1 of 8 ENCLOSURE 1

INFORMATION COLLECTION REQUEST FOR

Flexible Polyurethane Foam Production

We are conducting this I nformation C ollection R equest (ICR) to assist the EPA

Administrator in developing emission standards for Flexible Polyurethane Foam

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

authority of Section 114 of the CAA.

BACKGROUND:

We are required by s ectio n 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 heal th with an ample margin of safety or to prevent

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

required to promulgate more stringent standards

. T he Flexible Polyurethane Foam

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

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

polyurethane foam production only and does not cover flexible polyurethane foam

fabrication, other than identifying if flexible polyurethane foam fabrication is

conducted as a co

- located operation.

S ection 114(a) of the CAA give s us the authority to require you to provide us with

information for the following purposes:

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

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

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

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

(§ 112);

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

2. Determining 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).2 of 8

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

in direct data when direct monitoring of emissions is impractical;

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

 provide such other information as we may reasonably require.

We seek information on existin g f lexible p olyurethane f

oam production sources in

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

required by section 112 of the Act

.

DIRECTIONS FOR COMPLETING THIS SURVEY :

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

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

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

available database. You may r efer to Enclosures

, 3, 4, 5, and 6 to learn how we will

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

substantiate a claim of confidentiality.

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

Auxiliary blowing agent, or ABA, means a low

- boiling point liquid 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 essentia lly 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 polyurethane3 of 8

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 f oam process includes raw material

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

storage areas.

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

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

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

Slabstock flexible polyurethane foam means flexible polyurethane foam that is

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

Slabstock flexible p olyurethane foam production line includes all portions of the

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

where the foam is completely cured.

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

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

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

CONFIDENTIAL BUSINESS INFORMATION (CBI) :

Please indicate if any CBI is included in this survey response:  Y  N4 of 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:

a. Address:

b. City:

c. State:

d. Zip:

e. County:

2 .Facility Name:

_________________________ _________________________________

3

. Complete street address of facility (physical location):

a. Address:

b. City:

c. State:

d. Zip:

e. County:

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

figures to the right of the decimal place (e.g., 38.2794 1

, - 85.64371) ] :

___________________________________ _____________________________

4

. Facility Contact:

a. Name (First Name, Last Name):

b. Title:

c. Telephone Number: ( ) _Ext

____________ d. Fax Number: ( )

_

e. E

- mail address :

f. Primary NAICS code for the facility_______________________________5 of 8

5. Flexible Polyurethane Foam Production

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

slabstock, molded or rebond f lexible p olyurethane f

oam

. If you believe that this

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

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

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

Production plant. Include date the permit was inactivated.

________________________________ _______________________________

________________________________ ______________________________

________________________________ ______________________________

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

is located at this facility.

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

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

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

Please mail, fax, or e

- mail Part I to:

U.S. EPA Mailroom

Attn: Sharon Nizich

Mail Code: D243

- 0 4

Research Triangle Park, NC 27711

Phone: 919 541 2825

Fax: 919 541

- 5450

Email address : Nizich.sharon@epa.gov6 of 8

PART II. GENERAL FACILITY INFORMATION

1

. Please provide the following general information for each flexible

polyurethane foam production p lant:

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

production is located:

________________________________ _________________

b. Number of employees at the parent company, organization or institution (e.g.

municipality, university, etc.) that owns the facility:

_____________________

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

[i nsert the following if applicable]

d. Any other co

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

e. Are any operations on site subject to federal and State emission standards and

if yes, which standards?

f. Is the facility a major source or area so urce? 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.

g. T ype 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.7 of 8

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 poi nts in the flow

diagram

.

Identification code Description of item submitted with survey response8 of 8

3

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

Process unit name Process unit

identification code Federal air pollution control

regulation