1 of 11 ENCLOSURE 1 INFORMATION COLLECTION REQUEST FOR Flexible Polyurethane Foam Production

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

BACKGROUND:

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

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

- located operation.

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

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

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

c. National Emissions Standards for Hazardous Air Pollutants (NESHAP) (§ 112); d. Solid waste combustion or other related solid waste regulations (§ 129); 2. Determining whet her any person is in violation of any standards or requirements developed under the authorities cited above; or 3. Carrying out any provision under the CAA (except certain provisions under Title II).2 of 11 The Administrator may require that those persons identif ied above do the following so the Administrator may have the information necessary for the items listed in #1

- 3:

 make reports;

 establish and maintain records;

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

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

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

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

 provide such other information as we may reasonably require.

We seek information on existin g f lexible p olyurethane f oam production sources in this survey in order to collect information needed to conduct the residual risk review required by section 112 of the Act

.

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

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

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

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

- water reaction.

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

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

Flexible polyurethane foam process means the equipment used to produce a flexible polyurethane foam product. For the purpose of this survey, the flexible polyurethane3 of 11 foam process includes raw material storage; production equipm ent and associated piping, ductwork, etc.; and curing and storage areas.

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

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

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

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

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

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

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

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

CONFIDENTIAL BUSINESS INFORMATION (CBI) : Please indicate if any CBI is included in this survey response:  Y  N4 of 11 Flexible Polyurethane Foam Production Survey Form

PART I. OWNER INFORMATION

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

. 1 . Name of Legal Owner: Lear Corporation

a. Address: 21557 Telegraph Road b. City: Southfield

c. State: Michigan d. Zip: 48033 e. County: Oakland

2 .Facility Name: Renesol Seating, Farwell

_________________________ _________________________________ 3

. Complete street address of facility (physical location):
a. Address: 505 Hoover Street b. City: Farwell

c. State: Michigan d. Zip: 4 8622 e. County: Clare f. Longitude and Latitude coordinates [ in decimal degrees with five significant figures to the right of the decimal place (e.g., 38.2794 1
, - 85.64371) ] :

_ 43

. 84143
,

_ - 8 4

. 87154

_________________ _____________________________ 4

. Facility Contact: a. Name (First Name, Last Name): Mike Walkowski
b. Title: Director of Operations c. Telephone Number: ( 989 ) 588

- 6161 _Ext

____________ d. Fax Number: ( )

_ e. E

- mail address : mwalkowski@lear.com
f. Primary NAICS code for the facility___ 326150

_________________________5 of 11 5. Flexible Polyurethane Foam Production

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

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

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

________________________________ ________________________________

________________________________ ________________________________

________________________________ ________________________________

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

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

Please mail, fax, or e

- mail Part I to:
U.S. EPA Mailroom
Attn: Sharon Nizich
Mail Code: D243

- 0 4 Research Triangle Park, NC 27711
Phone: 919 541 2825
Fax: 919 541

- 5450
Email address : Nizich.sharon@epa.gov6 of 11 PART II. GENERAL FACILITY INFORMATION

1

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

a. Number of employees at the facility where the flexible polyurethane foam production is located : 1 79

________________________________ ________________ b. Number of employees at the parent company, organization or institution (e.g. municipality, university, etc.) that owns the facility: 93,000

________________

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  Unkn own [insert the following if applicable]

d. Any other co

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

e. Are any operations on site subject to federal and State emission standards and if yes, which standards? 40 CFR 52.21( c, d), Michigan Rule ( R ) 336.1702(a), R336.1224, R336.1225, R336.1901

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

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

g. Type of plant . Check all that apply.

 Molded Flexible Polyurethane Foam

 Slabstock Flexible Polyurethane Foam

 Rebond Foam Production

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

ID Contents Size(gal) Emissions(TPY) Piping characteristics
TDI 61 TDI 7,600 <0.01 Hard piped to closed day tanks7 of 11 ID Contents Size(gal) Emissions(TPY) Piping characteristics
TDI 66 TDI 10,500 <0.01 Hard piped to closed day tanks
TDI 67 TDI 10,500 <0.01 Hard piped to closed day tanks
T51 DEOA 6,100 <0.25 Hard piped to closed day tanks
T60 DEOA 5,000 <0.25 Hard piped to closed day tanks

2. Please provide a flow diagram of the process units associated with the flexible polyurethane foam production process at your facility. Label each process unit and emission point with a uniq ue identification code and complete the table below.
The flow diagram should display an identification code for streams entering (raw materials/feedstocks) and exiting the process unit (product streams), and emission streams. The flow diagram should also display an identification code for add

- on control devices and streams entering and exiting the add

- on control devices. Where applicable, include in

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

.

Identification code Description of item submitted with survey response TDI61 TDI storage tank

TDI66 TDI storage tank

TDI67 TDI storage tank

Admiral1TDI TDI day tank for the admiral 1 line

Admiral2TDI TDI day tank for the admiral 2 line

CannonTDI TDI day tank for the cannon line

MRCA1 Mold release container for the admiral 1 line

MRCA2 Mold release container for the admiral 2 line8 of 11 MRCC Mold release container for the cannon line

MRSOA1 Mold release spray operations for the admiral 1 line

MRSOA2 Mold release spray operations for the admiral 2 line

MRSOC Mold release spray operations for the cannon line

FOAMA1 Foam pour from robotic head to molds for the admiral 1 line
FOAMA2 Foam pour from robotic head to molds for the admiral 2 line
FOAMC Foam pour from robotic head to molds for the cannon line

TS001 TDI unloaded from bulk tank trucks into TDI storage tanks

TS002A1 TDI pumped from TDI storage tanks to Admiral1TDI

TS002A2 TDI pumped from TDI storage tanks to Admiral2TDI

TS002C TDI pumped from TDI storage tanks to CannonTDI

TS003A1 TDI pumped from Admiral1TDI to the robotic head for the admiral 1 line
TS003A2 TDI pumped from Admiral2TDI to the robotic head for the admiral 2 line
TS003C TDI pumped from CannonTDI to the robotic head for the cannon line
MRSA1 Mold release stream from the admiral 1 line

MRSA2 Mold release stream from the admiral 2 line

MRSC Mold release stream from the cannon line

CFD1 Carbon filter drum for TDI storage tanks9 of 11 CF A D 1 Carbon filter drum for Admiral1TDI day tank

CFAD2 Carbon filter drum for Admiral2TDI day tank

CFDC Carbon filter drum for CannonTDI day tank

TEP001 TDI emission point from TDI storage tanks

TEP002A1 TDI emission point from Admiral1TDI

TEP002A2 TDI emission point from Admiral2TDI

TEP002C TDI emission point from CannonTDI

SV

- A1

- A TDI emission point from robotic head for the admiral 1 line

SV

- A2

- A TDI emission point from robotic head for the admiral 2 line

SV

- Can

- A TDI emission point from robotic head for the cannon line

SV

- A1

- B Hydrocarbon HAP emission point from mold release spray operations for the admiral 1 line
SV

- A2

- B Hydrocarbon HAP emission point from mold release spray operations for the admiral 2 line
SV

- Can

- B Hydrocarbon HAP emission point from mold release spray operations for the cannon line
T51 Polyol storage tanks

T60 Polyol storage tanks

Admiral 1poly1 Polyol day tanks

Admiral1 poly 2 Polyol day tanks

Admiral 2poly1 Polyol day tanks10 of 11 Admiral 2 poly2 Polyol day tanks

Cannonpoly 1 Polyol day tanks

Cannonpoly2 Polyol day tanks

TEP003A1 DEOA emission point from Admiral1poly1 day tank

TEP003A1

- 2 DEOA emission point from Admiral1poly2 day tank

TEP003A2 DEOA emission point from Admiral2poly1 day tank

TEP003A2

- 2 DEOA emission point from Admiral2poly2 day tank

TEP003C DEOA emission point from Cannonpoly1 day tank

TEP003C

- 2 D EOA emission point from Cannon poly2 day tank

TEP004

- 51 DEOA emission point from T51 storage tank

TEP004

- 60 DEOA emission point from T60 storage tank

TS004A1 Blended polyol pumped from storage tanks to Admiral 1 day tanks
TS004A2 Blended polyol pumped from storage tanks to Admiral 2 day tanks
TS004C Blended polyol pumped from storage tanks to Cannon day tanks
TS005A1 Blended polyol pumped from blended polyol day tanks to the robotic head for the Admiral 1 line
TS005A2 Blended polyol pumped from blended polyol day tanks to the robotic head for the Admiral 2 line
TS005C Blended polyol pumped from blended polyol day tanks to the robotic head for the Cannon lineN / A PN-21110004 505 Hoover Street Farwell, Michigan 12 December 2011 Renosol Seating Process flow diagram - Admiral 1 line

1 Empty mold (start) Manually place parts and straps Spray solvent-based mold release

(MRSOA1) Foam pour by robotic heads

(FOAMA1) Mold opens, remove foam

cushion Mold closes, heat cures Clean mold out by hand

Compress cushion Mold release

container (MRCA1)

Inspect

Apply water-based noise reducer

Final product Repair with water-based glue, if necessary TDI emissions (SV-A1-A)

Key

Step in process

Process equipment

Storage and day tanks (TDI 67) (TDI 66) (TDI 61) Storage tanks T51, T60 Day tanks Admiral 1 poly 1

TDI Blended polyol

Polyol ethyl benzene, toluene emissions (SV-A1-B)

emissions to carbon filter drum (CFD1) (TS002A1) (MRSA1)

(TS003A1)

(Admiral 1 TDI) (TEP002A1)

TDI (TS001) Bulk tank trucks Common to Admiral 1 line, Admiral 2 line, and Cannon line emissions to carbon filter drum (CFDA1)

(TS004A1) Admiral 1 poly 2 DEOA emissions TEP003A1-2

DEOA emissions TEP003A1 (TS005A1)

DEOA emissions TEP004 TEP005

(TEP001) For environmental management purposes only.N / A PN-21110004 505 Hoover Street Farwell, Michigan 12 December 2011 Renosol Seating Process flow diagram - Admiral 2 line

1 Empty mold (start) Manually place parts and straps Spray solvent-based mold release

(MRSOA2) Foam pour by robotic heads

(FOAMA2) Mold opens, remove foam

cushion Mold closes, heat cures Clean mold out by hand

Compress cushion Mold release

container (MRCA2)

Inspect

Apply water-based noise reducer

Final product Repair with water-based glue, if necessary TDI emissions (SV-A2-A)

Key

Step in process

Process equipment

Storage and day tanks ethyl benzene, tolueneemissions (SV-A2-B)

(MRSA2)

(TDI 67) (TDI 66) (TDI 61) Storage tanks T51, T60 Day tanks Admiral 2 poly 1

TDI Blended polyol

Polyol emissions to carbon filter drum (CFD1) (TS002A2) (TS003A2)

(Admiral 2 TDI) (TEP002A2)

TDI (TS001) Bulk tank trucks Common to Admiral 1 line, Admiral 2 line, and Cannon line emissions to carbon filter drum (CFDA2)

(TEP001) (TS004A2) (TS005A2)

Admiral 2 poly 2 DEOA emissions TEP003A2

DEOA emissions TEP003A2-2

DEOA emissions TEP004 TEP005

For environmental management purposes only.N / A PN-21110004 505 Hoover Street Farwell, Michigan 12 December 2011 Renosol Seating Process flow diagram - Cannon line

1 Empty mold (start) Manually place parts and straps Spray solvent-based mold release

(MRSOC) Foam pour by robotic heads

(FOAMC) Mold opens, remove foam

cushion Mold closes, heat cures Clean mold out by hand

Compress cushion Mold release

container

(MRCC)

Inspect

Apply water-based noise reducer

Final product Repair with water-based glue, if necessary TDI emissions (SV-Can-A)

Key

Step in process

Process equipment

Storage and day tanks ethyl benzene, toluene emissions (SV-Can-B)

(MRSC)

(TDI 67) (TDI 66) (TDI 61) Storage tanks T51, T60 Day tanks Cannon poly 1

TDI Blended polyol

Polyol emissions to carbon filter drum (CFD1) (TS002C) (TS003C)

(Cannon

TDI) (TEP002C)

TDI (TS001) Bulk tank trucks Common to Admiral 1 line, Admiral 2 line, and Cannon line emissions to carbon filter drum (CFDC)

(TEP001) (TS004C) Cannon poly 2 (TS005C)

DEOA emissions TEP004 TEP005 DEOA emissions TEP003C-2 DEOA emissions TEP003C

For environmental management purposes only.11 of 11 3

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

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

N/A N/A N/A