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ENCLOSURE 1

INFORMATION COLLECTION REQUEST FOR

Flexible Polyurethane Foam Production

We are conducting this Information Collection Request (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 section 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 health 

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. The 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 polyurethane foam fabrication is conducted as a co-located operation.

Section 114(a) of the CAA gives 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 whether 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 data 

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.
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We seek information on existing flexible polyurethane foam production 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 refer to Enclosures , 

3, 4, 5, and 6 to learn how we will treat CBI as 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 definitions:

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 essentially 

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 storage; 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 affected 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 

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 foam 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.

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.
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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 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 Form
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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., 38.27941, -85.64371)]: _41.007287, -85.17694_______

4. Facility Contact:

a. Name (First Name, Last Name): Joe 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 flexible polyurethane foam. 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.
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___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

 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), we 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: D243-04

Research Triangle Park, NC 27711

Phone: 919 541 2825

Fax: 919 541-5450

Email address: Nizich.sharon@epa.gov
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PART II. GENERAL FACILITY INFORMATION

1. Please provide the following general information for each flexible polyurethane foam 

production plant:

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 colocated 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 the 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 Compounds
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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 – National 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 characteristics. 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 process 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-process streams, 

waste streams, wastewater streams, and emission release points in the flow diagram. 

Identification code Description of item submitted with survey response

PL-01a 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 2 
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TDI Tank TB TDI Tank TB (32,000 gallon tank) See Appendix A - Figure 

1 and Figure 2 
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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 PL01a 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 

Process unit ID made

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: ________oF

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: ________________________________oF

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 (oF)

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.
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

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 Branch 

 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 effectiveness 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 and IC 13-15-7-3 require that you file a petition for 

administrative review. This petition may include a request for stay 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 earliest 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 containing 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 represented 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 which, 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 issuance 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 enclosed documents, please contact the Office of Air 

Quality, Permits Branch at (317) 233-0178. Callers from within Indiana may call toll-free at 1-800-451-

6027, ext. 3-0178. 

 

Enclosures 

FNTV-PMOD.doc 3/27/08


Foamex 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 IAC 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 Exceedances [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 IAC 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, TRU-01, FPC, FPD, FPE, TRU-02, Loop slitters 

Emission Limitations and Standards [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 IAC 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 CONDITIONS - PL-01c, CL-01 .................................................................. 32 

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] 

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 Standards [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 (SO2) [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 Emissions 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 - Insignificant Activities .........................................................................37 

Emission Limitations and Standards [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 OPERATION CONDITIONS .............................................................................. 39

E.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR Part 63, Subpart A] 

E.1.2 Flexible Polyurethane Foam Production [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 OPERATION CONDITIONS .............................................................................. 41 

E.2.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR 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 Boiler Certification............................................................................ 46 

Quarterly Reports................................................................................................................................... 47 

Quarterly Deviation and Compliance Monitoring Report................................................................... 50 

Attachment A - NESHAP, Subpart III 

Attachment B - NESHAP, Subpart MMMMM 
Foamex 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 information 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 inaccurate 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: Attainment 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 following 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 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) 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 through 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 Grabber 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 flame 
Foamex 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 exhausting 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 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. 

(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) 

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 following 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 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, buffing, 

polishing, abrasive blasting, pneumatic conveying, and woodworking operations. [326 

IAC 6-3-2] 

(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] 

(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 pounds 
Foamex 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 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] 

(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 FPA, 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 containers 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 grease 
Foamex 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 precipitators, 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 products (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 VOC 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 designated 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 determined 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 plan 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 condition 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 rights of any sort or any exclusive privilege. 

B.7 Duty to Provide Information [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 determine 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 meets 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 "responsible 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 information 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 Certification [326 IAC 2-7-6(5)] 

(a) The Permittee shall annually submit a compliance 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 December 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 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. 

(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 compliance 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 Sections D of this permit, as IDEM, OAQ may 

require to determine the compliance status of the source. 
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Permit Reviewer: 

The submittal by the 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.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) meets the requirements of 326 IAC 1-6-3 if it 

includes, at a minimum: 

(1) Identification of the individual(s) responsible 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 quantification of the replacement parts 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 prepare and maintain Preventive Maintenance 

Plans (PMPs) no later than ninety (90) days after 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) responsible 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 quantification of the replacement parts that will be maintained 

in inventory for quick replacement. 

 If, due to circumstances beyond the Permittee’s control, the PMPs cannot be prepared 

and maintained within the above time frame, 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 "responsible 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 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). 
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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 relevant evidence that describe the following: 

(1) An emergency occurred and the Permittee 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 exceeded 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 IAC 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. 
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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 reasonable steps to correct the emergency. 

(c) In any enforcement proceeding, the Permittee seeking to establish the occurrence of an 

emergency has the burden of proof. 

(d) This emergency provision supersedes 326 IAC 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 occurrence 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 Plans 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 affected emitting facilities during the emergency 

provided the Permittee immediately takes all 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 included and specifically identified in this 

permit or the permit contains an explicit determination or concise summary of a 

determination that other specifically identified 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 determined 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 permit 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 permit term or condition that is determined after 

issuance of this permit to have been based on erroneous information supplied in the 
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Permit Reviewer: 

permit application. Erroneous information means information that the Permittee knew to 

be false, or in the exercise of reasonable care 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 permit shall alter or affect the following: 

(1) The provisions of Section 303 of the Clean 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 violation 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 information 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 Act 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 modifications. [326 IAC 2-7-12(c)(7)] 

(g) This permit shield is not applicable to minor Part 70 permit modifications until after IDEM, 

OAQ, has issued the modification. [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 accurately 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 terminates with the expiration of this permit unless a 

timely and complete renewal application is submitted at least nine (9) months prior to the date of 

expiration of the source’s existing permit, consistent 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 for a Part 70 Operating Permit modification, 

revocation and reissuance, or termination, or of a notification of planned changes or 

anticipated noncompliance does not stay any condition of this permit. 
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Permit Reviewer: 

[326 IAC 2-7-5(6)(C)] The notification by the 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 issuance 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 the 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 case 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 trivial 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 requirements 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 prior 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 considered 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, 
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Fort Wayne, Indiana Modified by: Anne-Marie C. Hart T003-27321-00225 

Permit Reviewer: 

subsequent to the completeness determination, 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 modifications 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 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) The Permittee may implement administrative 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, emissions 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 State 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 

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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 Development Branch - Indiana (AR-18J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

in advance of the change by written notification 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 Permittee 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 notification 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) 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 conditions of this permit in accordance with 

326 IAC 2-7-5(9). No prior notification of IDEM, OAQ, or U.S. EPA is required. 
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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 Requirement [326 IAC 2-7-10.5] 

A modification, construction, or reconstruction is governed by the requirements 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 cards, credentials, and other documents as may be 

required by law, and subject to the Permittee’s right under all applicable laws and regulations to 

assert that the information collected by the agency 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 records 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 monitoring 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 parameters for the purpose of assuring 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, and IC 13-30-3-1, utilize 

any photographic, recording, testing, monitoring, or other equipment for the purpose of 

assuring compliance with this permit or applicable requirements. 

B.23 Transfer of Ownership or Operational Control [326 IAC 2-7-11] 

(a) The Permittee must comply with the requirements of 326 IAC 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 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) The Permittee may implement administrative amendment changes addressed in the 

request for an administrative amendment immediately upon submittal of the request. 

[326 IAC 2-7-11(c)(3)] 
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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, Licensing, 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 certifications 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 compliance with the condition of this permit if the 

appropriate performance or compliance test or procedure had been performed. 
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Permit Reviewer: 

SECTION C SOURCE OPERATION CONDITIONS 

Entire Source 

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

C.1 Particulate Emission Limitations For Processes 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 process 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 Limitations), except as provided in 326 IAC 5-1-1 

(Applicability) and 326 IAC 5-1-3 (Temporary Alternative Opacity Limitations), opacity shall meet 

the following, unless otherwise stated in this permit: 

(a) Opacity shall not exceed an average of forty 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 incinerator 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 feet on other facility components, or at least 

thirty-five (35) cubic feet on all facility components, then the notification 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: 
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Permit Reviewer: 

(1) When the amount of affected asbestos 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 notice 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 certification 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 that 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 feet 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 affected facility or part of the facility where the 

demolition or renovation will occur for the 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 portion of the facility for the presence of asbestos. The 

requirement to use an Indiana Licensed Asbestos 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 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) The Permittee shall notify IDEM, OAQ of the actual test date at least fourteen (14) days 

prior to the actual test date. The notification 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 accordance 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 requirements not already legally 

required, the Permittee shall be allowed up to ninety (90) days from the date of permit issuance or 

initial start-up, whichever is later, to begin such monitoring. If due to circumstances beyond the 

Permittee's control, any monitoring equipment required 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 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). 

Unless otherwise specified in the approval for the new emission unit(s), compliance monitoring for 

new emission units or emission units added through a source modification shall be implemented 

when operation begins. 
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Permit Reviewer: 

C.10 Re served 

C.11 Instrum ent Specifications [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 provided 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 (Emergency 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 associated 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 computerized distribution 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 available, which may include, 

but is not limited to, the following: 

(1) monitori ng results; 
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Permit Reviewer: 

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

(3) inspection of the control device, associated 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 specified 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 calendar year. The emission statement shall 

contain, at a minimum, the information specified 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 emissions 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 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). 
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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, reports and support information required by this 

permit shall be retained for a period of at least 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 location 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 (as 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 IAC 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 unit 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 emissions 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 the 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 IAC 2-3-1(mm)), the Permittee shall comply with following: 
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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 period 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 reported pursuant to an applicable requirement that 

exists independent of this permit, shall be reported 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 exceedance 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 years, 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 any “project” (as defined in 326 IAC 2-2-1 

(qq) and/or 326 IAC 2-3-1 (ll)) at an existing 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, 

and 
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(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 actual-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 Stratospheric Ozone), Subpart F, except as provided for 

motor vehicle air conditioners in Subpart B, the Permittee shall comply with applicable standards 

for recycling and emissions reduction.
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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, 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. 

(The information describing the process 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.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 month period with compliance determined at 

the end of each month. 

(b) VOC emission from FL-02 shall not exceed 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 Control Technology (BACT)) and 326 IAC 2-4.1-

1 (Maximum Achievable Control Technology (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 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. 
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(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. 

(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. 
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(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 cylinder 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. 

 

(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. 

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: 
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Permit Reviewer: 

E = 4.10 P0.67 where E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour 

 

D.1.4 Preventive Maintenance 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 Permittee's obligation with regard to the preventive 

maintenance plan required by this condition. 

Compliance Determination Requirements 

D.1.5 Testing Requirements [326 IAC 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 accordance with the provisions of 326 IAC 3-6 

(Source Sampling Procedures). Section C- Performance Testing contains the Permittee's 

obligation with regard to the performance testing required by this condition. 

 

Record Keeping and Reporting Requirements [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 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. 

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 forms located at the end of this permit, or their 

equivalent, not later than thirty (30) days after the end of the quarter being reported. Section C - 

General Reporting Requirements contains the Permittee'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 official” 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 [326 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, exhausting to five (5) stacks (ID Nos. 60-64) 

(f) 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) 

(The information describing the process 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 Significant Deterioration (PSD) Best Available Control 

Technology (BACT)) and 326 IAC 8-1-6 (VOC BACT), 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 period, 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) polyurethane foam coating line shall not exceed 17.2 

tons per twelve (12) consecutive month period, with compliance determined at the end of 

each month. 

Compliance with the above shall satisfy the requirements of both 326 IAC 2-2-3 (PSD BACT) and 

326 IAC 8-1-6 (VOC BACT) for the modification 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 for PL-01c and CL-01. Section B - Preventive 

Maintenance Plan contains the Permittee's obligation 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 Requirements [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-containing 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 established 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 Condition 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 ndition 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 ets (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 Requirements 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 submitted 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 reports 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 (Btu) per hour, using No. 2 distillate fuel oil as 

back-up fuel, and each exhausting through one (1) stack (ID Nos. 45 and 46). 

(The information describing the process 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.3.1 Particulate [326 IAC 6-2-3] 

Pursuant to 326 IAC 6-2-3 (Particulate Limitations for Sources of Indirect 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 Q0.75 x N0.25 

where 

C = 50 u/m3

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 Limitations), the SO2 emission rate from each of the 

boilers shall not exceed five tenths (0.5) pounds 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 Maintenance Plan [326 IAC 2-7-5(13)] 

A Preventive Maintenance Plan is required for the two (2) boilers, identified as IPB-01 and IPB02. Section B - Preventive Maintenance Plan contains the Permittee's obligation with regard to 

the preventive maintenance plan required by this condition. 

Compliance Determination Requirements 

D.3.4 Sulfur Dioxide Emissions and Sulfur Content 

Compliance with Condition D.1.2 shall be determined 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 refilled, a new sample and analysis would 

be required upon filling. 

(b) Compliance may also be determined by conducting 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 Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] 

D.3.5 Record Keeping Requirements 

(a) To document the compliance status with Condition 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 certifies 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, measurement, or report. Support information 

includes all calibration and maintenance records and all original strip-chart recordings for 

continuous monitoring instrumentation, and copies of all reports required by this permit. 

(b) Section C - General Record Keeping Requirements 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 thirty (30) days after the end of the six (6) month 

period being reported. Section C - General Reporting 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 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 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, buffing, 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 description box is descriptive information 

and does not constitute enforceable conditions.) 

Emission Limitations and Standards [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 parts 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 

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Permit Reviewer: 

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

(f) Store waste solvent only in covered containers 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 P0.67 where E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour 
Foamex 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 [326 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) 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 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, 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 Grabber 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. 

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 capacity 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 description box is descriptive information 

and does not constitute enforceable conditions.)

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

E.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR Part 63, Subpart A] 

(a) The provisions of 40 CFR Part 63, Subpart 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 Production [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 'Attachment A'), which are incorporated by reference 

as 326 IAC 20-22, for the facilities 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 Polyurethane 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 Affected 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 existing flame lamination affected source. 

(The information describing the process 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)] 

E.2.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR Part 63, Subpart A] 

(a) The provisions of 40 CFR Part 63, Subpart 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 Operations [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 facilities 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 7 
Foamex 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 Polyurethane 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 Affected Facility Deadline 

Submit Initial Notification 40 CFR 63.8816(b) FL-02 no later than 

120 days after 

April 14, 2003 
Foamex 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 ENVIRONMENTAL 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 documents 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 formed 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 ENVIRONMENTAL 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 time of the emergency? Y N 

Type of Pollutants Emitted: TSP, PM-10, SO2, VOC, NOX, 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 why continued operation of the facilities are necessary to prevent 

imminent injury to persons, severe damage to equipment, 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 ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE AND ENFORCEMENT BRANCH 

PART 70 OPERATING PERMIT 

SEMI-ANNUAL NATURAL GAS FIRED 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 formed 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 ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE AND ENFORCEMENT 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 ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE AND ENFORCEMENT 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) consecutive 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 ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE AND ENFORCEMENT 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 coating line, identified as CL-01 

Parameter: VOC Input 

Limit: 17.2 tons per twelve (12) consecutive 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 ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE AND ENFORCEMENT BRANCH 

PART 70 OPERATING PERMIT 

QUARTERLY DEVIATION AND COMPLIANCE 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 OCCURRED THIS REPORTING 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 Standards for Hazardous Air Pollutants 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 listed 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 major 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 located at a contiguous plant site, with the 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) through (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 fabrication processes are the only processes at the plant site 

that emit HAP. The amount of non-diisocyanate HAP used, HAPused, shall be calculated using Equation 1. Owners or 

operators of slabstock foam processes exempt from the regulation in accordance with this paragraph shall maintain 

records to verify that total non-diisocyanate HAP use at the plant site is less than 5 tons per year (4.5 megagrams per 

year). 

Where,

HAPused= amount of HAP, excluding diisocyanate reactants, used at the plant site for slabstock foam 

production and foam fabrication, tons per year 

VOLABA,i= volume of HAP ABA i used at the facility, gallons per year 
Foamex Innovations Operating Company 

Fort Wayne, Indiana 

Permit Reviewer: Stephanie Wilkerson 

Attachment A 

40 CFR 63, Subpart III 

Page 2 of 35 

 T003-27321-00225 

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

m = number of HAP ABAs used 

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

Dclean,j= density of HAP equipment cleaner j, pounds per gallon 

WTHAPclean,k= HAP content of equipment cleaner j, weight percent 

n = number of HAP equipment cleaners used 

VOLadh,k= volume of adhesive k, gallons per year 

Dadh,k= density of adhesive k, pounds per gallon 

WTHAPadh,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 compliance with all provisions of this subpart upon initial 

startup. 

§ 63.1292 Definitions. 

All terms used in this subpart shall have the meaning given 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 section, 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 isocyanate-water reaction. 

Breakthrough means that point in the adsorption 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 breakthrough 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 device against a known standard. For the purpose of this 

subpart, there are two levels of calibration. The initial calibration includes the verification 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 common 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 container 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 fittings 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 developed physical properties. A period of 12 to 24 hours 

from pour is typically required to completely 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 facility 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 industry 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 strength and flexibility to allow repeated distortion or 

compression under stress with essentially 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 subpart, the flexible polyurethane foam process includes raw material storage; production 

equipment and associated piping, ductwork, 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 indentation 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 concentration 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 capacity 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, typically 15 inches square or larger, to 25 percent of the sample's initial height. 

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

In HAP ABA service means a piece of equipment 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 streams before dispensing foam producing mixture to 

the desired container. 

Molded flexible polyurethane foam means a flexible polyurethane foam that is produced by shooting the foam mixture 

into a mold of the desired shape and size. 

Mold release agent means any material which, when applied to the mold 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 polyester polymer with more than one reactive hydroxyl 

group attached to the molecule. 

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 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 foam 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 reconstruction, as defined in subpart A. For the 

purposes of this subpart, process modifications made to reduce HAP ABA emissions to meet the existing source 

requirements of this subpart shall not be counted in determining 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 the manufacture of products for commercial sale except in 

a de minimis manner. 

Run of foam means a continuous production of foam, which 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 vessels 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 used 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 affected source shall comply with §63.1294 and either 

paragraph (a) or (b) of this section: 

(a) The emission point specific limitations 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 shall comply with the provisions of this section. 

(a) Diisocyanate storage vessels. Diisocyanate storage vessels shall be equipped 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 line 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 adsorption system, meeting the monitoring requirements of 

§63.1303(a), that routes displaced vapors 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 service 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 requirements 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 accordance with the procedures in paragraphs (b)(2)(iii)(A) and (B) 

of this section, except as provided 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 calendar 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 operating 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 practicable, 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 diisocyanate service. 

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

(i) The owner or operator determines that diisocyanate emissions of purged 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 recovered in a control device when repair procedures are 

effected. 

(3) Delay of repair for pumps is also allowed if repair requires 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 affected 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 either a vapor balance system meeting 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 balance system. The owner or operator shall ensure that the 

vapor return line from the storage vessel to the tank 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 adsorption system, meeting the monitoring requirements of 

§63.1303(a), that routes displaced vapors through activated carbon before discharging to the atmosphere. The owner 

or operator shall replace the existing carbon with fresh carbon upon indication of breakthrough 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 affected 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 with 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 leaks 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 accordance with the procedures in paragraphs (a)(2)(iii)(A) and (B) 

of this section, except as provided 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 calendar 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 operating 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 leaks by the method specified in §63.1304(a). If an instrument 

reading of 10,000 parts per million or greater 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 calendar days after the leak is detected. First attempts at 

repair include, but are not limited to, the 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 requirements of paragraphs (b)(1) 

and (2) of this section if: 

(i) The owner or operator of the valve determines that the 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-monitor 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 requirements 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 without 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 than 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 for 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 monitored 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 provided 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 greater 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 for 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 accordance with the procedures in paragraphs (c)(2)(i) and (ii) of 

this section, except as provided in paragraph (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. 
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(3) Any connector that is designated as an unsafe-to-monitor 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 requires 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 personnel 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 monitored for leaks in 

accordance with paragraph (d)(1) of this section. Leaks shall 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 provided 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 valve shall be operated in a manner such that the valve on 

the process fluid end is closed before the second valve is closed. 

(3) When a double block and bleed system is being used, the bleed valve or line may remain open during operations 

that require venting the line between the block valves but shall comply with paragraph (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 from 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 process and that does not remain 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 purged 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 recovered in a control device when repair procedures are 

effected. 
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(3) Delay of repair for pumps is also allowed if repair requires 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 emissions from the slabstock polyurethane foam 

production line in accordance with the provisions in this 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 described in paragraph (a)(2) of this section. 

(1) Rolling annual compliance. In determining compliance on a rolling annual basis, actual HAP ABA emissions shall 

be compared to allowable HAP ABA emissions for each consecutive 12-month period. The allowable HAP ABA 

emission level shall be calculated based on the production for the 12-month period, resulting in a potentially different 

allowable level for each 12-month period. Compliance shall be determined each month for the previous 12-month 

period. The compliance requirements are provided 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 level shall be calculated based on the production for the month, 

resulting in a potentially different allowable level each 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 Administrator 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 paragraph (a)(1) of this section, actual HAP ABA emissions shall not exceed the 

allowable HAP ABA emission level for a consecutive 12-month period. The actual HAP ABA emission level for a 

consecutive 12-month period shall be determined using the procedures in paragraph (b)(1) of this section, and the 

allowable HAP ABA emission level for the corresponding 12-month period shall be calculated in accordance with 

paragraph (b)(2) of this section. 

(1) The actual HAP ABA emissions for a 12-month period shall be calculated as the sum of actual monthly HAP ABA 

emissions for each of the individual 12 months in the period. 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 foam 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-month 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:

emissallow,month= Allowable HAP ABA emissions from the slabstock foam production source for the month, 

pounds. 

m = Number of slabstock foam production lines. 
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polyoli

= Amount of polyol used in the month in the production 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. 

limiti

= 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 shall be based on the amount of polyol added to the slabstock 

foam production line at the mixhead, 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 section, actual HAP ABA emissions shall not exceed the 

corresponding allowable HAP ABA emission level for the same month. The actual monthly HAP ABA emission level 

shall be determined using the procedures in paragraph (c)(1) of this section, and the allowable 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 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 foam 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 the month shall be determined in accordance with 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 section. For any grade, the owner or operator may designate 

zero as the HAP ABA formulation limitation and not determine the HAP ABA formulation 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 any grade of foam where the 

result of the formulation limitation equation (Equation 3) is negative (i.e., less than zero). 

Where:

ABAlimit= HAP ABA formulation limitation, parts HAP 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 limitation 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 foam where the result of the 

formulation limitation equation (Equation 3 of this section) is negative (i.e., less than zero). 
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(ii) For each foam grade with a density of 1.4 pounds per cubic 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 grade 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 shall determine the allowable HAP ABA emissions for each month using Equation 2 in 

paragraph (b)(2) of this section, and the actual monthly HAP ABA emissions in accordance with paragraph (e)(1) of 

this section. The owner or operator shall also comply with the provisions of paragraph (e)(2) of this section. 

(1) The actual monthly HAP ABA emissions shall be determined using Equation 4: 

Where:

Eactual= Actual HAP ABA emissions after control, pounds/month. 

Eunc= Uncontrolled HAP ABA emissions, pounds/month, determined in accordance with paragraph (b)(1) 

of this section. 

HAPABArecovered= HAP ABA recovered, pounds/month, determined 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 affected 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 storage 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 compliance monthly, as described in paragraph (b) of this 

section. 

(a) Rolling annual compliance. Under the rolling annual compliance provisions, 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 emissions for each consecutive 12-month period. The allowable 
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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 period. While compliance is on an annual basis, compliance 

shall be determined monthly for the preceding 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 foam production sources using recovery devices shall determine 

actual source-wide HAP emissions in accordance with paragraph (e) of this section. The allowable HAP emission 

level for a consecutive 12-month period shall be determined using 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 calculated based on the production for the month, resulting in a 

potentially different allowable level each month. The actual monthly emission level shall be determined using the 

procedures in paragraphs (c)(1) through (3) of this section, 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 section. Actual source-wide HAP emissions for each individual 

month shall be determined using the procedures specified in paragraphs (c)(1) through (3) of this section. 

(1) Actual source-wide HAP emissions for a month shall be determined using Equation 5 and the information 

determined in accordance with paragraphs (c)(2) and (3) of this section. 

Where:

PWEactual= Actual source-wide HAP ABA and equipment cleaning HAP emissions for a month, 

pounds/month. 

n = Number of HAP ABA storage vessels. 

STi,begin= Amount of HAP ABA in storage vessel i at the beginning of the month, pounds, determined in 

accordance with the procedures listed in paragraph (c)(2) of this section. 

STi,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. 

ADDi

= 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 determined 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 sum 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. 
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(d) Allowable source-wide HAP emissions for a consecutive 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:

emissallow,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. 

polyoli

= Amount of polyol used in the month in the production 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. 

limiti

= 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 shall determine the allowable source-wide HAP emissions for each month using 

Equation 6 in paragraph (d) of this section, and the actual monthly source-wide HAP emissions in accordance with 

paragraph (e)(1) of this section. The owner or operator shall 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:

Eactual= Actual source-wide HAP emissions after control, pounds/month. 

Eunc= Uncontrolled source-wide HAP emissions, pounds/month, determined in accordance with paragraph 

(c) (1) through (3) of this section. 

HAPABArecovered= HAP ABA recovered, pounds/month, determined 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. 
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(a) A HAP or HAP-based material shall not be used as an equipment cleaner to flush the mixhead, nor shall it be 

used elsewhere as an equipment cleaner in a molded flexible polyurethane foam process, with the following 

exception. Diisocyanates may be used to flush the mixhead 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 requirements of §63.1294(a) or §63.1295 shall monitor 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 section 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 multiple 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 established 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 composition, constituent concentration, flow rate, relative 

humidity, and temperature. 

(ii) The design analysis shall establish the outlet organic concentration level, the capacity of the carbon bed, and the 

working capacity of activated carbon used for the carbon bed, and 

(iii) The design analysis shall establish the 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 made using 40 CFR part 60, appendix A, Method 18. The 

measurement shall be conducted over 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 over 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 provisions in paragraph (b)(1)(i) of this section, and, if 
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applicable, the provisions of paragraph (b)(1)(ii) of this section. Alternatively, the owner or operator may comply with 

paragraph (b)(5) of this section. 

(i) Owners or operators of all slabstock affected sources shall 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 sources using the emission point specific limitation option 

provided in §63.1293(a)(1) shall continuously monitor the 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 least 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 paragraphs (b)(2) through (4) 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 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 using 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. Until the program is approved, the owner or operator of an affected source 

remains subject to the requirements of this subpart. The components of an alternative monitoring program shall 

include, at a minimum, the items listed in paragraphs (b)(5)(i) through (iv) of this section. 

(i) A description of the parameter to be continuously monitored 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 recorded, 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 accuracy of the parameter monitoring results is maintained. These procedures 

shall, at a minimum, consist of periodic calibration of all monitoring devices. 

(c) Recovered HAP ABA monitoring. The owner or operator of each slabstock 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, the items listed in paragraphs 

(c)(1) through (5) of this section. These plans must be submitted for approval in accordance with paragraph (c)(6) of 

this section. 
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(1) A device, installed, calibrated, maintained, and operated according to the manufacturer's specifications, that 

indicates the cumulative amount of HAP ABA recovered by the solvent recovery device over each 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 ensure that the measurements are taken after HAP ABA has 

been fully recovered (i.e., after separation from water introduced into the HAP ABA during regeneration). 

(3) A description of the parameter to be monitored, and the times the parameter will be monitored. 

(4) Data demonstrating that the monitoring device is accurate to within ±2.0 percent. 

(5) Procedures to ensure that the accuracy of the parameter monitoring results is maintained. These procedures 

shall, at a minimum, consist of periodic calibration of all monitoring devices. 

(6) Recovered HAP ABA monitoring and recordkeeping programs 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 Administrator 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 operator 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 vessel using a level measurement 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 paragraphs (e)(1), (2), (3), or (4) of this section. 

(1) The volume of HAP ABA added to the storage vessel shall be determined by recording the volume in the storage 

vessel prior to the delivery and the volume after the delivery, provided that the storage 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 shall be determined by monitoring the flow rate using a 

device with an accuracy of ±2.0 percent, and calibrated initially and at least once each six months thereafter. 

(3) The weight of HAP ABA added to the storage vessel shall be calculated as the difference of the full weight of the 

transfer vehicle prior to unloading into the storage vessel and the empty weight of the transfer vehicle after unloading 

into the storage vessel. The weight shall be determined using 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 Weighing 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. 
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(4) As an alternative to the monitoring options described in paragraphs (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 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 using the alternative program. If the 

Administrator 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 operator of an affected source 

remains subject to the requirements of this subpart. The components of an alternative monitoring program shall 

include, at a minimum, the items 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 device is accurate to within ±2.0 percent, and 

(iv) Procedures to ensure that the accuracy of the monitoring measurements is maintained. These procedures shall, 

at a minimum, consist of periodic calibration of all monitoring devices. 

§ 63.1304 Testing requirements. 

Owners and operators of affected sources shall use the test 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 criteria 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 shall be calculated on an inert-free basis. 

The response factor may be determined at any concentration 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 methane 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 the higher concentration calibration gas shall be no higher than 10,000 ppm 

methane. 

(5) Monitoring shall be performed when the 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. 
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(6) If no instrument is available onsite that will meet the performance criteria specified in section 3.1.2(a) of Method 

21 of 40 CFR Part 60, appendix A, the readings 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 ASTM D3574–91, Standard Test Methods for Flexible Cellular Materials—Slab, 

Bonded, and Molded (incorporation by reference—see §63.14), using a sample of foam cut 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 operator 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 approval to use an alternative means 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 reconstruction 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 emission 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 emission limitation shall not begin until approval is granted by the Administrator in 

accordance with §63.6(g). 

§ 63.1306 Reporting requirements. 

Owners and operators of affected sources shall comply with 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 submit a precompliance report no later than 12 

months before the compliance date. 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). 
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(4) A description of how HAP ABA and/or polyol added at the mixhead will be monitored. If the owner or operator is 

developing an alternative monitoring program, the alternative 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 limitation, 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 operator of objections to an alternative monitoring program 

submitted in accordance with (c)(4) or (c)(6) of this section, or a recovered HAP ABA monitoring and recordkeeping 

program submitted in accordance with (c)(7) of this section, 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 notification 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 processes 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 utilized 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 §§63.1294 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 utilized 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 service made to comply with the provisions of §63.1296. 

(4) A statement that the molded foam affected source is in compliance with §63.1300, or a statement that molded 

foam processes at an affected source are in compliance with §63.1300. 

(5) A statement that the rebond foam affected source is in compliance with §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 complying with the rolling annual compliance provisions 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 12-month periods ending on each of the six months in the reporting period. This information is not 

required to be included in the initial semi-annual compliance report. 
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(2) For sources complying with the monthly compliance alternative 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 provisions of §63.1294(a) or §63.1295 using a carbon adsorption 

system, unloading events that occurred after breakthrough 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 owner 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 the period of compliance for either 

§63.1297 or §63.1299 (between rolling annual and monthly) shall notify the Administrator no later than 180 days prior 

to the change. 

(g) Annual compliance certifications. Each affected source subject to the provisions 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, provided that the compliance certification is based 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) through (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 with a record of the type of control utilized 

for each storage vessel. 

(2) For each slabstock affected source complying with the emission point specific limitations 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 greater 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), and 
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(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 vapor return line, paragraphs (a)(4)(i) through (iii) of this 

section. 

(i) Dates and times when each unloading event occurs and each 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 equipment identification number, shall be attached to the leaking 

equipment. 

(B) The identification on a valve may be removed after it has 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) through (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 detected and the dates of each attempt to repair the leak. 

(C) Repair methods applied in each attempt to repair the leak. 

(D) The words “above leak definition” if the maximum instrument reading measured by the methods specified in 

§63.1304(a) after each repair attempt is equal or greater 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 repair of the leak if a leak is not repaired within 15 calendar days. 
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(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 the monthly compliance alternative of 

§63.1297(a)(2), shall maintain the records listed in paragraphs (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 shall include a list of the grades produced during the run. 

(B) Results of the density and IFD testing for each grade of foam produced during each run of foam, conducted in 

accordance with the procedures in §63.1304(b). The results of this testing shall be recorded within 10 working days of 

the production of the foam. For grades of foam where 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 paragraphs (c)(1)(ii)(A) through (E) of this section. 

(A) A listing of all foam grades 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 month, determined in accordance with §63.1297(b)(2). 

(E) The total amount of HAP ABA added to the slabstock foam production line at the mixhead during the month, 

determined in accordance with §63.1303(b). 

(iii) Each source complying with the rolling annual compliance 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 emissions for the month and the previous 11 months. 

(B) The sum of the total actual HAP ABA emissions for the month and the previous 11 months. 

(iv) Records of all calibrations for each device used 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 this section. Each flexible 

polyurethane foam slabstock source complying with the source-wide limitations of §63.1299, and the monthly 

compliance alternative of §63.1299(b), shall maintain the records 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 paragraphs (c)(2)(i)(A) through (C) of this section. 
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(A) A log of foam runs each day. For each run, the log shall include a list of the grades produced during the run. 

(B) Results of the density and IFD testing for each grade of foam produced during each run of foam, conducted in 

accordance with the procedures in §63.1304(b). The results of this testing shall be recorded within 10 working days of 

the production of the foam. For grades of foam where 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 polyol added to the slabstock foam production line at the mixhead for each grade 

produced during each run of foam, determined 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 grades 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 the 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 the 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 cleaning 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 HAP 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 the storage vessel meet the 

requirements of §63.1303(e)(3). For scales meeting the criteria of §63.1303(e)(3)(i), this documentation shall be in 

the form of written confirmation of the State or local approval. For scales complying with §63.1303(e)(3)(ii), this 

documentation shall be in the form of a report provided by the registered scale technician. 
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(d) The owner or operator of each affected source complying with §63.1297 or §63.1299 through the use of a 

recovery device shall maintain 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 accuracy 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 HAP 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 during unloading, of any leaks detected 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 diisocyanates 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 agent used that includes the HAP content, 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 requirements listed in paragraphs (a)(1) through (a)(2) of this 

section shall mean compliance with the requirements contained 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 certification 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 diisocyanate 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 connected, each unloading 

event that the vapor line is not inspected 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 calendar 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 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; 
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(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 event that the diisocyanate storage vessel is not equipped 

with a carbon adsorption system, each time that the carbon adsorption system is not monitored 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 replaced 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 after 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 exception 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 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 meeting the criteria 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), failure to meet the requirements 

contained in §§63.1295 through 63.1298 shall be considered a violation of this subpart. Violation of each item listed in 

the paragraphs (c)(1) through (c)(17) of this section, as applicable, shall be considered 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 connected, each unloading event that 

the vapor line is not inspected for leaks as described in §63.1295(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 monitored 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 replaced 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 service 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 repaired, or if a leak is not 

repaired as soon as practicable, each subsequent calender day (with the exception of situations meeting the criteria 

of §63.1296(f)); 

(6) For each affected 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 detect leaks in accordance with §63.1304(a), each calendar day 
Foamex Innovations Operating Company 

Fort Wayne, Indiana 

Permit Reviewer: Stephanie Wilkerson 

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40 CFR 63, Subpart III 

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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)(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, whichever 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-monitor 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) for one or more valves designated as difficult-to-monitor 

in accordance with §63.1296(b)(4)(i) and (ii), failure to develop the written plan required by §63.1296(b)(4)(iii), each 

calendar year that a difficult-to-monitor 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; 

(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 otherwise 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 calendar day (with the exception of situations 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 develop the written plan required by §63.1296(c)(3)(ii), each 

period specified in the written plan that an unsafe-to-monitor valve 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 meeting 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 months after one or more unsafe-to-repair connectors has 

been opened, has otherwise had the seal broken, or a leak is repaired, that each unsafe-to-repair connector in HAP 

ABA service is not monitored to detect leaks in accordance 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 criteria 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 process 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 monitored (as required) 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 calendar day in a month in which the HAP ABA pumps are not 
Foamex Innovations Operating Company 

Fort Wayne, Indiana 

Permit Reviewer: Stephanie Wilkerson 

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40 CFR 63, Subpart III 

Page 28 of 35 

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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 mixhead is not monitored (as required) 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 6-month 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 §63.1297(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 element 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 element 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 provided in §63.1293(b), failure to meet the requirements 

contained in §63.1299 shall be considered a violation of this subpart. Violation of each item listed in the paragraphs 

(d)(1) through (d)(3) of this section, as applicable, shall be considered 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 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 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 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), and 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). 

(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 §63.1299(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 

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(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 affected sources, failure to meet the 

requirements contained in §63.1300 and §63.1301, respectively, shall be considered 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 for diisocyanates used to flush the mixhead and associated 

piping during periods of startup or maintenance, provided that 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 implement and enforce this subpart. Contact the 

applicable U.S. EPA Regional Office to find out if implementation and enforcement of this subpart 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 the State, local, or Tribal agency. 

(c) The authorities that cannot be delegated 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 tables 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 

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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 applicable to the extent area sources are 

not subject to subpart III. 

§63.2 YES Definitions are modified 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 subpart III affected sources are not required 

to develop and implement a startup, 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) YES 
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Permit Reviewer: Stephanie Wilkerson 

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40 CFR 63, Subpart III 

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§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 Notification of Compliance Status requirements.

§63.9 (i)–(j) YES 

§63.10 (a)–(b) YES Except that the records specified 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—Compliance 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 

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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 

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 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 

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Table 4 to Subpart III of Part 63—Compliance Requirements for Slabstock Foam Production 

Affected Sources Complying With the 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 

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Permit Reviewer: Stephanie Wilkerson 

Attachment A 

40 CFR 63, Subpart III 

Page 35 of 35 

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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 Molded 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 hazardous air pollutants (NESHAP) emitted from flexible 

polyurethane foam fabrication operations. This subpart also 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 located at, or is part of a major 

emission source of hazardous air pollutants (HAP) or that operates a loop slitter affected 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 using 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 processes 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 reconstructed 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 

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(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 flexible polyurethane foam fabrication plant site. 

(c)(1) A new affected source is one that commences construction 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 amended 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 subpart 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 sources 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, you 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 notification requirements in §63.8816 according to the schedule in §63.8816 and in subpart A 

of this part. Some of the notifications 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 demonstrate 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 

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(b) You must meet each operating limit in Table 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 affected 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 set, 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 lamination sources, you must 

develop and submit for approval a site-specific monitoring plan that addresses the requirements in paragraphs (f)(1) 

through (3) of this section. 

(1) Installation of the continuous monitoring system (CMS) sampling probe or other interface at a measurement 

location relative to each affected process unit such that the 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 procedures and acceptance criteria ( e.g., calibrations). 

(g) In your site-specific monitoring plan, you must also address the ongoing procedures specified in paragraphs (g)(1) 

through (3) of this section. 

(1) Ongoing operation and maintenance procedures in accordance 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 accordance with the general requirements of §63.8(d); and 

(3) Ongoing recordkeeping and reporting procedures in accordance 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 

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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 conduct 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 affected 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 malfunction, 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 run must last at least 1 hour. 

(e) You must determine the percent reduction of HAP emissions 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 retardant foams, determine the percent reduction of HCN to 

represent HAP emissions from the source. 

(2) Calculate the concentration of HAP at the control device inlet and at the control device outlet using the procedures 

in the specified test method. 

(3) Compare the calculated HAP concentration at the control device inlet to the calculated HAP concentration at the 

control device outlet to determine the percent reduction over the period of the performance test, using Equation 1 of 

this section: 

Where:

R=Efficiency of control device, percent. 

Einlet,i=HAP concentration of control device inlet stream for test run i, mg/dscm. 

Eoutlet,i=HAP concentration of control device outlet 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 

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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 typically 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 limits 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, you 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 subject 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 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 measured to be 

0.5 percent of the material by mass, you do not need to include it in the HAP total. Express the mass fraction of each 

HAP you measure as a value truncated to four places 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 determining mass fraction of HAP if you obtain 

prior approval by the Administrator. You must follow the procedure 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 section. 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 material by mass, you do not have to include it in the HAP 

total. 

(ii) If the HAP content is provided by the material supplier 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 specified 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 

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§ 63.8806 How do I demonstrate initial compliance with the emission limitations? 

(a) You must demonstrate initial compliance with each emission limit that applies to you according to Table 4 to this 

subpart. 

(b) You must establish each site-specific operating limit in Table 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 indicating the mass percent of each HAP for each adhesive. 

(b) If you own or operate a new or reconstructed flame lamination 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 for each operating parameter that applies to you. 

(c) If you own or operate a new or reconstructed flame lamination 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 applicable, calibration checks and required zero and span adjustments), you must monitor 

continuously (or collect data at all required intervals) at all times that the affected source is operating. This includes 

periods of startup, shutdown, and malfunction when the affected source is operating. A monitoring malfunction 

includes, but is not limited to, any sudden, infrequent, not reasonably 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 applicable minimum data availability requirement. You must use 

all the data collected during all other periods in assessing the operation of the control 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 

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§ 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 reconstructed flame lamination affected sources, this includes 

periods of startup, shutdown, and malfunction. 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 startup, shutdown, or malfunction are not violations if you demonstrate to the 

Administrator's satisfaction that you were operating in accordance with §63.6(e)(1). The Administrator will determine 

whether deviations that occur at a new or reconstructed flame 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 you 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, you must verify that each adhesive used in the affected 

source meets the emission limit, using 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 during which you used the new adhesive, you must submit the 

updated list of all adhesives and a statement certifying that, as purchased, each 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 amended 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 the notifications in §§63.7(b) and (c), 63.8(f), and 63.9(b) through (h) that apply to you. 

(b) If you own or operate an existing loop slitter or flame lamination 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 slitter or flame lamination affected source, submit the 

application for construction or reconstruction required by §63.9(b)(1)(iii) in lieu of the initial notification. 

(d) If you own or operate a new or reconstructed flame lamination 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, submit a Notification of Compliance Status according to 

§63.9(h)(2)(ii) within 60 days of the compliance date specified in §63.8786. 

(f) If you own or operate a new or reconstructed flame lamination affected source, submit a Notification of Compliance 

Status according to §63.9(h)(2)(ii) that includes the results of the performance test conducted according to the 
Foamex Innovations Operating Company 

Fort Wayne, Indiana 

Permit Reviewer: Stephanie Wilkerson 

Attachment B 

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requirements in Table 3 to this subpart. You must submit the notification before the close 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 source, the Notification of Compliance 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 emissions 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 Notification 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, its HAP content (percent by mass), and the manufacturer or 

supplier of each. 

(2) A statement certifying that each adhesive that was used at the affected source 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 flame lamination affected sources semiannually according to 

paragraphs (b)(1) through (4) of this section. 

(1) The first compliance report must cover the period beginning on the compliance date that is specified for your 

affected source in §63.8786 and ending on June 30 or December 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 delivered no later than July 31 or January 31, whichever date 

follows the end of the first calendar half after the compliance date that is specified for your affected source in 

§63.8786. 

(3) Each subsequent compliance report must cover the semiannual 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 postmarked 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, you 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 submit 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 

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(2) Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy and 

completeness of the content of the report. 

(3) Date of report and beginning and ending dates of the reporting period. 

(4) If there are no deviations from any emission limitations (emission limit or operating 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 occurs, 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, duration, 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) through (3) of this section. 

(1) If you had a startup, shutdown or malfunction at your new or reconstructed 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 the information in §63.10(d)(5)(i). 

(2) If there were no periods during which the CPMS was out-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 affected 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 adhesive 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 adhesive that was used at the affected source 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 source 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 all required information concerning deviations from any 

emission limitation (including any operating limit) in this subpart, submission of the compliance report shall be 

deemed to satisfy any obligation to report the same deviations 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 the 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 

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(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 made 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 affected source, you must also keep the following records 

specified in paragraphs (b)(1) through (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 malfunction 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 method, 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 available for expeditious review, according to §63.10(b)(1). 

(b) As specified in §63.10(b)(1), you must keep each record 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 each occurrence, measurement, 

maintenance, corrective action, report, or record, according to §63.10(b)(1). You 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 General 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 and 
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enforce this subpart. You should contact your U.S. EPA Regional Office to find out if implementation and 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 section 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, 63.8784, 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 monitoring under §63.8(f) and as defined in §63.90. 

(4) Approval of major alternatives to recordkeeping 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 foam, 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 other product with an adhesive incorporated onto 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 any 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 affected source required to obtain such a permit; or 

(3) Fails to meet any emission limitation (including any operating limit) in this subpart during startup, shutdown, or 

malfunction, regardless of whether or not such 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 sheets of foam from the large blocks 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 of 
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technically trained personnel, and which is not engaged in the 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 must comply with the emission limits 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 submit an initial 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 must comply with the operating limits in the following table: 

For each . . . You must . . . 

1. Scrubber a. Maintain the daily average scrubber inlet liquid flow rate 

above the minimum value established during the performance 

test. 

 b. Maintain the daily average scrubber effluent pH within the 

operating range value established during the performance test.

 c. If you use a venturi scrubber, maintain the daily average 

pressure drop across the venturi 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 parameter(s) within the ranges 

established during the performance 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 through 5 of the table if you are 

measuring HCl and using a scrubber, row 6 if you are measuring HCN and using a scrubber, and row 7 if you are 

using any other control device. 
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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 molecular 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. 
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 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 initial 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 Limits 
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As stated in §63.8812(a), you must comply with the requirements to demonstrate 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 adhesives 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, as 
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applicable. 

Table 6 to Subpart MMMMM of Part 63—Requirements for Reports 

As stated in §63.8818(a), you must submit 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 submit startup, shutdown, and 

malfunction reports according to the requirements in the following 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-control in accordance with the 

monitoring plan 

There were no periods during 

which 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 flame 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—Applicability of General Provisions to Subpart MMMMM 

As stated in §63.8826, you must comply with the applicable General Provisions 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. 
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§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 and 

maintenance 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) Compliance 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. 
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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 dates 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 testing facilities Yes. 

§63.7(e)(1) Conditions for conducting 

performance tests 

Yes. 

§63.7(f) Use of an alternative 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 not 
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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 relative 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 notifications 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. 
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§63.9(d) Notification that a new source is 

subject to special compliance 

requirements 

Yes. 

§63.9(e) Notification of performance 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 compliance 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 requirements Yes §63.8818 specifies additional 
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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—general 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 subject 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 

SO2 Better than national standards. 

CO Unclassifiable or attainment effective November 15, 1990. 

O3 Attainment effective February 12, 2007, for the Fort Wayne area, including Allen County, for 

the 8-hour ozone standard.1

PM10 Unclassifiable effective November 15, 1990. 

NO2 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 PM2.5. 

(a) Ozone Standards 

Volatile organic compounds (VOC) and nitrogen oxides (NOX) 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 NOX emissions are 

considered when evaluating the rule applicability relating to ozone. Allen County has 

been designated as attainment or unclassifiable for ozone. Therefore, VOC and NOX

emissions were reviewed pursuant to the requirements for 326 IAC 2-2 (Prevention of 

Significant Deterioration (PSD)). 
Foamex Innovations Operating Company Page 2 of 11 

Fort Wayne, Indiana TSD for Significant 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 PM2.5. On May 8, 2008, U.S. EPA 

promulgated the requirements for Prevention of Significant Deterioration (PSD) for PM2.5 

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 PM10 emissions 

as a surrogate for PM2.5 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 emissions 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 enforceable limits established in the effective permits: 

Pollutant Emissions (ton/yr) 

PM 44.61 

PM10 45.79 

PM2.5 45.79 

SO2 64.91 

VOC Greater than 250 

CO 78.52 

NOX 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 Significant 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 to 
Foamex Innovations Operating Company Page 3 of 11 

Fort Wayne, Indiana TSD for Significant 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 calculations 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 Document 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 the capacity of a source to emit an air pollutant, 

including air pollution control equipment and restrictions 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. Control 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 

PM10 0.00 

PM2.5 0.00 

SO2 0.00 

VOC 25.24 

CO 13.77 

NOX 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 pursuant 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, reflecting all limits, of the emission units. Any 

control equipment is considered federally enforceable 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 Operating Company Page 4 of 11 

Fort Wayne, Indiana TSD for Significant 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 PM10 SO2 VOC CO NOX

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 stationary 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 Assurance 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 Operating Company Page 5 of 11 

Fort Wayne, Indiana TSD for Significant 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 

Reticulation 

Unit (TRU03)/VOC 

N Y 25.24 25.24 100 N N 

Thermal 

Reticulation 

Unit (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 reticulation 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 Operating Company Page 6 of 11 

Fort Wayne, Indiana TSD for Significant 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 cylinder 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 Operating Company Page 7 of 11 

Fort Wayne, Indiana TSD for Significant 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 always fulfill the 

requirement for a continuous demonstration. When 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 those conditions that are found directly within state 

and federal rules and the violation of which serves as grounds for enforcement action. 

If the Compliance Determination Requirements are 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 trigger 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 Operating Company Page 8 of 11 

Fort Wayne, Indiana TSD for Significant 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. 

(fg) 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)) determination 

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: 

(aA) The following preventive maintenance procedures shall be performed on 

the thermal reticulation unit door. 

(1i) Grease chamber door gear boxes 

(2ii) Grease nonpolymer door linkages. (May possibly be converted to 

polymer bushing.) 

(3iii) Lubricate shuttle table drive chains and idler bearings 

(4iv) Inspect/maintain oil level in hydraulic reservoir 

(bB) The following preventive maintenance procedures shall be performed on 

the thermal reticulation unit: 

(1i) On an annual basis, remove and replace roof hydrogen and 

oxygen valves. 

(2ii) Per quality standard, replace floor level hydrogen and oxygen 

valves. 

 

(cC) The following inspections shall be done on the thermal reticulation unit. 

(1i) Check vacuum time and adjust if necessary. 

(2ii) Fuel pressure check/TPM fuel fill calibration. 

 

(dD) The thermal reticulation unit Nash pump shall be lubricated. 

(1i) Grease lube points per quality standard. 

 

(eE) The following preventive maintenance procedures shall be performed on 

the thermal reticulation unit mechanical vacuum system on a daily basis: 

(1i) Drain the condensed water from the exhaust line into the bucket. 
Foamex Innovations Operating Company Page 9 of 11 

Fort Wayne, Indiana TSD for Significant Source Modification No.: 003-30166-00225 

Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225 

(2ii) Check the oil level through the side sight glass. 

(3iii) Check for oil flow (sight glass with white ball). 

(4iv) Empty condensate bucket as needed. 

(5v) Check mechanical blower oil level and add as needed. 

(6vi) 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. 

 

(fF) The following preventive maintenance procedures shall be performed on 

the Stokes pumps per preventive maintenance frequency: 

(1i) Drain oil, remove side cover. 

(2ii) Remove baffle, remove valves. 

(3iii) Wipe inside of chamber to remove residue. 

(4iv) Install new or rebuilt valves. 

(5v) Clean baffle and reinstall. 

(6vi) Install side cover with new gasket, if needed. 

(7vii) Refill with oil. 

(8viii) Check V -belts for wear and proper tension, replace if needed. 

(9ix) Check gas ballast valves, replace if needed. 

(10x) Perform preventive maintenance on unit oil purifier per 

preventative maintenance specification. 

(gG) The following preventive maintenance procedures shall be performed on 

the mechanical blower per preventive maintenance specification: 

(1i) Change air filter. 

(2ii) Check for water leaks. 

(3iii) Check V -belts. 

(hH) The following preventive maintenance procedures shall be performed on 

the chamber pressure transducer per preventive maintenance 

specification: 

(1i) Remove manometer valve. 

(2ii) Install new or rebuilt valve. 

(3iii) Rebuild, tag and stock valve. 

(4iv) Check calibration of chamber pressure transducer per preventive 

maintenance specification. 

(iI) The following preventive maintenance procedures shall be performed on 

the shot pins per preventive maintenance frequency: 

(1i) Check shot pin hydraulic cylinder mount for broken or loose bolts. 

(2ii) Check shot pin hydraulic cylinder assembly plates for torque to 

chamber. 

(3iii) Check shot pin limit switch mounting bolts for tightness. 

(jJ) The following preventive maintenance procedures shall be performed on 

the Nash water heat exchanger per preventive maintenance specification: 

(1i) Open, clean and flush all tubes. 

(kK) Perform fuel fill alarm preventive maintenance monthly per preventive 

maintenance specification. 

 

(lL) Perform flammable fuel detector preventive maintenance per preventive 

maintenance specification 

(mM) Perform preventive maintenance procedure on plug purge system per 

preventive maintenance specification: 

(1i) Replace the plug purge valve. 

(2ii) Rebuild, tag and stock valve. 
Foamex Innovations Operating Company Page 10 of 11 

Fort Wayne, Indiana TSD for Significant Source Modification No.: 003-30166-00225 

Permit Reviewer: Anne-Marie C. Hart TSD for Significant Permit Modification No.: 003-30247-00225 

(3iii) Replace flame arrestor. 

(4iv) Replace plug block. 

(5v) Clean and stock plug block. 

(nN) Perform thermal reticulation unit cleaning procedure dictated by 

production schedule: 

(1i) Perform clean type per schedule. 

(2ii) Complete checklist per clean type. 

(oO) Perform preventive maintenance procedures on the thermal reticulation 

unit hydraulic system per quality control specifications: 

(1i) Perform oil analysis to determine replacement timing 

(2ii) Maintain fluid level. 

(3iii) 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 modification 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 Indiana 
Foamex Innovations Operating Company Page 11 of 11 

Fort Wayne, Indiana TSD for Significant 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. 
Page 1 of 3 TSD App A

Company Name: Foamex Innovations Operating Company

Address: 3005 Commercial Road, Fort Wayne, Indiana 46809

003‐30166‐00225

003‐30247‐00225

Reviewer: Anne‐Marie C. Hart

Date: February 28, 2011

Average Cycle Time

(minutes/cycle)

Maximum Number

of Cycles

(cycles/hour)

Maximum Number

of Cycles

(cycles/year)

TRU Chamber VOC

Emission Factor

(lb/cycle)

TRU Chamber CO

Emission Factor

(lb/cycle)

TRU Quick Cool

Area VOC

Emission Factor

(lb/cycle)

TRU Quick Cool

Area CO Emission

Factor (lb/cycle)

7 8.57 58800 0.12 0.41 0.74 0.06

TRU Chamber Emissions

Potential VOC

Emissions (lb/hr)

Potential CO

Emissions (lb/hr)

Potential VOC

Emissions

(tons/yr)

Potential CO

Emissions (tons/yr)

1.03 3.53 3.55 12.10

TRU Quick Cool Area

Potential VOC

Emissions (lb/hr)

Potential CO

Emissions (lb/hr)

Potential VOC

Emissions

(tons/yr)

Potential CO

Emissions (tons/yr)

6.32 0.49 21.69 1.67

Total TRU Emissions

Potential VOC

Emissions (tons/yr)

Potential CO

Emissions (tons/yr)

25.24 13.77

Emission factors from stack testing conducted on existing unit TRU‐01, dated November 6 and November 7, 2007

Emission factors have been adjusted by 71% to reflect the difference between the existing TRU‐01 (141.38 cubic feet) unit and the proposed TRU‐03 (100.31 cubic feet)

MethodologyMaximum Number of Cycles (cycles/hr) = 60 (min/hr) x 1 cycle/7 minutes

Potential Emissions (lb/hr) = Maximum Number of Cycles (cycles/hr) x Emission Factor (lb/cycle)Potential Emissions (tons/yr) = Maximum Number of Cycles (cycles/yr) x Emission Factor (lb/cycle) x 1 ton/2000 pounds

Appendix A: Emissions Calculations

VOC and CO Emissions ‐ TRU‐03

Source Modification Number:

Permit Modification Number:
Page 2 of 3 TS

Company Name: Foamex Innovations Operating Company

Address: 3005 Commercial Road, Fort Wayne, Indiana 46809

003‐30166‐00225

003‐30247‐00225

Reviewer: Anne‐Marie C. Hart

Date: February 28, 2011

Average Cycle Time

(minutes/cycle)

Maximum Number

of Cycles

(cycles/hour)

Maximum

Number of

Cycles

(cycles/year)

Benzene Emission

Factor (lbs/cycle)

Total HAPs

Emission

Factor

(lbs/cycle)

7 8.57 58800 0.31 0.40

Potential Benzene

Emissions (lb/hr)

Potential Benzene

Emissions (tons/yr)

Potential Total

HAP Emissions

(lb/hr)

Potential Total HAP

Emissions (tons/yr)

2.66 9.11 3.43 11.76

MethodologyPotential Emissions (lb/hr) = Maximum Number of Cycles (cycles/hr) x Emission Factor (lb/cycle)

Potential Emissions (tons/yr) = Maximum Number of Cycles (cycles/yr) x Emission Factor (lb/cycle) x 1 ton/2000 pounds

Emission factors based on stack testing at a similar facility in 1995 and adjusted by 71% based on the sizes of

the tested unit and the proposed unit (100.31 cubic feet/141.38 cubic feet)

Appendix A: Emissions Calculations

HAP Emissions ‐ TRU‐03

Source Modification Number:

Permit Modification Number:
Page 3 of 3 TSD App A

Company Name: Foamex Innovations Operating Company

Address: 3005 Commercial Road, Fort Wayne, Indiana 46809

003‐30166‐00225

003‐30247‐00225

Reviewer: Anne‐Marie C. Hart

Date: February 28, 2011

VOC Emission 

Factor, Ef VOC Emission

(lb/hr) (Tons/year)

FPC 0.026 0.114FPD 0.026 0.114

FPE 0.026 0.114

TOTAL: 0.342

Methodology: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)

Appendix A: Emissions Calculations

Felt Presses

Source Modification Number:

Permit Modification Number:

Emission Unit ID
Indiana Department of Environmental 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 proposed 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 controls and document the results; and 

 (e) Select BACT. 

Also 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, 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 techniques, 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 and may be consulted in searching for varied control 

alternatives for the analyzed emission sources: 
Foamex Innovations Operating 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 adTM 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 option 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 extent of applicability of each identified control 

alternative. 

 

(a) Condensation System - These systems utilize 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, collect 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 which would preclude any effective technical 

applicability of a condensation system. Condensation systems are therefore eliminated 

from further consideration in this BACT analysis because of technical infeasibility. 
Foamex Innovations Operating 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 have a track record of successful application 

for adsorbing specific VOC emissions. However, the application of the technology is 

subject to certain limitations which can negate 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 since 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 technical 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-entrainment 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, especially 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 easily regenerated or disposed of in an 

environmentally acceptable manner. 

This technology has been determined to be infeasible 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) PolyadTM System - This is an innovative system offered by a microwave technology 

vendor combining resin fluidized bed adsorption with microwave dynamic bed desorption 

that claims VOC control primarily for stripping VOCs from SVE (soil vapor extraction) 

units, air stripping at remediation sites, and solvent recovery. There are significant 

reservations regarding its technical applicability. 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 during microwave desorption; and 

4) Microwave desorption technology is not a proven technology for 

 application in the foam manufacturing and processing industry. 

In conclusion, the PolyadTM adsorption/microwave desorption technology is not 
Foamex Innovations Operating 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 feasible 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 industry 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 burning 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 infeasible 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 stream 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 vented, under controlled temperature and 

humidity, through a biologically active material. The microorganisms contained in the bed 

of compost-like material digest or biodegrade the organic to CO2 and water. This 

technology has been largely utilized for control of odorous emissions with a clearly 

speciated air stream. The process of biofilteration utilizes a biofilm containing a 

population of microorganisms immobilized on a porous 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 biotrickling 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 conditioning 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 neutralizing 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 the 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 feasible 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 organic 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 feed 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 plastic mesh spacers. The concentrated stream from the 

membrane module is returned to the compressor for further recovery in the condenser. 
Foamex Innovations Operating 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 proven application of this technology for the 

control of VOCs from a thermal reticulation unit, this technology is not considered 

available and will be eliminated from further consideration in this BACT analysis. 

(h) Ultraviolet (UV) Oxidation – UV light oxidation (or photolytic destruction) of vapor-phase 

contaminants is accomplished by passing the off-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., TiO2). The process is best used to treat 

easily oxidized organic compounds, such as those with double bonds (e.g., 

trichloroethylene, perchloroethylene and vinyl 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 useful in cleaving and ionizing certain organics 

so that they are easily removed by deionization and organic scavenging cartridges in a 

polishing loop. This technology has been proposed for off-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 concentrations. 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 TiO2 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 reservations, 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 a 

new 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 application 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 Gas 
Foamex Innovations Operating 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 incinerators 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 thermal 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 metallic substrates. Catalytic incinerators can 

achieve control device efficiencies of 95 to 99 percent. 

 From an operational standpoint, the lower reaction temperature means that the 

requirement for supplemental fuel is reduced or eliminated during normal operation. The 

lower operating temperatures will also decrease 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 VOC 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 ignited and combusted to carbon dioxide and 

water. Dilute gas streams require auxiliary fuel (generally natural gas) to sustain 

combustion. Various incinerator designs are 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 at 
Foamex Innovations Operating 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 Clearinghouse, 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 similar operations were identified as using any type 

of add-on control device, Foamex Innovations Operating 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) $25,000 
Foamex Innovations Operating 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 $400,000 
Foamex Innovations Operating 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 emissions from the thermal reticulation unit is 

prohibitive. Therefore, this level of control 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 emissions. The proper maintenance of the thermal 

reticulation unit was previously approved by IDEM 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 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. 

(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. 
Foamex Innovations Operating 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 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 cylinder 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. 

 

(L) Perform flammable fuel detector preventive maintenance per preventive 

maintenance specification 
Foamex Innovations Operating 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 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. 
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

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 Decision 

 Foamex Innovations 

 003-30247-00225 

Enclosed is the final decision and supporting materials 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 records 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 materials 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 documents, 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 think you have received this document 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 
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

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 available 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 11/30/07 

 
FACSIMILIE OF PS Form 3877 

Mail Code 61-53 

IDEM Staff DPABST 5/26/2011 

Foamex Innovations, Inc. 003-30247-00225 (Final) AFFIX STAMP 

HERE IF USED AS CERTIFICATE OF MAILING 

Name and address of Sender ► Indiana Department of Environmental Management Office of Air Quality – Permits Branch 

100 N. Senate Indianapolis, IN 46204 

Type of Mail: 

CERTIFICATE OF 

MAILING ONLY 

Line Article 

Number 

Name, Address, Street and Post Office Address Postage Handing 

Charges 

Act. Value (If Registered) 

Insured Value 

Due Send if COD 

RF

1 James Konuch Foamex Innovations, Inc. 3005 Commercial Rd Ft. Wayne IN 46809 (Source CAATS) (CONFIRM DELIVERY) 2 Richard Strozyk Plant Manager Foamex Innovations, Inc. 3005 Commercial Rd Ft. Wayne IN 46809 (RO CAATS)3 Daniel & Sandy Trimmer 15021 Yellow River Road Columbia City IN 46725 (Affected Party)4 Duane & Deborah Clark Clark Farms 6973 E. 500 S. Columbia City IN 46725 (Affected Party)5 Mr. Victor Locke WPTA-TV P.O.Box 2121 Fort Wayne IN 46801 (Affected Party)6 Fort Wayne City Council and Mayors Office One Main Street Fort Wayne IN 46802 (Local Official)7 Allen County Public Library, Waynedale Branch 2200 Lower Huntington Rd Fort Wayne IN 46809 (Library)8 Mr. John E. Hampton Plumbers & Steamfitters, Local 166 2930 W Ludwig Rd Fort Wayne IN 46818-1328 (Affected Party)9 Allen Co. Board of Commissioners One Main St. Fort Wayne IN 46802 (Local Official)10 Fort Wayne-Allen County Health Department 1 E Main Street, 5th Floor Fort Wayne IN 46802-1810 (Health Department)11 Mark Zeltwanger 26545 CR 52 Nappanee IN 46550 (Affected Party)12 13 14 15 Total number of pieces Listed by Sender 

Total number of Pieces Received at Post Office 

Postmaster, Per (Name of Receiving employee) 

The full declaration of value is required on all domestic anmaximum indemnity payable for the reconstruction of non

Mail document reconstructing insurance is $50,000 per pi

occurrence. The maximum indemnity payable on ExpresThe maximum indemnity payable is $25,000 for registereinsurance. See Domestic Mail Manual R900, S913, aninured and COD mail. See International Mail Manual fomail. Special handling charges apply only to Standard Ma