1 of 8 ENCLOSURE 1 INFORMATION COLLECTION REQUEST FOR Flexible Polyurethane Foam Production

We are conducting this Information Collection Request (ICR) to assist the EPA Administrator in developing emission standards for Flexible Polyurethane Foam

under Clean Air Act (CAA) section 112. We are sending this ICR to you under the authority of Section 114 of the CAA.

BACKGROUND:

We are required by section 112(f)(2) of the Clean Air Act (CAA) to assess the risk remaining (residual risk) eight years after the app lication of maximum achievable control technology (MACT) standards under section 112(d). If we find the residual risk fails to protect public health with an ample margin of safety or to prevent (taking into consideration various factors) adverse environme ntal effects, we are required to promulgate more stringent standards. T he Flexible Polyurethane Foam MACT standard was promulgated in October 1998 (see 63 FR 53980). We are preparing to initiate our residual risk review. Please note this survey is for f lexible polyurethane foam production only and does not cover flexible polyurethane foam fabrication, other than identifying if flexible polyurethane foam fabrication is

conducted as a co

- located operation.

Section 114(a) of the CAA gives us the authority to require you to provide us with information for the following purposes:

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

a. State implementation plans (§§ 110 and 111(d));

b. New Source Performance Standards (NSPS) (§ 111);

c. National Emissions Stan dards for Hazardous Air Pollutants (NESHAP) (§ 112);

d. Solid waste combustion or other related solid waste regulations (§ 129);

2. Determining whether any person is in violation of any standards or requirements developed under the authorities cited above; or

3. Ca rrying out any provision under the CAA (except certain provisions under Title II).2 of 8

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

listed in #1

- 3:

 make reports;

 establish and maintain records;

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

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

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

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

 provide such other information as we may reasonably require.

We seek information on existing flexible polyurethane foam production sources in this survey in order to collect information needed to conduct the residual risk review required by sec tion 112 of the Act

.

DIRECTIONS FOR COMPLETING THIS SURVEY:

You must complete and return this survey by December 6, 2011. You must identify clearly any response(s) that you consider to be confidential business information (CBI). Any responses not so identified will be included in a publicly available database. You may refer to Enclosures , 3, 4, 5, and 6 to learn how we will

treat CBI as well as what information you may be asked to submit later to substantiate a claim of confidentiality.

DEFINITIONS: For the purposes of this ICR only, use the following definitions:

Auxiliary blowing agent, or ABA, means a low

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

- water reaction.

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

- celled, permit the passage of air through the foam, and posses s the strength and flexibility to allow repeated distortion or compression under stress with essentially complete recovery upon

removal of the stress.

Flexible polyurethane foam process means the equipment used to produce a flexible polyurethane foam prod uct. For the purpose of this survey, the flexible polyurethane3 of 8

foam process includes raw material storage; production equipment and associated piping, ductwork, etc.; and curing and storage areas.

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

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

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

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

storage areas.

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

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

Slabstock flexible polyurethane foam production line includes all portions of the flexible polyurethane foam process from the mixhead to the point in the process

where the foam i s completely cured.

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

CONFIDENTIAL BUSINESS INFORMATION (CBI) :

Please indicate if any CBI is included in this survey response:  Y  N4 of 8 Flexible Polyurethane Foam Production Survey Form

PART I. OWNER INFORMATION

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

1 . Name of Legal Owner: FXI, Inc.

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

b. City: Media

c. State: PA

d. Zip: 19063

e. County : Delaware

2 .Facility Name:

____ Tupola

, MS Pouring Plant

3

. Complete street address of facility (physical location):

a. Address: 154 Lipford Road

b. City: Verona

c. State: MS

d. Zip: 38879

e. County: Lee f. Longi tude and Latitude coordinates [ in decimal degrees with five significant figures to the right of the decimal place (e.g., 38.2794 1

, - 85.64371) ] :

_____ 3 4

. 166694

, - 88

. 707188

_____________________________ 4

. Facility Contact:

a. Name (First Name, Last Name) : Kevin Partlow

b. Title: Plant Manager

c. Telephone Number: ( 662 ) 566

- 5122 _Ext

________ d. Fax Number:

_ e. E

- mail address: kpartlow @fxi.com

f. Primary NAICS code for the facility___ 326150

_______________________5 of 8

5. Flexible P

olyurethane Foam Production

We believe that you own or operate a facility that engages in production of slabstock, molded or rebond flexible polyurethane foam. If you believe that this survey does not pertain to you, please indicate your reason below:

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

________________________________ _______________________________

________________________________ ______________________________

________________________________ ______________________________

 No slabstock, rebond, or molded flex ible polyurethane foam production plant

is located at this facility.

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

Please mail, fax, or e

- mail Part I to:

U.S. EPA Mailroom

Attn: Sharon Nizich

Mail Code: D243

- 0 4

Research Triangle Park, NC 27711

Phone: 919 541 2825

Fax: 919 541

- 5450

Email address: Nizich.sharon@epa.gov6 of 8

PART II. GENERAL FACILITY INFORMATION

1

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

a. Number of employees at the facility where the flexible polyurethane foam production is located: 51 (as of November 2011)

____________________________

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

, 869 (as of November 2011)

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

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

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

 Y  N  Unknown

[insert the following if applicable]

d. Any other co

- located op erations and if so, what type of operation? None

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

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

.

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

- five (25) tons per year of a

combination of HAPs.

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

. The site has not utilized Methylene Chloride as a blowing agent since 1994

. TRI reports demonstrate extremely low levels of TDI emissions. Therefore , FXI is only submitting the Owner Information and General Facility Information sections of the ICR for this facility.

g. Type of plant. Check all that apply.

 Molded Flexible Polyurethane Foam

 Slabstock Flexible Polyurethane Foam

 Rebond Foam Product ion7 of 8

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

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

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

code for add

- on control devices and streams entering and exiting the add

- on
contro l devices. Where applicable, include in

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

Identification code Description of item submitted with survey response8 of 8

3. List Fed eral air pollution control regulations applicable to each process unit.

Process unit name Process unit

identification code Federal air pollution control regulation