) Pursuant to 326 IAC 3-7-4, the Permittee shall demonstrate that the sulfur dioxide emissions do not exceed five-tenths (0.5 ) pounds per million Btu heat input by:

(1) Providing vendor analysis of fuel delivered, if accompanied by a vendor certification, or,Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 36 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(2) Analyzing the oil sample to determine the sulfur content of the oil via the procedures in 40 CFR 60, Appendix A, Method 19.

(A) Oil samples may be collected from the fuel tank immediately after the fuel tank is filled and before any oil is combusted; and

(B) If a partially empty fuel tank is re filled, a new sample and analysis would be required upon filling.

(b) Compliance may also be determined by c onducting a stack test for sulfur dioxide emissions from the boilers (ID Nos. IPB- 01 and IPB-02), using 40 CFR 60, Appendix A, Method 6 in accordance with the procedures in 326 IAC 3-6.

A determination of noncompliance pursuant to any of the methods specified in (a) or (b) above shall not be refuted by evidence of compliance pursuant to the other method.

Record Keeping and Reporting Requiremen ts [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.3.5 Record Keeping Requirements (a) To document the compliance status with C ondition D.2.2, the Permittee shall maintain records in accordance with (1) through (6) below.

(1) Calendar dates covered in the compliance determination period;

(2) Actual fuel oil usage since last compliance determination period and equivalent sulfur dioxide emissions;

(3) To certify compliance when burning natural gas only, the Permittee shall maintain records of fuel used.

If the fuel supplier certification is used to demonstrate compliance, when burning alternate fuels and not determining compliance pursuant to 326 IAC 3-7-4, the following, as a minimum, shall be maintained:

(4) Fuel supplier certifications;

(5) The name of the fuel supplier; and

(6) A statement from the fuel supplier that cert ifies the sulfur content of the fuel oil.

The Permittee shall retain records of all recording/monitoring data and support information for a period of five (5) years or longer if specified elsewhere in this permit, from the date of the monitoring sample, meas urement, or report. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copi es of all reports required by this permit.

(b) Section C - General Record Keeping Require ments contains the Permittee's obligation with regard to the records required by this condition.

D.3.6 Rep orting Requirements The natural gas boiler certification shall be submitted using the reporting forms located at the end of this permit, or its equivalent, not later than th irty (30) days after the end of the six (6) month period being reported. Section C - General Repo rting Requirements contains the Permittee's obligation with regard to the reporting required by this condition. The natural gas-fired boiler certification does require a certification that meets the requirements of 326 IAC 2-7-6(1) by a “responsible official” as defined by 326 IAC 2-7-1(34).Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 37 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

SECTION D.4 FACILITY OPERATION CONDITIONS

Facility Description [326 IAC 2-7-5(15)]:

Insignificant Activities

(a) Degreasing operations that do not exceed 145 gallons per 12 months, except if subject to 326 IAC 20-6 (cold cleaner degreasing operation with several remote solvent reservoirs). [326 IAC 8- 3-2]

(b) The following equipment related to manufacturing activities not resulting in the emission of HAPs: brazing equipment, cutting torches, soldering equipment, welding equipment. [326 IAC 6-3-2]

(c) Trimmers that do not produce fugitive emissi ons and that are equipped with a dust collection or trim material recovery device such as a bag filter or cyclone. [326 IAC 6-3-2]

(d) Grinding and machining operations controlled with fabric filters, scrubbers, mist collectors, wet collectors, and electrostatic precipitators with a design grain loading of less than or equal to 0.03 grains per actual cubic foot and a gas flow rate less than or equal to 4000 actual cubic feet per minute, including the following: deburring, bu ffing, polishing, abrasive blasting, pneumatic conveying, and woodworking operations. [326 IAC 6-3-2]

(h) One (1) felter (FPB) with VOC emissions less than 3 pounds per hour or 15 pounds per day, CO emissions less than 25 pounds per day, and PM emissions less than 5 pounds per hour or 25 pounds per day. [326 IAC 6-3-2]

(i) One (1) skinner with VOC emissions less than 3 pounds per hour or 15 pounds per day, CO emissions less than 25 pounds per day, and NOX and PM emissions less than 5 pounds per hour or 25 pounds per day. [326 IAC 6-3-2]

(j) One (1) hot wire cutter with VOC emissions less than 3 pounds per hour or 15 pounds per day, CO emissions less than 25 pounds per day, and NOX and PM emissions less than 5 pounds per hour or 25 pounds per day. [326 IAC 6-3-2]

(k) Bun cutters. [326 IAC 6-3-2]

(l) BSV slitters. [326 IAC 6-3-2]

(The information describing the process contained in this facility descript ion box is descriptive information and does not constitute enforceable conditions.)

Emission Limitations and Sta ndards [326 IAC 2-7-5(1)]

D.4.1 Volatile Organic Compounds (VOC) [326 IAC 8-3-2] Pursuant to 326 IAC 8-3-2 (Cold Cleaner Operations), for cold cleaning operations constructed after January 1, 1980, the Permittee shall:

(a) Equip the cleaner with a cover;

(b) Equip the cleaner with a facility for draining cleaned parts;

(c) Close the degreaser cover whenever pa rts are not being handled in the cleaner;

(d) Drain cleaned parts for at least fifteen (15) seconds or until dripping ceases;Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 38 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

(e) Provide a permanent, conspicuous label summarizing the operation requirements;

(f) Store waste solvent only in covered cont ainers and not dispose of waste solvent or transfer it to another party, in such a manner that greater than twenty percent (20%) of the waste solvent (by weight) can evaporate into the atmosphere.

D.4.2 Particulate [326 IAC 6-3-2] (a) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the facilities listed in the table below shall be as follows:

Facility Process Weight Rate (tons/hr) Emission Limit (lbs PM/hr) Felter (FPB) 0.25 1.62

Skinner 0.50 2.58

Hot Wire Cutter 0.175 1.28

Bun Cutters 0.325 1.93

BSV Slitters 0.11 0.93

The pounds per hour limitations in the table above were calculated with the following equations:

Interpolation of the data for the process weight rate up to 60,000 pounds per hour shall be accomplished by use of the equation:

E = 4.10 P 0.67 where E = rate of emission in pounds per hour; and P = process weight rate in tons per hourFoamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 39 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

SECTION E.1 FACILITY OPERATION CONDITIONS Facility Description [3 26 IAC 2-7-5(15)]:

(a) One (1) flexible slabstock polyurethane foam manufacturing process (ID No. PL-01), producing a maximum of nine (9) million board feet per day of polyurethane foam, consisting of:

(1) One (1) periphlex pour line with integral mix chamber, identified as Pl-01a, constructed in 1986, exhausting through ten (10) st acks (ID Nos. 1-5, 9-12, and 19)

(2) One (1) ester pour line with integral mix c hamber, identified as PL-01b, constructed in 1968, exhausting through six (6) stacks (ID Nos. 21-26)

(3) One (1) polyurethane foam production line with integral mix chamber, identified as PL01c, approved in 2010 for construction, exhaust ing to five (5) stacks (ID Nos. 60-64)

(4) Three (3) foam bun storage areas (Carpet Underlay Mezzanine Bun Grabber Area, South Finishing Mezzanine Bun Grabber Area, and t he Loaf Stacker Area), exhausting through fourteen (14) stacks (ID Nos. 13-15, 17, 18, 20, 27-33, and 49)

Under 40 CFR 63 (NESHAP), Subpart III, PL-01 is considered an existing fl exible polyurethane foam or rebond foam process.

Insignificant Activities

(e) TDI storage tanks with activated carbon (TDI emissions less than 1 pound per day and 1 ton per year). [40 CFR 63, Subpart III] [326 IAC 12]

(f) MDI storage tanks with MDI emissions less than 1 pound per day and 1 ton per year. [40 CFR 63, Subpart III] [326 IAC 12]

(g) Polyol storage tanks with VOC emissions less than 3 pounds per hour or 15 pounds per day (one tank has a storage ca pacity of 30,000 gallons). [40 CFR 63, Subpart III] [326 IAC 12]

(m) One (1) VOC (N-ethylmorpholine) storage tank with VOC emissions less than 3 pounds per hour or 15 pounds per day. [40 CFR 63, Subpart III] [326 IAC 12]

(n) One (1) 20,000 gallon No. 2 fuel oil storage tank with VOC emissions less than 3 pounds per hour or 15 pounds per day. [40 CFR 63, Subpart III] [326 IAC 12]

(o) One (1) 6,000 gallon storage tank containing an organic chemical blend. [40 CFR 63, Subpart III] [326 IAC 12]

(The information describing the process contained in this facility descript ion box is descriptive information and does not constitute enforceable conditions.)

Emission Limitations and Sta ndards [326 IAC 2-7-5(1)]

E.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CF R Part 63, Subpart A] (a) The provisions of 40 CFR Part 63, S ubpart A - General Provisions, which are incorporated as 326 IAC 20-1-1, apply to the facilities described in this section except when otherwise specified in 40 CFR Part 63, Subpart III.

(b) Pursuant to 40 CFR 63.10, the Permittee shall submit all required notifications and reports to:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 40 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

and

United States Environmental Protection Agency, Region V Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590

E.1.2 Flexible Polyurethane Foam Productio n [40 CFR Part 63, Subpart III] [326 IAC 20-22] Pursuant to 40 CFR Part 63, Subpart III, the Permitt ee shall comply with the foll owing provisions of 40 CFR Part 63, Subpart III (inc luded as 'Attach ment A'), which are in corporated by reference as 326 IAC 20-22, for the facilit ies listed in this section:

(1) 40 CFR 63.1290(a) and (b) (2) 40 CFR 63.1291(a) and (b) (3) 40 CFR 63.1292 (4) 40 CFR 63.1293(b) (5) 40 CFR 63.1294(a) through (d) (6) 40 CFR 63.1299(a), (c), and (d) (7) 40 CFR 63.1302 (8) 40 CFR 63.1303(a), (b), (d), (e) (except (e)(4)) (9) 40 CFR 63.1304(b) (10) 40 CFR 63.1306 (except (d)(3), (d)(4), and (e)(1)) (11) 40 CFR 63.1307 (except (a)(2), (a)(3), (a)(4) , (b)(1)(ii), (c)(1), (d), (e), (g) and (h)) (12) 40 CFR 63.1308 (except (c), (d)(2), (d)(3), and (e)) (13) 40 CFR 63.1309 (14) Table 1 through 4 (except 3)

E.1.3 One-Time Deadlines Relating to Flexible Po lyurethane Foam Production Notifications [40 CFR Part 63, Subpart III] The Permittee shall comply with the following notification requirements by the dates listed:

Requirement Rule Cite Af fected Facility Deadline

Submit Initial Notification 40 CFR 63.1306 (a) Entire Source In accordance with 40 CFR 63.9(b).Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 41 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

SECTION E.2 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)]:

(b) One (1) natural gas flame laminator machine (ID No. FL-02), constructed in 1995, with a maximum capacity of 40,000 square feet per hour, with a heat input capacity of 0.35 MMBtu/hr, and exhausting through two (2) stacks (ID Nos. 02-002 and FL2). Under 40 CFR 63 (NESHAP), Subpart MMMMM, the FL-02 is considered a exis ting flame lamination affected source.

(The information describing the process contained in this facility descript ion box is descriptive information and does not constitute enforceable conditions.)

Emission Limitations and Sta ndards [326 IAC 2-7-5(1)]

E.2.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CF R Part 63, Subpart A] (a) The provisions of 40 CFR Part 63, S ubpart A - General Provisions, which are incorporated as 326 IAC 20-1-1, apply to the flame laminator (ID No. FL-02) described in this section except when otherwise specified in 40 CFR Part 63, Subpart MMMMM.

(b) Pursuant to 40 CFR 63.10, the Permittee shall submit all required notifications and reports to:

Indiana Department of Environmental Management

Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

and

United States Environmental Protection Agency, Region V Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590

E.2.2 Flexible Polyurethane Foam Fabrication O perations [40 CFR Part 63, Subpart MMMMM] [326 IAC 20-66] Pursuant to 40 CF R Part 63, Subpart MMMMM, the Permittee shall comply with the followin g provisions of 40 CF R Part 63, Subp art MMMMM (incl uded as 'Attachm ent B'), which are incorporated by reference as 326 IAC 20-22, for the facilit ies listed in this section:

(1) 40 CFR 63.8760 (2) 40 CFR 63.8782(except (d)(2)) (3) 40 CFR 63.8784 (except (c), (d), (e)) (4) 40 CFR 63.8794(c), (g) (5) 40 CFR 63.8816(b) (6) 40 CFR 63.8820(a) (7) 40 CFR 63.8822 (8) 40 CFR 63.8826 (9) 40 CFR 63.8828 (10) 40 CFR 63.8830 (11) Table 1 and 7Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 42 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

E.2.3 One-Time Deadlines Relating to Flexible Po lyurethane Foam Production Notifications [40 CFR Part 63, Subpart MMMMM] The Permittee shall comply with the following notification requirements by the dates listed:

Requirement Rule Cite Af fected Facility Deadline

Submit Initial Notification 40 CF R 63.8816(b) FL-02 no later than 120 days after April 14, 2003Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 43 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:



### INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY PART 70 OPERATING PERMIT CERTIFICATION

Source Name: Foamex Innovations, Inc. Source Address: 3005 Commercial Road, Fort Wayne, Indiana 46809 Part 70 Permit No.: T003-27321-00225



## This certification shall be included when submitting monitoring, testing reports/results or other document s as required by this permit.

Please check what document is being certified:

 Annual Compliance Certification Letter

 Test Result (specify)

 Report (specify)

 Notification (specify)

 Affidavit (specify)

 Other (specify)

I certify that, based on information and belief fo rmed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

Signature:

Printed Name:

Title/Position:

Phone:

Date:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 44 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:



### INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE AND ENFORCEMENT BRANCH 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 Phone: (317) 233-0178

Fax: (317) 233-6865

PART 70 OPERATING PERMIT EMERGENCY OCCURRENCE REPORT

Source Name: Foamex Innovations, Inc. Source Address: 3005 Commercial Road, Fort Wayne, Indiana 46809 Part 70 Permit No.: T003-27321-00225

This form consists of 2 pages Page 1 of 2

 This is an emergency as defined in 326 IAC 2-7-1(12)

 The Permittee must notify the Office of Air Quality (OAQ), within four ( 4 ) business hours (1-800-451-6027 or 317-233-0178, ask for Compliance Section); and

 The Permittee must submit notice in writing or by facsimile within two ( 2 ) working days (Facsimile Number: 317-233-6865), and follow the other requirements of 326 IAC 2-7-16.

If any of the following are not applicable, mark N/A

Facility/Equipment/Operation:

Control Equipment:

Permit Condition or Operation Limitation in Permit:

Description of the Emergency:

Describe the cause of the Emergency:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 45 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

If any of the following are not applicable, mark N/A Page 2 of 2

Date/Time Emergency started:

Date/Time Emergency was corrected:

Was the facility being properly operated at the ti me of the emergency? Y N

Type of Pollutants Emitted: TSP, PM-10, SO 2 , VOC, NO X , CO, Pb, other:

Estimated amount of pollutant(s) emitted during emergency:

Describe the steps taken to mitigate the problem:

Describe the corrective actions/response steps taken:

Describe the measures taken to minimize emissions:

If applicable, describe the reasons wh y continued operation of the fac ilities are necess ary to prevent imminent injury to persons, severe damage to equipmen t, substantial loss of capital investment, or loss of product or raw materials of substantial economic value:

Form Completed by:

Title / Position:

Date:

Phone:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 46 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:



## INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE AND ENFORCEMENT BRANCH

PART 70 OPERATING PERMIT SEMI-ANNUAL NATURAL GAS FI RED BOILER CERTIFICATION

Source Name: Foamex Innovations, Inc. Source Address: 3005 Commercial Road, Fort Wayne, Indiana 46809 Part 70 Permit No.: T003-27321-00225

 Natural Gas Only

 Alternate Fuel burned From: To:

I certify that, based on information and belief fo rmed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

Signature:

Printed Name:

Title/Position:

Phone:

Date:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 47 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:



### INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY 

### COMPLIANCE AND EN FORCEMENT BRANCH

Part 70 Quarterly Report

Source Name: Foamex Innovations, Inc. Source Address: 3005 Commercial Road, Fort Wayne, Indiana 46809 Part 70 Permit No.: T003-17694-00225 Facility: Flame Laminator (FL-02) Parameter: Laminated foam production rate for the flame laminator FL-02 Limit: 166,000,000 square feet per 12 consecutive month period

YEAR:

Month Column 1 Column 2 Column 1 + Column 2

Laminated Foam Production This Month (square feet) Laminated Foam Production Previous 11

Months (square feet) 12 Month Total Laminated Foam Production (square feet)

Month 1

Month 2

Month 3

No deviation occurred in this quarter.

Deviation/s occurred in this quarter. Deviation has been reported on:

Submitted by:

Title / Position:

Signature:

Date:

Phone:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 48 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:



### INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE AND EN FORCEMENT BRANCH

Part 70 Quarterly Report

Source Name: Foamex Innovations, Inc. Source Address: 3005 Commercial Road, Fort Wayne, Indiana 46809 Part 70 Permit No.: T003-17694-00225 Facility: One (1) polyurethane foam production line, identified as PL-01c Parameter: VOC Input Limit: 80.8 tons per twelve (12) consec utive month period, with compliance determined at the end of each month

YEAR:

Month Column 1 Column 2 Column 1 + Column 2

VOC Input this

month (tons) VOC Input the previous eleven (11) months (tons) 12 Month Total VOC Input (tons)

Month 1

Month 2

Month 3

No deviation occurred in this quarter.

Deviation/s occurred in this quarter. Deviation has been reported on:

Submitted by:

Title / Position:

Signature:

Date:

Phone:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 49 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:



### INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE AND EN FORCEMENT BRANCH

Part 70 Quarterly Report

Source Name: Foamex Innovations, Inc. Source Address: 3005 Commercial Road, Fort Wayne, Indiana 46809 Part 70 Permit No.: T003-17694-00225 Facility: One (1) polyurethane f oam coating line, identified as CL-01 Parameter: VOC Input Limit: 17.2 tons per twelve (12) consec utive month period, with compliance determined at the end of each month

YEAR:

Month Column 1 Column 2 Column 1 + Column 2

VOC Input this

month (tons) VOC Input the previous eleven (11) months (tons) 12 Month Total VOC Input (tons)

Month 1

Month 2

Month 3

No deviation occurred in this quarter.

Deviation/s occurred in this quarter. Deviation has been reported on:

Submitted by:

Title / Position:

Signature:

Date:

Phone:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 50 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:



### INDIANA DEPARTMENT OF EN VIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE AND EN FORCEMENT BRANCH PART 70 OPERATING PERMIT QUARTERLY DEVIATION AND COMP LIANCE MONITORING REPORT

Source Name: Foamex Innovations, Inc. Source Address: 3005 Commercial Road, Fort Wayne, Indiana 46809 Part 70 Permit No.: T003-27321-00225



## Months: to Year:

Page 1 of 2

This report shall be submitted quarterly based on a calendar year. Any deviation from the requirements of this permit, the date(s) of each deviation, the probable cause of the deviation, and the response steps taken must be reported. A deviation required to be reported pursuant to an applicable requirement that exists independent of the permit, shall be reported according to the schedule stated in the applicable requirement and does not need to be included in this report. Additional pages may be attached if necessary. If no deviations occurred, please specify in the box marked "No deviations occurred this reporting period".

 NO DEVIATIONS OCCURRED THIS REPORTING PERIOD.

 THE FOLLOWING DEVIATIONS OCC URRED THIS R EPORTING PERIOD

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:Foamex Innovations, Inc. Significant Permit Modification No. 003-30247-00225 Page 51 of 51 Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 Permit Reviewer:

Page 2 of 2

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Form Completed by:

Title / Position:

Date:

Phone:Attachment A to Part 70 Operating Permit Renewal No. T003-27321-00225

Foamex Innovations Operating Company 3005 Commercial Road Fort Wayne, Indiana 46809

Subpart III—National Emission Stan dards for Hazardous Air Polluta nts for Flexible Polyurethane Foam Production

Source: 63 FR 53996, Oct. 7, 1998, unless otherwise noted.

§ 63.1290 Applicability.

(a) The provisions of this subpart apply to each new and existing flexible polyurethane foam or rebond foam process that meets the criteria lis ted in paragraphs (a)(1) through (3) of this section.

(1) Produces flexible polyurethane or rebond foam;

(2) Emits a HAP, except as provided in paragraph (c)(2) of this section; and

(3) Is located at a plant site that is a majo r source, as defined in §63.2 of subpart A.

(b) For the purpose of this subpart, an affected source includes all processes meeting the criteria in paragraphs (a)(1) through (a)(3) of this section that are lo cated at a contiguous plant site, with t he exception of those processes listed in paragraph (c) of this section.

(c) A process meeting one of the following criteria listed in paragraphs (c)(1) th rough (3) of this section shall not be subject to the provisions of this subpart:

(1) A process exclusively dedicated to the fabrication of flexible polyurethane foam;

(2) A research and development process; or

(3) A slabstock flexible polyurethane foam process at a plant site where the total amount of HAP, excluding diisocyanate reactants, used for slabstock foam production and foam fabrication is less than or equal to five tons per year, provided that slabstock foam production and foam fabric ation processes are the only processes at the plant site that emit HAP. The amount of non-diisocyanate HAP used, HAP used , shall be calculated using Equation 1. Owners or operators of slabstock foam processes ex empt from the regulation in accordance with this paragraph shall maintain records to verify that total non-diisocy anate HAP use at the plant site is less than 5 tons per year (4.5 megagrams per year).

Where,

HAP used = amount of HAP, excluding diisocyanate reactant s, used at the plant site for slabstock foam production and foam fabrication, tons per year

VOL ABA,i = volume of HAP ABA i used at t he facility, gallons per yearFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 2 of 35 T003-27321-00225

D ABA,i = density of HAP ABA i, pounds per gallon

m = number of HAP ABAs used

VOL clean,j = volume of HAP used as an equipment cleaner, gallons per year

D clean,j = density of HAP equipment cleaner j, pounds per gallon

WT HAPclean,k = HAP content of equipment cleaner j, weight percent

n = number of HAP equipment cleaners used

VOL adh,k = volume of adhesive k, gallons per year

D adh,k = density of adhesive k, pounds per gallon

WT HAPadh,k = HAP content of adhesive k, weight percent

o = number of adhesives used

§ 63.1291 Compliance schedule.

(a) Existing affected sources shall be in compliance with all provisions of this subpart no later than October 8, 2001.

(b) New or reconstructed affected sources shall be in comp liance with all provisions of this subpart upon initial startup.

§ 63.1292 Definitions.

All terms used in this subpart shall have the meaning give n them in the Act, in subpart A of this part, and in this section. If a term is defined in subpart A and in this sect ion, it shall have the meaning given in this section for purposes of this subpart.

Auxiliary blowing agent, or ABA, means a low-boiling point liquid added to assist foaming by generating gas beyond that resulting from the is ocyanate-water reaction.

Breakthrough means that point in the adsorpti on step when the mass transfer zone (i.e., the section of the carbon bed where the HAP is removed from the carrier gas stream) first reaches the carbon bed outlet as the mass transfer zone moves down the bed in the direction of flow. The br eakthrough point is characterized by the beginning of a sharp increase in the outlet HAP or organic compound concentration.

Calibrate means to verify the accuracy of a measurement devic e against a known standard. For the purpose of this subpart, there are two levels of calibration. The initial calibration includes the ve rification of the accuracy of the device over the entire operating range of the device. Subsequent calibrations can be conducted for a point or several points in a limited range of operation that represents the most co mmon operation of the device.

Canned motor pump means a pump with interconnected cavity housings, motor rotors, and pump casing. In a canned motor pump, the motor bearings run in the process liquid and all seals are eliminated.

Carbon adsorption system means a system consisting of a tank or cont ainer that contains a specific quantity of activated carbon. For the purposes of this subaprt, a carbon adsorption system is used as a control device for storage vessels. Typically, the spent carbon bed does not undergo regeneration, but is replaced.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 3 of 35 T003-27321-00225

Connector means flanged, screwed, or other joined fittings used to connect two pipe lines or a pipe line and a piece of equipment. A common connector is a flange. Joined fitti ngs welded completely around the circumference of the interface are not considered to be connectors for the purposes of this subpart.

Cured foam means flexible polyurethane foam with fully devel oped physical properties. A period of 12 to 24 hours from pour is typically required to comp letely cure foam, although mechanical or other devices are sometimes used to accelerate the curing process.

Curing area means the area in a slabstock foam production fac ility where foam buns are allowed to fully develop physical properties.

Diaphragm pump means a pump where the driving member is a flexible diaphragm made of metal, rubber, or plastic. In a diaphragm pump, there is no packing or seals that are exposed to the process liquid.

Diisocyanate means a compound containing two isocyanate groups per molecule. The most common diisocyanate compounds used in the flexible polyurethane foam industr y are toluene diisocyanate (TDI) and methylene diphenyl diisocyanate (MDI).

Flexible polyurethane foam means a flexible cellular polymer containing urea and carbamate linkages in the chain backbone produced by reacting a diisocyanate, polyol, and water. Flexible polyurethane foams are open-celled, permit the passage of air through the foam, and possess the st rength and flexibility to allow repeated distortion or compression under stress with essentially comple te recovery upon removal of the stress.

Flexible polyurethane foam process means the equipment used to produce a flexible polyurethane foam product. For the purpose of this subpart, the flexible polyurethane foam process includes raw material storage; production equipment and associated piping, ductw ork, etc.; and curing and storage areas.

Foam fabrication process means an operation for cutting or bonding flexible polyurethane foam pieces together or to other substrates.

Grade of foam means foam with a distinct combination of in dentation force deflection (IFD) and density values.

HAP ABA means methylene chloride, or any other HAP compound used as an auxiliary blowing agent.

HAP-based means to contain 5 percent (by weight) or more of HAP. This applies to equipment cleaners (and mixhead flushes) and mold release agents. The concentra tion of HAP may be determined using EPA test method 18, material safety data sheets, or engineering calculations.

High-pressure mixhead means a mixhead where mixing is achieved by impingement of the high pressure streams within the mixhead.

Indentation Force Deflection (IFD) means a measure of the load bearing capac ity of flexible polyurethane foam. IFD is generally measured as the force (in pounds) required to compress a 50 square inch circular indentor foot into a four inch thick sample, typicall y 15 inches square or larger, to 25 per cent of the sample's initial height.

In diisocyanate service means a piece of equipment that cont ains or contacts a diisocyanate.

In HAP ABA service means a piece of equipm ent that contains or contacts a HAP ABA.

Initial startup means the first time a new or reconstructed affected source begins production of flexible polyurethane foam.

Isocyanate means a reactive chemical grouping composed of a nitrogen atom bonded to a carbon atom bonded to an oxygen atom; or a chemical compound, usually organic, containing one or more isocyanate groups.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 4 of 35 T003-27321-00225

Magnetic drive pump means a pump where an externally-mounted magnet coupled to the pump motor drives the impeller in the pump casing. In a magnetic drive pump, no seals contact the process fluid.

Metering pump means a pump used to deliver reactants, ABA, or additives to the mixhead.

Mixhead means a device that mixes two or more component st reams before dispensing foam producing mixture to the desired container.

Molded flexible polyurethane foam means a flexible polyurethane foam that is produced by shootin g the foam mixture into a mold of the desired shape and size.

Mold release agent means any material which, when applied to the mo ld surface, serves to prevent sticking of the foam part to the mold.

Plant site means all contiguous or adjoining property that is under common control, including properties that are separated only by a road or other public right-of-way. Common control includes properties that are owned, leased, or otherwise operated by the same entity, parent entity, subsidiary, or any combination thereof.

Polyol, for the purpose of this subpart, means a polyether or pol yester polymer with more than one reactive hydroxyl group attached to the molecule.

Rebond foam means the foam resulting from a process of adhering sm all particles of foam (usually scrap or recycled foam) together to make a usable cushioning product. Various adhesives and bonding processes are used. A typical application for rebond foam is for carpet underlay.

Rebond foam process means the equipment used to produce a rebond fo am product. For the purpose of this subpart, the rebond foam process includes raw material storage; production equipment and associated piping, ductwork, etc.; and curing and storage areas.

Reconstructed source means an affected source undergoing reconstr uction, as defined in subpart A. For the purposes of this subpart, process modifications made to r educe HAP ABA emissions to meet the existing source requirements of this subpart shall not be counted in dete rmining whether or not a change or replacement meets the definition of reconstruction.

Recovery device means an individual unit of equipment capable of and used for the purpose of recovering chemicals for use, reuse, or sale. Recovery devices include, but are not limited to, carbon adsorbers, absorbers, and condensers.

Research and development process means a laboratory or pilot plant operation whose primary purpose is to conduct research and development into new processes and products, where the operations are under the close supervision of technically trained personnel, and which is not engaged in t he manufacture of products for commercial sale except in a de minimis manner.

Run of foam means a continuous production of foam, wh ich may consist of several grades of foam.

Sealless pump means a canned-motor pump, diaphragm pump, or magnetic drive pump, as defined in this section.

Slabstock flexible polyurethane foam means flexible polyurethane foam that is produced in large continuous buns that are then cut into the desired size and shape.

Slabstock flexible polyurethane foam production line includes all portions of the flexible polyurethane foam process from the mixhead to the point in the process where the foam is completely cured.

Storage vessel means a tank or other vessel that is used to store diisocyanate or HAP ABA for use in the production of flexible polyurethane foam. Storage ve ssels do not include vessels with capacities smaller than 38 cubic meters (or 10,000 gallons).Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 5 of 35 T003-27321-00225

Transfer pump means all pumps used to transport diisocyanate or HAP ABA that are not metering pumps.

Transfer vehicle means a railcar, tank truck, or other vehicle us ed to transport HAP ABA to the flexible polyurethane foam facility.

§ 63.1293 Standards for slabstock flexible polyurethane foam production.

Each owner or operator of a new or existing slabstock a ffected source shall comply with §63.1294 and either paragraph (a) or (b) of this section:

(a) The emission point specific limitat ions in §§63.1295 through 63.1298; or

(b) For sources that use no more than one HAP as an ABA and an equipment cleaner, the source-wide emission limitation in §63.1299.

§ 63.1294 Standards for slabstock flexible polyurethane foam production—diisocyanate emissions.

Each new and existing slabstock affected source sha ll comply with the provisions of this section.

(a) Diisocyanate storage vessels. Diisocyanate storage vessels shall be equip ped with either a system meeting the requirements in paragraph (a)(1) of this section, or a carbon adsorption system meeting the requirements of paragraph (a)(2) of this section.

(1) The storage vessel shall be equipped with a vapor return lin e from the storage vessel to the tank truck or rail car that is connected during unloading.

(i) During each unloading event, the vapor return line shall be inspected for leaks by visual, audible, or any other detection method.

(ii) When a leak is detected, it shall be repaired as soon as practicable, but not later than the subsequent unloading event.

(2) The storage vessel shall be equipped with a carbon adsorp tion system, meeting the monitoring requirements of §63.1303(a), that routes displaced va pors through activated carbon before being discharged to the atmosphere. The owner or operator shall replace the existing carbon with fresh carbon upon indication of breakthrough before the next unloading event.

(b) Transfer pumps in diisocyanate service. Each transfer pump in diisocyanate se rvice shall meet the requirements of paragraph (b)(1) or (b)(2) of this section.

(1) The pump shall be a sealless pump; or

(2) The pump shall be a submerged pump system meeting the re quirements in paragraphs (b)(2)(i) through (iii) of this section.

(i) The pump shall be completely immersed in bis(2-ethylhexyl)phthalate (DEHP, CAS #118–81–7), 2(methyloctyl)phthalate (DINP, CAS #68515–48–0), or another neutral oil.

(ii) The pump shall be visually monitored weekly to detect leaks,

(iii) When a leak is detected, it shall be repaired in accord ance with the procedures in paragraphs (b)(2)(iii)(A) and (B) of this section, except as provi ded in paragraph (d) of this section.

(A) The leak shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 6 of 35 T003-27321-00225

(B) A first attempt at repair shall be made no later than 5 ca lendar days after the leak is detected. First attempts at repair include, but are not limited to, t he following practices where practicable:

( 1 ) Tightening of packing gland nuts.

( 2 ) Ensuring that the seal flush is operatin g at design pressure and temperature.

(c) Other components in diisocyanate service. If evidence of a leak is found by visual, audible, or any other detection method, it shall be repaired as soon as pr acticable, but not later than 15 calendar days after it is detected, except as provided in paragraph (d) of this section. The first attempt at repair shall be made no later than 5 calendar days after each leak is detected.

(d) Delay of repair. (1) Delay of repair of equipment for which leaks have been detected is allowed for equipment that is isolated from the process and that does not remain in diis ocyanate service.

(2) Delay of repair for valves and connectors is also allowed if:

(i) The owner or operator determines that diisocyanate emis sions of purged material resulting from immediate repair are greater than the fugitive emissions like ly to result from delay of repair, and

(ii) The purged material is collected and destroyed or re covered in a control device when repair procedures are effected.

(3) Delay of repair for pumps is also allowed if repair require s replacing the existing seal design with a sealless pump, and repair is completed as soon as practicable, but not later than 6 months after the leak was detected.

§ 63.1295 Standards for slabstock flexible polyurethane foam production—HAP ABA storage vessels.

Each owner or operator of a new or existing slabstock affe cted source complying with the emission point specific limitation option provided in § 63.1293(a) shall control HAP ABA storage vessels in accordance with the provisions of this section.

(a) Each HAP ABA storage vessel shall be equipped with eit her a vapor balance system m eeting the requirements in paragraph (b) of this section, or a carbon adsorption system meeting the requirements of paragraph (c) of this section.

(b) The storage vessel shall be equipped with a vapor balanc e system. The owner or oper ator shall ensure that the vapor return line from the storage vessel to the t ank truck or rail car is connected during unloading.

(1) During each unloading event, the vapor return line shall be inspected for leaks by visual, audible, olfactory, or any other detection method.

(2) When a leak is detected, it shall be repaired as soon as practicable, but not later than the subsequent unloading event.

(c) The storage vessel shall be equipped with a carbon ads orption system, meeting the monitoring requirements of §63.1303(a), that routes displaced vapo rs through activated carbon before discharging to the atmosphere. The owner or operator shall replace the existing carbon with fres h carbon upon indication of br eakthrough before the next unloading event.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 7 of 35 T003-27321-00225

§ 63.1296 Standards for slabstock flexible polyurethane foam production—HAP ABA equipment leaks.

Each owner or operator of a new or existing slabstock affe cted source complying with the emission point specific limitation option provided in §63.1293(a) shall control HAP ABA emissions from leaks from transfer pumps, valves, connectors, pressure-relief valves, and open-ended lines in accordance with the provisions in this section.

(a) Pumps. Each pump in HAP ABA service shall be controlled in accordance with either paragraph (a)(1) or (a)(2) of this section.

(1) The pump shall be a sealless pump, or

(2) Each pump shall be monitored for leaks in accordance wi th paragraphs (a)(2)(i) and (ii) of this section. Leaks shall be repaired in accordance with paragraph (a)(2)(iii) of this section.

(i) Each pump shall be monitored quarterly to detect lea ks by the method specified in §63.1304(a). If an instrument reading of 10,000 parts per million (ppm) or greater is measured, a leak is detected.

(ii) Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping from the pump seal. If there are indications of liquids dripping from the pump seal, a leak is detected.

(iii) When a leak is detected, it shall be repaired in accord ance with the procedures in paragraphs (a)(2)(iii)(A) and (B) of this section, except as provi ded in paragraph (f) of this section.

(A) The leak shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected.

(B) A first attempt at repair shall be made no later than 5 ca lendar days after the leak is detected. First attempts at repair include, but are not limited to, the following practices, where practicable:

( 1 ) Tightening of packing gland nuts.

( 2 ) Ensuring that the seal flush is operatin g at design pressure and temperature.

(b) Valves. Each valve in HAP ABA service shall be monitored for leaks in accordance with paragraph (b)(1) of this section, except as provided in paragraphs (b)(3) and (4) of this section. Leaks shall be repaired in accordance with paragraph (b)(2) of this section.

(1) Each valve shall be monitored quarterly to detect lea ks by the method specified in §63.1304(a). If an instrument reading of 10,000 parts per million or grea ter is measured, a leak is detected.

(2) When a leak is detected, the owner or operator shall repair the leak in accordance with the procedures in paragraphs (b)(2)(i) and (ii) of this section, except as provided in paragraph (f) of this section.

(i) The leak shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected.

(ii) A first attempt at repair shall be made no later than 5 cal endar days after the leak is detected. First attempts at repair include, but are not limited to, t he following practices where practicable:

(A) Tightening of bonnet bolts;

(B) Replacement of bonnet bolts;

(C) Tightening of packing gland nuts; and

(D) Injection of lubricant into lubricated packing.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 8 of 35 T003-27321-00225

(3) Any valve that is designated as an unsafe-to-monitor valve is exempt from the requ irements of paragraphs (b)(1) and (2) of this section if:

(i) The owner or operator of the valve determines that t he valve is unsafe to monitor because monitoring personnel would be exposed to an immediate danger as a consequence of complying with paragraphs (b)(1) and (2) of this section; and

(ii) The owner or operator of the valve has a written plan that requires monitoring of the valve as frequently as practicable during safe-to-monitor times. The plan shall also include requirements for repairing leaks as soon as possible after detection.

(iii) The owner or operator shall monitor the unsafe-to-mo nitor valve in accordance with the written plan, and

(iv) The owner or operator shall repair leaks in accordance with the written plan.

(4) Any valve that is designated as a difficult-to-monitor valve is exempt from the r equirements of paragraphs (b)(1) and (2) of this section if:

(i) The owner or operator of the valve determines that the valve cannot be monitored with out elevating the monitoring personnel more than 2 meters above a support surface or it is not accessible at any time in a safe manner;

(ii) The process within which the valve is located is an existing source, or the process within which the valve is located is a new source that has less t han 3 percent of the total number of valves designated as difficult to monitor; and

(iii) The owner or operator of the valve develops a written plan that requires monitoring of the valve at least once per calendar year. The plan shall also include requirements fo r repairing leaks as soon as possible after detection.

(iv) The owner or operator shall monitor the difficult-to -monitor valve in accordance with the written plan, and

(v) The owner or operator shall repair leaks in accordance with the written plan.

(c) Connectors. Each connector in HAP ABA service shall be monito red for leaks in accordance with paragraph (c)(1) of this section, except as provided in paragraph (c)(3) of this section. Leaks shall be repaired in accordance with (c)(2) of this section, except as prov ided in paragraph (c)(4) of this section.

(1) Connectors shall be monitored at the times specified in paragraphs (c)(1)(i) through (iii) of this section to detect leaks by the method specified in §63.1304(a). If an instrument reading of 10,000 ppm or gr eater is measured, a leak is detected.

(i) Each connector shall be monitored annually, and

(ii) Each connector that has been opened or has otherwise had the seal broken shall be monitored for leaks within the first 3 months after being returned to HAP ABA service.

(iii) If a leak is detected, the connector shall be monitored fo r leaks in accordance with paragraph (c)(1) of this section within the first 3 months after its repair.

(2) When a leak is detected, it shall be repaired in accordan ce with the procedures in paragraphs (c)(2)(i) and (ii) of this section, except as provided in paragr aph (c)(4) and paragraph (f) of this section.

(i) The leak shall be repaired as soon as practicable, but no later than 15 calendar days after the leak is detected.

(ii) A first attempt at repair shall be made no later than 5 calendar days after the leak is detected.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 9 of 35 T003-27321-00225

(3) Any connector that is designated as an unsafe-to-mo nitor connector is exempt from the requirements of paragraph (c)(1) of this section if:

(i) The owner or operator determines that the connector is unsafe to monitor because personnel would be exposed to an immediate danger as a result of complying with paragraph (c)(1) of this section; and

(ii) The owner or operator has a written plan that requir es monitoring of the connector as frequently as practicable during safe-to-monitor periods.

(4) Any connector that is designated as an unsafe-to-repair connector is exempt from the requirements of paragraph (c)(2) of this section if:

(i) The owner or operator determines that repair per sonnel would be exposed to an immediate danger as a consequence of complying with paragraph (c)(2) of this section; and

(ii) The connector will be repaired as soon as practicable, but not later than 6 months after the leak was detected.

(d) Pressure-relief devices. Each pressure-relief device in HAP ABA service shall be monito red for leaks in accordance with paragraph (d)(1) of this section. Leaks shal l be repaired in accordance with paragraph (d)(2) of this section.

(1) Each pressure-relief device in HAP ABA service shall be monitored within 5 calendar days by the method specified in §63.1304(a) if evidence of a potential leak is found by visual , audible, olfactory, or any other detection method. If an instrument reading of 10,000 ppm or greater is measured, a leak is detected.

(2) When a leak is detected, the leak shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provid ed in paragraph (f) of this section. The owner or operator shall make a first attempt at repair no later than 5 calendar days after the leak is detected.

(e) Open-ended valves or lines. (1)(i) Each open-ended valve or line in HAP ABA service shall be equipped with a cap, blind flange, plug, or a second valve, except as provided in paragraph (e)(4) of this section.

(ii) The cap, blind flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open-ended valve or line, or during maintenance or repair.

(2) Each open-ended valve or line equipped with a second valv e shall be operated in a manner such that the valve on the process fluid end is closed bef ore the second valve is closed.

(3) When a double block and bleed system is being used, t he bleed valve or line may remain open during operations that require venting the line between the block valves but shall comply with parag raph (e)(1) of this section at all other times.

(4) Open-ended valves or lines in an emergency shutdown system which are designed to open automatically in the event of a process upset are exempt fr om the requirements of paragraphs (e )(1), (2), and (3) of this section.

(f) Delay of repair. (1) Delay of repair of equipment for which leaks have been detected is allowed for equipment that is isolated from the proc ess and that does not re main in HAP ABA service.

(2) Delay of repair for valves and connectors is also allowed if:

(i) The owner or operator determines that emissions of purg ed material resulting from immediate repair are greater than the fugitive emissions likely to result from delay of repair, and

(ii) The purged material is collected and destroyed or re covered in a control device when repair procedures are effected.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 10 of 35 T003-27321-00225

(3) Delay of repair for pumps is also allowed if repair require s replacing the existing seal design with a sealless pump, and repair is completed as soon as practicable, but not later than 6 months after the leak was detected.

§ 63.1297 Standards for slabstock flexible polyurethane foam production—HAP ABA emissions from the production line.

(a) Each owner or operator of a new or existing slabstock affected source complying with the emission point specific limitation option provided in §63.1293(a)(1) shall control HAP ABA emissi ons from the slabstock polyurethane foam production line in accordance with the provisions in th is section. Compliance shall be determined on a rolling annual basis as described in paragraph (a)(1) of this section. As an alternative, the owner or operator can determine compliance on a monthly basis, as describ ed in paragraph (a)(2) of this section.

(1) Rolling annual compliance. In determining compliance on a rolling annual basis, ac tual HAP ABA emissions shall be compared to allowable HAP ABA emissions for each consecutive 12-month perio d. The allowable HAP ABA emission level shall be calculated based on the production fo r the 12-month period, resulting in a potentially different allowable level for each 12-month period. Compliance sh all be determined each month for the previous 12-month period. The compliance requirements are prov ided in paragraph (b) of this section.

(2) Monthly compliance alternative. As an alternative to determining compliance on a rolling annual basis, an owner or operator can determine compliance by comparing actual HAP ABA emissions to allowable HAP ABA emissions for each month. The allowable HAP ABA emission leve l shall be calculated based on the production for the month, resulting in a potentially different allowable level ea ch month. The requirements for this monthly compliance alternative are provided in paragraph (c) of this section.

(3) Each owner or operator electing to change between the compliance methods described under paragraphs (a)(1) and (a)(2) of this section shall notify the Administrato r no later than 180 calendar days prior to the change.

(b) Rolling annual compliance. At each slabstock foam production source complying with the rolling annual compliance provisions described in paragr aph (a)(1) of this section, actual HAP ABA emissions shall not exceed the allowable HAP ABA emission level for a consecutive 12-mo nth period. The actual HAP ABA emission level for a consecutive 12-month period shall be determined using the pr ocedures in paragraph (b)(1) of this section, and the allowable HAP ABA emission level for the corresponding 12 -month period shall be calcul ated in accordance with paragraph (b)(2) of this section.

(1) The actual HAP ABA emissions for a 12-month period s hall be calculated as the sum of actual monthly HAP ABA emissions for each of the individual 12 months in the per iod. Actual monthly HAP ABA emissions shall be equal to the amount of HAP ABA added to the slabstock foam production line at the mixhead, determined in accordance with §63.1303(b), unless a recovery device is used. Slabstock fo am production sources using recovery devices to reduce HAP ABA emissions shall determine actual monthly HAP ABA emissions using the procedures in paragraph (e) of this section.

(2) The allowable HAP ABA emissions for a consecutive 12-m onth period shall be calculated as the sum of allowable monthly HAP ABA emissions for each of the individual 12 months in the period. Allowable HAP ABA emissions for each individual month shall be calculated using Equation 2.

Where:

emiss allow,month = Allowable HAP ABA emissions from the slabst ock foam production so urce for the month, pounds.

m = Number of slabstock foam production lines.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 11 of 35 T003-27321-00225

polyol i = Amount of polyol used in the month in the produ ction of foam grade i on foam production line j, determined in accordance with paragraph (b)(3) of this section, pounds.

n = Number of foam grades produced in the month on foam production line j.

limit i = HAP ABA formulation limit for foam grade i, parts HAP ABA per 100 parts polyol. The HAP ABA formulation limits are determined in accordance with paragraph (d) of this section.

(3) The amount of polyol used for specific foam grades sha ll be based on the amount of polyol added to the slabstock foam production line at the mixh ead, determined in accordance with the provisions of §63.1303(b).

(c) Monthly compliance alternative. At each slabstock foam production source complying with the monthly compliance alternative described in paragraph (a)(2) of this se ction, actual HAP ABA emissions shall not exceed the corresponding allowable HAP ABA emission level for the same month. The ac tual monthly HAP ABA emission level shall be determined using the procedur es in paragraph (c)(1) of this secti on, and the allowa ble monthly HAP ABA emission level shall be calculated in accordance with paragraph (c)(2) of this section.

(1) The actual monthly HAP ABA emissions shall be equa l to the amount of HAP ABA added to the slabstock foam production line at the mixhead, determined in accordan ce with §63.1303(b), unless a recovery device is used. Slabstock foam production sources using recovery devices to reduce HAP ABA emissions shall determine actual monthly HAP ABA emissions using the procedur es in paragraph (e) of this section.

(2) The allowable HAP ABA emissions for the month shall be determined in accordance wi th Equation 2 of this section.

(d) HAP ABA formulation limitations. For each grade, the HAP ABA formulation limitation shall be determined in accordance with paragraphs (d)(1) through (d)(3) of this se ction. For any grade, the owner or operator may designate zero as the HAP ABA formulation limitati on and not determine the HAP ABA formulati on limitation in accordance with paragraphs (d)(1) through (d)(3) of this section.

(1) For existing sources, the HAP ABA formulation limitation for each grade of slabstock foam produced shall be determined using Equation 3 of this section. Zero shall be the formulation limitation for an y grade of foam where the result of the formulation limitation equation (Equation 3) is negative (i.e., less than zero).

Where:

ABA limit = HAP ABA formulation limitation, parts H AP ABA allowed per hundred parts polyol (pph).

IFD = Indentation force deflection, pounds.

DEN = Density, pounds per cubic foot.

(2) For new sources, the HAP ABA formulation limitati on for each grade of slabstock foam produced shall be determined as described in paragraphs (d)(2)(i) through (d)(2 )(iv) of this section and in Table 1 of this subpart.

(i) For each foam grade with a density of 0.95 pounds per cubic foot or less, the HAP ABA formulation limitation shall be determined using Equation 3. Zero shall be the formulation limitation for any grade of f oam where the result of the formulation limitation equation (Equation 3 of this section) is negative (i.e., less than zero).Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 12 of 35 T003-27321-00225

(ii) For each foam grade with a density of 1.4 pounds per cu bic foot or less, and an IFD of 15 pounds or less, the HAP ABA formulation limitation shall be determined using Equation 3.

(iii) For each foam grade with a density greater than 0.95 pounds per cubic foot and an IFD greater than 15 pounds, the HAP ABA formulation limitation shall be zero.

(iv) For each foam grade with a density greater than 1.40 pounds per cubic foot, the HAP ABA formulation limitation shall be zero.

(3) With the exception of those grades for which the owner or operator has designated zero as the HAP ABA formulation limitation, the IFD and density for each foam gra de shall be determined in accordance with §63.1304(b) and recorded in accordance with §63.1307(c)(1)(i)(B) or §63.1307(c)(2)(i)(B) within 10 working days of the production of the foam.

(e) Compliance using recovery devices. If a recovery device is used to comply with paragraphs (b) or (c) of this section, the owner or operator sha ll determine the allowable HAP ABA emissions for each month using Equation 2 in paragraph (b)(2) of this section, and the actual monthl y HAP ABA emissions in accordance with paragraph (e)(1) of this section. The owner or operator shall also comply wi th the provisions of paragraph (e)(2) of this section.

(1) The actual monthly HAP ABA emission s shall be determined using Equation 4:

Where:

E actual = Actual HAP ABA emissions after control, pounds/month.

E unc = Uncontrolled HAP ABA emissions, pounds/month, det ermined in accordance with paragraph (b)(1) of this section.

HAPABA recovered = HAP ABA recovered, pounds/month, determin ed in accordance with paragraph (e)(2) of this section.

(2) The amount of HAP ABA recovered shall be determined in accordance with §63.1303(c).

§ 63.1298 Standards for slabstock flexible polyurethane foam production—HAP emissions from equipment cleaning.

Each owner or operator of a new or existing slabstock affe cted source complying with the emission point specific limitation option provided in §63.1293(a)(1) shall not use a HAP or a HAP-based material as an equipment cleaner.

§ 63.1299 Standards for slabstock flexible polyurethane foam production—source-wide emission limitation.

Each owner or operator of a new or existing slabstock affected source complying with the source-wide emission limitation option provided in §63.1293(b) shall control HAP ABA stor age and equipment leak emissions, HAP ABA emissions from the production line, and equipment cleaning HAP emissions in accordance with the provisions in this section. Compliance shall be determined on a rolling annual basis in accordance with paragraph (a) of this section. As an alternative, the owner or operator can determine co mpliance monthly, as described in paragraph (b) of this section.

(a) Rolling annual compliance. Under the rolling annual compliance prov isions, actual source-wide HAP ABA storage and equipment leak emissions, HAP ABA emissions from the production line, and equipment cleaning HAP emissions are compared to allowable source-wide emissi ons for each consecutive 12-month period. The allowableFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 13 of 35 T003-27321-00225

source-wide HAP emission level is calculated based on the production for the 12-month period, resulting in a potentially different allowable level for each 12-month peri od. While compliance is on an annual basis, compliance shall be determined monthly for the pr eceding 12-month period. The actual source-wide HAP emission level for a consecutive 12-month period shall be determined using the procedures in paragraphs (c)(1) through (4) of this section, unless a recovery device is used. Slabstock f oam production sources using recovery devices shall determine actual source-wide HAP emissions in accordance with parag raph (e) of this section. The allowable HAP emission level for a consecutive 12-month period shall be determined us ing the procedures in paragraph (d) of this section.

(b) Monthly compliance alternative. As an alternative to determining compliance on a rolling annual basis, an owner or operator can determine compliance by comparing actual HAP emissions to allowable HAP emissions for each month. The allowable source-wide emission level is calculat ed based on the production for the month, resulting in a potentially different allowable level each month. The actual monthly emissi on level shall be determined using the procedures in paragraphs (c)(1) through (3) of this sect ion, unless a recovery device is used. Slabstock foam production sources using recovery devices shall determine actual source-wide HAP emissions in accordance with paragraph (e) of this section. The allowable monthly HAP ABA emission level shall be determined in accordance with Equation 6.

(c) Procedures for determining actual source-wide HAP emissions. The actual source-wide HAP ABA storage and equipment leak emissions, HAP ABA emissions from the production line, and equipment cleaning HAP emissions shall be determined using the procedures in this secti on. Actual source-wide HAP emissions for each individual month shall be determined using the pr ocedures specified in paragraphs (c)(1) through (3) of this section.

(1) Actual source-wide HAP emissions for a month sh all be determined using Equation 5 and the information determined in accordance with paragraphs (c)(2) and (3) of this section.

Where:

PWE actual = Actual source-wide HAP ABA and equipment cleaning HAP emissions for a month, pounds/month.

n = Number of HAP ABA storage vessels.

ST i,begin = Amount of HAP ABA in storage vessel i at t he beginning of the month, pounds, determined in accordance with the procedures listed in paragraph (c)(2) of this section.

ST i,end = Amount of HAP ABA in storage vessel i at the end of the month, pounds, determined in accordance with the procedures listed in paragraph (c)(2) of this section.

ADD i = Amount of HAP ABA added to storage vessel i during the month, pounds, determined in accordance with the procedures listed in paragraph (c)(3) of this section.

(2) The amount of HAP ABA in a storage vessel shall be dete rmined by monitoring the HAP ABA level in the storage vessel in accordance with §63.1303(d).

(3) The amount of HAP ABA added to a storage vessel for a given month shall be the su m of the amounts of all individual HAP ABA deliveries that occur during the month. The amount of each individual HAP ABA delivery shall be determined in accordance with §63.1303(e).

(4) Actual source-wide HAP emissions for each consecutive 12 -month period shall be calculated as the sum of actual monthly source-wide HAP emissions for each of the individual 12 months in the period, calculated in accordance with paragraphs (c) (1) through (3) of this section.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 14 of 35 T003-27321-00225

(d) Allowable source-wide HAP emissions for a consecutiv e 12-month period shall be calculated as the sum of allowable monthly source-wide HAP emissions for each of the individual 12 months in the period. Allowable sourcewide HAP emissions for each individual month shall be calculated using Equation 6.

Where:

emiss allow,month = Allowable HAP ABA storage and equipment leak emissions, HAP ABA emissions from the production line, and equipment cleaning HAP emissions from the slabstock foam production source for the month, pounds.

m = Number of slabstock foam production lines.

polyol i = Amount of polyol used in the month in the produ ction of foam grade i on foam production line j, determined in accordance with §63.1303(b), pounds.

n = Number of foam grades produced in the month on foam production line j.

limit i = HAP ABA formulation limit for foam grade i, parts HAP ABA per 100 parts polyol. The HAP ABA formulation limits are determined in accordance with §63.1297(d).

(e) Compliance using recovery devices. If a recovery device is used to comply with paragraphs (a) or (b) of this section, the owner or operator sha ll determine the allowable source-wide HAP emissions for each month using Equation 6 in paragraph (d) of this section, and the actu al monthly source-wide HAP emissions in accordance with paragraph (e)(1) of this section. The owner or operator sh all also comply with the provisions of paragraph (e)(2) of this section.

(1) Actual monthly source-wide HAP emissions shall be determined using Equation 7.

Where:

E actual = Actual source-wide HAP emissi ons after control, pounds/month.

E unc = Uncontrolled source-wide HAP emissions, pounds/m onth, determined in accordance with paragraph (c) (1) through (3) of this section.

HAPABA recovered = HAP ABA recovered, pounds/month, determin ed in accordance with paragraph (e)(2) of this section.

(2) The amount of HAP ABA recovered shall be determined in accordance with §63.1303(c).

§ 63.1300 Standards for molded flexible polyurethane foam production.

Each owner or operator of a new or existing molded affected source shall comply with the provisions in paragraphs (a) and (b) of this section.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 15 of 35 T003-27321-00225

(a) A HAP or HAP-based material shall not be used as an e quipment cleaner to flush the mixhead, nor shall it be used elsewhere as an equipment cleaner in a molded flex ible polyurethane foam process, with the following exception. Diisocyanates may be used to flush the mixhe ad and associated piping during periods of startup or maintenance, provided that the diisocyanate compounds are contained in a closed-loop system and are re-used in production.

(b) A HAP-based mold release agent shall not be used in a molded flexible polyurethane foam source process.

§ 63.1301 Standards for rebond foam production.

Each owner or operator of a new or existing rebond foam affected source shall comply with the provisions in paragraphs (a) and (b) of this section.

(a) A HAP or HAP-based material shall not be used as an equipment cleaner at a rebond foam source.

(b) A HAP-based mold release agent shall not be used in a rebond foam source.

§ 63.1302 Applicability of subpart A requirements.

The owner or operator of an affected source shall comply with the applicable requirements of subpart A of this part, as specified in Table 2 of this subpart.

§ 63.1303 Monitoring requirements.

Owners and operators of affected sources shall comply with each applicable monitoring provision in this section.

(a) Monitoring requirements for storage vessel carbon adsorption systems. Each owner or operator using a carbon adsorption system to meet the requirem ents of §63.1294(a) or §63.1295 shall mo nitor the concentration level of the HAP or the organic compounds in the exhaust vent stream (or outlet stream exhaust) from the carbon adsorption system at the frequency specified in (a)(1) or (2) of this sect ion in accordance with either (a)(3) or (4) of this section.

(1) The concentration level of HAP or organic compounds shall be monitored during each unloading event, or once per month during an unloading event if mult iple unloading events occur in a month.

(2) As an alternative to monthly monitoring, the owner or operator can set the monitoring frequency at an interval no greater than 20 percent of the carbon replacement interval, which is estab lished using a design analysis described below in paragraphs (a)(1)(i) through (iii) of this section.

(i) The design analysis shall consider the vent stream com position, constituent concentra tion, flow rate, relative humidity, and temperature.

(ii) The design analysis shall establish the outlet organic c oncentration level, the capacit y of the carbon bed, and the working capacity of activated carbon used for the carbon bed, and

(iii) The design analysis shall establish t he carbon replacement interval based on the total carbon working capacity of the carbon adsorption system and the schedule for filling the storage vessel.

(3) Measurements of HAP concentration shall be m ade using 40 CFR part 60, appendix A, Method 18. The measurement shall be conducted ov er at least one 5-minute interval during which the storage vessel is being filled.

(4) Measurements of organic compounds shall be made using 40 CFR part 60, Appendix A, Method 25A. The measurement shall be conducted ov er at least one 5-minute interval during which the storage vessel is being filled.

(b) Monitoring for HAP ABA and polyol added to the foam production line at the mixhead. (1) The owner or operator of each slabstock affected source shall comply with the pr ovisions in paragraph (b)(1)(i) of this section, and, ifFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 16 of 35 T003-27321-00225

applicable, the provisions of paragraph (b)(1)(ii) of this sect ion. Alternatively, the owner or operator may comply with paragraph (b)(5) of this section.

(i) Owners or operators of all slabstock affected sources sh all continuously monitor the amount of polyol added at the mixhead when foam is being poured, in accordance with paragraphs (b)(2) through (4) of this section.

(ii) Owners or operators of slabstock foam affected sour ces using the emission point specific limitation option provided in §63.1293(a)(1) shall continuously monitor t he amount of HAP ABA added at the mixhead when foam is being poured, in accordance with paragraphs (b )(2)(ii), (b)(3), and (b)(4) of this section.

(2) The owner or operator shall monitor either:

(i) Pump revolutions; or

(ii) Flow rate.

(3) The device used to monitor the parameter from paragraph (b )(2) shall have an accuracy to within ±2.0 percent of the HAP ABA being measured, and shall be calibrated initially, and periodically, in accordance with paragraph (b)(3)(i) or (ii) of this section.

(i) For polyol pumps, the device shall be calibrated at least once each 6 months.

(ii) For HAP ABA pumps, the device shall be calibrated at leas t once each month.

(4) Measurements must be recorded at the beginning and end of the production of each grade of foam within a run of foam.

(5) As an alternative to the monitoring described in paragr aphs (b)(2) through (4) of this section, the owner or operator may develop an alternative monitoring program. Al ternative monitoring programs must be submitted to the Administrator for approval in the Precompliance Report as specified in §63.1306(c)(4) for existing sources or in the Application for approval of construction or reconstruction for new sources. If an owner or operator wishes to develop an alternative monitoring program after the compliance date, the program shall be submitted to the Administrator for approval before the owner or operator wishes to begin us ing the alternative program. If the Administrator does not notify the owner or operator of objections to the program, or any part of the program, within 45 days after its receipt, the program shall be deemed approved. Un til the program is approved, the owner or operator of an affected source remains subject to the requirements of this subpart. T he components of an alternative monitoring program shall include, at a minimum, the item s listed in paragraphs (b)(5)(i) through (iv) of this section.

(i) A description of the parameter to be continuously monito red when foam is being poured to measure the amount of HAP ABA or polyol added at the mixhead.

(ii) A description of how the monitoring results will be reco rded, and how the results will be converted into amount of HAP ABA or polyol delivered to the mixhead.

(iii) Data demonstrating that the monitoring device is accurate to within ±2.0 percent.

(iv) Procedures to ensure that the a ccuracy of the parameter monitoring results is maintained. These procedures shall, at a minimum, consist of periodi c calibration of all monitoring devices.

(c) Recovered HAP ABA monitoring. The owner or operator of each slabst ock affected source using a recovery device to reduce HAP ABA emissions shall develop and comply with a recovered HAP ABA monitoring and recordkeeping program. The components of these plans shall include, at a minimum, t he items listed in paragraphs (c)(1) through (5) of this section. These plans must be s ubmitted for approval in accordance with paragraph (c)(6) of this section.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 17 of 35 T003-27321-00225

(1) A device, installed, calibrated, maintained, and operated according to th e manufacturer's specifications, that indicates the cumulative amount of HAP ABA recovered by the solvent recove ry device over eac h 1-month period. The device shall be certified by the manufacturer to be accurate to within ±2.0 percent.

(2) The location where the monitoring will occur shall ens ure that the measurements are taken after HAP ABA has been fully recovered (i.e., after separation from wa ter introduced into the HAP ABA during regeneration).

(3) A description of the parameter to be monitor ed, and the times the parameter will be monitored.

(4) Data demonstrating that the monitoring dev ice is accurate to within ±2.0 percent.

(5) Procedures to ensure that the a ccuracy of the parameter monitoring results is maintained. These procedures shall, at a minimum, consist of periodi c calibration of all monitoring devices.

(6) Recovered HAP ABA monitoring and recordkeeping program s must be submitted to the Administrator for approval in the Precompliance Report as specified in §63.1306(c)(6) for existing sources or in the Application for approval of construction or reconstruction for new sources. If an owner or operator wishes to develop a recovered HAP ABA monitoring program after the compliance date, the program shall be submitted to the Administrator for approval before the owner or operator wishes to begin using the program. If the Admini strator does not notify the owner or operator of objections to the program within 45 days after its receipt, the program shall be deemed approved. Until the program is approved, the owner or op erator of an affected source remains subject to the requirements of this subpart.

(d) Monitoring of HAP ABA in a storage vessel. The amount of HAP ABA in a storage vessel shall be determined weekly by monitoring the HAP ABA level in the storage ve ssel using a level measurem ent device that meets the criteria described in paragraphs (d)(1) and either (d)(2) or (d)(3) of this section.

(1) The level measurement device must be calibrated initially and at least once per year thereafter.

(2) With the exception of visually-read level measurement devices (i.e., gauge glass), the device must have either a digital or printed output.

(3) If the level measurement device is a visually-read device, the device must be equipped with permanent graduated markings to indicate HAP ABA level in the storage tank.

(e) Monitoring of HAP ABA added to a storage vessel. The amount of HAP ABA added to a storage vessel during a delivery shall be determined in accordance with either par agraphs (e)(1), (2), (3), or (4) of this section.

(1) The volume of HAP ABA added to the storage vessel sha ll be determined by recording the volume in the storage vessel prior to the delivery and the volume after the delivery, provided that the stor age tank level measurement device used to determine the levels meets the criteria in (d) of this section.

(2) The volume of HAP ABA added to the storage vessel sha ll be determined by monitoring the flow rate using a device with an accuracy of ±2.0 percent, and calibrated in itially and at least once ea ch six months thereafter.

(3) The weight of HAP ABA added to the storage vessel shall be calculated as the differenc e of the full weight of the transfer vehicle prior to unloading into the storage vessel and the empty weight of the tr ansfer vehicle after unloading into the storage vessel. The weight shall be determined us ing a scale meeting the requirements of either paragraph (e)(2)(i) or (ii) of this section.

(i) A scale approved by the State or local agencies using the procedures contained in Handbook 44, Specifications, Tolerances, and Other Technical Requirements for We ighing and Measuring Devices 1998 (incorporation by reference—see §63.14).

(ii) A scale determined to be in compliance with the requirements of the National Institute of Standards and Technology Handbook 44 at least once per year by a registered scale technician.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 18 of 35 T003-27321-00225

(4) As an alternative to the monitoring options described in par agraphs (e)(1) through (e)(3) of this section, the owner or operator may develop an alternative monitoring program . Alternative monitoring programs must be submitted to the Administrator for approval in the Precompliance Report as specified in §63.1306(c)(4) for existing sources or in the Application for approval of construction or reconstruc tion for new sources. If an owner or operator wishes to develop an alternative monitoring program after the compli ance date, the program shall be submitted to the Administrator for approval before the owner or operator wi shes to begin using the alternative program. If the Administrator does not notify the owner or operator of objec tions to the program within 45 days after its receipt, the program shall be deemed approved. Until the program is a pproved, the owner or operator of an affected source remains subject to the requirements of this subpart. T he components of an alternative monitoring program shall include, at a minimum, the item s listed in paragraphs (e)(3)(i) through (iv) of this section.

(i) A description of the parameter to be monitored to determine the amount of HAP ABA added to the storage vessel during a delivery,

(ii) A description of how the results will be recorded, and how the results will be converted into the amount of HAP ABA added to the storage vessel during a delivery,

(iii) Data demonstrating that the monitoring dev ice is accurate to within ±2.0 percent, and

(iv) Procedures to ensure that the a ccuracy of the monitoring measurements is maintained. These procedures shall, at a minimum, consist of periodic ca libration of all monitoring devices.

§ 63.1304 Testing requirements.

Owners and operators of affected sources shall use the te st methods listed in this section, as applicable, to demonstrate compliance with this subpart.

(a) Test method and procedures to determine equipment leaks. Monitoring, as required under §63.1296, shall comply with the following requirements:

(1) Monitoring shall comply with Method 21 of 40 CFR part 60, appendix A.

(2) The detection instrument shall meet the performance criteria of Method 21 of 40 CFR part 60, appendix A, except that the instrument response factor cr iteria in section 3.1.2(a) of Method 21 shall be for the average composition of the source fluid, rather than for each individual VOC in the stream. For source streams that contain nitrogen, air, or other inerts which are not HAP or VOC, the average stream response factor s hall be calculated on an inert-free basis. The response factor may be determined at any concentrat ion for which monitoring for leaks will be conducted.

(3) The instrument shall be calibrated before use on each day of its use by the procedures specified in Method 21 of 40 CFR part 60, appendix A.

(4) Calibration gases shall be:

(i) Zero air (less than 10 ppm of hydrocarbon in air); and

(ii) A mixture of methane and air at a concentration of approximately, 1,000 ppm for all transfer pumps; and 500 ppm for all other equipment, except as provided in paragraph (a)(4)(iii) of this section.

(iii) The instrument may be calibrated at a higher metha ne concentration (up to 2,000 ppm) than the leak definition concentration for a specific piece of equipment for monitoring that piece of equipment. If the monitoring instrument's design allows for multiple calibration gas concentrations, then the lower concentration calibration gas shall be no higher than 2,000 ppm methane and t he higher concentration calibration gas shall be no higher than 10,000 ppm methane.

(5) Monitoring shall be performed when t he equipment is in HAP ABA service, in use with an acceptable surrogate volatile organic compound which is not a HAP ABA, or is in use with any other detectable gas or vapor.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 19 of 35 T003-27321-00225

(6) If no instrument is available onsite t hat will meet the performance criteria s pecified in section 3.1.2(a) of Method 21 of 40 CFR Part 60, appendix A, the r eadings from an available instrument may be adjusted by multiplying by the average response factor for the stream.

(b) Test method to determine foam properties. The IFD and density of each grade of foam produced during each run of foam shall be determined using AST M D3574–91, Standard Test Methods for Flexible Cellular Materials—Slab, Bonded, and Molded (incorporation by reference—see §63.14), using a sample of foam cu t from the center of the foam bun. The maximum sample size for which the IFD and density is determined shall not be larger than 24 inches by 24 inches by 4 inches. For grades of foam where the owner or operator has designated the HAP ABA formulation limitation as zero, the owner or operat or is not required to determine the IFD and density in accordance with this paragraph.

§ 63.1305 Alternative means of emission limitation.

An owner or operator of an affected source may request appr oval to use an alternative m eans of emission limitation, following the procedures in this section.

(a) The owner or operator can request approval to use an alternative means of emission limitation in the precompliance report for existing sources, the application for construction or rec onstruction for new sources, or at any time.

(b) This request shall include a complete description of the alternative means of emission limitation.

(c) Each owner or operator applying for permission to use an alternative means of emissi on limitation under §63.6(g) shall be responsible for collecting and verifying data to demonstrate the emission reduction achieved by the alternative means of emission limitation.

(d) Use of the alternative means of emi ssion limitation shall not begin until approv al is granted by the Administrator in accordance with §63.6(g).

§ 63.1306 Reporting requirements.

Owners and operators of affected sources shall comply wi th each applicable reporting provision in this section.

(a) Initial notification. Each affected source shall submit an initial notification in accordance with §63.9(b).

(b) Application for approval of construction or reconstruction. Each owner or operator shall submit an application for approval of construction or reconstruction in accordance with the provisions of §63.5(d).

(c) Precompliance report. Each slabstock affected source shall subm it a precompliance report no later than 12 months before the compliance dat e. This report shall contain the information listed in paragraphs (c)(1) through (c)(8) of this section, as applicable.

(1) Whether the source will comply with the emission point specific limitations described in §63.1293(a), or with the source-wide emission limitation described in §63.1293(b).

(2) For a source complying with the emission point specific limitations, whether the source will comply on a rolling annual basis in accordance with §63.1297(b), or will comply with the monthly alternative for compliance contained in §63.1297(c).

(3) For a source complying with the source-wide emission limitation, whether the source will comply on a rolling annual basis in accordance with §63.1299(a), or will comply with the monthly alternative for compliance contained in §63.1299(b).Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 20 of 35 T003-27321-00225

(4) A description of how HAP ABA and/or polyol added at t he mixhead will be monitored. If the owner or operator is developing an alternative monitoring program, the alternat ive monitoring program containing the information in §63.1303(b)(5)(i) through (iv) shall be submitted.

(5) Notification of the intent to use a recovery device to comply with the provisions of §63.1297 or §63.1299.

(6) For slabstock affected sources complying with §63.1297 or §63.1299 using a recovery device, the continuous recovered HAP ABA monitoring and recordkeeping program, developed in accordance with §63.1303(c).

(7) For sources complying with the source-wide emission limit ation, a description of how the amount of HAP ABA in a storage vessel shall be determined.

(8) For sources complying with the source-wide emission limitation, a description of how the amount of HAP ABA added to a storage vessel during a delivery will be monitored. If the owner or operator is developing an alternative monitoring program, the alternative monitoring program containing the information in §63.1303(e)(4)(i) through (iv) shall be submitted.

(9) If the Administrator does not notify the owner or oper ator of objections to an alternative monitoring program submitted in accordance with (c)(4) or (c)(6) of this section, or a recove red HAP ABA monitoring and recordkeeping program submitted in accordance with (c)(7) of this se ction, the program shall be deemed approved 45 days after its receipt by the Administrator.

(d) Notification of compliance status. Each affected source shall submit a noti fication of compliance status report no later than 180 days after the compliance date. For slabstock affected sources, this report shall contain the information listed in paragraphs (d)(1) through (3) of this section, as applicable. This report shall contain the information listed in paragraph (d)(4) of this section for molded foam pr ocesses and in paragraph (d)(5) for rebond foam processes.

(1) A list of diisocyanate storage vessels, along with a record of the type of control util ized for each storage vessel.

(2) For transfer pumps in diisocyanate service, a record of the type of control utilized for each transfer pump.

(3) If the source is complying with the emission point specific limitations of §§6 3.1294 through 63.1298, the information listed in paragraphs (b)(3)(i) through (iii) of this section.

(i) A list of HAP ABA storage vessels, along with a record of the type of control util ized for each storage vessel.

(ii) A list of pumps, valves, connectors, pressure-relief devices, and open-ended valves or lines in HAP ABA service.

(iii) A list of any modifications to equipment in HAP ABA se rvice made to comply with the provisions of §63.1296.

(4) A statement that the mol ded foam affected source is in compliance wi th §63.1300, or a statement that molded foam processes at an affected source are in compliance with §63.1300.

(5) A statement that the rebon d foam affected source is in compliance wi th §63.1301, or that rebond processes at an affected source are in compliance with §63.1301.

(e) Semiannual reports. Each slabstock affected source shall submit a report containing the information specified in paragraphs (e)(1) through (5) of this section semiannually no later than 60 days after the end of each 180 day period. The first report shall be submitted no later than 240 days after the date that the Notification of Compliance Status is due and shall cover the 6-month period beginning on the date that the Notification of Compliance Status Report is due.

(1) For slabstock affected sources comply ing with the rolling annual compliance provisions of either §63.1297 or §63.1299, the allowable and actual HAP ABA emissions (o r allowable and actual source-wide HAP emissions) for each of the 12-month periods ending on eac h of the six months in the reporti ng period. This information is not required to be included in the initial semi-annual compliance report.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 21 of 35 T003-27321-00225

(2) For sources complying with the monthly compliance alte rnative of either §63.1297 or §63.1299, the allowable and actual HAP ABA emissions (or allowable and actual source -wide HAP emissions) for each of the six months in the reporting period.

(3) For sources complying with the storage vessel provisio ns of §63.1294(a) or §63.1295 using a carbon adsorption system, unloading events that occurred after breakthrou gh was detected and before the carbon was replaced.

(4) Any equipment leaks that were not repaired in accordance with §63.1294(b)(2)(iii), §63.1294(c), §63.1296(a)(2)(iii), (b)(2), (b)(3)(iv), (b )(4)(v), (c)(2), (c)(4)(ii), and (d)(2).

(5) Any leaks in vapor return lines that were not repaired in accordance with §63.1294(a)(1)(ii) or §63.1295(b)(2).

(f) Other reports. (1) Change in selected emission limitation. An owne r or operator electing to change their slabstock flexible polyurethane foam emission limitation (from emission point specific limitations to a source-wide emission limitation, or vice versa), selected in accordance with § 63.1293, shall notify the Administrator no later than 180 days prior to the change.

(2) Change in selected compliance method. An owner or operator changing t he period of compliance for either §63.1297 or §63.1299 (between rolling annual and monthly) s hall notify the Administrator no later than 180 days prior to the change.

(g) Annual compliance certifications. Each affected source subject to the pr ovisions in §§63.1293 through 63.1301 shall submit a compliance certification annually.

(1) The compliance certification shall be based on information consistent with that contained in §63.1308 of this section, as applicable.

(2) A compliance certification required pursuant to a State or local operating permit program may be used to satisfy the requirements of this section, provid ed that the compliance certification is bas ed on information consistent with that contained in §63.1308 of this section, and provided that the Administrator has approved the State or local operating permit program under part 70 of this chapter.

(3) Each compliance certification submitted pursuant to this section shall be signed by a responsible official of the company that owns or operates the affected source.

§ 63.1307 Recordkeeping requirements.

The applicable records designated in paragraphs (a) throug h (c) of this section shall be maintained by owners and operators of all affected sources.

(a) Storage vessel records. (1) A list of diisocyanate storage vessels, along wi th a record of the type of control utilized for each storage vessel.

(2) For each slabstock affected source complying with the emission point specific limit ations of §§63.1294 through 63.1298, a list of HAP ABA storage vessels, along with a record of the type of control utilized for each storage vessel.

(3) For storage vessels complying through the use of a carbon adsorption system, paragraph (a)(3)(i) or (ii), and paragraph (a)(3)(iii) of this section.

(i) Records of dates and times when the carbon adsorption system is monitored for carbon breakthrough and the monitoring device reading, when the device is monitored in accordance with §63.1303(a); or

(ii) For affected sources monitoring at an interval no gr eater than 20 percent of the carbon replacement interval, in accordance with §63.1303(a)(2), the records listed in paragraphs (a)(3)(ii)(A) and (B) of this section.

(A) Records of the design analysis, including all the information listed in §63.1303(a)(2)(i) through (iii), andFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 22 of 35 T003-27321-00225

(B) Records of dates and times when the carbon adsorption system is monitored for carbon breakthrough and the monitoring device reading.

(iii) Date when the existing carbon in the carbon adsorption system is replaced with fresh carbon.

(4) For storage vessels complying through the use of a vapo r return line, paragraphs (a)(4)(i) through (iii) of this section.

(i) Dates and times when each unloading event occurs and eac h inspection of the vapor return line for leaks occurs.

(ii) Records of dates and times when a leak is detected in the vapor return line.

(iii) Records of dates and times when a leak is repaired.

(b) Equipment leak records. (1) A list of components as specified below in paragraphs (b)(1)(i) and (ii).

(i) For all affected sources, a list of components in diisocyanate service,

(ii) For affected sources complying with the emission point specific limitations of §§63. 1294 through 63.1298, a list of components in HAP ABA service.

(2) For transfer pumps in diisocyanate service, a record of the type of control utilized for each transfer pump and the date of installation.

(3) When a leak is detected as specified in §63.1294(b)(2 )(ii), §63.1294(c), §63.1296(a)(2), (b)(1), (c)(1), and (d)(1), the requirements listed in paragraphs (b)(3 )(i) and (ii) of this section apply:

(i) Leaking equipment shall be identified in accordance with the requirements in paragraphs (b)(3)(i)(A) through (C) of this section.

(A) A readily visible identification, marked with the equi pment identification number, shall be attached to the leaking equipment.

(B) The identification on a valve may be removed after it ha s been monitored for 2-successive quarters as specified in §63.1296(b)(1) and no leak has been detected during those 2 quarters.

(C) The identification on equipment, other than a valve, may be removed after it has been repaired.

(ii) The information in paragraphs (b)(2)(ii)(A) thr ough (H) shall be recorded for leaking components.

(A) The instrument and operator identification numbers and the equipment identification number.

(B) The date the leak was detec ted and the dates of each a ttempt to repair the leak.

(C) Repair methods applied in each attempt to repair the leak.

(D) The words “above leak definition” if the maximum in strument reading measured by the methods specified in §63.1304(a) after each repair attempt is equal or greate r than the leak definitions for the specified equipment.

(E) The words “repair delayed” and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of the leak.

(F) The expected date of the successful r epair of the leak if a leak is not repaired within 15 calendar days.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 23 of 35 T003-27321-00225

(G) The date of successful repair of the leak.

(H) The date the identification is removed.

(c) HAP ABA records —(1) Emission point specific limitations—rolling annual compliance and monthly compliance alternative records. Each slabstock affected source complying with the emission point specific limitations of §63.1294 through 63.1298, and the rolling annual compliance provisions of §63.1297(a)(1), shall maintain the records listed in paragraphs (c)(1)(i), (ii), (iii), and (iv) of this section. Each flexible polyurethane foam slabstock source complying with the emission point specific limitations of §§63.1294 through 63.1298, and t he monthly compliance alternative of §63.1297(a)(2), shall maintain the records listed in pa ragraphs (c)(1)(i), (ii), and (iv) of this section.

(i) Daily records of the information listed below in paragraphs (c)(1)(i)(A) through (C) of this section.

(A) A log of foam runs each day. For each run, the log sha ll include a list of the grades produced during the run.

(B) Results of the density and IFD testing for each grad e of foam produced during eac h run of foam, conducted in accordance with the procedures in §63.13 04(b). The results of this testing sha ll be recorded within 10 working days of the production of the foam. For grades of foam wh ere the owner or operator has designated the HAP ABA formulation limitation as zero, the owner or operator is not required to keep records of the IFD and density.

(C) The amount of polyol added to the slabstock foam production line at the mixhead for each run of foam, determined in accordance with §63.1303(b).

(ii) Monthly records of the information listed in par agraphs (c)(1)(ii)(A) through (E) of this section.

(A) A listing of all foam gr ades produced during the month,

(B) For each foam grade produced, the HAP ABA formulation limitation, calculated in accordance with §63.1297(d).

(C) With the exception of those grades for which the owner or operator has designated zero as the HAP ABA formulation limitation, the total amount of polyol used in the month for each foam grade produced.

(D) The total allowable HAP ABA emissions for the mont h, determined in accordance with §63.1297(b)(2).

(E) The total amount of HAP ABA added to the slabstock fo am production line at the mixhead during the month, determined in accordance with §63.1303(b).

(iii) Each source complying with the rolling annual compli ance provisions of §63.1297(b) shall maintain the records listed in paragraphs (c)(1)(iii)(A) and (B) of this section.

(A) The sum of the total allowable HAP ABA emissi ons for the month and t he previous 11 months.

(B) The sum of the total actual HAP ABA emissi ons for the month and t he previous 11 months.

(iv) Records of all calibrations for each device us ed to measure polyol and HAP ABA added at the mixhead, conducted in accordance with §63.1303(b)(3).

(2) Source-wide limitations—rolling annual compliance and monthly compliance alternative records. Each slabstock affected source complying with the source-wide limitations of §63.1299, and the rolling annual compliance provisions in §63.1299(a), shall maintain the records listed in paragraphs (c)(2)(i) through (c)(2)(vii) of th is section. Each flexible polyurethane foam slabstock source complying with t he source-wide limitations of §63.1299, and the monthly compliance alternative of §63.1299(b), shall maintain the re cords listed in paragraphs (c)(2)(i) through (c)(2)(iii) and paragraphs (c)(2)(v) through (c )(2)(vii) of this section.

(i) Daily records of the information listed in par agraphs (c)(2)(i)(A) through (C) of this section.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 24 of 35 T003-27321-00225

(A) A log of foam runs each day. For each run, the log sha ll include a list of the grades produced during the run.

(B) Results of the density and IFD testing for each grad e of foam produced during eac h run of foam, conducted in accordance with the procedures in §63.13 04(b). The results of this testing sha ll be recorded within 10 working days of the production of the foam. For grades of foam wh ere the owner or operator has designated the HAP ABA formulation limitation as zero, the owner or operator is not required to keep records of the IFD and density.

(C) With the exception of those grades for which the owner or operator has designated zero as the HAP ABA formulation limitation, the amount of pol yol added to the slabstock foam produc tion line at the mixhead for each grade produced during each run of foam, determi ned in accordance with §63.1303(b).

(ii) For sources complying with the source-wide emission limitation, weekly records of the storage tank level, determined in accordance with §63.1303(d).

(iii) Monthly records of the information listed below in paragraphs (c)(2)(iii)(A) through (E) of this section.

(A) A listing of all foam gr ades produced during the month,

(B) For each foam grade produced, the residual HAP formulation limitation, calculated in accordance with §63.1297(d).

(C) With the exception of those grades for which the owner or operator has designated zero as the HAP ABA formulation limitation, the total amount of polyol used in the month for each foam grade produced.

(D) The total allowable HAP ABA and equipment cleaning emissions for the month, determined in accordance with §63.1297(b)(2).

(E) The total actual source-wide HAP ABA emissions for th e month, determined in accordance with §63.1299(c)(1), along with the information listed in paragraphs (c)(2)(iii)(E)( 1 ) and ( 2 ) of this section.

( 1 ) The amounts of HAP ABA in the storage vessel at the beginning and end of t he month, determined in accordance with §63.1299(c)(2); and

( 2 ) The amount of each delivery of HAP ABA to the storage vessel, determined in accordance with §63.1299(c)(3).

(iv) Each source complying with the rolling annual compliance provisions of §63.1299(a) shall maintain the records listed in paragraphs (c)(2)(iv)(A) and (B) of this section.

(A) The sum of the total allowable HAP ABA and equipment cleaning HAP emissions for the month and the previous 11 months.

(B) The sum of the total actual HAP ABA and equipment cl eaning HAP emissions for the month and the previous 11 months.

(v) Records of all calibrations for each device used to measure polyol added at the mixhead, conducted in accordance with §63.1303(b)(3).

(vi) Records of all calibrations for each device used to measure the amount of H AP ABA in the storage vessel, conducted in accordance with §63.1303(d)(1).

(vii) Records to verify that all scales used to measure the amount of HAP ABA added to t he storage vessel meet the requirements of §63.1303(e)(3). For scale s meeting the criteria of §63.1303(e)(3 )(i), this documentation shall be in the form of written confirmation of t he State or local approval. For scales complying with §63.1303(e)(3)(ii), this documentation shall be in the form of a report pr ovided by the registered scale technician.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 25 of 35 T003-27321-00225

(d) The owner or operator of each affected source comp lying with §63.1297 or §63.1299 through the use of a recovery device shall mainta in the following records:

(1) A copy of the recovered HAP ABA monitoring and recordkeeping program, developed pursuant to §63.1303(c);

(2) Certification of the accura cy of the monitoring device,

(3) Records of periodic calibration of the monitoring devices,

(4) Records of parameter monitoring results, and

(5) The amount of HAP ABA recovered each time it is measured.

(e) The owner or operator of an affected source subject to §63.1298 of this subpart shall maintain a product data sheet for each equipment cleaner used which includes the H AP content, in kg of HAP/kg solids (lb HAP/lb solids).

(f) The owner or operator of an affected source following the compliance methods in §63.1308(b)(1) and (c)(1) shall maintain records of each use of a vapor return line duri ng unloading, of any leaks detec ted during unloading, and of repairs of leaks detected during unloading.

(g) The owner or operator of an affected source subject to §63.1300 or §63.1301 of this subpart shall maintain a product data sheet for each compound other than diisocy anates used to flush the mixhead and associated piping during periods of startup or maintenance, which includes the HAP content, in kg of HAP/kg solids (lb HAP/lb solids), of each solvent other than diisocyanates used to flush the mixhead and associated piping during periods of startup or maintenance.

(h) The owner or operator of an affected source subject to §63.1300 or §63.1301 of this subpart shall maintain a product data sheet for each mold release a gent used that includes the HAP conten t, in kg of HAP/kg solids (lb HAP/lb solids), of each mold release agent.

§ 63.1308 Compliance demonstrations.

(a) For each affected source, compliance with the requirement s listed in paragraphs (a)(1) through (a)(2) of this section shall mean compliance with the requirements cont ained in §§63.1293 through 63.1301, absent any credible evidence to the contrary.

(1) The requirements described in Tables 3, 4, and 5 of this subpart; and

(2) The requirement to submit a compliance cert ification annually as required under §63.1306(g).

(b) All slabstock affected sources. For slabstock affected sources, failure to meet the requirements contained in §63.1294 shall be considered a violation of this subpart. Violation of each item listed in the paragraphs (b)(1) through (b)(6) of this section, as applicable, shall be considered a separate violation.

(1) For each affected source complying with §63.1294(a) in accordance with §63.1294(a)(1), each unloading event that occurs when the diisocya nate storage vessel is not equipped with a v apor return line from the storage vessel to the tank truck or rail car, each unloadi ng event that occurs when the vapor line is not connected, each unloading event that the vapor line is not inspec ted for leaks as described in §63.1294(a)(1)(i), each unloading event that occurs after a leak has been detected and not repaired, and each cale ndar day after a leak is detected, but not repaired as soon as practicable;

(2) For each affected source complying with §63.1294(a) in accordance with §63.1294(a)(2), each unloading event that the diisocyanate st orage vessel is not equipped with a carbon adsorption system, each unloading event (or each month if more than one unloading event occurs in a month) that the carbon adsorption system is not monitored for breakthrough in accordance with §63.1303(a)(3) or (4), and each unloading event that occurs when the carbon is not replaced after an indication of breakthrough;Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 26 of 35 T003-27321-00225

(3) For each affected source complying with §63.1294(a) in accordance with §63.1294(a)(2) through the alternative monitoring procedures in §63.1303(a)(2), each unloading ev ent that the diisocyanate storage vessel is not equipped with a carbon adsorption system, each time that the carbon adsorption system is not m onitored for breakthrough in accordance with §63.1303(a)(3) or (4) at the interval established in the design analysis, and each unloading event that occurs when the carbon is not repl aced after an indication of breakthrough;

(4) For each affected source complying with §63.1294(b) in accordance with §63.1294(b)(1), each calendar day that a transfer pump in diisocyanate service is not a sealless pump;

(5) For each affected source complying with §63.1294(b) in accordance with §63.1294(b)(2), each calendar day that a transfer pump in diisocyanate service is not submerged as described in §63.1294(b)(2)(i), each week that the pump is not visually monitored for leaks, each calendar day a fter 5 calendar days after detection of a leak that a first attempt at repair has not been made in accordance with §63.1294(b)(2)(iii)(B), and the earlier of each calendar day after 15 calendar days after detection of a leak that a leak is not repaired, or a leak is not repaired as soon as practicable, each subsequent calender day (with the excepti on of situations meeting the criteria of §63.1294(d));

(6) For each affected source complying with §63.1294(c), each calendar day after 5 calendar days after detection of a leak that a first attempt at repair has not been made, and t he earlier of each calendar day after 15 calendar days after detection of a leak that a leak is not repaired, or if a leak is not repair ed as soon as practicable, each subsequent calender day (with the exception of situatio ns meeting the criter ia of §63.1296(f)).

(c) Slabstock affected sources complying with the emission point specific limitations. For slabstock affected sources complying with the emission point specific limitations as provided in §63.1293(a), fail ure to meet the requirements contained in §§63.1295 through 63.1298 shall be considered a vi olation of this subpart. Viol ation of each item listed in the paragraphs (c)(1) through (c)(17) of this section, as applicable, shall be consi dered a separate violation.

(1) For each affected source complying with §63.1295(a) in accordance with §63.1295(b), each unloading event that occurs when the HAP ABA storage vessel is not equipped with a vapor return line from the storage vessel to the tank truck or rail car, each unloading event that occurs when the vapor line is not connecte d, each unloading event that the vapor line is not inspected for leaks as described in §6 3.1295(b)(1), each unloading event that occurs after a leak has been detected and not repaired, and each calendar day after a leak is detected but not repaired as soon as practicable;

(2) For each affected source complying with §63.1295(a) in accordance with §63.1295(c), each unloading event that the HAP ABA storage vessel is not equipped with a carbon adsorption system, each unloading event (or each month if more than one unloading event occurs in a month) that the carbon adsorption system is not monitored for breakthrough in accordance with §63.1303(a)(3) or (4), and each unloading event that occurs when the carbon is not replaced after an indication of breakthrough ;

(3) For each affected source complying with §63.1295(a) in accordance with §63.1295(c) through the alternative monitoring procedures in §63.1303(a)(2), each unloading event that the HAP ABA storage vessel is not equipped with a carbon adsorption system, each time that the carbon adsorption system is not m onitored for breakthrough in accordance with §63.1303(a)(3) or (4) at the interval established in the design analysis, and each unloading event that occurs when the carbon is not repl aced after an indication of breakthrough;

(4) For each affected source complying with §63.1296(a) in accordance with §63.1296(a)(1), each calendar day that a transfer pump in HAP ABA service is not a sealless pump;

(5) For each affected source complying with §63.1296(a) in accordance with §63.1296(a)(2), each week that a visual inspection of a pump in HAP ABA servic e is not performed, each quarter that a pump in HAP ABA service is not monitored to detect leaks in accordance with §63.1304(a) , each calendar day after 5 calendar days after detection of a leak that a first attempt at repair has not been made in accordance with §63.1296(b)(2)(iii)(B), and the earlier of each calendar day after 15 calendar days after detection of a leak that a leak is not repa ired, or if a leak is not repaired as soon as practicable, each subsequent calender da y (with the exception of situ ations meeting the criteria of §63.1296(f));

(6) F or each af fected source complying with §63.1296(b) in accordance with §63.1296(b)(1) and (2), each quarter that a valve in HAP ABA service is not monitored to detec t leaks in accordance with §63.1304(a), each calendar dayFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 27 of 35 T003-27321-00225

after 5 calendar days after detection of a leak that a fi rst attempt at repair has not been made in accordance with §63.1296(b)(2)(ii), and each calendar day after 15 calendar days after detection of a leak that a leak is not repaired, or if a leak is not repaired as soon as practicable, whiche ver is earlier (with the exception of situations meeting the criteria of §63.1296(f));

(7) For each affected source complying with §63.1296(b )(3) for each valve designated as unsafe to monitor as described in §63.1296(b)(3)(i), failure to develop the written plan required by §63.1296(b)(3)(ii), each period specified in the written plan that an unsafe-to-mo nitor valve in HAP ABA service is not monitored, and each calendar day in which a leak is not repaired in accordance with the written plan;

(8) For each affected source complying with §63.1296(b)(4) fo r one or more valves designated as difficult-to-monitor in accordance with §63.1296(b)(4)(i) and (ii), failure to dev elop the written plan required by §63.1296(b)(4)(iii), each calendar year that a difficult-to-monitor valve in HAP ABA se rvice is not monitored, and each calendar day in which a leak is not repaired in accordance with the written plan;

(9) For each affected source complying with §63.1296(c) in accordance with §63.1296(c)(1) and (2), each year that a connector in HAP ABA service is not monitored to detect leaks in accordance with §63.1304(a); each calendar day after 3 months after a connector has been opened, has otherwis e had the seal broken, or a leak is repaired, that each connector in HAP ABA service is not monitored to detect leaks in accordance with §63.1304(a); each calendar day after 5 calendar days after detection of a leak that a first attempt at repair has not been made, and the earlier of each calendar day after 15 calendar days after detection of a leak that a leak is not repaired, or if a leak is not repaired as soon as practicable, each subsequent ca lendar day (with the exception of si tuations meeting the criteria of §63.1296(f));

(10) For each affected source complying with §63.1296(c)(3 ) for one or more connectors designated as unsafe-tomonitor in accordance with §63.1296(c)(3)(i), failure to dev elop the written plan required by §63.1296(c)(3)(ii), each period specified in the written plan that an unsafe-to-monitor va lve in HAP ABA service is not monitored, each calendar day after 5 calendar days after detection of a leak of an unsafe-to-monitor connector that a first attempt at repair has not been made, and the earlier of each calendar day after 15 calendar days after detection of a leak that a leak is not repaired, or if a leak is not repaired as soon as practicable, each subsequent calender day (with the exception of situations meetin g the criteria of §63.1296(f));

(11) For each affected source complying with §63.1296(c)(4 ) for one or more connectors designated as unsafe to repair, each year that one or more unsafe- to-repair connectors in HAP ABA service is not monitored to detect leaks in accordance with §63.1304(a); each calendar day after 3 mont hs after one or more unsafe-to-repair connectors has been opened, has otherwise had the seal br oken, or a leak is repaired, that eac h unsafe-to-repair connector in HAP ABA service is not monitored to detect leaks in accordanc e with §63.1304(a); and the earlier of each calendar day after six-months after detection of a leak that a leak is not repaired, or if a leak is not repaired as soon as practicable, each subsequent calendar day;

(12) For each affected source complying with §63.1296(d) in accordance with §63.1296(d)(1) and (2), each calendar day after the 5 days that the pressure-relief device has not been monitored in accordance with §63.1304(a) after a potential leak was discovered as described in §63.1296(d)(1 ), each calendar day after 5 calendar days after detection of a leak that a first attempt at repair has not been made, and the earlier of each calendar day after 15 calendar days after detection of a leak that a leak is not repaired, or if a leak is detected and not repaired as soon as practicable, each subsequent calendar day (with the exception of situations meeting the cr iteria of §63.1296(f));

(13) For each affected source complying with §63.1296(e) in accordance with §63.1296(e)(1) through (5), each calendar day that an open-ended valve or line has no cap, blind flange, plug or second valve as described in §63.1296(e)(2), and each calendar day that a valve on the pr ocess fluid end of an open-ended valve or line equipped with a second valve is not closed before the second valve is closed;

(14) For each affected source complying with §63.1297(a) in accordance with the rolling annual compliance option in §63.1297(a)(1) and (b), each calendar day in the 12-month period for which the actual HAP ABA emissions exceeded the allowable HAP ABA emissions level, each calendar day in which foam is being poured where the amount of polyol added at the mixhead is not moni tore d (as requ ired) in accordance with §63.1303(b)(1)(i), each calendar day in which foam is being poured where the amount of HAP ABA added at the mixhead is not monitored (as required) in accordance with §63.1303(b)(1)(ii), each calendar day in a 6-month period in which the polyol pumps are not calibrated in accordance with §63.1303(b)(3)(i), each cale ndar day in a month in which the HAP ABA pumps are notFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 28 of 35 T003-27321-00225

calibrated in accordance with §63.1303(b)(3)(ii), and each calendar day after 10 working days after production where the IFD and density of a foam grade are not determined (where required) in accordance with §63.1304(b);

(15) For each affected source complying with §63.1297(a) in accordance with the monthly compliance option in §63.1297(a)(2) and (c), each calendar day of each month for which the actual HAP ABA emissions exceeded the allowable HAP ABA emissions level for that month, each calendar day in which foam is being poured where the amount of polyol added at the mixhea d is not monitored (as required) in accordance with §63.1303(b)(1)(i), each calendar day in which foam is being poured where the am ount of HAP ABA added at the mixhead is not monitored (as required) in accordance with §63.1303(b)(1)(ii), each 6-m onth period in which the polyol pumps are not calibrated in accordance with §63.1303(b)(3)(i), each month in which the HAP ABA pumps are not calibrated in accordance with §63.1303(b)(3)(ii), and each calendar day after 10 working days after production where the IFD and density of a foam grade are not determined (where required) in accordance with §63.1304(b);

(16) For each affected source complying with §63.1297(a) by using a recovery device as allowed under §63.1297(e), the items listed in (c)(16)(i) or (ii) of this section, as applicable.

(i) If complying with rolling annual compliance option in §6 3.1297(a)(1) and (b), each item listed in (c)(14) of this section, failure to develop a recovered HAP ABA monitoring and recordkeeping program in accordance with §63.1303(c), and each instance when an elem ent of the program is not followed.

(ii) If complying with the monthly compliance option in §63.1297(a)(2) and (c), each item listed in (c)(15) of this section, failure to develop a recovered HAP ABA monitoring and recordkeeping program in accordance with §63.1303(c), and each instance when an elem ent of the program is not followed.

(17) For each affected source complying with §63.1298, each calendar day that a HAP or any HAP-based material is used as an equipment cleaner.

(d) Slabstock affected sources complying with the source-wide emission limitation. For slabstock affected sources complying with the source-wide emission limitation as pr ovided in §63.1293(b), failure to meet the requirements contained in §63.1299 shall be consider ed a violation of this subpart. Violati on of each item listed in the paragraphs (d)(1) through (d)(3) of this sect ion, as applicable, shall be c onsidered a separate violation.

(1) For each affected source complying with §63.1299 in accordance with the rolling annual compliance option in §63.1299(a), each calendar day in the 12-month perio d for which the actual HAP ABA emissions exceeded the allowable HAP ABA emissions level, each calendar day in which foam is being poured where the amount of polyol added at the mixhead is not monitored (as required) in accordance with §63.1303(b)(1)(i), each calendar day in a week in which the amount of HAP ABA in a storage vessel is not determined in accordance with §63.1303(d), each delivery of HAP ABA in which the amount of HAP ABA added to the storage vessel is not determined in accordance with §63.1303(e), each calendar day in a 6-month period in which the polyol pumps are not calibrated in accordance with §63.1303(b)(3)(i), and each calendar day after 10 working days after production where the IFD and density of a foam grade are not determined (where required) in accordance with §63.1304(b);

(2) For each affected source complying with §63.1299 in accordance with the monthly compliance option in §63.1299(b), each calendar day of each month for which the actual HAP ABA emissions exceeded the allowable HAP ABA emissions level for that month, each calendar da y in which foam is being poured where the amount of polyol added at the mixhead is not moni tored (as required) in accordance with §63.1303(b)(1)(i), each calendar day in a week in which the amount of HAP ABA in a storage vessel is not determined in accordance with §63.1303(d), each delivery of HAP ABA in which the amount of HAP ABA added to the storage vessel is not determined in accordance with §63.1303(e), and each calendar day in a 6-month pe riod in which the polyol pumps are not calibrated in accordance with §63.1303(b)(3)(i), and each calendar day after 10 working days after production where the IFD and density of a foam grade are not determined (where required) in accordance with §63.1304(b).

(3) For each affected source complying with §63.1299 by using a recovery device as allowed under §63.1299(e), the items listed in (d)(3)(i) or (ii) of this section, as applicable.

(i) If complying with rolling annual compliance option in §63.129 9(a), each item listed in (d)(1) of this section, failure to develop a recovered HAP ABA monitoring and recordkeeping program in accordance with §63.1303(c), and each instance when an element of the program is not followed.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 29 of 35 T003-27321-00225

(ii) If complying with the monthly compliance option in §63.1299( b), each item listed in (d)(2) of this section, failure to develop a recovered HAP ABA monitoring and recordkeeping program in accordance with §63.1303(c), and each instance when an element of the program is not followed.

(e) Molded and rebond foam affected sources. For molded and rebond foam affect ed sources, failure to meet the requirements contained in §63.1300 an d §63.1301, respectively, shall be cons idered a violation of this subpart. Violation of each item listed in the following paragraphs shall be considered a separate violation.

(1) For each molded foam affected source subject to the provisions in §63.1300(a), each calendar day that a HAPbased material is used as an equipment cleaner (except fo r diisocyanates used to flush the mixhead and associated piping during periods of startup or maintenance, provided th at the diisocyanate compounds are contained in a closedloop system and are re-used in production);

(2) For each molded foam affected source subject to the provisions of §63.1300(b), each calendar day that a HAPbase material is used as a mold release agent;

(3) For each rebond foam affected source subject to the provisions of §63.1301(a), each calendar day that a HAPbased material is used as an equipment cleaner; and

(4) For each rebond foam affected source complying with §63.1301(b), each calendar day that a HAP-based mold release agent is used.

§ 63.1309 Implementation and enforcement.

(a) This subpart can be implemented and enforced by the U.S. EPA, or a delegated authority such as the applicable State, local, or Tribal agency. If the U. S. EPA Administrator has delegated authority to a State, local, or Tribal agency, then that agency, in addition to the U. S. EPA, has the authority to implemen t and enforce this subpart. Contact the applicable U.S. EPA Regional Offi ce to find out if implementation and enforc ement of this subpar t is delegated to a State, local, or Tribal agency.

(b) In delegating implementation and enforcement authority of this subpart to a State, local, or Tribal agency under subpart E of this part, the authorities contained in paragraph (c ) of this section are retained by the Administrator of U.S. EPA and cannot be transferred to t he State, local, or Tribal agency.

(c) The authorities that cannot be delegat ed to State, local, or Tribal agencies are as specified in paragraphs (c)(1) through (5) of this section.

(1) Approval of alternatives to the requirements in §§63.1290, 63.1291, 63.1293 through 63.1301, and 63.1305.

(2) Approval of major alternatives to test methods under §63. 7(e)(2)(ii) and (f), as defined in §63.90, and as required in this subpart.

(3) Approval of major alternatives to monitoring under § 63.8(f), as defined in §63.90, and as required in this subpart.

(4) Approval of alternatives to the specific monitoring requirements of §63.1303(b)(5).

(5) Approval of major alternatives to recordkeeping and reporting under §63.10(f), as defined in §63.90, and as required in this subpart.

[68 FR 37357, June 23, 2003]

Appendix to Subpart III of Part 63—Tables: Note

For the convenience of the readers of subpart III, the t ables below summarize the requirements in §§63.1290 to 63.1307. These tables are intended to assist the reader in determining the requirements applicable to affected sources and do not alter an affected source's obligation to comply with the requirements in §§63.1290 to 63.1307.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 30 of 35 T003-27321-00225

Table 1 to Subpart III of Part 63—HAP ABA Formulation Limitations Matrix for New Sources [see §63.1297(d)(2)]

Table 2 to Subpart III of Part 63—Applicability of General Provisions (40 CFR Part 63, Subpart A) to Subpart III



### Subpart A reference Applies
to subpart III Comment

§63.1 YES Except that §63.1(c)(2) is not applic able to the extent area sources are not subject to subpart III.

§63.2 YES Definitions are modifi ed and supplemented by §63.1292.

§63.3 YES

§63.4 YES

§63.5 YES

§63.6 (a)–(d) YES

§63.6(e) (1)–(2) YES
§63.6(e)(3) NO Owners and operators of subpa rt III affected sour ces are not required to develop and implement a star tup, shutdown, and malfunction plan.
§63.6 (f)–(g) YES
§63.6(h) NO Subpart III does not require opacity and visible emission standards.
§63.6 (i)–(j) YESFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 31 of 35 T003-27321-00225



### §63.7 NO Performance tests not required by subpart III.

§63.8 NO Continuous monitoring, as defined in subpart A, is not required by subpart III.

§63.9 (a)–(d) YES
§63.9 (e)–(g) NO
§63.9(h) NO Subpart III specifies Notificat ion of Compliance Status requirements.
§63.9 (i)–(j) YES
§63.10 (a)–(b) YES Except that the records speci fied in §63.10(b)(2)(vi) through (xi) and (xiii) are not required.

§63.10(c) NO

§63.10(d)(1) YES

§63.10 (d) (2)– (3) NO

§63.10 (d) (4)– (5) YES

§63.10(e) NO

§63.10(f) YES

§63.11 YES

§63.12 YES

§63.13 YES

§63.14 YES

§63.15 YES

Table 3 to Subpart III of Part 63—Complian ce Requirements for Slabstock Foam Production Affected Sources Complying With the Emission Point Specific Limitations



### Emission point Emission point compliance option Emission, work practice, and

equipment standards Monitoring Recordkeeping Reporting

Diisocyanate storage vessels §63.1294(a) Vapor balance §63.1294(a)(1) and (1)(ii) §63.1294(a)(1)(i) §63.1307(a)(1) and (4) §63.1306(e)(5).

Carbon §63.1294(a)(2) §63.1303(a)(1), §63.1307(a)(1), §63.1306(e)(3).Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 32 of 35 T003-27321-00225



### adsorber (3), and (4) (3)(i), and (3)(iii)

Carbon adsorber— alternative monitoring §63.1294(a)(2) §63.1303(a)(2), (3) and (4) §63.1307(a)(1), (3)(ii), and (3)(iii) §63.1306(e)(3).

Diisocyanate transfer
pumps §63.1294(b) Sealless
pump §63.1294(b)(1) §63.1307 (b)(1)(i) and (2)

Submerged
pump §63.1294(b)(2)(i) and (iii) §63.1294 (b)(2)(ii) §63.1307 (b)(1)(i), (2), and (3) §63.1306(e)(4).

Other components in diisocyanate service §63.1294(c) N/A §63.1294(c) §63.1294(c) §63.1307 (b)(1)(i) and (3) §63.1306(e)(4).

HAP ABA storage vessels §63.1295 Vapor balance §63.1295(b) and (b)(2) §63.1295 (b)(1) §63.1307(a)(2) and (4) §63.1306(e)(5).

Carbon adsorber §63.1295(c) §63.1303(a)(1), (3), and (4) §63.1307(a)(2), (3)(i), (3)(iii) §63.1306(e)(3).

Carbon adsorber— alternative monitoring §63.1295(c) §63.1303(a)(2), (3) and (4) §63.1307(a)(2), (3)(ii), and (3)(iii) §63.1306(e)(3).

HAP ABA
pumps §63.1296(a): Sealless
pump §63.1296(a)(1) §63.1307 (b)(1)(ii)

Quarterly monitoring §63.1296(a)(2) and (2)(iii) §63.1296(a)(2)(i), (2)(ii) and §63.1304(a) §63.1307 (b)(1)(ii) and (3) §63.1304(e)(4).

HAP ABA valves §63.1296(b): Quarterly monitoring §63.1296(b), and (b)(2) §63.1296 (b)(1) and §63.1304(a) §63.1307 (b)(1)(ii) and (3) §63.1304(e)(4).Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 33 of 35 T003-27321-00225



### Unsafe-tomonitor §63.1296(b)(3) (i), (ii), and (iv) §63.1296 (b)(3)(iii) §63.1307 (b)(1)(ii), and (4) §63.1304(e)(4).

Difficultto-monitor §63.1296(b)(4) (i), (ii), (iii), and (v) §63.1296(b)(4)(iv) and §63.1304(a) §63.1307 (b)(1)(ii) and (4) §63.1306(e)(4).

HAP ABA Connectors §63.1296(c): Annual monitoring §63.1296(c) and (c)(2) §63.1296(c)(1) and §63.1304(a) §63.1307 (b)(1)(ii) and (3) §63.1306(e)(4).

Unsafe-tomonitor §63.1296(c)(2), (3) (i), and (ii) §63.1296(c)(3) (iii) and §63.1304(a) §63.1307 (b)(1)(ii) and (4) §63.1306(e)(4).

Unsafe-torepair §63.1296(c)(4) §63.1296(c)(1) §63.1307 (b)(1)(ii) §63.1306(e)(4).

Pressurerelief devices §63.1296(d) N/A §63.1296(d) and (d)(2) §63.1296 (d)(1) and §63.1304(a) §63.1307 (b)(1)(ii) and (3) §63.1306(e)(4).

Open-ended valves or lines §63.1296(e) N/A §63.1296(e) §63.1307 (b)(1)(ii)

Production line §63.1297 Rolling annual compliance §63.1297(a)(1) and (b) §63.1303 (b) §63.1307(c)(1) §63.1306(e)(1).

Monthly compliance §63.1297(a)(2) and (c) §63.1303 (b) §63.1307(c)(1) §63.1306(e)(2).

Compliance Using a Recovery device §63.1297(a)(1), (b), and (e) for rolling annual compliance or §63.1297(a)(2), (c), and (e) for monthly compliance §63.1303 (b) and (c) §63.1307(c)(1) and (d) §63.1306(e)(1) or (2).

Equipment Cleaning §63.1298 N/A §63.1298 §63.1307(e)Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 34 of 35 T003-27321-00225

Table 4 to Subpart III of Part 63—Complian ce Requirements for Slabstock Foam Production Affected Sources Complying With th e Source-Wide Emission Limitation



### Emission point Emission point compliance option Emission, work practice, and

equipment standards Monitoring Recordkeeping Reporting
Diisocyanate storage vessels §63.1294(a) Vapor balance §63.1294(a)(1) and (1)(ii) §63.1294(a)(1)(i) §63.1307(a)(1) and (4) §63.1306(e)(5).

Carbon adsorber §63.1294(a)(2) §63.1303(a)(1), (3), and (4) §63.1307(a)(1), (3)(i), and (3)(iii) §63.1306(e)(3).

Carbon adsorber— alternative monitoring §63.1294(a)(2) §63.1303(a)(2), (3) and (4) §63.1307(a)(1), (3)(ii), and (3)(iii) §63.1306(e)(3).

Diisocyanate transfer
pumps §63.1294(b) Sealless
pump §63.1294(b)(1) §63.1307 (b)(1)(i) and (2)

Submerged
pump §63.1294(b)(2)(i) and (iii) §63.1294 (b)(2)(ii) §63.1307 (b)(1)(i), (2), and (3) §63.1306(e)(4).

Other components in diisocyanate service §63.1294(c) N/A §63.1294(c) §63.1294(c) §63.1307 (b)(1)(i) and (3) §63.1306(e)(4).

HAP ABA storage vessels, equipment leaks, production line, and equipment cleaning Rolling annual compliance §63.1299(a), (c)(1) through (4), and (d) §63.1303 (b) except (b)(1)(ii), (d), and (e) §63.1307(c)(2) §63.1306(e)(1).

Monthly compliance §63.1299(b), (c)(1) through (4), §63.1303 (b) except (b)(1)(ii), §63.1307(c)(2) §63.1306(e)(2).Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment A 40 CFR 63, Subpart III Page 35 of 35 T003-27321-00225



### and (d) (d), and (e)
Compliance Using a Recovery device §63.1299(a), (d), and (e) for rolling annual compliance or §63.1299(b), (d), and (e) for monthly compliance §63.1303 (b) except (b)(1)(ii) and (c) §63.1307(c)(2) and (d) §63.1306(e)(1) or (2).

Table 5 to Subpart III of Part 63—Compliance Requirements for Mold ed and Rebond Foam Production Affected Sources



### Emission point Emission point compliance option Emission, work practice, and equipment standards Monitoring Recordkeeping Reporting

Molded

Foam

Equipment cleaning N/A §63.1300(a) §63.1307(g)

Mold release agent N/A §63.1300(b) §63.1307 (h)

Rebond

Foam

Equipment cleaning N/A §63.1301(a) §63.1307 (g)

Mold release agent N/A §63.1301(b) §63.1307 (h)Attachment B to Part 70 Operating Permit Renewal No. T003-27321-00225

Foamex Innovations Operating Company 3005 Commercial Road Fort Wayne, Indiana 46809

Subpart MMMMM—National Emission Standards for Hazardous Air Pollutants: Flexible Polyurethane Foam Fabrication Operations

Source: 68 FR 18070, Apr. 14, 2003, unless otherwise noted.

What This Subpart Covers

§ 63.8780 What is the purpose of this subpart?

This subpart establishes national emission standards for haza rdous air pollutants (NESHAP) emitted from flexible polyurethane foam fabrication operations. This subpart al so establishes requirements to demonstrate initial and continuous compliance with the emission standards.

§ 63.8782 Am I subject to this subpart?

(a) You are subject to this subpart if you own or operate a flexible polyurethane foam fabrication plant site that operates a flame lamination affected source, as defined at §63. 8784(b)(2), and that is locat ed at, or is part of a major emission source of hazardous air pollutants (HAP) or that operates a loop slitter a ffected source, as defined at §63.8784(b)(1), that meets the criteria in paragraphs (a)(1) and (2) of this section.

(1) The loop slitter affected source uses one or more HAP- based adhesives at any time on or after April 14, 2003.

(2) The loop slitter affected source is located at or is part of a major source of HAP.

(b) A flexible polyurethane foam fabrication plant site is a plant site where pieces of flexible polyurethane foam are bonded together or to other substrates usin g HAP-based adhesives or flame lamination.

(c) A major source of HAP is a plant site that emits or has the potential to emit any single HAP at a rate of 10 tons or more per year or any combination of HAP at a rate of 25 tons or more per year.

(d) This subpart does not apply to the following proce sses in paragraphs (d)(1) and (2) of this section:

(1) Processes that produce flexible polyurethane or rebond foam as defined in subpart III of this part.

(2) A research and development facility, as defined in section 112(c)(7) of the Clean Air Act (CAA).

§ 63.8784 What parts of my plant does this subpart cover?

(a) This subpart applies to each existing, new, or reconstr ucted affected source at facilities engaged in flexible polyurethane foam fabrication.

(b) The affected sources are defined in this section in paragraphs (b)(1) and (2) of this section.

(1) The loop slitter adhesive use affected source is the collection of all loop slitters and associated adhesive application equipment used to apply HAP-based adhesives to bond foam to foam at a flexible polyurethane foam fabrication plant site.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 2 of 21 T003-27321-00225

(2) The flame lamination affected source is the collection of all flame lamination lines associated with the flame lamination of foam to any substrate at a flex ible polyurethane foam fabrication plant site.

(c)(1) A new affected source is one that commences cons truction after August 8, 2001 and meets the applicability criteria of §63.8782 at the time construction commences.

(2) If you add one or more flame lamination lines at a plant site where flame lamination lines already exist, the added line(s) shall be a new affected source and meet new source requirements if the added line (s) has the potential to emit 10 tons per year or more of any HAP or 25 tons or more per year of any combination of HAP.

(d) A reconstructed affected source is one that commences reconstruction after August 8, 2001 and meets the criteria for reconstruction as defined in §63.2.

(e) For each new or reconstructed flame lamination affected source, you must develop a written startup, shutdown, and malfunction plan according to the provisions in §63.6(e)(3).

[68 FR 18070, Apr. 14, 2003, as amen ded at 71 FR 20470, Apr. 20, 2006]

§ 63.8786 When do I have to comply with this subpart?

(a) If you have a new or reconstructed affected source, you must comply with this subp art according to paragraphs (a)(1) and (2) of this section.

(1) If you start up your new or reconstructed affected source before April 14, 2003, then you must comply with the emission standards for new or reconstructed sour ces in this subpart no later than April 14, 2003.

(2) If you start up your new or reconstructed affected source on or after April 14, 2003, then you must comply with the emission standards for new or reconstructed sources in this subpart upon startup of your affected source.

(b) If you have an existing loop slitter affected source, y ou must comply with the emission standards for existing sources no later than 1 year after April 14, 2003.

(c) If you have an area source that increases its emissions or its potential to emit such that it becomes a major source of HAP and an affected source subject to this subpart, the provisions in paragraphs (c)(1) and (2) of this section apply.

(1) A new affected source as specified at §63.8784(c) or a reconstructed affected source as specified at §63.8784(d) must be in compliance with this subpart upon startup.

(2) An existing affected source as specified at §63.8784( e) must be in compliance with this subpart no later than 1 year after the date on which the area source became a major source.

(d) You must meet the notific ation requirements in §63.8816 according to the schedule in §63.8816 and in subpart A of this part. Some of the notificati ons must be submitted before you are required to comply with the emission standards in this subpart.

(e) If you have a loop slitter affected source, you must have data on hand beginning on the compliance date specified in paragraph (b) of this section as necessary to demonstra te that your adhesives are not HAP-based. The types of data necessary are described in §§63.8802 and 63.8810.

Emission Limitations

§ 63.8790 What emission limitations must I meet?

(a) You must meet each emission limit in Table 1 to this subpart that applies to you.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 3 of 21 T003-27321-00225

(b) You must meet each operating limit in T able 2 to this subpart that applies to you.

General Compliance Requirements

§ 63.8794 What are my general requirements for complying with this subpart?

(a) For each loop slitter adhesive use affected source, you must be in compliance with the requirements in this subpart at all times.

(b) For each new or reconstructed flame lamination affected source, you must be in compliance with the requirements in this subpart at all times, except during periods of startup, shutdown, and malfunction.

(c) You must always operate and maintain your affect ed source, including air pollution control and monitoring equipment, according to the provisions in §63.6(e)(1)(i).

(d) During the period between the compliance date specified for your new or reconstructed flame lamination affected source in §63.8786, and the date upon which continuous compliance monitoring systems have been installed and verified and any applicable operating limits have been se t, you must maintain a log detailing the operation and maintenance of the process and emissions control equipment.

(e) For each new or reconstructed flame lamination affected source, you must develop a written startup, shutdown, and malfunction plan according to the provisions in §63.6(e)(3).

(f) For each monitoring system required in this section for new or reconstructed flame la mination sources, you must develop and submit for approval a site-specific monitoring pl an that addresses the requir ements in paragraphs (f)(1) through (3) of this section.

(1) Installation of the continuous monitoring system (C MS) sampling probe or other interface at a measurement location relative to each affected process unit such that t he measurement is representative of control of the exhaust emissions ( e.g., on or downstream of the last control device);

(2) Performance and equipment specifications for the sample interface, the pollutant concentration or parametric signal analyzer, and the data collection and reduction system; and

(3) Performance evaluation procedur es and acceptance criteria ( e.g., calibrations).

(g) In your site-specific monitoring plan, you must also ad dress the ongoing procedures specified in paragraphs (g)(1) through (3) of this section.

(1) Ongoing operation and maintenance procedures in accor dance with the general requirements of §§63.8(c)(1), (3), (4)(ii), (7), and (8), and 63.8804;

(2) Ongoing data quality assurance procedures in accord ance with the general requirements of §63.8(d); and

(3) Ongoing recordkeeping and reporting procedures in ac cordance with the general requirements of §63.10(c), (e)(1), and (e)(2)(i).

[68 FR 18070, Apr. 14, 2003, as amended at 71 20470, Apr. 20, 2006]Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 4 of 21 T003-27321-00225

Testing and Initial Compliance Requirements

§ 63.8798 By what date must I conduct performance tests or other initial compliance demonstrations?

(a) For each loop slitter affected source, you must conduc t the initial compliance demonstration by the compliance date that is specified for your source in §63.8786.

(b) For each new or reconstructed flame lamination affect ed source, you must conduct performance tests within 180 calendar days after the compliance date that is specified for your source in §63.8786 and according to the provisions in §63.7(a)(2).

§ 63.8800 What performance tests and other procedures must I use to demonstrate compliance with the emission limit for flame lamination?

(a) You must conduct each performance test in Table 3 to this subpart that applies to you.

(b) Each performance test must be conducted according to the requirements in §63.7(e)(1) and under the specific conditions in Table 3 to this subpart.

(c) You may not conduct performance tests during periods of startup, shutdown, or ma lfunction, as specified in §63.7(e)(1).

(d) You must conduct at least three separate test runs for each performance test required in this section, as specified in §63.7(e)(3). Each test r un must last at least 1 hour.

(e) You must determine the percent reduction of HAP emis sions during the performance test according to paragraphs (e)(1) through (3) of this section.

(1) If you use chlorinated fire retardant foams, determine the percent reduction of HCl to represent HAP emissions from the source. If you do not use chlorinated fire reta rdant foams, determine the pe rcent reduction of HCN to represent HAP emissions from the source.

(2) Calculate the concentration of HAP at the control device inlet and at the c ontrol device outlet using the procedures in the specified test method.

(3) Compare the calculated HAP concentra tion at the control device inlet to the calculated HAP concentration at the control device outlet to determine the percent reduction ov er the period of the performance test, using Equation 1 of this section:

Where:

R=Efficiency of control device, percent.

E inlet,i =HAP concentration of control device in let stream for test run i, mg/dscm.

E outlet,i =HAP concentration of control device out let stream for test run i, mg/dscm.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 5 of 21 T003-27321-00225

n=Number of runs conducted for the performance test.

(f) You must also meet the requirements in paragraphs (f)(1) and (2) of this section.

(1) Conduct the performance tests using foams that are representative of foams typi cally used at your flame lamination affected source. If you use foams containing chlorinated fire retardants, you must conduct the performance tests using these foams.

(2) Establish all applicable operating limit s that correspond to the control system efficiency as described in Table 3 to this subpart.

§ 63.8802 What methods must I use to demonstrate compliance with the emission limitation for loop slitter adhesive use?

(a) Determine the HAP content for each material used. To determine the HAP content for each material used in your foam fabrication operations, y ou must use one of the options in paragraphs (a)(1) through (3) of this section. If you use the option in paragraph (a)(3) of this section, you are subj ect to the provisions of paragraph (a)(4) of this section.

(1) Method 311 (appendix A to 40 CFR part 63). You may use Method 311 for determining the mass fraction of HAP. Use the procedures specified in paragraphs (a)(1)(i) and (ii) of this section when determining HAP content by Method 311.

(i) Include in the HAP total each HAP that is measured to be present at 0.1 percent by mass or more for Occupational Safety and Health Administration (OSHA)-defined carcin ogens as specified in 29 CFR 1910.1200(d)(4) and at 1.0 percent by mass or more for other compounds. For example, if toluene (not an OSHA carcinogen) is measured to be 0.5 percent of the material by mass, you do not need to include it in the HAP total. Ex press the mass fraction of each HAP you measure as a value truncated to four plac es after the decimal point (for example, 0.1234).

(ii) Calculate the total HAP content in the test material by adding up the individual HAP contents and truncating the result to three places after the decimal point (for example, 0.123).

(2) Alternative method. You may use an alternative test method for det ermining mass fraction of HAP if you obtain prior approval by the Administrator. You must follow the pr ocedure in §63.7(f) to submit an alternative test method for approval.

(3) Information from the supplier or manufacturer of the material. You may rely on information other than that generated by the test methods specified in paragraphs (a)( 1) and (2) of this section to determine the mass fraction of HAP according to paragraphs (a)(3)(i) and (ii) of this sect ion. This information may include, but is not limited to, a material safety data sheet (MSDS), a certified product data sheet (CPDS), or a manufacturer's hazardous air pollutant data sheet.

(i) Include in the HAP total each HAP that is present at 0.1 percent by mass or more for OSHA-defined carcinogens as specified in 29 CFR 1910.1200(d)(4) and at 1.0 percent by mass or more for other compounds. For example, if toluene (not an OSHA carcinogen) is 0.5 percent of the ma terial by mass, you do not have to include it in the HAP total.

(ii) If the HAP content is provided by the material supplie r or manufacturer as a range, then you must use the upper limit of the range for determining compliance.

(4) Verification of supplier or manufacturer information. Although you are not required to perform testing to verify the information obtained according to paragraph (a)(3) of this section, the Administrator may require a separate measurement of the total HAP content using the methods spec ified in paragraph (a)(1) or (2) of this section. If this measurement exceeds the total HAP content provided by the material supplier or manufacturer, then you must use the measured HAP content to determine compliance.

(b) [Reserved]Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 6 of 21 T003-27321-00225

§ 63.8806 How do I demonstrate initial compliance with the emission limitations?

(a) You must demonstrate initial compliance with each emissi on limit that applies to you according to Table 4 to this subpart.

(b) You must establish each site-specific operating limit in T able 2 to this subpart that applies to you according to the requirements in §63.8800 and Table 3 to this subpart.

(c) You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.8816(e) through (h).

Continuous Compliance Requirements

§ 63.8810 How do I monitor and collect data to demonstrate continuous compliance?

(a) If you own or operate a loop slitter adhesive use affected source, you must meet the requirements in paragraphs (a)(1) and (2) of this section.

(1) Maintain a list of each adhesive and the manufacturer or supplier of each.

(2) Maintain a record of EPA Method 311 (appendix A to 40 CFR part 63), approved alternative method, or other reasonable means of HAP content determinations indica ting the mass percent of each HAP for each adhesive.

(b) If you own or operate a new or reconstructed flame laminat ion affected source, you must meet the requirements in paragraphs (b)(1) through (3) of this section if you use a scrubber, or paragraph (b)(4) of this section if you use any other control device.

(1) Keep records of the daily average scrubber inlet liquid flow rate.

(2) Keep records of the daily average scrubber effluent pH.

(3) If you use a venturi scrubber, keep records of daily average pressure drop across the venturi.

(4) Keep records of operating parameter values fo r each operating parameter that applies to you.

(c) If you own or operate a new or reconstructed flame laminat ion affected source, you must meet the requirements in paragraphs (c)(1) through (4) of this section.

(1) Except for periods of monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as app licable, calibration checks and required zero and span adju stments), you must monitor continuously (or collect data at all required intervals) at al l times that the affected source is operating. This includes periods of startup, shutdown, and malf unction when the affected source is operating. A monitoring malfunction includes, but is not limited to, any sudden, infrequent, not re asonably preventable failure of the monitoring device to provide valid data. Monitoring failures that are caused by poor maintenance or careless operation are not malfunctions.

(2) In data average calculations and calculations used to report emission or operating levels, you may not use data recorded during monitoring malfunctions, associated repairs, or recorded during required quality assurance or control activities. Nor may such data be used in fulfilling any a pplicable minimum data availability requirement. You must use all the data collected during all other periods in assessing the operation of the contro l device and associated control system.

(3) You must conduct a performance evaluation of each CMS in accordance with your site-specific monitoring plan.

(4) You must operate and maintain the CMS in continuous operation according to the site-specific monitoring plan.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 7 of 21 T003-27321-00225

§ 63.8812 How do I demonstrate continuous compliance with the emission limitations?

(a) You must demonstrate continuous compliance with each emission limit and operating limit in Tables 1 and 2 to this subpart that applies to you according to the methods specified in Table 5 to this subpart.

(b) You must report each instance in which you did not meet each emission limit and each operating limit in Tables 1 and 2 to this subpart that apply to you. For new or recons tructed flame lamination affect ed sources, this includes periods of startup, shutdown, and malf unction. These instances are deviations from the operating limits in this subpart. These deviations must be reported according to the requirements in §63.8818.

(c) [Reserved]

(d) Consistent with §§63.6(e) and 63.7(e)(1), deviations that occur at a new or reconstructed flame lamination affected source during a period of start up, shutdown, or malfunction are not violations if you demonstrate to the Administrator's satisfaction that you we re operating in accordance with §63.6 (e)(1). The Administrator will determine whether deviations that occur at a new or reconstructed fl ame lamination affected source during a period of startup, shutdown, or malfunction are violations, according to the provisions in §63.6(e).

(e) You also must meet the following requirements if yo u are complying with the adhesive use ban for loop slitter adhesive use described in §63.8790(a).

(1) If, after you submit the Notification of Compliance Status, you use an adhesive for which you have not previously verified percent HAP mass using the methods in §63.8802, yo u must verify that each adhesive used in the affected source meets the emission limit, usi ng any of the methods in §63.8802.

(2) You must update the list of all the adhesives used at the affected source.

(3) With the compliance report for the reporting period durin g which you used the new adhes ive, you must submit the updated list of all adhesives and a stat ement certifying that, as purchased, eac h adhesive used at the affected source during the reporting period met the emission limit in Table 1 to this subpart.

[68 FR 18070, Apr. 14, 2003, as amen ded at 71 FR 20470, Apr. 20, 2006]

Notification, Reports, and Records

§ 63.8816 What notifications must I submit and when?

(a) You must submit all of t he notifications in §§63.7(b) a nd (c), 63.8(f), and 63.9(b) thr ough (h) that apply to you.

(b) If you own or operate an existing loop slitter or flame lami nation affected source, submit an initial notification no later than 120 days after April 14, 2003.

(c) If you own or operate a new or reconstructed loop s litter or flame lamination affected source, submit the application for construction or reconstruction required by §63.9(b)(1)(iii) in lieu of the initial not ification.

(d) If you own or operate a new or reconstructed flame laminat ion affected source, submit a notification of intent to conduct a performance test at least 60 calendar days before the performance test is scheduled to begin, as required in §63.7(b)(1).

(e) If you own or operate a loop slitter affected source, su bmit a Notification of Compliance Status according to §63.9(h)(2)(ii) within 60 days of the co mpliance date specified in §63.8786.

(f) If you own or operate a new or reconstructed flame laminat ion affected source, submit a Notification of Compliance Status according to §63.9(h)(2)(ii) t hat includes the results of the performa nce test conducted according to theFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 8 of 21 T003-27321-00225

requirements in Table 3 to this subpart. You must submit the notification before the cl ose of business on the 60th calendar day following the completion of the performance test according to §63.10(d)(2).

(g) For each new or reconstructed flame lamination affected s ource, the Notification of Comp liance Status must also include the information in paragraphs (g )(1) and (2) that applies to you.

(1) The operating parameter value averaged over the full period of the performance test (for example, average pH).

(2) The operating parameter range within which HAP emissi ons are reduced to the level corresponding to meeting the applicable emission limits in Table 1 to this subpart.

(h) For each loop slitter adhesive use affected source, the No tification of Compliance Status must also include the information listed in paragraphs (h)(1) and (2) of this section.

(1) A list of each adhesive used at the affected source, it s HAP content (percent by mass), and the manufacturer or supplier of each.

(2) A statement certifying that each adhe sive that was used at the affected sour ce during the reporting period met the emission limit in Table 1 to this subpart.

§ 63.8818 What reports must I submit and when?

(a) You must submit each report in Table 6 to this subpart that applies to you.

(b) Unless the Administrator has approved a different schedule for submission of reports under §63.10(a), you must submit each compliance report for new or reconstructed flam e lamination affected sources semiannually according to paragraphs (b)(1) through (4) of this section.

(1) The first compliance report must cover the period beginn ing on the compliance date that is specified for your affected source in §63.8786 and ending on June 30 or Decem ber 31, whichever date is the first date following the end of the first calendar half after the compliance date that is specified for your source in §63.8786.

(2) The first compliance report must be postmarked or delive red no later than July 31 or January 31, whichever date follows the end of the first calendar half after the complia nce date that is specified fo r your affected source in §63.8786.

(3) Each subsequent compliance report must cover the se miannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31.

(4) Each subsequent compliance report must be postmarke d or delivered no later than July 31 or January 31, whichever date is the first date following the end of the semiannual reporting period.

(c) For each loop slitter adhesive use affected source, y ou may submit annual compliance reports in place of semiannual reports.

(d) For each affected source that is subject to permitting regulations pursuant to 40 CFR part 70 or 40 CFR part 71, and if the permitting authority has established dates for submitting semiannual reports pursuant to 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A), you may subm it the first and subsequent compliance reports according to the dates the permitting authority has established instead of according to the dates in paragraphs (b)(1) through (4) of this section.

(e) The compliance report must contain the information in paragraphs (e)(1) through (5) of this section.

(1) Company name and address.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 9 of 21 T003-27321-00225

(2) Statement by a responsible official with that official's name, title, and signature, cert ifying the truth, accuracy and completeness of the c ontent of the report.

(3) Date of report and beginning and en ding dates of the reporting period.

(4) If there are no deviations from any em ission limitations (emission limit or oper ating limit) that applies to you, a statement that there were no deviations from the emission limitations during the reporting period.

(5) For each deviation from an emission limitation that o ccurs, the compliance report must contain the information specified in paragraphs (e)(5)(i) through (iii) of this section.

(i) The total operating time of each affected source during the reporting period.

(ii) Information on the number, duratio n, and cause of deviations (including unknown cause, if applicable), as applicable, and the corrective action taken.

(iii) Information on the number, duration, and cause for continuous parameter monitoring system (CPMS) downtime incidents, if applicable, other than downtime associated with zero and span and other daily calibration checks.

(f) The compliance report for a new or reconstructed flame lamination affected source must also contain the following information in paragraphs (f)(1) th rough (3) of this section.

(1) If you had a startup, shutdown or malfunction at your new or reconstruc ted flame lamination affected source during the reporting period and you took actions consistent with your startup, shutdown, and malfunction plan, the compliance report must include t he information in §63.10(d)(5)(i).

(2) If there were no periods during which the CPMS was ou t-of-control in accordance with the monitoring plan, a statement that there were no periods during which the CPMS was out-of-control during the reporting period.

(3) If there were periods during which the CPMS was out-of -control in accordance with the monitoring plan, the date, time, and duration of each out-of-control period.

(g) The compliance report for a loop slitter adhesive use a ffected source must also contain the following information in paragraphs (g)(1) and (2) of this section.

(1) For each annual reporting period during which you use an ad hesive that was not included in the list submitted with the Notification of Compliance Status in §63.8816(h) (1), an updated list of all adhesives used at the affected source.

(2) A statement certifying that each adhe sive that was used at the affected sour ce during the reporting period met the emission limit in Table 1 to this subpart.

(h) Each affected source that has obtained a title V operating permit pursuant to 40 CFR part 70 or 40 CFR part 71 must report all deviations as defined in this subpart in the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A). If an affected s ource submits a compliance report pursuant to Table 6 to this subpart along with, or as part of, the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A), and the compliance report includes al l required information concerning deviations from any emission limitation (including any operating limit) in th is subpart, submission of the compliance report shall be deemed to satisfy any obligation to report the same devia tions in the semiannual monitoring report. However, submission of a compliance report shall not otherwise affect any obligation the affected source may have to report deviations from permit requirements to the permit authority.

(i) For each startup, shutdown, or malfunction during t he reporting period where the source does not meet the emission limitations set out in §63.8790 that occurs at a new or reconstructed flame lamination affected source and that is not consistent with your startup, shutdown, and malfunction plan, you must submit an immediate startup, shutdown and malfunction report.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 10 of 21 T003-27321-00225

(1) An initial report containing a description of the actions taken for the event must be submitted by fax or telephone within 2 working days after starting actions inconsistent with the plan.

(2) A followup report containing the information listed in §63. 10(d)(5)(ii) must be submitted within 7 working days after the end of the event unless you have ma de alternative reporting arrangements with the permitting authority.

§ 63.8820 What records must I keep?

(a) You must keep a copy of each notification and report that you submit to comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status that you submitted, according to the requirements in §63.10(b)(2)(xiv).

(b) For each new or reconstructed flame lamination affect ed source, you must also keep the following records specified in paragraphs (b)(1) th rough (4) of this section.

(1) The records in §63.6(e)(3)(iii) through (v) related to startup, shutdown, and malfunction.

(2) Records of performance tests, as required in §63.10(b)(2)(viii).

(3) Records of operating parameter values.

(4) Records of the date and time that each deviation started and stopped and whether the deviation occurred during a period of startup, shutdown, or ma lfunction or during another period.

(c) For each loop slitter adhesive use affected source, you must keep the following records specified in paragraphs (c)(1) and (2) of this section.

(1) A list of each adhesive and the manufacturer or supplier of each.

(2) A record of EPA Method 311 (appendix A to 40 CFR part 63), approved alternative met hod, or other reasonable means of determining the mass percent of total HAP for each adhesive used at the affected source.

§ 63.8822 In what form and how long must I keep my records?

(a) Your records must be in a form suitable and readily av ailable for expeditious review, according to §63.10(b)(1).

(b) As specified in §63.10(b)(1), you must keep each re cord for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record.

(c) You must keep each record on site for at least 2 years after the date of eac h occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1). Y ou can keep the records offsite for the remaining 3 years.

Other Requirements and Information

§ 63.8826 What parts of the General Provisions apply to me?

Table 7 to this subpart shows which sections of the G eneral Provisions in §§63.1 through 63.15 apply to you.

§ 63.8828 Who implements and enforces this subpart?

(a) This subpart can be implemented and enforced by us, the U.S. Environmental Protection Agency (U.S. EPA), or a delegated authority such as your State, local, or tribal agency. If the U.S. EPA Administrator has delegated authority to your State, local, or tribal agency, then that agency, in addition to the U.S. EPA, has the authority to implement andFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 11 of 21 T003-27321-00225

enforce this subpart. You should contact your U.S. EPA Regional Office to find out if implementation an d enforcement of this subpart is delegated to your State, local, or tribal agency.

(b) In delegating implementation and enforcement authority of this subpart to a State, local, or tribal agency under 40 CFR part 63, subpart E, the authorities contained in paragraph (c) of this se ction are retained by the Administrator of U.S. EPA and are not transferred to the State, local, or tribal agency.

(c) The authorities in paragraphs (c)(1) through (4) that cannot be delegated to State, local, or tribal agencies are as follows:

(1) Approval of alternatives to requirements in §§63.8780, 63.8782, 63.8 784, 63.8786, and 63.8790.

(2) Approval of major alternatives to test methods under §63.7(e)(2)(ii) and (f) and as defined in §63.90.

(3) Approval of major alternatives to moni toring under §63.8(f) and as defined in §63.90.

(4) Approval of major alternatives to recordkeepi ng and reporting under §63.10(f) and as defined in §63.90.

§ 63.8830 What definitions apply to this subpart?

Terms used in this subpart are defined in the CAA, in 40 CFR 63.2, and in this section as follows:

Adhesive means any chemical substance that is applied for the purpose of bonding foam to f oam, foam to fabric, or foam to any other substrate, other than by mechanical means. Products used on humans and animals, adhesive tape, contact paper, or any ot her product with an adhesive incorporated on to it in an inert substrate shall not be considered adhesives under this subpart.

Deviation means any instance in which an affected source subject to this subpart, or an owner or operator of such a

source:

(1) Fails to meet any requirement or obligation established by this subpart, including but not limited to any emission limitation (including an y operating limit); or

(2) Fails to meet any term or condition that is adopted to implement an applicable requirement in this subpart and that is included in the operating permit for any affe cted source required to obtain such a permit; or

(3) Fails to meet any emission limitation (including any oper ating limit) in this subpart during startup, shutdown, or malfunction, regardless of whether or not su ch failure is permitted by this subpart.

Emission limitation means any emission limit or operating limit.

Flame lamination means the process of bonding flexible foam to one or more layers of material by heating the foam surface with an open flame.

Flame lamination line means the flame laminator and associated rollers.

HAP-based adhesive means an adhesive containing 5 percent (by weight ) or more of HAP, according to EPA Method 311 (appendix A to 40 CFR part 63) or another approved alternative.

Loop slitter means a machine used to create thin sh eets of foam from the large blo cks of foam or “buns” created at a slabstock flexible polyurethane foam production plant.

Research and development process means a laboratory or pilot plant operation whose primary purpose is to conduct research and development into new processes and products where the operations are under the close supervision ofFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 12 of 21 T003-27321-00225

technically trained personnel, and which is not engaged in t he manufacture of products for commercial sale, except in

a de minimis manner.

Responsible official means responsible official as defined in 40 CFR 70.2.

Table 1 to Subpart MMMMM of Part 63—Emission Limits

As stated in §63.8790(a), you mu st comply with the emission lim its in the following table:



### For . . . You must . . .
1. Each existing, new, or reconstructed loop slitter adhesive use affected source Not use any HAP-based adhesives.

2. Each new or reconstructed flame lamination affected source Reduce HAP emissions by 90 percent.

3. Each existing flame lamination affected sources There are no emission limits for existing flame lamination sources. However, you must s ubmit an initia l notification per §63.8816(b).

Table 2 to Subpart MMMMM of Part 63—Operating Limits for New or Reconstructed Flame Lamination Affected Sources

As stated in §63.8790(b), you mu st comply with the operating lim its in the following table:



### For each . . . You must . . .

1. Scrubber a. Maintain the daily aver age scrubber inlet liquid flow rate above the minimum value estab lished during the performance

test.
b. Maintain the daily average scrubber effluent pH within the operating range value establishe d during the performance test.

c. If you use a venturi scrubber, maintain the daily average pressure drop across the vent uri within the operating range value established during the performance test.

2. Other type of control device to which flame lamination emissions are ducted Maintain your operating para meter(s) within the ranges established during the performan ce test and according to your monitoring plan.

Table 3 to Subpart MMMMM of Part 63—Performance Test Requirements for New or Reconstructed Flame Lamination Affected Sources

As stated in §63.8800, you must comply with the requirements for performance tests for new or reconstructed flame lamination affected sources in the following table using the requirements in rows 1 throu gh 5 of the table if you are measuring HCl and using a scrubber, row 6 if you are m easuring HCN and using a scrubber, and row 7 if you are using any other control device.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 13 of 21 T003-27321-00225



### For each new or reconstructed flame lamination affected source, you must . . . Using . . . According to the following requirements . . .
1. Select sampling port's location and the number of traverse ports Method 1 or 1A in appendix A to part 60 of this chapter Sampling sites must be located at the inlet and outlet of the scrubber and prior to any releases to the atmosphere.
2. Determine velocity Method 2, 2A, 2C, 2D, 2F, or 2G in appendix A to part 60 of this chapter.
3. Determine gas molecular weight Not applicable Assume a mol ecular weight of 29 (after moisture correction) for calculation
purposes.

4. Measure moisture content of the stack gas Method 4 in appendix A to part 60 of this chapter.

5. Measure HCl concentration if you use chlorinated fire retardants in the laminated foam a. Method 26A in appendix A to part 60 of this chapter i. Measure total HCl emissions and determine the reduction efficiency of the control device using Method 26A. ii. Collect scrubber liquid flow rate, scrubber effluent pH , and pressure drop (pressure drop data only required for venturi scrubbers) every 15 minutes during the entire duration of each 1-hour test run, and determine the average scrubber liquid flow rate, scrubber effluent pH, and pressure drop (pressure drop data only required for Venturi scrubbers) over the period of the performance test by computing the average of all of the 15-minute readings.

6. Measure HCN concentration if you do not use chlorinated fire retardants in the laminated foam a. A method approved by the Administrator i. Conduct the performance test according to the site-specific test plan submitted according to §63.7(c)(2)(i). Measure total HCN emissions and determine the reduction efficiency of the control device. Any performance test which measures HCN concentrations must be submitted for the administrator's approval prior to testing. You must use EPA Method 301 (40 CFR part 63, Appendix A) to validate your method.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 14 of 21 T003-27321-00225



### ii. Collect scrubber liquid flow rate, scrubber effluent pH , and pressure drop (pressure drop data only required for venturi scrubbers) every 15 minutes during the entire duration of each 1-hour test run, and determine the average scrubber liquid flow rate, scrubber effluent pH, and pressure drop (pressure drop data only required for venturi scrubbers) over the period of the performance test by computing the average of all of the 15-minute readings.

7. Determine control device efficiency and establish operating parameter limits with which you will demonstrate continuous compliance with the emission limit that applies to the source if you use any control device other than a scrubber a. EPA-approved methods and data from the continuous parameter monitoring system i. Conduct the performance test according to the site-specific test plan submitted according to §63.7(c)(2)(i). ii. Collect operating parameter data as specified in the site-specific test plan.

Table 4 to Subpart MMMMM of Part 63—Initial Compliance With Emission Limits

As stated in §63.8806, you must comply with the requirements to demonstrate in itial compliance with the applicable emission limits in the following table:



### For . . . For the following emission limit . .

. You have demonstrated initial compliance if . . .

1. Each new, reconstructed, or existing loop slitter adhesive use affected source Eliminate use of HAP-based adhesives You do not use HAP-based adhesives.

2. Each new or reconstructed flame lamination affected source using a scrubber Reduce HAP emissions by 90 percent The average HAP emissions, measured over the period of the performance test(s), are reduced by 90 percent.

3. Each new or reconstructed flame lamination affected source using any other control device emissions by Reduce HAP emissions by 90 percent The average HAP emissions, measured over the period of the performance test(s), are reduced by 90 percent.

Table 5 to Subpart MMMMM of Part 63—Continuous Compliance With Emission Limits and Operating LimitsFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 15 of 21 T003-27321-00225

As stated in §63.8812(a), you must comply with the requirements to demonstra te continuous compliance with the applicable emission limits or operating limits in the following table:



### For . . . For the following emission limits or operating limits . . . You must demonstrate continuous compliance by . . .

1. Each new, reconstructed, or existing loop slitter affected source Eliminate use of HAP-based adhesi ves Not using HAP-based adhesives.

2. Each new or reconstructed flame lamination affected source using a scrubber a. Maintain the daily average scrubber inlet liquid flow rate above the minimum value established during the performance b. Maintain the daily average scrubber effluent pH within the operating range established during the performance test c. Maintain the daily average pressure drop across the venturi within the operating range established during the performance test. If you use another type of scrubber ( e.g., packed bed or spray tower scrubber), monitoring pressure drop is not required i. Collecting the scrubber inlet liquid flow rate and effluent pH monitoring data according to §63.8804(a) through (c). ii. Reducing the data to 1-hour and daily block averages according to the requirements in §63.8804(a). iii. Maintaining each daily average scrubber inlet liquid flow rate above the minimum value established during the performance test. iv. Maintaining the daily average scrubber effluent pH within the operating range established during the performance test. v. If you use a venturi scrubber, maintaining the daily average pressure drop across the venturi within the operating range established during the performance test.

3. Each new or reconstructed flame lamination affected source using any other control device a. Maintain the daily average operating parameters above the minimum value established during the performance test, or within the range established during the performance test , as applicable i. Collected the operating parameter data according to the site-specific test plan. ii. Reducing the data to one-hour averages according to the requirements in §63.8804(a). iii. Maintaining the daily average during the rate above the minimum value established during the performance test, or within the range established during the performance test, asFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 16 of 21 T003-27321-00225



### applicable.

Table 6 to Subpart MMMMM of Part 63—Requirements for Reports

As stated in §63.8818(a), you must subm it a compliance report that includes the information in §63.8818(e) through (g) as well as the information in the following table. Rows 1 and 3 of the following table apply to loop slitter affected sources. Rows 1 through 5 apply to flame lamination affected sources. You must also subm it startup, shutdown, and malfunction reports according to the requirements in the foll owing table if you own or operate a new or reconstructed flame lamination affected source.



### If . . . Then you must submit a report or statement that . . .

1. There are no deviations from any emission limitations that apply to you There were no deviations from the emission limitations during the reporting period.

2. There were no periods during which the operating parameter monitoring systems were out-of-c ontrol in accordance with the monitoring plan There were no periods duringwhich the CPMS were out-ofcontrol during the reporting period.

3. There was a deviation from any emission limitation during the reporting period Contains the information in §63.8818(e)(5).

4. There were periods during which the operating parameter monitoring systems were out-of-control in information in accordance with the monitoring plan Contains the information in §63.8818(f)(3).

5. There was a startup, shutdown, or malfunction where the source did not meet the emission limitations set out in §63.8790 at a new or reconstructed fl ame lamination affected source during the reporting period that is not consistent with your startup, shutdown, and malfunction plan. Contains the information in §63.8818(i).

Table 7 to Subpart MMMMM of Part 63—Applicabi lity of General Provisions to Subpart MMMMM

As stated in §63.8826, you must comp ly with the applicable General Provis ions requirements according to the following table:



### Citation Requirement Applies to subpart MMMMM Explanation
§63.1 Initial applicability determination; applicability after standard established; permit requirements; extensions; notifications Yes.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 17 of 21 T003-27321-00225



### §63.2 Definitions Yes Additional definitions are found in §63.8830.

§63.3 Units and abbreviations Yes.
§63.4 Prohibited activities; compliance date; circumvention, severability Yes.

§63.5 Construction/reconstruction applicability; applications; approvals Yes.

§63.6(a) Compliance with standards andmaintenance requirementsapplicability Yes.

§63.6(b)(1)–(4) Compliance dates for new or reconstructed sources Yes §63.8786 specifies compliance dates.

§63.6(b)(5) Notification if commenced construction or reconstruction after proposal Yes.

§63.6(b)(6) [Reserved] Yes.
§63.6(b)(7) Compliance dates for new or reconstructed area sources that become major Yes §63.8786 specifies compliance dates.

§63.6(c)(1)–(2) Complian ce dates for existing

sources Yes §63.8786 specifies compliance dates.

§63.6(c)(3)–(4) [Reserved] Yes.
§63.6(c)(5) Compliance dates for existing area sources that become major Yes §63.8786 specifies compliance dates.

§63.6(d) [Reserved] Yes.
§63.6(e)(1) Operation and maintenance requirements Yes.

§63.6(e)(2) [Reserved] Yes.
§63.6(e)(3) Startup, shutdown, and malfunction plans Yes Only applies to new or reconstructed flame lamination affected sources.
§63.6(f)(1) Compliance except during SSM Yes Only applies to new or reconstructed flame lamination affected sources.
§63.6(f)(2)–(3) Methods for determining Yes.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 18 of 21 T003-27321-00225



### compliance
§63.6(g) Use of an alternative nonopacity emission standard Yes.

§63.6(h) Compliance with opacity/visible emission standards No Subpart MMMMM does not specify opacity or visible emission standards.
§63.6(i) Extension of compliance with emission standards Yes.

§63.6(j) Presidential compliance exemption Yes.

§63.7(a)(1)–(2) Performance test da tes Yes Except for loop slitter affected sources as specified in §63.8798(a).

§63.7(a)(3) Administrator's section 114 authority to require a performance

test Yes.

§63.7(b) Notification of performance test and rescheduling Yes.

§63.7(c) Quality assurance program and site-specific test plans Yes.

§63.7(d) Performance testi ng facilities Yes.
§63.7(e)(1) Conditions for conducting performance tests Yes.

§63.7(f) Use of an alternat ive test method Yes.
§63.7(g) Performance test data analysis, recordkeeping, and reporting Yes.

§63.7(h) Waiver of performance tests Yes.
§63.8(a)(1)–(2) Applicability of monitoring requirements Yes Unless otherwise specified, all of §63.8 applies only to new or reconstructed flame lamination sources. Additional monitoring requirements for these sources are found in §§63.8794(f) and (g) and 63.8804.

§63.8(a)(3) [Reserved] Yes.
§63.8(a)(4) Monitoring with flares No Subpart MMMMM does notFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 19 of 21 T003-27321-00225



### refer directly or indirectly to §63.11.
§63.8(b) Conduct of monitoring and procedures when there are multiple effluents and multiple monitoring systems Yes.

§63.8(c)(1)–(3) Continuous monitoring system (CMS) operation and maintenance Yes Applies as modified by §63.8794(f) and (g).
§63.8(c)(4) Continuous monitoring system requirements during breakdown, out-of-control, repair, maintenance, and high-level calibration drifts Yes Applies as modified by §63.8794(g).

§63.8(c)(5) Continuous opacity monitoring system (COMS) minimum procedures No Subpart MMMMM does not have opacity or visible emission standards.
§63.8(c)(6) Zero and high level calibration checks Yes Applies as modified by §63.8794(f).
§63.8(c)(7)–(8) Out-of-control periods, including reporting Yes.

§63.8(d)–(e) Quality control program and CMS performance evaluation No Applies as modified by §63.8794(f) and (g).
§63.8(f)(1)–(5) Use of an alternative monitoring method Yes.

§63.8(f)(6) Alternative to rela tive accuracy test No Only applies to sources that use continuous emissions monitoring systems (CEMS).
§63.8(g) Data reduction Yes Applies as modified by §63.8794(g).
§63.9(a) Notification requirements— applicability Yes.

§63.9(b) Initial notifi cations Yes Except §63.8816(c) requires new or reconstructed affected sources to submit the application for construction or reconstruction required by §63.9(b)(1)(iii) in lieu of the initial notification.
§63.9(c) Request for compliance extension Yes.Foamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 20 of 21 T003-27321-00225



### §63.9(d) Notification that a new source is subject to special compliance requirements Yes.

§63.9(e) Notification of pe rformance test Yes.

§63.9(f) Notification of visible emissions/opacity test No Subpart MMMMM does not have opacity or visible emission standards.
§63.9(g)(1) Additional CMS notifications— date of CMS performance evaluation Yes.

§63.9(g)(2) Use of COMS data No Subpart MMMMM does not require the use of COMS.
§63.9(g)(3) Alternative to relative accuracy testing No Applies only to sources with CEMS.

§63.9(h) Notification of co mpliance status Yes.
§63.9(i) Adjustment of submittal deadlines Yes.
§63.9(j) Change in previous information Yes.
§63.10(a) Recordkeeping/reporting applicability Yes.

§63.10(b)(1) General recordkeeping requirements Yes §§63.8820 and 63.8822 specify additional recordkeeping requirements.

§63.10(b)(2)(i)– (xi) Records related to startup, shutdown, and malfunction periods and CMS Yes Only applies to new or reconstructed flame lamination affected sources.

§63.10(b)(2)(xii) Records when under waiver Yes.
§63.10(b)(2)(xiii) Records when using alternative to relative accuracy test No Applies only to sources with CEMS.
§63.10(b)(2)(xiv) All documentation supporting initial notification and notification of compliance status Yes

§63.10(b)(3) Recordkeeping requirements for applicability determinations Yes.

§63.10(c) Additional recordkeeping requirements for sources with CMS Yes Applies as modified by §63.8794(g).
§63.10(d)(1) General reporting require ments Yes §63.8818 specifies additionalFoamex Innovations Operating Company Fort Wayne, Indiana Permit Reviewer: Stephanie Wilkerson Attachment B 40 CFR 63, Subpart MMMMM Page 21 of 21 T003-27321-00225



### reporting requirements.

§63.10(d)(2) Performance test results Yes
§63.10(d)(3) Opacity or visible emissions observations No Subpart MMMMM does not specify opacity or visible emission standards.
§63.10(d)(4) Progress reports for sources with compliance extensions Yes.

§63.10(d)(5) Startup, shutdown, and malfunction reports Yes Only applies to new or reconstructed flame lamination affected sources.
§63.10(e)(1) Additional CMS reports—gene ral Yes Applies as modified by §63.8794(g).
§63.10(e)(2)(i) Results of CMS performance evaluations Yes Applies as modified by §63.8794(g).
§63.10(e)(2) Results of continuous opacity monitoring systems performance evaluations No Subpart MMMMM does require the use of COMS.

§63.10(e)(3) Excess emissions/CMS performance reports Yes Only applies to new or reconstructed flame lamination affected sources.
§63.10(e)(4) Continuous opacity monitoring system data reports No Subpart MMMMM does not require the use of COMS.
§63.10(f) Recordkeeping/reporting waiver Yes
§63.11. Control device requirements— applicability No Facilities su bject to subpart MMMMM do not use flares as control devices.
§63.12 State authority and delegations Yes §63.8828 lists those sections of subparts MMMMM and A that are not delegated.

§63.13 Addresses Yes.
§63.14 Incorporation by reference Yes Subpart MMMMM does not incorporate any material by reference.
§63.15 Availability of information/confidentiality. Yes.

## Indiana Department of Environmental Management Office of Air Quality

Technical Support Document (TSD) for a Part 70 Significant Source and Significant Permit Modification

Source Description and Location

Source Name: Foamex Innovations Operating Company Source Location: 3005 Commercial Road, Fort Wayne, Indiana 46809 County: Allen SIC Code: 3086 Operation Permit No.: 003-27321-00225 Operation Permit Issuance Date: July 23, 2009 Significant Source Modification No.: 003-30166-00225 Significant Permit Modification No.: 003-30247-00225 Permit Reviewer: Anne-Marie C. Hart

Existing Approvals

The source was issued Part 70 Operating Permit Renewal No. 003-27321-00225 on July 23, 2009. The source has since received the following approvals:

(a) Significant Source Modification No . 003-29260-00225, issued on November 8, 2010; and

(b) Significant Permit Modification No. 003-29273-00225

, issued on November 30, 2010.

County Attainment Status

The source is located in Allen County.

Pollutant Designation SO 2 Better than national standards. CO Unclassifiable or attainment effective November 15, 1990. O 3 Attainment effective February 12, 2007, for the Fort Wayne area, including Allen County, for the 8-hour ozone standard. 1

PM 10 Unclassifiable effective November 15, 1990. NO 2 Cannot be classified or better than national standards. Pb Not designated.

1 Unclassifiable or attainment effective October 18, 2000, for the 1-hour ozone standard which was revoked effective June 15, 2005. Unclassifiable or attainment effective April 5, 2005, for PM 2.5

.
(a) Ozone Standards Volatile organic compounds (VOC) and nitrogen oxides (NO X ) are regulated under the Clean Air Act (CAA) for the purposes of attaining and maintaining the National Ambient Air Quality Standards (NAAQS) for ozone. Therefore, VOC and NO X emissions are considered when evaluating the rule applicab ility relating to ozone. Allen County has been designated as attainment or unclassifiable for ozone. Therefore, VOC and NO X emissions were reviewed pursuant to the r equirements for 326 IAC 2-2 (Prevention of Significant Deterioration (PSD)).Foamex Innovations Operati ng Company Page 2 of 11 Fort Wayne, Indiana TSD for Signific ant Source Modification No.: 003-30166-00225 Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225

(b) PM 2.5 Allen County has been classified as attainment for PM 2.5 . On May 8, 2008, U.S. EPA promulgated the requirements for Prevention of Significant Deterioration (PSD) for PM 2.5 emissions. These rules became effective on July 15, 2008. Indiana has three (3) years from the publication of these rules to revise its PSD rules, 326 IAC 2-2, to include those requirements. The May 8, 2008 rule revisions require IDEM to regulate PM 10 emissions as a surrogate for PM 2.5 emissions until 326 IAC 2-2 is revised.

(c) Other Criteria Pollutants Allen County has been classified as attainment or unclassifiable in Indiana for all other regulated criteria pollutants

. Therefore, these emissions were reviewed pursuant to the requirements for 326 IAC 2-2 Prevention of Significant Deterioration (PSD)).

Fugitive Emissions

Since this type of operation is not one (1) of the twenty-eight (28) listed source categories under 326 IAC 2-2 or 326 IAC 2-7, and there is no applicable New Source Performance Standard that was in effect on August 7, 1980, fugitive emissi ons are not counted toward the determination of PSD and Part 70 Permit applicability.

Source Status

The table below summarizes the potential to emit of the entire source, prior to the proposed modification, after consideration of all enforc eable limits established in the effective permits:

Pollutant Emissions (ton/yr)

PM 44.61
PM 10 45.79
PM 2.5 45.79
SO 2 64.91
VOC Greater than 250
CO 78.52
NO X 21.59 Single HAP Greater than 10
Total HAP Greater than 25

(a) This existing source is a major stationary source, under 326 IAC 2-2 (PSD), because a regulated pollutant is emitted at a rate of 250 tons per year or more, and it is not one (1) of the twenty-eight (28) listed source categories, as specified in 326 IAC 2-2-1(gg)(1).

(b) This existing source is a major source of HAPs, as defined in 40 CFR 63.2, because HAP emissions are greater than ten (10) tons per year for a single HAP and greater than twenty-five (25) tons per year for a combination of HAPs. Therefore, this source is a major source under Section 112 of the Clean Air ACT (CAA).

(c) These emissions are based upon Signific ant Source Modification No. 003-29260-00225, issed November 8, 2010, and Part 70 Operating Permit Renewal No. 003-27321-00225, issued July 23, 2009.

Description of Proposed Modification

The Office of Air Quality (OAQ) has reviewed a modification application, submitted by Foamex Innovations Operating Company on January 31, 2011, relating to the construction and operation of a new thermal reticulation unit, identified as TRU-03. Also, the emission factors used toFoamex Innovations Operati ng Company Page 3 of 11 Fort Wayne, Indiana TSD for Signific ant Source Modification No.: 003-30166-00225 Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225

calculate potential emissions from the felt presses, identified as FPC, FPD and FPE, were incorrect. The potential emissions calculati ons have been corrected in Appendix A: Emissions Calculations. The following is a description of the proposed emission unit:

(a) One (1) thermal reticulation unit, approved in 2011 for construction, identified as TRU-03, with a maximum capacity of 58,800 cycles per year, uncontrolled, and exhausting to eight (8) stacks.

Enforcement Issues

There are no pending enforcement actions related to this modification.

Emission Calculations

See Appendix A of this Technical Support Docu ment for detailed emission calculations.

Permit Level Determination – Part 70

Pursuant to 326 IAC 2-1.1-1(16), Potential to Emit is defined as “the maximum capacity of a stationary source or emission unit to emit any air pollutant under its physical and operational design. Any physical or operational limitation on t he capacity of a source to emit an air pollutant, including air pollution control equipment and restri ctions on hours of operation or type or amount of material combusted, stored, or processed shall be treated as part of its design if the limitation is enforceable by the U. S. EPA, IDEM, or the appropriate local air pollution control agency.”

The following table is used to determine the appropriate permit level under 326 IAC 2-7-10.5. This table reflects the PTE before controls. Contro l equipment is not considered federally enforceable until it has been required in a federally enforceable permit.

Increase in PTE Before Controls of the Modification

Pollutant Potential To Emit (ton/yr)

PM 0.00
PM 10 0.00
PM 2.5 0.00
SO 2 0.00
VOC 25.24
CO 13.77
NO X 0.00 Single HAP (Benzene) 9.11
Total HAPs 11.76

This source modification is subject to 326 IAC 2-7-10.5(f)(4)(D), because the proposed modification has the potential to emit greater than or equal to twenty-five (25) tons per year of VOC. Additionally, the modification will be incorporated into the Part 70 Operating Permit through a significant permit modification issued pur suant to 326 IAC 2-7-12(d)(1), because the modification requires a case-by-case determination of an emission limitation.

Permit Level Determination – PSD

The table below summarizes the potential to emit, re flecting all limits, of the emission units. Any control equipment is considered federally enfor ceable only after issuance of this Part 70 source/permit modification, and only to the extent that the effect of the control equipment is made practically enforceable in the permit.Foamex Innovations Operati ng Company Page 4 of 11 Fort Wayne, Indiana TSD for Signific ant Source Modification No.: 003-30166-00225 Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225

Potential to Emit (ton/yr)

Process / Emission Unit PM PM 10 SO 2 VOC CO NO X New Thermal Reticulation Unit (TRU-03) 0.00 0.00 0.00 25.24 13.77 0.00

Total for Modification 0.00 0.00 0.00 25.24 13.77 0.00 Significant Level 25 15 40 40 100 40

This modification to an existing major stationar y source is not major because the emissions increase is less than the PSD significant levels. Therefore, pursuant to 326 IAC 2-2, the PSD requirements do not apply.

Federal Rule Applicability Determination

NSPS:

(a) There are no New Source Performance Standards (NSPS)(326 IAC 12 and 40 CFR Part 60) applicable to this proposed thermal reticulation unit.

NESHAP:

(b) There are no National Emission Standards for Hazardous Air Pollutants (NESHAPs) applicable to this proposed thermal reticulation unit.

(1) The National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Flexible Polyurethane Foam Production, Subpart III, are not included in the permit for the proposed thermal reticulation unit, identified as TRU-03, because the thermal reticulation process is a post-manufacturing process.

(2) The National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Flexible Polyurethane Foam Fabrication Operations, Subpart MMMMM, are not included in the permit for the new thermal reticulation unit, identified as TRU-03, because the proposed thermal reticulation process is not a loop slitter or a flame lamination line as defined in 40 CFR 63.8830.

(c) Pursuant to 40 CFR 64.2, Compliance Assu rance Monitoring (CAM) is applicable to each new or modified pollutant-specific emission unit that meets the following criteria:

(1) has a potential to emit before controls equal to or greater than the Part 70 major source threshold for the pollutant involved;

(2) is subject to an emission limitation or standard for that pollutant; and

(3) uses a control device, as defined in 40 CFR 64.1, to comply with that emission limitation or standard.

The following table is used to identify the applicability of each of the criteria, under 40 CFR 64.1, to each new or modified emission unit involved:Foamex Innovations Operati ng Company Page 5 of 11 Fort Wayne, Indiana TSD for Signific ant Source Modification No.: 003-30166-00225 Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225

CAM Applicability Analysis
Emission Unit Control Device Used Emission Limitation (Y/N) Uncontrolled PTE (ton/yr) Controlled PTE (ton/yr) Part 70 Major Source Threshold

(ton/yr) CAM Applicable (Y/N) Large Unit (Y/N)

Thermal ReticulationUnit (TRU03)/VOC N Y 25.24 25.24 100 N N

Thermal ReticulationUnit (TRU03)/CO N N 13.77 13.77 100 N N

Based on this evaluation, the requirements of 40 CFR Part 64 (CAM) are not applicable to the new thermal reticulation unit as part of this modification.

State Rule Applicability Determination

326 IAC 2-2 (PSD) PSD applicability is discussed under the Permit Level Determination – PSD section.

326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants (HAP)) The operation of the one (1) proposed thermal reticulation unit identified as TRU-03 will emit less than ten (10) tons per year for a single HAP and less than twenty-five (25) tons per year for a combination of HAPs. Therefore, 326 IAC 2-4.1 does not apply.

326 IAC 8-1-6 (New Facilities; General Reduction Requirements) The proposed unit has potential VOC emissions greater than twenty-five (25) tons per year and is not otherwise regulated by another Article 8 rule, 326 IAC 20-48, or 326 IAC 20-56. Therefore, pursuant to 326 IAC 8-1-6, the new thermal reti culation unit shall reduce VOC emissions using best available control technology (BACT). The Best Available Control Technology (BACT) for the Thermal Reticulation Unit, identified as TRU-03 shall be the following:

(1) Maintain the thermal reticulation unit in good working order; and

(2) Utilize quality procedures to minimize VOC emissions from this unit. The work practices to be performed on the thermal reticulation unit include the following inspection and preventive maintenance procedures:

(A) The following preventive maintenance procedures shall be performed on the thermal reticulation unit door. (i) Grease chamber door gear boxes. (ii) Grease nonpolymer door linkages. (May possibly be converted to polymer bushing.) (iii) Lubricate shuttle table drive chains and idler bearings. (iv) Inspect/maintain oil level in hydraulic reservoir.

(B) The following preventive maintenance procedures shall be performed on the thermal reticulation unit: (i) On an annual basis, remove and replace roof hydrogen and oxygen valves. (ii) Per quality standard, replace floor level hydrogen and oxygen valves.

(C) The following inspections shall be done on the thermal reticulation unit. (i) Check vacuum time and adjust if necessary.Foamex Innovations Operati ng Company Page 6 of 11 Fort Wayne, Indiana TSD for Signific ant Source Modification No.: 003-30166-00225 Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225

(ii) Fuel pressure check/TPM fuel fill calibration.

(D) The thermal reticulation unit Nash pump shall be lubricated. (i) Grease lube points per quality standard.

(E) The following preventive maintenance procedures shall be performed on the thermal reticulation unit mechanical vacuum system on a daily basis: (i) Drain the condensed water from the exhaust line into the bucket. (ii) Check the oil level through the side sight glass. (iii) Check for oil flow (sight glass with white ball). (iv) Empty condensate bucket as needed. (v) Check mechanical blower oil level and add as needed. (vi) Check the oil purifier as follows: Check gauge for proper pressure between (20-25 psi). When the purifier pressure exceeds 40 psi, service the unit.

(F) The following preventive maintenance procedures shall be performed on the Stokes pumps per preventive maintenance frequency: (i) Drain oil, remove side cover. (ii) Remove baffle, remove valves. (iii) Wipe inside of chamber to remove residue. (iv) Install new or rebuilt valves. (v) Clean baffle and reinstall. (vi) Install side cover with new gasket, if needed. (vii) Refill with oil. (viii) Check V -belts for wear and proper tension, replace if needed. (ix) Check gas ballast valves, replace if needed. (x) Perform preventive maintenance on unit oil purifier per preventative maintenance specification.

(G) The following preventive maintenance procedures shall be performed on the mechanical blower per preventive maintenance specification: (i) Change air filter. (ii) Check for water leaks. (iii) Check V -belts.

(H) The following preventive maintenance procedures shall be performed on the chamber pressure transducer per preventive maintenance specification: (i) Remove manometer valve. (ii) Install new or rebuilt valve. (iii) Rebuild, tag and stock valve. (iv) Check calibration of chamber pressure transducer per preventive maintenance specification.

(I) The following preventive maintenance procedures shall be performed on the shot pins per preventive maintenance frequency: (i) Check shot pin hydraulic cylinder mount for broken or loose bolts. (ii) Check shot pin hydraulic cyli nder assembly plates for torque to chamber. (iii) Check shot pin limit switch mounting bolts for tightness.

(J) The following preventive maintenance procedures shall be performed on the Nash water heat exchanger per preventive maintenance specification: (i) Open, clean and flush all tubes.

(K) Perform fuel fill alarm preventive maintenance monthly per preventive maintenance specification.Foamex Innovations Operati ng Company Page 7 of 11 Fort Wayne, Indiana TSD for Signific ant Source Modification No.: 003-30166-00225 Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225

(L) Perform flammable fuel detector preventive maintenance per preventive maintenance specification

(M) Perform preventive maintenance procedure on plug purge system per preventive maintenance specification: (i) Replace the plug purge valve. (ii) Rebuild, tag and stock valve. (iii) Replace flame arrestor. (iv) Replace plug block. (v) Clean and stock plug block.

(N) Perform thermal reticulation unit cleaning procedure dictated by production schedule: (i) Perform clean type per schedule. (ii) Complete checklist per clean type.

(O) Perform preventive maintenance procedures on the thermal reticulation unit hydraulic system per quality control specifications: (i) Perform oil analysis to determine replacement timing (ii) Maintain fluid level. (iii) Maintain filter.

326 IAC 9-1 (Carbon Monoxide Emission Limits) The new unit has the potential to emit carbon monoxide. However, the new unit does not perform petroleum refining, ferrous metal smelting or refuse incineration. Therefore, the new unit is not subject to the requirements of 326 IAC 9-1.

Compliance Determination and Monitoring Requirements

Permits issued under 326 IAC 2-7 are required to ensure that sources can demonstrate compliance with all applicable state and federal rules on a continuous basis. All state and federal rules contain compliance provisions; however, these provisions do not alway s fulfill the requirement for a continuous demonstration. W hen this occurs, IDEM, OAQ, in conjunction with the source, must develop specific conditions to satisfy 326 IAC 2-7-5. As a result, Compliance Determination Requirements are included in the permit. The Compliance Determination Requirements in Section D of the permit are thos e conditions that are found directly within state and federal rules and the violation of which se rves as grounds for enforcement action.

If the Compliance Determination Requirements ar e not sufficient to demonstrate continuous compliance, they will be supplemented with Compliance Monitoring Requirements, also in Section D of the permit. Unlike Compliance Determination Requirements, failure to meet Compliance Monitoring conditions would serve as a tri gger for corrective actions and not grounds for enforcement action. However, a violation in relation to a compliance monitoring condition will arise through a source’s failure to take the appropriate corrective actions within a specific time period.

Changes to the compliance determination and monitoring requirements are detailed in the Proposed Changes section of this document

.
Proposed Changes

The changes listed below have been made to Part 70 Operating Permit Renewal No. 003-27321- 00225. Deleted language appears as strikethroughs and new language appears in bold :

Modification 1: Sections A.1 and D.1 have been revised to include the new thermal reticulation unit, identified as TRU03, as follows:

...Foamex Innovations Operati ng Company Page 8 of 11 Fort Wayne, Indiana TSD for Signific ant Source Modification No.: 003-30166-00225 Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225

(e) One (1) thermal reticulation unit (ID No. TRU-02), approved for construction in 2007, with a maximum throughput of 87,600 cycles per year, exhausting through eight (8) stacks (ID Nos. 52-59)

(f) One (1) thermal reticulation unit, approved in 2011 for construction, identified as TRU-03, with a maximum capacity of 58,800 cycles per year, uncontrolled, and exhausting to eight (8) stacks.

(f g ) One (1) polyurethane foam coating line, identified as CL-01, approved in 2010 for construction, utilizing flow coat technology, exhausting to one (1) stack (ID No. 65)

Modification 2: Section D.1 has been revised to include the new thermal reticulation unit in Conditions D.1.2, D.1.4 and D.1.6. Additionally, typographical errors have been corrected in these sections, as follows:

D.1.2 Volatile Organic Compounds [326 IAC 8-1-6] [326 IAC 2-4.1-1] (a) Pursuant to Significant Source Modification No. 003-25183-00225, issued on December 18, 2007, 326 IAC 8-1-6 ( Best Available Control Technology ( BACT) ) and 326 IAC 2-4.1-1 ( Maximum Achievable Control Technology ( MACT) ) deter mination made under source modification No. 003

- 25183

- 00225, issued on December 18, 2007

, the operating conditions for the one (1) thermal reticulation unit , identified as ( TRU-02) shall be the following comply with the provisions of (1) and (2) below. :

(b) Pursuant to 326 IAC 8-1-6 (BACT), the one (1) thermal reticulation unit identified as TRU-03 shall comply witht he provisions of (1) and (2) below.

(1) Maintain the thermal reticulation unit in good working order.

(2) Utilize quality procedures to minimize VOC emissions from this unit. The work practices to be performed on the thermal reticulation unit include the following inspection and preventive maintenance procedures:

(a A ) The following preventive maintenance procedures shall be performed on the thermal reticulation unit door. (1 i ) Grease chamber door gear boxes (2 ii ) Grease nonpolymer door linkages. (May possibly be converted to polymer bushing.) (3 iii ) Lubricate shuttle table drive chains and idler bearings (4 iv ) Inspect/maintain oil level in hydraulic reservoir

(b B ) The following preventive maintenance procedures shall be performed on the thermal reticulation unit: (1 i ) On an annual basis, remove and replace roof hydrogen and oxygen valves. (2 ii ) Per quality standard, replace floor level hydrogen and oxygen valves.

(c C ) The following inspections shall be done on the thermal reticulation unit. (1 i ) Check vacuum time and adjust if necessary. (2 ii ) Fuel pressure check/TPM fuel fill calibration.

(d D ) The thermal reticulation unit Nash pump shall be lubricated. (1 i ) Grease lube points per quality standard.

(e E ) The following preventive maintenance procedures shall be performed on the thermal reticulation unit mechanical vacuum system on a daily basis: (1 i ) Drain the condensed water from the exhaust line into the bucket.Foamex Innovations Operati ng Company Page 9 of 11 Fort Wayne, Indiana TSD for Signific ant Source Modification No.: 003-30166-00225 Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225

(2 ii ) Check the oil level through the side sight glass. (3 iii ) Check for oil flow (sight glass with white ball). (4 iv ) Empty condensate bucket as needed. (5 v ) Check mechanical blower oil level and add as needed. (6 vi ) Check the oil purifier as follows: Check gauge for proper pressure between (20-25 psi). When the purifier pressure exceeds 40 psi, service the unit.

(f F ) The following preventive maintenance procedures shall be performed on the Stokes pumps per preventive maintenance frequency: (1 i ) Drain oil, remove side cover. (2 ii ) Remove baffle, remove valves. (3 iii ) Wipe inside of chamber to remove residue. (4 iv ) Install new or rebuilt valves. (5 v ) Clean baffle and reinstall. (6 vi ) Install side cover with new gasket, if needed. (7 vii ) Refill with oil. (8 viii ) Check V -belts for wear and proper tension, replace if needed. (9 ix ) Check gas ballast valves, replace if needed. (10 x ) Perform preventive maintenance on unit oil purifier per preventative maintenance specification.

(g G ) The following preventive maintenance procedures shall be performed on the mechanical blower per preventive maintenance specification: (1 i ) Change air filter. (2 ii ) Check for water leaks. (3 iii ) Check V -belts.

(h H ) The following preventive maintenance procedures shall be performed on the chamber pressure transducer per preventive maintenance specification: (1 i ) Remove manometer valve. (2 ii ) Install new or rebuilt valve. (3 iii ) Rebuild, tag and stock valve. (4 iv ) Check calibration of chamber pressure transducer per preventive maintenance specification.

(i I ) The following preventive maintenance procedures shall be performed on the shot pins per preventive maintenance frequency: (1 i ) Check shot pin hydraulic cylinder mount for broken or loose bolts. (2 ii ) Check shot pin hydraulic cylinder assembly plates for torque to chamber. (3 iii ) Check shot pin limit switch mounting bolts for tightness.

(j J ) The following preventive maintenance procedures shall be performed on the Nash water heat exchanger per preventive maintenance specification: (1 i ) Open, clean and flush all tubes.

(k K ) Perform fuel fill alarm preventive maintenance monthly per preventive maintenance specification

.
(l L ) Perform flammable fuel detector preventive maintenance per preventive maintenance specification

(m M ) Perform preventive maintenance procedure on plug purge system per preventive maintenance specification: (1 i ) Replace the plug purge valve. (2 ii ) Rebuild, tag and stock valve.Foamex Innovations Operati ng Company Page 10 of 11 Fort Wayne, Indiana TSD for Signific ant Source Modification No.: 003-30166-00225 Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225

(3 iii ) Replace flame arrestor. (4 iv ) Replace plug block. (5 v ) Clean and stock plug block.

(n N ) Perform thermal reticulation unit cleaning procedure dictated by production schedule: (1 i ) Perform clean type per schedule. (2 ii ) Complete checklist per clean type.

(o O ) Perform preventive maintenance procedures on the thermal reticulation unit hydraulic system per quality control specifications: (1 i ) Perform oil analysis to determine replacement timing (2 ii ) Maintain fluid level. (3 iii ) Maintain filter.

... D.1.4 Preventive Maintenance Plan [326 IAC 2-7-5(13)] A Preventive Maintenance Plan is required for FL-02, TRU-01
, and TRU-02 and TRU-03 . Section B - Preventive Maintenance Plan contains the Permittee's obligation with regard to the preventive maintenance plan required by this condition.

... D.1.6 Record Keeping Requirements (a) To document the compliance status with Condition D.1.1(a), the Permittee shall maintain a record of the total production of laminated foam per month in square feet for the flame laminator FL-02. Records maintained shall be taken monthly and shall be complete and sufficient to establish compliance with the production limit established in Condition D.1.1(a). Records necessary to demonstrate compliance shall be available within 30 days of the end of each compliance period.

(b) To document the compliance status with Condition D.1.2, the Permittee shall maintain records of work practice standard activities performed for the TRU-02 and TRU-03

. (c) Section C - General Record Keeping Requirements contains the Permittee's obligation with regard to the records required by this condition.

IDEM Change 1: Part 70 Operating Permit Renewal No. 003-27321-00225, issued July 23, 2009, incorrectly calculated the PTE for three (3) insignificant felt presses, identified as FPC, FPD and FPE. Based on a 2007 stack test, the correct emission factor should be 0.026 pounds of VOC per hour instead of 0.023 pounds of VOC per hour that was applied. The corrected calculations are included as Page 3 of 3 of TSD Appendix A. This change does not affect rule applicability so no changes to the permit are required

Conclusion and Recommendation

The construction and operation of this proposed modi fication shall be subject to the conditions of the attached proposed Part 70 Significant Source Modification No. 003-30166-00225 and Significant Permit Modification No. 003-30247-00225. The staff recommends to the Commissioner that this Part 70 Significant Source and Significant Permit Modification be approved.

IDEM Contact

(a) Questions regarding this proposed permit can be directed to Anne-Marie C. Hart at the IndianaFoamex Innovations Operati ng Company Page 11 of 11 Fort Wayne, Indiana TSD for Signific ant Source Modification No.: 003-30166-00225 Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225

Department Environmental Management, Office of Air Quality, Permits Branch, 100 North Senate Avenue, MC 61-53 IGCN 1003, Indianapolis, Indiana 46204-2251, or by telephone at (317) 234- 5400 or toll free at 1-800-451-6027, extension 4-5400.

(b) A copy of the findings is available on the Internet at: http://www.in.gov/ai/appfiles/idem-caats/

. (c) For additional information about air permits and how the public and interested parties can participate, refer to the IDEM’s Guide for Citizen Participation and Permit Guide on the Internet at: www.idem.in.gov

.Page1of3TSDAppACompanyName:FoamexInnovationsOperatingCompanyAddress:3005CommercialRoad,FortWayne,Indiana46809003‐30166‐00225003‐30247‐00225Reviewer:Anne‐MarieC.HartDate:February28,2011AverageCycleTime(minutes/cycle)MaximumNumberofCycles(cycles/hour)MaximumNumberofCycles(cycles/year)TRUChamberVOCEmissionFactor(lb/cycle)TRUChamberCOEmissionFactor(lb/cycle)TRUQuickCoolAreaVOCEmissionFactor(lb/cycle)TRUQuickCoolAreaCOEmissionFactor(lb/cycle)78.57588000.120.410.740.06TRUChamberEmissionsPotentialVOCEmissions(lb/hr)PotentialCOEmissions(lb/hr)PotentialVOCEmissions(tons/yr)PotentialCOEmissions(tons/yr)1.033.533.5512.10TRUQuickCoolAreaPotentialVOCEmissions(lb/hr)PotentialCOEmissions(lb/hr)PotentialVOCEmissions(tons/yr)PotentialCOEmissions(tons/yr)6.320.4921.691.67TotalTRUEmissionsPotentialVOCEmissions(tons/yr)PotentialCOEmissions(tons/yr)25.2413.77EmissionfactorsfromstacktestingconductedonexistingunitTRU‐01,datedNovember6andNovember7,2007Emissionfactorshavebeenadjustedby71%toreflectthedifferencebetweentheexistingTRU‐01(141.38cubicfeet)unitandtheproposedTRU‐03(100.31cubicfeet)MethodologyMaximumNumberofCycles(cycles/hr)=60(min/hr)x1cycle/7minutesPotentialEmissions(lb/hr)=MaximumNumberofCycles(cycles/hr)xEmissionFactor(lb/cycle)PotentialEmissions(tons/yr)=MaximumNumberofCycles(cycles/yr)xEmissionFactor(lb/cycle)x1ton/2000poundsAppendixA:EmissionsCalculationsVOCandCOEmissions‐TRU‐03SourceModificationNumber:PermitModificationNumber:Page2of3TSDAppACompanyName:FoamexInnovationsOperatingCompanyAddress:3005CommercialRoad,FortWayne,Indiana46809003‐30166‐00225003‐30247‐00225Reviewer:Anne‐MarieC.HartDate:February28,2011AverageCycleTime(minutes/cycle)MaximumNumberofCycles(cycles/hour)MaximumNumberofCycles(cycles/year)BenzeneEmissionFactor(lbs/cycle)TotalHAPsEmissionFactor(lbs/cycle)78.57588000.310.40PotentialBenzeneEmissions(lb/hr)PotentialBenzeneEmissions(tons/yr)PotentialTotalHAPEmissions(lb/hr)PotentialTotalHAPEmissions(tons/yr)2.669.113.4311.76MethodologyPotentialEmissions(lb/hr)=MaximumNumberofCycles(cycles/hr)xEmissionFactor(lb/cycle)PotentialEmissions(tons/yr)=MaximumNumberofCycles(cycles/yr)xEmissionFactor(lb/cycle)x1ton/2000poundsEmissionfactorsbasedonstacktestingatasimilarfacilityin1995andadjustedby71%basedonthesizesofthetestedunitandtheproposedunit(100.31cubicfeet/141.38cubicfeet)AppendixA:EmissionsCalculationsHAPEmissions‐TRU‐03SourceModificationNumber:PermitModificationNumber:Page3of3TSDAppACompanyName:FoamexInnovationsOperatingCompanyAddress:3005CommercialRoad,FortWayne,Indiana46809003‐30166‐00225003‐30247‐00225Reviewer:Anne‐MarieC.HartDate:February28,2011VOC EmissionFactor,EfVOC Emission(lb/hr)(Tons/year)FPC0.0260.114FPD0.0260.114FPE0.0260.114TOTAL:0.342Methodology:The VOC emission factor is from year 2007 IDEM approved stack testing.Potential Emissions = Emission Factor (lb/hr) x 8760 (hrs/yr) /2000 (lb/ton)AppendixA:EmissionsCalculationsFeltPressesSourceModificationNumber:PermitModificationNumber:Emission Unit ID

## Indiana Department of En vironmental Management Office of Air Quality

APPENDIX B BACT ANALYSIS

Source Description and Location

Source Name: Foamex Innovations Operating Company Source Location: 3005 Commercial Road, Fort Wayne, Indiana 46809 County: Allen SIC Code: 3086 Operation Permit No.: 003-27321-00225 Operation Permit Issuance Date: July 23, 2009 Significant Source Modification No.: 003-30166-00225 Significant Permit Modification No.: 003-30247-00225 Permit Reviewer: Anne-Marie C. Hart

Background Information

The Office of Air Quality (OAQ) has performed a best available control technology (BACT) review relating to the operation of a proposed thermal reticulation unit at Foamex Innovations Operating Company in Fort Wayne, Indiana.

Foamex Innovations Operating Company submitted an application on January 31, 2011, to construct and operate one (1) new thermal reticulation unit. The pr oposed unit has potential VOC emissions greater than twenty-five (25) tons per year. Therefore, the operation of the one (1) new thermal reticulation unit is subject to the requirements of 326 IAC 8-1-6 (VOC BACT).

IDEM, OAQ conducts BACT analyses in accordance with the “Top-Down” Best Available Control Technology Guidance Document outlined in the 1990 draft U.S. EPA New Source Review Workshop Manual , which outlines the steps for conducting a top-down BACT analysis. Those steps are listed below.

(a) Identify all potentially available control options;

(b) Eliminate technically infeasible control options;

(c) Rank remaining control technologies;

(d) Evaluate the most effective cont rols and document the results; and

(e) Select BACT.

Also in accordance with the “Top-Down” Best Available C ontrol Technology Guidance Document outlined in the 1990 draft U.S. EPA New Source Review Workshop Manual , BACT analyses take into account the energy, environmental, and economic impacts on the source. Emission reductions may be determined through the application of available control techniq ues, process design, and/or operational limitations. Such reductions are necessary to demonstrate that the emissions remaining after application of BACT will not cause or contribute to air pollution thereby protecting public health and the environment.

The following information resources are available a nd may be consulted in searching for varied control alternatives for the analyzed emission sources:Foamex Innovations Operat ing Company Page 2 of 11 Fort Wayne, Indiana TSD Appendix B Permit Reviewer: Anne-Marie C. Hart BACT Analysis for SSM 003-30166-00225

(a) On-line USEPA RACT/BACT/LAER Clearinghouse (RBLC) System;

(b) USEPA/State/Local Air Quality Permits;

(c) Federal/State/Local Permit Engineers;

(d) Control Technology Vendors; and

(e) Inspection/Performance Test Reports.

VOC BACT Analysis

Step One: Identify All Control Technologies

The following control technologies were identified as possible options available to control VOC emissions from the one (1) proposed thermal reticulation unit:

(a) Condensation System

(b) Carbon Adsorption

(c) Absorption Control of VOC Gas Streams

(d) Poly ad TM System

(e) Flare

(f) Biofiltration

(g) Membrane Separation Technology

(h) Ultraviolet (UV) Oxidation

(i) Non-Thermal Plasma (NTP) Technology

(j) Catalytic Incineration

(k) Therm al Oxidation

Step Two: Evaluate Technical Feasibility

The test for technical feasibility of any control opt ion is whether it is both available and applicable to reducing VOC emissions from the thermal reticulating unit. The previously listed information resources were consulted to determine the ext ent of applicability of each identified control alternative.

(a) Condensation System - These systems ut ilize a refrigerant to cool the exhaust stream, effect a phase change from gas to liquid for a target volatile constituent with ascertainable phase change conditions, colle ct the liquid, and thereby lower the concentration in the gas phase. However, this technology is only effective under high concentration gradients in excess of 100 ppmv. The exhaust streams associated with the thermal reticulation unit are very dilute wh ich would preclude any effective technical applicability of a condensation system. Con densation systems are therefore eliminated from further consideration in this BACT anal ysis because of technical infeasibility.Foamex Innovations Operat ing Company Page 3 of 11 Fort Wayne, Indiana TSD Appendix B Permit Reviewer: Anne-Marie C. Hart BACT Analysis for SSM 003-30166-00225

(b) Carbon Adsorption - Activated carbon beds hav e a track record of successful application for adsorbing specific VOC emissions. Howe ver, the application of the technology is subject to certain limitations which can n egate its applicability for specific organic streams. Whenever an exhaust stream contains other contaminants such as particulates and moisture, the technology loses its efficiency. The presence of moisture in the stream will require significant gas pre-conditioning si nce these interferences are harmful to the efficiency of the carbon bed. In effect, they induce a masking phenomenon reducing the available adsorption surface area.

In addition, very dilute exhaust streams, such as that of the thermal reticulation unit, would significantly impair the effective te chnical applicability of a carbon adsorption system which starts to collapse at inlet VOC concentrations less than approximately 50 ppmv. The desorption cycle would involve re-e ntrainment of the VOCs unless they were further controlled by some form of an oxidization scheme.

In conclusion, carbon adsorption technology is not considered technically feasible to reduce VOC emissions from the thermal reticulation unit because the presence of moisture and the dilute exhaust stream inhibit the effectiveness of carbon adsorption technology. Carbon adsorption is therefore eliminated from further consideration due to technical infeasibility in this BACT analysis.

(c) Absorption Control of VOC Gas Streams - Absorption is widely used as a raw material and/or product recovery technique in separation and purification of gaseous streams containing high concentrations of VOC, espe cially water-soluble compounds such as methanol, ethanol, isopropanol, butanol, acetone, and formaldehyde. However, as an emission control technique, it is much more commonly employed for controlling inorganic gases than for VOC. When using absorption as the primary control technique for organic vapors, the spent solvent must be easi ly regenerated or disposed of in an environmentally acceptable manner.

This technology has been determined to be infeas ible for the thermal reticulation unit due to the variation in VOC that may be present in the unit's gas stream, the variability of the VOC concentration in the gas stream, as well as the low relative solubility of the gas stream. Absorption control has therefore been eliminated from further consideration in this BACT analysis.

(d) Polyad TM System - This is an innovative syst em offered by a microwave technology vendor combining resin fluidized bed adsorpti on with microwave dynamic bed desorption that claims VOC control primarily for stri pping VOCs from SVE (soil vapor extraction) units, air stripping at remediation sites, and solvent recovery. There are significant reservations regarding its technical applicab ility. Any adsorption system would suffer from limitations, as those summarized below:

1) Impaired efficiency due to dilute inlet stream concentrations;

2) Effect of interferences such as moisture and the presence of certain constituents which are particularly harmful;

3) Re-entrainment of VOCs du ring microwave desorption; and

4) Microwave desorption technology is not a proven technology for application in the foam manufa cturing and processing industry.

In conclusion, the Polyad TM adsorption/microwave desorption technology is notFoamex Innovations Operat ing Company Page 4 of 11 Fort Wayne, Indiana TSD Appendix B Permit Reviewer: Anne-Marie C. Hart BACT Analysis for SSM 003-30166-00225

considered technically feasib le to reduce VOC emissions from the thermal reticulation unit and will be eliminated from further consideration in this BACT analysis.

(e) Flare - Flares are commonly used in indust ry to safely combust VOC and volatile HAPs. Flares are used extensively to dispose of (1 ) purged and wasted products from refineries, (2) unrecoverable gases emerging with oil from oil wells, (3) vented gases from blast furnaces, (4) unused gases from coke ovens, and (5) gaseous wastes from chemical industries. Flares are also used for burn ing waste gases generated by sewage digesters, coal gasification, rocket engine testing, nuclear power plants with sodium/water heat exchangers, heavy water plants, and ammonia fertilizer plants.

This technology has been determined to be infeas ible for the thermal reticulation unit due to the large amount of fuel that would be needed to combust the low VOC concentration/high air volume waste st ream and will be eliminated from further consideration in this BACT analysis.

(f) Biofiltration – This is an air pollution control technology in which off-gases containing biodegradable organic compounds are v ented, under controlled temperature and humidity, through a biologically active materi al. The microorganisms contained in the bed of compost-like material digest or biodegrade the organic to CO 2 and water. This technology has been largely utilized for control of odorous emissions with a clearly speciated air stream. The process of biof ilteration utilizes a biofilm containing a population of microorganisms immobilized on a po rous substrate such as peat, soil, sand, wood, compost, or numerous synthetic media. As an air stream passes through the biofilter, the contaminants in the air stream partition from the air phases to the liquid phase of the biofilm. Once the contaminants pass into the liquid phase, they become bioavailable for complex oxidative process by the microorganisms inhabiting the biofilm.

The bioscrubber is an enhancement of the bi otrickling filter whereby a packed tower is flooded with a liquid-phase contaminant stream and the discharge effluent is retained in a sump for added time to improve the microbe contact time. The advantages of a bioscrubber are as follows - no gas condit ioning or humidification required, smaller footprint than other reactors, process suitable for neutralizing acids formed in-situ during treatment, and lesser interference from particulates. The disadvantages of a biofiltration system include complex feeding and neutra lizing systems and the handling of toxic chemicals to control biomass growth.

Most bioreactors have large footprints, are maintenance-intensive, operate in narrow bands of temperature and pressure requiring expensive gas conditioning, and have primarily been used for odor control in clearly speciated air streams. Because of the size of a biofiltration system, existing space at t he plant would not be available to support this type of system.

In conclusion, due to the above operational and space limitations, the technology is not considered technically feasib le to reduce VOC emissions from the thermal reticulation unit and will be eliminated from further consideration in this BACT analysis.

(g) Membrane Separation Technology – This organic vapor/air separation technology involves the preferential transport of organi c vapors through a non-porous gas separation membrane via a diffusion process analogous to pumping saline water through a reverse osmosis membrane. In this system, the f eed stream is compressed to approximately 150 psig and sent to a condenser where the liquid solvent is recovered. The condenser bleed stream is sent to the membrane module comprised of spirally-wound modules of thin film membranes separated by plasti c mesh spacers. The conc entrated stream from the membrane module is returned to the compressor for further recovery in the condenser.Foamex Innovations Operat ing Company Page 5 of 11 Fort Wayne, Indiana TSD Appendix B Permit Reviewer: Anne-Marie C. Hart BACT Analysis for SSM 003-30166-00225

There is no known proven application of membrane separation technology for thermal reticulation units.

In conclusion, since there is no known prov en application of this technology for the control of VOCs from a thermal reticulati on unit, this technology is not considered available and will be eliminated from furt her consideration in this BACT analysis.

(h) Ultraviolet (UV) Oxidation – UV light oxidat ion (or photolytic destr uction) of vapor-phase contaminants is accomplished by passing the o ff-gas in close proximity to a powerful UV light source. Oxidation occurs as a result of reactions with hydroxyl radicals produced by the UV light. The photo-oxidation usually is supplemented by a gaseous chemical oxidant (i.e., ozone) or a solid catalyst (e.g., TiO 2 ). The process is best used to treat easily oxidized organic compounds, such as those with double bonds (e.g., trichloroethylene, perchloroethylene and viny l chloride) as well as simple aromatic compounds (e.g., toluene, benzene, xylene, and phenol).

Initially, this technology emerged as a biocidal technology for water treatment since bacteria are destroyed at a wavelength of 254 nanometers. Additionally, it was recognized that the technology was also us eful in cleaving and ionizing certain organics so that they are easily removed by deioniz ation and organic scavenging cartridges in a polishing loop. This technol ogy has been proposed for o ff-gas treatment from SVE and other groundwater remediation units by the U.S. Department Of Energy (DOE). For thermal reticulation units, this technology has the following effective technical applicability reservations:

(1) UV light frequency must be selected for maximum VOC removal based on inlet stream VOC species and concentration s. Questionable effectiveness for a matrix of volatile constituents with variable photolytic destruction isotherms, interaction between chemical constituents, preferential destruction and premature breakthroughs or non-oxidizable species;

(2) Pretreatment of inlet gas required to minimize ongoing cleaning and maintenance of UV reactor and quartz sleeves;

(3) Potential fouling of solid TiO 2 catalyst by interferences such as particulates, moisture and long-chain organics;

(4) Prohibitive energy requirements to power the UV reactor in excess of competing technologies; and

(5) Extensive maintenance and calibration requirements.

Due to the above technical applicability reserv ations, this technology is not considered technically feasible to reduce VOC emissions from the thermal reticulation unit and will be eliminated from further consideration in this BACT analysis.

(i) Non-Thermal Plasma (NTP) Technology – NTP technology was developed by the Los Alamos National Lab for the U.S. Department Of Defense (DOD) and DOE as part of anew generation of VOC control options. The intent of the research was to develop a lowcost solution with reduced energy and power requirements for controlling a host of air contaminants including VOCs. An NTP is an electrically neutral form of gas containing substantial concentrations of electrons, ions and other highly reactive free radicals which may be generated in the gas stream by applicat ion of electrical energy. In theory, the sequential chemical reactions result in the destruction of the air contaminants. Other research organizations such as Batelle have developed NTP variants such as the GasFoamex Innovations Operat ing Company Page 6 of 11 Fort Wayne, Indiana TSD Appendix B Permit Reviewer: Anne-Marie C. Hart BACT Analysis for SSM 003-30166-00225

Phase Corona Reactor (GPCR) which creates non-thermal plasma in a reactor filled with dielectric packing which significantly improves reactor performance.

The U.S. Navy sought to be one of the first to install NTP technology for controlling paint booth VOC emissions. However, at this time , the technology is not "off-the shelf" and not widely commercially available in the United States.

Based on the above lack of commercial availability and proven track record in controlling VOC emissions, this technology is not available to reduce VOC emissions from the thermal reticulation unit and will be eliminated from further consideration in the BACT analysis.

(j) Catalytic Incineration – Catalytic incinerato rs are control devices in which the solventladen air is preheated and the organic HAPs are ignited and combusted to carbon dioxide and water. In the presence of a catalyst, this reaction will take place at lower temperatures than those required for therma l oxidation. Temperatures between 350 and 500 degrees Celsius are common. The catalysts are metal oxides or precious metals where they are supported on ceramic or meta llic substrates. Cataly tic incinerators can achieve control device efficiencies of 95 to 99 percent.

From an operational standpoint, the lowe r reaction temperature means that the requirement for supplemental fuel is reduced or eliminated during normal operation. The lower operating temperatures will also decrea se the formation of oxides of nitrogen.

The catalytic incinerator is appropriate for units with flow rates between 700 and 50,000 scfm. This type of control would be feasible for the proposed thermal reticulation unit since the flow rate will be approximately 25,000 acfm. However, the low VOC concentration loading in the thermal reticulation unit makes catalytic incineration questionable when trying to achieve higher VO C destruction efficiencies (i.e., >95%). The incorporation of a catalytic incinerator is not considered to be technically feasible because the concentration of VOC in the gas stream is low and can affect the overall conversion of the VOC contaminants.

In conclusion, because of technical issues stated above, the use of catalytic incineration to control VOC emissions from the thermal reticulation unit has been eliminated from further consideration in this BACT analysis.

(k) Thermal Oxidation – Thermal oxidizers are control devices in which the solvent-laden air is preheated and the organic VOCs are i gnited and combusted to carbon dioxide and water. Dilute gas streams require auxiliary fuel (generally natural gas) to sustain combustion. Various incinerator designs ar e used by different manufacturers. The combustion chamber designs must provide high turbulence to mix the fuel and solvent laden air. The other requirement is enough residence time to ensure essentially complete combustion. Thermal oxidizers can be operated to achieve a wide range of control device efficiencies. Efficiencies of 95% are possible.

The use of thermal oxidation to control VOC emissions from the proposed thermal reticulation unit has been deemed to be technically feasible and is considered the top level of control for reducing VOC emissions.. The economic, energy and environmental impacts associated with this technology are further discussed in this BACT analysis.

Step Three: Rank Feasible Technologies

As shown in Steps 1 and 2, the only remaining viable control technology for the thermal reticulation unit is thermal oxidation. This type of technology has been shown to be effective atFoamex Innovations Operat ing Company Page 7 of 11 Fort Wayne, Indiana TSD Appendix B Permit Reviewer: Anne-Marie C. Hart BACT Analysis for SSM 003-30166-00225

reducing VOC emissions and can be considered the top alternative for controlling VOC emissions from the thermal reticulation unit.

Step Four: Evaluate Top Control Alternatives

A review of USEPA’s RACT/BACT/LAER Cleari nghouse, Indiana air permits and sources permitted by other states' agencies, identified the following previous BACT determinations with respect to polyurethane foam products manufacturing process:

Thermal Reticulation Unit

Plant/ Facility

Description RBLC ID or Permit # Date Issued and State Emission Unit VOC Control Technology/VOC Emissions Limit Basis of Limit or Control Foamex, LP

Polyurethane Foam Manufacturing SSM No. 003- 25183- 00225 December 18, 2007 (Indiana) Thermal Reticulation Unit Maintain unit in good working order.

Utilize best management work practices to minimize VOC emissions. State BACT

Foamex, LP

Polyurethane Foam Manufacturing SSM No. 003- 12873- 00225 July 3, 2001 (Indiana) Thermal Reticulation Unit Maintain unit in good working order.

Utilize best management work practices to minimize VOC emissions. State BACT

IDEM, OAQ, searched the RBLC database under Polyurethane Foam Products Manufacturing as well as under Polystyrene Foam Products Manufacturing. Thermal reticulation processes were not found in the RBLC database.

Although no similar sources or sources with simila r operations were identified as using any type of add-on control device, Foamex Innovations O perating Company explored using a recuperative thermal oxidation system (RTO) with 95% destruction efficiency. The following cost analysis is based on OAQPS Cost Manual:

Estimated Capital and Operating Costs [Recuperative Thermal Oxidation System (with 70% Heat Recovery) for 95% Control of VOC from Thermal Reticulation Unit (TRU-03).

CAPITAL COSTS Direct Capital Costs (DC)
Gas Flow: 25,000 acfm Purchased Equipment Costs (PE) Recuperative Thermal Oxidation System (OAQPS Budgetary Pricing)

$280,877 Incinerator system with 95% regenerative heat exchanger, housing and frame, inlet and exhaust ductwork. Instrumentation (10% of Equipment, OAQPS Manual) $28,000
Access Way Addition (Engr. Estimate) $25,000Foamex Innovations Operat ing Company Page 8 of 11 Fort Wayne, Indiana TSD Appendix B Permit Reviewer: Anne-Marie C. Hart BACT Analysis for SSM 003-30166-00225

Sales Taxes (6% of Equipment) $19,000

Freight (5% of Equipment) $15,000
Total Purchased Equipment Cost (PE) $368,000

Direct Installation Costs (DI) Foundations & Supports (0.08 PE) $29,000
Erection & Handling (0.14 PE) $52,000
Electrical (0.04 PE) $15,000
Piping (0.02 PE) $7,000
Insulation + Painting (0.02 PE) $7,000
Site Preparation , etc. $30,000

Total Direct Installation Costs $140,000
Total Direct Costs (DC) $508,000

Indirect Capital Costs (IC) Engineering & Supervision (0.1PE) $37,000
Construction & Field Expenses (0.05 PE) $18,000
Contractor Fees (0.10 PE) $37,000
Start Up + Performance Costs (0.03 PE) $11,000
Overall Contingencies (0.03 PE) $11,000 IC Total $114,000 Total Capital Investment (TCI) = Sum (DC + IC) = $622,000 Capital Recovery at 7% interest over 10 years (0.14238*TCI) $88,560

Operation and Maintenance (O & M)

Direct ANNUAL COSTS (DA) Direct Operating Costs Operating Labor

Operator (1 hr/day, 365 days/yr, $20/hr) + Supervisor (15% of Operator) $8,000

Maintenance

Labor (1hr/day, 365 days/yr, $20/hr) + Materials (100% of Labor) $15,000 Natural Gas Requirement (0.0018 scfm gas/acfm exhaust air flow @ $12.85/1000 ft3) $304,000 Electricity (0.003705 kW/acfm flow for 8760 hrs/yr @ $0.057/kW-hr) $34,000
Total Direct Annualized Costs (DA) $361,000

Indirect Annual Costs (IA) Overhead (60% of maintenance parts and labor costs $14,000 Admin., Property Tax, Insurance (4% of TCI) $25,000 Indirect Annual Total $39,000

O & M Total $400,000Foamex Innovations Operat ing Company Page 9 of 11 Fort Wayne, Indiana TSD Appendix B Permit Reviewer: Anne-Marie C. Hart BACT Analysis for SSM 003-30166-00225

Total Annual Capital and O & M Costs (including Capital Recovery) $488,560

Baseline VOC Emissions from the Thermal Reticulation Unit (TRU-03) (tpy) 25.24 Annual VOC removal assuming 95% Removal Efficiency (tons) 23.98 Cost Effectiveness,$/Ton VOC Removed $20,374

Note: - Cost Factors are based on OAQPS Control Cost Manual (Ch. 3, 5th Ed., Dec 1995)

As demonstrated above, the cost to control VOC em issions from the thermal reticulation unit is prohibitive. Therefore, this level of contro l has been determined to be not representative of BACT.

Step Five: Select BACT

Foamex Innovations Operating Company is proposing BACT as maintaining the thermal reticulation unit, identified as TRU-03, in good working order and utilizing best management practices work practices to minimize VOC emissi ons. The proper maintenance of the thermal reticulation unit was previously approved by ID EM as BACT for the existing thermal reticulation unit at the source, identified as TRU-02, pursuant to Significant Source Modification 003-25183- 00225, issued December 18, 2007.

Pursuant to 326 IAC 8-1-6, the Best Availabl e Control Technology (BACT) for the Thermal Reticulation Unit, identified as TRU-03 shall be the following:

(1) Maintain the thermal reticulation unit in good working order; and

(2) Utilize quality pr ocedures to minimize VOC emissions from this unit. The work practices to be performed on the thermal reticulation unit include the following inspection and preventive maintenance procedures:

(A) The following preventive maintena nce procedures shall be performed on the thermal reticulation unit door. (i) Grease chamber door gear boxes. (ii) Grease nonpolymer door linkages. (May possibly be converted to polymer bushing.) (iii) Lubricate shuttle table drive chains and idler bearings. (iv) Inspect/maintain oil level in hydraulic reservoir.

(B) The following preventive maintena nce procedures shall be performed on the thermal reticulation unit: (i) On an annual basis, remove and replace roof hydrogen and oxygen valves. (ii) Per quality standard, replace floor level hydrogen and oxygen valves.

(C) The following inspections shall be done on the thermal reticulation unit. (i) Check vacuum time and adjust if necessary. (ii) Fuel pressu re check/TPM fuel fill calibration.

(D) The thermal reticulation unit Nash pump shall be lubricated. (i) Grease lube points per quality standard.

(E) The following preventive maintena nce procedures shall be performed on the thermal reticulation unit mechanical vacuum system on a daily basis: (i) Drain the condensed water from the exhaust line into the bucket.Foamex Innovations Operatin g Company Page 10 of 11 Fort Wayne, Indiana TSD Appendix B Permit Reviewer: Anne-Marie C. Hart BACT Analysis for SSM 003-30166-00225

(ii) Check the oil level through the side sight glass. (iii) Check for oil flow (sight glass with white ball). (iv) Empty condensate bucket as needed. (v) Check mechanical blower oil level and add as needed. (vi) Check the oil purifier as follows: Check gauge for proper pressure between (20-25 psi). When the purifier pressure exceeds 40 psi, service the unit.

(F) The following preventive maintena nce procedures shall be performed on the Stokes pumps per preventive maintenance frequency: (i) Drain oil, remove side cover. (ii) Remove baffle, remove valves. (iii) Wipe inside of cham ber to remove residue. (iv) Install new or rebuilt valves. (v) Clean baffle and reinstall. (vi) Install side cover with new gasket, if needed. (vii) Refill with oil. (viii) Check V -belts for wear and proper tension, replace if needed. (ix) Check gas ballast valves, replace if needed. (x) Perform preventive maintenance on unit oil purifier per preventative maintena nce specification.

(G) The following preventive maintena nce procedures shall be performed on the mechanical blower per prevent ive maintenance specification: (i) Change air filter. (ii) Check for water leaks. (iii) Check V -belts.

(H) The following preventive maintena nce procedures shall be performed on the chamber pressure transducer per preventive maintenance specification: (i) Remove manometer valve. (ii) Install new or rebuilt valve. (iii) Rebuild, tag and stock valve. (iv) Check calibration of chamber pressure transduce r per preventive maintenance specification.

(I) The following preventive maintena nce procedures shall be performed on the shot pins per preventive maintenance frequency: (i) Check shot pin hydraulic cy linder mount for broken or loose bolts. (ii) Check shot pin hydraulic cylinder assembly plates for torque to chamber. (iii) Check shot pin limit swit ch mounting bolts for tightness.

(J) The following preventive maintena nce procedures shall be performed on the Nash water heat exchanger per preventive maintenance specification: (i) Open, clean and flush all tubes.

(K) Perform fuel fill alarm preventive maintenance monthly per preventive maintenance specification.

(L) Perform flammable fuel detector preventive maintenance per preventive maintenance specificationFoamex Innovations Operatin g Company Page 11 of 11 Fort Wayne, Indiana TSD Appendix B Permit Reviewer: Anne-Marie C. Hart BACT Analysis for SSM 003-30166-00225

(M) Perform preventive maintenance procedure on plug purge system per preventive maintenanc e specification: (i) Replace the plug purge valve. (ii) Rebuild, tag and stock valve. (iii) Replace flame arrestor. (iv) Replace plug block. (v) Clean and stock plug block.

(N) Perform thermal reticulation unit cleaning procedure dictated by production schedule: (i) Perform clean type per schedule. (ii) Complete checklist per clean type.

(O) Perform preventive maintenance procedures on the thermal reticulation unit hydraulic system per quality control specifications: (i) Perform oil analysis to determine replacement timing (ii) Maintain fluid level. (iii) Maintain filter.

## I NDIANA 

## D EPARTMENT OF 

## E NVIRONMENTAL 

## M ANAGEMENT
We Protect Hoosiers and Our Environment.
Mitchell E. Daniels Jr. 100 North Senate Avenue
Governor Indianapolis, Indiana 46204 (317) 232-8603 Thomas W. Easterly Toll Free (800) 451-6027
Commissioner www.idem.IN.gov

Recycled Paper An Equal Opportunity Employer Please Recycle SENT VIA U.S. MAIL: CONFIRMED DELIVERY AND SIGNATURE REQUESTED

TO: James Konuch Foamex Innovations, Inc. 3005 Commercial Rd Ft. Wayne, IN 46809

DATE: May 26, 2011

FROM: Matt Stuckey, Branch Chief Permits Branch Office of Air Quality

SUBJECT: Final D ecision Foamex I nnovations 003-302 4 7-00225

Enclosed i s the final decision and supporting material s for the air permit application referenced above. Please note that this packet contains the original, signed, permit documents.

The final decision is being sent to you because our reco rds indicate that you are the contact person for this application. However, if you are not the appropriate person within your company to receive this document, please forward it to the correct person.

A copy of the final decision and supporting mate rials has also been sent via standard mail to: Richard Strozyk, Responsible Official OAQ Permits Branch Interested Parties List

If you have technical questions regarding the enclosed doc uments, please contact the Office of Air Quality, Permits Branch at (317) 233-0178, or toll-free at 1-800-451-6027 (ext. 3-0178), and ask to speak to the permit reviewer who prepared the permit. If you thin k you have received this do cument in error, please contact Joanne Smiddie-Brush of my staff at 1-800-451-6027 (ext 3-0185), or via e-mail at jbrush@idem.IN.gov

.

Final Applicant Cover letter.dot 11/30/07

## I NDIANA 

## D EPARTMENT OF 

## E NVIRONMENTAL 

## M ANAGEMENT
We Protect Hoosiers and Our Environment.
Mitchell E. Daniels Jr. 100 North Senate Avenue
Governor Indianapolis, Indiana 46204 (317) 232-8603 Thomas W. Easterly Toll Free (800) 451-6027
Commissioner www.idem.IN.gov

Recycled Paper An Equal Opportunity Employer Please Recycle 

### May 26, 2011

TO: Allen County Public Library

From: Matthew Stuckey, Branch Chief Permits Branch Office of Air Quality

Subject: Important Information for Display Regarding a Final Determination

Applicant Name: Foamex Innovations Permit Number: 003-30247-00225

You previously received information to make av ailable to the public during the public comment period of a draft permit. Enclosed is a copy of the final decision and supporting materials for the same project. Please place the enclosed information along with the information you previously received. To ensure that your patrons have ample opportunity to review the enclosed permit, we ask that you retain this document for at least 60 days.

The applicant is responsible for placing a copy of the application in your library. If the permit application is not on file, or if you have any questions concerning this public review process, please contact Joanne Smiddie-Brush, OAQ Permits Administration Section at 1-800-451-6027, extension 3-0185.

Enclosures Final Library.dot 11/30/07FACSIMILIE OF PS Form 3877Mail Code 61-53IDEM Staff DPABST 5/26/2011Foamex Innovations,Inc. 003-30247-00225(Final)AFFIX STAMPHERE IFUSED ASCERTIFICATEOF MAILINGName andaddress ofSender►Indiana Department of EnvironmentalManagementOffice of Air Quality – Permits Branch100 N. SenateIndianapolis, IN 46204Type of Mail:CERTIFICATE OFMAILING ONLYLine ArticleNumberName, Address, Street and Post Office Address Postage HandingChargesAct. Value(If Registered)InsuredValueDue Send ifCODR.R.FeeS.D. Fee S.H.FeeRest.Del. FeeRemarks1James Konuch Foamex Innovations, Inc. 3005 CommercialRd Ft. Wayne IN 46809 (Source CAATS) (CONFIRM DELIVERY)2Richard Strozyk Plant Manager Foamex Innovations, Inc. 3005 Commercial Rd Ft. Wayne IN 46809(RO CAATS)3Daniel & Sandy Trimmer 15021 Yellow River Road Columbia City IN 46725(Affected Party)4Duane & Deborah Clark Clark Farms 6973 E. 500 S. Columbia City IN 46725(Affected Party)5Mr. Victor Locke WPTA-TV P.O.Box 2121 Fort Wayne IN 46801(Affected Party)6Fort Wayne City Council and Mayors Office One Main Street Fort Wayne IN 46802(Local Official)7Allen County Public Library, Waynedale Branch 2200 Lower Huntington Rd Fort Wayne IN 46809(Library)8Mr. John E. Hampton Plumbers & Steamfitters, Local 166 2930 W Ludwig Rd Fort Wayne IN 46818-1328(Affected Party)9Allen Co. Board of Commissioners One Main St. Fort Wayne IN 46802(Local Official)10Fort Wayne-Allen County Health Department 1 E Main Street, 5th Floor Fort Wayne IN 46802-1810(Health Department)11Mark Zeltwanger 26545 CR 52 Nappanee IN 46550(Affected Party)12131415Total number of piecesListed by SenderTotal number of PiecesReceived at Post OfficePostmaster, Per (Name ofReceiving employee)The full declaration of value is required on all domestic and international registered mail. Themaximum indemnity payable for the reconstruction of nonnegotiable documents under ExpressMail document reconstructing insurance is $50,000 perpiece subject to a limit of $50, 000 peroccurrence. The maximum indemnity payable onExpress mil merchandise insurance is $500.The maximum indemnity payable is $25,000 for registered mail, sent with optional postalinsurance. SeeDomestic Mail ManualR900, S913, andS921for limitations of coverage oninured and COD mail. SeeInternational Mail Manualfor limitations o coverage on internationalmail. Special handling charges apply only to Standard Mail (A) and Standard Mail (B) parcels.