1 of 8 ENCLOSURE 1 INFORMATION COLLEC TION REQUEST FOR Flexible Polyurethane Foam Production We are conducting this Information Collection Reque st (ICR) to assist th e EPA Administrator in developing emission standards for Flexible Po lyurethane Foam under Clean Air Act (CAA) section 112. We are sending this ICR to you under the authority of Secti on 114 of the CAA.
BACKGROUND: We are required by section 112(f)(2) of the Clea n Air Act (CAA) to assess the risk remaining (residual risk) eight years afte r the application of maximum achievable cont rol 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 (t aking into consideration various factors) adverse environmental effects, we are required to promul gate more stringent standards. The Flexible Polyurethane Foam MACT standard was promul gated in October 1998 (see 63 FR 53980). We are preparing to initiate our residual ri sk review. Please note this surv ey is for flexible polyurethane foam production only and does not cover flexible polyurethane foam fabrication, other than identifying if flexible polyuret hane foam fabrication is conduct ed 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 rela ted solid waste regulations (§ 129); 2. Determining whether any person is in violati on of any standards or requirements developed under the authoritie s cited above; or 3. Carrying out any provision under the CAA (excep t certain provisions under Title II). The Administrator may require that those pers ons 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 equipm ent, and use audit procedures, or methods;

 sample emissions (in accordance with such pr ocedures 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 acco rdance with section 114(a)(3); and

 provide such other information as we may reasonably require.2 of 8 We seek information on existing flexible polyuret hane foam production source s in this survey in order to collect information needed to conduct th e residual risk review required by section 112 of the Act.
DIRECTIONS FOR COMP LETING 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 co nfidential business information (CBI). Any responses not so identified will be included in a publicly ava ilable 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 fr om the isocyanate-water reaction. Flexible polyurethane foam means a flexible cellular polyme r 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 pa ssage of air through th e foam, and possess the strength and flexibility to allow repeated dist ortion 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 a ssociated 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 reconstructe d 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 applicat ion for rebond foam is for carpet underlay. Rebond foam process means the equipment used to pr oduce a rebond foam product. For the purpose of this subpart, the rebond foam proce ss includes raw material storage; production equipment and associated piping, ductwo rk, 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, absorb ers, 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.3 of 8 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 th at is used to store diisocyanate or HAP ABA for use in the production of flexible polyurethane fo am. Storage vessels do not include vessels with capacities smaller than 38 cubi c meters (or 10,000 gallons).

CONFIDENTIAL BUSINE SS INFORMATION (CBI) : Please indicate if any CBI is include d in this survey response:  Y  N4 of 8 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 deci mal 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_____________________

_5 of 8 5. Flexible Polyurethane Foam Production
We believe that you own or operate a facility that engages in productio n 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 pol yurethane 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 inform ation 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.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 wh ere the flexible polyuret hane 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 Ad ministration’s Size Standards at: http://www.sba.gov/sites/defaul t/files/Size_Stan dards_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 federa l and State emission standa rds and if yes, which standards? The facility operates under Mecklenburg C ounty 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 Practi ces for Sources of Volatile Organic Compounds MCAPCO Regulation 2.0518 – Miscella neous Volatile Organic Compound Emissions MCAPCO Regulation 2.1100 – Contro l of Toxic Air Pollutants MCAPCO Regulation 2.1111 – Maximum Achievable Control Technology 40 CFR Part 63 Subpart A – National Em ission Standards for Hazardous Air Pollutants 40 CFR Part 63 Subpart III – National Em ission Standards for Hazardous Air Pollutants for Flexible Poly urethane Foam Production MCAPCO Regulation 2.0949 - Storage of Miscellaneous Volatile Organic Compounds7 of 8 f. Is the facility a major source or area source? Major sources are all activities located on contiguous area under common control wh ere the aggregate potential to emit for the activities exceeds ten (10) tons per year of a sing le HAP or twenty-five ( 25) tons per year of a combination of HAPs. FXI – Cornelius Facility was a major sour ce at the time of the compliance date (October 8, 2001) established in 40 CF R Part 63, Subpart III, Section § 63.1291. FXI is submitting this ICR as requested for f acilities 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 ta nks 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 a nd Figure 1 of CBI Submittal
2. Please provide a flow diagram of the process unit s associated with the flexible polyurethane foam production process at your facility. Labe l each process unit and emission point with a unique identification code and complete the table below. The flow diagram should display an iden tification code for streams entering (raw materials/feedstocks) and exiting the process un it (product streams), and emission streams. The flow diagram should also displa y an identification code for a dd-on control devices and streams entering and exiting the add-on control devices. Where applicable, include in-process streams, waste streams, wastewater streams, and emi ssion 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 re quested above for both source ES-16 (Variable Pressure Foam Pouring Line) and ES-14 ((Four (4) 10,900 gallon TDI/MDI storage tanks)). ES-148 of 8 3. List Federal air pollution control regul ations 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 ProductionEnclosure 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 manufactured (e.g., days, or hours) Process unit name

6,730,660 312,711 3,787,639Enclosure 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 80/20Enclosure 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? NoHours 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 unitEnclosure 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 madeEnclosure 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-16Enclosure 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 ofEnclosure 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 CBIOperating 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.hEnclosure 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 CBIEnclosure 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 CBIof 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

IDHeight 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 Dimension of Source Location of release point (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: ________________________________ o F
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: ________ o F
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 CBIEnclosure 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 ( o F)
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 frequencyEnclosure 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 ( o F)
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 ADSORBEREnclosure 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 ( o F)
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 ADSORBEREnclosure 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

IDHeight 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 Dimension of Source Location of release point (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.