1 of 9 

### 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 9 

### 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 9 

### 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 9 

### 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 de cimal 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

______________________5 of 9 

### 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 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.gov6 of 9 

### 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: 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 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 – Auburn 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 the Indiana Department of Environmental Management (IDEM) Title V Operat ing Permit No. T033-27355-00047 and is subject to the followi ng emission standards: 326 IAC 2-7-5(1) – Emission Li mitations and Standards 326 IAC 6-3-2 – Particulate Emission Li mitations 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 CF R 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 Maintenance7 of 9 

### 326 IAC 20-22 Flexible Poly urethane Foam Production 40 CFR Part 63 Subpart A – National Em ission Standards for Hazardous Air Pollutants 40 CFR Part 63, Subpart III – National Em issions Standards for Hazardous Air Pollutants for Flexible Po lyurethane Foam Production f. Is the facility a major source or area source? Major sour ces 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 – Auburn Facility was a major source 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 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 ta nks 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 un its 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.8 of 9 

### 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-R49 of 9 

### 3. List Federal air pollution control regulat ions 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 ProductionEnclosure 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 manufactured (e.g., days, or hours) Process unit name

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/feedstockEnclosure 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 80/20Enclosure 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? NoEnclosure 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 unitEnclosure 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 made Process unit ID Year(s) upgrade was madeEnclosure 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: VPFEnclosure 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 0.0025Enclosure 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-036Enclosure 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, 2007Enclosure 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 CBIEnclosure 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 eachEnclosure 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 eachEnclosure 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 CBIEnclosure 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

decimal) Emission Point 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: ________________________________ 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 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 CBIEnclosure 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 ( 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 - 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 CBIEnclosure 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 ( 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 - 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 CBIEnclosure 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 ( 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 - 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 frequencyEnclosure 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 ( 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 - 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 frequencyEnclosure 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

decimal) Emission Point 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