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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). 
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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.

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 
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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.

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 
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Flexible Polyurethane Foam Production Survey Form

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, Inc.

a. Address: 1400 N. Providence Road, Suite 2000

b. City: Media

c. State: PA

d. Zip: 19063

e. County: Delaware

2.Facility Name: ____Kent, WA Pouring Plant

3.Complete street address of facility (physical location):

a. Address: 19635 78th Ave South

b. City: Kent

c. State: WA

d. Zip: 98032

e. County: King

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)]: 

_____47.426106, -122.236267_____________________________

4. Facility Contact:

a. Name (First Name, Last Name): Kyle Sundarum

b. Title: Plant Manager

c. Telephone Number: (253) 872-0170 _Ext 1040________

d. Fax Number: (253) 395-1009 _

e. E-mail address: ksundarum@fxi.com

f. Primary NAICS code for the facility___326150_______________________
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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.

_______________________________________________________________

______________________________________________________________

______________________________________________________________

 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: 43 (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? None

e. Are any operations on site subject to federal and State emission standards and 

if yes, which standards?

No, the site is not required to maintain an air permit.

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.

No, the site is a minor source of HAP emissions, and has never been subject to 40 CFR Part 63 

Subpart III. The site has not utilized Methylene Chloride as a blowing agent. TRI reports 

demonstrate extremely low levels of TDI emissions. Therefore, FXI is only submitting the Owner 

Information and General Facility Information sections of the ICR for this facility.

g. Type of plant. Check all that apply.

 Molded Flexible Polyurethane Foam

 Slabstock Flexible Polyurethane Foam

 Rebond Foam Production
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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.

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
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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