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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 

 a. Address: 1400 North Providence Road, Suite 2000 

 b. City: Media 

 c. State: Pennsylvania 

 d. Zip: 19063 

 e. County: Delaware 

2.Facility Name: FXI – Auburn, IN Facility

______________________________________________________ 

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

 a. Address: 2211 South Wayne Street 

 b. City: Auburn 

 c. State: Indiana 

 d. Zip: 46706 

 e. County: DeKalb 

 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)]:41.348222, -85.064639

4. Facility Contact:

 a. Name (First Name, Last Name): Joe Bertolini 

 b. Title: Corporate Technical Director 

 c. Telephone Number: (610) 256-9744 Ext ____ 

 d. Fax Number: ( ) 

 e. E-mail address: jbertolini@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: 126 (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 – Auburn 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 the Indiana Department of Environmental 

Management (IDEM) Title V Operating Permit No. T033-27355-00047 and is 

subject to the following emission standards: 

326 IAC 2-7-5(1) – Emission Limitations and Standards 

326 IAC 6-3-2 – Particulate Emission Limitations for Processes with Process 

Weight Rates Less than One Hundred (100) Pounds per Hour 

326 IAC 5-1 – Opacity 

326 IAC 4-1 and IAC 13-17-9 – Open Burning 

326 IAC 4-2 and 326 IAC 9-1-2 – Incineration 

326 IAC 6-4 – Fugitive Dust Emissions 

326 IAC 1-7 – Stack Height 

326 IAC 14-10 and 326 IAC 18 and 40 CFR 61, Subpart M – Asbestos 

326 IAC 8-1-6 – Volatile Organic Compounds 

326 IAC 6-3-2 – Particulate 

326 IAC 1-6-3 and 326 IAC 2-6-5(13) – Preventative Maintenance 
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326 IAC 20-22 Flexible Polyurethane Foam Production 

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

Pollutants 

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

Pollutants for Flexible Polyurethane Foam Production 

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 – Auburn 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 – Auburn 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.

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. 
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Identification 

code 

Description of item submitted with survey response 

VPF

Appendix A – Figure 1 contains a generalized process flow drawing 

of the items requested above for the variable pressure foam pouring 

line (VPF), Tank # 3, Tank # 4, Tank # 7, and Tank # 14.

T3 

T4 

T7 

T14 

EU-R1

Appendix A – Figure 2 contains a generalized process flow drawing 

of the four (4) polyurethane foam rebond units. 

EU-R2

EU-R3

EU-R4
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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 

Foaming Line (VPF) 

40 CFR Part 63 Subpart III – National 

Emissions Standards for Hazardous Air 

Pollutants for Flexible Polyurethane 

Foam Production 

Rebond Mold Units EU-R1, EU-R2, EUR3, EU-R4 

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

VPF Variable Pressure 

Foam Pouring Line

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI Board Feet 575 hours 502 hours 681 hours

EU-R1 Rebond Mold Unit (b) 

EU-R2 Rebond Mold Unit (b)

EU-R3 Rebond Mold Unit (b)

EU-R4 Rebond Mold Unit (b)

T3 TDI Tank (a) 4,768,248 4,029,566 6,299,494 lbs N/A N/A N/A

T4 TDI Tank (a) 4,768,248 4,029,566 6,299,494 lbs N/A N/A N/A

T7 TDI Tank (a) 4,768,248 4,029,566 6,299,494 lbs N/A N/A N/A

T14 MDI Tank (b) 1,951,945 1,480,991 799,525 lbs N/A N/A N/A

(a) Throughput quantities for Tanks 3, 4, and 7 are not tracked individually.

(b) MDI is used in the rebond process and reflects the feedstock usage for all of the rebond units. Each rebond unit MDI consumption is not tracked individually. 

MDI is used as feedstock for the Rebond 

Units and the MDI tank below reflects 

feedstock usage for all four (4) units. 

 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)

The production quantity of the four (4) rebond mold units 

is not readily available.
Enclosure 2

2010 2009 2008

TDI 80/20 lbs 4,768,248 4,029,566 6,299,494

MDI lbs 1,951,945 1,480,991 799,525

EU-R1 Rebond Mold Unit

EU-R2 Rebond Mold Unit

EU-R3 Rebond Mold Unit

EU-R4 Rebond Mold Unit

Tanks 3, 4 and 7 (a) TDI 80/20 lbs 4,768,248 4,029,566 6,299,494

Tank 14 MDI lbs 1,951,945 1,480,991 799,525

(a) Throughput quantities for Tanks 3, 4, and 7 are not individually tracked.

(b) The quantity of MDI used in the four (4) rebond units is not individually tracked. 

lbs 1,951,945 (b) 1,480,991 (b) 799,525 (b)

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

 Include only HAP-containing feedstock.

Variable Pressure 

Foam Pouring Line 

(VPF)

Process unit name Raw material/feedstock Raw material/feedstock 

amount

Raw material/feedstock
Enclosure 2

Raw material 

products/feedstock

Auxiliary Blowing 

Agents

Chemical Compounds

% of each chemical 

compound (a)

N/A 2,4-Toluene Diisocyanate (TDI) 80

N/A 2,6-Toluene Diisocyanate (TDI) 20

MDI N/A Diphenylmethanediisocyanate (MDI) 60 - 100

(a) The percentages of MDI and TDI were taken from the product MSDS. 

3. Provide composition information for feedstock/raw materials.

TDI 80/20
Enclosure 2

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

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

4. Are any HAP-containing adhesivies utilized in repair of foam as part of the production process? No
Enclosure 2a

Hours

Per (e.g., week, 

month, year)

VPF - Variable 

Pressure Foam 

Pouring Line

Submitted as 

CBI

Submitted as 

CBI Submitted as CBI 1.2 billion board feet per year 

Submitted 

as CBI

Submitted as 

CBI

Tanks 3, and 4 

(TDI)

Submitted as 

CBI

Tank 7 (TDI) Submitted as 

CBI

Tank 14 (MDI) Submitted as 

CBI

Submitted as 

CBI Submitted as CBI 10,000 gallon capacity

Submitted 

as CBI

Submitted as 

CBI

EU-R1 Submitted as 

CBI

Submitted as 

CBI Submitted as CBI

EU-R2 Submitted as 

CBI

Submitted as 

CBI Submitted as CBI

EU-R3 Submitted as 

CBI

Submitted as 

CBI Submitted as CBI

EU-R4 Submitted as 

CBI

Submitted as 

CBI Submitted as CBI

Submitted as 

CBI Submitted as CBI Submitted as CBI

Submitted 

as CBI

9.6 tons per hour

Submitted as 

CBI

Submitted 

as CBI

Submitted as 

CBI

Submitted 

as CBI

25,000 gallon 

capacity (each)

Owner Name: FXI, Inc. Facility Name: FXI - Auburn, IN Facility

 Process Unit ID: VPF, Tanks 3, 4, 7, 14, EU-R1, EU-R2, EU-R3, EU-R4

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 unit
Enclosure 2a

Owner Name: FXI, Inc. ____________________________ Facility Name: FXI - Auburn, IN Facility

 Process Unit ID: VPF

VPF - Variable 

Pressure Foam 

Pouring Line

Submitted as CBI

 air pollution control trains.

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

Description of upgrades made 

to air pollution control 

devices associated with the 

Description of 

upgrades made to 

the process unit

Year(s) upgrade was 

Process unit ID made

Year(s) upgrade was 

made
Enclosure 2a

Process Unit ID Total operating and 

maintenance costs

2008 2009 2010

VPF - 

Variable 

Pressure 

Foam 

Pouring Line

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 - Auburn, IN Facility

 Process Unit ID: VPF
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

Tons per year 

2007

Tons per year 

2008

Tons per year 

2009

Tons per year 

2010

Adsorber North 

Stack VPF 2,4-Toluene Diisocyanate

Adsober South Stack VPF 2,4-Toluene Diisocyanate

Carbon Canister 

Venting inside of 

building 

Tanks 3, 4, 

and 7 (TDI) 2,4-Toluene Diisocyanate 0.0025 0.0025 0.0025 0.0025 0.0064

Carbon Canister 

Venting inside of 

building 

Tank 14 4,4'-Methylenediphenyl 

Diisocyanate 0.3505 0.2325 0.101 0.0025 0.0007

EU-R1 Stacks EU-R1 4,4'-Methylenediphenyl 

Diisocyanate

EU-R2 Stacks EU-R2 4,4'-Methylenediphenyl 

Diisocyanate

EU-R3 Stacks EU-R3 4,4'-Methylenediphenyl 

Diisocyanate

EU-R4 Stacks EU-R4 4,4'-Methylenediphenyl 

Diisocyanate

 unit.

Owner Name: FXI, Inc. Facility Name: FXI - Auburn Facility

Process Unit ID: VPF, Tanks 3, 4, 7, 14, EU-R1, EU-R2, EUR3, EU-R4

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

0.049 0.037 0.025 0.0015 0.00185

0.0025 0.0025 0.0025 0.0025 0.0025
Enclosure 2a

both the Rebond units and the VPF.

e. Submit a copy of the test reports. Attached - See Appendix B (Note: The attached test report contains test 

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. N/A

Owner Name: FXI, Inc. Facility Name: FXI - Auburn, IN Facility

 Process Unit ID: VPF

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: VPF (Variable Pressure Foam Line) 

b. Describe emission release point(s) that were tested: North and South Carbon adsorber stacks serving the VPF 

c. Date of test: July 17 - 19, 2007

d. Specify the test method(s) used: EPA Reference Methods 1, 2, 3, 4, 5, 18, 25A, and CTM-036
Enclosure 2a

both the Rebond units and the VPF.

d. Specify the test method(s) used: EPA Reference Methods 1, 2, 3, 4, 5, 18, 25A, and CTM-036

e. Submit a copy of the test reports. Attached - See Appendix B (Note: The attached test report contains test 

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. N/A

Owner Name: FXI, Inc. Facility Name: FXI - Auburn, IN Facility

 Process Unit ID: EU-R1, EUR2, EU-R3, EU-R4

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: Rebond Mold Units: EU-R1, EUR2, EUR3, EU-R4 

b. Describe emission release point(s) that were tested: Each rebond units main stack and dryer stack 

c. Date of test: July 17 - 19, 2007
Enclosure 2a

Operating cost 

information 2008 2009 2010

Control device ID:

Total operating costs

Electricity costs

Wastwater treatment 

costs

Fuel costs

Water costs

Waste disposal costs

Process unit operating 

labor costs

Monitoring, 

recordkeeping, and 

reporting

Other (please describe): 

 control device.

 Process Unit ID: VPF

 (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 - Auburn, IN 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
Enclosure 2a

Operating cost 

information 2008 2009 2010

Control device ID:

Total operating costs

Electricity costs

Wastwater treatment 

costs

Fuel costs

Water costs

Waste disposal costs

Process unit operating 

labor costs

Monitoring, 

recordkeeping, and 

reporting

Other (please describe): 

 Submitted as CBI

Owner Name: FXI, Inc. _______________ Facility Name: FXI - Auburn, IN Facility

 Process Unit ID: Tanks 3, 4, and 7 

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: 

g. Model No: 

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): 

 __________________________________________________________________________________

 __________________________________________________________________________________

 __________________________________________________________________________________

 __________________________________________________________________________________

d. Type of control device: 

e. Year installed: 

f. Manufacturer: 

 control device.

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 

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

 __________________________________________________________________________________

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

Operating cost 

information 2008 2009 2010

Control device ID:

Total operating costs

Electricity costs

Wastwater treatment 

costs

Fuel costs

Water costs

Waste disposal costs

Process unit operating 

labor costs

Monitoring, 

recordkeeping, and 

reporting

Other (please describe): 

 Submitted as CBI

Owner Name: FXI, Inc. _______________ Facility Name: FXI - Auburn, IN Facility

 Process Unit ID: Tank 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: 

g. Model No: 

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): 

 __________________________________________________________________________________

 __________________________________________________________________________________

 __________________________________________________________________________________

 __________________________________________________________________________________

d. Type of control device: 

e. Year installed: 

f. Manufacturer: 

 control device.

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 

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

 __________________________________________________________________________________

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

Process unit ID

Measures or modification made to 

minimize emissions

Estimated emission 

reduction (lb/yr)

VPF Carbon Adsorber Control 70.3

Tanks 3, 4, and 7 (TDI) Carbon Canister Control <1

Tank 14 (MDI) Carbon Canister Control <1

Owner Name: FXI, Inc. Facility Name: FXI - Auburn, IN Facility 

 Process Unit ID: VPF, Tanks 3,4,7,14

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

Emission reduction 

technique descriptions Pollutants affected Reduction efficiency

________________________ _______________________ ____________________

________________________ _______________________ ____________________

________________________ _______________________ ____________________

________________________ _______________________ ____________________

________________________ _______________________ ____________________

________________________ _______________________ ____________________

f. What is annual parameter monitoring cost?

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.

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

Owner Name: FXI, Inc. Facility Name: FXI - Auburn, IN Facility

 Process Unit ID: VPF

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

 usage to 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?

______________________________________________________________________________________________

c. At what frequency is parameter monitoring done? 

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

 ___________________________________________________________________________________________

 ___________________________________________________________________________________________

Submitted as CBI
Enclosure 2a

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 - Auburn, IN Facility 

 Process Unit ID: ___________________________

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

 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 CBI

 _______________________________________________________________________________

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 

__________________________________________________________________________________

__________________________________________________________________________________

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 - Auburn, IN Facility

 Process Unit ID: VPF

 _______________________________________________________________________________

 _______________________________________________________________________________

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

 _______________________________________________________________________________
Enclosure 2a

Longitude Latitude

VPF Carbon Unit 1 North 

Stack VPF Submitted as CBI Submitted as CBI Submitted as CBI

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI

VPF Carbon Unit 2 

South Stack VPF Submitted as CBI Submitted as CBI Submitted as CBI

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI

EU-R1 Stack Process 28a Submitted as 

CBI Submitted as CBI Submitted as CBI

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI

EU-R1 Stack Dryer 28b Submitted as 

CBI Submitted as CBI Submitted as CBI

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI

EU-R2 Stack Process 29a Submitted as 

CBI Submitted as CBI Submitted as CBI

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI

EU-R2 Stack Dryer 29b Submitted as 

CBI Submitted as CBI Submitted as CBI

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI

EU-R3 Stack Process 35a Submitted as 

CBI Submitted as CBI Submitted as CBI

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI

EU-R3 Stack Dryer 35b Submitted as 

CBI Submitted as CBI Submitted as CBI

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI

EU-R4 Stack Process 36a Submitted as 

CBI Submitted as CBI Submitted as CBI

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI

EU-R4 Stack Dryer 36b 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 - Auburn, IN Facility 

 Process Unit ID: VPF, EU-R1, EU-R2, EU-R3, EUR4

9. Stack Relase Parameters for Emission Points

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

Location of release point (decimal 

degrees, minimum 5 digits beyond 

Emission Point decimal) Process Unit 

ID
Height of 

release point 

(a)

Release Height (a)

Angle of 

Rotation 

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

Fugitive 

Area Source 

Tank Farm 

Building 

Tank TA, 

Tank TB 

Submitted 

as CBI

Submitted 

as CBI

Submitted 

as CBI

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI

Submitted as 

CBI

half the building height. 

Dimension of Source

Location of release point 

(decimal degrees, 

minimum 5 digits beyond 

decimal)

Emission 

Point

Process Unit 

ID

(a) Since no direct ventiliation of the tank farm building exists, the building was treated as a fugitive source and the release height was reported as

Owner Name: FXI, Inc. ___________________ Facility Name: FXI - Auburn, IN 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 scurbbing 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 - Auburn, IN Facility

 Process Unit ID: ___________________________

11. Scrubber

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

_____ Yes _____ No

Submitted as CBI
Enclosure 2a

 Process Unit ID: VPF

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 temerature (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 - Auburn, IN 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 SOUTH

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

Submitted as CBI
Enclosure 2a

 Process Unit ID: VPF

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 temerature (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 - Auburn, IN 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 NORTH

Submitted as CBI
Enclosure 2a

 Process Unit ID: Tanks 3, 4, and 7 

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 temerature (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 - Auburn, IN Facility

12. Carbon Adsorber

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

 flexible polyurethane foam production process unit.

Submitted as CBI

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: Tank 14

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 temerature (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 - Auburn, IN Facility

12. Carbon Adsorber

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

 flexible polyurethane foam production process unit.

Submitted as CBI

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

Longitude Latitude

VPF Carbon Unit 1 North 

Stack VPF -85.065237° 41.348572° 28 31 97 0.9

VPF Carbon Unit 2 

South Stack VPF -85.065573° 41.347889° 28 137 89 1.2

EU-R1 Stack Process 28a -85.064693° 41.349533° not readily 

available 5 94 8.9

EU-R1 Stack Dryer 28b -85.064660° 41.349523° not readily 

available 47 105 1.0

EU-R2 Stack Process 29a -85.064678° 41.349573° not readily 

available 5 95 8.9

EU-R2 Stack Dryer 29b -85.064637° 41.349562° not readily 

available 261 95 1.0

EU-R3 Stack Process 35a -85.064658° 41.349615° not readily 

available 4 90 2.0

EU-R3 Stack Dryer 35b -85.064618° 41.349602° not readily 

available 77 103 1.0

EU-R4 Stack Process 36a -85.064631° 41.349665° not readily 

available 43 89 5.1

EU-R4 Stack Dryer 36b -85.064595° 41.349652° not readily 

available 5 94 1.0

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 - Auburn, IN Facility 

 Process Unit ID: VPF, EU-R1, EU-R2, EU-R3, EUR4

9. Stack Relase Parameters for Emission Points

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

Location of release point (decimal 

degrees, minimum 5 digits beyond 

Emission Point decimal) Process Unit 

ID
Height of 

release point 

(a)

Release Height (a) Angle of Rotation 

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

Fugitive 

Area Source 

Tank Farm 

Building 

Tank TA, 

Tank TB -85.064972° 41.349025° ≈ 11 ≈ 11 50 65 73

half the building height. 

Dimension of Source

Location of release point 

(decimal degrees, 

minimum 5 digits beyond 

decimal)

Emission 

Point

Process Unit 

ID

(a) Since no direct ventiliation of the tank farm building exists, the building was treated as a fugitive source and the release height was reported as

Owner Name: FXI, Inc. ___________________ Facility Name: FXI - Auburn, IN 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.
FXI, Inc.

FXI – Auburn, IN Facility 

2211 South Wayne Street

Auburn, IN 456706

APPENDIX B

EMISSION TEST REPORT