CARPENTER Comfort Cushioning 

 Products 

CARPENTER CO. 

M. H. REINHART TECHNICAL CENTER

2600 JEFFERSON DAVIS HIGHWAY

P. 0. BOX 34546

RICHMOND, VIRGINIA 23234 - 0546

804 - 233 - 0606

We bring comfort to your life® 

October 5, 2011

Sharon V. Nizich (Mail Code D243-04)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Research Triangle Park, NC 27711

Re: Requirement to provide information according to Title 42 of the United States Code, Chapter 85, 

Subpart I, Part A, Section 7414 (42 U.S.C. 7414)

Your Letter of September 8, 2011

Dear Ms. Nizich:

Thank you for speaking on the phone with me last week. I have enclosed under separate cover a CD 

containing the plant air emission permits you requested, along with annual air emissions summaries (if 

available). I have also included in each plant directory any other documentation available regarding 

compliance with the NESHAP for Flexible Foam Production in 40 CFR 63 Subpart III.

All Carpenter Co. flexible foam production plants in the US moved permanently out of major source 

status for HAP emissions prior to the October 8, 2001 compliance deadline for the referenced NESHAP. 

All plants discontinued the use of HAP based adhesives in production operations prior to the NESHAP 

compliance deadline of October 8, 2001.

Included with this letter is a list of all Carpenter Co. flexible foam production plants in the US and their 

status as of October 8, 2001.

You indicated during our phone conversation that this information will be sufficient to satisfy the data

request dated September 8, 2011. Carpenter Co. requests a written or email acknowledgement of your 

concurrence. 

If questions arise or addition information is needed please contact me at the above address or by email at 

charles.johnson@carpenter.com.

Best regards,

Charles Johnson

Corporate Environmental Manger

Carpenter Co.
Carpenter Co. Flexible Foam Production Facilities (US)

1) Fogelsville, PA

Facility has never used HAP blowing agents or adhesives

2003 Prime pouring line installed

2010 Bonded line installed 

2) Richmond ,VA

Facility submitted precompliance report stating we were subject to the NESHAP

10/4/2001 Facility notified VDEQ we were no longer subject to the NESHAP 

8/23/2001 Federally Enforceable State Operating air permit limiting HAPS use issued 

3) Lakeland, FL

Facility has never used HAP blowing agents or adhesives

4) Conover, NC

Facility has not used HAP blowing agents or adhesives since prior to 1995

5) Elkhart, IN

Facility submitted precompliance report stating we were subject to the NESHAP

9/24/2001 Last use of HAP blowing agent

10/2/2001 Facility notified IDEM we were no longer subject to the NESHAP 

6) Russellville, KY

Facility submitted precompliance report stating we were subject to the NESHAP

3/14/2000 Facility notified KDEP we were no longer subject to the NESHAP 

7) Tupelo, MS

9/14/2000 Facility submitted precompliance report stating we were subject to the NESHAP

9/28/2001 Revised Title V issued eliminating the use of methylene chloride

10/2/2001 Facility notified MDEQ we were no longer subject to the NESHAP

8) Temple, TX

Facility has not used HAP blowing agents or adhesives since prior to 1995

9) Riverside, CA

7/1998 Last use of HAP blowing agents or adhesives

10) Lathrop, CA

Facility submitted precompliance report stating we were subject to the NESHAP

8/17/2001 Last use of HAP blowing agents in production

10/3/2001 Facility notified EPA we were no longer subject to the NESHAP