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ENCLOSURE 1

INFORMATION COLLECTION REQUEST FOR

Flexible Polyurethane Foam Production

We are conducting this Information Collection Request (ICR) to assist the EPA 

Administrator in developing emission standards for Flexible Polyurethane Foam

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

authority of Section 114 of the CAA. 

BACKGROUND:

We are required by section 112(f)(2) of the Clean Air Act (CAA) to assess the risk 

remaining (residual risk) eight years after the application of maximum achievable 

control technology (MACT) standards under section 112(d). If we find the residual 

risk fails to protect public health with an ample margin of safety or to prevent 

(taking into consideration various factors) adverse environmental effects, we are 

required to promulgate more stringent standards. The Flexible Polyurethane Foam 

MACT standard was promulgated in October 1998 (see 63 FR 53980). We are 

preparing to initiate our residual risk review. Please note this survey is for flexible 

polyurethane foam production only and does not cover flexible polyurethane foam 

fabrication, other than identifying if flexible polyurethane foam fabrication is 

conducted as a co-located operation.

Section 114(a) of the CAA gives us the authority to require you to provide us with 

information for the following purposes:

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

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

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

c. National Emissions Standards for Hazardous Air Pollutants (NESHAP) 

(§ 112);

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

2. Determining whether any person is in violation of any standards or 

requirements developed under the authorities cited above; or

3. Carrying out any provision under the CAA (except certain provisions under 

Title II). 
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The Administrator may require that those persons identified above do the 

following so the Administrator may have the information necessary for the items 

listed in #1-3:

 make reports; 

 establish and maintain records; 

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

methods; 

 sample emissions (in accordance with such procedures or methods, at such 

locations, at such intervals, during such periods, and in such manner as we

shall prescribe); 

 keep records on control equipment parameters, production variables or other 

indirect data when direct monitoring of emissions is impractical; 

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

 provide such other information as we may reasonably require.

We seek information on existing flexible polyurethane foam production sources in 

this survey in order to collect information needed to conduct the residual risk review 

required by section 112 of the Act. 

DIRECTIONS FOR COMPLETING THIS SURVEY: 

You must complete and return this survey by December 6, 2011. You must 

identify clearly any response(s) that you consider to be confidential business 

information (CBI). Any responses not so identified will be included in a publicly 

available database. You may refer to Enclosures , 3, 4, 5, and 6 to learn how we will 

treat CBI as well as what information you may be asked to submit later to 

substantiate a claim of confidentiality.

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

Auxiliary blowing agent, or ABA, means a low-boiling point liquid added to assist 

foaming by generating gas beyond that resulting from the isocyanate-water reaction.

Flexible polyurethane foam means a flexible cellular polymer containing urea and 

carbamate linkages in the chain backbone produced by reacting a diisocyanate, 

polyol, and water. Flexible polyurethane foams are open-celled, permit the passage 

of air through the foam, and possess the strength and flexibility to allow repeated 

distortion or compression under stress with essentially complete recovery upon 

removal of the stress.

Flexible polyurethane foam process means the equipment used to produce a flexible 

polyurethane foam product. For the purpose of this survey, the flexible polyurethane 
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foam process includes raw material storage; production equipment and associated 

piping, ductwork, etc.; and curing and storage areas.

HAP ABA means methylene chloride, or any other HAP compound used as an 

auxiliary blowing agent.

Initial startup means the first time a new or reconstructed affected source begins 

production of flexible polyurethane foam.

Rebond foam means the foam resulting from a process of adhering small particles of 

foam (usually scrap or recycled foam) together to make a usable cushioning product. 

Various adhesives and bonding processes are used. A typical application for rebond 

foam is for carpet underlay.

Rebond foam process means the equipment used to produce a rebond foam product. 

For the purpose of this subpart, the rebond foam process includes raw material 

storage; production equipment and associated piping, ductwork, etc.; and curing and

storage areas.

Recovery device means an individual unit of equipment capable of and used for the 

purpose of recovering chemicals for use, reuse, or sale. Recovery devices include, 

but are not limited to, carbon adsorbers, absorbers, and condensers.

Slabstock flexible polyurethane foam means flexible polyurethane foam that is 

produced in large continuous buns that are then cut into the desired size and shape.

Slabstock flexible polyurethane foam production line includes all portions of the 

flexible polyurethane foam process from the mixhead to the point in the process 

where the foam is completely cured.

Storage vessel means a tank or other vessel that is used to store diisocyanate or HAP 

ABA for use in the production of flexible polyurethane foam. Storage vessels do not 

include vessels with capacities smaller than 38 cubic meters (or 10,000 gallons).

CONFIDENTIAL BUSINESS INFORMATION (CBI): 

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

PART I. OWNER INFORMATION

For questions 3 through 5, provide a separate Part I form for each facility, if 

you own or operate more than one facility.

1. Name of Legal Owner: 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: 48622

e. County: Clare

f. Longitude and Latitude coordinates [in decimal degrees with five significant 

figures to the right of the decimal place (e.g., 38.27941, -85.64371)]: 

_43.84143,_-84.87154______________________________________________

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_________________________
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5. Flexible Polyurethane Foam Production

We believe that you own or operate a facility that engages in production of 

slabstock, molded or rebond flexible polyurethane foam. If you believe that this 

survey does not pertain to you, please indicate your reason below: 

 Plant is permanently shut down. Please also identify the date the Foam 

Production plant was shut down and what steps were taken to close the Foam 

Production plant. Include date the permit was inactivated.

________________________________________________________________

________________________________________________________________

________________________________________________________________

 No slabstock, rebond, or molded flexible polyurethane foam production plant 

is located at this facility.

If you do not operate a flexible polyurethane foam production plant (i.e., you 

check either box for question 5), we will review that information and respond 

as to whether you need to complete any other part of the survey 

Please mail, fax, or e-mail Part I to: 

U.S. EPA Mailroom

Attn: Sharon Nizich

Mail Code: D243-04

Research Triangle Park, NC 27711

Phone: 919 541 2825

Fax: 919 541-5450

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

1. Please provide the following general information for each flexible 

polyurethane foam production plant:

a. Number of employees at the facility where the flexible polyurethane foam 

production is located: 179 ________________________________________________

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 Unknown

[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 exceeds 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 tanks
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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 unique identification code and 

complete the table below.

The flow diagram should display an identification code for streams entering 

(raw materials/feedstocks) and exiting the process unit (product streams), 

and emission streams. The flow diagram should also display an identification 

code for add-on control devices and streams entering and exiting the add-on 

control devices. Where applicable, include in-process streams, waste 

streams, wastewater streams, and emission release points in the flow 

diagram. 

Identification code Description of item submitted with survey response

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 line
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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 tanks
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CFAD1 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

Admiral1poly1 Polyol day tanks

Admiral1poly2 Polyol day tanks

Admiral2poly1 Polyol day tanks
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Admiral 2 poly2 Polyol day tanks

Cannonpoly1 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 DEOA emission point from Cannonpoly2 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 line
505 Hoover Street N / A PN-21110004

Farwell, Michigan

Renosol Seating 12 December 2011

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

Blended polyol TDI

Polyol

ethyl benzene,

toluene emissions

(SV-A1-B)

emissions to

carbon filter

drum(CFD1)

(TS002A1)

(MRSA1)

(TS003A1)

(Admiral

1

TDI)

(TEP002A1)

TDI

Bulk tank trucks (TS001)

Common to Admiral 1 

line, Admiral 2 line, 

and Cannon line

emissions to

carbon filter

drum(CFDA1)

(TS004A1)

Admiral

1

DEOA emissions TEP003A1-2 poly 2

DEOA emissions TEP003A1

(TS005A1)

DEOA emissions

TEP004

TEP005

(TEP001) For environmental management purposes only.
505 Hoover Street N / A PN-21110004

Farwell, Michigan

Renosol Seating 12 December 2011

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

Blended polyol TDI

Polyol

emissions to

carbon filter

drum(CFD1)

(TS002A2)

(TS003A2)

(Admiral

2

TDI)

(TEP002A2)

TDI

Bulk tank trucks (TS001)

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.
505 Hoover Street N / A PN-21110004

Farwell, Michigan

Renosol Seating 12 December 2011

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

Blended polyol TDI

Polyol

emissions to

carbon filter

drum(CFD1)

(TS002C)

(TS003C)

(Cannon

TDI)

(TEP002C)

TDI

Bulk tank trucks (TS001)

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

Process unit name

Process unit 

identification code

Federal air pollution control 

regulation

N/A N/A N/A