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 polyurethan e 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 whet her 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 da ta 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.2 of 8

We seek information on existin g f lexible p olyurethane f

oam pro duction 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 wil l 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 polyurethane foam process includes raw material sto rage; 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 af fected 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 bon ding 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; p roduction 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.3 of 8

Slabstock flexible pol

yurethane 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 : 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

– Corry Facility
3. Complete street address of facility (physical location):
a. Address: 466 South Shady Avenue b. City: Corry
c. State: Pennsylvania d. Zip: 16407 e. County: Erie f. Longitude and Latitude coordin ates [in decimal degrees with five significant figures to the right of the decimal place (e.g., 38.27941,

- 85.64371)]: 41.916276,

- 79

. 614119

_ 4. Facility Contact: a. Name (First Name, Last Name): Matt Johnson
b. Title: EHS and Quality Manag er c. Telephone Number: (814) 664

- 7771 Ext 228 d. Fax Number: ( )
e. E

- mail address: majohnson@fxi.com f. Primary NAICS code for the facility : 3261505 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 : 186 (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

– Corry 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?
Yes, acc ording to Pennsylvania Department of Environmental Protection (PADEP)(Title V/State Operating Permit No. 25

- 00326), FXI

- Corry F acility is subject to the following emission standards : 25 Pa. Code §123.1

– Prohibition of Certain Fugitive Emissions

25 Pa. Code §123.31

– Odor Emissions 25 Pa. Code §123.41

– Visible Emissions 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 Production7 of 8

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

- Corry 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

– Corry facility ceased the use of HAP A BA in August, 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 in CBI Submittal

2. Please provide a flow diagram of the process units associated with the flexible polyureth ane 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/feedstock s) 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

- proce ss streams, waste streams, wastewater streams, and emission release points in the flow diagram

.
Identification code Description of item submitted with survey response

101 Figure 1

– Contains a generalized drawing of the items

requested above for both sources 101 (Slabstock Foam Line) and TS1 (

(Four (4) 10,000 gallon TDI storage tanks ) ). TS18 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
MAXFOAM Machine (Slabstock Foam Line) 101 40 CFR Part 63, Subpart III

TDI Storage Tanks (4) 10,000 gallons each TS1 40 CFR Part 63, Subpart IIIEnclosure 2

2010 2009 2008 2010 2009 2008

101 MAXFOAM MACHINE (Slabstock Foam Pouring Line) Submitted as CBI Submitted as

CBI Submitted as

CBI tons of foam

produced 575 418 595

TS1 (a) Four (4) TDI Storage Tanks (10,000) gallons each 4,820,089 3,831,772 5,645,123 lbs of TDI feedstock N/A N/A N/A

(a) The quantity of TDI in the four TDI storage tanks is not tracked individually. Process unit name Production Amount Production units 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 (hours) Process unit nameEnclosure 2

2010 2009 2008

Slabstock Foam Line TDI lbs 4,820,089 3,831,772 5,645,123

TS1 (TDI Tanks) (a) TDI lbs 4,820,089 3,831,772 5,645,123

(a) The quantity of TDI in the four TDI storage tanks is 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.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 3. Provide composition information for feedstock/raw materials.

TDI 80/20Enclosure 2

Adhesive Name HAP Contained HAP Content (wt%) Annual Usage (lbs) 4. Are any HAP-containing adhesives utilized in repair of foam as part of the production process? No

FXI - Corry does not use adhesives in the foam production process that contain HAP.Enclosure 2a

Owner Name: FXI, Inc. Facility Name: FXI - Corry, PA Facility Process Unit ID: 101 and TS1

Hours Per (e.g., week, month, year)

101 Submitted

as CBI Submitted as

CBI Submitted as CBI 18,720 lb/hr of TDI Submitted as CBI Submitted as

CBI

TS1 Submitted

as CBI Submitted as

CBI Submitted as CBI 55 gallons/hr each tank Submitted

as CBI Submitted as

CBI PART IV. GENERAL FLEXIBLE POLYURETHANE FOAM PRODUCTION INFORMATION

Process unit ID 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 - Corry, PA Facility Process Unit ID: 101 and TS1

101 Foam Pouring Line Submitted as CBI Submitted as CBI Submitted as CBI Submitted as CBI

TS1 - Four (4) 10,000 gallons tanks Submitted as CBI Submitted as CBI Submitted as CBI Submitted as CBI trains. b. Provide information on upgrades to each flexible polyurethane foam production process unit and associated air

Description of upgrades made to 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: 101 and TS1

Process Unit ID Total operating and

maintenance costs 2008 2009 2010

101 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 - Corry, PA FacilityEnclosure 2a

Process Unit ID: 101 and TS1

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

Emission Point Process Unit ID HAP Pollutant Tons per year 2006 Tons per year 2007 Tons per year

2008 Tons per year

2009 Tons per year

2010
Stacks: S1P, S2P, S3P, S4P, S5P, S6P, S7P, S8P,

S9P 101 Slabstock Pouring Line 2,4-Toluene Diisocyanate 0.082 0.072 0.064 0.102 0.128

Tanks TS1 - Four (4) TDI Storage Tanks 2,4-Toluene Diisocyanate 0.001 0.001 0.001 0.006 0.007

(a) Emissions are from FXI - Corry's Toxic Release Inventory (TRI) Form R annual reports. Stack emissions are from the slabstock foam line and fugitive emissions from tanks. unit. Owner Name: FXI, Inc. Facility Name: FXI - Corry, PA Facility

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

Process Unit ID: 101 and TS1

No emission tests have been performed at the FXI-Corry facility during the last five (5) years.

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 - Corry, PA Facility

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: ___________________________________ c. Date of test: ______________________________________ d. Specify the test method(s) used: ___________________________________________________________________

_________________________________________________________________________________________________Process Unit ID: 101 and TS1

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):

________________ Other (please describe):

________________ b. Does the process unit have a control device that reduces air pollution : _____ Yes _____ No Owner Name: FXI, Inc. Facility Name: FXI - Corry, PA 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:

__________________________________________________________________________________ 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):

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

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

__________________________________________________________________________________
j. Use the following table to provide the annual cost for operating and maintenance of eachEnclosure 2a

Process Unit ID: 101 and TS1

Process unit ID Measures or modification made to minimize emissions Estimated emission reduction (lb/yr)

101 Elimination of HAP ABA Methylene chloride usage was 723,659 lbs in 2002, 336,957 lbs in 2003, and 18,054 lbs in 2004. HAP ABA usage was completely eliminated in August 2004. Owner Name: FXI, Inc. Facility Name: FXI - Corry, PA Facility

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:Enclosure 2a

Process Unit ID: 101 and TS1 Submitted as CBI

Emission reduction technique descriptions Pollutants affected Reduction efficiency

________________________ _______________________ _________________

________________________ _______________________ _________________

________________________ _______________________ _________________

________________________ _______________________ _________________

________________________ _______________________ _________________

________________________ _______________________ _________________ Owner Name: FXI, Inc. Facility Name: FXI - Corry, PA 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

___________________________________________________________________________________________ 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 addon control devices) listed above. ____ ___________________________________________________________________________________

___________________________________________________________________________________________
f. What is annual parameter monitoring cost?

____ ___________________________________________________________________________________Enclosure 2a

Process Unit ID: 101 and TS1

Submitted as CBI

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 - Corry, PA Facility

8. Please provide the following information for each process unit during start-up and shutdown operation:Process Unit ID: 101 and TS1

_______________________________________________________________________________ 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):

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

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

__________________________________________________________________________________

__________________________________________________________________________________ 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 - Corry, PA Facility

_______________________________________________________________________________

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

______________________________________________________________________________

_______________________________________________________________________________

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 Submitted as CBIEnclosure 2a

Process Unit ID: 101 and TS1

Longitude Latitude

S1P Stack 1 Pourline Submitted as CBI Submitted as

CBI Submitted

as CBI Submitted as

CBI Submitted as

CBI Submitted as

CBI

S2P Stack 2 Pourline Submitted as CBI Submitted as

CBI Submitted

as CBI Submitted as

CBI Submitted as

CBI Submitted as

CBI

S3P Stack 3 Pourline Submitted as CBI Submitted as

CBI Submitted

as CBI Submitted as

CBI Submitted as

CBI Submitted as

CBI

S4P Stack 4 Pourline Submitted as CBI Submitted as

CBI Submitted

as CBI Submitted as

CBI Submitted as

CBI Submitted as

CBI

S5P Stack 5 Pourline Submitted as CBI Submitted as

CBI Submitted

as CBI Submitted as

CBI Submitted as

CBI Submitted as

CBI

S6P Stack 6 Pourline Submitted as CBI Submitted as

CBI Submitted

as CBI Submitted as

CBI Submitted as

CBI Submitted as

CBI

S7P Stack 7 Pourline Submitted as CBI Submitted as

CBI Submitted

as CBI Submitted as

CBI Submitted as

CBI Submitted as

CBI

S8P Stack 8 Pourline Submitted as CBI Submitted as

CBI Submitted

as CBI Submitted as

CBI Submitted as

CBI Submitted as

CBI

S9P Stack 9 Pourline 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 - Corry, PA Facility

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 IDProcess Unit ID: 101 and TS1

Height of release point Release Height Angle of Rotation

Longitude Latitude (ft) (ft) x (length, ft) y (width, ft) (degrees) Fugitive Tank Emissions Building Ventilation TS1 Submitted as CBI Submitted

as CBI Submitted

as CBI Submitted as

CBI Submitted as

CBI Submitted as

CBI Submitted as

CBI Owner Name: FXI, Inc. Facility Name: FXI - Corry, PA 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.

Dimension of Source Location of release point (decimal degrees, minimum 5 digits beyond decimal) Process Unit ID Emission PointEnclosure 2a

Process Unit ID: 101 and TS1

Submitted as CBI Owner Name: FXI, Inc. Facility Name: FXI - Corry, PA Facility

11. Scrubber

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

____ Yes

___ No

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): _________________________

_______________________________________________________________________________
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 _____): _________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________Enclosure 2a

Submitted as CBI

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 - Corry, PA 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: 101 and TS1

Longitude Latitude S1P Stack 1 Pourline -79.616027 41.916778 30 34.1 70 1.8 S2P Stack 2 Pourline -79.615972 41.916757 50 31.7 70 1.8 S3P Stack 3 Pourline -79.615889 41.916728 50 21.5 70 1.8 S4P Stack 4 Pourline -79.615834 41.916708 50 24.9 70 2 S5P Stack 5 Pourline -79.615609 41.916627 30 14.8 70 3.6 S6P Stack 6 Pourline -79.615505 41.916589 30 16.3 70 3.6 S7P Stack 7 Pourline -79.615383 41.916555 50 11.0 70 3.6 S8P Stack 8 Pourline -79.615274 41.916517 30 9.9 70 3.6 S9P Stack 9 Pourline -79.615200 41.916488 30 18.0 70 2.4

20.24853333 2.688888889 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 - Corry, PA Facility

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 IDProcess Unit ID: 101 and TS1

Height of release point Release Height Angle of Rotation

Longitude Latitude (ft) (ft) x (length, ft) y (width, ft) (degrees) Fugitive Tank Emissions Building Ventilation TS1 -79.616216° 41.916883° 30 30 2 2 N/A Owner Name: FXI, Inc. Facility Name: FXI - Corry, PA 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.

Dimension of Source Location of release point (decimal degrees, minimum 5 digits beyond decimal) Process Unit ID Emission Point