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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). 

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. 
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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 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. 
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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: FXI, Inc. 

 a. Address: 1400 North Providence Road, Suite 2000 

 b. City: Media 

 c. State: Pennsylvania 

 d. Zip: 19063 

 e. County: Delaware 

2.Facility Name: FXI – Cornelius Facility 

3. Complete street address of facility (physical location): 

 a. Address: 18801 Old Statesville Road 

 b. City: Cornelius 

 c. State: North Carolina 

 d. Zip: 28031 

 e. County: Mecklenburg 

 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)]: 35.465742, -80.849673_ 

4. Facility Contact:

 a. Name (First Name, Last Name): Kyle Yonce 

 b. Title: Chemist 

 c. Telephone Number: (704) 892-8081 Ext. 416 

 d. Fax Number: ( ) 

 e. E-mail address: kyonce@fxi.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: 134 (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 operations and if so, what type of operation? 

FXI – Cornelius does not operate any co-located operations. 

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

standards? 

The facility operates under Mecklenburg County Air Pollution Control Ordinance 

(MCAPCO) Permit to Construct/Operate No. 09-189-570 and is subject to the 

following emission standards: 

MCAPCO Regulation 1.5236 – Synthetic Minor Facilities 

MCAPCO Regulation 2.0958 – Work Practices for Sources of Volatile Organic 

Compounds 

MCAPCO Regulation 2.0518 – Miscellaneous Volatile Organic Compound 

Emissions 

MCAPCO Regulation 2.1100 – Control of Toxic Air Pollutants 

MCAPCO Regulation 2.1111 – Maximum Achievable Control Technology 

40 CFR Part 63 Subpart A – National Emission Standards for Hazardous Air 

Pollutants 

40 CFR Part 63 Subpart III – National Emission Standards for Hazardous Air 

Pollutants for Flexible Polyurethane Foam Production 

MCAPCO Regulation 2.0949 - Storage of Miscellaneous Volatile Organic 

Compounds 
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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. 

FXI – Cornelius Facility was a major source at the time of the compliance date 

(October 8, 2001) established in 40 CFR Part 63, Subpart III, Section §63.1291. FXI 

is submitting this ICR as requested for facilities that were a major HAP source at 

the time of the compliance date. The FXI – Cornelius Facility ceased the use of 

HAP-containing ABA in 2004. 

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. See Appendix A - Table 1 and Figure 1 of CBI Submittal

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 

ES-16 Appendix A - Figure 1 - contains a generalized process 

flow drawing of the items requested above for both source 

ES-16 (Variable Pressure Foam Pouring Line) and ES-14 

ES-14 ((Four (4) 10,900 gallon TDI/MDI storage tanks)).
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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 

Variable Pressure 

Foam Pouring Line 

ES-16 40 CFR Part 63, Subpart III – National 

Emissions Standards for Hazardous Air 

Pollutants for Flexible Polyurethane 

Foam Production 

Four (4) Above 

Ground Storage 

Tanks containing 

TDI and MDI 

ES-14 40 CFR Part 63, Subpart III – National 

Emissions Standards for Hazardous Air 

Pollutants for Flexible Polyurethane 

Foam Production
Enclosure 2

2010 2009 2008 2010 2009 2008

ES-16

Variable 

Pressure Foam 

(VPF) Pouring 

Line 

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI Board Feet 581 433 552

Tank # 1 (a) lbs N/A N/A N/A

Tank # 2 (a) lbs N/A N/A N/A

Tank # 3 (a) lbs N/A N/A N/A

Tank # 4 (a) 192,754 4,854,589 6,113,313 lbs N/A N/A N/A

(a) Note that quanitites for Tanks 1, 2, and 3 are not tracked individually. 

ES-14

 Process unit name Production Amount Production units (e.g., 

gallons, pounds)

PART III. FEEDSTOCK, RAW MATERIAL, AND PRODUCTION INFORMATION

1. Please complete the following table for production information for each process unit.

Average time each product was 

Process unit name manufactured (e.g., days, or hours)

6,730,660 312,711 3,787,639
Enclosure 2

2010 2009 2008

Variable Pressure 

Foam (VPF) 

Pouring Line ES16

TDI TDI 6,730,660 312,711 3,787,639

Variable Pressure 

Foam (VPF) 

Pouring Line ES16

MDI MDI 192,754 4,854,589 6,113,313

Tanks 1,2 and 3 

ES-14 (a) TDI TDI 6,730,660 312,711 3,787,639

Tank 4, 

aggregated with 

Tanks 1,2, and 3 

as ES-14 

MDI MDI 192,754 4,854,589 6,113,313

(a) Note that quantities for Tanks 1, 2, and 3 are not tracked individually. 

Process unit name Raw material/feedstock Raw material/feedstock amount

Raw material/feedstock

2. Please complete the following table for Raw Materials/feedstocks entering each process unit. 

 Include only HAP-containing feedstock.

(lbs)
Enclosure 2

Raw material products/feedstock Auxiliary Blowing 

Agents

Chemical Compounds % of each chemical 

compound

N/A 2,4-Toluene Diisocyante 80

N/A 2,6-Toluene Diisocyante 20

MDI N/A Diphenylmethanediisocyante (MDI) 60-100

3. Provide composition information for feedstock/raw materials.

TDI 80/20
Enclosure 2

Adhesive Name HAP Contained HAP Content (wt%) Annual Usage (lbs)

 FXI - Cornelius does not use or have adhesives which contain HAP. 

4. Are any HAP-containing adhesives utilized in repair of foam as part of the production process? No
Hours Per (e.g., week, 

month, year)

ES-14 Four HAP 

Storage Tanks 

Submitted 

as CBI

Submitted as 

CBI Submitted as CBI 10,900 gallon capacity (each) Submitted as CBI Submitted as CBI

ES-16 One Variable 

Pressure Foam Pouring 

(VPF) Line 

Submitted 

as CBI

Submitted as 

CBI Submitted as CBI 380,000 Submitted as CBI Submitted as CBI

Owner Name: FXI, Inc. ______________________________ Facility Name: FXI - Cornelius, NC Facility

 Process Unit ID: ES-14 and ES-16 

PART IV. GENERAL FLEXIBLE POLYURETHANE FOAM PRODUCTION INFORMATION

Year unit 

originally 

installed

Original capital 

cost of unit(s)

Remaining useful life 

of unit

Maximum design 

capacity (e.g., 

lbs/day)

Please complete the following questions for each Flexible Polyurethane Foam Production process unit. You are not expected to 

generate new information for this survey. Only supply data that are readily available to you.

Typical unit operation

1. Please provide the following information for each Flexible Polyurethane Foam Production process unit: 

a. Provide general information for each process unit
Enclosure 2a

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility 

Process Unit ID: ES16, ES14

Submitted as CBI

b. Provide information on upgrades to each flexible polyurethane foam production process unit and associated air pollution control 

trains.

Description of upgrades made 

to air pollution control 

devices associated with the 

Description of 

upgrades made to 

the process unit

Year(s) upgrade was 

made Process unit ID

Year(s) upgrade was 

made
Enclosure 2a

Process Unit ID Total operating and 

maintenance costs description 

2008 2009 2010

ES-16 Submitted as CBI Submitted as CBI Submitted as CBI Submitted as CBI

c. Using the format on this page, include operating and maintenance cost information for each 

 process unit. Definitions for different types of costs are taken from EPA Air Pollution Control

 Cost Manual at http://epa.gov/ttn/catc/products.html#cccinfo

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility

 Process Unit ID: ES-16
Enclosure 2a

2. Include yearly emissions information in the following table (include source of information). 

Emission Point

Process 

Unit ID HAP Pollutant

Tons per year 

2006 (a)

Tons per year 

2007(b) Tons per year 2008(b)

Tons per year 

2009 (a)

Tons per year 

2010

VPF Stack ES-16 2,4-Toluene Diisocyanate 0.00550 0.00137 0.00076 0.00061 0.00185

Tanks Fugitive ES-14 2,4-Toluene Diisocyanate 0.00032 0.00025 0.00016 0.00013 0.00004

VPF Stack ES-16 4,4'-Methylenediphenyl Diisocyanate 0.00024 0.00028 0.00030 0.00025 0.00008

Tanks Fugitive ES-14 4,4'-Methylenediphenyl Diisocyanate 0.00004 0.00004 0.00004 0.00004 0.00002

(a) FXI - Cornelius is a minor air emisison source and is required by North Carolina to submit emission reports every three (3) years. Emissions are from 2006 and 2009 

 triennial state emissions reports. 

(b) 2007, 2008 and 2010 emissions are from the Toxic Release Inventory (TRI). 

 unit.

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility

 Process Unit ID: ES-14 and ES16 

 Include storage tanks or any auxiliary equipment on site, per unit ID and label each as type of
Enclosure 2a

e. Submit a copy of the test reports.

f. For pollutants measured with continuous emissions monitoring systems (CEMS), please submit a copy of the 

most recent Relative Accuracy Test Audit (RATA) for the last 30 day period including those days where manual testing was conducted.

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility 

 Process Unit ID: ES-16

3. Provide information on each emission test conducted at each specific process unit. Please copy this page and provide the following 

information for each test conducted at anytime in the last 5 years.

a. Identify the Process Unit ID: N/A - No emission tests were conducted during the last five years. 

b. Describe emission release point(s) that were tested: __________________________________________________

c. Date of test: ______________________________________

d. Specify the test method(s) used: ___________________________________________________________________

 _________________________________________________________________________________________________
Operating cost 

information 2008 2009 2010

Control device ID:

Total operating costs

Electricity costs

Wastewater treatment 

costs

Fuel costs

Water costs

Waste disposal costs

Process unit operating 

labor costs

Monitoring, 

recordkeeping, and 

reporting

Other (please describe): 

Annual Bed change 

Other (please describe): 

 control device.

 Process Unit ID: ES-16

 (e.g., ductwork, piping, foundation/supports, site preparation): 

j. Use the following table to provide the annual cost for operating and maintenance of each 

d. Type of control device: 

e. Year installed: 

f. Manufacturer: 

g. Model No: ________________________________________________________________________

h. Original installed cost of the control device (capital cost of the control plus installation cost): 

a. Process Unit ID: 

b. Does the process unit have a control device that reduces air pollution : _____ Yes ____ No

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility 

4. For each flexible polyurethane foam production process unit, provide the following 

i. List the elements that are included in the installed cost estimate in question IV.5.h 

c. Describe the release point(s) that are being controlled (e.g., equipment or unit operation 

 where the release point is located): 

 information regarding air pollution control devices. Please copy this page and provide the

 following information for each unit: 

 ________________________________________________________________________________

Submitted as CBI
Operating cost 

information 2008 2009 2010

Control device ID:

Total operating costs

Electricity costs

Wastewater treatment 

costs

Fuel costs

Water costs

Waste disposal costs

Process unit operating 

labor costs

Monitoring, 

recordkeeping, and 

reporting

Other (please describe): 

Annual Bed change 

Other (please describe): 

d. Type of control device: 

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility 

 Process Unit ID: ES-14

4. For each flexible polyurethane foam production process unit, provide the following 

 information regarding air pollution control devices. Please copy this page and provide the

 following information for each unit: 

a. Process Unit ID: 

b. Does the process unit have a control device that reduces air pollution : _____ Yes ____ No

c. Describe the release point(s) that are being controlled (e.g., equipment or unit operation 

 where the release point is located): 

Submitted as CBI

 (e.g., ductwork, piping, foundation/supports, site preparation): 

j. Use the following table to provide the annual cost for operating and maintenance of each 

 control device.

e. Year installed: 

f. Manufacturer: 

g. Model No: ________________________________________________________________________

h. Original installed cost of the control device (capital cost of the control plus installation cost): 

 ________________________________________________________________________________

i. List the elements that are included in the installed cost estimate in question IV.5.h 
Enclosure 2a

Process unit ID

Measures or modification made to 

minimize emissions

Estimated emission 

reduction (lb/yr) 

ES-16 (a) Carbon Adsorber Control (TDI) ≈ 75 

ES-16 (a) Carbon Adsorber Control (MDI) ≈ 10

ES-14 Carbon Canister Control <1

(a) Estimated emission reduction is based on 2009 emission data and uses a 95% control 

efficiency for the carbon adsorption system.

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility 

 Process Unit ID: ES-14, ES-16

5. For each process unit identify measures (e.g., annual tune-ups or burners, good combustion practices, 

pollution prevention measures, or any other emission control approaches that reduce HAP emissions) or 

modifications made to the process unit to reduce emissions:
Emission reduction technique 

descriptions Pollutants affected Reduction efficiency

________________________ _______________________ ____________________

________________________ _______________________ ____________________

_______________________ ____________________

________________________ _______________________ ____________________

________________________ _______________________ ____________________

________________________ _______________________ ____________________

 ___________________________________________________________________________________________

e. At what frequency is parameter monitor quality assurance/control (e.g., calibration) performed?

7. Please submit a copy of any cost information you have for the modification or emission reduction method (other than add-on 

control devices) listed above.

f. What is annual parameter monitoring cost?

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility

______________________________________________________________________________________________

c. At what frequency is parameter monitoring done? 

d. Describe initial and ongoing parameter monitoring quality assurance/control: 

 ________________________________________________________________________________________

 reduce emissions, such as substitutions or product reformulation.

a. Complete for each emission reduction technique utilized that is not a control device.

b. What parameters are monitored to ensure operation of the emission reduction technique?

6. Other emission reduction techniques. Include any information about changes made in raw material usage to

 Process Unit ID: ES16

Submitted as CBI
Enclosure 2a

Emission 

source(s) causing 

event

Description 

of event

Permit 

conditions 

exceeded 

(Y/N)

Date of 

Event

Duration 

of each 

event 

(hours)

Was the event covered 

by a contingency plan for 

controlling emissions? 

(Y/N)

Estimates of 

emissions 

during event 

(pounds)

Basis for 

emissions 

estimate

Any monitoring 

data or control 

system parameter 

monitoring 

collected during 

event? 

(Y/N)

a. Please indicate number of times over the last 3 years that a shutdown and start-up event has occurred: 

b. Complete the following table for each shutdown and start-up event occurring over the last three years.

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility 

 Process Unit ID: ___________________________

8. Please provide the following information for each process unit during start-up and shutdown operation:

Submitted as CBI
 of the flexible polyurethane foam production process unit. 

k. Are you required to submit periodic and immediate start-up and shutdown reports

 (either stand-alone or constrained within the periodic excess emissions report) to your

 permitting authority? 

 _______________________________________________________________________________

i. What were the test conditions at the time of testing ? ________________________________

 _______________________________________________________________________________

 _______________________________________________________________________________

 _______________________________________________________________________________

j. Please submit a copy of any test data you have conducted during any start-up or shutdown

Enclosure 2a

c. Please list the procedures that are followed or any activities that occur during start-up and shutdown at this 

process unit to minimize emissions (e.g., turn off unit, monitor pressure):

f. Do you have test data that show emissions during start-up or shutdown? __ Yes __ No

g. If yes, when and why did you conduct such testing? __________________________________

Owner Name: FXI, Inc. Facility Name: _FXI - Cornelius, NC Facility

 Process Unit ID: ES-16

d. Is the emission profile of the flexible polyurethane foam production unit different during start-up and shutdown 

than during normal operating conditions? _____ Yes _____No

Submitted as CBI

e. If the answer to Part IV 9.d. is yes, please explain, in detail, how and why emissions are different during start-up 

__________________________________________________________________________________

__________________________________________________________________________________

 _______________________________________________________________________________

 _______________________________________________________________________________

 _______________________________________________________________________________

h. Please identify the emissions test method(s) used during start-up or shutdown.

 _______________________________________________________________________________

 _______________________________________________________________________________
Enclosure 2a

Longitude Latitude

VPF Stack ES-16 Submitted as 

CBI

Submitted as 

CBI

Submitted 

as CBI Submitted as CBI Submitted as CBI

Submitted as 

CBI

Height of 

release point 

(feet)

Exit of velocity of vent 

release point 

(feet/second)

Exit 

temperature of 

vent/flue gas 

(F)

Diameter of 

release point 

(feet)

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility 

 Process Unit ID: ES-16

9. Stack Release Parameters for Emission Points

 Please provide the following information for all emission release points for use in risk modeling

Location of release point (decimal 

degrees, minimum 5 digits beyond 

decimal) Emission Point Process Unit 

ID
Height of 

release point

Release Height Angle of Rotation 

Longitude Latitude (ft) (ft) x (length, ft) y (width, ft) (degrees)

Tanks 

(Venting 

indoors to 

carbon 

canisters) 

ES14 Submitted as CBI Submitted as CBI Submitted 

as CBI Submitted as CBI Submitted as CBI

Submitted as 

CBI Submitted as CBI

Location of release point Dimension of Source

(decimal degrees, minimum 5 digits beyond 

decimal)

Emission Point

Process Unit 

ID

Since the building is being treated as a fugitive source, 0.5 x building height was used as the release point height for a fugitive building source. 

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility

10. Non point releases. Please include a listing of fugitive releases, including the following

 information per release point. Please include "no releases" if this question does not

 apply. Notes on modeling data definitions are below.
Enclosure 2a

 _______________________________________________________________________________

n. What control devices are upstream of the scrubber? _________________________________

o. What control devices are downstream of the scrubber? ______________________________

l. Average outlet gas temperature for each scrubber: ________________________________oF

m. Please describe the source and quality of the water fed to the scrubber (e.g., effluent 

 water with a total solids content of _____): _________________________________________

 _______________________________________________________________________________

 _______________________________________________________________________________

 _______________________________________________________________________________

k. Mist eliminator: _____ Yes _____ No

 _______________________________________________________________________________

 _______________________________________________________________________________

c. Type of scrubber: _______________________________________________________________

d. Design pollutant-laden gas inlet flow rate: ______acfm

e. Design pollutant-laden gas inlet temperature: ________oF

f. Scrubbing medium (describe): ____________________________________________________

g. Influent scrubbing medium pH: ___________________________________________________

h. Effluent scrubbing medium pH: ___________________________________________________

i. Scrubber water flow: _________________________________________________ gals/min (?)

j. Scrubber pressure drop (across each scrubber--provide units): _________________________

b. Please list the pollutants that the scrubber is intended to reduce or remove.

Owner Name: __FXI, Inc. Facility Name: _FXI - Cornelius Facility

 Process Unit ID: ___________________________

a. Does the flexible polyurethane foam production process unit have a scrubber? 

_____ Yes ____ No

11. Scrubber Submitted as CBI
Enclosure 2a

 Process Unit ID: ES-16

Submitted as CBI

Legal Owner Name:

Facility Name:

Process Unit ID:

Process Unit ID for controlled processes:

Stack or Vent Height (ft)

Stack or Vent Diameter (ft)

Manufacturer/Model

Original Installation Date

Gas flow rate to condenser (acfm)

Inlet gas temperature (oF)

Compound Name

Volume Fraction

Compound Name

Volume Fraction

Compound Name

Volume Fraction

Compound Name

Volume Fraction

Describe any plans to replace or upgrade the adsorber

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility

12. Carbon Adsorber

 Please include a copy of this table for each carbon adsorber controlling emissions from 

 flexible polyurethane foam production process unit.

CARBON ADSORBER

Organic compounds in inlet gas stream

Vendor guarantee on adsorber efficient (attach copy)

Describe preventative maintenance procedures and frequency 

List all monitoring methods used, including parameters and frequency
Enclosure 2a

 Process Unit ID: ES-14 (Tank 4)

Submitted as CBI

Legal Owner Name:

Facility Name:

Process Unit ID:

Process Unit ID for controlled processes:

Stack or Vent Height (ft)

Stack or Vent Diameter (ft)

Manufacturer/Model

Original Installation Date

Gas flow rate to condenser (acfm)

Inlet gas temperature (oF)

Compound Name

Volume Fraction

Compound Name

Volume Fraction

Compound Name

Volume Fraction

Compound Name

Volume Fraction

for the purposes of this ICR. 

Vendor guarantee on adsorber efficient (attach copy)

Describe preventative maintenance procedures and frequency

(a) Tanks 26a, 26b, and 26c are MDI tanks that do not meet the definition of storage vessel 

List all monitoring methods used, including parameters and frequency

Describe any plans to replace or upgrade the adsorber

Organic compounds in inlet gas stream

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility

12. Carbon Adsorber

 Please include a copy of this table for each carbon adsorber controlling emissions from 

 flexible polyurethane foam production process unit.

CARBON ADSORBER
Enclosure 2a

 Process Unit ID: ES-14 Tanks 1,2, and 3 

Submitted as CBI

Legal Owner Name:

Facility Name:

Process Unit ID:

Process Unit ID for controlled processes:

Stack or Vent Height (ft)

Stack or Vent Diameter (ft)

Manufacturer/Model

Original Installation Date

Gas flow rate to condenser (acfm)

Inlet gas temperature (oF)

Compound Name

Volume Fraction

Compound Name

Volume Fraction

Compound Name

Volume Fraction

Compound Name

Volume Fraction

Vendor guarantee on adsorber efficient (attach copy)

Describe preventative maintenance procedures and frequency

List all monitoring methods used, including parameters and frequency

Describe any plans to replace or upgrade the adsorber

Organic compounds in inlet gas stream

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility

12. Carbon Adsorber

 Please include a copy of this table for each carbon adsorber controlling emissions from 

 flexible polyurethane foam production process unit.

CARBON ADSORBER
Enclosure 2a

Longitude Latitude

VPF Stack ES-16 -80.849265° 35.465719° 75 135 100 1

Height of 

release point 

(feet)

Exit of velocity of vent 

release point 

(feet/second)

Exit 

temperature of 

vent/flue gas 

(F)

Diameter of 

release point 

(feet)

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility 

 Process Unit ID: ES-16

9. Stack Release Parameters for Emission Points

 Please provide the following information for all emission release points for use in risk modeling

Location of release point (decimal 

degrees, minimum 5 digits beyond 

decimal) Emission Point Process Unit 

ID
Height of 

release point

Release Height Angle of Rotation 

Longitude Latitude (ft) (ft) x (length, ft) y (width, ft) (degrees)

Tanks 

(Venting 

indoors to 

carbon 

canisters) 

ES14 -80.849875° 35.466756° 10.75 10.75 37 105 325

Location of release point Dimension of Source

(decimal degrees, minimum 5 digits beyond 

decimal)

Emission Point

Process Unit 

ID

Since the building is being treated as a fugitive source, 0.5 x building height was used as the release point height for a fugitive building source. 

Owner Name: FXI, Inc. Facility Name: FXI - Cornelius, NC Facility

10. Non point releases. Please include a listing of fugitive releases, including the following

 information per release point. Please include "no releases" if this question does not

 apply. Notes on modeling data definitions are below.