United States Office of Air Quality EPA-456/B-98-001

Environmental Protection Planning and Standards December 1998

Agency Research Triangle Park, NC 27711 www.epa.gov/ttn/uatw/foam/foampg.html

EPA

Plain Language Guide to the Flexible

Polyurethane Foam Production NESHAP 

40 CFR 63, Subpart III
Plain Language Guide to the

 Flexible Polyurethane Foam Production

NESHAP 

40 CFR 63, Subpart III

Prepared for:

Information Transfer and Program Integration Division (ITPID)

Program Implementation and Review Group (PIRG)

Office of Air Quality Planning and Standards

U. S. Environmental Protection Agency

Research Triangle Park, NC 27711

Prepared by:

EC/R, Incorporated

2327 Englert Dr., Suite 100

Durham, NC 27713

December 31, 1998
i

What is the legal status of this guide?

The Office of Air Quality Planning and Standards (OAQPS) and the Office of Enforcement

and Compliance Assistance (OECA) of the U. S. Environmental Protection Agency (EPA)

have reviewed this document and approved it for publication.

When using this document, remember that it isn’t legally binding and doesn’t replace the final

rule - “National Emission Standard for Hazardous Air Pollutants for Flexible Polyurethane

Foam Production” (published in the Federal Register, 10/7/98, 63 FR 53980) or any State,

local or tribal rules that may apply to your facility.

This document isn’t intended, nor can you rely on it, to create any rights enforceable by any

party in litigation with the United States. The EPA may change this document at any time

without public notice.

This document includes only requirements from the final rule published in the Federal Register

10/7/98, 63 FR 53996.
ii

Thank You

This document was prepared by a joint partnership among the Environmental Protection

Agency (EPA, or we), State and local agencies for air pollution control, trade associations, and

organizations who produce flexible polyurethane foam. At the time of publication, the

development team had the following members:

Shaun Burke, EPA Region V

Joelle Burleson, NC DEQ

Umesh Dhloakia, EPA, Region II

Mozafar Ghaffari, EPA, Region II

Chrys Lemon, McIntyre Law Firm

Perry Luckett, The Murawski Group 

Maria Malave, EPA, OECA, OC

Janet McDonald, EC/R Incorporated

Jim McIntyre, McIntyre Law Firm

Phil Norwood, EC/R Incorporated

Barrett Parker, EPA, OAQPS, ITPID

Lou Peters, Polyurethane Foam Association

Stephen P. Risotto, Halogenated Solvents Industry Alliance, Inc.

David Svendsgaard, EPA, OAQPS, ESD

Jim Szykman, EPA, OAQPS, ESD

Dianne Walker, EPA, Region III

Ingrid Ward, EPA, OAQPS, ITPID

Mary Ann Warner, EPA, OAQPS, ITPID

We thank those people for their participation. Their technical insights, experiences, and

suggestions were essential to this guide’s development.
iii

Contents

Chapter 1 - Introduction

Why should I use this document? ....................................... 1

Is there anything I should know before using this document? .................... 1

How do I get copies of this document? ...................................... 1

We want your feedback ................................................. 2

Chapter 2 - What this rule covers - An Overview

Why was the rule written? ............................................ 4

How do I know if I’m subject to this rule? ................................... 4

When do I need to comply? .............................................. 5

Are any processes exempt? ............................................... 5

How do I know if I have a covered process? .................................. 6

Does this rule apply to fabrication of foam? .................................. 6

What are my requirements for slabstock foam? ................................ 6

What are my requirements for molded and rebond foam? ........................ 7

Chapter 3 - Complying with requirements for slabstock foam

What do the Slabstock sections of the rule cover? ......................... 8

What is exempt under these sections of the rule? ............................... 10

What compliance options do I have? ........................................ 10

What monitoring must I do? .................................. 11

What records must I keep? ................................... 12

What reports must I submit? ............................................. 13
iv

Contents

What test methods am I required to use? ..................................... 14

How do I show compliance? .............................................. 14

Is an inspection checklist available? ........................................ 14

Chapter 4 - Complying with requirements for molded foam

What does the Molded section cover? ....................................... 66

What is exempt under this section? ......................................... 66

What compliance options do I have? ........................................ 68

What monitoring must I do? .............................................. 68

What records must I keep? ............................................... 69

What reports must I submit? ............................................. 69

How do I show compliance? .............................................. 69

Is an inspection checklist available? ........................................ 69

Chapter 5 - Complying with requirements for rebond foam

What does the Rebond section cover? ....................................... 72

What is exempt under this section? ......................................... 72

What compliance options do I have? ........................................ 74

What monitoring must I do? .............................................. 74

What records must I keep? ............................................... 75

What reports must I submit? ............................................. 75

How do I show compliance? .............................................. 75

Is an inspection checklist available? ........................................ 75
v

Contents

Chapter 6 - Calculations and procedures

How do I calculate Hazardous Air Pollutants used (HAPused) to see if I’m 

exempt from the rule? .................................................. 77

How do I calculate HAP Auxiliary Blowing Agent (ABA) 

formulation limit for a grade of foam? ...................................... 80 

How do I calculate allowable HAP ABA emissions to comply using

the emission point specific limit? .......................................... 82

If I’m complying using the emission point specific limit without a recovery device, 

how do I calculate actual monthly HAP ABA emissions? ........................ 86

If I’m complying with the emission point specific limit using a recovery device, 

how do I calculate actual emissions? ....................................... 88

If I’m complying with the sourcewide emission limit, 

how do I calculate allowable emissions? ..................................... 90

If I’m complying with the sourcewide emission limit without using a recovery device, 

how do I calculate actual sourcewide HAP emissions? .......................... 91

If I’m complying with the sourcewide emission limit using a recovery device, 

how do I calculate actual emissions? ....................................... 92

How can I check my slabstock process for leaks? .............................. 95

Chapter 7 - Notification and reporting 

What do I have to report and when? ........................................ 99

How can I change the date my reports are due? ................................ 99

Where do I send my reports? ............................................. 99

Where do I submit my Alternative Program? ................................. 100

Can I get example reporting forms? ........................................ 101

Initial Notification Report ............................................ 101

Application for Approval of Construction or Reconstruction .................. 110

Precompliance Report ............................................... 115
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Contents

Notification of Compliance Status ...................................... 121

Semiannual Compliance Report ........................................ 124 

Change in Selected Emission Limit and Compliance Method .................. 128 

Annual Compliance Certification ....................................... 129 

Chapter 8 - Other requirements and information

Who administers this regulation? .......................................... 130

Do I need a title V permit? ............................................... 130

How do I change my permit to include this rule? ............................... 131

What portions of the General Provisions apply? ............................... 131

Chapter 9 - Getting additional help

Where do I go for help? ................................................. 132

Can I get more information on the Web? ..................................... 133

Is there a list of commonly asked questions? .................................. 135

Chapter 10 - Supplemental information for State or local agencies and

Tribes

How many plants may need to meet emission limits? ............................ 136

Are plants in Indian Country regulated by the State? ............................ 136

How much HAP emissions will the rule reduce? ............................... 137

Figures

Figure 3.1 - A Typical Process for Slabstock foam Production ........................ 9

Figure 3.2 - Option 1, Emission Point Specific Limit ........................... 15

Figure 3.3 - Option 2, Sourcewide Emission Limit ............................. 16
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Contents

Figure 3.4 - Option 1 and 2, Diisocyanate Emissions ........................... 17

Figure 3.5 - Option 1, HAP ABA Equipment Leaks ............................ 18

Figure 4.1- A Typical Process for Molded foam Production ...................... 67

Figure 5.1- A Typical Process for Rebond foam Production ...................... 73

Figure 10.1 - Slabstock Flexible Polyurethane-Foam Plants ...................... 141

Tables

Table 3.1 - Monitoring Requirements for Slabstock foam Production ............... 19

Table 3.2 - Recordkeeping Requirements for Slabstock foam Production ............ 28

Table 3.3- Checklist for Inspecting Slabstock foam Plants ....................... 38

Table 4.1- Checklist for Inspecting Molded foam Plants ......................... 70

Table 5.1- Checklist for Inspecting Rebond foam Plants ......................... 76

Table 6.1 - Foam Grades Produced by The Example Facilities .................... 96

Table 6.2 - HAP ABA Formulation Limits for Foam Grades

Produced by The Example Facilities ........................................ 97

Table 6.3 - Allowable HAP ABA Emissions for Foam Grades

Produced by The Example Facilities ........................................ 98

Table 7.1- Report due dates .............................................. 102

Table 7.2 - Reporting Requirements ........................................ 104

Table 9.1 - EPA Regional Air Division Offices ............................... 134

Table 10.1 - 1993 U.S. Slabstock foam Plant List ............................. 138

Appendices

A - Contents for Subpart III, Final Rule ..................................... 142
1

Chapter 1 - Introduction

Why should I use this document?

This document can help plant owners and operators (you) understand the Flexible Polyurethane

Foam Production NESHAP (also known as Subpart III) by helping you determine four main

things:

C if the rule applies to your plant and process

C what compliance options are available

C what to monitor, record and report

C dates by which you must meet requirements

Is there anything I should know before using this document?

When using this document, remember that it doesn’t replace the final rule and covers only

requirements published on or before 12/31/98. You should keep up with new requirements printed

after this date by periodically checking the

Federal Register and the Code of Federal

Regulations (CFR). You can download

Federal Register notices by going to the

Government Printing Office (GPO) website

at www.access.gpo.gov/su_docs/aces/aces140.html. 

We’ve included a copy of the final rule in Appendix A (as published in the Federal Register,

10/7/98, 63 FR 53980), so you can reference the rule while you’re using this document. 

How do I get copies of this document?

You can get copies of this document in four ways:

C EPA’s Unified Air Toxics Website (www.epa.gov/ttn/uatw). Look under Rules and

Implementation, flexible polyurethane foam, or www.epa.gov/ttn/uatw/foam/foampg.html

C Library Services Office, (MD-35), U.S. EPA, Research Triangle Park, NC 27711, or

www.epa.gov/natlibra/ols.html (limited supply)

Keep informed of rule changes by checking the

Federal Register
2

C National Technical Information Services (NTIS), 5285 Port Royal Road, Springfield, VA

22161, or 1-(800)- 553-6847, or www.fedworld.gov/ntis/ntishome.html (NTIS will charge

you a fee for this document)

• National Center for Environmental Publications and Information, 1-(800)-490-9198 or

www.epa.gov/ncepihom/index.html

We want your feedback

To serve you better, we’ve included a survey on the usefulness of this document. If you’d like to

participate, please fill out the survey on page 3 and return it to the address indicated. We’ll keep

your responses confidential if you desire, but use them to help us improve future documents.

Help us publish better documents by filling out our

survey
3

Survey on the Plain Language Guide to the Flexible Polyurethane Foam

Production NESHAP

Please help us gauge this document’s usefulness by completing this short form. We’ll keep your responses confidential if you

desire, but use them to help improve future documents. Check this box if you would like us to keep your responses

confidential Q

1. What type of business do you work for? (check one of the following)

Manufacturing Q Contractor Q Tribe Q Government (specify Federal, State, local) _______

Other __________

2. What are your job responsibilities? (check any that apply)

Plant Operator Q Maintenance Q Plant Manager Q Environmental Staff Q

Regulator Q Other: ____________

3. How did you hear about this guidance? (check any that apply)

Co-worker Q EPA TTN via dial up modem Q EPA TTN via the Web Q Other _____________

Please check the box under the number that most closely shows your agreement with the following statements

1= Strongly Agree to 5 = Strongly Disagree

Statement 1 2 3 4 5 N/A

The guidance was timely.

The document provides a good overview of the rule.

The document provides the type of information my organization needs to comply.

The guidance helped us achieve compliance more quickly than if we had developed our

own.

We have incorporated parts of this document into our own policy documents.

The format of this document was well organized and easy to understand.

4. What did you like about this document or what helped you the most? (be as specific as you can) _____________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

5. What did you not like about this document or what helped you the least? (be as specific as you can) __________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

6. What would you change about this document (e.g. formats; excluding information or including things that you didn’t 

see in the document)? _____________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

7. Overall, did you find this document to be:

extremely useful Q very useful Q so-so useful Q not useful at all Q

8. Other comments: ______________________________________________________________________________________

Provide additional comment on the back of this form or on a separate sheet of paper.

Return survey to: ATTN: Flexible Polyurethane Foam Implementation Contact, U.S. Environmental Protection Agency (EPA),

Research Triangle Park (RTP) MD-12, Research Triangle Park, NC 27711, or fax (919) 541-2664
4

Chapter 2 - What this rule covers - An Overview

Why was this rule written?

We wrote the rule to reduce emissions of hazardous air pollutants and achieve the environmental

benefits intended by the Clean Air Act (CAA) of 1990. 

Our research has shown that emissions from a typical production plant may include a number of

HAPs. We’ve estimated that methylene chloride accounts for more than 98 percent of the total

HAP emissions from flexible polyurethane foam plants and is the primary HAP affected by the

rule.

Some of the HAPs that might be emitted during the production of flexible polyurethane foam

include:

• methylene chloride

• 1,2- propylene oxide

• 2,4- toluene diisocyanate

• diethanolamine 

• methanol

C methyl chloroform

C methylene diphenyl diisocyanate

C methyl ethyl ketone

C toluene

How do I know if I’m subject to this rule?

You’re subject to this rule if your plant meets all of the following:

C is a major source of HAPs

C produces flexible polyurethane (slabstock or molded) or rebond foam

C emits a HAP

C doesn’t qualify for one of the exemptions

For a list of regulated HAPs, check our Unified Air Toxics Website (UATW) at

http://www.epa.gov/ttn/uatw/188polls.txt.
5

If you have an enforceable limit on your facility that restricts your emissions to ‹10 tons per year

of any single HAP and ‹25

tons per year of multiple

HAPs, your facility would not

be a major source and not

subject to this rule. If,

however, you determine that

you’re a major source, some processes at your plant may still be exempt from the rule. These

exemptions are listed below.

When do I need to comply?

If your facility is an existing source, you must comply by 10/8/01, which is three years and a day

after the rule’s effective date of 10/7/98. The effective date is the date the final rule was published

in the Federal Register. If you’re a new source, comply before you begin operating.

If your initial startup

is . . . 

Then you’re1. . . And must comply . . .

on or before 12-27-96 an existing source by 10/8/01

after 12-27-96 a new source upon initial startup

1When determining if a source is new or existing, the General Provisions (40 CFR 63,

Subpart A, §63.2) requires us to use the proposal date of the rule as the cut-off date. In

the case of Subpart III, the rule was proposed on 12/27/96. 

Are any processes exempt from the rule?

Your process is exempt if it’s any of the following:

C a research and development process

C exclusively dedicated to fabricating flexible

polyurethane foam

C a slabstock foam operation where your plantwide

HAPs used are less than five tons per year. You must use §63.1290(c)(3) to calculate

HAP used. 

Your facility is a major source if it can potentially emit $10

tons per year of a single HAP or $ 25 tons per year of all HAPs.

If your process is exempt, make

sure you document why it’s

exempt
6

This last exemption - the slabstock foam operation where your whole facility (plantwide) uses less

than five tons per year (tpy) of HAP, is based on your usage of HAP, rather than the amount of

HAP emitted. You can claim this exemption only if your slabstock foam production and foamfabrication processes are the only processes at the plant site that emit HAP and emissions from

your facility are ó5 tpy. The exemption applies only to Subpart III and does not effect other CAA

rules, for example other NESHAPs that apply to your facility. See Chapter 6 for an example of

how to calculate this exemption.

Note: Although foam fabrication isn’t covered by the rule, you’ll need to include emissions

from your fabrication process to claim this exemption.

How do I know if I have a covered process?

The rule defines the terms "flexible polyurethane foam production,” “slabstock,” “molded,” and

“rebond” foam based on a typical process. Compare your process with these definitions in the

rule.

If your operation doesn’t fit one of the definitions exactly, use your judgment and talk to your

State, local or Tribal agency for air pollution control. If all else fails, your EPA Regional Office

can help you render a judgement on applicability.

Does this rule apply to fabrication of foam?

Your process for fabricating flexible polyurethane foam will fall under a different rule - the

Flexible Polyurethane Foam Fabrication NESHAP. We expect to publish this rule in 2000.

What are my requirements for slabstock foam?

The rules for producing slabstock foam cover the two major uses of HAP in the slabstock process:

C diisocyanates used as a reactant in making foam

C HAP used as an auxiliary blowing agent (ABA) and for

equipment cleaning

See Chapter 3 for

details about your

compliance options

for slabstock foam

Definition. The rule defines “foam fabrication” as a operation for

cutting or bonding flexible polyurethane foam pieces together or to

other substrates. Typical bonding techniques include gluing, taping,

and flame lamination.
7

You must control diisocyanate emissions from all of the following types of equipment:

C storage vessels

C transfer pumps

C other components in service (such as connectors, valves, pressure-relief devices, etc.)

You must control HAP ABA emissions from all of the following equipment and processes:

C storage vessels

C equipment leaks

C the production line

C equipment cleaning

Depending on which compliance option you choose, you’ll have to meet one or more of the

following requirements:

C use control equipment

C meet limits on point or sourcewide emissions

C restrict or eliminate the use of some materials

C inspect and monitor equipment for leaks

What are my requirements for molded and rebond foam?

If you have a molded or rebond foam plant,

you can’t use a HAP or HAP-based

products to clean your equipment or use it

as a mold-release agent. 

The only exception is your molded foam plant using diisocyanates during startup or maintenance to

flush the mixhead and associated piping. If you use diisocyanates for flushing, you must contain

the diisocyanate in a closed-loop system and reuse it in production. 

See Chapter 4 & 5 for details about your

compliance options for molded and rebond foam

Definition. The rule defines diisocyanate as 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).
Chapter 3 - Complying with requirements for slabstock foam

8

Definition. 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.”

Definition. Slabstock flexible polyurethane foam

production line means “all portions of the flexible

polyurethane foam process from the mixhead to the point

in the process where the foam is completely cured.”

Definition. Flexible polyurethane foam process means

”equipment used to produce a flexible polyurethane foam

product. It includes raw material storage; production

equipment and associated piping, ductwork, etc.; and

curing and storage areas.”

What do the Slabstock sections of the rule cover?

Your slabstock foam production plant is covered under §§63.1293-1299 of the rule if your process

meets all of the following conditions:

C emits a HAP

C is a slabstock foam production process

C is located at a plantsite that is a major source of HAPs

C is not exempt

The slabstock sections of the rule cover vessels for storing diisocyanates, pumps for transferring

them, and other diisocyanate components you have in service (such as connectors, valves, pressurerelief valves, etc.) These sections also cover vessels for storing HAP auxiliary blowing agents

(ABA), HAP ABA equipment leaks, HAP ABA emissions from the production line, and HAP

ABA emissions from equipment cleaning.

Figure 3.1 (on page 9) shows a typical process for producing slabstock foam.

About this Chapter:

C Whenever you see “§,”

we are referring to the

section number of the

rule. You can go to that

section in the rule for

more information

C When you see a

definition, it comes

straight from the rule
9
10

Definition. 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 or products for commercial

sale except in a de minimis manner.”

Definition. Foam fabrication process means “an operation for cutting or bonding flexible

polyurethane foam pieces together or to other substrates.”

What is exempt under these sections of the rule?

Your slabstock facility is exempt from the rule if HAP used at your foam production and

fabrication facility is no more than five tons per year or if your process exclusively does either of

the following [§63.1290]: 

• fabricates foam 

C does research and development

You must use §63.1290(c)(3) of the rule (Equation 1) to calculate if your facility uses less than

five tons per year HAP. Your facility will be able to take the five ton per year exemption only if 

your slabstock foam production and foam fabrication note processes are the only processes at the

plant site that emit HAP. See Chapter 6 for examples on how to calculate this exemption.

Note: Although foam fabrication isn’t covered by the rule, you’ll need to include

emissions from your fabrication process to claim this exemption.

What compliance options do I have?

If you produce slabstock foam, you have three main regulatory options: 

• Option 1: meet limits on HAP Auxiliary Blowing Agent (ABA) emissions (e.g. emission

point specific limit) and control diisocyanate emissions [§§63.1295 - 63.1298, §63.1294]

C Option 2: meet a sourcewide emission limit and control diisocyanate emissions. Option 2

applies to plants that use only one HAP as an ABA and an equipment cleaner [§63.1299,

§63.1294]

• Option 3: request an alternate means of emission limitation under §63.1305(d). Your

request may be submitted in your Precompliance Report, your Application for Approval of 

Construction or Reconstruction, or at any other time. See Chapter 7 for additional

information [§63.1305(d), §63.1309(b)]
11

To summarize, your options are as follows:

If ... And you ... Then use the following options ... For more

information,

see figures ...

your slabstock

foam plant is

regulated under

Subpart III

use multiple

HAPs as an

ABA and

equipment

cleaner

Option 1: comply with §63.1294

(diisocyanate emissions) 

and

§63.1295 through 63.1298 (emission

point specific limits)

3.2, 3.4 and

3.5

use only one

HAP as an ABA

and equipment

cleaner

Option 2: comply with §63.1294

(diisocyanate emissions)

and 

§63.1299 (sourcewide emission limit)

3.3 and 3.4

want to use an

alternative

means of

emission

limitation

Option 3: comply with §63.1305

(alternative means of emission

limitation)

Not in table,

see

§63.1305(b)

Your specific requirements under Options 1 and 2 differ based on the type of equipment or

processes at your plant. Depending on the option you choose, you may be required to monitor one

or more pieces of equipment or processes. Each equipment or process you monitor may have

subsequent options you can choose. Clearly understanding all your available options and suboptions can get confusing. To help you understand your choices, we’ve included several figures.

Figure 3.2 (on page 15) outlines your requirements if you choose Option 1. Figure 3.3 (page 16)

outlines your requirements if you choose Option 2. Finally, Figure 3.4 (page 17) outlines your

requirements for controlling diisocyanate emissions under Options 1 and 2. 

What monitoring must I do?

Your monitoring requirements will depend on the compliance options you select. If you choose

Option 1, your main types of monitoring include one or more of the following:

C diisocyanate equipment leaks and repairs made on transfer pumps and other components in

diisocyanate service [§63.1294(b)]

• HAP ABA and diisocyanate vapor balancing (vapor-return line) used for storage vessels

[§63.1295(b), §63.1294(a)]

C HAP ABA and diisocyanate carbon-adsorption systems used for storage vessels 

[§63.1295(c), §63.1303(a), §63.1294(a)]
12

C HAP ABA and polyol added to the foam production line at the mixhead OR an alternate

monitoring program under §63.1303(b)(5) [§63.1303(b), §63.1303(b)(5)] 

C HAP ABA recovery monitoring device used (you must develop a monitoring program and

get it approved prior to it’s use) [§63.1303(c), §63.1303(c)(6)]

C HAP ABA level in storage vessels [§63.1303(d)]

C HAP ABA added to storage vessels OR an alternate monitoring program under

§63.1303(e)(4) [§63.1303(e), §63.1303(e)(4)]

C Equipment leaks and repairs made to HAP ABA pumps, valves, connectors, pressurerelief devices, and diisocyanate transfer pumps and other components in diisocyanate

service [§63.1296(a)-(e), §63.1294(b)]

If you choose the alternative monitoring program for HAP ABA and polyol added to the

foam production line at the mixhead, you’ll need to request and obtain approval from the EPA

before you use your alternate. This is because we’ve chosen not to delegate §63.1303(b)(5) to

your State, local or Tribal agency for air pollution control. See Chapter 7 for additional

information [§63.1303(b)(5), §63.1309(b)].

Also see Chapter 7 for information on where to submit your alternative monitoring program

for HAP ABA added to storage vessels, and, where to submit your HAP ABA recovery

monitoring program [§63.1303(e)(4), §63.1303(c)(6)].

If you choose Option 2, your main types of monitoring include one or more of the following:

C diisocyanate vapor-balancing used for storage vessels [§63.1294(a)]

C diisocyanate carbon-adsorption systems used for storage vessels [§63.1294(a)]

C diisocyanate equipment leaks and repairs made on transfer pumps and other components in

diisocyanate service [§63.1294(b)]

C emissions from HAP ABA storage vessels, equipment leaks, the production line and

equipment cleaning [§63.1299]

C emissions from recovery devices [§63.1299(e)]

§63.1303 of the rule explains the requirements for each type of monitoring, except for vapor

balancing and leak detection and repair, which are in §63.1294-1296. Table 3.1 (on page 19) also

gives you details about your monitoring requirements under Option 1 and 2.

What records must I keep?

For slabstock-production, you must keep one of more of the following types of information:
13

C records on storage vessels

C records on equipment leaks

C records on HAP ABA and polyol added to

equipment

C records on recovery devices

C copies of data sheets on equipment cleaners

C records on your use of vapor-return lines

The types of records required depend on whether you decide to comply with a specific emission

point (Option 1 - emission point specific limit) or the sourcewide limits (Option 2). Your

recordkeeping will also vary according to the control options you’re using. Table 3.2 (on page 28)

details these recordkeeping requirements as does §63.1307 of the rule.

What reports must I submit?

You must submit up to seven types of reports on each slabstock foam plant:

C an initial notification sent in within 120 days after the effective date of the rule

[§§63.1306(a), 63.9(b)]

C an application for approval for construction or reconstruction sent in as soon as practical

before construction [§§63.1306(b), 63.5(d)]

C a pre-compliance report sent in at least 12 months prior to the rule’s compliance date 

[§63.1306(c)]

C a notification of compliance status sent in within 180 days after the rule’s compliance date 

[§63.1306(d)]

C semiannual compliance reports sent in within 60 days after each 180 day period, with the

first report due 240 days after the notification of compliance status [§63.1306(e)]

• an annual compliance certification sent in yearly [§63.1306(g)]

The seventh report is also necessary if want to change the option you are using to meet the

emission limit or compliance method. You must send a notification of your intent to switch options

at least 180 days prior to making the change [§63.1306(f)]. For example, if you wanted to switch

from the rolling-annual to the monthly compliance method for your HAP ABA production line,

you’d need to make notification at least 180 days prior to making the change. 

Chapter 7 gives you more details on the reporting requirements above, as well as additional

reporting information including dates and example forms. The forms are optional, but you may

find them useful.

Maintain records for at

least five years
14

What test methods am I required to use?

You’ll need to use the following two test methods if you produce Slabstock foam: 

C use EPA Test Method 21 to monitor leaks from HAP ABA pumps, valves, connectors,

pressure-relief devices, and open-ended valves or lines [§63.1304(a)]

C use the American Society for Testing and Materials (ASTM) D3574 to determine the

density and IFD of each grade of foam produced [§63.1304(b)]

You can download a list of the latest ASTM versions by going to www.astm.org and

clicking on “Search for ASTM standards,” then continue as prompted. You can also order

ASTM methods by calling (610) 832-9585.

How do I show compliance?

You can show compliance with §§63.1293-1299 by doing all of the following:

• control diisocyanate emissions from storage vessels, transfer pumps, and other components

using the options in Figure 3.4 [Option 1 and 2, §63.1294]

C control HAP ABA emissions from either one of the following:

< storage vessels, equipment leaks, the production line, and equipment cleaning as

described in Figures 3.2 and 3.5 (e.g. emission point specific limit) [Option 1,

§63.1295 - 1298]

OR

< your entire slabstock production process if you use only one HAP as an ABA and

an equipment cleaner (e.g. sourcewide emission limit) as described in Figure 3.3

[Option 2, §63.1299] 

C do the monitoring described in Table 3.1

C maintain the records described in Table 3.2

C submit the reports described in Chapter 7

You must meet all of these requirements, otherwise, you’ll be in violation of §§63.1293-1299. 

Check §63.1308 of the rule for more information.

Is an inspection checklist available?

We’ve included an inspection checklist in Table 3.3 (on page 38) to help you check your slabstock

foam plant for compliance with the rule.
15

Figure 3.2

Option 1

Emission Point Specific Limit

See separate PDF file
16

Figure 3.3

Option 2

Sourcewide Emission Limit

See separate PDF file
17

Figure 3.4

Option 1 and 2

Diisocyanate Emissions

see separate PDF file
18

Figure 3.5

Option 1

HAP ABA Equipment Leaks

see separate PDF file
19

Table 3.1 Monitoring Requirements for Slabstock foam Production

If your emission

 point is . . . . 

And you have

chosen, as your 

overall

compliance

strategy, the . . . 

And you are

using the

following control

option . . . Then you must monitor as described below . . . 

According to

these sections of

the rule ... 

Diisocyanate

storage vessels

(Option 1 or 2)

Emission point

specific limit 

OR

Sourcewide emission

limit 

Vapor balance Look, listen, and otherwise check for leaks in the vapor-return line each time diisocyanate is

unloaded from a tank truck or rail car into the storage tank.

Repair leaks found before the next unloading event.

§63.1294(a)(1)(i)

§63.1294(a)(1)(ii)

Carbon-adsorber Measure HAP or organic concentrations in the exhaust-vent stream or outlet stream’s exhaust

from the carbon-adsorption system during each unloading of diisocyanate from a tank truck or

rail car. If diisocyanate is unloaded more often than once a month, you must monitor only one

unloading event per month. 

OR

Instead of monthly monitoring, you can monitor at the frequency you’ve established during the

design analysis as long as the monitoring is performed within 20 percent of the carbon

replacement interval.

Measure HAP concentration using 40 CFR part 60, Appendix A, Method 18 over at least a 5-

minute period while the storage vessel is being filled .

Measure organic concentration using 40 CFR part 60, Appendix A, Method 25A over at least a

5-minute period while the storage vessel is being filled.

You must replace existing carbon with fresh carbon prior to the next unloading event if you

detect breakthrough.

§63.1303(a)(1)

§63.1303(a)(2)

§63.1303(a)(3)

§63.1303(a)(4)

§63.1294(a)(2)
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont’d)

If your emission

 point is . . . . 

And you have

chosen, as your 

overall

compliance

strategy, the . . . 

And you are

using the

following control

option . . . Then you must monitor as described below . . . 

According to

these sections of

the rule ... 

20

Transfer pumps

in diisocyanate

service

(Option 1 or 2)

Emission point

specific limit

OR

Sourcewide emission

limit

Sealless pump None

Submerged pump Immerse each pump in bis(2-ethylhexyl)phthalate (DEHP, CAS#118-81-7),

2(methyloctyl)phthalate (DINP, CAS #68515-48-0), or another neutral oil.

Look at each pump at least once a week to be sure it isn’t leaking.

If you find a leak, attempt your first repair within 5 calendar days and repair it within 15

calendar days unless you have determined that your equipment meets the delay of repair

allowances in §63.1294(d)

Note: First attempt at repair should include tightening of packing gland nuts and checking

the seal flush to see if it is operating at design temperature and pressure.

§63.1294(b)(2)(i)

§63.1294(b)(2)(ii)

§63.1294(b)(2)(iii)
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont’d)

If your emission

 point is . . . . 

And you have

chosen, as your 

overall

compliance

strategy, the . . . 

And you are

using the

following control

option . . . Then you must monitor as described below . . . 

According to

these sections of

the rule ... 

21

Other

components in

diisocyanate

service

(Option 1 or 2)

Emission point

specific limit

OR

Sourcewide emission

limit

N/A None, but if you find a leak, you must make your first attempt to repair it within 5 calendar days

and repair it within 15 calendar days unless you have determined that your equipment meets the

delay of repair allowances in §63.1296(f)

§63.1294(c)

HAP ABA

storage vessels

(Option 1)

Emission point

specific limit

Vapor balancing or

carbon-adsorber

Monitor the amount of HAP ABA in the storage vessel weekly using a level-measurement

device. Calibrate the level-measurement device initially and at least once per year. Unless you

visually read the device with permanent graduated marks, such as for a gauge glass, the device

must have either a digital or printed output.

Monitor the amount of HAP ABA added to the storage vessel each time there is a delivery. You

may determine the amount of HAP ABA added by using a level-measurement device, monitoring

the flow rate, or measuring the weight. If the amount of HAP ABA added is determined using a

scale, it must be approved by your State or local agency or checked once per year by a registered

scale technician. §63.1303(e) describes each of these options.

The rule also allows you to develop and submit for approval an alternative monitoring plan for

determining the amount of HAP ABA added to the storage vessel.

 §63.1303(d)

§63.1303(e)

§63.1303(e)(4)
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont’d)

If your emission

 point is . . . . 

And you have

chosen, as your 

overall

compliance

strategy, the . . . 

And you are

using the

following control

option . . . Then you must monitor as described below . . . 

According to

these sections of

the rule ... 

22

Vapor balance Look, listen, and otherwise check for leaks in the vapor-return line each time the HAP ABA is

unloaded from a tank truck or rail care into the storage tank.

If you detect a leak, repair it by the next unloading event.

§63.1295(b)(1)

§63.1295(b)(2)

Carbon-adsorber Measure HAP or organic concentrations in the exhaust-vent stream or outlet stream’s exhaust

from the carbon-adsorption system during each unloading of diisocyanate from a tank truck or

rail car. If diisocyanate is unloaded more often than once a month, you must monitor only one

unloading event per month.

OR

Instead of monthly monitoring, you can monitor at the frequency you’ve established during the

design analysis as long as the monitoring is performed within 20 percent of the carbon

replacement interval.

Measure HAP concentration using 40 CFR part 60, Appendix A, Method 18 over at least a 5-

minute period while the storage vessel is being filled .

Measure organic concentration using 40 CFR part 60, Appendix A, Method 25A over at least a

5-minute period while the storage vessel is being filled.

You must replace existing carbon with fresh carbon prior to the next unloading event if you

detect breakthrough.

§63.1303(a)(1)

§63.1303(a)(2)

§63.1303(a)(3)

§63.1303(a)(4)

§63.1295(c)
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont’d)

If your emission

 point is . . . . 

And you have

chosen, as your 

overall

compliance

strategy, the . . . 

And you are

using the

following control

option . . . Then you must monitor as described below . . . 

According to

these sections of

the rule ... 

23

HAP ABA

equipment leaks,

pumps

(Option 1)

Emission point

specific limit 

Sealless pump None

Other types of 

pumps

Monitor each pump quarterly using EPA Method 21 to detect leaks. If you measure an

instrument reading of 10,000 parts per million (ppm) or more, you have a leak.

Look at each pump every calendar week to see if liquids are dripping from the pump’s seal.

If you find a leak, attempt your first repair within 5 calendar days and repair it within 15

calendar days unless you’ve determined your pump meets the delay of repair under §63.1296(f).

Note: Your first attempt to repair should include tightening of packing land nuts and

ensuring the seal flush is operating at it’s design pressure and temperature.

§63.1296(a)(2)(i); 

§63.1304(a)

§63.1296(a)(2)(ii)

§63.1296(a)(2)(iii)

HAP ABA

equipment leaks,

valves

(Option 1)

Emission point

specific limit

Valves not

designated as

Unsafe-to monitor

or

Difficult-to-monitor

Monitor each valve quarterly using EPA Method 21 to detect leaks. If you measure an

instrument reading of 10,000 parts per million (ppm) or more, you have a leak.

If you find a leak, attempt your first repair within 5 calendar days and repair it within 15

calendar days unless you have determined that your equipment meets the delay of repair

allowances in §63.1296(f).

Note: Your first attempt to repair should include tightening of bonnet bolts, replacement of

bonnet bolts, tightening gland nuts and lubricating the packing.

§63.1296 (b)(1);

§63.1304(a)

§63.1296(b)(2)
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont’d)

If your emission

 point is . . . . 

And you have

chosen, as your 

overall

compliance

strategy, the . . . 

And you are

using the

following control

option . . . Then you must monitor as described below . . . 

According to

these sections of

the rule ... 

24

Unsafe-to-monitor

valves 

Unsafe-to-monitor valves are those where monitoring could expose personnel to an immediate

danger situation. You must have a written plan for monitoring valves identified as unsafe-tomonitor. Monitor and repair leaks according to the written plan, which is at least as soon as

practicable. 

§63.1296(b)(3)

Difficult-to-monitor

valves

Difficult-to-monitor valves are those where the valve cannot be monitored without elevating the

monitoring personnel more than 2 meters above a support surface or where the valve is not

accessible at any time in a safe manner. You must have a written plan for monitoring valves

identified as difficult-to-monitor. Monitor and repair leaks according to the written plan, which

is at least once every calendar year. 

§63.1296(b)(4)

HAP ABA

equipment leaks,

connectors 

(Option 1)

Emission point

specific limit

Connectors not

designated as

Unsafe-to monitor

or

Unsafe-to-repair

Monitor each connector annually using EPA Method 21 to detect leaks.

If the connector has been opened or the seal is broken, you must monitor it using EPA Method 21

no later than 3 months after you start using it again.

Whenever you repair a connector, you must monitor it using EPA Method 21 for leaks within 3

months after the repair.

If you find a leak, attempt your first repair within 5 calendar days and repair it within 15

calendar days unless you have determined that your equipment meets the delay of repair

allowances in §63.1296(f).

§63.1296(c)(1)(i); 

§63.1304(a)

§63.1296(c)(1)(ii);

§63.1304(a)

§63.1296(c)(1)(iii);

§63.1304(a)
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont’d)

If your emission

 point is . . . . 

And you have

chosen, as your 

overall

compliance

strategy, the . . . 

And you are

using the

following control

option . . . Then you must monitor as described below . . . 

According to

these sections of

the rule ... 

25

Unsafe-to-monitor Unsafe-to-monitor valves are those where monitoring could expose personnel to an immediate

danger situation. You must have a written plan for monitoring connectors identified as unsafeto-monitor. Monitor and repair leaks according to the written plan, which is at least as soon as

practicable.

§63.1296(c)(3)

Unsafe-to-repair Unsafe-to-repair valves are those where repair personnel would be exposed to an immediate

danger situation. You must have a written plan for monitoring connectors identified as unsafe-torepair. Monitor and repair leaks according to the written plan, which is at least within 6 months

after the leak was detected. 

§63.1296(c)(4)

HAP ABA

equipment leaks,

pressure-relief

devices

(Option 1)

Emission point

specific limit

N/A None, unless you see, hear, or smell a leak. If you detect a leak, then you must monitor within 5

days using EPA Method 21. If you measure an instrument reading of 10,000 parts per million

(ppm) or more, you have a leak.

If you find a leak, attempt your first repair within 5 calendar days and repair it within 15

calendar days unless you have determined that your equipment meets the delay of repair

allowances in §63.1296(f).

§63.1296 (d)(1);

§63.1304(a)

§62.1296(d)(2)

HAP ABA

equipment leaks,

open-ended

valves or lines

(Option1)

Emission point

specific limit

N/A None, but you must make sure that a cap, blind flange, plug, or second valve is appropriately

sealed, except for emergency-shutdown system, at all times when you’re not operating,

maintaining or repairing the system. If your valve or line has a second valve, make sure that the

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

§63.1296(e)
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont’d)

If your emission

 point is . . . . 

And you have

chosen, as your 

overall

compliance

strategy, the . . . 

And you are

using the

following control

option . . . Then you must monitor as described below . . . 

According to

these sections of

the rule ... 

26

HAP ABA

Production line

(Option 1)

Emission point

specific limit,

rolling annual or

monthly compliance

alterative

(You must make

notification to switch

between the monthly

and yearly

alternatives)

Recovery device Monitor the cumulative amount of HAP ABA recovered by the solvent-recovery device each

month using equations 2 and 4.

You must submit a HAP ABA monitoring and recordkeeping program for approval. The program

must contain information found in §63.1303(c)(1)-(5). 

§63.1297(e);

§63.1297(e)(1)

§63.1303(c)(6)

All options other

than recovery

device

Continuously monitor the amount of HAP ABA and polyol added at the mixhead when foam is

being poured. For polyol added to the mixhead, you can use pump revolutions or flow rate for

the measurement. For HAP ABA added to the mixhead, you can use flow rate. You must

measure at the beginning and end of the production of each grade of foam within a run of foam. 

The rule also allows you to develop and submit for approval an alternative monitoring plan for

determining the amount of HAP ABA and polyol added to the foam production line at the

mixhead. The plan must be approved by the EPA prior to it’s use.

§63.1297(b); 

§62.1297(c); 

§63.1303(b)

§63.1303(b)(5)

HAP ABA

equipment

cleaning

(Option 1)

Emission point

specific limit

NA None, but you must make sure that you don’t use a HAP or HAP-based materials as an

equipment cleaner.

§63.1298
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont’d)

If your emission

 point is . . . . 

And you have

chosen, as your 

overall

compliance

strategy, the . . . 

And you are

using the

following control

option . . . Then you must monitor as described below . . . 

According to

these sections of

the rule ... 

27

HAP ABA

storage vessels,

equipment leaks,

production line,

and equipment

cleaning

(Option 2)

Sourcewide emission

limit,

rolling annual or

monthly compliance

alterative

Recovery device Monitor the actual and allowable cumulative amount of HAP ABA recovered by the solventrecovery device each month using Equations 6 and 7

You must submit a HAP ABA monitoring and recordkeeping program for approval before you

wish to begin using the program. The program must contain information found in

§63.1303(c)(1)-(5). 

§63.1299(d);

§63.1299(e)(1)

§63.1303(c)(6)

All options other

than recovery

device

Calculate actual source-wide HAP emissions for a month using Equation 5. Calculate actual

source-wide HAP emissions for each consecutive 12-month period by summing actual monthly

source-wide HAP emissions for each of the individual 12 months.

Calculate allowable source-wide HAP emissions for each individual month by using equation 6. 

Calculate allowable source-wide HAP emissions for a consecutive 12-month period by summing

allowable monthly source-wide HAP emissions for each individual 12 months in the period.

§63.1299(c)

§63.1299(d)
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont’d)

28

If your emission

point is . . . 

And you have

chosen, as your

overall

compliance

strategy, the . . . 

And you

are using

the

following

control

option . . . Then you must keep records as described below . . . 

According to these

sections of the rule 

. . . 

Diisocyanate storage

vessels

(Option1 or 2)

Emission point

specific limit

OR

Sourcewide

emission limit

All options Keep a list of diisocyanate storage vessels, along with a record of the type of control used

for each storage vessel.

§63.1307(a)(1)

Vapor

balancing

Dates and times of each unloading event.

Dates and times of each inspection of the vapor-return line.

Dates and times when you detect a leak in the vapor-return line.

Dates and times when you repair a leak in the vapor-return line.

§63.1307(a)(4)(i)-(iii); 

§63.1307(f)

Carbonadsorption Dates and times when you monitor the system for carbon breakthrough.

Monitoring device reading each time monitored.

Date when you replaced the carbon.

§63.1307(a)(3)(i); 

§63.1307(a)(3)(iii)

Carbonadsorption --

design

analysis

monitoring 

Record the systems design analysis.

Dates and times when you monitor the system for carbon breakthrough.

Monitoring device reading each time you monitor.

Date when you replaced the carbon.

§63.1307(a)(3)(ii); 

§63.1307(a)(3)(iii); 

§63.1303(a)(2)
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont’d)

If your emission

point is . . . 

And you have

chosen, as your

overall

compliance

strategy, the . . . 

And you

are using

the

following

control

option . . . Then you must keep records as described below . . . 

According to these

sections of the rule 

. . . 

29

Transfer pumps in

diisocyanate service

(Option 1 or 2)

Emission point

specific limit

OR

sourcewide

emission limit

All options,

except

sealless

pumps

For each pump, date of installation and type of control.

If you detect a leak, you must record and identify on the equipment the following

information: 

• Instrument and operator identification numbers

• Equipment identification number

• Date you detected the leak and the dates of each attempt to repair the leak

• Repair methods applied in each attempt to repair the leak

• Words "above leak definition" if maximum leak reading is equal to or more than the

leak definition for the equipment

• Words "repair delayed" and the reason for the delay if not repaired within 15 calendar

days

• Date you expect to successfully repair the leak if not repaired within 15 calendar days

• Date you repaired the leak

• Date you removed the identification 

§63.1307(b)(2)

§63.1307(b)(3)(ii)
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont’d)

If your emission

point is . . . 

And you have

chosen, as your

overall

compliance

strategy, the . . . 

And you

are using

the

following

control

option . . . Then you must keep records as described below . . . 

According to these

sections of the rule 

. . . 

30

Other components in

diisocyanate service

(Option 1 or 2)

Emission point

specific limit

OR

Sourcewide

emission limit

All options List of components in diisocyanate service.

If you detect a leak, you must record and identify on the equipment the following

information: 

• Instrument and operator identification numbers

• Equipment identification number

• Date you detected the leak and the dates of each attempt to repair the leak

• Repair methods applied in each attempt to repair the leak

• Words "above leak definition" if maximum leak reading is equal to or more than the

leak definition for the equipment

• Words "repair delayed" and the reason for the delay if not repaired within 15 calendar

days

• Date you expect to successfully repair the leak if not repaired within 15 calendar days

• Date you repaired the leak

• Date you removed the identification 

§63.1307(b)(1)(i)

§63.1307(b)(3)(ii)
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont’d)

If your emission

point is . . . 

And you have

chosen, as your

overall

compliance

strategy, the . . . 

And you

are using

the

following

control

option . . . Then you must keep records as described below . . . 

According to these

sections of the rule 

. . . 

31

HAP ABA storage vessels

(Option 1)

Emission point

specific limit

All options A list of HAP ABA storage vessels, along with a record of the type of control used for each

storage vessel.

§63.1307(a)(2)

Vapor

balancing

Dates and times of each unloading event.

Dates and times of each inspection of the vapor-return line.

Dates and times when you detect a leak in the vapor-return line.

Dates and times when you repair a leak in the vapor-return line.

§63.1307(a)(4); 

§63.1307(f)

Carbonadsorption Dates and times when you monitor the system for carbon breakthrough.

Monitoring device reading each time you monitor.

Date when you replaced the carbon.

§63.1307(a)(3)(i); 

§63.1307(a)(3)(iii)

Carbonadsorption --

design

analysis

monitoring

Records of the systems design analysis.

Dates and times when you monitor the system for carbon breakthrough.

Monitoring device reading each time you monitor.

Date when you replaced the carbon.

§63.1307(a)(3)(ii); 

§63.1307(a)(3)(iii); 

§63.1303(a)(2)
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont’d)

If your emission

point is . . . 

And you have

chosen, as your

overall

compliance

strategy, the . . . 

And you

are using

the

following

control

option . . . Then you must keep records as described below . . . 

According to these

sections of the rule 

. . . 

32

HAP ABA Equipment

Leaks (e.g. transfer pumps,

valves, connectors,

pressure-relief devices, and

open-ended lines)

(Option 1)

Emission point

specific limit

All options List of components in HAP ABA service. §63.1307(b)(1)(ii)

All options,

except

sealless

pumps

If you detect a leak, you must record and identify on the equipment the following

information: 

• Instrument and operator identification numbers

• Equipment identification number

• Date you detected the leak and the dates of each attempt to repair the leak

• Repair methods applied in each attempt to repair the leak

• Words "above leak definition" if maximum leak reading is equal to or more than the

leak definition for the equipment

• Words "repair delayed" and the reason for the delay if not repaired within 15 calendar

days

• Date you expect to successfully repair the leak if not repaired within 15 calendar days

• Date you repaired the leak

• Date you removed the identification 

§63.1307(b)(3)(ii)
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont’d)

If your emission

point is . . . 

And you have

chosen, as your

overall

compliance

strategy, the . . . 

And you

are using

the

following

control

option . . . Then you must keep records as described below . . . 

According to these

sections of the rule 

. . . 

33

HAP ABA Production line

(Option 1)

Emission point

specific limit,

rolling annual or

monthly

compliance

alterative

All options Record the following daily:

• Foam runs, with a list of the grades produced during each run

• Amount of polyol added to the slabstock foam production line at the mixhead for each

run (not required for grades of foam where you’ve designated the formulation limit for

HAP ABA as zero)

• Results of the density and IFD testing for each grade of foam produced during each run

of foam (must be recorded within 10 days of production; not required for grades of

foam where you’ve designated the formulation limit for HAP ABA as zero)

Record the following monthly:

• Listing of all foam grades produced during the month

• Residual HAP formulation limit for each foam grade produced

• Total amount of polyol used in the month for each foam grade produced (not required

if zero is the HAP ABA formulation limit)

• Total allowable HAP ABA emissions for the month

• Total amount of HAP ABA added to the line at the mixhead during the month

If you’re using rolling-annual compliance, also record the following:

• Sum of the total allowable HAP ABA emissions for the month and the previous 11

months

• Sum of the total actual HAP ABA emissions for the month and the previous 11 months

§63.1307 (c)(1)(i)

§63.1307(c)(1)(ii)

§63.1307(c)(1)(iii)
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont’d)

If your emission

point is . . . 

And you have

chosen, as your

overall

compliance

strategy, the . . . 

And you

are using

the

following

control

option . . . Then you must keep records as described below . . . 

According to these

sections of the rule 

. . . 

34

Also keep all of the following records:

• Records of calibrations for each device used to measure polyol added at the mixhead

• Records of all calibrations for devices used to measure the amount of HAP ABA in

storage vessels

§63.1307(c)(1)(iv)
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont’d)

If your emission

point is . . . 

And you have

chosen, as your

overall

compliance

strategy, the . . . 

And you

are using

the

following

control

option . . . Then you must keep records as described below . . . 

According to these

sections of the rule 

. . . 

35

HAP ABA Production line

(Option 2)

Sourcewide limit,

rolling annual or

monthly

compliance

alternative

All options Record the following daily:

• Foam runs, with a list of the grades produced during each run

• Results of the density and IFD testing for each grade of foam produced during each run

of foam (must be recorded within 10 days of production; not required for grades of

foam where you’ve designated the formulation limit for HAP ABA as zero)

• Amount of polyol added to the slabstock foam production line at the mixhead for each

run (not required for grades of foam where you’ve designated the formulation limit for

HAP ABA as zero)

Record the following weekly:

• storage tank level 

Record the following monthly:

• Listing of all foam grades produced during the month

• Residual HAP formulation limit for each foam grade produced

• Total amount of polyol used in the month for each foam grade produced (not required

if zero is the HAP ABA formulation limit)

• Total allowable HAP ABA and equipment cleaning emissions for the month

• Total actual sourcewide HAP ABA emissions for the month

• Amounts of HAP ABA in the storage vessel at the beginning and end of the month

• Amount of each delivery of HAP ABA to the storage vessel

§63.1303 (c)(2)(i)

§63.1303(c)(2)(ii)

§63.1303(c)(2)(iii)
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont’d)

If your emission

point is . . . 

And you have

chosen, as your

overall

compliance

strategy, the . . . 

And you

are using

the

following

control

option . . . Then you must keep records as described below . . . 

According to these

sections of the rule 

. . . 

36

If using rolling-annual compliance, also record the following:

• Total allowable HAP ABA and equipment cleaning HAP emissions for the month and

the previous 11 months

• Total actual HAP ABA and equipment cleaning HAP emissions for the month and the

previous 11 months

• Records of all calibrations for each device measuring polyol added at the mixhead

• Records of all calibrations for each device used to measure the amount of HAP ABA in

the storage vessel

Also keep all of the following records:

• Records of calibrations for each device used to measure polyol added at the mixhead

• Records of all calibrations for devices used to measure the amount of HAP ABA in

storage vessels

• 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)

§63.1303(c)(2)(iv)

§63.1307(c)(2)(v) -

(vii)

HAP ABA Recovery

device

(Option 1 or 2)

Emission point

specific limit

OR

Sourcewide limit

N/A Copy of the monitoring and recordkeeping program for recovered HAP ABA.

Certification of the monitoring device’s accuracy.

Records of periodic calibration of the monitoring devices.

Records showing results of parameter monitoring.

Amount of HAP ABA recovered each time it is measured.

§63.1307 (d)
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont’d)

If your emission

point is . . . 

And you have

chosen, as your

overall

compliance

strategy, the . . . 

And you

are using

the

following

control

option . . . Then you must keep records as described below . . . 

According to these

sections of the rule 

. . . 

37

HAP ABA Equipment

cleaning

(Option 1)

Emission point

specific limit

N/A Product data-sheet for each equipment cleaner used, including HAP content, in kg of

HAP/kg solids (lb HAP/lb solids).

§63.1307 (e)
38

Table 3.3 Checklist for Inspecting Slabstock Foam Plants

Facility Name: _______________________________________________________

Facility Location: _______________________________________________________

Facility TRI ID #: _______________________________________________________

Person Conducting Evaluation: _______________________________________________________

Date of Evaluation: _______________________________________________________

This inspection checklist is broken up into eleven sections as follows:

Section Page Option

I. Applicability 38

II. Diisocyanate storage vessels 39 1 or 2

III. Diisocyanate transfer pumps 42 1 or 2

IV. Other diisocyanate components in service 44 1 or 2

V. HAP ABA storage vessels 45 1

VI. HAP ABA equipment leaks 49 1

VII. HAP ABA production line 54 1

VIII. HAP ABA equipment cleanig 59 1

IX. Sourcewide emission limit 60 2

X. Testing 64 1 or 2

XI. Reporting 65 1 or 2

Section I: Applicability checklist (All Options)

A. Applicability

 Note: If you answer YES to any Section A questions, don’t continue. Your slabstock

foam process isn’t covered . 

Comments

1 Is your facility exclusively dedicated to the fabrication of flexible

polyurethane foam? §63.1290(c)(1)

Q Yes Q No

2 Is your slabstock process devoted solely to research and development

of new products and processes? §63.1290(c)(2)

Q Yes Q No

3 Are your plantwide HAP emissions, as calculated using Equation 1,

no more than five tons per year? §63.1290(c)(3)

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

39

Section II: Diisocyanate storage vessels checklist (Option 1 or 2)

B. Requirements for Diisocyanate Storage Vessels Comments

1 Does each diisocyanate storage vessel have a vapor-return line

(vapor-balancing system) or a carbon-adsorption system? 

§63.1294(a)

Q Yes Q No No. vessels with vaporreturn line:

No. vessels with carbonadsorption:

2 For each diisocyanate storage vessel with a vapor-return line, are

you visually inspecting for leaks each time diisocyanate is unloaded

from the tank truck or rail car? §63.1294(a)(1)(i)

Q Yes Q No Date of last unloading:

Date of last visual

inspection: 

3 For each diisocyanate storage vessel with a vapor-return line, did

you repair any leaks found before the next unloading event?

§63.1294(a)(1)(ii)

Q Yes Q No Date of leak:

Date leak repaired:

Date next loading event:

No. vessels with leaks:

No. vessels repaired:

4 For each diisocyanate storage vessel with a carbon-adsorption

system, do you route displaced vapors through activated carbon?

§63.1294(a)(2)

Q Yes Q No

5 For each carbon-adsorption system, do you replace the carbon after

you find the breakthrough and before the next unloading? 

§63.1294(a)(2)

Q Yes Q No Date of breakthrough:

Date of Carbon

Replacement:

Date of Next Unloading: 

No. vessels with

breathrough: 

C. Monitoring Requirements for Diisocyanate Storage Vessels 

SKIP this section if you don’t use a carbon-adsorption system on your storage vessels

Comments

1 Do you monitor the HAP or organic concentration in the exhaustvent stream or outlet stream’s exhaust from the carbon adsorption

system during each unloading (or once a month if loading occurs

more often than monthly)? Or, do you monitor at a regular interval

established in your design analysis? §63.1303(a)(1),(2)

Q Yes Q No No. storage vessels

measured at the carbon

adsorption system:

No. vessels using design

analysis:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

C. Monitoring Requirements for Diisocyanate Storage Vessels 

SKIP this section if you don’t use a carbon-adsorption system on your storage vessels

Comments

40

2 If you monitor the HAP concentration in the carbon-adsorption

system’s exhaust, do you follow Method 18 and make the

measurement for at least one 5-minute interval while the vessel is 

being filled? §63.1303(a)(3)

Q Yes Q No Value Method 18:

3 If you monitor the organic concentration in the carbon-adsorption

system’s exhaust, do you follow Method 25A and make the

measurement for at least one 5-minute interval while the vessel is 

being filled? §63.1303(a)(4)

Q Yes Q No Value Method 24:

4 For each carbon-adsorption system monitored according to

intervals in a design analysis, have you replaced the carbon at the

specified interval? §63.1303(a)(2)

Q Yes Q No Design’s Replacement

Interval:

Last Replacement of

Carbon:

D. Recordkeeping Requirements for Diisocyanate Storage Vessels Comments

1 Do you have a list of diisocyanate storage vessels that includes the

type of control for each storage vessel? §63.1307(a)(1)

Q Yes Q No No. of storage vessels:

No. of controls used:

2 If you’re complying with the requirements for diisocyanate storage

vessels using carbon-adsorption, do you keep the following records?

§63.1307(a)(3)

C Dates and times when you monitor the system for carbon

breakthrough

C Reading from the monitoring device each time you monitor it

C Date when your replaced the carbon

Q Yes Q No

Q Yes Q No

Q Yes Q No

No. vessels using carbonadsorption:

3 If you’re complying with the requirements for diisocyanate storage

vessels using carbon-adsorption with alternative monitoring, do

you keep the following records? §63.1307(a)(3)

C Records of design analysis 

C Dates and times when you monitor the system for carbon

breakthrough

C Reading from the monitoring device each time you monitor it

C Date when you replaced the carbon 

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

No. vessels using carbon

adsorption:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

D. Recordkeeping Requirements for Diisocyanate Storage Vessels Comments

41

4 If you’re complying with the diisocyanate storage using a vaporreturn line, do you keep the following records? §63.1307(a)(4), 

§63.1307(f)

C Dates and times of each unloading event

C Dates and times of each inspection of the vapor-return line

C Dates and times each time you used the vapor-return line

C Dates and times you detect a leak in the vapor-return line

C Dates and times when you repair a leak in the vapor-return line

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

No. vessels using vaporreturn:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

42

Section III: Diisocyanate transfer pump checklist (Option 1 or 2)

E. Requirements for Diisocyanate Transfer Pumps Comments

1 Is each transfer pump in diisocyanate service either sealless or

submerged? §63.1294(b)

Q Yes Q No No. of sealless pumps:

No. submerged pumps: 

2 Have you completely immersed each submerged pump in bis(2-

ethylhexyl)phthalate (DEHP, CAS #118-81-7),

2(methyloctyl)phthalate (DINP, CAS #68515-48-0), or another

neutral oil? §63.1294(b)(2)(i)

Q Yes Q No Submerging oil used:

3 Do you visually monitor each submerged pump weekly to detect

leaks? §63.1294(b)(2)(ii)

Q Yes Q No Date last wkly inspection:

4 When you detect a leak from a submerged pump, do you first

attempt to repair it within 5 calendar days and actually repair it

within 15 calendar days unless you’ve determined that your

equipment meets the delay of repair definition in §63.1294(d)?

§63.1294(b)(2)(iii)

Q Yes Q No Date Leak Detected:

Date First Attempt at

Repair:

Date Leak Repaired:

No. of pumps with leaks:

5 Does your first attempt to repair a leaking submerged pump include:

tightening of packing gland nuts and checking the seal flush to see if

it is operating at design temperature and pressure? 

§63.1294(b)(2)(iii)(B)

Q Yes Q No

F. Recordkeeping Requirements for Diisocyanate Transfer Pumps

Complete this section only if you used submerged pumps

Comments

1 Do you have a list of all submerged transfer pumps in diisocyanate

service, including the date of installation and type of control?

§63.1307(b)(2)

Q Yes Q No No. transfer pumps:

2 For each submerged transfer pump that’s leaking, do you attach to

the equipment a readily visible identification number?

§63.1307(b)(3)(i)(A)

Q Yes Q No No. pumps with tags:

3 For each submerged transfer pump that’s leaking, do you remove the

tag only after you’ve repaired the pump? §63.1307(b)(3)(i)(C)

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

F. Recordkeeping Requirements for Diisocyanate Transfer Pumps

Complete this section only if you used submerged pumps

Comments

43

4 For each submerged transfer pump in diisocyanate service, do you

keep the following records each time you detect a leak

§63.1307(b)(3)(ii)

C Instrument and operator identification numbers and the

equipment identification number

C Date you detected the leak and dates of each attempt to repair

the leak.

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

C Words "above leak definition" if applicable

C Words "repair delayed" and the reason for the delay if not

repaired within 15 calendar days. Date you expect to repair the

leak if not repaired within 15 calendar days

C Date you repaired the leak

C Date you removed the identification 

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No 

Q Yes Q No

Q Yes Q No

Q Yes Q No

No. pumps in diisocyante

service:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

44

Section IV: Other diisocyanate components checklist (Option 1 or 2)

G. Requirements for Other Components in Diisocyanate Service Comments

1 If you detect a leak from other components in diisocyanate service,

do you first attempt to repair the leak within 5 calendar days and

actually repair it within 15 calendar days unless you’ve determined

that your equipment meets the delay of repair definition in

63.1296(f)? §63.1294(c)

Q Yes Q No Date Leak Detected: 

Date First Attempt

at Repair: 

 

Date Leak Repaired: 

No. of components with

leaks:

H. Recordkeeping Requirements for Other Components in Diisocyanate Service Comments

1 Do you have a list of all other components in diisocyanate service?

§63.1307(b)(i)

Q Yes Q No No. of components in

service:

2 For each other component in diisocyanate service that’s leaking, do

you attached to the equipment a readily visible identification

number? §63.1307(b)(3)(i)(A)

Q Yes Q No No. components tags:

3 For each other component in diisocyanate service that’s leaking, do

you remove the tag only after you’ve repaired the leak?

§63.1307(b)(3)(i)(C)

Q Yes Q No

4 For each other component in diisocyanate service, do you keep the

following records each time you detect a leak §63.1307(b)(3)(ii)

C Instrument and operator identification numbers and the

equipment identification number

C Date you detected the leak and dates of each attempt to repair

the leak.

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

C Words "above leak definition" if applicable

C Words "repair delayed" and the reason for the delay if not

repaired within 15 calendar days. Date you expect to repair the

leak if not repaired within 15 calendar days

C Date you repaired the leak

C Date you removed the identification 

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No 

Q Yes Q No

Q Yes Q No

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

45

Section V: HAP ABA storage vessel checklist (Option 1)

I. Requirements for HAP ABA Storage Vessels Comments

1 Have you equipped each HAP ABA storage vessel with a vapor

return line (vapor-balance system) or a carbon-adsorption system? 

§63.1295(a)

Q Yes Q No No. vessels with vaporreturn line:

No. vessels with carbonadsorption: 

2 For each HAP ABA storage vessel with a vapor-return line, is the

line connected from the storage vessel to the tank truck or rail car

during each unloading? §63.1295(b)

Q Yes Q No

3 For each HAP ABA storage vessel with a vapor-return line, do you

inspect (visual, audible, olfactory, or other detection method) for

leaks each time HAP ABA is unloaded from the tank truck or rail

car? §63.1295(b)(1)

Q Yes Q No Date Last Unloading:

Date last visible inspection:

4 For each HAP ABA storage vessel with a vapor-return line, if you

found a leak, did you repair it before the next unloading event?

§63.1295(b)(2)

Q Yes Q No Date of leak:

Date Leak Repaired:

Date Subsequent

Unloading: 

No. of vessels with leaks:

No. of vessels repaired:

5 For each HAP ABA storage vessel with a carbon-adsorption

system, do you route displaced vapors through activated carbon

before discharging into the atmosphere? §63.1295(c)

Q Yes Q No

6 For each carbon-adsorption system, do you replace the carbon after

you find breakthrough and before the next unloading? §63.1295(c)

Q Yes Q No Date of breakthough:

Date of carbon replacement:

Date of Subsequent

Unloading:

No. vessels with

breakthrough:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

46

J. Monitoring Requirements for HAP ABA in Storage Vessels Comments

1 Do you determine the amount of HAP ABA in each storage vessel

weekly? §63.1303(d)

Q Yes Q No Method used:

Date Last Measurement:

2 Do you monitor the amount of HAP ABA in each storage vessel with

a level-measurement device? §63.1303(d)

Q Yes Q No

3 Did you calibrate each level-measurement device initially and then

annually? §63.1303(d)(1)

Q Yes Q No Date of Annual

Calibration:

4 Unless the level-measurement device is a visually read device, such

as a gauge glass, does the device have a digital or printed output?

§63.1303(d)(2)

Q Yes Q No Type of output:

5 If the level-measurement device is a visually read device, does it

have permanent graduated markings to show the HAP ABA level in

the storage tank? §63.1303(d)(3)

Q Yes Q No

K. Monitoring Requirements for HAP ABA added to Storage Vessels Comments

1 Do you monitor the amount of HAP ABA added to a storage vessel

by measuring the volume, weight or by an alternative monitoring

program? §63.1303(e)

Q volume

Q weight

Q alternate

No. vessels using volume:

No. vessels using weight:

No. vessels using alternate:

2 If you measure using volume, do you record the volume of HAP

ABA in each storage vessel before and after each delivery?

§63.1303(e)(1)

Q Yes Q No Date Last Delivery:

Volume before last delivery:

Volume after last delivery:

3 If you measure using the volume of HAP ABA delivered, does your

measurement device follow the requirements outlined in section J of

this checklist?§63.1303(e)(1)

Q Yes Q No

4 If measuring using volume, is volume flow rate measured using a

device with an accuracy of ±2.0% ? §63.1303(e)(2)

Q Yes Q No Device Accuracy:

5 If measuring using volume, did you calibrate your device initially

and at least once every 6 months? §63.1303(e)(2)

Q Yes Q No Date Initial Calibration:

Date Last 2 Calibrations:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

K. Monitoring Requirements for HAP ABA added to Storage Vessels Comments

47

6 If measuring weight, do you measure by calculating the difference of

the full weight of the transfer vehicle prior to unloading and the

empty weight of the transfer vehicle after unloading? §63.1303(e)(3)

Q Yes Q No Date of last transfer:

Wt of last full transfer

vehicle:

Wt of last empty transfer

vehicle:

7 If measuring weight, is your scale approved by your State or local

agency using procedures in Handbook 44 or is it certified once per

year by a registered scale technician? §63.1303(e)(3)(i) and (ii)

Q Yes Q No No. scales approved by

State:

No. scales approved by

technician:

8 If your using an alternative monitoring program, have you

submitted the plan for approval? Has the plan been approved? 

§63.1303(e)(4)

Q Yes Q No Date Plan Submitted:

Date Plan Approved:

L. Monitoring Requirements for Storage Vessels with Carbon-Adsorption

SKIP this section if you don’t use a carbon-adsorption system on your storage vessels

Comments

1 Do you monitor the HAP or organic concentration in the exhaustvent stream or outlet stream’s exhaust from the carbon adsorption

system during each unloading (or once a month if loading occurs

more often than monthly)? Or, do you monitor at a regular interval

established in your design analysis? §63.1303(a)(1),(2)

Q Yes Q No No. storage vessels

measured at the carbon

adsorption system:

No. vessels using design

analysis:

2 If you monitor the HAP concentration in the carbon-adsorption

system’s exhaust, do you follow Method 18 and make the

measurement for at least one 5-minute interval while the vessel is 

being filled? §63.1303(a)(3)

Q Yes Q No Value Method 18:

3 If you monitor the organic concentration in the carbon-adsorption

system’s exhaust, do you follow Method 25A and make the

measurement for at least one 5-minute interval while the vessel is 

being filled? §63.1303(a)(4)

Q Yes Q No Value Method 24:

4 For each carbon-adsorption system monitored according to

intervals in a design analysis, have you replaced the carbon at the

specified interval? §63.1303(a)(2)

Q Yes Q No Design’s Replacement

Interval:

Last Replacement of

Carbon:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

48

M. Recordkeeping Requirements for HAP ABA Storage Vessels Comments

1 Do you have a list of HAP ABA storage vessels that includes the

type of control for each storage vessel? §63.1307(a)(2)

Q Yes Q No No. vessels using emission

point specific limit:

2 If you’re complying with the requirements for HAP ABA storage

vessels using carbon-adsorption, do you keep the following records?

§63.1307(a)(3)

C Dates and times when you monitor the system for carbon

breakthrough

C Reading from the monitoring device each time you monitor it

C Date when your replaced the carbon

Q Yes Q No

Q Yes Q No

Q Yes Q No

No. vessels using carbonadsorption:

3 If you’re complying with the requirements for HAP ABA storage

vessels using carbon-adsorption with alternative monitoring, do

you keep the following records? §63.1307(a)(3)

C Records of design analysis 

C Dates and times when you monitor the system for carbon

breakthrough

C Reading from the monitoring device each time you monitor it

C Date when you replaced the carbon 

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

No. vessels using carbon

adsorption:

4 If you’re complying with the HAP ABA storage using a vapor-return

line, do you keep the following records? §63.1307(a)(4),§63.1307(f)

C Dates and times of each unloading event

C Dates and times of each inspection of the vapor-return line

C Dates and times of each use of the vapor-return line

C Dates and times you detect a leak in the vapor-return line

C Dates and times when you repair a leak in the vapor-return line

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

No. vessels using vaporreturn:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

49

Section VI: HAP ABA equipment leaks checklist (Option 1)

N. Requirements for HAP ABA Equipment Leaks

Note: Equipment leak requirements are for transfer pumps, valves, connectors, pressurerelief devices and open-ended lines

Comments

1 Is each pump in HAP ABA service either sealless or monitored for

leaks? §63.1296(a)

if you’re using a sealless pump, skip item 2-4 and go to 5

Q sealless

Q monitored

No. sealless pumps:

No. pumps monitored:

2 Do you monitor each pump quarterly by using Method 21 and

weekly by visual inspection? §63.1296(a)(2)(i),(ii); §63.1304(a)

Q Yes Q No Last Quarterly Inspection:

Value Method 21:

3 If you detect a pump leak, do you first attempt to repair it within 5

calendar days and actually repair it within 15 calendar days unless

you’ve determined your pump meets the delay of repair under

§63.1296(f)? §63.1296(a)(2)(iii)

Q Yes Q No Date Leak Detected:

Date First Attempt at

Repair: 

Date Leak Repaired:

No . of pumps with leaks:

4 Does your first attempt to repair a leaking pump include: tightening

of packing gland nuts and ensuring the seal flush is operating at it’s

design pressure and temperature? §63.1296(a)(2)(iii)(B)

Q Yes Q No

5 Do you monitor each valve quarterly using Method 21? 

§63.1296(b)(1); §63.1304(a)

Q Yes Q No Last Quarterly Inspection:

Value Method 21:

6 If you detect a valve leak using Method 21, do you attempt to repair

it within 5 calendar days and repair it within 15 calendar days unless

you’ve determined your pump meets the delay of repair under

§63.1296(f)? §63.1296(b)(2); §63.1304(a)

Q Yes Q No Date Leak Detected: 

Date First Attempt at

Repair:

Date Leak Repaired:

No. of valves with leaks:

7 Does your first attempt to repair a leaking valve include: tightening

of bonnet bolts, replacement of bonnet bolts, tightening gland nuts

and lubricating the packing? §63.1296(b)(2)(ii)

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

N. Requirements for HAP ABA Equipment Leaks

Note: Equipment leak requirements are for transfer pumps, valves, connectors, pressurerelief devices and open-ended lines

Comments

50

8 For each valve you’ve designated as unsafe-to-monitor, do you have

a written plan that requires monitoring as often as possible and

repair of leaks as soon as possible? §63.1296(b)(3)(ii)

Note: unsafe-to-monitor valves are those valves that can’t be

monitored because personnel would be exposed to an immediate

danger situation. §63.1296(b)(3)(i)

Q Yes Q No No. of unsafe-to-monitor

valves:

9 Do you monitor and repair each unsafe-to-monitor valve according to

your written plan? §63.1296(b)(3)(iii) and (iv)

Q Yes Q No Date Last Monitored:

Plan Requirements for

Monitoring:

Date Leak Last Detected: 

Date Leak Repaired: 

Plan Requirements

for Leak Repair:

10 For each valve you’ve designed as difficult-to-monitor, do you have a 

written plan that requires monitoring at least once per calendar year

and repair of leaks as soon as possible? §63.1296(b)(4)(iii)

Note: difficult-to-monitor valves are those valves that can’t be

monitored without elevating personnel more than 2 meters

above a support surface or the valve is not accessible at any time

in a safe manner. Your valve must be an existing source or a

new source where you have designed <3% of your valves as

difficult-to-monitor. §63.1296(b)(4)(i), (ii)

Q Yes Q No No. of difficult-to-monitor

valves:

11 Do you monitor and repair each difficult-to-monitor valve according

to your written plan? §63.1296(b)(4)(iv) and (v)

Q Yes Q No Plan Requirements for

Monitoring:

Date Last Monitored:

Plan Requirements for Leak

Repair:

Date Leak Last Detected:

Date Leak Repaired:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

N. Requirements for HAP ABA Equipment Leaks

Note: Equipment leak requirements are for transfer pumps, valves, connectors, pressurerelief devices and open-ended lines

Comments

51

12 Do you monitor each connector annually using Method 21? 

§63.1296(c)(1); §63.1304(a)

Q Yes Q No No of connectors monitored

using Method 21:

Date Last Monitored:

Value Method 21:

13 If you’ve opened a connector or broken its seal, do you monitor it

for leaks within the first 3 months after it’s used for HAP ABA

again? §63.1296(c)(1)(ii)

Q Yes Q No Date Connector

Opened/Seal Broken:

Date Connector Monitored:

No. Connectors

Opened/Seal Broke:

14 If you’ve detected a leak, do you monitor the connector within the

first 3 months after its repair? §63.1296(c)(1)(iii)

Q Yes Q No Date Leak Detected:

Date Leak Repaired:

Date Leak Monitored:

No. Connectors with Leaks::

15 If you detect a connector leaking, do you try to repair it within 5

calendar days and repair it within 15 calendar days unless you’ve

determined your pump meets the delay of repair under §63.1296(f)?

§63.1296(c)(2)

Q Yes Q No Date Leak Detected:

Date First Attempt at

Repair:

16 For each connector designated as unsafe-to-monitor, do you have a

written plan that requires monitoring as often as possible and repair

of leaks within 6 months? §63.1296(c)(3), (c)(4)(ii)

Note: unsafe-to-monitor connectors are those that can’t be

monitored because personnel would be exposed to an immediate

danger situation. §63.1296(c)(3)(i)

Q Yes Q No No. unsafe-to-monitor

connectors:

17 Do you monitor and repair each unsafe-to-monitor connector

according to your written plan? §63.1296(c)(3)(ii)

Q Yes Q No Plan Requirements for

Monitoring:

Date Last Monitored:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

N. Requirements for HAP ABA Equipment Leaks

Note: Equipment leak requirements are for transfer pumps, valves, connectors, pressurerelief devices and open-ended lines

Comments

52

18 For each connector designated as unsafe-to-repair, do you repair the

connector as soon as possible but no later than 6 months after you

detected the leak? §63.1296(c)(4)(ii)

Note: unsafe-to-repair connectors are those that can’t be

repaired because personnel would be exposed to an immediate

danger situation. §63.1296(c)(4)(i)

Q Yes Q No Plan Requirement for Leak

Repair:

Date Leak Detected:

Date Leak Repaired:

19 If you find evidence of a potential leak by visual, audible, or

olfactory detection, do you monitor the pressure-relief device using

Method 21 within 5 calendar days? §63.1296(d)(1); §63.1304(a)

Q Yes Q No Date Potential Leak Last

Detected:

Date Monitored:

Results Method 21:

20 If you detect a leak a pressure-relief device, do you first attempt

repair it within 5 calendar days and actually repair it within 15

calendar days unless you’ve determined your pump meets the delay

of repair under §63.1296(f)? §63.1296(d)(2)

Q Yes Q No No. pressure-relief devices

with leaks:

Date Leak Detected:

Date First Attempt at

Repair:

Date Leak Repaired:

21 Have you equipped each open-ended valve or line in HAP ABA

service (except those in an emergency-shutdown system designed to

open automatically during a process upset) with a cap, blind flange,

plug, or a second valve? §63.1296(e)(i)

Q Yes Q No

22 Do you keep open-ended valve or line sealed at all times, except

when in use or during maintenance or repair? §63.1296(e)(1)(ii)

Q Yes Q No

23 For each open-ended valve or line with a second valve, do you close 

the valve on the process fluid end before closing the second valve?

§63.1296(e)(2)

Q Yes Q No No. valves or lines with

second valve:

24 For each open ended valve or line with a double-block-and-bleed

system, do you keep the bleed-valve or line closed except during

operations that require venting the line between the block-valves? 

§63.1296(e)(3)

Q Yes Q No No. valves or lines with

double-block-and-bleed:

O. Recordkeeping Requirements for HAP ABA Equipment Leaks Comments

1 Do you have a list of transfer pumps, valves, connectors, pressurerelief devices and open-ended lines in HAP ABA service

(components in service)? §63.1307(b)(1)(ii)

Q Yes Q No No. of components in

service:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

O. Recordkeeping Requirements for HAP ABA Equipment Leaks Comments

53

2 For each component in service that’s leaking, do you attached to the

equipment a readily visible identification number?

§63.1307(b)(3)(i)(A)

Q Yes Q No No. components with tags:

3 For each component in service that’s leaking, do you remove the tag

only after you’ve repaired the equipment or after 2 successive

quarters of no leaks if your equipment is a valve?

§63.1307(b)(3)(i)(C)

Q Yes Q No

4 Do you keep the following records for components in service?

§63.1307(b)(3)(ii)

C Instrument and operator identification numbers and the

equipment identification number

C Date you detected the leak and dates of each attempt to repair

the leak.

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

C Words "above leak definition" if applicable

C Words "repair delayed" and the reason for the delay if not

repaired within 15 calendar days. Date you expect to repair the

leak if not repaired within 15 calendar days

C Date you repaired the leak

C Date you removed the identification 

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No 

Q Yes Q No

Q Yes Q No

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

54

Section VII: HAP ABA production line checklist (Option 1)

P. Requirements for HAP ABA Emissions from the Production Line Comments

1 Do you determine compliance with the HAP ABA emission limits

from the production line by using a rolling-annual or monthly

basis? §63.1297(a)

Q rolling-annual

Q monthly

No. lines using rollingannual:

No. lines using monthly:

2 If you switch between the rolling-annual and monthly compliance

options, do you make notification 180 calendar days prior to making

the change? §63.1297(a)(3)

Q Yes Q No Date switched options:

Date of notification:

3 If you determine compliance on a rolling-annual basis, and don’t

use a recovery device, are actual HAP ABA emissions for each

consecutive 12-month period less than allowable HAP ABA

emissions for the same consecutive 12-months? §63.1297(b)

Q Yes Q No Value actual HAP ABA:

Value allowable HAP ABA:

4 If you determine compliance on a rolling-annual basis, and don’t

use a recovery device, do you calculate actual HAP ABA emissions

as the sum of actual monthly HAP ABA emissions for each 12 month

period? §63.1297(b)(1)

Q Yes Q No Value actual HAP ABA for

last 12 months:

Value allowable HAP ABA:

5 If you determine compliance on a rolling-annual basis, and don’t

use a recovery device, do you use Equation 2 in §63.1297(b)(2) to

calculate allowable HAP ABA emissions on the production for the

12-month period? §63.1297(b)(2); §63.1297(c)(2)

Q Yes Q No Value Equation 2:

6 If you determine compliance monthly, and don’t use a recovery

device, do you compare actual HAP ABA emissions to allowable

HAP ABA emissions for each month? Do you determine actual by

using HAP ABA added to the production line at the mixhead? 

§63.1297(a)(2)

Q Yes Q No Value actual HAP ABA:

Value allowable HAP ABA:

7 If you determine compliance monthly, and don’t use a recovery

device, are actual HAP ABA emissions less than the corresponding

allowable level of HAP ABA emissions for the same month? 

§63.1297(c)

Q Yes Q No Value actual HAP ABA:

Value allowable HAP ABA:

8 If you determine compliance monthly, and don’t use a recovery

device, do you calculate actual monthly HAP ABA emissions as the

amount of HAP ABA added to the production line at the mixhead?

§63.1297(c)(1)

Q Yes Q No Value actual HAP ABA:

Value allowable HAP ABA:

9 If you determine compliance monthly, and don’t use a recovery

device, do you use Equation 2 in §63.1297(b)(2) to calculate

allowable HAP ABA emissions for the month? §63.1297(b)(2)

Q Yes Q No Value Equation 2:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

P. Requirements for HAP ABA Emissions from the Production Line Comments

55

10 Except for formulation limits of zero, do you determined a HAP

ABA formulation limit for each grade of foam produced? 

§63.1297(d)

Q Yes Q No No. grades produced:

Formulation limit value:

11 Except for formulation limits of zero, for each existing source, do

you use Equation 3 in §63.1297(d) to calculate HAP ABA

formulation limit? §63.1297(d)(1)

Q Yes Q No Value equation 3:

12 Except for formulation limits of zero, for each new source, do you

use Equation 3 in §63.1297(d) to calculate the HAP ABA

formulation limit for each grade of foam with a density of 0.95

pound per cubic foot or less? §63.1297(d)(2)(i)

Q Yes Q No Value equation 3:

13 Except for formulation limits of zero, for each new source, do you

use Equation 3 in §63.1297(d) to calculate the HAP ABA

formulation limit for each grade of foam with a density of 1.4

pound per cubic foot or less and an Indentation Force Deflection

(IFD) of 15 pounds or less? §63.1297(d)(2)(ii)

Q Yes Q No Value equation 3:

14 Except for formulation limits of zero, for each new source, with a 

foam grade density greater than 0.95 pounds per cubic foot and an

IFD greater than 15 pounds, is the HAP ABA formulation limit

zero? §63.1297(d)(2)(iii)

Q Yes Q No Density:

Formulation limit:

15 Except for formulation limits of zero, for each new source with a 

foam grade density greater than 1.40 pounds per cubic foot, is the

HAP ABA formulation limit zero? §63.1297(d)(2)(iv)

Q Yes Q No Density:

Formulation limit:

16 Except for formulation limits of zero, do you determine the IFD and

density for each foam grade within 10 working days of its production

using §63.1304(b)? §63.1297(d)(3)

Q Yes Q No Last production start date:

Last IFD and density

determination:

17 If you’re using a recovery -device and determine compliance on a

rolling-annual or monthly basis, do you calculate allowable HAP

ABA emissions using Equation 2 in §63.1297(e) monthly? 

§63.1297(e)

Q Yes Q No Value equation 2:

18 If you’re using a recovery -device and determine compliance on a

rolling-annual or monthly basis, do you calculate actual monthly

HAP ABA emissions according to Equation 4 in §63.1297(e)?

§63.1297(e)(1)

Q Yes Q No Value equation 4:

19 If you’re using a recovery-device and determine compliance on a

rolling-annual or monthly basis, have you submitted a HAP ABA

monitoring program for approval? §63.1297(e)(2);§63.1303(c)

Q Yes Q No No. recovery-devices used:

Date plan submitted:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

56

Q. Monitoring Requirements for HAP ABA Emissions from the Production Line when a

Recovery Device is Used

SKIP this section if you don’t use a recovery device 

Comments

1 Have you sent a recovered HAP monitoring and recordkeeping plan

in for approval? §63.1303(c)

Q Yes Q No Date Sent:

Date Approved:

2 Does your equipment have a device showing the cumulative amount

of HAP ABA recovered by the solvent-recovery device each month? 

§63.1303(c)(1)

Q Yes Q No Last cumulative monthly

value:

3 Has the manufacturer certified the device to be accurate within +/-

2.0 percent? §63.1303(c)(1)

Q Yes Q No Device accuracy:

4 Do you measure after fully recovering the HAP ABA (i.e., after

separating it from water introduced into the HAP ABA during

regeneration)? §63.1303(c)(2)

Q Yes Q No

R. Monitoring Requirements for HAP ABA and Polyol added to the Production Line at the

mixhead

Comments

1 Do you continuously monitor the amount of HAP ABA added at the

mixhead when foam is being poured or monitor under an alternative

monitoring program? §63.1303(b)((1)(i)

Q Yes Q No

2 When monitoring HAP ABA added, do you measure using flow

rate?§63.1303(b)((1)(ii) 

Q Yes Q No

3 When measuring HAP ABA added, does your monitoring device

have an accuracy to within ±2.0 percent of the HAP ABA being

measured? §63.1303(b)(3)

Q Yes Q No Device Accuracy:

4 When measuring HAP ABA added, did you calibrate your

measuring device initially and at least once each month? 

§63.1303(b)(3)(ii)

Q Yes Q No Date Initial Calibration:

Date Last 2 Calibrations:

5 Are you measuring HAP ABA at the beginning and end of a run of

foam for the production of each grade of foam? §63.1303(b)(4)

Q Yes Q No Value last beginning run:

Value last end run:

6 Do you continuously monitor the amount of polyol added at the

mixhead according to the rule or an alternative monitoring

program? §63.1303(b)(1)(i)

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

R. Monitoring Requirements for HAP ABA and Polyol added to the Production Line at the

mixhead

Comments

57

7 If you’re monitoring the amount of polyol, are you measuring using

pump revolutions or flow rate? §63.1303(b)(2)

Q Yes Q No No. monitoring using

revolutions:

No. monitoring using flow

rate:

8 If your monitoring the amount of polyol, does your monitoring device

have an accuracy to within ±2.0 percent of the HAP ABA being

measured? §63.1303(b)(3)

Q Yes Q No Device Accuracy:

9 If your monitoring the amount of polyol, did you calibrate your

measuring device initially and at least every 6 months? 

§63.1303(b)(3)(i)

Q Yes Q No Date Initial Calibration:

Date Last 2 Calibrations:

10 Are you measuring polyol at the beginning and end of a run of foam

for the production of each grade of foam? §63.1303(b)(4)

Q Yes Q No Last beginning value:

Last end value:

11 If your using an alternative monitoring program, have you

submitted the plan for approval? Has the plan been approved? 

§63.1303(b)(5)

Q Yes Q No Date Plan Submitted:

Date Plan Approved:

S. Recordkeeping Requirements for HAP ABA at the Production Line Comments

1 Do you have a list of HAP ABA Production lines? §63.1307(b)(ii) Q Yes Q No

2 If you’re complying using the rolling-annual or monthly

compliance option, do you keep the following production-line

records daily? §63.1307(c)(1)(i)

C Foam run log, with a list of the grades produced during each run

C Amount of polyol added to the production line for slabstock

foam at the mixhead for each run 

C Results of the density and IFD testing for each grade of foam

produced during each run of foam (not required on grades of

foam for which you’ve designated a zero formulation limit for

HAP ABA)

Q Yes Q No

Q Yes Q No

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

S. Recordkeeping Requirements for HAP ABA at the Production Line Comments

58

3 If you’re complying using the rolling-annual or monthly

compliance option, do you keep the following records for each

month? §63.1307(c)(1)(ii)

C Listing of all foam grades produced during the month

C Formulation limit for HAP ABA on each foam grade produced

C Total allowable HAP ABA emissions for the month

C Total amount of HAP ABA added at the mixhead during the

month 

C Total amount of polyol used in the month for each foam grade

produced (not required on grades of foam for which you’ve

designated a zero formulation limit for HAP ABA)

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

4 If you’re complying using the rolling-annual or monthly

compliance option, do you keep the following records for each

month? §63.1307(c)(1)(iv)

C Calibrations for each device used to measure polyol and HAP

ABA added at the mixhead Q Yes Q No

5 If you’re complying using the emission point specific limit, rollingannual option, do you keep the following records for each month? 

§63.1307(c)(1)(iii)

C Sum of the total allowable HAP ABA emissions for the month

and the previous 11 months

C Sum of the total actual HAP ABA emissions for the month and

the previous 11 months

Q Yes Q No

Q Yes Q No

T. Recordkeeping Requirements for HAP ABA Emissions from the Production Line when

a Recovery Device is Used

SKIP this section if you don’t use a recovery device 

Comments

1 If you’re complying using a recovery device, do you keep the

following records? §63.1307(d)

C Copy of your monitoring and recordkeeping program for

recovered HAP ABA

C Certification of the monitoring device’s accuracy

C Records of periodic calibration of the monitoring device

C Records of parameter-monitoring results

C Amount of HAP ABA recovered each time you measure it

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

59

Section VIII: HAP ABA equipment cleaning checklist (Option 1)

U. Requirements for HAP ABA Equipment Cleaning Comments

1 Are your cleaning operations free of HAP or HAP based materials? 

§63.1298

Q Yes Q No

V. Recordkeeping Requirements for HAP ABA Equipment Cleaning Comments

1 Do you have a product data-sheet for each equipment cleaner you

used? Does the product data-sheet include the HAP content, in kg of

HAP/kg solids (or lb of HAP/lb of solids)? §63.1307(e)

Q Yes Q No

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

60

Section IX: Sourcewide emission limit checklist (Option 2)

W. Requirements for Sourcewide Emission Limit

Note: This includes emissions from HAP ABA storage and equipment leaks, HAP ABA

emissions from the production line and equipment cleaning

Comments

1 Do you use rolling-annual or monthly methods to comply with the

sourcewide allowable limits on HAP ABA emissions? §63.1299

Q annual

Q monthly

2 If you determine compliance on a rolling-annual basis and don’t use

a recovery device, are actual sourcewide HAP ABA emissions from

the facility (including storage, equipment leaks, production line, and

equipment cleaning) less than the sourcewide allowable HAP ABA

emissions for each consecutive 12-month period? §63.1299(a)

Q Yes Q No Actual sourcewide value:

Allowable sourcewide

value: 

3 If you determine compliance on a rolling-annual basis and don’t use

a recovery device, do you calculate allowable HAP emissions for 12

consecutive months using equation 6? §63.1299(a); §63.1299(d)

Q Yes Q No Value Equation 6:

4 If you determine compliance on a rolling-annual basis and don’t use

a recovery device, do you use Equation 5 in §63.1299(c) to calculate

the actual, monthly sourcewide HAP emissions? §63.1299(c)(1)

Q Yes Q No Value Equation 5:

5 If you determine compliance on a rolling-annual basis and don’t use

a recovery device, do you determine the amount of HAP ABA in a

storage vessel weekly by monitoring using a level measurement

device? §63.1299(c)(2); §63.1303(d)

Q Yes Q No Last weekly value:

6 If you determine compliance on a rolling-annual basis and don’t use

a recovery device, do you determine the amount of HAP ABA added

to the storage vessel monthly by summing the individual HAP ABA

deliveries that occur in that month? §63.1299(c)(3); §63.1303(e)

Q Yes Q No Last monthly value:

7 If you determine compliance on a rolling-annual basis and don’t use

a recovery device, do you calculate annual emissions by summing the

actual monthly sourcewide HAP emissions for each of the individual

12 months in the period? §63.1299(c)(4)

Q Yes Q No

8 If you determine compliance on a monthly basis and don’t use a

recovery device, do you compare actual HAP emissions for each

month to allowable HAP emissions for that month? §63.1299(b)

Q Yes Q No Last actual HAP value:

Last allowable HAP value:

9 If you determine compliance on a monthly basis and don’t use a

recovery device, do you use Equation 5 in §63.1299(c) to calculate

actual, sourcewide, emissions? §63.1299(c)(1)

Q Yes Q No Value Equation 5:

10 If you determine compliance on a monthly basis and don’t use a

recovery device, do you determine the amount of HAP ABA in a

storage vessel weekly by monitoring using a level measurement

device? §63.1299(c)(2); §63.1303(d)

Q Yes Q No Last weekly value:
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

W. Requirements for Sourcewide Emission Limit

Note: This includes emissions from HAP ABA storage and equipment leaks, HAP ABA

emissions from the production line and equipment cleaning

Comments

61

11 If you don’t use a solvent-recovery device and you determine

compliance on a monthly basis, do you determine the amount of

HAP ABA added to the storage vessel monthly by summing the

individual HAP ABA deliveries that occur in that month? 

§63.1299(c)(3); §63.1303(e)

Q Yes Q No Last monthly value:

12 If you determine compliance on a rolling-annual or monthly basis

and you use a solvent-recovery device, do you use Equation 6 to

calculate the allowable HAP emissions for each month? §63.1299(e)

Q Yes Q No Value Equation 6:

13 If you determine compliance on a rolling-annual or monthly basis

and you use a solvent-recovery device, do you use Equation 7 to

calculate actual, monthly, HAP ABA emissions? §63.1299(e)(1)

Q Yes Q No Value Equation 7:

14 If you determine compliance on a rolling-annual or monthly basis

and you use a solvent-recovery device, have you submitted a HAP

ABA monitoring program for approval? §63.1299(e)(2); §63.1303(c)

Q Yes Q No Submittal date:

Approval date:

X. Monitoring Requirements for Sourcewide Emissions when a Recovery Device is Used

SKIP this section if you don’t use a recovery device 

Comments

1 Have you sent a recovered HAP monitoring and recordkeeping plan

in for approval? §63.1303(c)

Q Yes Q No Date Sent:

Date Approved:

2 Does your equipment have a device showing the cumulative amount

of HAP ABA recovered by the solvent-recovery device each month? 

§63.1303(c)(1)

Q Yes Q No Last cumulative monthly

value:

3 Has the manufacturer certified the device to be accurate within +/-

2.0 percent? §63.1303(c)(1)

Q Yes Q No Device accuracy:

4 Do you measure after fully recovering the HAP ABA (i.e., after

separating it from water introduced into the HAP ABA during

regeneration)? §63.1303(c)(2)

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

62

Y. Recordkeeping Requirements for Sourcewide Emissions Comments

1 If you’re complying using rolling-annual or monthly compliance

option, do you keep the following production-line records daily?

§63.1303(c)(2)(i)

C Foam run log, with a list of the grades produced during each run

C Amount of polyol added to the production line for slabstock

foam at the mixhead for each run (not required if zero is the

formulation limit for HAP ABA)

C Results of the density and IFD testing for each grade of foam

produced during each run of foam (not required on grades of

foam for which you’ve designated a zero formulation limit for

HAP ABA)

Q Yes Q No

Q Yes Q No

Q Yes Q No

2 If you’re complying using rolling-annual or monthly compliance

option, do you keep weekly records of the storage tank level? 

§63.1303(c)(2)(ii)

3 If you’re complying using rolling-annual or monthly compliance

option, do you keep the following records monthly? 

§63.1307(c)(2)(iii)

C List of all foam grades produced during the month

C Formulation limit on residual HAP for each foam grade

produced

C Total amount of polyol used in the month for each foam grade

produced (not required if zero is the formulation limit for HAP

ABA)

C Total allowable HAP ABA and equipment-cleaning emissions

for the month

C Total actual sourcewide emissions of HAP ABA for the month

C Amounts of HAP ABA in the storage vessel at the beginning

and end of the month

C Amount of each delivery of HAP ABA to the storage vessel

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

4 If complying by the rolling-annual or monthly option, do you keep

the following? §63.1307(c)(2)(v) - (vii)

C Records of all calibrations for each device used to measure

polyol added at the mixhead

C Records of all calibrations for each device used to measure

amount of HAP ABA in the storage vessel

C Written confirmation of State or local approval of scales, or the

registered scale technician’s report for all scales used to

measure the amount of HAP ABA added to storage vessels

Q Yes Q No

Q Yes Q No

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

Y. Recordkeeping Requirements for Sourcewide Emissions Comments

63

5 If you’re complying using the rolling-annual option, do you keep the

following records monthly? §63.1307(c)(2)(iv)

C Total allowable HAP ABA and equipment-cleaning emissions of

HAP for the month and the previous 11 months.

C Total actual HAP ABA and equipment-cleaning emissions of

HAP for the month and the previous 11 months.

Q Yes Q No

Q Yes Q No

Z. Recordkeeping Requirements for Sourcewide Emissions when a Recovery Device is Used

SKIP this section if you don’t use a recovery device 

Comments

1 If you’re complying using a recovery device, do you keep the

following records? §63.1307(d)

C Copy of your monitoring and recordkeeping program for

recovered HAP ABA

C Certification of the monitoring device’s accuracy

C Records of periodic calibration of the monitoring device

C Records of parameter-monitoring results

C Amount of HAP ABA recovered each time you measure it

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

64

Section X: Testing checklist (Options 1 or 2 as required)

AA. Testing Requirements Comments

1 For each time you use Method 21, is the instrument’s response factor

based on the fluid’s average composition, rather than on the

individual VOC in the stream? §63.1304 (a)(2)

Q Yes Q No

2 If the source stream contains nitrogen, air, or other inerts that aren’t 

HAP or VOC, do you calculate the average stream response factor on

an inert-free basis? §63.1304 (a)(2)

Q Yes Q No

3 Do you calibrate the detection instrument before each use on the day

of its use according to Method 21, Appendix A, of 40 CFR Part 60?

§63.1304 (a)(3)

Q Yes Q No Date Last Use:

Date Last Calibration:

4 Are calibration gases zero air (less than 10 ppm of hydrocarbon in

air)? §63.1304 (a)(4)

Q Yes Q No Calibration gas used:

5 Are calibration gases a mixture of methane and air at a concentration

of about 1,000 ppm for all transfer pumps and 500 ppm for all other

equipment? §63.1304 (a)(4)

Q Yes Q No

6 If the instrument design allows for multiple concentrations of gas, is

the lower concentration no higher than 2,000 ppm methane and the

higher concentration no higher than 1,000 ppm methane? §63.1304

(a)(4)

Q Yes Q No

7 Do you monitor when the equipment is in HAP ABA service, with an

acceptable surrogate volatile organic compound that isn’t a HAP

ABA, or with any other detectable gas or vapor? §63.1304 (a)(5)

Q Yes Q No

8 If the instrument used for monitoring doesn’t meet the performance

criteria in Method 21, do you adjust readings by multiplying the

average response factor for the stream? §63.1304 (a)(6)

Q Yes Q No Value average response

factor:

9 Unless the formulation limit for HAP ABA is zero, do you use

ASTM D3574 to determine the IFD for each grade of foam produced

during each run? §63.1304 (b)

Q Yes Q No

10 Do you cut each sample of foam from the center of the foam bun? 

§63.1304 (b)

Q Yes Q No

11 Is each sample of foam no larger than 24 inches by 24 inches by 4

inches? §63.1304 (b)

Q Yes Q No
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont’d)

65

Section XI: Reporting Requirements (Options 1 or 2)

BB. Reporting Requirements Comments

1 Did you send in an initial notification form? §63.1306(a) Q Yes Q No Date submitted:

2 Have you applied for approval of construction or reconstruction? 

§63.1306(b)

Q Yes Q No Date submitted:

3 Did you send in a precompliance report? §63.1306(c) Q Yes Q No Date submitted:

4 Did you send in a notification of compliance status? 

§63.1306(d)(4)

Q Yes Q No Date submitted:

5 Do you send in semiannual compliance reports no later than 60

days after the end of the 180-day period? §63.1306(e)

Q Yes Q No Date end of period:

Date submitted:

6 Do you submit an annual compliance certification? §63.1306(g) Q Yes Q No Date first certification

due:

Date certification

submitted:

7 If you switch from emission point specific limit to sourcewide

limit, or vice versa, did you make notification before changing? 

§63.1306(f)

Q Yes Q No Date Notification

Submitted:

Date Limit

Switched:

8 If you switch from rolling-annual to monthly, or vice versa, did

you make notification before changing? §63.1306(f)

Q Yes Q No Date Notification

Submitted:

Date Method Switched:

Additional comments:
Chapter 4 - Complying with requirements for molded foam

66

Definition. A molded flexible polyurethane process

means “a flexible polyurethane foam that is produced by

shooting the foam mixture into a mold of the desired

shape and size. Molded foam is primarily used in

automobile, furniture, packaging, textiles and fiber

manufacturing.”

Definition. 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.”

Definition. Foam fabrication process means “an operation for cutting or bonding flexible

polyurethane foam pieces together or to other substrates.”

What does the Molded section cover?

§63.1300 of the rule covers your molded foam process if your process meets all of the following

conditions:

C emits a HAP

C is a molded foam production process

C is located at a plantsite that is a major source of HAPs

C is not exempt

Figure 4.1 (on page 67) shows a typical process for molded foam.

What is exempt under this section?

Your molded foam process is exempt if it’s devoted exclusively to either of the following

[§63.1290]:

C fabricating molded foam 

• conducting research and development

About this Chapter:

C Whenever you see “§,” we are

referring to the section number

of the rule. You can go to that

section in the rule for more

information

C When you see a definition, it

comes straight from the rule
67
68

Definitions.

mold-release agent means “any material (when applied to

the mold surface) which prevents sticking of the foam part

to the mold.”

HAP-based means “any compound used as an equipment

cleaner or mold-release agent that contains five percent (by

weight) or more of HAP.”

mixhead means “a device that mixes two or more

component streams before dispensing the foam producing

mixture to the desired container.”

What compliance options do I have?

You have two compliance options for molded foam. 

• Option 1: do not use HAP-based materials in any of the following ways [§63.1300(a), (b)]:

< as an equipment cleaner to flush the mixhead (except for diisocyanates)

< as an equipment cleaner elsewhere in the process

< as a mold-release agent

The rule does allow you to use diisocyanates (but no other HAP) for flush cleaning the mixhead

and associated piping. However, if you do use diisocyanates for flushing, you must meet all of

the following conditions [§63.1300(a)]:

< flushing occurs only during startup or maintenance

< diisocyanates are contained in a closed-loop system

< diisocyanates are reused in production

• Option 2: you may submit an alternative means of emission limitation under §63.1305. You

can submit your request in your Precompliance Report, your Application for Approval of

Construction or Reconstruction, or at any other time, as long as it contains the information

required in §63.1305. Your request must be approved by the EPA before you use it. See

Chapter 7 for additional information. 

What monitoring must I do?

None for molded foam production. 
69

What records must I keep?

You must keep two basic pieces of information for each molded foam process [§63.1307(g), (h)]:

• a product data-sheet (e.g., MSDS) for each solvent and mold-release agent you use

C the HAP content for each solvent or mold-release agent you use (in kg of HAP/kg solids or

lb HAP/lb solids)

What reports must I submit?

You must submit four types of reports on each molded foam plant:

C an initial notification [§§63.1306(a), 63.9(b)]

C an application for approval for construction or reconstruction [§§63.1306(b), 63.5(d)]

C a notification of compliance status [§63.1306(d)]

C an annual compliance certification [§63.1306(g)]

For additional reporting information including dates and example forms, see Chapter 7. The forms

are optional, but you may find them useful.

How do I show compliance?

You can show compliance with §63.1300 by following all these requirements [Table 5 of the rule]:

C don’t use a HAP-based material as an equipment cleaner (except for diisocyanates) 

[§63.1300(a)]

C don’t use a HAP-based mold-release agent [§63.1300(b)]

C maintain product data-sheets for each solvent you use [§63.1307(g)]

C maintain product data-sheets for each mold-release agent you use [§63.1307(h)]

You will violate §63.1300 if you do any of the following [§63.1308(e)]:

C fail to meet the requirements in §63.1300

C use a HAP-based material in the molded foam process (except for diisocyanates)

C use a HAP-based mold-release agent

Is an inspection checklist available?

We’ve included an inspection checklist in Table 4.1 (on page 70). You can use the checklist when

you check your foam plant for compliance with the rule.
Table 4.1 Checklist for Inspecting Molded foam Plants

70

Facility Name: _______________________________________________________

Facility Location: _______________________________________________________

Facility TRI ID #: _______________________________________________________

Person Conducting Evaluation: _______________________________________________________

Date of Evaluation: _______________________________________________________

A. HAP Usage

 Note: If you answer NO to ALL questions in Section A, don’t proceed. Your molded

foam process isn’t covered because you don’t use HAPs. 

Comments

1 Do you use HAPs as an equipment cleaner to flush the mixhead or

associated piping? §63.1300 (a)

You may use diisocyanates as an equipment cleaner if you follow

procedures in section B. If you use diisocyanates as an equipment

cleaner, complete section B.

Q Yes Q No

2 Do you use HAPs as an equipment cleaner elsewhere in the process? 

§63.1300 (a)

Q Yes Q No

3 Do you use HAPs as a mold-release agent? §63.1300 (b) Q Yes Q No

B. Flush Cleaning with Diisocyanates Comments

1 Do you use diisocyanates as an equipment cleaner to flush the

mixhead? §63.1300(a)

Q Yes Q No

2 Do you use diisocyanates as an equipment cleaner to flush associated

piping? §63.1300(a)

Q Yes Q No

3 Do you use diisocyanates only during startup or maintenance? 

§63.1300(a)

Q Yes Q No

4 Are diisocyanates contained in a closed-loop system? §63.1300(a) Q Yes Q No

5 Do you reuse diisocyanates in production? §63.1300(a) Q Yes Q No

C. Recordkeeping Comments

1 Do you have product data-sheets for each compound used? 63.1307(g) Q Yes Q No

2 Is HAP data available for each compound you use (expressed in kg of

HAP/kg solids or lb HAP/lb solids)? §63.1307(g)

Q Yes Q No

3 Do you have product data-sheets for each mold-release agent use? 

§63.1307(h)

Q Yes Q No
Table 4.1 Checklist for Inspecting Molded foam Plants (cont’d)

C. Recordkeeping Comments

71

4 Is HAP data available for each mold-release agent you use (expressed

in kg of HAP/kg solids or lb HAP/lb solids)? §63.1307(h)

Q Yes Q No

D. Reporting Comments

1 Did you submit an initial notification? §63.1306(a) Q Yes Q No Date last submitted:

2 Have you applied for approval of construction or reconstruction? 

§63.1306(b)

Q Yes Q No Date last submitted: 

3 Did you submit a notification of compliance status? §63.1306(d)(4) Q Yes Q No Date last submitted: 

4 Did you submit an annual compliance certification? §63.1306(g) Q Yes Q No Date last submitted:

Additional comments:
Chapter 5 - Complying with requirements for rebond foam

72

Definition. Rebond foam means “the foam resulting

from a process of adhering small particles of 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.”

What does the Rebond section cover?

§63.1301 of the rule covers your process for rebond foam your process meets all of the following

conditions:

C is located at facility that is a major source of HAPs

C uses a HAP

C is a rebond foam production process

C is not exempt

§63.1301 covers these parts of your rebond foam process:

C storage areas for raw materials

C production equipment and associated piping, ductwork, etc.

C curing and storage areas

Figure 5.1 (on page 73) shows a typical process for rebond foam.

What is exempt under this section?

Your rebond foam process, or portions of your process, are exempt if it’s devoted exclusively to

either of the following: [§63.1290(c)]

C fabricating rebond foam

C conducting research and development

About this Chapter:

C Whenever you see “§,” we are

referring to the section number

of the rule. You can go to that

section in the rule for more

information

C When you see a definition, it

comes straight from the rule
73
74

Definition. 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.” 

Definition. Foam fabrication process means “an operation for cutting or

bonding flexible polyurethane foam pieces together or to other substrates.” 

Definitions.

mold-release agent means “any material (when applied to

the mold surface) which prevents sticking of the foam part

to the mold.”

HAP-based means “any compound used as an equipment

cleaner or mold-release agent that contains five percent

(by weight) or more of HAP.”

What compliance options do I have?

You have two compliance options for your rebond foam process.

• Option 1: do not use HAP-based materials in any of the following ways [§63.1301(a), (b)]:

< as an equipment cleaner

< as a mold-release agent

• Option 2: you may submit an alternative means of emission limitation under §63.1305. You

can submit your request in your Precompliance Report, your Application for Approval of

Construction or Reconstruction, or at any other time, as long as it contains the information

required in §63.1305. Your request must be approved by the EPA before you use it. See

Chapter 7 for additional information. 

What monitoring must I do?

None for rebond foam. 
75

What records must I keep?

You must keep two basic pieces of information for each rebond foam process [§63.1307(g), (h)]:

C a product data-sheet for each solvent and mold-release agent you use

C the HAP content for each solvent or mold-release agent you use (in kg of HAP/kg solids or

lb HAP/lb solids)

What reports must I submit?

You must submit four types of reports for each rebond foam plant:

C an initial notification [§§63.1306(a), 63.9(b)]

C an application for approval of construction or reconstruction [§§63.1306(b), 63.5(d)]

C a notification of compliance status [§63.1306(d)]

C an annual compliance certification [§63.1306(g)]

For additional reporting information including dates and example forms, see Chapter 7. The forms

are optional, but you may find them useful.

How do I show compliance?

You can show compliance with §63.1301 by meeting all of the following conditions [Table 5 of the

rule]:

C don’t use a HAP-based material as an equipment cleaner [§63.1301(a)]

C don’t use a HAP-based mold-release agent [§63.1301(b)]

C maintain product data-sheets for each solvent you use [§63.1307(g)]

C maintain product data-sheets for each molded release agent you use [§63.1307(h)]

You will violate §63.1300 if you do any of the following [§63.1308(e)]:

C fail to meet the requirements in §63.1301

C use a HAP-based material in the rebond foam process

C use a HAP-based mold-release agent

Is an inspection checklist available?

We’ve included an inspection checklist in Table 5.1 (on page 76). You can use the checklist when

you check your foam plant for compliance with the rule.
76

Table 5.1 Checklist for Inspecting Rebond foam Plants

Facility Name: _______________________________________________________

Facility Location: _______________________________________________________

Facility TRI ID #: _______________________________________________________

Person Conducting Evaluation: _______________________________________________________

Date of Evaluation: _______________________________________________________

A. HAP Usage

 Note: If you answer NO to ALL questions in Section A, don’t proceed. Your rebond

foam process isn’t covered because you don’t use HAPs. 

Comments

1 Do you use HAPs as equipment cleaners? §63.1301(a) Q Yes Q No

2 Do you use HAPs as a mold-release agent? §63.1301(b) Q Yes Q No

B. Recordkeeping Comments

1 Do you have product data-sheets available for each compound used? 

§63.1307(g)

Q Yes Q No

2 Is HAP data available for each compound use (expressed in kg of

HAP/kg solids or lb HAP/lb solids)? §63.1307(g)

Q Yes Q No

3 Do you have product data-sheets for each mold-release agent you use?

 §63.1307(h)

Q Yes Q No

4 Is HAP data available for each mold-release agent you use?

(expressed in kg of HAP/kg solids or lb HAP/lb solids)? §63.1307(h)

Q Yes Q No

C. Reporting Comments

1 Did you submit an initial notification form? §63.1306(a) Q Yes Q No Date last submitted: 

2 Have you applied for approval of construction or reconstruction? 

§63.1306(b)

Q Yes Q No Date last submitted: 

3 Did you submit a notification of compliance status? §63.1306(d)(4) Q Yes Q No Date last submitted: 

4 Did you submit an annual compliance certification? §63.1306(g) Q Yes Q No Date last submitted:

Additional comments:
Chapter 6 - Calculations and procedures

77

How do I calculate HAPused to see if I’m exempt from the rule?

If your slabstock foam production process is at a facility that uses less than five tons per year of

HAP (HAPused), it may be exempt from the rule [§63.1290(c)(3)]. HAPused refers to the amount of

HAP chemicals used, not to HAP emissions. 

HAPused is the total amount of HAP (excluding

diisocyanate used as a reactant) that the facility

consumes. This exemption is only allowed if

your slabstock foam production and foamfabrication processes are the only processes at

the plant site that emit HAP.

In other words, this includes all HAP ABA used in the production of slabstock foam, all HAP

cleaners used at the plant site, and all HAP adhesives used in foam fabrication operations at the plant

site. It does not include diisocyanates used as a reactant to make the slabstock foam. It includes

HAP used in all parts of the plant, including the ones that aren’t producing slabstock foam. Equation

1 of the rule, §63.1290(c)(3), contains the HAPused calculation. Following are two examples of

facilities that are trying to take advantage of this exemption.

Example 1

Assumptions:

C The plant site includes two lines for slabstock foam production and foam-fabrication

operations.

C Both slabstock production lines are equipped with liquid carbon dioxide ABA systems, but

one line still uses 625 gallons per year of methylene chloride for specialty applications.

C 100 gallons of methylene chloride are used each year to clean the slabstock mixhead

C The foam fabrication operation uses 1,300 gallons of adhesive XYZ with the following

properties: 

Density of adhesive - 9.8 lb/gal

Methylene chloride content of adhesive - 60 weight percent

Use Equation 1 to see if your facility uses less than 5

tons per year of HAP
78

HAPused'[j

m

i'1

(VOLABA,i)(DABA,i)%j

n

j'1

(VOLclean,j)(Dclean,j)(WTHAPclean,j)%

j

o

k'1

(VOLadh, k)(Dadh,k)(WTHAPadh, k)]÷ 2000

HAPused '

(625)(10.4) % (100)(10.4)(1.0) % (1,300)(9.8)(0.60)

2,000

' 7.6 tons/yr

Equation 1 from the Rule:

where,

HAPused = amount of HAP, excluding toluene diisocyanate reactants, used at the plant

site for slabstock foam production and foam fabrication, tons per year

VOLABA,i = volume of methylene chloride used as an ABA i at the facility - 625 gal 

per year

DABA,i = density of methylene chloride ABA - 10.4 pounds per gal

m = number of HAP ABAs used - 1

VOLclean,j = volume of methylene chloride used as an equipment cleaner - 100 gal

per year

Dclean,j = density of methylene chloride equipment cleaner, 10.4 pounds per gal

WTHAPclean,k = HAP content of methylene chloride equipment cleaner - 100 weight percent

n = number of HAP equipment cleaners used - 1

VOLadh,k = volume of adhesive XYZ used - 1,300 gal per year

Dadh,k = density of adhesive XYZ - 9.8 pounds per gal (from MSDS)

WTHAPadh,k = methylene chloride content of adhesive XYZ - 60 weight percent (from

MSDS)

o = number of adhesives used - 1

Therefore, for Example 1, this plant’s production lines for slabstock foam would not be exempt from

the rule under §63.1290(b)(5), since the total HAP used is greater than 5 tons per year.
79

HAPused'[j

m

i'1

(VOLABA,i)(DABA,i)%j

n

j'1

(VOLclean,j)(Dclean,j)(WTHAPclean,j)%

j

o

k'1

(VOLadh,k)(Dadh, k)(WTHAPadh,k)]÷ 2000

Example 2

Assumptions:

C The plant site includes a production line for slabstock foam and foam-fabrication operations.

C The slabstock production line uses acetone as an ABA.

C No HAPs are used as equipment cleaners.

C The foam-fabrication operation uses 1,200 gallons of the water-based adhesive DEF, plus

2,500 gallons of adhesive ABC with the following properties: 

Density of adhesive - 10.1 lb/gal 

Methylene chloride content of adhesive - 70 weight percent

where:

HAPused = amount of HAP, excluding TDI reactants, used at the plantsite for slabstock

foam production and foam fabrication, tons per year

VOLABA,i = volume of HAP ABA used at the facility - N/A

DABA,i = density of HAP ABA - N/A

m = number of HAP ABAs used - 0

VOLclean,j = volume of HAP used as equipment cleaner -NA

Dclean,j = density of HAP equipment cleaner, N/A

WTHAPclean,k = HAP content of equipment cleaner - N/A

n = number of HAP equipment cleaners used - 0

VOLadh,ABC = volume of adhesive ABC used - 2,500 gal /yr

Dadh,ABC = density of adhesive ABC - 10.1 pounds per gal (from MSDS)

WTHAPPAdh,ABC = methylene chloride content of adhesive ABC - 70 weight percent (from

MSDS)

VOLadh,DEF = volume of adhesive DEF used - 1,200 gal /yr

Dadh,DEF = density of adhesive DEF - N/A

WTHAPadh,DEF = HAP content adhesive ABC - 0 weight percent

o = number of adhesives used - 2
80

HAPused'

(0)(0)%(0)(0)(0)%[(1,000)(10.2)(0.70)%(1,000)(0)(0)]

2,000

'3.6tons/yr

ABAlimit'&0.25(IFD) &19.1(

1

IFD

)&16.2(DEN)&

7.56(

1

DEN

)%36.5

Therefore, for Example 2, the slabstock foam process would be exempt from the regulation

according to §63.1290(c)(3) since the total HAP used is less than 5 tons per year.

How do I calculate the HAP ABA formulation limit for a grade of

foam?

The HAP ABA formulation limit is used to calculate the allowable HAP ABA emissions (if your

using the emission point specific compliance

option) and the allowable sourcewide HAP

emissions (if using the sourcewide compliance

option).

Equation 3 of the rule [§63.1297(d)(1)] contains the HAP formulation limit. To determine the limit

for a foam grade, you need the Indentation Force Density (IFD) in pounds and the density in pounds

per cubic foot (pcf). Following are two examples of determining this limit.

Example 3

Assumption:

C You want to make a foam with a density of 1.2 pounds per cubic foot (pcf) and an IFD of 28

pounds.

Equation 3 from the rule:

where:

ABAlimit = HAP ABA formulation limitation, parts HAP ABA allowed per hundred

parts polyol (pph).

IFD = Indentation force deflection of the foam grade you want to produce -

28 pounds.

Use Equation 3 to calculate the HAP ABA

formulation limit
81

ABAlimit'&0.25(28) &19.1(

1

28

)&16.2(1.2)&

7.56(

1

1.2

)%36.5 ' 3 pph

ABAlimit'&0.25(30) &19.1(

1

30

)&16.2(2.1)&

7.56(

1

2.1

)%36.5 ' &9 pph

DEN = Density of the foam grade you want to produce - 1.2 pounds per cubic foot

(pcf).

Note: The IFD and density used in the determining the HAP ABA formulation limit are the values

measured using ASTM D3574 (in accordance with §63.1304(b)) after the production of the foam

grade, and not the planned IFD and density.

Therefore, the limit for foam with a density of 1.2 pcf and an IFD of 28 pounds is 3 parts HAP ABA

per 100 parts polyol.

Example 4

Assumption:

C You want to make a foam with a density of 2.1 pcf and an IFD of 30 pounds. 

Using Equation 3 from the rule (see above), where:

ABAlimit = HAP ABA formulation limitation, parts HAP ABA allowed per hundred

parts polyol (pph).

IFD = Indentation force deflection of the foam grade you want to produce - 

30 pounds.

DEN = Density of the foam grade you want to produce - 2.1 pounds per cubic foot

(pcf).

The HAP ABA formulation limitation would be calculated as follows: 

Paragraph §63.1297(d)(1) states that the HAP ABA formulation limit is zero for any grade of foam

if the result of the equation is negative. Therefore, the limit for foam with a density of 2.1 pcf and an

IFD of 30 pounds is 0 parts HAP ABA per 100 parts polyol.
82

emissallow,month '

m

j

j'1

n

j

i'1

(limiti)(polyoli)

100 j

How do I calculate allowable HAP ABA emissions to comply using

the emission point specific limit?

The allowable level of HAP ABA emissions depends on the mix of foam grades you produce during

the compliance period. Use Equation 2 of

the rule [§63.1297(b)(2)] to calculate it. 

Except in cases where a recovery device is

used, the allowable level of HAP ABA

emissions is equal to the maximum amount

of HAP ABA you can use because 100

percent of the ABA used volatilizes and is emitted. Calculate allowable HAP ABA emissions for

each individual month using the following equation:

Equation 2 from the rule:

where:

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

the month, pounds

m = Number of production lines for slabstock foam at the affected source

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

polyoli = Amount of polyol used in the month in producing foam grade i on foamproduction line j, pounds 

To determine the allowable emissions of HAP ABA, use these three basic steps:

Step 1: Determine the HAP ABA formulation limitation for each grade

Step 2: For each month, determine the amount of polyol used to produce each grade

Step 3: Calculate the allowable HAP ABA emissions for each month

The rule allows two options: monthly and rolling-annual compliance. Under the monthly

compliance, compare actual HAP emissions to the allowable HAP emissions for each month. Under

rolling-annual compliance, compare the allowable HAP ABA emissions for 12 consecutive months to

the actual HAP ABA emissions for the same period. The allowable HAP ABA emissions for 12

Use Equation 2 to calculate allowable HAP ABA

emissions
83

ABAlimit'&0.25(30) &19.1(

1

30

)&16.2(0.9)&

7.56(

1

0.9

)%36.5 ' 5 pph

ABAlimit'&0.25(40) &19.1(

1

40

)&16.2(1.5)&

7.56(

1

1.5

)%36.5 ' &3 pph

consecutive months are the sum of allowable monthly HAP ABA emissions for each of the 12

months in the period. Therefore, if you’re using rolling-annual compliance, follow the three steps

above and then:

Step 4: Sum the allowable HAP ABA emissions for each month in the 12-month period.

Example 5 below shows the calculation of allowable HAP ABA emissions using these four steps.

Example 5:

Assumption:

C For June 2002, a slabstock foam facility manufactures the mix of foam grades shown in

Table 6.1 (on page 86), using the amount of polyol for each grade shown in Table 6.3 (page

88). 

Step 1 for Example 5

The first step in calculating allowable HAP ABA emissions is to determine the HAP ABA

formulation limit for each grade. Examples 3 and 4 showed how the HAP ABA formulation limit is

calculated.

Additional examples of how to calculate the HAP ABA formulation limit are below. They show the

calculation of HAP ABA formulation limit for foam grade 0930 (density of 0.9 pcf and IFD of 30

lbs) and foam grade 1540 (density of 1.5 pcf and IFD of 40 lbs). These two foam grades are shown

in Table 6.1. Using Equation 3 from the rule (see Example 3), the HAP ABA formulation limit for

the 0930 foam grade is calculated as follows:

Therefore, the HAP ABA formulation for foam grade 0930 is 5 pph.

 For foam grade 1540, the calculation is as follows:
84

emissallow,month '

m

j

j'1

n

j

i'1

(limiti)(polyoli)

100 j

As previously explained, the HAP ABA formulation limit is zero for any grade of foam where the

result of the equation is negative. Therefore, the HAP ABA formulation for foam grade 1540 is 0

pph. Table 6.2 (on page 87) provides the HAP ABA formulation limitations for all of the foam

grades produced by this example facility.

Step 2 for Example 5

The second step in determining the HAP ABA formulation limit is to obtain the amount of polyol

used for each grade of foam during the compliance period. In this case, the amount of polyol used by

foam grade is shown in Table 6.3

Step 3 for Example 5

The third step is to calculate the allowable HAP ABA emissions for the month. Do this by using

Equation 2 found in §63.1297(b)(2) of the rule.

Equation 2 from rule::

Where:

emissallow,month = Allowable HAP ABA 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, 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.

Calculate the total allowable HAP ABA emissions from the slabstock foam source for a month, by

added together the allowable HAP ABA emissions for each foam grade. Following are examples of 

allowable HAP ABA emissions for foam grades 0930 and 1540.

For foam grade 0930, where:

emissallow,month,0930 = Allowable HAP ABA emissions from the slabstock foam

production source for the month for foam grade 0930, pounds.
85

emissallow,month,0930'

5poundsHAPABAallowed

100poundspolyol

(13,300pounds polyol)' 665 pounds

emissallow,month,1540'

0poundsHAPABAallowed

100poundspolyol

(20,000pounds polyol)' 0 pounds

m = Number of slabstock foam production lines that produce grade

0930 - 1

polyoli

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

grade 0930 - 13,300 pounds.

limiti

= HAP ABA formulation limit for foam grade 0930 - 5 parts

HAP ABA per 100 parts polyol

For foam grade 1540, where:

emissallow,month,1540 = Allowable HAP ABA emissions from the slabstock foam

production source for the month for foam grade 1540, pounds.

m = Number of slabstock foam production lines that produce grade

1540 - 1

polyoli

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

grade 1540 - 20,000 pounds.

limiti

= HAP ABA formulation limit for foam grade 1540 - 0 parts

HAP ABA per 100 parts polyol

Table 6-3 provides the amount of polyol used and the allowable HAP ABA emissions for the month,

for each grade of foam in Example 5. Table 6-3 shows the total allowable HAP ABA emissions for

the example facility during June 2002 would be 4,320 pounds. 

Step 4 for Example 5

You have two options on the compliance period you will use for HAP ABA emission limits - annual

(i.e., rolling 12 month) or monthly. How you complete Step 4 will depend on which compliance

option you choose.
86

Step 4 Using Annual Compliance Option for Example 5

Annual compliance is a rolling 12-month period. If you choose the annual option, the allowable

HAP ABA emissions for the 12-month period would be the allowable HAP ABA emissions for the

month (determined as discussed in Step 3 above), plus the allowable HAP ABA emissions for the

previous 11 months. Here is an example.

Assumption:

• The allowable HAP ABA emissions for June 2002 was 4,320 pounds (as calculated in Step

3 above)

C The allowable HAP ABA emissions (in pounds) for the previous 11 months are: 

May 2002 - 4,112; April 2002 - 3,789; March 2002 - 2,125; February 2002 - 5,552;

January 2002 - 4,001; December 2001 - 3,222; November 2001 - 2,247; October 2001 -

1,785; September 2001 - 3,555; August 2001 - 4,885; and July 2001 - 2,753.

Therefore, the total allowable HAP ABA emissions for the previous 11 months (e.g. July 2001

through May 2002) is 38,026 pounds. This value is added to the June 2002 monthly allowable

emissions of 4,320 pounds. This gives you a total allowable HAP ABA emissions of 42,346 pounds

for the 12-month compliance period.

Step 4 Using Monthly Compliance Option for Example 5

If you choose the monthly option, then the allowable HAP ABA emissions for the compliance period

(i.e., the month) would be determined as discussed above, which is 4,320 pounds.

If I’m complying using the emission point specific limit without

using a recovery device, how do I calculate actual monthly HAP

ABA emissions?

If you aren’t using a recovery device to reduce HAP ABA emissions, your actual HAP ABA

emissions are equal to the amount of

HAP ABA you add at the mixhead. 

Determine the latter amount by

monitoring the HAP ABA pump

revolutions or flow rate. Following is an

example of how to calculate actual HAP

ABA emissions for the facility in Example 5. 

If you’re not using a recovery device, the actual HAP

ABA emissions are equal to the amount of HAP ABA

added at the mixhead
87

Example 6

Assumption:

C The example facility discussed in Example 5 added 4,420 pounds of methylene chloride at

the mixhead during June 2002 (i.e., the same month for which the allowable HAP ABA

emissions were determined in Example 5).

Therefore, the actual HAP ABA emissions for June 2002 are 4,420 pounds. To determine if you are

in compliance for the compliance period, compare the actual HAP ABA emissions to the allowable

HAP ABA emissions. Following are examples of this comparison for the two compliance options.

Example 6 Using Annual Compliance Option

Annual compliance is a rolling 12-month period. If you choose the annual option, then the actual

HAP ABA emissions for the compliance period (i.e., the 12-month period) would be the actual HAP

ABA emissions for the month (4,420 pounds for our example 5 facility) plus the actual HAP ABA

emissions for the 11 previous months. For example,

Assumption:

C The actual HAP ABA emissions (in pounds) for the previous 11 months are:

May 2002 - 3,514; April 2002 - 4,002; March 2002 - 2,052; February 2002 - 5,100;

January 2002 - 3,750; December 2001 - 3,810; November 2001 - 2,440; October 2001 -

1,750; September 2001 - 3,226; August 2001 - 4,500; and July 2001 - 2,666.

Therefore, the total actual HAP ABA emissions for the previous 11 months (e.g. July 2001 through

May 2002) is 37,278 pounds. This value is added to the total actual HAP ABA emissions of 4,420

pounds for June 2002 to obtain the total actual HAP ABA emissions for the 12-month compliance

period (41,698 pounds).

To determine compliance, you will now compare the total actual HAP ABA emissions for the 12-

month period (41,698 pounds) to the total allowable HAP ABA emissions for the same period

(42,346 pounds). Since the actual emissions are less than the allowable emissions for the 12

month period, you are in compliance. This is true even though for five month out of the 12 months

(November 2001, December 2001, March 2002, April 2002, and June 2002), your actual HAP ABA

emissions exceeded the allowable HAP ABA emissions. This demonstrates the flexibility of the 12-

month compliance period.
88

Eactual ' Eunc & HAPABArecovered

Example 6 Using Monthly Compliance Option

If you choose the monthly option, compare the total actual HAP ABA emissions for the month

(4,420 pounds), to the allowable HAP ABA emissions for the month (4,320 pounds). Since the

actual emissions are greater than the allowable emissions for the month, you are out of

compliance. You would also have been out of compliance for November 2001, December 2001,

March 2002, and April 2002.

If I’m complying with the emission point specific limit using a

recovery device, how do I calculate actual emissions? 

If you’re using a recovery device to reduce HAP ABA emissions, the actual HAP ABA emissions are

equal to the amount of HAP ABA you add at

the mixhead minus the amount of HAP ABA

recovered. Use Equation 4 of the rule

[§63.1297(e)(1)] to calculate actual HAP

ABA emissions when a recovery device is

used. 

When a recovery device is used, the

parameters needed to determine the actual HAP ABA emissions are the amount of HAP ABA added

at the mixhead and the amount of HAP ABA recovered. Following is an example of actual emissions

when using a recovery device for the facility used in Example 5.

Example 7

Assumption:

C Assume that the example facility discussed in Example 5 added 26,000 pounds (2500

gallons at 10.4 lbs/gal) of methylene chloride at the mixhead and recovered 21,840 

pounds (2100 gallons at 10.4 lbs/gal) of methylene chloride in June 2002.

The actual HAP ABA emissions for June 2002 would be calculated as follows.

Equation 4 from the rule:

If you use a recovery device, your actual emissions

are equal to the amount of HAP ABA added at the

mixhead minus the amount of HAP ABA recovered. 

Use Equation 4 of the rule to calculate actual

emissions.
89

where:

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

Eunc = Uncontrolled HAP ABA emissions - 26,000 pounds

HAPABArecovered = HAP ABA recovered - 21,840 pounds

Therefore, the actual HAP emissions for June 2002 would be 4,160 pounds.

To determine whether you are in compliance for the compliance period, compare the actual HAP

ABA emissions to the allowable HAP ABA emissions. Following are examples of this comparison

for the two compliance options.

Example 7 Using Annual Compliance Option

Annual compliance period is a rolling 12-month period. Therefore, if you choose the annual option,

the actual HAP ABA emissions for the compliance period (i.e., the 12-month period) would be the

actual HAP ABA emissions for the month (4,160 pounds) plus the actual HAP ABA emissions for

the 11 previous months. Following is an example.

Assumption:

C The actual HAP ABA emissions (in pounds) for the previous 11 months are: 

May 2002 - 3,514; April 2002 - 4,002; March 2002 - 2,052; February 2002 - 5,100;

January 2002 - 3,750; December 2001 - 3,810; November 2001 - 2,440; October 2001 -

1,750; September 2001 - 3,226; August 2001 - 4,500; and July 2001 - 2,666.

Therefore, the total actual HAP ABA emissions for the previous 11 months (e.g. July 2001 through

May 2002) is 37,278 pounds. This value is added to the total actual HAP ABA emissions of 4,160

pounds for June 2002 to obtain the total allowable HAP ABA emissions for the 12-month

compliance period (41,438 pounds).

To determine compliance, compare the total actual HAP ABA emissions for the 12-month period

(41,438 pounds), to the total allowable HAP ABA emissions for the same period (42,346 pounds). 

Since the actual emissions are less than the allowable emissions for the 12 month period, you

are in compliance. This is true even though for four month out of the 12 months (November 2001,

December 2001, March 2002, and April 2002) your actual HAP ABA emissions exceeded the

allowable HAP ABA emissions. This demonstrates the flexibility of the 12-month compliance

period.
90

Example 7 Using Monthly Compliance Option

If you choose the monthly option, then compliance is determined by comparing the total actual HAP

ABA emissions for the month (4,160 pounds), to the allowable HAP ABA emissions for the month

(4,320 pounds). Since the actual emissions are less than the allowable emissions for the month,

you are in compliance. However, you would have been out of compliance for November 2001,

December 2001, March 2002, and April 2002.

If I’m complying with the sourcewide emission limit, how do I

calculate allowable emissions?

If you’re complying with the sourcewide emission limit, the allowable sourcewide HAP emission

level depends on the mix of foam grades produced during the compliance period. Equation 6 of the

rule [§63.1299(d)] contains the allowable sourcewide HAP emission limit calculation. The allowable

sourcewide HAP emission limit is determined in exactly the same manner as the allowable HAP

ABA emission limit would be if complying using the emission point specific limitations. That is,

Equation 6 (which calculates the sourcewide HAP limit) and Equation 2 (which calculates the HAP

ABA emission limit) are identical.

Example 8

Assumptions:

C A facility produces the same foam grades as

those shown in Table 6.1. 

C In June 2002, the facility used the amount of polyol for each foam grade shown in Table 6.3.

Therefore, the allowable sourcewide HAP emissions for the facility for June 2002 are 4,320 pounds. 

This level would be calculated exactly as shown in Example 5.

There are two choices regarding the compliance period for the sourcewide HAP emission limitation -

annual (i.e., rolling 12 month) or monthly.

Example 8 Using Annual Compliance Option

The annual compliance period is a rolling 12-month period. Therefore, if you choose the annual

option, then the allowable sourcewide HAP emissions for the compliance period (i.e., the 12-month

period) would consist of the allowable sourcewide HAP emissions for the month plus the allowable

sourcewide HAP emissions for the 11 previous months. For example,

Use Equation 6 to calculate allowable

sourcewide limits
91

• The allowable sourcewide HAP emissions (in pounds) for the previous 11 months are: May

2002 - 4,112; April 2002 - 3,789; March 2002 - 2,125; February 2002 - 5,552; January

2002 - 4,001; December 2001 - 3,222; November 2001 - 2,247; October 2001 - 1,785;

September 2001 - 3,555; August 2001 - 4,885; and July 2001 - 2,753.

The total allowable sourcewide HAP emissions for the previous 11 months (e.g. July 2001 through

May 2002) is 38,026 pounds. This value is added to the total allowable sourcewide HAP emissions

of 4,320 pounds for June 2002 to obtain the total allowable sourcewide HAP emissions for the 12-

month compliance period, (42,346 pounds).

Example 8 Using Monthly Compliance Option

If you choose the monthly option, then the allowable sourcewide HAP emissions for the compliance

period (i.e., the month) would be 4,320 pounds.

If I’m complying with the sourcewide emission limit without using

a recovery device, how do I calculate actual sourcewide HAP

emissions?

If you’re complying with the sourcewide emission limit, your actual sourcewide HAP emissions are

determined by doing a material balance on the HAP ABA storage vessels. The inputs needed to

determine the sourcewide emissions are the

amounts of HAP ABA in all the storage

vessels at the beginning of the month and at

the end of the month. You will also need the

amount of HAP ABA added to each storage

vessel during the month.

Equation 5 of the rule [§63.1299(c)(1)] is used to calculate actual sourcewide HAP ABA and

equipment emissions.

Example 9

Assumptions:

C The facility discussed in Example 8 has two storage vessels for methylene chloride, each

able to hold 10,000 gallons. Following are the data you need to calculate the actual,

monthly, sourcewide emissions of HAP.

If you’re not using a recovery device, use Equation 5

to calculate actual emissions
92

PWEactual '

n

j

i

(STi,begin & STi,end % ADDi)

Tank 1 Tank 2

Amount of MeCl in tank at beginning of month (lbs) 1,046 80,064

Amount of MeCl in tank at end of month (lbs) 47,300 78,400

Amount of MeCl added to tank (lbs) 50,000 0

Equation 5 from the rule:

where:

PWEactual = Actual sourcewide HAP ABA and equipment cleaning HAP emissions

for a month, in pounds/month.

n = Number of HAP ABA storage vessels - 2.

ST1,begin = Amount of HAP ABA in storage vessel 1 at the beginning of the month,

1,046 pounds.

ST1, end = Amount of HAP ABA in storage vessel 1 at the end of the month,

47,300 pounds.

ADD1

= Amount of HAP ABA added to storage vessel 1 during the month,

pounds - 50,000 pounds.

Therefore, the actual sourcewide HAP emissions for June 2002 are 5,140 pounds.

If I’m complying with the sourcewide emission limit using a

recovery device, how do I calculate actual emissions?

If you’re complying with the sourcewide emission limitations using a recovery device, your actual

sourcewide HAP emissions are calculated

by performing a material balance on the

HAP ABA storage vessels and

subtracting the amount of HAP ABA

recovered. To do the calculation, you’ll

need to know the amount of HAP ABA in

all the storage vessels at the beginning of the month and at the end of the month, the amount of HAP

ABA added to each storage vessel during the month, and the amount of HAP ABA recovered during

the month.

If you’re using a recovery device, use Equation 7 to

calculate actual sourcewide HAP emissions
93

Eactual ' Eunc& HAPABArecovered

'

n

j

i

(STi,begin & STi,end % ADDi

Equation 7 of the rule [§63.1299(e)] is used to calculate actual sourcewide HAP emissions when a

recovery device is used.

Example 10:

Assumptions:

C For the facility discussed in Example 8, assume the following storage vessel data for June

2002.

Tank 1 Tank 2

Amount of MeCl in tank at beginning of month

(lbs)

2,346 40,000

Amount of MeCl in tank at end of month (lbs) 26,832 77,000

Amount of MeCl added to tank (lbs) 40,000 50,000

Lets assume that our example facility recovered 24,250 pounds of methylene chloride in June 2002. 

Equation 7 from rule 

where:

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

Eunc = Uncontrolled sourcewide HAP emissions = 

HAPABArecovered = HAP ABA recovered, 24,250 pounds/month.

Therefore, the actual sourcewide HAP emissions for June 2002 are 4,264 pounds.

To determine whether you are in compliance for the compliance period, compare the actual
94

sourcewide HAP emissions to the allowable sourcewide HAP emissions. Following are examples of

this comparison for the two compliance options.

Example 10 Using Annual Compliance Option

Annual compliance period is a rolling 12-month period. Therefore, if you choose the annual option,

the actual sourcewide HAP emissions for the compliance period (i.e., the 12-month period) would be

the actual sourcewide HAP emissions for the month (4,264 pounds) plus the allowable HAP ABA

emissions for the 11 previous months. For example,

Assumptions:

C The actual sourcewide HAP ABA emissions (in pounds) for the previous 11 months are: 

May 2002 - 3,514; April 2002 - 4,002; March 2002 - 2,052; February 2002 - 5,100;

January 2002 - 3,750; December 2001 - 3,810; November 2001 - 2,440; October 2001 -

1,750; September 2001 - 3,226; August 2001 - 4,500; and July 2001 - 2,666.

The total actual sourcewide HAP ABA emissions for the previous 11 months ( e.g. July 2001

through May 2002) is 37,278 pounds. This value is added to the total actual HAP ABA emissions of

4,264 pounds for June 2002 to obtain the total actual HAP ABA emissions for the 12-month

compliance period (41,542 pounds).

To determine compliance, the total actual sourcewide HAP emissions for the 12-month period

(41,542 pounds), are compared to the total allowable sourcewide HAP emissions for the same period

(42,346 pounds). Since the actual emissions are less than the allowable emissions for the 12

month period, you are in compliance. This is true even though for four of the 12 months

(November 2001, December 2001, March 2002, and April 2002) the actual sourcewide HAP

emissions exceeded the allowable HAP ABA emissions for the month. This demonstrates the

flexibility of the 12-month compliance period.

Example 10 Using Monthly Compliance Option

If you choose the monthly option, then compliance is determined by comparing the total actual

sourcewide HAP emissions for the month (4,264 pounds) to the allowable HAP ABA emissions for

the month (4,320 pounds). Since the actual emissions are less than the allowable emissions for

the month, you are in compliance.
95

How can I check my slabstock process for leaks?

The EPA Publication, APTI Course SI:417, Controlling VOC Emissions from Leaking Process

Equipment (EPA 450/2-82-015), gives helpful information on how to sample equipment and where

leaks may be. You can get information on how to get a copy of this self-instructional course by

going to http://www.epa.gov/oar/oaqps/eog/. 
96

Table 6.1 Foam Grades Produced By The Example Facility

This table shows the density and IFD for example foam grades, some of which are used in

Chapter 6 examples for calculating HAP emissions. 

Grade

Density

(pcf)

 IFD

(lbs)

930 0.9 30

1010 1.0 10

1015 1.0 15

1020 1.0 20

1030 1.0 30

1120 1.1 20

1130 1.1 30

1230 1.2 30

1330 1.3 30

1340 1.3 40

1440 1.4 40

1520 1.5 20

1530 1.5 30

1540 1.5 40

1640 1.6 40

1740 1.7 40

1820 1.8 20

1830 1.8 30

1840 1.8 40

1930 1.9 30

1940 1.9 40

>2020 2.5 25
97

Table 6.2 HAP ABA Formulation Limitations For Foam Grades

Produced By The Example Facility

This table shows the HAP ABA formulation limitations that have been calculated for various

grades of foam.

Grade

Density

(pcf)

 IFD

(lbs)

HAP ABA

Formulation

Limitation

(pph)

 930 0.9 30 5

1010 1.0 10 8

1015 1.0 15 8

1020 1.0 20 7

1030 1.0 30 5

1120 1.1 20 6

1130 1.1 30 4

1230 1.2 30 3

1330 1.3 30 1

1340 1.3 40 0

1440 1.4 40 0

1520 1.5 20 1

1530 1.5 30 0

1540 1.5 40 0

1640 1.6 40 0

1740 1.7 40 0

1820 1.8 20 0

1830 1.8 30 0

1840 1.8 40 0

1930 1.9 30 0

1940 1.9 40 0

>2020 >2.5 >25 0
98

TABLE 6.3 Allowable HAP ABA Emissions For Foam Grades

Produced By The Example Facility

This table shows the allowable HAP ABA emissions, calculated for various grades of foam.

Grade

Density

(pcf)

 IFD

(lbs)

HAP ABA

Formulation

Limitation

(pph)

Amount of

polyol used in

the month

(pounds)

Allowable

HAP ABA

Emissions

(pounds)

 930 0.9 30 5 13,300 665

1010 1.0 10 8 6,600 528

1015 1.0 15 8 6,700 536

1020 1.0 20 7 6,500 455

1030 1.0 30 5 13,500 675

1120 1.1 20 6 6,600 396

1130 1.1 30 4 10,000 400

1230 1.2 30 3 16,500 495

1330 1.3 30 1 10,000 100

1340 1.3 40 0 9,500 0

1440 1.4 40 0 10,750 0

1520 1.5 20 1 7,000 70

1530 1.5 30 0 7,500 0

1540 1.5 40 0 20,000 0

1640 1.6 40 0 19,500 0

1740 1.7 40 0 21,000 0

1820 1.8 20 0 9,000 0

1830 1.8 30 0 8,500 0

1840 1.8 40 0 22,000 0

1930 1.9 30 0 10,000 0

1940 1.9 40 0 16,500 0

>2020 >2.5 >25 0 85,000 0

Totals 335,950 4,320
Chapter 7 - Notification, reporting and alternate monitoring plans

99

What do I have to report and when?

You will need to complete several different types of notifications and reports based on the type of

process at your plant. The term, reports, is used in this section to include both notifications and

reports. Table 7.1 (on page 102) shows what reports you must submit and when they are due. 

Table 7.2 (page 104) gives you details about what should be included in these reports.

How can I change the date my reports are due?

Under the General Provisions, §63.10(a)(5), you may request a change in the date you submit your

reports. You and your EPA Regional Office or State, local or Tribal agency for air pollution control

(from now on referred to as “State”) must mutually agree to the change and the change can’t affect

the frequency that you report. For example, semiannual reports for an existing Slabstock foam

facility are required in June and December of 2004. You may request that these dates be changed to

some other time frame, such as one that coincides with your title V operating permit notifications. 

This doesn’t change your reporting frequency since you’re still submitting your semiannual reports

twice per year.

Changes to reporting dates can begin 1 year after the compliance date (that is, reports required after

10/8/02 can be changed). Reports due before 10/8/02 can’t be changed and must be reported by the

date shown in Table 7.1. Contact your State for more information. 

Where do I send my reports?

The General Provisions §63.9(a) and §63.10(a) require you to submit reports to your State or your

EPA Regional Office or both (dual reporting). Whom you send your reports to depends on whether

your State has been granted the authority to implement the Flexible Polyurethane Foam Production

NESHAP.

You’ll need to submit reports in one of the following ways:

• to your EPA Regional Office if your State has not been delegated the authority to implement

and enforce the Flexible Polyurethane Foam Production NESHAP
100

• to your State with a copy to your EPA Regional Office, if your State has been granted

delegation and we haven’t waived the dual reporting requirement

• to your State if it’s been granted delegation and we’ve waived the dual reporting requirement

Not all State agencies have been granted delegation. Also, as of this publication, our Region I, III,

VIII and X offices haven’t waived the dual reporting requirement under §63.9 and §63.10. This

means if your plant is in Region I (CT, ME, MA, NH, RI, VT), Region III (DE, MD, PA, VA, WV,

District of Columbia), Region VIII (CO, MT, ND, SD, UT, WY), or Region X (AK, ID, WA OR),

you’ll need to submit your reports to your State, local or Tribal agency and the EPA Regional

Office. You’ll find a list of our Regional Offices and their addresses in Chapter 9.

You should check with your EPA Regional Office or State for the latest information on submitting

reports.

Where do I submit my Alternative Programs?

There are two types of alternative programs under the rule.

The first is the alternative means of emission limitation under §63.1305. You would use this

compliance method in cases where you believe you have a better approach than what is required in

the rule for controlling and monitoring HAP emissions at your plant. If you use this approach, you

will develop your own overall compliance strategy and submit it for approval. Since we haven’t

delegated the approval of this alternative to your State agency, you’ll send your alternative means of

emission limitation program to your EPA Regional Office for review and approval. You can do this

by using your Precompliance Report, your Application for Approval of Construction or

Reconstruction, or at any other time as long as the request includes all the information required under

§63.1305(b). Your request must be approved as described in §63.6(g) before you can use the

alternate emission limit.

The second type of alternative program is the alternative monitoring program. You can choose to

develop an alternative monitoring program for HAP Auxiliary Blowing Agent (ABA) and polyol

added to the foam production line at the mixhead [§63.1303(b)(5)], and HAP ABA added to storage

vessels [§63.1303(e)(4)]. This means that you would be developing your own compliance strategy

for monitoring these two sections of the rule and submit it for approval. You can send in your

alternative monitoring program by using your Precompliance Report, your Application for Approval

of Construction or Reconstruction, or at any other time as long as the request includes all the

information under §63.1303(b)(5) and §63.1303(e)(4).

We haven’t granted delegation of the alternative monitoring program under §63.1303(b)(5) to your

State agency. This means that you’ll submit your request to determine the HAP ABA and polyol

added to the line at the mixhead to your EPA Regional Office for review and approval.
101

However, your request for determining HAP ABA added to storage vessels under §63.1303(e)(4)

should be submitted as you would any other reports. Your request must be approved before you can

use the alternative program. If your regulatory agency doesn’t notify you of any objections to your

alternative program within 45 days after they receive it, your program will be deemed approved.

If you’re using a recovery device to reduce HAP ABA emissions, you’re also required under

§63.1303(c)(6) to develop and submit a recovery HAP ABA monitoring and recordkeeping

program. This means that you’ll send in a program (plan) that describes what type of recovery

device you’ve installed and how you’ll monitor whether the device is operating properly. You can

send in your plan by using your Precompliance Report, your Application for Approval of

Construction or Reconstruction, or at any other time as long as it includes all the information under

§63.1306(c)(6). You should send in your plan as you would any other report. Your plan must be

approved before you can use it. If your regulatory agency doesn’t notify you of any objections

within 45 days after they receive it, your plan will be deemed approved. 

Can I get example reporting forms?

We’ve included example forms for all reports this rule requires. You’ll find the following example

reports in this chapter:

 Page

• Initial Notification Report 108

• Application for Approval of Construction or Reconstruction 110

• Precompliance Report 115

• Notification of Compliance 121

• Semi-annual Compliance Report 124

• Change in Selected Emission Limit and Compliance Method 128

• Annual Compliance Certification 129

You may use these forms for reporting, but you don’t have to use them. You may want to check

with your State agency to make sure they don’t have their own forms, or, if you do use these forms,

check to see if they meet your State requirements first.
102

Table 7.1 - Report Due Dates

If you have. . . And need to submit a . . . Then submit the report

before . . .

An existing Slabstock,

Molded or Rebond plant

Initial Notification Report [§63.1306(a)] 2/4/99

(120 days after the effective

date)

Application for Approval of Construction or

Reconstruction, if reconstructing after 10/7/98

(effective date) [§63.5(d)]

Application for Approval of Construction or

Reconstruction, if reconstruction started before

10/7/98 (effective date), but, your initial startup

was after 10/7/98 (effective date) [§63.5(d)]

As soon as practicable before

reconstruction is planned to start

but no sooner than 10/7/98

(effective date)

As soon as practicable before

reconstruction is planned to start

but no later than 12/6/98

(60 days after the effective date)

Notification of Compliance [§63.1306(d)] 4/6/02

(180 days after the compliance

date)

Annual Compliance Certification [§63.1306(g)] Annually - can submit with

semi-annual report

An existing Slabstock

plant

Precompliance Report [§63.1306(c)] 10/8/00

(12 months before compliance

date)

(These requirements are in

addition to the above)

Initial Semi-annual Compliance Report 

[§63.1306(e)]

Compliance period is for 180 days (240 days

minus 60 days allowed to submit report)

12/2/02 (include information

from 4/6/02 - 10/3/02)

(240 days after Notification of

Compliance) 

Subsequent Semi-annual Compliance Reports 

[§63.1306(e)]

180 day (6 month) period starts after the

initial semiannual compliance report.

6/2/03 (include information from

10/4/02 - 4/3/03);

12/2/03 (include information

from 4/4/03 - 10/3/03);

6/2/04 (include information from

10/4/03 - 4/3/04);

12/2/04 (include information

from 4/4/04-10/3/04); etc.

(60 days after each 180 day

period)
Table 7.1 - Report Due Dates (cont’d)

If you have. . . And need to submit a . . . Then submit the report

before . . .

103

Change in Selected Emission Limit and

Compliance Method [§63.1306(f)(1),(2)]

180 days before the change

takes effect

(120 days after the effective

date)

A new Slabstock,

Molded 

or Rebond plant

Initial Notification Report [§63.1306(a)] 2/4/99 or 120 days after initial

startup or use your construction 

permit

Application for Approval of Construction or

Reconstruction, if constructing after 10/7/98

(effective date) [§63.5(d)]

Application for Approval of Construction or

Reconstruction, if reconstruction started before

10/7/98 (effective date), but, your initial startup

was after 10/7/98 (effective date) [§63.5(d)]

As soon as practicable before

construction is planned to start

but no sooner than 10/7/98

(effective date)

As soon as practicable before

construction is planned to start

but no later than 12/6/98

(60 days after the effective date)

Notification of Compliance [§63.1306(d)] 240 days after initial startup

Annual Compliance Certification [§63.1306(g)] Annually - can submit with semiannual report

A new Slabstock plant Precompliance Report [§63.1306(c)] 10/7/00 or 12 months after initial

startup, whichever is later

(These requirements are in

addition to the above)

Initial semi-annual Compliance Report 

[§63.1306(e)]

240 days after the notification of

compliance is due

Subsequent semi-annual Compliance Reports 

[§63.1306(e)]

240 days after the Initial semiannual Compliance Report and

every 60 days after the end of

each 180 day period thereafter

Change in Selected Emission Limit and

Compliance Method [§63.1306(f)(1),(2)]

180 days before the change takes

effect
Table 7.2 Reporting Requirements

104

If you are submitting 

an. . . 

then submit by . . . and include the following information . . . according to these

sections of the rule...

Initial Notification

Report

[slabstock, molded and

rebond foam plants]

120 days after the

effective date or 120

days after rule applies

to your facility

Name and address of owner or operator.

Address (physical location) of the facility.

Compliance date.

Brief description of nature, size, design, and method of operation.

Identify each point of emission for each hazardous air pollutant.

Statement of whether you’re a major or area source.

§63.1306(a); §63.9(b)

Application for

Approval of

Construction or

Reconstruction

[slabstock, molded and

rebond foam plants]

Before construction or

reconstruction

Applicant’s name and address.

Notification of intent to construct or reconstruct.

Address (physical location) of the facility.

Identify the standard you’re subject to. 

Date that you expect to start construction or reconstruction.

Date that you expect to finish construction or reconstruction.

Date you expect to start operating (initial startup).

Type and amount of HAP you’re emitting or expect to emit.

For construction, description of proposed nature, size, design, method of operation and

emission controls and other information under §63.5(d)(2).

For reconstruction, brief description of the facility, parts to be replaced and emission

controls and other information under §63.5(d)(3).

§63.1306(b); §63.5(d)
Table 7.2 Reporting Requirements (cont’d)

If you are submitting 

an. . . 

then submit by . . . and include the following information . . . according to these

sections of the rule...

105

Precompliance Report

[slabstock foam plants]

12 months before

compliance date

Whether you’ll comply using the emission point specific limit or sourcewide emission

limit.

Whether you’ll comply on a rolling-annual or monthly basis.

Description of how you’ll monitor HAP ABA or polyol added at the mixhead.

Notice of your intent to use a recovery device.

A copy of your program for continuous monitoring and recordkeeping on recovered HAP

ABA, if complying using a recovery device.

If complying with the sourcewide emission limit:

• description of how you’ll determine the amount of HAP ABA in a storage vessel 

 • description of how you’ll monitor the amount of HAP ABA added to a storage

vessel during a delivery

Information on your alternative monitoring program found in §63.1303(b)(5)(i)-(iv), if

applicable.

§63.1306(c)

Notification of

Compliance Status

[slabstock, molded and

rebond foam plants]

Within 180 days after

compliance date

List of your diisocyanate storage vessels, and controls used for each. 

Type of control used for each transfer pump in diisocyanate service.

If complying with the emission point specific limits:

• List of HAP ABA storage vessels, along with control used for each

• List of pumps, valves, connectors, pressure-relief devices, and open-ended valves

or lines in HAP ABA service

• List of any modifications to equipment in HAP ABA service you’ve made to

comply with §63.1296

§63.1306(d)
Table 7.2 Reporting Requirement (cont’d)

If you are submitting 

an. . . 

then submit by . . . and include the following information . . . according to these

sections of the rule...

106

Semiannual Compliance

Report

[slabstock foam plants]

Semiannually no later

than 60 days after the

end of the 180-day

period.

If you’re using rolling-annual compliance, report the allowable and actual HAP ABA

emissions (or allowable and actual sourcewide HAP emissions) for each 12-month period

ending on each of the six months in the reporting period (not required for initial semiannual compliance report).

If you’re using monthly compliance, report allowable and actual HAP ABA emissions (or

allowable and actual sourcewide HAP emissions) for each of the six months in the

reporting period.

If you’re using a carbon-adsorption system, report unloading events that occurred after

you detected a breakthrough and before you replaced the carbon.

Any equipment leaks you didn’t repair.

Any leaks in vapor- return lines you didn’t repair.

§63.1306(e)

Change in Selected

Emission Limit

[slabstock foam plants]

180 days before a

change takes effect

Notify your regulatory agency that you’re switching from complying with the emission

point specific limit to the sourcewide emission limit (or vice versa).

§63.1306(f)(1)

Change in Selected

Compliance Method

[slabstock foam plants]

180 days before a

change takes effect

Notify your regulatory agency that you’re switching from monthly to rolling-annual

compliance (or vice versa).

§63.1306(f)(2)
Table 7.2 Reporting Requirement (cont’d)

If you are submitting 

an. . . 

then submit by . . . and include the following information . . . according to these

sections of the rule...

107

Annual Compliance

Certification

[slabstock, molded or

rebond foam plants]

Annually Statement that your facility complies with each applicable requirement of the rule. §63.1306(g)
108

Example

Initial Notification Report

This is a sample notification form that you can use to comply with 40 CFR 63.1306(a).

Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for Flexible Polyurethane

foam Production. Initial Notification is being made in accordance with §63.1306(a)

and §63.9(b). 

1. Print or type the following information for each plant in which you produce flexible polyurethane foam

(slabstock and molded) or rebond foam [§63.9(b)(2)(i)- (ii)] :

Owner/Operator/Title_____________________________________________________________

Street Address__________________________________________________________________

City __________________________ State ________________ Zip Code_______________

Plant Name____________________________________________________________________

Plant Contact/Title_______________________________________________________________

Plant Contact Phone Number (optional)______________________________________________

Plant Address (if different than owner/operator’s)_______________________________________

Street Address__________________________________________________________________

City _____________________ State ________________ Zip Code: ______________

2. Show your anticipated compliance date [§63.9(b)(2)(iii)]:

ë __________ (Insert compliance date)

ë Upon startup Anticipated startup date ___________________________

3. Check which affected source(s) (as defined by 40 CFR 63.1290) exist at your plant (optional):

ë Slabstock flexible polyurethane foam production

ë Molded flexible polyurethane foam production

ë Rebond foam production

4. Briefly describe your sources nature, size, design, and method of operation, including its designed

operating capacity. [§63.9(b)(2)(iv)]:

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

____________________________________________________________________
109

Example Initial Notification Report (Cont’d)

5. Identify each point of emission for each Hazardous Air Pollutant (HAP). If you can’t do this definitively

yet, do a preliminary identification. If you need more lines, copy this page [§63.9(b)(2)(iv)].

Please indicate if the information below is: ë Definitive ë Preliminary

Source ID Source Location Source

Description

Operation Performed

6. My plant is a major source of Hazardous Air Pollutants (HAPs) ë Yes ë No

NOTE: Only major sources of HAPs are regulated under this rule [§63.9(b)(2)(v)]. If you are not a

major source, you are not subject to the rule and don’t need to submit this initial notification. You

should, however, keep documentation on how you determined you were an area source and maintain

those records on file at your plant.

A major source is a facility that may emit more than 10 tons per year of any one hazardous air pollutant

(HAP) or 25 tons per year of multiple HAPs. All other sources are area sources. Whether a source is

a major or area source depends on all HAP emission-points inside the pant’s fenceline, not just the

flexible polyurethane foam or rebond foam production facilities.

End of Initial Notification Form
110

Example

Application for Approval of Construction or Reconstruction

This is a sample notification form that you can use to comply with 40 CFR 63.5(d).

Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for Flexible Polyurethane

foam Production. Notification is being made in accordance with §63.5(d)

[§64.5(d)(1)(ii)(D)]

Description: Your Application for Approval of Construction or Reconstruction falls under the General

Provisions, §63.5(d). This section requires anyone constructing or reconstructing a major

source after the effective date of a standard (in this case 10/7/98) to obtain written

approval to construct or reconstruct the source. 

By this we mean, approval is required if you do any one of the following:

• construct a new major affected source

• reconstruct a major affected source

• reconstruct a source that becomes a major affected source

This means that if you construct a new source or reconstruct an existing source that is

subject to the rule and that source a major source of HAPs, you will need to submit an

Application for Approval of Construction or Reconstruction. You can find a definition of

construction and reconstruction in the General Provisions, §63.2.

Use a separate form for each construction or reconstruction you are planning.

1. Print or type the following information for each affected source you’re constructing or reconstructing

[§64.5(d)(1)(ii)(A), (C)]:

Owner/Operator/Title ____________________________________________________________

Street Address__________________________________________________________________

City __________________________ State ________________ Zip Code:______________

Plant Name (optional)____________________________________________________________

Plant Contact/Title (optional)_______________________________________________________

Plant Contact Phone Number (optional) _____________________________________________

Plant Address (if different than owner/operator’s) _____________________________________

Street Address _________________________________________________________________

City __________________________ State ________________ Zip Code:______________
111

Example

Application for Approval of Construction or Reconstruction (cont’d)

2. I intend to (check only one, use a separate sheet of paper for each separate construction or reconstruction)

[§64.5(d)(1)(ii)(B)]:

ë construct a new major affected source

ë reconstruct a major affected source

ë reconstruct a source that has become a major affected source

3. Describe the type of source you are constructing or reconstructing (optional): 

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

____________________________________________________________________

4. I expect to begin construction or reconstruction on (mm/dd/yy) [§64.5(d)(1)(ii)(E)]

I expect to finish construction or reconstruction on ____________ (mm/dd/yy) [§64.5(d)(1)(ii)(F)]

I expect to startup on ___________ (mm/dd/yy) [§64.5(d)(1)(ii)(G)]

5. Complete this section only if you plan on constructing a new major affected source. All others go to

6 [§64.5(d)(2)].

(a) Describe the size and design capacity of the source you’re constructing and at what capacity you

intend to operate:

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

___________________________________________________________________________

(b) Identify the type and quantity of Hazardous Air Pollutants (HAPs) emitting after the construction,

the pollution control equipment you intend on using, if any, and it’s control efficiency. If you can’t

do this definitively, do a preliminary identification. 

Please indicate if the information below is: ë Definitive ë Preliminary
112

Example

Application for Approval of Construction or Reconstruction (cont’d)

Note: If you do a preliminary identification, you must submit actual data as soon as practical after it

becomes available, but, no later than your notification of compliance status.

Source ID: ________________

Emission

Point ID

(if applicable)

HAP(s) emitted Emissions 

(____units1)

Air Pollution

Control Device 

(if applicable)

 Control Efficiency of

Control Device

 (% efficiency)

1 use the same units, percent reductions or averaging times that are required in the subpart

(c) Include with your submittal any technical information such as calculations you made to determine

your estimated emissions.

6. Complete this section only if you plan on reconstructing an existing major affected source or

reconstructing a source that becomes a major affected source after reconstruction. All others go to 7 

[§64.5(d)(3)].

(a) Describe they type of components that you’re replacing:

_______________________________________________________________________________

_______________________________________________________________________________

____________________________________________________________________________

(b) Identify the type and quantity of HAPs emitting after the reconstruction, the pollution control

equipment you currently use and intend on using, if any, and it’s control efficiency. If you can’t do

this definitively, do a preliminary identification. 

Please indicate if the information below is: ë Definitive ë Preliminary
113

Example

Application for Approval of Construction or Reconstruction (cont’d)

Note: If you do a preliminary identification, you must submit actual data as soon as practical after it

becomes available, but, no later than your notification of compliance status.

Source ID: ________________

Emission

Point ID

(if applicable)

HAP(s)

emitted

Emissions 

(____units1)

Air Pollution

Control Device

Currently Used

(if applicable)

Planned

Air Pollution

Control

Device 

(if applicable)

 Control

Efficiency of

Control

Device

 (% efficiency)

1 use the same units, percent reductions or averaging times that are required in the subpart

(c) Include with your submittal any technical information such as calculations you made to determine

your estimated emissions.

(d) A discussion of any economic or technical limits you’ll have in complying with this subpart after

reconstruction. If you don’t plan on having any economic or technical limits after reconstruction,

go to 7.

(i) Discuss what your economic or technical limits will be, how they effect your compliance under

this subpart, what subparts will be effected, and what alternate methods of compliance you

plan on using:

____________________________________________________________________________

____________________________________________________________________________

________________________________________________________________________

(ii) My estimated fixed capital cost to reconstruct the affected source is : $ _____.00
114

Example

Application for Approval of Construction or Reconstruction (cont’d)

(iii) The estimated life of my affected source after reconstruction is: _____ years

(iv) If I were to forgo reconstruction and construct a entirely new affected source, comparable with

the one I am reconstructing, my fixed capital costs would be: $ ______.00

7. End of form.

End of Application for Approval of Construction or Reconstruction
115

Example

Precompliance Report

This is a sample notification form you can use to comply with 40 CFR 63.1306(c)

Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for Flexible

Polyurethane foam Production. This Precompliance Report is being made for my

slabstock foam facility in accordance with §63.1306(c). 

1. Print or type the following information for each plant in which you produce slabstock foam:

Owner/Operator/Title ____________________________________________________________

Street Address__________________________________________________________________

City __________________________ State ________________ Zip Code:______________

Plant Name ___________________________________________________________________

Plant Contact/Title ______________________________________________________________

Plant Contact Phone Number (optional) _____________________________________________

Plant Address (if different than owner/operator’s) _____________________________________

Street Address _________________________________________________________________

City __________________________ State ________________ Zip Code:______________

2. Check which compliance option you’re choosing for your slabstock facility (check all that apply)

[§63.1306(c)(2)]:

ë Emission point limit described in §63.1293(a) [§63.1306(c)(1)]

check which option you’re choosing [§63.1306(c)(2)]

ë I’ll comply on a rolling-annual basis under §63.1297(b)

ë I’ll comply on a monthly basis under §63.1297(c)

ë Sourcewide emission limit described in §63.1293(b) [§63.1306(c)(1)]

check which option you’re choosing [§63.1306(c)(3)]

ë I’ll comply on a rolling-annual basis under §63.1299(a)

ë I’ll comply on a monthly basis under §63.1299(b)
116

Example Precompliance Report (Cont’d)

3. Describe how you’ll monitor HAP ABA or polyol added at the mixhead. If you’re developing an

alternate monitoring program, go to 4 [§63.1306(c)(4)]:

___________________________________________________________________________________

___________________________________________________________________________________

____________________________________________________________________

4. Fill out only if you plan to use an alternate monitoring program for HAP ABA or polyol added at the

mixhead. Otherwise, go to 5 [§63.1306(c)(4)]:

If you intend to use an alternate monitoring program for HAP ABA or polyol added at the mixhead

under §63.1303(b)(5), you develop and submit an alternative monitoring program for approval.

You can use this precompliance report for submitting your monitoring program if you’re an existing

source. If you’re a new source, you can use your Application for Approval of Construction or

Reconstruction. You may also submit a monitoring program after the compliance date. Alternate

monitoring programs must be approved before you can use the alternate. 

(a) I have attached an alternate monitoring program:

ë Yes (don’t fill out the rest of 4, go to 5)

ë No (fill out the information below)

(b) Describe the parameter you’ll monitor to continuously measure the amount of HAP ABA or polyol

added at the mixhead while you’re pouring foam [§63.1303(b)(5)(i)]:

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

___________________________________________________

(c) Describe how you’ll record results, and how you’ll convert them into the amount of HAP ABA or

polyol delivered to the mixhead [§63.13031(b)(5)(ii)]:

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

_______________________________________________________________________
117

Example Precompliance Report (Cont’d)

(d) Provide data to show the monitoring device is accurate to within ±2.0 percent [§63.1303(b)(5)(iii)]: 

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________

(e) Describe what you’ll do to maintain accurate results from parameter monitoring. Make sure your

procedures at least include calibration of all monitoring devices [§63.1303(b)(5)(iv)]:

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________

5. Fill out this section only if you plan to use a recovery device to comply with §63.1297 or 63.1299. 

Otherwise, go to 6 [§§63.1306(c)(5), (c)(6)]:

If you intend to use a recovery device to reduce HAP ABA emissions, under §63.1303(c)(6) you must

develop and submit a recovery HAP ABA monitoring and recordkeeping program for approval.

You can use this precompliance report for submitting your monitoring program if you’re an existing

source. If you’re a new source, you can use your Application for Approval of Construction or

Reconstruction. You may also submit a monitoring program after the compliance date. Alternate

monitoring programs must be approved before you can use the alternate. 

(a) I have attached a program to monitor and keep records on recovered HAP ABA:

ë Yes (don’t fill out the rest of 5, go to 6)

ë No (fill out the information below)

(b) Describe the solvent-recovery device you’ve installed, calibrated, maintained, and operated

according to the manufacturer’s specification and that shows the cumulative amount of HAP ABA

recovered by the device during each month. Make sure the manufacturer certifies this device to

be accurate to within ± 2.0 percent [§63.1303(c)(1)]:

____________________________________________________________________________

____________________________________________________________________________

_________________________________________________________________________
118

Example Precompliance Report (Cont’d)

(c) Describe where the monitoring will occur. Make sure the location allows you to measure the HAP

ABA after you’ve fully recovered it [§63.1303(c)(2)]:

fully recovered means after separation from water introduced into the HAP ABA during regeneration

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________

(d) Describe the parameter you’ll monitor and the times you’ll monitor it [§63.1303(c)(3)]:

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________

(e) Provide data to show that the monitoring device is accurate to within ±2.0 percent [§63.1303(c)(4)]:

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

__________________________________

(f) Describe how you’ll maintain accurate results from parameter monitoring. Make sure your

procedures at least include periodic calibration of all monitoring devices [§63.1303(c)(5)]:

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

____________________
119

Example Precompliance Report (Cont’d)

6. For sources complying with the sourcewide emission limit, describe how you’ll determine the amount

of HAP ABA in a storage vessel [§63.1306(c)(7)]:

___________________________________________________________________________________

___________________________________________________________________________________

_______________________________________________

7. For sources complying with the sourcewide emission limit, describe how you’ll monitor the amount of

HAP ABA added to a storage vessel during a delivery. If you’re developing an alternate monitoring

program, go to 8 [§63.1306(c)(8)]:

___________________________________________________________________________________

___________________________________________________________________________________

_______________________________________________

8. Fill out only if you plan to use an alternative monitoring program for HAP ABA added to a storage

vessel during delivery. Otherwise, go to 9 [§63.1306(c)(8)]:

If you intend to use an alternate monitoring program for HAP ABA added to a storage vessel

during loading, under §63.1303(e)(4) you must develop and submit an alternative monitoring

program for approval.

You can use this precompliance report for submitting your monitoring program if you’re an existing

source. If you’re a new source, you can use your Application for Approval of Construction or

Reconstruction. You may also submit a monitoring program after the compliance date. Alternate

monitoring programs must be approved before you can use the alternate. 

(a) I have attached an alternative monitoring program for HAP ABA added to a storage vessel during

loading:

ë Yes (don’t fill out the rest of 8, go to 9)

ë No (fill out the information below)

(b) Describe the parameter you’ll monitor to determine the amount of HAP ABA added to the storage

vessel during a delivery [§63.1303(e)(4)(i)]:

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________
120

Example Precompliance Report (Cont’d)

(c) Describe how you’ll record the results and how you’ll convert them into the amount of HAP ABA

added to the storage vessel during a delivery [§63.1303(e)(4)(ii)]:

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_________________________

(d) Provide data to show the monitoring device is accurate to within ±2.0 percent [§63.1303(e(4)(iii)]:

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_________________________

(e) Describe how you’ll maintain accurate results from monitoring. Make sure your procedures at

least include periodic calibration of all monitoring devices [§63.1303(e)(4)(iv)]:

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_________________________

End of Precompliance Report
121

Example

Notification of Compliance Status

This is a sample notification form which you can use to comply with 40 CFR 63.1306(d)

Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for 

Flexible Polyurethane foam Production. Notification of compliance status

is being made in accordance with §63.1306(d).

1. Print or type the following information for each slabstock, molded, or rebond process (optional)

:

Owner/Operator/Title ____________________________________________________________

Street Address__________________________________________________________________

City _________________________ State ________________ Zip Code: ______________

Plant Name ____________________________________________________________________

Plant Contact/Title ____________________________________________________________

Plant Contact Phone Number (optional) ______________________________________________

Plant Address (if different than owner/operator’s) ______________________________________

Street Address _________________________________________________________________

City __________________________ State ________________ Zip Code: _____________

2. Fill out only if you produce Slabstock foam. Otherwise, go to 3 [§63.1306(d)]:

(a) List your diisocyanate storage vessels and the type of control you use [§63.1306(d)(1)]:

Diisocyanate Storage Vessel Type of control 
Example Notification of Compliance Status (cont’d)

122

(b) If transfer pumps are in diisocyanate service, record the type of control you’ll use for each transfer

pump [§63.1306(d)(2)]:

Transfer pump in diisocyanate

service

Type of control

(c) My slabstock processes are complying with the emission point specific limit under §§63.1294

through 63.1298:

ë Yes

ë No

If yes, provide the following information; otherwise, go to 3:

(c1) List your HAP ABA storage vessels, and the type of control you use [§63.1306(d)(3)(i)]:

HAP ABA Storage Vessels Type of control 
Example Notification of Compliance Status (cont’d)

123

(c2) List your pumps, valves, connectors, pressure-relief devices, and open-ended values or lines in

HAP ABA service [§63.1306(d)(3)(ii)]:

 Equipment List Type

ë pump ë valve ë pressure-relief device 

ë open-ended valve or line ë connector

ë pump ë valve ë pressure-relief device 

ë open-ended valve or line ë connector

ë pump ë valve ë pressure-relief device 

ë open-ended valve or line ë connector

ë pump ë valve ë pressure-relief device 

ë open-ended valve or line ë connector

(c3) List any modifications you made to equipment in HAP ABA service to comply under §63.1296

[§63.1306(d)(3)(iii)]:

Equipment Description Modification Made

3. Fill out only if you produce Molded foam. Otherwise, go to 4 [§63.1306(d)(4)]:

check all that apply

ë My affected source for molded foam complies with §63.1300

ë My molded foam processes at the effected source comply with §63.1300

4. Fill out only if you produce Rebond foam. Otherwise, go to 5 [§63.1306(d)(5)]:

check all that apply

ë My affected source for rebond foam complies with §63.1301

ë My rebond foam processes at the affected source comply with §63.1301

End of Notification of Compliance Status
Example

 Semi-Annual Compliance Report

124

This is a sample notification form that you can use to comply with 40 CFR 63.1306(e).

Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for 

Flexible Polyurethane foam Production. This semiannual report

is being made for my Slabstock foam facility in accordance with §63.1306(3).

and covers a 6 month period from __________ to ________.

1. Print or type the following information for each slabstock foam process (optional):

Owner/Operator/Title_____________________________________________________________

Street Address__________________________________________________________________

City __________________________ State ________________ Zip Code: ______________

Plant Name __________________________________________________________________

Plant Contact/Title ______________________________________________________________

Plant Contact Phone Number (optional) ____________________________________________

Plant Address (if different than owner/operator’s) ____________________________________

Street Address ________________________________________________________________

City _________________________ State ________________ Zip Code: ______________

2. If your slabstock foam source is following rolling-annual compliance under §63.1297 or §63.1299,

record the following. Otherwise, go to 3. If this is your initial semi-annual compliance report, go to 3;

the information in 2 isn’t required.

List the allowable and actual HAP ABA emissions (or allowable and actual sourcewide HAP emissions)

for each 12-month period ending on each of the six months in the reporting period [§63.1306(e)(1)]. 

Example: if you’re submitting a July 2000 semiannual report, you would send emission information from JanuaryJune 2000 and July-December 1999.
Example Semi-Annual Compliance Report (cont’d)

125

Type of Affected source: __________________________

Type of emission limit used: 

ë actual HAP ABA emission or ë sourcewide HAP emissions

Reporting

Period

Reporting

Year

allowable emissions

(________units)

actual emissions

(________units)

January

February

March

April

May

June

July

August

September

October

November

December

3. If your slabstock source is following monthly compliance under §63.1297 or §63.1299, record the

following. Otherwise, go to 4.

List the allowable and actual HAP ABA emissions (or allowable and actual sourcewide HAP emissions)

for each of the 6 months in the reporting period [§63.1306(e)(2)]. 
Example Semi-Annual Compliance Report (cont’d)

126

Affected source: 

Type of emission limit used:

 ë actual HAP ABA emission or ë sourcewide HAP emissions

Reporting

Period

Reporting

Year

allowable

emissions

(__________ units)

actual emissions

(__________ units)

January

February

March

April

May

June

July

August

September

October

November

December

4. If your slabstock source is using a carbon-adsorption system to comply with the storage-vessel

provisions in §63.1294(a) or §63.1295, record the following. Otherwise, go to 5.

Identify any unloading event that occurred after you’ve detected breakthrough and before you

replaced the carbon [§63.1306(e)(3)]:

Unloading Event

Date

Breakthrough Comments
Example Semi-Annual Compliance Report (cont’d)

127

5. If your slabstock source had equipment leaks that you didn’t repair according to §63.1294(b)(2)(iii);

§63.1294(c); §63.1296(a)(2)(iii); §63.1296(b)(2); §63.1296(b)(3)(iv); §63.1296(b)(4)(v); §63.1296(c)(2)

§63.1296(c)(4)(ii); or §63.1296(d)(2), record the following. Otherwise, go to 6.

Identify any equipment leaks you didn’t repair [§63.1306(e)(4)]

Type of

Equipment Leak

Date

Leak

Detected 

Applicable Section

of Rule

(as indicated above)

Comments

6. If your slabstock source had leaks in the vapor-return line leaks that you didn’t repair according to

§63.1294(a)(1)(ii) or §63.1295(b)(2), record the following. 

Identify any leaks in the vapor-return line that you didn’t repair [§63.1306(e)(5)]

Type of VaporReturn Line

Date

Leak

Detected 

Applicable Section

of Rule

(as indicated above)

Comments

End of Semiannual Report
128

Example

Change in Selected Emission Limit and Compliance Method

Make notification to change the selected emission limit and compliance method for your slabstock

foam process by requesting the change in writing (using a letter, memorandum, or a similar

document). Make notification at least 180 days before the change and include the following based on

the type of notification you’re making [63.1306(f)(1)]:

I. If your complying with §63.1293

My [identify affected source} is complying with §63.1293. We currently comply

using the emission point specific limit but will be switching to the sourcewide emission limit on 

 [identify date].

or

My [identify affected source} is complying with §63.1293. We currently comply

using the sourcewide emission limit but will be switching to the emission point specific limit on

 [identify date].

II. If your complying with §63.1297 or §63.1299

My ______________ [identify affected source] is complying with §__________ [identify §63.1297 or

§63.1299] . We’re currently using the rolling-annual compliance period but will be switching to the

rolling-monthly on [identify date].

or

My ______________ [identify affected source] is complying with §__________ [identify §63.1297 or

§63.1299] . We’re currently using the rolling-monthly compliance period but will be switching to the

rolling-annually on [identify date].

End of Change in Selected Emission Limitation and Compliance Method
129

Example 

Annual Compliance Certification

This is a sample notification form that you can use to comply with 40 CFR 63.1306(g).

Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for Flexible

Polyurethane foam Production. I’m certifying compliance annually under

§63.1306(g) and §63.1306.

You may use compliance certifications required in your State or local operating permit program to

satisfy this reporting requirement as long as the compliance certification is consistent with §63.1308

[§63.1306(g)(2)]. 

1. Print or type the following information for each slabstock, molded or rebond process:

Owner/Operator/Title_____________________________________________________________

Street Address__________________________________________________________________

City __________________________ State ________________ Zip Code:_____________

Plant Name __________________________________________________________________

Plant Contact/Title _____________________________________________________________

Plant Contact Phone Number (optional)____________________________________________

Plant Address (if different than owner/operator’s) ______________________________________

Street Address_________________________________________________________________

City __________________________ State ________________ Zip Code:_____________

I certify that my slabstock foam 9 molded foam 9 Rebond foam 9 is in compliance with

each applicable requirement in §63.1308, Compliance Demonstration, of the Flexible Polyurethane

Foam NESHAP (40 CFR 63, Subpart III). For operations that are not in compliance, provide a

description of your noncompliant operations. 

Signature of Responsible Official: _____________________________________ [§63.1306(g)(3)]

Title of Responsible Official: __________________________________________
Chapter 8 - Other requirements and information

130

Definition. An eligible Tribe means “a Tribe that has been

determined by the EPA to meet criteria for being treated in the same

manner as a State, pursuant to the regulations implementing section

301(d)(2) of the Act.”

Who administers this regulation?

Your State or local agency for air pollution control, or your EPA Regional Office, will regulate you. If your

plant is in Indian Country, and your eligible Tribe or your EPA Regional Office will regulate you. You may

be regulated by one or more agencies depending on whether they’ve been granted delegation of this rule. 

Not all States have been granted delegation, or, if they have been granted delegation, they may not have been

delegated all portions of the rule. Our EPA Regional Offices may also have retained certain rights even after

delegation (for example, you may continue to have dual reporting requirements as explained in Chapter 7). 

You should check with your EPA Regional Office or State for the latest information.

Do I need a title V permit?

You’ll need a title V permit if you’re subject to the Flexible Polyurethane Foam Production NESHAP since,

under title V, you must get a permit if your facility is a major source. The Flexible Polyurethane Foam

Production NESHAP applies to major sources.

To determine if your facility is a major source, you’ll need to calculate your HAP emissions from your entire

facility, not just your foam operations. If you don’t have federally enforceable limits in a State permit, you

must calculate your emissions by determining your potential emissions. If you need help determining if your

facility is a major source or what your potential emissions are, see the definitions in the Operating Permits

Rule §70.2, or visit our title V policy and guidance page at www.epa.gov/ttn/oarpg/t5main.html.
131

How do I change my permit to include this rule?

If you’ve already been issued a final title V permit and you have three or more years left on your permit, your

permitting authority will reopen your permit within 18 months of the publication date of the final rule or final

amendments. If you have less than three years left on your permit, update your permit during your renewal

period. If your permit hasn’t been issued in final form, update your application or draft permit.

To summarize, your options are as follows:

If a new rule is effective1,2

and you have . . . 

Then . . . 

not been issued a final title V permit update your permit application or draft permit

less than three years left on your

permit

update your title V permit during renewal

three or more years left on your permit your permitting authority will reopen your permit

within 18 months after the publication date of the

final rule or final amendments

1 The rule’s effective date is the date the final rule is published in the Federal Register (which is 10/7/98 for

this rule).

2 This also applies if existing rules are modified and final amendments are published in the Federal Register.

Title V permitting rules may change after the publication of this document. Keep abreast of any changes by

checking the Federal Register or visit our title V websites at www.epa.gov/ttn/oarpg/t5main.html and

www.epa.gov/oar/oaqps/permits/.

What portions of the General Provisions apply?

The General Provisions were published in the Federal Register on March 16, 1994 (Volume 59, page 12408)

and apply to all NESHAPs, including the flexible polyurethane foam rule. 

This means that when you became subject to this rule, you also became subject to the General Provisions. 

Some sections in this rule over-ride the General Provisions. You’ll find that Table 2 of the final rule shows

you which sections of the General Provisions apply to this rule and which don’t. General Provision

requirements, except for notification and reporting are not addressed in this document. 
Chapter 9 - Getting additional help

132

If you have questions about this rule, you should

contact your State, local or Tribal agency before

calling the EPA. Their rules may be more stringent

than Federal requirements.

Whom can I ask for help?

You can go to a lot of places for help, including all of the following:

C your State, local or Tribal agency for air pollution control

C your State’s Small Business Assistance Program (SBAP)

C local, regional, or national trade associations

C your EPA Regional Office

State and local contacts can change frequently. To get the most current contact information, go to the

STAPPA/ALAPCO website (www.4cleanair.org) and then the membership directory. The directory will give

you the latest contact points for major air programs (that is, emission standards for toxic air pollutants,

ozone, etc.) at the State and local level.

Trade Associations representing the flexible polyurethane foam industry are listed below. Trade associations

sometimes have rule information for their members. 

Trade Association Telephone # Address

Carpet Cushion Council (203) 637-1312 26 Arcadia Rd., Suite 8

Old Greenwich, CT 06870

Society of the Plastics Industry, Inc. 

Polyurethane Division

(202) 974-5362 1801 “K” Street

600K

Washington, DC 20006

Polyurethane Foam Assoc. (973) 633-9044 P.O. Box 1459

Wayne, NJ 07474
133

Many States have a Small Business Assistance Program. If you’re a small business and don’t know who

your SBAP is, you can call EPA's Control Technology Center Hotline at (919) 541-0800 or visit EPA’s SBAP

at www.epa.gov/oar/oaqps/sbap for help.

Contact numbers for EPA’s Regional Air Division Offices may also change frequently. To obtain the most

up-to-date information, you may want to visit your Regional Office’s website. Table 9.1 (on page 134) lists

each of our Regional Offices, the Air Toxics Division Phone and Address, and the Regions internet home

page. Make all written inquiries to the attention of “NESHAP (insert rule name) Contact.”

Can I get more information on the Web?

You can get a wealth of information on the World Wide Web (WWW). Some of the more popular ways to

get information on this rule include:

C EPA’s Unified Air Toxics Website (www.epa.gov/ttn/uatw) 

You can download copies of preambles, regulations, background information documents, policy

memos, and other guidance materials here. All rule pages can be found under the Rules and

Implementation page. Flexible polyurethane foam can be found under

www.epa.gov/ttn/uatw/foam/foampg.html.

C EPA’s Applicability Determination Index (ADI) (http://es.epa.gov/oeca/eptdd/adi.html) 

EPA’s Office of Enforcement and Compliance Assurance (OECA) posts memos dealing with

applicability and compliance at this site.

C OECA Compliance Assistance Centers (http://www.epa.gov/epahome/business.htm)

You can find information on compliance with federal regulations at this site. There are centers for

printing, automotive services and repair, agriculture, and metal finishing industries. We plan to add

centers for the chemical industry, printed wiring board manufacture, transportation, and local

governments.

C STAPPA/ALAPCO home page (http://www.4cleanair.org)

STAPPA/ALAPCO is the State and Territorial Air Pollution Program Administrators (STAPPA)

and Local Air pollution Control Officials (ALAPCO) organization. STAPPA/ALAPCO has

members representing each State and local agency for air pollution control. 

You can get air pollution information at this site, including a document entitled “Communicating

Air Quality: A Compendium of Resources." It lists educational materials on air pollution that State

and local agencies have created.
134

Table 9.1

EPA Regional Air Division Offices

EPA Region States Covered Division Phone and Address Phone 

Home Page

Region I CT, ME, MA, NH,

RI & VT

Office of Environmental Stewardship

(OES)

1 Congress Street, Suite 1100

Boston, MA 02114-2023

(617) 918-1510

www.epa.gov/region1

Region II NJ, NY, Puerto

Rico & Virgin

Islands

Division of Environmental Planning and

Protection

290 Broadway, 21st Floor

New York, NY 10007-1866

(212) 637-3735

www.epa.gov/region2

Region III DE, MD, PA, VA,

WV & DC

Air Protection Division, 3AP12

1650 Arch Street

Philadelphia, PA 19103-2029

(215) 814-2056

www.epa.gov/region3

Region IV AL, FL, GA, KY,

MS, NC, SC & TN

Air, Pesticides and Toxics Management

Division

345 Courtland Street, NE

Atlanta, GA 30365

(404) 562-9077

www.epa.gov/region4

Region V IL, IN, MI, WI, MN

& OH

Air and Radiation Division

77 West Jackson Blvd.

Chicago, IL 60604-3507

(312) 353-2212

www.epa.gov/region5

Region VI AR, LA, NM, OK &

TX

Multimedia Planning and Permitting

Division

1445 Ross Avenue

Dallas, TX 75202-2733

(214) 665-7200

www.epa.gov/region6

Region VII IA, KS, MO & NE Air, RCRA and Toxics Division

726 Minnesota Avenue

Kansas City, KS 66101

(913) 551-7097

www.epa.gov/region7

Region VIII CO, MT, ND, SD,

UT & WY

Office of Enforcement, Compliance and

Environmental Justice (ECEJ)

999 18th Street, 1 Denver Place, Suite 500

Denver, CO 80202-2405

(303) 312-7028

www.epa.gov/region8

Region IX AZ, CA, HI, NV,

American Samoa,

& Guam

Air Division

75 Hawthorne Street

San Francisco, CA 94105

(415) 744-1219

www.epa.gov/region9

Region X AK, ID, WA & OR Office of Air Quality

1200 Sixth Avenue

Seattle, WA 98101

(206) 553-1505

www.epa.gov/region10
135

Is there a list of commonly asked questions?

For a list of questions and answers about the final rule, you’ll find EPA’s “Hazardous Air Pollutant

Emissions from the Production of Flexible Polyurethane Foam -- Basis and Purpose Document for Final

Standards, Summary of Public Comments and Responses, July, 1998 (EPA-453/R-97-008b) useful. You can

download the document by going to our UATW Flexible Polyurethane Foam page at

www.epa.gov/ttn/uatw/foam/foampg.html. 
Chapter 10 - Supplemental information for State and local agencies and Tribes

136

EPA’s “Enabling Document: Source Identification Procedures for Sources

Subject to Regulations Under Section 112(d) of the Clean Air Act as Amended

in 1990”, September 20, 1996 (otherwise known as the “Cookbook”), can

help you identify the steps you can take to locate more sources.

You can download the cookbook by going to

www.epa.gov/ttn/uatw/eparules.html, scroll down until you see “MACT

Implementation Strategy”. The cookbook is in Appendix G of this document.

How many plants may need to meet emission limits?

According to information we collected in 1993, we estimated that approximately 77 slabstock, 21 rebond,

and 98 molded foam production plants might be affected by this rule.

You can find a list of slabstock plants that may be affected by the rule in Table 10.1 (on page 138). 

Unfortunately, we don’t have a list of molded and rebond foam plants. When looking at Table 10.1, realize

that our information is from 1993 and some of the plants may have closed or been redesignated as area

sources. We’ve included the list as a reference for you, not as an official or complete list of regulated plants. 

You can see how many slabstock plants are in your state by going to Figure 10.1 (page 141).

Are plants in Indian country regulated by the State?

Generally, State rules aren’t enforceable in Indian country. When we delegate authority to States under

section 112(d), the authority to regulate doesn’t extend to Indian country unless the delegation agreement

says so.

We encourage tribes to develop the capacity to administer section 112(d) programs and to request delegation. 

If we don’t delegate the authority to carry out section 112(d) rules to an eligible Tribe, the EPA Regional

Office will be the regulatory authority.
137

Slabstock Foam Molded Foam

0

5,000

10,000

15,000

20,000

16,568

3,186

5,080

854

HAP Emissions (tpy)

Before Regulation After Regulation

How much HAP emissions will the rule reduce?

We estimate that full implementation of the rule will reduce HAP emissions by about 13,800 tons annually. 

Breaking this down, we think that 11,500 tons annually (69%) will be reduced from slabstock foam producers

and 2,300 tons annually (73%) from molded foam producers. 

We believed that all rebond foam producers are already complying with the NESHAP requirements, so we

don’t estimate any additional reductions from this subcategory.

Estimated National HAP Emission Reductions
138

Table 10.1

1993 U.S. Slabstock Foam Plant List

STATE COMPANY LOCATION

ARKANSAS Foamex (formerly Crain Industries) Fort Smith

Hickory Springs Manufacturing Co. Fort Smith

Ludwig, Inc. Waldo

CALIFORNIA Foamex (formerly Crain Industries) Compton

Foamex (formerly Crain Industries) San Leandro

Carpenter Company Lathrop

Carpenter Company Riverside

Foamex, L.P. Orange

Foamex, L.P. San Bernadino

Future Foam, Inc. Fullerton

Hickory Springs Manufacturing Co. Commerce

DELAWARE E-A-R Division Newark

FLORIDA Flexible Foam Products Miami

Foamex, L.P. Orlando

Omnifoam, Inc. Miami

GEORGIA Austin Urethane, Inc. Americus

Foamex (formerly Crain Industries) Newman

Foamex, L.P. Conyers

Hickory Springs Manufacturing Co. Americus

Woodbridge Foam Lithonia

ILLINOIS Burkart Foam, Inc. Cairo

General Foam Corp. Bridgeview

No-Sag Foam Products West Chicago

INDIANA Foamex (formerly Crain Industries) Elkhart

E-A-R Specialty Composites Indianapolis

Carpenter Company Elkhart

Flexible Foam Products Elkhart

Foamex, L.P. Auburn

Foamex, L.P. Elkhart

Foamex, L.P. Fort Wayne

Foamex, L.P. Laporte

IOWA Future Foam, Inc. Council Bluffs

KANSAS Future Foam, Inc. Newton

MARYLAND William T. Burnett and Co. Baltimore
Table 10.1

Slabstock foam Plant List (cont’d)

STATE COMPANY LOCATION

139

MASSACHUSETTS Crest Foam Industries Newburyport

MICHIGAN Armaly Brands Walled Lake

Plastomer Corp. Livonia

MINNESOTA General Foam of Minnesota St. Paul

MISSISSIPPI Hickory Springs Manufacturing Co. Verona

MPI, Inc. Coldwater

Vitafoam (formerly Olympic Products Co.) Tupelo

Superior Product Sales, Inc. Plantersville

Vitafoam, Inc. Tupelo

MISSOURI Foamex (formerly Crain Industries) Verona

Carpenter Company Verona

Foamex, L.P. Verona

NEVADA Universal Urethanes, Inc. N. Las Vegas

NEW JERSEY Crest Foam Industries Moonachie

General Foam Corp. East Rutherford

NORTH CAROLINA Foamex (formerly Crain Industries) Conover

Carpenter Company Conover

Foamex, L.P. Cornelius

Hickory Springs Manufacturing Co. Conover

North Carolina Foam Industries, Inc. Mount Airy

North Carolina Foam Industries Mount Airy

Prestige Fabricators, Inc. Asheboro

Vitafoam, Inc. High Point

Vitafoam (formerly Olympic Products Co.) Greensboro

OHIO Flexible Foam Products Spencerville

Scottdel, Inc. Swanton

OREGON Hickory Springs Manufacturing Co. Portland

PENNSYLVANIA Foamex (formerly Crain Industries) Easton

Foamex, L.P. Corry

Foamex, L.P. Eddystone

General Foam Corp. West Hazelton

TENNESSEE Foamex, L.P. Milan
Table 10.1

Slabstock foam Plant List (cont’d)

STATE COMPANY LOCATION

140

Foamex, L.P. Morristown

Nu-Foam Products, Inc. Chattanooga

TEXAS Carpenter Company Temple

Flexible Foam Products Terrel

Foamex, L.P. Mesquite

Texas Fibers Branch 1708 Brenham

VIRGINIA Carpenter Company Richmond

WASHINGTON Foamex (formerly Crain Industries) Kent

WISCONSIN Future Foam, Inc. Middleton
141

No. Plant Sites

(per Regional Office):

R1 - 1 R6- 8

R2- 2 R7- 5

R3- 7 R8- 0

R4 - 26 R9- 9

R5 - 17 R10- 2

Figure 10.1

Slabstock Flexible Polyurethane foam Plants (77 plants)
142

Appendix A- Subpart III, final rule

Contents for Subpart III, Final Rule

Applicability

Is my facility regulated under this Subpart? §63.1290(a)

What is an affected source? §63.1290(b)

Are any processes exempt? §63.1290(c)

How do I calculate if HAPused is <5 tpy? §63.1290(c)(3)

Compliance Schedule

How long do I have to come into compliance with the rule? §63.1291

Definitions and nomenclature

What are some commonly terms used in this Subpart? §63.1292

Standards for slabstock flexible polyurethane foam production

What are the emission limitation options? §63.1293

What options do I have if I only use one HAP? §63.1293(b)

Standards for diisocyanate emissions for slabstock production

What are the control requirements for diisocyanate storage vessels? §63.1294

What are the requirements during unloading? §63.1294(a)

What are the control requirements for diisocyanate transfer pumps? §63.1294(b)

What are the requirements for other diisocyanate components? §63.1294(c)

When can I delay repair of diisocyanate equipment leaks? §63.1294(d)
Contents for Subpart III, Final Rule (cont’d)

143

Standards for HAP ABA storage vessel emissions for slabstock production

What are the control requirements for HAP ABA storage vessels? §63.1295(a)

What are the vapor balancing requirements? §63.1295(b)

What the are requirements for carbon adsorption systems? §63.1295(c)

Standards for HAP ABA equipment leaks for slabstock production

What are the control options for pumps? §63.1296(a)

What are the leak detection requirements for pumps? §63.1296(a)

What are the leak detection requirements for valves? §63.1296(b) 

What are the leak detection requirements for connectors? §63.1296(c)

What are the leak detection requirements for pressure-relief devices? §63.1296(d) 

What are the requirements for pressure-relief devices? §63.1296(e) 

When can I delay repair of HAP ABA equipment? §63.1296(f) 

Standards for HAP ABA emissions from slabstock production lines

What are the compliance options for production lines? §63.1297(a) 

What are the requirements for rolling-annual compliance? §63.1297(b)

What are the requirements for monthly compliance? §63.1297(c)

How do I determine the HAP ABA formulation limitations? §63.1297(d)

What are the requirements for solvent-recovery devices? §63.1297(e)

Standards for HAP equipment cleaning emissions from slabstock production

When can I use a HAP or a HAP-based material as an equipment cleaner? §63.1298

Standards for sourcewide HAP ABA emissions from slabstock production lines

What are the compliance options? §63.1299

What are the requirements for rolling-annual compliance? §63.1299(a)
Contents for Subpart III, Final Rule (cont’d)

144

What are the requirements for monthly compliance? §63.1299(b)

How do I determine actual sourcewide HAP emissions? §63.1299(c)

How do I determine allowable sourcewide HAP emissions? §63.1299(d)

What are the requirements for solvent-recovery devices? §63.1297(e)

Standards for molded foam production

What molded processes are regulated? §63.1300

Can HAPs be used as an equipment cleaner? §63.1300(a)

What must I do if I use diisocyanates for flushing? §63.1300(a)

Can HAPs be used as a mold-release agent? §63.1300(b)

Standards for rebond foam production

What rebond processes are regulated? §63.1301

Can HAPs be used as an equipment cleaner? §63.1301(a)

Can HAPs be used as a mold-release agent? §63.1301(b)

Applicability to Subpart A requirements

What sections of the General Provisions apply to me? §63.1302

Table 2

Do I have to develop a Start-up, Shutdown and Malfunction Plan? §63.1302

Table 2

Monitoring requirements 

What are the requirements for storage vessels carbon adsorption systems? §63.1303(a) 

What are the requirements for HAP ABA and polyol added at the mixhead? §63.1303(b)

What are the requirements for solvent-recovery? §63.1303(c) 

How do I monitor HAP ABA in the storage vessel? §63.1303(d)

How do I monitor HAP ABA added to the storage vessel? §63.1303(e)
Contents for Subpart III, Final Rule (cont’d)

145

Testing requirements

What test methods must I use for equipment leaks? §63.1304(a)

What test methods must I use for IFD and density? §63.1304(b)

Alternate means of emission limitation

How can I get approval for an alternative means of emission limitation? §63.1305

How soon can I use the alternative emission limitation? §63.1305(d)

Reporting Requirements

Do I have to submit an initial notification report? §63.1306(a)

If I install a new source or reconstruct an existing source, what are my requirements? §63.1306(b)

Is a precompliance report required for slabstock sources? §63.1306(c)

Do I have to submit a notification of compliance status? §63.1306(d)

If I have a slabstock source, do I have to report any information semiannually? §63.1306(e)

What notifications must I make if I change my slabstock emission limit? §63.1306(f)(1)

What notifications must I make if I change my slabstock compliance method? §63.1306(f)(2)

Do I have to submit annual reports? §63.1306(g)

Recordkeeping requirements

What storage vessel records must I keep? §63.1307(a)

What equipment leak records must I keep? §63.1307(b)

What HAP ABA records must I keep? §63.1307(c)

What recovery device records must I keep? §63.1307(d)

Do I have to keep product data sheets for equipment cleaners? §63.1307(e)
Contents for Subpart III, Final Rule (cont’d)

146

What records are required for unloading? §63.1307(f)

What records do I need for solvents used for flushing the mixhead and associated piping? §63.1307(g)

What records do I need for mold-release agents? §63.1307(h)

Compliance demonstrations

How do I demonstrate compliance for my slabstock facility? §63.1308(b)

How do I demonstrate compliance for my slabstock facility if I am using emission point specific

limitations?

§63.1308(c)

How do I demonstrate compliance for my slabstock facility if I am using sourcewide limitations? §63.1308(d)

How do I demonstrate compliance for my molded source? §63.1308(e)

How do I demonstrate compliance for my rebond source? §63.1308(e)

Delegation of authority

What sections under this Subpart have not been delegated to my State or local agency? §63.1309
147

Insert copy of rule

(See separate PDF file)
TECHNICAL REPORT DATA

1. REPORT NO.

 EPA-456/B-98-001

2. 3. RECIPIENT'S ACCESSION NO.

4. TITLE AND SUBTITLE

The Plain Language Guide to the Flexible Polyurethane Foam Production

NESHAP (40 CFR 63, Subpart III)

5. REPORT DATE

 December 1998

6. PERFORMING ORGANIZATION CODE

7. AUTHOR(S)

 Ingrid Ward, EPA/OAQPS/ITPID/PRG

 Janet McDonald, EC/R, Incorporated

8. PERFORMING ORGANIZATION REPORT NO.

9. PERFORMING ORGANIZATION NAME AND ADDRESS

ECR

10. PROGRAM ELEMENT NO.

11. CONTRACT/GRANT NO.

68D30008

12. SPONSORING AGENCY NAME AND ADDRESS

 Office of Air Quality Planning and Standards

 Office of Air and Radiation

 U.S. Environmental Protection Agency

13. TYPE OF REPORT AND PERIOD COVERED

 Final

14. SPONSORING AGENCY CODE

 EPA/200/04

15. SUPPLEMENTARY NOTES

 Project Officer is Carolyn Wigington, Mail Drop 13 (919-541-5374)

 Work Assignment Manager is Ingrid Ward, Mail Drop 12 (919-541-0300)

16. ABSTRACT

National emissions standards to control emissions of HAP from major sources producing flexible polyurethane

foam were published in Federal Register 10/7/98, 63 FR 53996. This document contains information to help

State and local agencies for air pollution control, as well as the regulated community, carry out these standards. 

The document summarizes the NESHAP requirements and provides example calculations, inspection

checklists, and example notification and reporting forms. The document also provides information on where to

submit reports, go to for additional help and applicability of foam sources to such things as General Provisions

and Title V. A copy of the rule is provided in hard copy format. An electronic version of this document can be

download at www.epa.gov/ttn/uatw/foram/foampg.html. 

17. KEY WORDS AND DOCUMENT ANALYSIS

a. DESCRIPTORS b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI

Air pollution Title III

Air pollution control NESHAP

National emissions standards Compliance

Hazardous air pollutants 40 CFR 63

Flexible Polyurethane Foam Subpart III

Air pollution control

Flexible Polyurethane Foam 

Slabstock Foam

Molded

Rebond

18. DISTRIBUTION STATEMENT

 Unlimited

19. SECURITY CLASS (Report)

 Unclassified

21. NO. OF PAGES

 216 (hard copy)

 155 (UATW)

20. SECURITY CLASS (Page)

 Unclassified

22. PRICE

no cost