United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-453/R-96-009a
September 1996
Air
Hazardous Air Pollutant
Emissions from the
t
Production of Flexible
Polyurethane Foam
Supplementary Information Document
for Proposed Standards
-------
HAZARDOUS AIR POLLUTANT
EMISSIONS FROM THE PRODUCTION
OF FLEXIBLE POLYURETHANE FOAM
Supplementary Information Document
for Proposed Standards
U.S. Environmental Protection Agency
5 Library (PL-12J)
Emission Standards Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
September 1996
-------
DISCLAIMER
This report has been reviewed by the Emission Standards
Division of the Office of Air Quality Planning and Standards,
EPA, and has been approved for publication. Mention of trade
names or commercial products is not intended to constitute
endorsement or recommendation for use.
-------
ENVIRONMENTAL PROTECTION AGENCY
Hazardous Air Pollutant Emissions from the Production of Flexible
Polyurethane Foam - Supplementary Information Document
for Proposed Standards
•«
1. The standards regulate hazardous air pollutant emissions
from the production of flexible polyurethane foam. Only
flexible polyurethane production facilities that are part of
major sources under Section 112(d) of the Clean Air Act
(Act) will be regulated.
2. For additional information contact:
Mr. David Svendsgaard
Organic Chemicals Group
U.S. Environmental Protection Agency (MD-13)
Research Triangle Park, NC 27711
Telephone: (919) 541-2380
3. Paper copies of this document may be obtained from:
U.S. Environmental Protection Agency Library (MD-36)
Research Triangle Park, NC 27711
Telephone: (919) 541-2777
National Technical Information Service (NTIS)
5285 Port Royal road
Springfield, VA 22161
Telephone: (703) 487-4650
ill
-------
OVERVIEW
This Supplementary Information Document (SID) contains
memoranda providing rationale and information used to develop the
Flexible Polyurethane Foam proposal package. These memoranda
were written by EC/R Incorporated under contract to the U.S.
Environmental Protection Agency (EPA). The data and information
contained in these memoranda were obtained through literature
searches, industry meetings, plant visits, and replies to section
114 letters sent to industry.
The memoranda included in this SID are referred to in the
Basis and Purpose Document and in the preamble to the proposed
rule. These memoranda were compiled into this single document to
allow interested parties more convenient access to this
information. The memoranda included herein are also available
from the docket (Docket A-95-48).
The memoranda included in this SID are listed below with
their document numbers.
Document No. Description
II-B-13 Williams, A. and Battye, W., EC/R Incorporated,
to Svendsgaard, D., U.S. Environmental
Protection Agency. June 17, 1996. Memorandum.
Flexible Polyurethane Foam Industry Description.
II-B-14 Williams, A., EC/R Incorporated, to Svendsgaard,
D., U.S. Environmental Protection Agency.
November 3, 1995. Memorandum. Flexible
Polyurethane Foam Molded Plants: New Count and
Nationwide Model Plant Representation.
-------
Document No. Description
II-B-15 Williams, A. and Norwood, P., EC/R Incorporated,
to Svendsgaard, D., U.S. Environmental
Protection Agency. June 17, 1996. Memorandum.
Subcategorization of the Flexible Polyurethane
Foam Source Category.
II-B-16 Williams, A., EC/R Incorporated, to Svendsgaard,
« D., U.S. Environmental Protection Agency. June
17, 1996. Memorandum. Flexible Polyurethane
Foam Model Plants.
II-B-17 Williams, A. and Norwood, P., EC/R Incorporated,
to Svendsgaard, D., U.S. Environmental
Protection Agency. June 17, 1996. Memorandum.
Baseline Emissions for the Flexible Polyurethane
Foam Production Industry.
II-B-18 Williams, A. and Norwood, P., EC/R Incorporated,
to Svendsgaard, D., U.S. Environmental
Protection Agency. June 17, 1996. Memorandum.
MACT Floors for Flexible Polyurethane Foam
Production.
II-B-19 Williams, A. and Norwood, P., EC/R Incoporated,
to Svendsgaard, D., U.S. Environmental
Protection Agency. June 17, 1996. Memorandum.
Regulatory Alternatives for New and Existing
Sources in the Flexible Polyurethane Foam Source
Category.
II-B-20 Norwood, P. and Williams, A., EC/R Incoporated,
to Svendsgaard, D., U.S. Environmental
Protection Agency. June 17, 1996. Memorandum.
Estimated Regulatory Alternative Impacts for
Flexible Polyurethane Foam Production.
II-B-6 Norwood, P., EC/R Incorporated, to Svendsgaard,
D., U.S. Environmental Protection Agency.
September 24, 1996. Development of Equation to
Calculate Auxiliary Blowing Agent Formulation
Limitation.
-------
ffj /J> InCOTDOTCltCd — : Environmental Consulting and Research
MEMORANDUM
Date: June 17, 1996
Subject: Flexible Polyurethane Foam Industry .Description
From: Amanda Williams, EC/R Incorporated
William Battye, EC/R Incorporated
To: David Svendsgaard, EPA/OAQPS/ESD/OCG
The purpose of this memorandum is to present a description
•of the flexible polyurethane foam industry. The information in
this memorandum was compiled from several sources including
Information Collection Requests (ICRs), trip reports, other
project efforts, and from several other sources. This memorandum
is arranged in several sections. The first section presents a
general description of the industry, including facility location
and other general statistics. The next section describes the
.foam chemistry, foam characteristics, and foam applications. The
third section describes the slabstock foam production process,
including rebond and fabrication processes,, followed'by sections
that describe where hazardous air pollutant. (HAP} emissions occur
in the slabstock process, and control technologies for these
emissions. .The next three sections present the same information
for the molded foam process, from'production process to emission
control. •
INDUSTRY DESCRIPTION
The flexible polyurethane foam source category is contained
in the initial .list of source categories for NESHAP under the
amended Clean Air Act of 1990. In the Environmental Protection
Agency's (EPA).initial source category listing,1 the source
category is defined as follows:
"The Flexible Polyurethane Foam Production Source category
includes any facility which manufactures foam made from a
. polymer containing a plurality of carbamate linkages in the
chain backbone (polyurethane)." .
Three types of polyurethane foam facilities appear to fit in this
category description: slabstock flexible polyurethane foam (i.e.,
Documentation for Developing the Initial Source Category
List. U.S. Environmental Protection Agency. Research Triangle
Park, NC. Publication No. EPA-450-3-91-030. July 1992.
3721-D University Drive • Durham, North Carolina 27707
Telephone: (919) 493-6099 • Fax: (919) 493-6393
-------
slabstock foam), molded flexible polyurethane foam (i.e., molded
foam), and rebond foam. Slabstock foam is produced in large
continuous buns that are then cut into the desired size and shape
(fabricated) . Slabstock foam is used in furniture, bedding,
packaging, and carpet cushioning. Molded foam is produced by
"shooting" the foam mixture into a mold of the desired shape and
size. The major use of molded foam, by weight, is in automobile
interiors, but is used in many other applications such as
packaging, novelty applications, and medical supplies. Rebond
foam is made from scrap foam that is converted into a material
primarily used for carpet underlay.
The foam chemistry of the slabstock and molded segments of
the industry is analogous; however, the equipment, production
processes, emission sources, and control techniques are very
different. The rebond foam segment differs from both other
segments in these areas, as well as in the chemistry.
Slabstock Foam Facility Distribution and Description
The EPA estimates that there are 78 slabstock foam
facilities in the United States. Table 1 shows the distribution
of foam facilities by state, and a complete list of slabstock
facilities and their location are included as Attachment 1. Data
were received from all 78 facilities through the distribution of
an Information Collection Request (ICR) by the EPA.2 The total
reported 1992 foam production for these 78 slabstock facilities
was approximately 560,000 tons. Three companies were responsible
for over half of the production by weight. The annual production
rate for individual facilities ranged from under 500 tons, to
over 20,000 tons, with an industry average of approximately 7,500
tons.
In terms of corporate ownership and industry concentration,
the slabstock foam industry is divided into two main segments.
There are 10 companies that own or operate multiple plants. The
three largest companies account for over half of the industry's
foam production, and the seven largest companies account for
80 percent of the production. At the other end of the spectrum,
there are 13 single-plant companies, and two companies operating
only two plants each. Together, these small companies account
for less that 10 percent of the industry's production.
Since slabstock foam is produced in large "buns," which must
be cut into the desired sizes and shapes, fabrication operations
are sometimes co-located with slabstock foam production
facilities. In the ICR responses, of the 78 plants reporting
2 Memorandum. Norwood, P., Williams, A., and Battye, W.,
EC/R Incorporated to Svendsgaard, D., U.S. Environmental
Protection Agency. Summary of Flexible Polyurethane Foam
Information Collection Requests. January 24, 1994.
-------
TABLE 1. DISTRIBUTION OF SLABSTOCK FOAM
FACILITIES BY STATE
State
Arkansas
California
Delaware «
Florida
Georgia
Illinois
Indiana
Iowa
Kansas
Kentucky
Maryland
Massachusetts
Michigan
Mississippi
Minnesota
New Jersey
New Mexico
North Carolina
Ohio
Oregon
Pennsylvania
Tennessee
Texas
Virginia
Washington
Wisconsin
Total
Number of Facilities
2
8
1
5
4
3
8
1
1
1
1
1
2
8
1
2
1
9
2
1
4
5
5
1
1
1
78
-------
slabstock production, 69 indicated that they have fabrication
operations on-site. The total amount of foam fabricated at the
facilities was approximately 233,000 tons in 1992. This
indicates that only about 48 percent of the total foam produced
is fabricated by on-site fabrication operations.
Also, rebond foam production operations, which use foam
scraps as the primary starting material to produce the foam
product, are sometimes co-located with slabstock foam production
facilities. A^total of 21 facilities indicated that they produce
rebond foam on-site, with a total production of 182,520 tons per
year.2
Molded Foam Facility Distribution and Description
The EPA estimates that there are 228 molded foam production
facilities in the United States.3 The EPA used several sources
to obtain this estimate. First, ICR responses were received from
46 molded foam facilities. Using the "Polyurethane Industry
Directory and Buyer's Guide - 1994",4 an additional 182 flexible
molded foam companies were identified based on company
descriptions. Table 2 presents the distribution of these 228
molded foam facilities by state. ICR responses were received
from 46 facilities that manufacture molded flexible polyurethane
foam. These 46 facilities are owned by 34 companies, and in 1992
they produced just over 99,000 tons of foam. The individual
facility production ranged from 1 to 10,000 tons. The majority
of this foam, by weight, was manufactured by two companies.
Companies producing molded foam tend to be either medium-to-large
(over 1500 employees), or much smaller (less than 100 employees).
In fact, in 1992, 42 percent of plants produced less than 500
tons per year each.2
Rebond Foam Facility Distribution
The EPA estimates that there are 52 rebond foam facilities
in the United States.5 Of these rebond facilities, 21 are
located at plant sites that also produce slabstock flexible
polyurethane foam. Data were obtained from the ICR responses for
these rebond operations.
3 Memorandum. Williams, A., EC/R Incorporated, to
Svendsgaard, D., U.S. Environmental Protection Agency. Flexible
Polyurethane Foam Molded Plants: New Count and Nationwide Model
Plant Representation. November 3, 1995.
4 The Polyurethane Industry Directory and Buyer's Guide -
1994. Larson Publishing. Saco, Maine.
5 Telecon. Norwood, P., EC/R Incorporated, with Oler, B.,
Carpet Cushion Council. May 30, 1996. U.S. Population of Rebond
Foam Production Facilities.
-------
TABLE 2. DISTRIBUTION OF MOLDED FOAM
FACILITIES BY STATE
State
Alabama
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Illinois
Indiana
Iowa
Kansas
Kentucky
Maine
Maryland
Massachusetts
Michigan
Minnesota
Number of
Facilities
3
1
1
19
6
8
2
1
4
11
7
5
3
3
1
5
4
29
7
State
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New York
North
Carolina
Ohio
Oregon
Pennsy 1 vani a
Rhode Island
South
Carolina
Tennessee
Virginia
Washington
West Virginia
Wisconsin
TOTAL
Number of
Facilities
1
7
1
1
2
2
11
9
5
23
2
14
1
2
5
4
4
1
8
228
-------
FOAM CHEMISTRY, CHARACTERISTICS, AND APPLICATIONS
This section describes the chemistry involved in producing
flexible polyurethane foam, the foam characteristics used to
describe the final foam product by the industry, and some of the
many applications for the foam product.
Chemistry of Flexible Polyurethane Foam: Slabstock and Molded
Flexible polyurethane foam is produced by mixing three major
ingredients: a polyol polymer, an isocyanate, and water. The
polyol is either a polyether or polyester polymer with hydroxyl
end groups. Other ingredients are often added to modify the
polymer, and catalysts are used to balance the principal foam
production reactions. The amount of each ingredient used in a
foam formulation varies, depending on the grade of foam desired.
Foam formulations are generally denoted in terms of the number of
parts (by weight) of diisocyanate and water used, per 100 parts
polyol.
A polyol is an organic polymer characterized by more than
one terminal hydroxyl ("-ol") group. In flexible foams, the
most commonly used polyols are trifunctional, with three terminal
hydroxyl groups. Both polyether and polyester polyols are used
in the production of flexible foams, but polyether polyols are
the most common. These are produced by the polymerization of
ethylene oxide and propylene oxide, starting with glycerine. The
molecular weight of polyols used in foam production ranges from
about 3000 to about 6000.
The second key ingredient in the foam formulation, the
diisocyanate, links polyol molecules to produce the foam polymer.
The diisocyanates used in flexible foam production are primarily
toluene diisocyanate (TDI) and methylene diphenyl diisocyanate
(MDI). Typically, TDI used in foam manufacture is a mixture of
the 2,4- and 2,6- isomers, with the ratio being 80 percent 2,4-
and 20 percent 2,6-. TDI is used primarily in slabstock
production and MDI is used primarily in molded foam production.
However, neither slabstock producers nor molded foam producers
use one isocyanide to the exclusion of the other.
Surfactants and catalysts are also added to the mixture.
The surfactants aid in mixing incompatible components of the
reaction mixture, and also help control the size of the foam
cells by stabilizing the forming gas bubbles. Amine catalysts
balance the isocyanate/water and isocyanate/polyol reactions, and
assist in driving the polymerization reaction to completion. Tin
catalysts control foam gelling by assisting in driving
polymerization to completion, which provides an optimal cure in a
reasonable period.
Both the polyol and the diisocyanate are liquids at room
conditions prior to the foam-producing reaction. These are mixed
-------
with water under carefully controlled conditions. When the
polyol, diisocyanate, and water are mixed, two main
polymerization reactions occur. Most importantly, isocyanate
groups react with hydroxyl groups on the polyol to produce
urethane linkages (hence the term polyurethane). This reaction
is generally promoted using a catalyst. The rate of
polymerization is dependent on the structure of the polyol and
the amount of catalyst used. Polyols with primary hydroxyl end-
groups are much more reactive than polyols with secondary
hydroxyl groups, although the most common polyols have secondary
groups.
The other main reaction is that of the isocyanate and water.
The initial product of the reaction with water is a substituted
carbamic acid, which breaks down into an araine and carbon
dioxide. The amine then reacts with another isocyanate to yield
a substituted urea linkage. The CO2 formed in this reaction acts
as the "blowing agent." This reaction is extremely exothermic,
and causes the temperature of the foam to rise to around 250 -
350°F. The reaction is also much faster than the polyurethane
reaction discussed above. Thus, the polyurethane-forming
reaction actually uses isocyanate that remains after most of the
water is consumed.
The CO2 generated in the isocyanate/water reaction acts as
the "blowing agent" (blowing agents will be discussed in more
detail later in this section) and produces bubbles, causing the
foam to expand to its full volume within minutes after the
ingredients are mixed and poured. The bubbles formed come into
close contact and a network of cells is formed separated by thin
membranes. Reaction rates must be balanced so that the polymer
is strong enough at this point to maintain its shape without
collapsing. At full foam rise, the cell membranes are stretched
to their limits and rupture, releasing the blowing agent and
leaving open cells supported by polymer "struts."
At the time that the cells open the polymer strength is low,
with a significant proportion of the isocyanate groups remaining
unreacted. The temperature continues to rise after the foam has
fully expanded because of the continuing reaction. The maximum
temperature is usually reached between 30 minutes and 1 hour
after pouring. The temperature of the foam can remain at this
temperature for up to 8 hours due to the insulating properties of
the foam. After this period, terminal isocyanate groups from the
polymer chains continue to react to form cross-links with amine
hydrogens in the mid-section of the chains. This reaction can
persist for up to 48 hours. These secondary reactions involve
the hydrogen atoms of the urethane and urea linkages to form
allophanate and biuret linkages, respectively. These cross-link
reactions are part of the foam curing process, and affect the
strength and elasticity of the foam polymer. Therefore, the
amount of isocyanate relative to other ingredients in the
-------
8
formulation is an important parameter in determining foam
properties.
The relative amount of isocyanate is specified by the
isocyanate "index." This index is defined as the ratio,
expressed in percent, of the number of moles of isocyanate groups
to the number of moles of other chemical groups that will react
with isocyanate. An index of 105 refers to a 5 percent excess of
isocyanate, while an index on 95 refers to a 5 percent shortfall
of isocyanate.. An isocyanate index of 100 refers to balanced
stoichiometry.
The final polymer is composed of the urethane and urea
cross-linkages formed in the isocyanate/polyol and
isocyanate/water reactions. The polyol-to-isocyanate urethane
linkages provide strength, and the isocyanate-to-isocyanate urea
linkages give the foam its firmness.6
Auxiliary Blowing Agents
As noted in the previous section, one result of the
isocyanate-water reaction is the liberation of CO2 gas. The
blowing action of this C02 is termed "water-blowing, " because the
C02 blowing agent is produced from the isocyanate-water reaction.
Many grades of foam can be produced using only this CO2 gas as a
blowing agent.
Increasing the amount of water in a formulation generally
produces a lower-density foam, because additional C02 blowing
agent is produced. However, there is a practical limit to the
amount of water that can be used. First, an increase in the
water level results in an increase in the number of urea linkages
in the final polymer. These linkages tend to make the polymer
stiffer because they undergo hydrogen bonding. Second, the
isocyanate-water reaction is extremely exothermic. An excessive
level of water can cause high temperatures that can scorch the
foam, or even cause the foam to ignite.
As a result, some grades of foam require the use of an
auxiliary blowing agent (ABA) . The ABA is mixed with the foam
reactants as a liquid when the reactant mixture is first poured.
As the exothermic polymerization reactions raise the temperature
of the polymer mass, the ABA vaporizes, supplementing the blowing
action of CO2 from the water-isocyanate reaction. The
vaporization of the ABA also serves to remove excess heat from
the foam, reducing the potential for scorching or auto-ignition.
Auxiliary blowing agents (ABAs) are more widely used in the
production of slabstock foams than in the production of molded
6 Woods, George. The JCJ Polyurethanes Book. ICI
Polyurethanes and John Wiley & Sons. 1987.
-------
foams. The amount of ABA required depends on the grade of foam
being produced and the ABA used. ABAs are most important for low
density and soft foams. In these grades, water-blowing alone
would cause problems with either overheating or with increased
foam stiffness. For low-density foams, ABAs are used in
conjunction with water-blowing to avoid overheating. In the case
of soft foams, ABAs provide blowing action without increasing the
foam's stiffness.
Previously, the principal ABA used was chlorofluorocarbon 11
(CFC-11). However, since this compound has been shown to deplete
the earth's ozone layer, U.S. producers have almost completely
phased out its use. Methylene chloride, a listed HAP, has
replaced CFC-11 as the principal ABA. Since the role of the
methylene chloride is simply to volatilize and expand the foam,
it does not directly participate in the polyurethane reaction.
Therefore, all of the methylene chloride that is added eventually
is emitted.6
Foam Grades and Applications
Flexible polyurethane foam is produced in a wide range of
grades. Foam grades are almost always identified by two
parameters: density, and firmness. Foam densities range from
less than 1 pound per cubic foot to more than 3 pounds per cubic
foot. Higher density foams are typically more durable than lower
density foams, because they contain more mass of polymer per unit
volume. However, the higher density foams require more raw
materials, and hence have higher production costs.
The firmness of a foam determines its load bearing ability.
This parameter is also related to the foam's softness. Softer
foams will necessarily have a low degree of firmness. The most
common measure of firmness is the "indentation force deflection"
(IFD) . This is the force required for a 50 square inch disk to
cause a certain percentage of indentation in a foam block. IFD
is expressed in pounds, and is measured at different percentages
of indentation. The most common IFD measurement is at 25 percent
indentation. Foam IFD can range from 20 pounds to over 100
pounds (both at 25 percent).
Different grades of foam have different primary
applications; however, there is no strict relationship between
the grade and the application. For instance, the density of foam
used for seat cushioning can range from 1 pound per cubic foot to
3 pounds per cubic foot, depending on quality and other
specifications. In general, lower density and softer foams are
used for seat backs and arm rests. Low density, stiff foams are
well suited for packaging. Foams with moderate density and load
bearing capacity are used for seat cushions and bedding. Higher
density foams are generally used for carpet packing, and other
heavy-duty applications.6
-------
10
In addition to the density and IFD grades, polyurethane foam
grades are specified based on additives that are used to achieve
specific properties. Some additives are inert materials that
become incorporated in the foam polymer matrix. Others are
actually incorporated into the polyurethane polymer chains, or
increase cross-linking between polymer chains. The most
important of these additives are flame retardants. Flame
retardants operate by a number of different mechanisms. Some
simply provide a heat sink. Others give off incombustible gases
when heated, asd others actually modify the mechanism of
combustion of the foam.
Foam Characteristics and Quality Measurements
A number of other physical properties besides density and
IFD are measured as indicators of foam quality. These include
hysteresis, dynamic fatigue, air flow, tensile strength,
elongation, tear strength, and resilience. Hysteresis is a
measure of the foam's durability and is determined by the
percentage of the original 25 percent IFD retained after
measurement of the 65 percent IFD. Dynamic fatigue is another
foam durability measurement. It is measured as the loss in IFD
after the sample has been flexed numerous times. Air flow is a
measure of the breathability of the foam, and is measured as the
rate of pressurized air flow through a foam sample. Tensile
strength is a foam's resistance to tearing and shredding, and is
measured as the force (pounds) required to break a 0.25 square
inch segment of foam. Elongation is defined as a foam's
resistance to tearing and shredding, and is measured as the
percent extension of a one-inch segment of foam at rupture. Tear
strength is another measure of a foam's resistance to tearing
and shredding, and is defined as the force required to tear a
one-inch length of foam. Resilience is a measure of a foam's
surface elasticity or "springiness", and is measured by
calculating the percent of the original height a steel ball
bounces when dropped on a foam sample. Resilience is also often
determined by the compression set performance of the foam, which
is the ability of a foam to return to its original shape after
being compressed.
SLABSTOCK FOAM PRODUCTION
Process Description
Flexible slabstock foam is produced as a large continuous
"bun" that is later cut into sections with the desired
dimensions. There are variations in the design of the machines
that produce the foam, they may be horizontal or vertical, with
the horizontal foam line being the most common. There are
several types of horizontal foam machines found in foam
facilities. The most common system is called Maxfoam,
illustrated in Figure 1, which is described in the next section.
Following the description of the Maxfoam line will be a
-------
11
description of the Vertifoam process, a vertical foam production
process (Figure 2). A slabstock foam facility may have more than
one foam line, however, for the remaining discussions it will be
assumed that there is only one foam line. Rebond and foam
fabrication will also be discussed in this section.
Horizontal Maxfoam Production6'7
From bulk chemical storage, raw ingredients are moved to
smaller feed tanks. The temperature of the feed materials,
particularly the TDI, is very important. The chemicals are
pumped from the feed tanks to the mixing head of the foam line
where they are vigorously mixed. The amount of each chemical
sent to the mixing head is carefully controlled by metering
pumps. The mixture is discharged through a mixing head into a
trough where the reactions begin to occur (i.e., "creaming").
From this trough, the froth flows onto the foam tunnel. The
mixture quickly spreads evenly across the width of the tunnel,
which is typically around 82 inches.
The bottom of the tunnel consists of a series of five
adjustable fall-plates that are covered by paper. The foam
reaches its maximum height, or "full rise" about 25 feet from the
nozzle. The full rise time is dependent on the grade of foam,
with lower density foams rising highest and at the fastest rate.
Instead of "rising," the foam actually expands downward along the
slope of the fall plates. The slope of the tunnel can be altered
to allow for the changing reaction rates of different foam
grades. The downward slope helps flatten the top of the bun by
cutting down on side-wall drag. Flat-top buns are desirable to
eliminate waste foam. The sides of the foam tunnel are vertical
conveyors, covered with plastic as they move the foam down the
tunnel. The fall plats are stationary, and it is the moving side
plastic and the bottom paper that move the foam to the belt
conveyor portion.
The belt conveyor carrying the foam block moves at an
average speed of 15 to 20 feet per minute. Additional time on
the conveyor after full rise is required to allow the
polymerization reactions to be completed so the foam will
solidify. The side papers are then removed from the bun, and the
bun is sawed into the desired lengths. After sawing, the end of
the bun is marked with the foam grade, and the bun moves off the
belt conveyor onto a roller-type conveyor moving at a higher rate
of speed. This conveyor continues through the wall of the
pouring area, through the foam storage area, and then into the
7 Memorandum. Norwood, P. and Williams, A., EC/R
Incorporated, to Svendsgaard, D., U.S. Environmental Protection
Agency. Site Visit Report of Hickory Springs Manufacturing's
Conover, NC facility on May 25, 1993. June 18, 1993.
-------
12
foam curing area. In the curing area, the buns are removed from
the conveyor with overhead cranes and placed on the floor.
Typically, buns are cured 12 to 24 hours before being moved
from the curing area to foam storage. To move a bun to the
storage area, the overhead crane lifts it from the floor and
carries it to another conveyor system, which takes it back to the
storage area. In the storage area, buns are piled 4 or 5 high.
The buns remain in the storage area until ready for fabrication
or shipping. ,
Vertifoam Production Process Description6'8
In the Vertifoam process, the foam reaction mixture is
introduced at the bottom of a completely enclosed chamber. This
chamber is lined with paper or plastic, which is drawn upwards at
a controlled rate. The rate is dependent on the pressure in the
chamber, the foam formulation, and the rate of production. With
a controlled rate of upward pull, the rheology of the foam
reaction process, combined with the effect of gravity, ensures a
stable foaming front, and prevents the mixing of the still liquid
reacting mixture with the partially gelling foam poured a few
seconds earlier.
Foam Fabrication Process
As mentioned earlier, slabstock flexible polyurethane foam
is produced in large buns which are typically 4 feet tall, 8 feet
wide, and 50 to 100 feet long. Prior to being delivered to the
furniture manufacturer or other end-user, the large buns are
"fabricated" according to the end-use. The simplest type of
fabrication is to cut the foam into the desired shape by use of
specialized saws, by hand-cutting, or other techniques. However,
many customers desire foam products that are more "finished" or
complex. To produce such products generally requires the gluing
of foam-to-foam, or foam to some other material such as cotton
batting. 'The most commonly used adhesives are methyl chloroform
based (a HAP). Since methyl chloroform has also been identified
as an ozone depleting substance, fabricators have been searching
for alternative adhesives. It appears that the most popular
replacement has been MeCl2-based adhesives.
Fabrication operations are sometimes co-located with foam
production operations (i.e. on-site). Information from the ICR's
revealed that approximately 40 percent of the foam produced is
fabricated on-site.2
8 Memorandum. Williams, A., EC/R Incorporated to
Svendsgaard, D., U.S. Environmental Protection Agency. Site
Visit Report of Grain Industries' San Leandro, CA facility on
August 26, 1993.
-------
13
Slabstock HAP Emission Sources
This section will discuss the HAP emission points for
slabstock foam production and fabrication. The four main sources
of HAP emissions are: storage and transfer of raw materials,
leaking components in HAP service, the foam tunnel and curing
area, and equipment cleaning. In addition, HAP emissions also
occur in the fabrication area due to the use of HAP-based
adhesives.
«
Storage and Transfer
Raw HAP chemicals are received at foam facilities by
railcar, tank truck, and in drums. Emissions can occur during
the unloading of the HAP from the railcar or tank truck. There
can also be small amounts of HAP emitted from the storage tank
due to diurnal temperature or pressure changes. However, since
many foam facilities have storage vessels located in temperature
controlled environments, these "breathing loss" emissions are
uncommon.
Components in HAP Service
There can be small amounts of HAP releases from leaking
components in HAP service. Some examples of components in HAP
service that may leak are pumps, valves, flanges, or connectors.
Foam Tunnel and Curing (ABA Usage)
As mentioned earlier, MeCl2 is the principal auxiliary
blowing agent used, and its role is simply to volatilize and
expand the foam, not directly participate in the polyurethane
reaction. Therefore, all of the methylene chloride that is added
eventually is emitted. The use of MeCl2 as an ABA was the
largest emission source of HAP's reported in the ICRs.2 Industry
representatives state that approximately 40 percent of the
methylene chloride emissions occur before the cutoff saw and
another 20 percent are released during foam transfer. The
remaining 40 percent is emitted in the curing area.9
Equipment Cleaning
Methylene chloride is used as a cleaner to rinse and/or soak
foam machine parts such as mixheads and foam troughs at the end
of a pour. There is hardened foam residues on the trough, fall
plates, and other equipment that must be removed.
9 Flexible Polyurethane Foam (Slabstock) Assessment of
Manufacturing Emission Issues and Control Technology.
Polyurethane Foam Association. May 17, 1993.
-------
14
Fabrication
The HAP emissions in fabrication operations occur due to the
use of HAP-based spray adhesives to glue fabric-to-foam, or foam-
to-foam. As mentioned earlier, in the slabstock industry, only
about 40 percent of the fabrication is done "in-house", and not
all fabrication involves gluing. Fabrication covers the broad
range of die cut parts, cut parts, as well as glued parts.
Normally these adhesives are approximately 20 to 40 percent
solids, while tjie remainder consists of a solvent carrier, such
as methyl chloroform or MeCl2.
Control Technologies for Slabstock HAP Emissions
The EPA reviewed information from the ICR responses that
were received from flexible polyurethane foam producers, as well
as the information contained in other pertinent project files, to
identify potential HAP emission reduction and control
technologies. This section discusses HAP emission reduction
technologies for the slabstock industry. The EPA created a
report entitled "Flexible Polyurethane Foam Emission Reduction
Technologies Cost Analysis".1" (This report will hereafter be
referred to as the Cost Report.) The intent of this report was
to examine some proven emission reduction technologies for this
industry, and some of the costs associated with the installation,
and use, of these technologies. The reader is referred to this
document for information on cost and emission reduction
potential, as well as additional process and operational
information, for each technology.
Control Technologies for ABA Emissions
There were several alternatives identified to either reduce
or eliminate the use of MeCl2 as an ABA in the manufacture of
flexible slabstock polyurethane foam. The technologies
identified were acetone or liquid CO2 as an ABA, foaming in a
controlled environment, forced cooling, chemical modifications,
and carbon adsorption. These alternatives are .discussed in the
following paragraphs.
Acetone as an ABA.7 In response to environmental concerns
over the use of methylene chloride, Hickory Springs developed and
patented a technology to allow the use of acetone as an ABA.
Acetone is not a HAP, and has recently been delisted as a
volatile organic compound, or VOC (60 FR 31633). One of
acetone's biggest advantages is that it only requires 55 percent
(by weight) as much acetone as MeCl2 for the same amount of foam.
The use of acetone requires certain equipment modifications
10 Flexible Polyurethane Foam Emission Reduction
Technologies Cost Analysis. EPA-453/R-95-011. U.S.
Environmental Protection Agency. September 1996.
-------
15
because of the high flammability of acetone, but does not require
significant changes in the manner in which the process is
operated.
Liquid C02 as an ABA. Several companies have developed
processes for using liquid C02 as the ABA in slabstock foam
manufacture. One of these systems, called CarDio™, has been
developed by the Cannon Group, and is patented worldwide,
available under license by Foaming Technologies Cardio B.V.
Other companies that have developed liquid C02 systems are
Hennecke Machinery and the Beamech Group. There are several full
scale units reported to be in operation in the United States.
The CarDio™ system operates by adding liquid CO2 to the
polyol stream before the polyol stream is injected into the
mixing head. This generates a rapidly expanding froth
immediately after the pouring nozzle. Cannon developed a special
laydown device to counteract this rapid expansion. This device
controls the expansion phase immediately after the mixing head,
and allows for the depositing of a homogenous pre-expanding and
reacting mixture over the entire section of the fall-plate. The
laydown device's special design allows for a progressive release
of blowing agent in the reacting mass, avoiding local
concentrations of free gas that can cause pinholes or "chimneys"
in the foam.11
The use of this technology requires additional equipment and
modifications to existing equipment, and it cannot be used to
produce all grades of foam. Therefore, it is not an acceptable
direct replacement for HAP ABA. However, it can provide a
significant emission reduction of HAP ABA.
Foaming in a Controlled Environment - Variable Pressure
Foaming (VPF) and Controlled Environment Foaming (CEF). Foam
expands more under conditions of decreased atmospheric pressure,
meaning that many types of foam can be manufactured at higher
altitudes with little or no ABA. In other words, when a given
foam formulation is processed at less than atmospheric pressure
(i.e., under vacuum), a lower density and a softer foam will
result when compared to the same foam formulation being processed
at atmospheric pressure. This principle can be applied under
standard atmospheric conditions through enclosure of the foam
line, and subsequent reduction of pressure during foam
production. Two systems that control the atmospheric conditions
during foam production were identified: variable pressure foaming
and controlled environment foaming. Descriptions of these
systems follow below.
11 Florentine, C., T. Griffiths, M. Taverna, and B.
Collins. Auxiliary Blowing Agent Substitution in Slabstock
Foams.
-------
16
The VPF system is patented by Foamex Worldwide. The system
involves processing foam in an enclosed chamber under a
controlled pressure. The pressure in the chamber is fixed before
foaming, and remains constant during the foaming operation.
After the bun is cut, it is then passed into a second airlock
chamber, which is at the same pressure as the foaming chamber.
This chamber is then opened to the atmosphere, and the bun is
removed and transported to a storage rack. During this time,
foam production is continuing in the first chamber. In the
United States, «Foamex has one VPF facility in full-scale
operation, and a few others are being installed.12'13
FOAM ONE company has developed and patented a polyurethane
foam manufacturing process, which is called CEF.14 The CEF
process is a discrete block production method which uses a
containment vessel to control the pressure and temperature during
foaming. During production, foam is poured into a mold inside
the containment vessel. The foam reaction is allowed to take
place under the controlled conditions of the containment vessel.
In addition to the complete elimination of ABA, there are
other advantages of the CEF system. Since the blocks are
prepared in heated molds, the finished block has a perfectly flat
top and a very thin skin, thus maximizing foam yield. The
process is under complete computer control, ensuring exact
duplication of products. In addition, TDI emissions from the
foaming reaction are vented through a carbon bed, thus
practically eliminating TDI emissions. While there are low
energy requirements and low maintenance expenses, the production
rate is considerably slower than a traditional Maxfoam line.
Therefore, it would take longer to make the same amount of foam
on a CEF machine.
Forced-Cooling: Enviro-Cure®. Two of the primary functions
of an ABA are to reduce the density of the foam and to provide
cooling effects. Increasing the amount of water in the
formulation will reduce the foam density, but increases the
exotherm of the reaction, which can lead to bun scorching or even
auto-ignition. The cooling of the bun by mechanical means can
12 Spellmon, L, Foamex, to Jordan, B., U.S. Environmental
Protection Agency. Letter discussing Variable Pressure Foaming
(VPF). October 25, 1993.
13 Hay, R, Foamex International Inc., to Williams, A., EC/R
Incorporated. Letter transmitting comments on the May 1995
preliminary draft of the "Flexible Polyurethane Foam Emission
Reduction Technologies Cost Analysis." June 1, 1995.
14 Carson, S. Controlled Environment Foaming:
Manufacturing a New Generation of Polyurethane Foam. Prepared
for FOAM ONE.
-------
17
eliminate this potentially dangerous situation, while allowing
the production of low density foams.
The EPA obtained and reviewed information on two different
patented types of forced-cooling techniques that are in full-
scale operation, Enviro-Cure® by Grain Industries, and Rapid-
Cure® by General Foam. The EPA is also aware of other companies
experimenting with similar forced cooling processes. Since the
Enviro-Cure® technology is fully operational at several
facilities acrbss the United States, the following discussion
focuses on this system.
Most of the Enviro-Cure® systems in operation in the United
States are installed on Vertifoam® lines, which is a type of foam
line used only by Grain in the United States at this time. Grain
has also retrofit a traditional Maxfoam system with Enviro-Cure®.
This type of retrofit is described in the following paragraphs,
but the general Enviro-Cure® principle for a Vertifoam® system is
the same.
The Maxfoam Enviro-Cure system is an enclosure with an
associated conveyor system, which is put in place after the
traditional slabstock pouring line. The cut blocks from the
Maxfoam machine are transferred to the Enviro-cure unit, where
the block is transported through the cooling enclosure. Once the
blocks are inside the enclosure, controlled air is passed through
the block by means of a vacuum process, which cools the block by
convection and conduction. In addition to the
elimination/reduction of ABA, forced cooling produces a more
uniform bun. That is, the properties are more consistent between
the outer portion of the bun and the core.
Chemical Modifications. Chemical modifications are
demonstrated methods of reducing ABA usage. The types of
chemical modifications included in this analysis can be separated
into two groups: chemical additives, and alternative or "soft"
polyols. Additives are usually added to the foam formulation at
the mixhead. The alternative polyols are substituted for a
portion of the traditional polyols in the foam formulations.
Chemical additives and alternative polyols have proven to be
successful in the reduction of ABA used for foam softening.
There are two basic methods by which these technologies soften
the foam. The most common method is by reducing the TDI index,
which reduces the number of isocyanate groups available to form
urea linkages. One of the additives studied softens foam by
changing the reactivity of the isocyanate groups of the TDI
isomers so that the resulting polyurea segments of the foam are
altered.
These chemical modification technologies can allow the
elimination of ABA for foams with densities greater than
1.0 lb/ft3 and Indentation Force Deflections (IFDs) greater than
-------
18
20 Ibs, although there will likely be a-deterioration in foam
properties at densities less than 1.5 Ibs and IFDs lower than
around 25 Ibs. However, the use of these chemical alternatives
for the lower density/lower IFD foams does allow a reduction in
the amount of ABA needed, without sacrificing foam property
quality. The actual amount of reduction will vary with the
combination of density, IFD, and other desired foam properties,
but can be as high as 70 percent.
These technologies have not been as successful in the area
of density reduction. Unlike methylene chloride, they do not
directly decrease the density by auxiliary "blowing" of the foam.
They also do not provide the necessary cooling effects to allow
increased water levels. However, as noted above in the section
on forced cooling, the combination of forced cooling and chemical
modification can allow further reduction in the ABA usage for
density reduction.
An advantage of chemical modifications is that their use
does not change the production method for slabstock foam.
Capital improvements may be necessary, including a new storage
tank and associated plumbing, and new pump(s) and a metering
system.
Carbon Adsorption. The recovery of HAP ABA is also an
option to reduce emissions. However, the traditional layout of a
slabstock production line is not conducive to a recovery system,
particularly the recovery area. The large volumes of air in the
curing area, which is typically a large open warehouse, and the
low concentrations, make the design of a recovery device
impractical. However, the installation of unconventional curing
enclosures to allow higher concentrations and lower flow rate
could allow the use of carbon adsorption. One facility in the
United States has installed and is successfully operating a
carbon adsorption recovery system on a full-scale slab;stock foam
production operation.15
Control Technologies for Chemical Storage and Handling Emissions
There were two methods identified for reducing HAP emissions
from this source, carbon canisters and a. vapor balance system.
Carbon canisters control emissions by routing the vapors that
were displaced from the vapor space of the tank during filling
through activated carbon prior to being released to the
atmosphere.
15 Memorandum. Williams, A. and Norwood, P., EC/R
Incorporated, to Svendsgaard, D., U.S. Environmental Protection
Agency. Summary of April 26, 1995 Telephone Conference between
Ohio Decorative Products and the EPA. May 31, 1996.
-------
19
Vapor balancing is the other method identified. When a
storage tank is filled, the vapors forced out by the incoming
liquid and are routed through piping back to the railcar or tank
truck.
Control Technologies for Leaking Components in HAP Service
Two methods for controlling leaks from components in HAP
service were identified, canned pumps and a leak detection and
repair (LDAR) programs. Canned pumps are a type of sealless pump
than can be used to replace traditional pumps except for high
pressure metering pumps. LDAR programs have set methods and
timetables for monitoring for equipment leaks, and certain
procedures for fixing any problems found.
Control Technologies for Equipment Cleaning Emissions
Methylene chloride is used as a cleaner to rinse and/or soak
foam machine parts such as mixheads and foam troughs. The two
alternatives to eliminate these HAP emissions identified were
steam cleaning and non-HAP cleaners.
Non-HAP Cleaners. There were several alternative cleaners
identified that were not HAP based. Some solvents they contain
are furanone, cyclic amide, ethyl ester, other esters, N-
Methylepyrrolidone (NMP), and D-limonene. All cleaners
identified are direct replacements for MeCl2/ meaning that they
typically require no equipment or operational changes.
All the non-HAP solvent-based cleaners identified eliminate
HAP emissions, but the solvents in them are still classified as
VOCs. All three products have low evaporation rates, and can be
reclaimed and reused. There are also savings in disposal costs
of the waste material, as none of the spent cleaner from these
products is classified as a hazardous waste, unlike MeCl2.
Steam Cleaning. Some flexible polyurethane foam slabstock
plants were identified in the ICR database that use steam to
flush hoses, mixheads, and other pouring equipment.2 The reacted
foam scrap from the steam cleaning was collected and shredded for
use in a rebond operation.
Control Technologies for Fabrication Adhesive Emissions
HAP-based adhesives are used in both slabstock and molded
foam facilities. As the reduction alternatives are the same for
both subcategories, they will both be discussed below. In
slabstock facilities, spray adhesives are used to glue fabric-to-
foam, or foam-to-foam. As mentioned earlier, in the slabstock
industry, only about 40 percent of the fabrication is done
"in-house", and not all fabrication involves gluing. The main
use of adhesives in molded foam facilities is for the repair of
voids and tears in the molded pieces.
-------
20
Three alternatives were identified that eliminate HAP
emissions from the use of adhesives. These are (1) hot-melt
adhesive, (2) water-based adhesives, and (3) Hydrofuse. Each is
discussed below.
Hot-Melt Adhesives. Hot-melt adhesives are sold as solids
that are melted in a tank system before being sprayed on, like
solvent-based adhesives. They have a quick drying, or "tack"
time, so it is possible to maintain normal production rates. In
some instances, the tack time is too short to allow proper
adhesion, so that by the time a cushion as been sprayed, the
earliest adhesive applied has cooled to the point that it is no
longer sticky. However, the tack time depends on the product
used, and some manufacturers produce hot-melts with expanded tack
times. Another problem is the possibility of operator injury, as
the temperature of the adhesive is maintained above 200° F, which
could cause burns.
Hot-melt adhesives do not contain any HAP's; however, small
amounts of low molecular weight hydrocarbons may be emitted at
application temperatures. There is also a decrease in the amount
of adhesive needed to adhere the same amount of foam.
Water-Based Adhesives. The largest advantage to water-based
adhesives is that all HAP's have been replaced by water, and
there is a complete elimination of organic emissions. The main
drawback is the slower drying times of these adhesives. Many
fabrication systems require an additional heat source to speed
the evaporation of the water. This additional wait increases the
space needed, and increases the utilities to operate the lamps.
However, there are no other equipment or operational changes
necessary to replace HAP-based adhesives with water-based.
Hvdrofuse. Another water-based alternative to solvent-based
adhesives is a product called Hydrofuse. Hydrofuse is a two-
component, water-based adhesive that allows immediate contact
bonding without the need for drying. The two-components, a
water-based latex adhesive, and a mild citric acid solution, are
externally co-sprayed causing the adhesive to immediately
coagulate.
This process does require some process and equipment
changes. Equipment alterations will include changing to new
spray guns, and assuring that all wetted parts are stainless
steel or plastic. Process considerations include operator
training in the use of a two-component adhesive, and in
application rates. Another special requirement for this adhesive
is that one of the two surfaces to be adhered must be porous. A
significant advantage of this product is that there is little or
no penetration of the surface it is applied to, and it dries
almost instantly.
-------
21
MOLDED FOAM PRODUCTION
Process Description16
A typical molded foam production line includes multiple
molds, with each mold consisting of top and bottom sections,
joined by hinges. The molds are mounted on a circular or oval-
shaped track. Both the molds and the track can vary broadly in
size. Mold sizes range from less than one foot for novelty
items, to several feet for mattresses. The track can be a small
carousel, with fewer than 10 molds, or a large racetrack, with
over 20 molds. The molds travel around the track, and the
necessary process operations are performed at fixed stations.
The following paragraphs describe a basic molding cycle.
The first step in the molding cycle is the application of
mold release agent. This is a substance that is applied to the
mold to facilitate removal of the foam product. The mold release
agent is typically a wax in a solvent carrier. The carrier may
be either a chlorinated solvent or a naphtha petroleum solvent.
Mold release agent is typically applied by a spray system. After
the mold release agent is applied, any special components to be
molded into the foam are placed in the mold. These might include
covers, springs, or reinforcing materials.
Raw materials, including polyol, diisocyanate, water,
catalyst, and surfactant are all pumped to a common mixhead in
predetermined amounts. The mixhead injects a precisely measured
"shot" of raw material into each mold. There are two types of
mixheads used in the industry, high-pressure and low-pressure.
In a high pressure system, mixing is achieved by impingement of
the high pressure streams within the mixhead. The low-pressure
system relies on a rotating mixer within the mixhead to blend the
raw chemicals together. The two types of mixheads have different
cleaning requirements, resulting in a dramatic difference in
overall emissions from the process, which will be discussed in
the HAP emission section that follows.
After the raw materials are charged by the mixhead, the
molds may be heated to accelerate foam curing reactions. This
can be accomplished by pumping hot water through tubes in the
body of the mold, or by passing the mold through a curing oven.
The amount of heating required, if any, depends on the specific
process.
The mold is then closed, and the polymerization reaction
occurs, producing a foam product that fills the mold. Most
16 Memorandum. Williams, A. and Norwood, P., EC/R
Incorporated, to Svendsgaard, D., U.S. Environmental Protection
Agency. Trip Report - Foamex International, Morristown, TN.
EC/R Incorporated. January 18, 1994.
-------
22
molded foams are produced without any auxiliary blowing agent
(ABA), using only the blowing action of carbon dioxide (CO2) gas
from the water-isocyanate reaction. After curing, the molds are
opened and the product is removed. The mold is then cleaned and
starts the circuit again. The entire cycle takes approximately
10 minutes.
Another important variation of molded foams is the integral
skin foam, also known as a self-skinning foam. An integral skin
foam is a foam*with a dense, tough outer surface. The skin is
produced by overpacking the mold and using an ABA, usually
Freon-11. Unlike other types of molded foams, integral skin
foams require an ABA. The skin production is also driven by the
temperature gradient between the center of the foam mass and the
relatively cooler surface of the mold. Integral skin foams are
used in such products as steering wheels and footwear.
Most grades of molded foam, especially those using more
reactive raw materials, have closed cells when they are initially
removed from the mold. The cells are opened, by mechanical or
physical processes, to prevent shrinkage. The most common method
used to open the foam cells is to "crush" the foam by passing it
through a set of rollers.
After a foam piece is removed from the mold and its cells
are opened, it generally is trimmed and inspected for tears or
holes. Any tears and holes are repaired. Repair operations are
carried out at glue stations, which may by equipped with local
ventilation systems to remove solvent vapors emanating from the
glue.
Molded HAP Emission Sources
This section will discuss the HAP emission points for molded
foam production. Three main areas of HAP emissions from molded
foam are mixhead flush, mold release agents, and repair
operations (from adhesive use) .
Mixhead Flush
Methylene chloride emissions for flushing of low-pressure
mixheads was the largest emission source for flexible molded foam
manufacture.2 With low-pressure mixheads, the chemical streams
enter the mixing chamber at approximately 40 to 100 psi, and are
blended by rotating mixer blades before being released or "shot"
into the mold. Residual materials can remain in the chamber, as
well as on the blades. This material needs to be cleaned out,
either after every shot, or after several, depending on the
conditions. Flushing is necessary because the residual froth can
harden and clog the mixhead or can interfere with the necessary
precision required of the volume of the foam shot.
-------
23
Mold Release Agents
Emissions from mold release agents was another source of HAP
emissions from molded foam. Mold release agents are sprayed on
the mold surface(s) before the foam mixture is poured into the
mold to prevent adhesion and create a smooth surface.
Traditional mold release agents consist of a resin in a solvent
carrier, frequently methylene chloride or 1,1,1-trichloroethylene
(methyl chloroform), both HAPs. The carrier evaporates, leaving
the resin, which prevents the foam from sticking to the mold.
Molded Foam Repair
Once a foam piece has been removed from the mold, it is
inspected for tears or holes. If repair is needed, scrap foam
pieces, or the original piece that stuck to the mold, are glued
to fill in the void. A HAP-based adhesive may be used for this
process, with the carrier solvent being a HAP. The emissions
occur when the solvent carrier evaporates after the adhesive is
applied.
Control Technologies for Molded HAP Emissions
As was discussed in the HAP control technologies section for
slabstock, the EPA identified emission reduction and control
techniques for the flexible polyurethane foam industry. Mixhead
flush and mold repair emission reduction technologies are
discussed below. The emission reduction technologies for repair
adhesives are the same as for slabstock fabrication, and were
discussed in that section earlier in the memorandum.
Control Technologies for Mixhead Flushing Emissions
As noted above in the discussion of HAP emission sources,
methylene chloride emissions for flushing of low-pressure
mixheads was the largest emission source for flexible molded foam
manufacture. Several technologies were identified to reduce or
eliminate this source of HAP emissions for the molded foam
producer. They are non-HAP flushes, high-pressure mixheads,
self-cleaning mixheads, and solvent recovery units.
High-Pressure (HP) Mixheads. Low-pressure mixheads can be
replaced with high pressure (HP) mixheads. HP mixheads dispense
the foam at a higher pressure. These mixheads have already
replaced low-pressure mixheads in many larger molded foam
facilities. With HP mixheads, the raw materials are fed into the
mixing chamber through two or more opposing nozzles. The nozzles
are sized to produce a sharp pressure drop that causes the liquid
streams to be accelerated, so that when they impinge the streams
are thoroughly mixed. HP mixheads eliminate the need for MeCl2
as a flushing agent as there is no residual froth left in the
mixhead. HP heads may not be applicable for manufacturers of
-------
24
small parts, as the low throughput rate for these parts may be
too low for the HP system to achieve the required mixing.
Replacing low-pressure mixheads with HP heads requires
replacing more than just the mixing heads. It usually requires
new metering pumps and metering controls to provide the chemicals
at the higher pressures. The connecting hoses may also need to
be replaced if they are not suitable for handling the chemicals
under increased pressure.
«
Non-HAP Mixhead Flushes. Several non-HAP solvent-based
flushes were identified and investigated. The solvents they
contain are cyclic amide, ethyl ester, glutarate ester, and other
esters;17'18 and one product's major component is D-limonene,
with small amounts of terpene hydrocarbons.19 The important
characteristics of alternative flushes are that they are quick-
drying, quick cleaning, and non-reactive with the foam raw
ingredients. All flushes identified are direct replacements for
methylene chloride, meaning they typically require no equipment
or operational changes. The spent flush from these products is
not classified as a hazardous waste, unlike MeCl2.
All solvent-based flushes eliminate HAP emissions, but the
solvents in them are still classified as VOCs. However, all
three products identified have significantly lower evaporation
rates, with maximum vapor pressures of 2 mm Hg, as compared to
MeCl2 (355 mm Hg vapor pressure.) Another major advantage is
that all three products are reclaimable and reusable. According
to the vendors, the solids can be filtered out and the solvent
reused 2 to 5 times. Further use can be extracted from these
products if the solvent is distilled, while MeCl2 can only be
reused if it is distilled.
Solvent Recovery Systems. Two molded foam facilities were
contacted that had solvent recovery systems in place.20'21
17 Dynaloy, Inc. Material Safety Data Sheet. Transmitted
to EC/R Inc. via facsimile on April 26, 1994.
18 Huron Technologies, Inc. Material Safety Data Sheet.
Transmitted to EC/R Inc. via facsimile on April 29, 1994. Cover
letter from G. Borgeson, president, Huron Technologies, Inc. to
A. Williams, EC/R Inc.
19 Florida Chemical Co., Inc. Material Safety Data Sheet.
Transmitted via facsimile from Steven Ferdelman, Chem Central, to
A. Williams, EC/R Inc., on April 23, 1994.
20 Telecon: A. Williams, EC/R Inc., to D. Peck, Renosol
Corp. June 7, 1994.
-------
25
Both systems had a capture system where the HAP flush is captured
in a 55-gallon drum at each line. The drums are then taken to a
reclamation room, and the flush is pumped into a 2000 to 2500
pound tote. This tote is placed in a solvent reclamation unit,
which is heated to between 210 and 240° F. The solvent vapors
are flashed off and go to a condenser. The solids from the still
are collected for disposal. Both systems had a recovery rate of
about 70 to 80 percent.
One of the systems had an additional step to reduce
emissions at the capture area. They have equipped the three
molded lines that use solvent flush with a "closed-loop system"
for capturing the methylene chloride vapors from the area around
the 55-gallon drum used to capture the flush. This system
consists of a fan that draws the air from that area through a
carbon filter, which captures the solvent vapors before they are
released to the atmosphere.
Control Technologies for Mold Release Agent Emissions
Alternatives being used, or being investigated, by the
industry to eliminate the use of HAP-based mold release agents
include water- or naphtha-based agents, and reduced-VOC solvent
agents. The following paragraphs discuss these three options.
Reduced-VOC Mold Release Agents. The reduced-VOC mold
release agents are high-solids, solvent-based formulations. The
advantage of these agents over traditional HAP-based agents is a
reduction in VOC emissions of up to 80 percent. It was unclear
if any of the solvents used are HAP's, although the EPA believes
that they are not. One vendor stated that most users have seen a
reduction in mold release consumption of 20 to 50 percent after
switching to the reduced-VOC release agents.22 No equipment
changes are necessary in switching to this type of release agent,
and no significant operator training or mold temperature changes
are necessary.
Naphtha-based Release Agents. Naphtha-based release agents
are composed of resins in a hydrocarbon naphtha carrier solvent.
Naphtha typically composes at least 90 percent of the mold
release agent.23 Naphtha is not considered a HAP, however, it
is listed as a VOC, so the emission reduction is in HAP emissions
only. Foam manufacturers contacted indicated that they have
21 Telecon: A. Williams, EC/R Inc., to S. Smoller, E-A-R
Specialty Corporation. June 10, 1994.
22 Telecon: A. Williams, EC/R Inc., to J. Robinson, Air
Products. July 11, 1994.
23 Telecon: A. Williams, EC/R Inc., to M. Gromnicki,
Swenson Corp. July 14, 1994.
-------
26
found less naphtha-based release agents are required than HAP-
based, however, the EPA was unable to quantify this reduction.
There were no necessary process or equipment changes identified.
Water-based release agents. The use of water-based mold
release agents is more complicated than for naphtha or reduced-
VOC solvent based agents.22'24 However, unlike the other two
alternatives, water-based mold release agents totally eliminate
organic emissions.
4
All water-based mold release agent manufacturers spoken to
emphasized that selecting a water-based release agent is very
customer-specific, and that the correct selection can require
considerable time and many trials before the correct product is
found. The developmental procedures can be costly in time, as
well as in scrap foam, during the transitional period.
There are also a few production changes that need to be made
when converting from a solvent-based to a water-based agent.
Water-based release agents are more application-sensitive than
the solvent-based agents, so some spray re-training may be
necessary. Mold temperature is another common change necessary
when switching to water-based agents, due to the higher
evaporation temperature of water. There are no equipment changes
necessary, except that some manufacturers recommend High Volume
Low Pressure (HVLP) sprayers for use with the water-based agents,
due to the need for increased application sensitivity.
The major disadvantages of water-based agents are the
increased drying time and a development period which may be
extensive. Also, foams produced using water-based mold release
agents have a less porous surface than those poured with
conventional release agents, which can be a disadvantage when
adhering fabrics to the foam.
REBOND FOAM PRODUCTION
Process Description25
Another flexible foam product that is produced on-site at
slabstock foam facilities is rebond. Rebond foam is also
produced at stand-alone, or off-site facilities. Rebonding is a
process where scrap foam is converted into a material that is
used for carpet underlay and several other end-uses such as
24 Telecon: A. Williams, EC/R Inc., to C.. Asuncion, Air
Products. April 20, 1994.
25 Norwood, P. and Williams, A., EC/R Incorporated, to
Svendsgaard, D., U.S. Environmental Protection Agency. Site
Visit Report of Foamex L.P.'s Morristown, TN facility on May 26,
1993. January 18, 1994.
-------
27
school bus seats. A typical rebond production process is
described below.
The scrap foam may have been generated at the facility from
its slabstock operations, or may have been shipped or bought from
other foam facilities. There is such a high demand for this
product that foam scrap is imported from overseas. The scraps
are received in "bales." The baled foam is loaded by conveyor
into the bale-breaker, which "chews" the foam into smaller
pieces. The scrap bales are sent to the bale-breaker as
received, and often contain plastic and other non-foam materials.
Magnets at the exit of the bale-breaker remove any metal pieces
that could damage the grinders. The foam pieces from the bale-
breaker fall through screens into the grinder where the scrap is
converted into 3/4 to 3/8 inch pieces.
These small pieces are loaded into a blender, where a
mixture of polyol and TDI (or MDI) is added. The foam and binder
mixture, and occasionally a dye, is poured into a cylindrical
mold, that is below floor level. This mold has a central core so
that there is a hole that runs the length of the cylinder.
Pressure and steam are applied to the mixture in the mold, and
then the roll is taken out of the mold and allowed to cool or
"set" for about 24 hours.
To manufacture carpet padding, the roll is carried to the
sawing area after it has set, using a forklift. In this area,
the roll is peeled in a continuous operation, comparable to
peeling a potato. The end of the sliced material is fed into a
series of conveyors. As it is being peeled, the end of a roll is
glued to the beginning of the next roll to keep a continuous
sheet of rebond moving to the cutting and packaging area. The
amount and grade of the foam added, as well as the particle size,
determine the density of the final product. A density of 6
lb/ft3 is considered to be quality rebond carpet backing.
Rebond HAP Emission Sources
There were three emission sources identified in the
production of rebond foam. First, there is the opportunity for
emissions of TDI or MDI in the mold area. However, the emissions
from this area are minimal. The other two emission sources
identified were from the use of HAP cleaners and HAP-based mold
release agents.
Control Technologies for Rebond HAP Emissions
No control technologies were identified for the TDI or MDI
emissions from the molding area. For equipment cleaning and mold
release agents, there are numerous options available that do not
result in HAP emissions. These options were not investigated by
the EPA.
-------
-------
, [4,
Environmental Consulting and Research
MEMORANDUM
Date: November 3, 1995
Subject: .Flexible Polyurethane Foam Molded Plants: New Count and
Nationwide Model Plant Representation
From: Amanda Williams, EC/R Incorporated
To: David Svendsgaard,. EPA/OAQPS/ESD/OCG
Since the early phases of the polyurethane foam maximum
achievable control technology (MACT) project there has been a
difficulty in determining-the number of flexible molded
facilities in the U.S. The number has been difficult to estimate
for several' reasons, one being that this segment of the flexible
foam industry has no real representation by any trade
organization. . The Society for Plastics Institute (SPI) , and the
Polyurethane Foam Trade Association (PFA) both.had some knowledge
of this industry, but neither had.listings of facilities. Other
reasons the molded plant population has been hard to estimate is
that 'many of these facilities are small, and may be combined with
other industrial operations. Only 46 molded foam facilities were
identified when the information collection requests (ICRs) were
distributed in the fall of 1992. The information from these 46
facilities was used to create model plants. However, the EPA and
industry representatives both, believe that there could be as many
as several..hundred facilities nationwide.
The purpose of this memorandum is to describe an attempt to
provide a better nationwide estimate, predominantly for the
purpose .of the economic impact analysis. In this effort to
establish a better estimate of the., molded facilities nationwide,
the "Polyurethane Industry Director and Buyer's Guide -.1994"1.
was used. This resource contains company names and addresses, as
well as some information as to what-the company does.
The directory contains several indexes, one of which is by
finished goods. This index identified facilities producing
•flexible polyurethane foam, fabricated or raw bun stock, or
molded pieces. Another index used was for integral skin
manufacturers (a type of molded flexible polyurethane -foam) . The
companies identified on. this list were then looked up in the main
The Polyurethane' Industry Directory and Buyer's Guide -
1994. Larson Publishing. Saco, Maine.
3721-D University Drive • Durham, North Carolina 27707
Telephone: (919) 493-6099 . Fax: (919) 493-6393
-------
body of the directory where more detailed company descriptions
are provided, and a judgement was made as to whether they
produced molded flexible foam. These indices are included as
Attachment 1, with the selected companies starred. Every effort
was made to only include facilities that produced molded foam
from raw materials, and not fabricators that press manufactured
foam into molds. Based on the company descriptions, an
additional 182 flexible molded foam companies were identified,
bringing the total nationwide estimate up to 228. The directory
used did not indicate whether the companies had multiple
facilities, therefore it was assumed that each company had one
facility unless otherwise indicated.
The first assumption that was made regarding the
characterization of the newly identified facilities was that all
the facilities had low pressure (LP) mixheads. This assumption
was made based on the fact that all known facilities using high
pressure (HP) mixheads are large facilities, and that is believed
that all large facilities have all been identified.
There was no information on the size of these facilities,
therefore it was determined that it would be necessary to assume
the same distribution across the model plants as the facilities
for which information was obtained through the ICRs.
-------
ATTACHMENT 1
-------
FINISHED GOODS MANUFACTURERS
PRODUCT CROSS REFEREN
PLAXTONS PIC-UK
PIUMERS ISOLAT1E - NETHERLANDS
POLIFLEKS 5ENTETIK MADDELER - TURKEY
PONISCH REISEN GMBH - GERMANY
RADIUM FOAM 8V - NETHERLANDS
RADOMSKIE ZAKLADY - POLAND
RAMICO BOILEVIN - FRANCE
RAOUL IABORD, SA - FRANCE
RGB - FRANCE
RECORD RIGA FOOTWEAR - LATVIA
REIN SPA - ITALY
RENAULT - FRANCE ,
RK FOOTWEAR MNFTS (PVT) - ZIMBABWE
ROMIKA - GERMANY
ROSSETTI SPA - ITALY
ROTH FRERES, SA - FRANCE
ROVER - UK
SAAB SCANIA - SWEDEN
SABA DINXPERLO - NETHERLANDS
SAITEC - FRANCE
SALOMON, SA - FRANCE
SAMSONITE NV- BELGIUM
SANDELLA FABRIKKEN - NORWAY
SARRAIZIENNE, SA - FRANCE
SCAN-AQUA LTD. - FINLAND
SCHAFER WERKE GMBH - GERMANY
SCHMIT2-ANHANGER - GERMANY
SCHOLL, SA • FRANCE
SCHOMBERG & GRAF GMBH - GERMANY
SECURITE 24 - FRANCE
SHELLER CLIFFORD LTD. - UK
SHORT BROS PIC-UK
SIEVIN STALLMAN - SWEDEN
S1LAC - FRANCE
SILENTNIGHT KENYA LTD. - KE.VYA
SISA SPA - ITALY
SITAB SPA - ITALY
SOLEMAKERS (OLEMARK) - FINLAND
SOUviARK SOLECKIE ZAK - POLAND
STEELCASE STRAFOR - FRANCE
STOVVE WOODWARD FINLAND OY • FINLAND
TEBBUTT AND HALL BROS LTD. - UK
TELEWIG GMBH - GERMANY
THREE STAR SHOE CO. - IRAN
TILMAR BV - NETHERLANDS
TOBESCO HANDELS GMBH - AUSTRIA
TOCOVER - FRANCE
TORTORA EFCT G - FRANCE
TOYOTA MOTOR CORP • BELGIUM
TREVES - FRANCE
TUFTON BV - NETHERLANDS
UHL GMBH - GERMANY
UNITED FOAM UK LTD. - UK
UTA CLIFFORD LTD. - UK
VARIOFORM GMBH - C£RMAVY
VEB SACHSANRING AUTOMOBILWK - GERMANY
VEENENDAAL & CO. BV - NETHERLANDS
VEENENOAAL SCHAUMSTOFFWERK - GERMANY
VILIANMAA OY - FINLAND
VITA ACHTER LTD- • UK
VREDESTEIN ICOPRO BV - NETHERLANDS
WEBAC CHEMIE GMBH - GERMANY
WILHELM KARMANN GMBH - GERMANY
WOLLASTON VULCANIZING CO. - UK
YMOS AC - GERMANY
FLEXIBLE FOAM
South/Central/North America
-P-A.M.E. CORP. -USA
AASR, INC - USA
ABBOT INDUSTRIES, INC. - USA
^-ACCESSIBLE PRODUCTS - USA
ACCURATE FOAM CO. - USA
ACME MACHELL CO., INC - USA
•# ADAPT PLASTICS, INC - USA
ADFOAM - USA
jy ADVANCE LATEX PRODUCTS, INC. - USA
ADVANCE FOAM PLASTICS. INC. - USA
,_ ADVANCED FOAM AND PLASTIC CO. - USA
AERO SPECIALTIES CORP. - USA
,_r AGC INC - USA
AIR-O-PLASTIK - USA
f AIRTEX INDUSTRIES, INC. - USA
; AKRON PORCELAIN & PLASTICS CO. - USA
. ALACRA SYSTEMS - USA
. ALADDIN INDUSTRIES, INC - USA
ALF Mil CORP. -USA
:. ALL AMERICAN ENTERPRISES - USA
ALL-STATE BELTING CO. - USA
p ALLEN FOAM CORP. - USA
?• ALLIED-BALTIC RUBBER. INC - USA
ALMAC PLASTICS, INC. - USA
y AME CORP.-USA
AMERICAN EXCELSIOR COMPANY - USA
, AMERICAN FIBRIT, INC - USA
- AMERICAN FOAM PRODUCTS. INC. - USA
AMERICAN POLY-FOAM CO., INC - USA
= AMERICAN POLY-THERM CO. - USA
-- AMERICAN PRECISION PRODUCTS - USA
.-- AMERICAN RUBBER PRODUCTS CORP. - USA
? AMES RUBBER CORP. - USA
APPLIED PRODUCTS, INC. - USA
ARMALY FOAM - USA
. ASHTABULA RUBBER CO. - USA
-ASSOCIATED RUBBER. INC. - USA
s ASTEC CO. - USA
ASTROFOAM. INC. - USA
400
THE POLYURETllANE ISDL-STRY DIRECTORY fND Bfm'S Gl IDE
-------
PRODUCT CROSS REFERENCE
RNEHED GOODS MANUFACTURERS
ATLANTIC POLYMERS & PRODUCTS • USA
^ATLANTICTHERMOPIASTICS CO., INC - USA
AUSTIN URETHANE, INC. - USA
,, AUTOMA INTERIOR SYSTEMS - USA
f B. W. FREEMAN, INC. - USA
,,BANKS BROS. -USA
BARNHARDT MANUFACTURING - USA
/* BASF CORPORATION - USA
BENOIES FORMS, INC - CANADA
BEST FOAM FABRICATORS - USA
- • BONDED PRODUCTS. INC. - USA,
Hf BOYD CORPORATION - USA
f BRUNSWICK SEAT CO. - USA
"-'"BRYN HILL INDUSTRIES - USA
j*'BUCKEYE RUBBER & PACKING CO. - USA
BURKART FOAM, INC - USA
-rs C.J. PRODUCTS INCORPORATED - USA
•2-CALIFORNIA URETHANE - USA
•^ CARPENTER INSULATION & COATINGS, INC. - USA
CARTEX CORP. - USA
? CASTLE RUBBER CO. - USA
•a- CHARLES ENGINEERING & SERVICES INCORPORATED - USA
f CHESTNUT RIDGE FOAM, INC - USA
.* CHIVAS PRODUCTS LIMITED HEADQUARTERS - USA
3>COLEMAN CO. - USA
^•COMPONENT FINISHING CORP. - USA
s-CONE MILLS CORP. - USA
PCONITRON-USA
CONVERTERS, INC - USA
CONWAY INDUSTRIES, INC - USA
CORCORAN MANUFACTURING CO., INC. - USA
COWART FOAM CO., INC - USA
CRAIN INDUSTRIES - USA
CREATIVE FOAM CORP. - USA
-*. CREATIVE URETHANES, INC - USA
CREST FOAM INDUSTRIES, INC - USA
CUSTOM COATING, INC - USA
CUSTOM PACK, INC - USA
-^ CUSTOM RUBBER CORP. - USA
^ DAVIDSON INTERIOR TRIM TEXTRON - USA
*> DAYTON POLYMERIC PRODUCTS. INC. - USA
y DELAWARE SEAT CO. - USA
? DELCO PRODUCTS - USA
DIPOL, SA DE CV. - MEXICO
DIVERSIFIED FOAM, INC - USA
DOMFOAM INTERNATIONAL. INC. - CANADA
DOUGLAS AND LOMASON CO. - USA
DOUGLASS INDUSTRIES - USA
-F DOVE PRODUCTS. INC - USA
-7 DURAFOAM SEATING - USA
f DYNAMIC FOAM PRODUCTS, INC - USA
DYNAMIC PACKAGING, INC. - USA
E-A-R SPECIALTY COMPOSITES - USA
E-K MANUFACTURING - USA
E. R. CARPENTER CO. - USA
if EAGLE PICKER AUTOMOTIVE CROUP-USA
^ EASTERN CONTAINERS - USA
EASTERN FOAM CORP. - USA
EG GASKET & SUPPLY, INC - USA
-i ENGINEERED POLYMERS CORP. - USA
•5 ENGINEERED SYSTEMS - USA
•v ENGINEERING POLYMERS CORP. - USA
r EVERGREEN MOLDING • USA
x EXPANDED RUBBER & PLASTICS - USA
•ti F.H.MALONEYCO.-USA
F.P.WOLL&CO.-USA
•X FLEXAN CORP. - USA
aEXIBLE FOAM PRODUCTS - USA
•? FLEXIBLE INDUSTRIES - USA
-3 aEXIBLE PRODUCTS MFC CO., INC. - USA
* FLEXSTEEL INDUSTRIES - USA
? FLEXTRON INDUSTRIES - USA
FLORIDA FOAM CO. - USA
T FLORIFOAM - USA
FOAM MOLDERS & SPECIALTIES - USA
tr FOAM PACKAGING LTD. • USA
FOAM PRODUCTS CORP. - USA
FOAM PRODUCTS CORPORATION - USA
FOAM PRODUCTS. INC - USA
FOAM RUBBER FABRICATORS, INC - USA
•g FOAM RUBBER PRODUCTS-USA
V FOAM SPECIALITIES • USA
FOAM CONVERTERS T/A COMPLETE PKC. - USA
FOAM DESIGN, INC - USA
•$ FOAM FABRICATORS, INC - USA
FOAM FACTORY, INC - USA
FOAM FAIR INDUSTRIES - USA
FOAM TEK INCORPORATED - USA
FOAM TO SIZE • USA
^ FOAM-FORM, INC - USA
FOAMADE INDUSTRIES - USA
FOAMCRAFT INCORPORATED - USA
FOAMCRAFT, INC - USA
FOAMCRAFTERS - USA
FOAMEDGE PRODUCTS • USA
FOAMEX LP.-USA
FOAMFAB, INC • USA
FORD MOTOR, CO. UTICA TRIM OPERATIONS • USA
•P FRANK LOWE RUBBER & GASKET CO, INC - USA
FRANKLIN FIBRE-LAMITEX CORPORATION - USA
ft FREUDENBERG-NOK - USA
FUROM CO. - USA
FUTURA COATINGS, INC - USA
FUTURE FOAM, INC - USA
f G-FORCE AERODYNAMICS - USA
-Z G. T. SALES & MANUFACTURING. INC - USA
GASKA TAPE, INC - USA
1? GASKET & MOLDED PRODUCTS - USA
GENERAL FOAM - USA
GENERAL FOAM - USA
THE PoiYLnrnuNS Isousrn DIMCTORY A>D BETTER'S GUOE
401
-------
FINISHED GOODS MANUFACTURERS
PRODUCT CROSS REFERENC
GENERAL FOAM OF MINNESOTA - USA
-f GENERAL PLASTICS MFC. CO. - USA
GENERAL RUBBER & PLASTICS CO., INC. - USA
GEORGIA BONDED FIBERS. INC - USA
GOODYEAR TIRE & RUBBER CO. - USA
•$ COULD MID-WEST CORP. - USA
& GOULD SOUTHERN, INC. - USA
GREAT WESTERN FOAM PRODUCTS CO. - USA
GREEN MOUNTAIN FOAM PRODUCTS - USA
GUARDIAN PACKAGING, INC. - USA
-? HEDSTROM CO. - USA
HELLER CO. - USA *
HERMAN A. GELMAN CO. - USA
HERMAN MILLER - USA
* HIBCO PLASTICS. INC. - USA
7 HICKORY SPRINGS MANUFACTURING CO. - USA
HOUSTON FOAM PLASTICS, iNC - USA
HOY SHOE CO. - USA
•3> HUDSON INDUSTRIES. INC. - USA
•% HYDRA-MATIC PACKING CO. - USA
ILLBRUCK, INC. - USA
IU.IG INDUSTRIES, INC. - USA
•& ILLINOIS INSTITUTE OF TECHNOLOGY - USA
•3> INDUSTRIAL & MILITARY TECHNOLOGY CORP. - USA
INDUSTRIAL CUSTOM PRODUCTS - USA
INDUSTRIAL POLYMERS, INC - USA
ff INDUSTRIAL RUBBER & PLASTICS CO., INC. - USA
INDUSTRIAL RUBBER & SUPPLY, INC - USA
INDUSTRIAL RUBBER WORKS, INC • USA
INOAC U.S.A., INC. - USA
INSTA-FOAM PRODUCTS, INC - USA
INTEGRAM ST. LOUIS FOAM OPERATIONS - USA
INTEK WEATHERSEAL PRODUCTS, INC. - USA
-5>l. LSCHROTHCO.-USA
JEFFCO UPHOLSTERY & FOAM PRODUCTS - USA
=y JOHNSON BROTHERS RUBBER CO. - USA
JOHNSON CONTROLS, INC - USA
KEENE CORP. - USA
-7 KEMCO PLASTICS - USA
3" KENT MFC CO. - USA
KERN FOAM PRODUCTS CORP. - USA
KEYSTONE URETHANE PRODUCTS - USA
KIRSCH CHEMICAL COMPANY. INC - USA
.7 KRYPTONICS, INC - USA
t> KURTH INTERNATIONAL - USA
KUSTOM FOAM MFG., INC. - USA
LAMATEK, INC. - USA
f LARSTAN, INC. - USA
LEGGETT & PLATT, INC. - USA
LEWIS INDUSTRIES - USA
LIBERTY FOAM & PACKAGING • USA
^ LOYALTY FOAM CO. - USA
j- LUDWIC. INC. - USA
< LUNDELL MFC CORP. - USA
3T M & C SPECIALTIES CO. - USA
M & R FLEXIBLE PACKAGING, INC - USA
2>M&H INDUSTRIES • USA
a" MAC SPECIALITIES LTD. - USA
"i'MADISON POLYMERIC ENG - USA
-^•MANCHESTER PLASTICS - USA
•y MARCHEM CORPORATION - USA
'^MARCHEM DUBLON, INC - USA
*' MARIAN RUBBER PRODUCTS CO.. INC - USA
MARKO FOAM PRODUCTS, INC - USA
MARTEC PLASTICS - USA
£>• MARVLEE - USA
-y MAYPAK, INC - USA
MEARTHANE PRODUCTS - USA
MECHANICAL RUBBER PRODUCTS CORP. - USA
T MERRYWEATHER FOAM, INC - USA
MICROFOAM, INC - USA
MIDCO PACKAGING INDUSTRIES - USA
TJr MIDWEST CORTLAND, INC - USA
* MIDWEST URETHANE - USA
MILCUT, INC - USA
•£• MILFOAM CORPORATION - USA
<3 MILSCO MANUFACTURING CO. - USA
3 MINNESOTA RUBBER • USA
•3 MOLDED MATERIALS, INC - USA
-y MONO-THANE-USA
•y MOULDED CHEMICAL PRODUCTS. CO., INC • USA
MUTH ASSOCIATES, INC - USA
NASHVILLE RUBBER 4 GASKET - USA
NATION/RUSKIN, INC - USA
NATIONAL FOAM MFG. CO. - USA
T NEW ENGLAND FOAM PRODUCTS - USA
~ NO SAG PRODUCTS CORP./ LEAR SICLER - USA
NORTH AMERICAN FOAM & PACKAGING. INC - USA
:•• NORTH CAROLINA FOAM INDUSTRIES, INC - USA
NORTON PERFORMANCE PLASTICS CORPORATION - USA
NORWOOD INDUSTRIES - USA
NTD AMERICAN, INC - USA
OHIO FOAM CORPORATION - USA
y OLEA INTERNATIONAL - USA
OLYMPIC PRODUCTS CO. - USA
IOMEGA RUBBER PRODUCTS - USA
-fi OMNI PLASTICS, INC - USA
'/*• PAC FOAM PRODUCTS CORP. - USA
PACIFIC STATES FELT AND MANUFACTURING - USA
PACKAGING FOAM FABRICATORS, INC - USA
PACKAGING TECHNOLOGY, INC - USA
PACKATEERS, INC - USA
•jr PAGE BELTING CO. - USA
PAR-FOAM PRODUCTS - USA
PENN FOAM CORP. - USA
PERMA-FOAM INC - USA
PERRY CHEMICAL & MANUFACTURING CO. - USA
# PHOENIX FOAM & FIBERGLASS, INC - USA
PIPELINE PIGGING PRODUCTS - USA
PLASTOMER CORPORATION - USA
402
THE POLYVRETIlASE IVDLSTRY DIRECTORY *SD BUYER'S GUDE
-------
PRODUCT CROSS REFERENCE
FINISHED GOODS MANUFACTURERS
•* PlEIGER PLASTICS COMPANY - USA
~ PLYFOAM PRODUaS - USA
Z POLLY PIC BY KNAPP, INC. - USA
POLLY PRODUCTS - USA
• POLY FOAM, INC. - USA
* POLY-FOAM, INC - USA
,vPOLYFOAM PACKERS CORPORATION • USA
PONTIAC PLASTICS & SUPPLY - USA
f POW-R-TOW, INC - USA
PRESTO TECHNOLOGIES, INC - CANADA
•sr PRINCE MASTERCRAFT, INC. - USA.
3* PRODUQS RESEARCH & CHEMICAL CORP. - USA
PROTECT MANUFACTURING, INC. - USA
*- PURETHANE. INC - USA
R.B.L. INDUSTRIES - USA
RADVA CORP. - USA
f RANDALL TEXTRON - USA
^REDCO - USA
REILLY FOAM CORP. - USA
REISS INDUSTRIES, INC - USA
RELIABLE PLASTICS, INC - USA
^ RELIANCE PATTERN WORKS CO. - USA
RELIANCE UPHOLSTERY SUPPLY CO. - USA
REMPAC FOAM CORP. - USA
7S> RENOSOL CORPORATION - USA
REPUBLIC PACKAGING CORP. - USA
RICHARDS, PARENTS & MURRAY, INC. - USA
•ff RIVERSIDE SEAT CO. - USA
-S ROCKMONT INDUSTRIES - USA
<#RODAC RUBBER CO. - USA
y RODMAR MFC & RESEARCH, INC. - USA
.^ROGERS CORP. WILLIMANT1C DIVISION - USA
ROGERS CORPORATION - USA
ROGERS CORPORATION - USA
ROGERS FOAM CORP. - USA
•£• ROMEO RIM, INC - USA
ROSS & ROBERTS. INC - USA
& ROYAL PRODUCTS CO. - USA
RS RUBBER CORP. - USA
3> RUBBER & SILICONS PRODUCTS CO., INC. - USA
5* RUBBER DEVELOPMENT, INC - USA
•^RYNELLTD.-USA
S&S PLASTICS - USA
.tf SACKNER PRODUCTS - USA
SAN ANTONIO FOAM FABRICATORS - USA
SANICLASTIC MFG. CO. - USA
* SAVON FOAM CORP. - USA
~3 SCO CORP - USA
SCHNADIC CORP. - USA
SCOTT PORT-A-FOLD. INC. • USA
SCOTTDEL INC. • USA
& SEARS MANUFACTURING CO. - USA
SFT. INC. - USA
SHELLER-CLOBE CORP - USA
3 SNOW CRAFT CO.. INC. - USA
SOLAR COMPOUNDS CORP. - USA
TEXSTAR, INC - USA
TEXTILE RUBBER & CHEMICAL CO. - USA
TEXTILE RUBBER CO.-USA
-------
FINISHED GOODS MANUFACTURERS
PRODUCT CROSS REFERENC
WILSHIRE ADVANCED MATERIAL - USA
WILSHIRE FOAM PRODUCTS, INC. - USA
WISCONSIN FOAM PRODUCTS, INC. - USA
WM. T. BURNETT & CO., INC - USA
WOODBRIDGE FOAM CORPORATION - CANADA
WOODBRIDGE FOAM FABRICATING, INC - USA
WOODBRIDCE GROUP, THE - USA
ZERILLO PRODUCTS, INC - USA
Europe/Middle East/Africa
AARSLEV POLYMERE IND, AS - DENMARK
AB B AKESSON & COMPANY - SWEDEN
ASTRALI ACCESSORIES • UK /
AVALON CHEMICAL CO. LTD • j
CALIGEN FOAM\LIMITED - UK/
DC-SYSTEM INSULATION, AS/DENMARK
DRAKA IN'TERFOAM B.V. - NETHERLANDS
DUN LOP LTD. •
EUROPLASTIC GM^H & COMPANY - GERMANY
f. S. FEHRER CMBHU Cp. KG - GERMANY
iv\
HAIRLOK LTD. - UK
JARRI PLASTIC INDUSTRIES LTD. - ISRAEL
JOHNSON CONTROLS LTD. - UK
KAYFOAM WOOLFSCbN LTD. - IRELAND
KOEPP AKTIENCES/LIJSCHAFT - GERMANY
LOXI-PUR.A8-5VVEOSN
NORDFLEX. AB - fwED.EN
RECTICEL DEUTSCHLA'ND GMBH - GERMANY
RECTICEL INTERNATIONAL - BELGIUM
SPUMOTIM, SA - ROMANIA
SUNTAS FOA^M & MA1JTRE5S CORP. - TURKEY
TANEX, PLASIY AS - CZECHOSLOVAKIA
TECNODENT SPA - /TAJY
TRAM I CO. ^SA - FRANCE
VERT1FOAM INTERNATIONAL LTD. - UK
VITA CORTEX HOLDINGS LTD. - IRELAND
VITAFOAM LTD. -UK \
WOODBRIDGE FOAM GMBH - GERMANY
ZACO ^PTI) BV - NETHERLANDS
ZDA PARTIZANSKE - CZECHOSLOVAKIA
I \
Asia/Pacific Rim \
ADVANCE FOAM - MALAYSIA
AEROFOAM - ,VfAMY5/A I
AGMAN - MALAYSIA \
AMfT POLYSEATS (P) LTD. - ^ND(A
AMRAPALI PROPERTIES LTDi- WDM
ART RISE - MAMY5/A \
BAN MORE FOAM PVT. LTD. -,/<\OM
BANGKOK FOAM CO. LTD. - 7HAILAND
BRIDGESTONE I'M) SON. BHD. \ MALAYS/A
CAMATIC-AUSTRALIA PTY. LTD. V AUSTRALIA
CAMEL - MALAYSIA
CHANCSU PU CUSHION MATERIAL FACTORY - PRC
CHEMI-NOVA INDUSTRIES PTE. LTD. - INDIA
CHIAN CHEN COMPANY PTE. LTD. - SINGAPORE
CHIAO FU ENTERPRISE CO. LTD. - TAIWAN.ROC
tHIAO FU ENTERPRISES CO. - AUSTRALIA
CHINA SHENYANG PU FACTORY - PRC
CHONGQINY CHAOYANC CHEMICAl PLANT - PRC
CONCORDE (M) SON. BHD. - MALAYSIA
CRECIMIENTO INDUSTRIES CO. LTD: (CRMTO) - TAIWAN RC
CRYSTAL FOAM - MALAYSIA /
DA-FOING FOAM CO. LTD. - TAIWAN ROC
DAE WON SEATS INDUSTRIAL CD. LTD. • KOREA
DEWF^AM CORP. - PHILIPPINES/
DP FOAM PRIVATE LTD. - INDIA
DREAMLAND - MALAYSIA /
DUNIA GHEMICAt INDUSTRIES - INDONESIA
DURAFO^M INDUSTRIES PVT. LTD. • INDIA
ERLANGCA FOAM INDUSTRY - INDONESIA
FAR EAST i MALAYSIA /
FLEXO FO/*M INDUSTRIES • INDIA
FOAM CENTRE - SINGAPORE
FUZHOU N. - KOREA
Kli'N CHING INDUSTRIA^CO. LTD. - TAIWAN ROC "
LljCA FOAM - INDONESIA \
LfDNC LAST MERCHANDISING CENTRE - PHILIPPINES
LOW AH CHONG & CO. - 5/NCAPORE
LbCKY GROUP - THAILAND
MADRAS POLYMOULDS - INDIA
MANOAUE FOAM INDUSTRIES'- PHILIPPINES
MAYO FOAM MANUFACTURING. PTE. LTD. - SINGAPORE
MOW WING COTTON MANUFACTURING CO. - SINGAPORE
MUSTIKA - INDUSTRI BUSA URETHANE - INDONESIA
NANTA KOAM IM) SON. BHD. - MALAYS/A
404
THE POLYL'RETHANE IVDL'STRY DlRECTORr \*D BuYER'i Ol :=E
-------
PRODUCT CROSS REFERENCE
FINISHED GOODS MANUFACTURERS
NATSON FOAM MANUFACTURING PVT. LTD. - INDIA
NECHECO • FOAM PLASTICS - INDONESIA
NEW RAHARDJA FOAM - INDONESIA
NGAI LIM INDUSTRIES PTL LTD. - SINGAPORE
NIPPON MEKTRON LTD. -JAPAN
NITE BEAUTY (M) SON. BHD. - MALAYSIA
NUFOAM INDUSTRIES - INDIA
NYLON FOAM INDUSTRIAL CORP. - PHILIPPINES
OCEAN FOAM - INDONESIA
PACIFIC DUNLOP PTY. LTD. - AUSTRALIA
PANAMA POLY PRODUCTS PVfc LTD. - INDIA
PEACE & HAPPINESS COMPANY - PRC
PEXAFOAM SDH. BHD. - MALAYS/A
PHOENIX BASE SON. BHD. - MALAYSIA
POLYFOAM-RGC INTERNATIONAL CORP. - PHILIPPINES
PON TON ENTERPRISE CO. LTD. - TAIWAN ROC
PT MAJU FOAM - INDONESIA
PT SURYA AGUNG - PU FOAM INDUSTRY - INDONESIA
PT. CITRA SARANA MAKMUR - INDONESIA
PT. DASA WINDU AGUNG - INDONESIA
PT. INDUSTRI URETHAN - INDONESIA
PT. MEIWA INDONESIA - INDONESIA
PT. POSITIVE FOAM INDUSTRY - INDONESIA.
PT. REMAJA JAYA FOAM - /NDONE5/A
PT. SUPER POLY FOAM INDUSTRY - INDONESIA
PT. VITAFOAM - INDONESIA (INOAC) - INDONESIA
QING YANG PLASTIC FOAM FACTORY - PRC
QUANGZHOU FOAM PLASTICS FACTORY - PRC
RECOS FOAM (M) SON. BHD. - MALAYSIA
SAM KVVANG URETHANE CO., LTD. - KOREA
SAM YANG CHEMICAL CO. LTD. - KOREA
SAM YOUNG CHEMICAL CO. LTD. - KOREA
SAMMIT AUTOSEATS & PARTS CO. LTD. - THAILAND
SEDA CHEMICAL PRODUCTS CO. LTD. - TAIWAN ROC
SERIM CO. LTD. - KOREA
SHANDONG PENGLAI PU PRODUCTS FACTORY - PRC
SHANGHAI NO.6 PLASTICS FACTORY/CHIAO FU ENTERPRISE
CO. - PRC
SHANGHAI YAN FENG MACHINE MOULD FACTORY - PRC
SHARIKAT PERNIAGAAN COSMO - MALAYSIA
SHEELA FOAM PVT. LTD. - INDIA
SHIH FENG CHEMICAL PRODUCTS CO. LTD. - TAIWAN ROC
SHROFF FOAM INDUSTRIES PVT. LTD. - INDIA
SIONG BEE INDUSTRIES PTE. LTD. - SINGAPORE
STAR LIGHT CHEMICAL INDUSTRY - INDONESIA
SWASTIK FOAM PVT. LTD. - INDIA
SYARIKAT PER1NDUSTRIAN MADAH • MALAYS/A
SYARIKAT POLYKIM SON. BHD. - MALAYS/A
- SYARIKAT UNITED CHEMICAL INDUSTRIES - MALAYSIA
SYRENE HOLDINGS (M) SON. BHD. - MALAYSIA
TAH U THONG FOAM INDUSTRY - SINGAPORE
TAKEDA CHEMICAL INDUSTRIES LTD. - ;APA,V
TEKCO TRADING CO. - MALAYS/A
fONC HEUNG ELECTRIC CO. LTD. - KOREA
fOSOH CORPORATION • JAPAN
TSUANG HINE CORP. LTD. - TAIWAN ROC
U-FOAM - INDIA
URATEX PHILIPPINES - PHILIPPINES
VINYLEX (M) SON. BHD. - MALAYS/A
HIGH DENSITY
South/Central/North America
DAVIDSON EXTERIOR TRIM TEXTRON - USA
FYPON, INC - USA
MARLOCK, INC - USA
INTEGRAL SKIN
South/Central/North America
A.M.E. CORP. - USA
^ABBA RUBBER CO., INC - USA
ADAPT PLASTICS, INC. - USA
ADVANCED FOAM AND PLASTIC CO. - USA
ATLANTIC THERMOPLASTICS CO, INC - USA
BASF CORPORATION - USA
BONDED PRODUCTS, INC - USA
• BOYD CORPORATION - USA
& CALIFORNIA URETHANE - USA
CHIVAS PRODUCTS LIMITED HEADQUARTERS - USA
fr COMCAST URETHANE COMPANY - USA
CONITRON - USA
CREATIVE URETHANES, INC • USA
DAYTON POLYMERIC PRODUCTS, INC. - USA
DOVE PRODUCTS, INC - USA
E. R. CARPENTER CO. - USA
EVERGREEN MOLDING - USA
FLEXAN CORP. - USA
FLEXIBLE INDUSTRIES - USA
FRANK LOWE RUBBER & GASKET CO, INC. - USA
FREUDENBERG-NOK - USA
G-FORCE AERODYNAMICS - USA
G. T. SALES & MANUFACTURING, INC. - USA
<&GP\ CORP. - USA
GRIFFITH POLYMERS, INC - USA
HEDSTROM CO. - USA
HERMAN MILLER - USA
ILLINOIS INSTITUTE OF TECHNOLOGY - USA
-y IN1ECTEC LTD. - USA
KALAMAZOO PLASTICS CO. - USA
KEMCO PLASTICS - USA
KERN FOAM PRODUCTS CORP. - USA
KRYPTONICS, INC - USA
KURTH INTERNATIONAL - USA
KUSTOM FOAM MFG.. INC. - USA
LUDWIC, INC. - USA
THE
KDITTRY DIRECTORY
«inrr
-------
FINISHED GOOES MANUFACTURERS
PRODUCT CROSS REFERENCE
MANCHESTER PLASTICS - USA
MANDRELS INCORPORATED • USA
MARCHEM CORPORATION - USA
MARCHEM DU8LON, INC - USA
•* MATERIALS TECHNOLOGY ASSOCIATES - USA
if MERAMEC CROUP, INC - USA
MILFOAM CORPORATION - USA
MILSCO MANUFACTURING CO. - USA
MINNESOTA RUBBER - USA
<£ MODERN TOOLS • USA
NORTH CAROLINA FOAM INQUIRIES. INC - USA
PAGE BELTING CO. - USA
POW-R-TOW, INC - USA
PRINCE MASTERCRAFT, INC. - USA
PURETHANE. INC. - USA
REISS INDUSTRIES, INC - USA
RENOSOL CORPORATION - USA
* ROGERS CORPORATION - USA
ROMEO RIM, INC - USA
SCCI CORP - USA
SCOTT PORT-A-FOLD, INC - USA
SEARS MANUFACTURING CO. - USA
SSF MOLDERS, INC - USA
STEPHENSON & LAWYER, INC - USA
T?TANDEM PRODUCTS INCORPORATED - USA
TECNIFOAM - USA
TEMPRESS, INC - USA
UNIQUE URETHANES, INC - USA
URETHANE ENGINEERING CORP- - USA
WEAVER INDUSTRIES, INC - USA
WE1N8RENNER SHOE COMPANY, INC - USA
Europe/Middle East/Africa
AARSLEV POLYMERE IND, AS - DENMARK
ASTRAL! ACCESSORIES - UK
BRINSEA PRODUCTS LTD. - UK
FIBRE FOAM LTD.-UK
HAIRLOK LTD. - UK
JARRI PLASTIC INDUSTRIES LTD. - ISRAEL
LAITOSJALKINE OY - FINLAND
MIDLAND INDUSTRIAL PLASTICS LTD. - UK
RECTICEL INTERNATIONAL - BELGIUM
SPUMOTIM, SA - ROMANIA
TANEX, PLASTY AS - CZfCHOSIOVAJWA
TECNODENT SPA - ITALY
Asia/Pacific Rim
AMIT POLYSEATS (P) LTD. - INDIA
CAMATIC-AUSTRALIA PTY. LTD. - AUSTRALIA
HENDERSON'S PLASTICS PTY. LTD. - AUSTRAUA
HYUNDAI MOTOR CO. - KOREA
INOAC CORPORATION - JAPAN
INOAC CORPORAHON -JAPAN
POLYFOAM-RCC INTERNATIONAL CORP. • PHILIPPINES
PT. DASA WINDU AGUNG - INDONESIA
RIMCO PTY. LTD. - AUSTRALIA
SEDA CHEMICAL PRODUCTS CO. LTD. - TAIWAN ROC
SHANGHAI YAN FENG MACHINE MOULD FACTORY - PRC
TAKEDA CHEMICAL INDUSTRIES LTD. -JAPAN
TOSOH CORPORATION -JAPAN
U-FOAM - INDIA
URATEX PHILIPPINES - PHILIPPINES
MICROCELLULAR
South/Central/North America
ATLANTIC POLYMERS & PRODUCTS - USA
BOTTOMS USA, INC - USA
CALCODOS SAMELLO. SA - BRAZIL
CALVOYOASA-CH/tf
COMCAST URETHANE COMPANY - USA
CUSTOM MATERIALS, INC - USA
ENDICOTT JOHNSON - USA
FALCON SHOE MFC COMPANY - USA
JAMES H. RHODES & COMPANY - USA
JONES & V1NING - USA
KINGSLEY MFC COMPANY - USA
KNAPP SHOE-USA
LACKS INDUSTRIES • USA
PARKWAY PRODUCTS. INC - USA
POLY FLEX INC-USA
ROGERS CORP. WILUMANT1C DIVISION - USA
USA DRIVES, INC -USA
WINFIELD INDUSTRIES, INC - USA
Europe/Middle East/Africa
CABER ITALIA SPA - /TAIY
LA GEAR-UK
NIKE (UK) LTD. - UK
MILLABLEGUMS
South/Central/North America
AK RUBBER PRODUCTS CO.. INC - USA
ALEXANDER RUBBER PRODUCTS - USA
APEX MOLDED PRODUCTS CO. - USA
COATED FABRICS GROUP, INC - USA
CONNECTICUT RUBBER MOLDING CORPORATION - USA
FOULKE RUBBER PRODUCTS, INC - USA
NATIONAL O-RING - USA
RHEIN-CHEMIE CORPORATION - USA
SCULLY RUBBER MANUFACTURING INC. - USA
406
Tli£ POLYVRETIUVE INDUSTRY D«EC7ORY \KD BUYER'S GLIDE
-------
ffj /jf JnCOrDOTdtCd Environmental Consulting and Research
MEMORANDUM
Date: June,17, 1996
Subject: Subcategorization of the Flexible Polyurethane Foam
Source Category •
Prom: Amanda Williams, EC/R Incorporated
Phil Norwood, EC/R Incorporated^/ . .
To: • David Svendsgaard, EPA/OAQPS/ESD/OCG
The purpose of this memorandum is to present information
related to the subcategorization of the flexible polyurethane
foam production source category. The first section identifies
criteria for subcategorizing a source category, the second
section presents brief descriptions of the flexible polyurethane
foam operations, and the third section presents discusses the
application of these criteria to the source category.
SUBCATEGORIZATION CRITERIA
Subcategories, or subsets of similar emission sources within
a source category, may be defined, if technicial differences in
emissions characteristics, processes, control device
applicability, or opportunities for pollution prevention exist
within the source category.1 Specific examples of these .
•differences include the types of products, process equipment
differences, the type and level of emission control, emission
sources, and any other factors that would impact a maximum
achievable control technology (MACT)- standard.
Four types of flexible polyurethane foam processes were
identified. These are slabstock foam production, molded foam
production, slabstock foam fabrication, and rebond foam
production. Each process will be discussed briefly below. More
1 Federal Register. Vol. 57, No. 137. Initial List of
Categories of Sources Under Section 112 (c) (1) of the Clean Air
Act Amendments of 1990. '
3721-D University Drive • Durham, North Carolina 27707
Telephone: (919) 493-6099 . Fax: (919) 493-6393
-------
complete descriptions of these processes are in the industry
description memo.2
PROCESS AND HAP EMISSION DESCRIPTIONS
This section briefly describes the molded, slabstock,
fabrication, and rebond processes, including the main hazardous
air pollutant (HAP) emission points, as well as a brief
discussion of flexible polyurethane foam chemistry.
Polyurethane Fbam Chemistry
Flexible polyurethane foam is produced by mixing three major
ingredients: a polyol polymer, an isocyanate, and water. The
polyol is either a polyether or polyester polymer with hydroxyl
end groups. The second key ingredient in the foam formulation,
the diisocyanate, links polyol molecules to produce the foam
polymer. The diisocyanates used in flexible foam production are
primarily toluene diisocyanate (TDI) and methylene diphenyl
diisocyanate (MDI). Typically, TDI used in foam manufacture is a
mixture of the 2,4- and 2,6- isomers, with the ratio being
80 percent 2,4- and 20 percent 2,6-. TDI is used primarily in
slabstock production and MDI is used primarily in molded foam
production. However, neither slabstock producers nor molded foam
producers use one isocyanide to the exclusion of the other.
Surfactants and catalysts are also added to the mixture. The
surfactants aid in mixing incompatible components of the reaction
mixture, and also help control the size of the foam cells by
stabilizing the forming gas bubbles.
When the polyol, diisocyanate, and water are mixed, two main
polymerization reactions occur. Most importantly, isocyanate
groups react with hydroxyl groups on the polyol to produce
urethane linkages (hence the term polyurethane). The other main
reaction is that of the isocyanate and water. The initial
product of the reaction with water is a substituted carbamic
acid, which breaks down into an amine and carbon dioxide. The
amine then reacts with another isocyanate to yield a substituted
urea linkage. The CO2 formed in this reaction acts as the
"blowing agent" and produces bubbles, causing the foam to expand
to its full volume within minutes after the ingredients are mixed
and poured. The final polymer is composed of the urethane and
urea cross-linkages formed in the isocyanate/polyol and
isocyanate/water reactions.
2 Memorandum. Williams, A. and Battye, W., EC/R
Incorporated, to Svendsgaard, D., U.S. Environmental Protection
Agency. Flexible Polyurethane Foam Industry Description.
June 19, 1996.
-------
Slabstock Polyurethane Foam Production
Flexible slabstock foam is produced as a large continuous
"bun" that is cut into sections with the desirable dimensions.
The raw ingredients are pumped to a mixing head and discharged
through the nozzle onto the front of a conveyor belt, called the
foam line. The conveyor first passes through an enclosed,
ventilated "tunnel," where the ingredients react quickly to form
the foam bun. From the point of its maximum expansion, the foam
begins to release blowing agents and unreacted chemicals. These
chemicals are exhausted from the enclosed section. As the bun
leaves the conveyor, it is sawed into smaller sections and
transported to a curing area, where the remainder of the blowing
agents leave the bun.
The major HAP emission source at slabstock facilities is
from the use of methylene chloride (MeCl2) as an ABA. Methylene
chloride's role is simply to volatilize and expand the foam, not
directly participate in the polyurethane reaction. Therefore,
all of the methylene chloride that is added eventually is
emitted. Approximately 40 percent of the methylene chloride
emissions occur before the cutoff saw and another 20 percent are
released during foam transfer. The remaining 40 percent is
emitted in the curing area.
HAP's are also emitted through the use of HAP cleaning
solvents. Methylene chloride is used as a cleaner to rinse
and/or soak foam machine parts such as mixheads and foam troughs
at the end of a pour. There is hardened foam residues on the
trough, fall plates, and other equipment that must be removed
after each production run.
Molded Polyurethane Foam Production
Molded foam production uses somewhat different chemical
formulations from those used for slabstock production, although
the basic polyurethane foam reaction is the same. These foams
have higher densities than the slabstock flexible foams, and
therefore, seldom use an ABA. In contrast to the slabstock
process, the molding method is an intermittent batch process
where the raw ingredients are placed in a mold and allowed to
react.
The molded production line includes multiple molds, with each
mold consisting of top and bottom sections, joined by hinges.
The molds are mounted on a circular or oval-shaped track, with
the molds and tracks varying broadly in size from facility to
facility. The molds travel around the track, and the necessary
process operations are performed at fixed stations. The
following paragraph describes a basic molding cycle.
The first step in the molding cycle is the application of
mold release agent. This is a substance that is applied to the
mold to facilitate removal of the foam product. After the mold
release agent is applied, any special components to be molded
-------
into the foam, such as springs or reinforcing materials are
placed in the mold. The foam mixture is then injected into the
mold through a mix head, which injects a precisely measured
"shot" of raw material into each mold. There are two types of
mix heads used in the industry, high-pressure and low-pressure.
The two types of mix heads have different cleaning requirements,
resulting in a dramatic difference in overall emissions from the
process, which will be discussed briefly in the next paragraph.
The mold is then closed, and the polymerization reaction occurs,
producing a foam product that fills the mold. After curing for a
predetermined time, the molds are opened and the product is
removed. The mold is then cleaned and starts the circuit again.
After a foam piece is removed from the mold, it generally is
trimmed and inspected for tears or holes, and any tears and/or
holes are repaired. Repair operations are carried out at glue
stations, which may by equipped with local ventilation systems to
remove solvent vapors emanating from the glue.
Methylene chloride emissions for flushing of low-pressure
mixheads is the largest emission source for flexible molded foam
manufacture. With low-pressure mixheads, flushing is necessary
because the residual froth can harden and clog the mixhead or can
interfere with the necessary precision required of the volume of
the foam shot. Emissions from mold release agents is another
source of HAP emissions from molded foam. Traditional mold
release agents consist of a resin in a solvent carrier,
frequently methylene chloride or 1,1,1-trichloroethylene (methyl
chloroform), both HAPs. The carrier evaporates, leaving the
resin, which prevents the foam from sticking to the mold. If
repair of the molded piece is needed, scrap foam, or the original
piece that stuck to the mold, are glued to fill in the void. A
HAP-based adhesive may be used for this process, with the carrier
solvent being a HAP. The emissions occur when the solvent
carrier evaporates after the adhesive is applied.
Slabstock Foam Fabrication
As mentioned earlier, slabstock flexible polyurethane foam
is produced in large buns which are typically 4 feet tall, 8 feet
wide, and 50 to 100 feet long. Prior to being delivered to the
furniture manufacturer or other end-user, the large buns are
"fabricated" according to the end-use. The simplest type of
fabrication is to cut the foam into the desired shape by use of
specialized saws, by hand-cutting, or other techniques. However,
many customers desire foam products that are more "finished" or
complex. To produce such products generally requires the gluing
of foam-to-foam, or foam to some other material such as cotton
batting. The most commonly used adhesives are either methyl
chloroform based, or MeCl2-based.
Rebond Foam Production
Another flexible foam product that is sometimes produced on-
site at slabstock foam facilities is rebond. Rebonding is a
-------
process where scrap foam is converted into a material that is
used for carpet underlay and several other end-uses such as
school bus seats. The scrap foam may have been generated at the
facility from its slabstock operations, or may have been shipped
or bought from other foam facilities. The baled foam is "chewed"
into smaller pieces in a bale-breaker. The foam pieces then
through screens into a grinder where the scrap is converted into
3/4 to 3/8 inch pieces. These small pieces are loaded into a
blender, where a mixture of polyol and TDI is added. The foam
and binder mixture, and occasionally a dye, is poured into a
cylindrical mold, that is below floor level. This mold has a
central core so that there is a hole that runs the length of the
cylinder. Pressure and steam are applied to the mixture in the
mold, and then the roll is taken out of the mold and allowed to
cool or "set" for about 24 hours.
CONCLUSIONS
As is evident from the information presented in the
paragraphs above, the only characteristic that the flexible
polyurethane foam processes share is a similar chemistry between
the molded and foam production processes. While the foam
chemistry is analogous, the equipment, emission sources, and
control techniques are very different. Molded foam is
manufactured in a batch-type process, while slabstock is made in
a continuous method. The major emission source for slabstock
foam is from the use of an ABA, and there is no analogous
emission point for molded foam. The only significant HAP
emission point that the two segments share is equipment cleaning
(mixhead cleaning for molded), and the reasons for these
emissions, and the control technologies that could be used, are
very different.
-------
/j> IflCOTDOTdtCd Environmental Consulting and Research
MEMORANDUM
Date: June 17, 1996 . .
Subject:' Flexible Polyurethane Foam Model Plants
From: Amanda Williams, EC/R Incorporated
To: David Svendsgaard, EPA/OAQPS/ESD/OCG
This memorandum presents model plants for the flexible
polyurethane foam production industry. A model plant does not
represent any single actual facility, but rather it represents a
range of facilities with similar characteristics that may be
impacted by a standard. Each model plant is characterized in
terms of facility type, size, and other parameters that affect
estimates of emissions, control costs, and secondary impacts.
The model plants developed here will be used further in the
development of the Maximum Achievable Control Technology (MACT)
standard for the flexible polyurethane foam production source
category to analyze cost and environmental impacts, Control
options, and the final regulation.
The molded and slabstock segments of the foam industry were
treated separately in the development of the model plants. In
both cases, model plants were developed based on available
information including data in company responses-to the
Information Collection Requests (ICR's), observations made during
site visits, and information received from Polyurethane Foam
Association (PFA) representatives, vendors, manufacturers, and
foam producers. Information was also used from the Environmental
Protection Agency's (EPA's) report, "Flexible Polyurethane Foam
Emission Reduction Technologies Cost.Analysis.nl This report, is
hereafter referred to as the "Cost Report.." :
All 21 rebond facilities located at major source plant sites
reported emission controls that would be in compliance with the
proposed standards. It is estimated the remaining 31•rebond foam
facilities are area sources, and would not be subject to the
regulation. Therefore, since it is estimated that no rebond
facilities will be subject to the standard, no rebond model
plants were developed.
1 Flexible Polyurethane Foam Emission Reduction Cost
Analysis. EPA-453/R-95-Q11. U.S. Environmental Protection
Agency. September 1996.
3721-D University Drive • Durham, North Carolina 27707
Telephone: (919) 493-6099 • Fax: (919) 493-6393
-------
The first section of this memorandum provides a brief
background on emission points at slabstock and molded foam
production facilities. This is followed by tables presenting the
slabstock and molded model plants, and brief discussions of the
development of the model parameters.
POLYURETHANE FOAM PRODUCTION HAP EMISSION SOURCES
Flexible slabstock foam is produced as a large continuous
"bun" that is cut into sections with the desirable dimensions.
The raw ingredients are pumped to a mixing head and discharged
through the nozzle onto the front of a conveyor belt, called the
foam line. The conveyor first passes through an enclosed,
ventilated "tunnel," where the ingredients react quickly to form
the foam bun. From the point of its maximum expansion, the foam
begins to release blowing agents and unreacted chemicals. These
chemicals are exhausted from the enclosed section. As the bun
leaves the conveyor, it is sawed into sections and transported to
a curing area, where the remainder of the blowing agents leave
the bun. The major HAP emission source at slabstock facilities
is from the use of methylene chloride (MeCl2) as an ABA. HAP's
are also emitted through the use of HAP cleaning solvents.
Molded foam production uses somewhat different chemical
formulations from those used for slabstock production, although
the basic polyurethane foam reaction is the same. These foams
have higher densities than the slabstock flexible foams, and
therefore, seldom use an ABA. In contrast to the slabstock
process, the molding method is an intermittent batch process
where the raw ingredients are placed in a mold and allowed to
react. The major HAP emission source at molded facilities is
from the use of HAP solvents to clean, or "flush," the dispensing
mixhead. HAP's are also used in smaller quantities for many
other purposes at molding facilities such as the use of HAP-based
adhesives, and HAP-based mold release agents.
MODEL PLANT DESCRIPTIONS
Model plants for the flexible polyurethane foam industry,
and the rationale for their development, are presented below.
The discussion is separated into the slabstock and molded
segments of the industry.
Slabstock Model Plants
Operating and Emission Parameters
Five basic model plants were developed for the slabstock
segment of the industry, which are presented in Table 1. They
differ in the amount of foam produced and the amount of MeCl2
used (and emitted). The range of foam produced in each of these
models was determined by creating a frequency distribution of the
amount of foam produced by slabstock manufacturers. Within each
-------
CO
Oi
u
H
cu
E-
04
Q
i
§
M
E"
U
D
Q
O
tt
O4
U
O
H
CO
CO
Ed
u
C
a
0)
•o
£
c
a
a
(i
1
m
c
a
Cu
V
•o
i
N
JJ
10
CU
V
•o
o
1-1
JJ
c
10
cu
f-l
,1"!
o
£
a
in
rf
in
a
*
rt
a
<
n
09
M
O
rt
<;
NO PARAMETERS
H
3
M
g
o
n
o
vo
r4
A
in
f-i
0
(N
s's
H
I
0
CO
1 A
O •
00 r-l
A
O
«
A
f
t
0
A
1
O
A
I
O
oduction Range
nd tons/yr)
£S
E§
• -C
o
A rt "^SS0
""* *"* H M ^ w "^^5°
HH<*°MVO r4"00
rH d • f^ ^
vo o r»o
lHHSoiMKO " H S 5 °
H PI N m
^4 W W W
rtrHrt°M>° rtrtJ5S°
r-lrt«>0OUO flflU>00
iH M rt d
cu
£ 2
e S« S
" BO ua> c on
B a a. ti-H -H aa
2 EECrH^ee
C 3 3 3 V 33
g aa) ou •& a a,
5 wen^o TJ wen
fu tic au c «c
VM-HO)V3at> VU-HB
a M «i enca « i a M v
rj C U > C to > C C a >
(04Ji-ia4lr-lt) aWiH
u .^MDiai-IMIOQ, MOID
0.0 oHZ>Ilu0<>0wt
« u p
M O £ r4
3 «
2 M
2
-1
n
rt
H
M
3
A
V£>
f Line (ft/min)
o
•o
u
V
Q.
CO
0
0
o
I-l
o
l-t
o
r1
O
I-l
0
H
0
I-l
o
o
2
ectricity Use (kw)
rl
U
V
n
•H
j
«o
vo
09
•vo
.
in
o
vo
«
in
vo
A
in
to
PI
A
A
A
A
A
n
g
f4
a
en
o
o
o
r-l
TJ
O
O.U
< 4)
2z
o
A
A
O
A
A
O
«*
A
A
O
A
A
O
A
A
a
e
d as Cleaner (gallo
«
s-~
*-4
OjCJ
»
n
^
*
A
in
A
A
1*1
H
10
a
of Plants Represent
ide
3
U C
V O
JO -r4
t u
3 a
-------
o
bu
^
O
g
CO
03
i
10
0 O'n n)n
an 2 "* '"I0
"no -In
0 On n|n
3n gin "I"
~ n in -|»
O O *"* **n'f*
oT! Ss0«|~
olo 0 n n|n
2n 5 o inlch
"I n in -In
o ,-Jn n|n
an 2 in inlot
to o -ito
o ,-Jrt n|rt
an £m inlv
. to in Hf*
0 0rH n|rt
o'l" »«" o1^!01 '
olo 0' « nl-n
r||m Ot y,.
olo " "* i*J*°
m rj
C **
rj -5 w
CD C CB ^
^t « *8 J^ ^*
S|I SS-7
O C
e H c 'cz
« o i> »> u
DIE Dl E E
10 CU <0 QiQ.
S& jSg&l.
M COW y M rt M U
3 £
o o m n
n • f \o *
S » o m " ^ o
"» ° to" r." n
Pt rt <"l
0 ° . * * ™ S
« » * °1 " *~. ••
^ ® ^ \0 f^ n *
PI ^ M '^
0 2 « S
n « o « "1 « o
" H H PI
0 "* rt ** 0
_ — » » « 2
? « . « in ^_ »
M » to 2 ^
_ ft ft m
_ ° n r- o
S » ° t 1 T °
* n n n
_. to n OD o
^ ~ » n t» o in
>» » ^ 'I 'I ^ *.
* r« « n HI
it
W O
S ^ - s *
w v> a -H «
2 -o o u *»
5 c u «— •
M B M -W W M W
a. 3 C O « &•>»
2 o £ u o o«» •"
SiaAv rj 11 O
•"• « U <-)— --i— E— XC
9 S 9 SIS «>£ g^B "35 °
Hp! C^5C SC •«<-!
<< W U B U « Ofl 6u— •
H AJ AJO flO >O flu CU>i
SO OAJ OAJ CDAJ OO •«H
3 0- H- 3~ HO Q —
g .
1 1
8 ?
S £
S S
U w
& w
and 5 b«v« V
av«U*bU (
• 0
a 2
! •
l 1
M
o z c
fa h
* &**
A ftp
i si
° *• 1
9 Is-
1 l\
ill
5 | ".
S
: 1".
•« *
» :»
I >\
\ r
if
n *
C"
ki
O &
• 9
«I
« 5
u •
a:
i!
ai;
_55|
isa^
-------
production range, the average amount of foam produced was
calculated by averaging the production amounts for the "real"
plants represented by each model plant. For example, 19
slabstock facilities reported annual foam production less than
4,000 tons per year. This was the production range selected to
characterize model plant 1. The total foam produced by these 19
facilities was around 40,500 tons per year, yielding an average
facility production of just over 2,000 tons per year. This
average production value was selected to represent the annual
production of Model Plant 1.
Although approximately 25 percent of the foam plants in the
industry reported having more than one line, there was no
correlation identified between the amount of foam produced and
the number of lines at the facility. Therefore, each model plant
has only one production line. The speed of the line and the
electricity used represent operating parameters for a typical
Maxfoam line.
While the size of HAP storage vessels at slabstock
facilities varies, the model plant storage tank sizes were
assumed to be consistent for all model plants. The tank
capacities represent typical tank sizes for the industry. The
number of tanks was based on actual numbers reported in the ICR's
from actual plants in each size category. Only 16 facilities
reported using vapor balance (VB) to control MeCl2 storage and
unloading emissions, and 27 reported using VB to control TDI
emissions. Therefore, model plants 1 and 2 have no controls for
storage or unloading, model plant 3 has emission controls for TDI
only, and 4 and 5 have controls for both TDI and MeCl2.
The number of HAP pumps was calculated assuming one transfer
pump per storage vessel,-and one metering pump per chemical. The
other types of components were estimated using the following
component to pump ratios: 8:1 for valves, 10:1 for flanges
connectors, and 3:1 for open-ended lines. The number of MeCl2
pressure relief valves was calculated assuming one valve per
pump. It was assumed that all TDI systems were closed with no
pressure-relief valves. Some slabstock facilities reported using
canned pumps, a type of sealless pumps to eliminate leaks. For
the model plants it was assumed that for model plant 2, 3, and 4,
have canned pumps for all TDI transfer pumps, and model plant 5
has canned pumps for MeCl2 and TDI transfer. According to
industry representatives, canned pumps can not be used for
metering due to the high pressure requirements.
As mentioned earlier, the use of a HAP (usually MeCl2) as an
ABA is the primary source of HAP emissions at a slabstock foam
facility. However, the amount of ABA needed varies considerably
depending on the "grade" of the foam being produced. During the
development of the Cost Report, the EPA worked with a group of
PFA representatives to develop foam grades and formulations for a
"representative" slabstock facility. Each slabstock model plant
-------
presented in this memorandum incorporates the same grades and
formulations as the representative plant from the Cost Report.
The grades produced by the model plants represent the most
commonly produced grades in the industry, and the formulations
are based on ICR responses and input from PFA representatives.
The grade-specific information for each major model plant is
presented in Table 2.
For each of the five model plants, the average facility HAP
ABA usage was determined using information from the real
facilities represented by the model plant. The amount of each
grade of foam produced by the model plant was adjusted so that
the total annual HAP ABA usage for the model plant equaled the
average of the real plants. All HAP ABA used was assumed to be
emitted. Storage emissions were calculated using AP-42 emission
factors for chemical storage tanks.2 Emissions from components
in HAP service (e.g. pumps, valves, flanges, etc.) were
calculated using SOCMI average emissions factors.3
Thirty-three percent of the slabstock facilities reported
the use of MeCl2 as a general equipment cleaner, including
facilities represented by all five model plants. However, no
correlation was found between the use of a HAP cleaner (or the
amount of HAP used as a cleaner) and the amount of foam produced.
Therefore, each of the five model plants were separated into two
smaller model plants (i.e., 1A and IB), with one using MeCl2 as a
cleaner, and the other employing cleaning methods that did not
use a HAP. One-third of the nationwide facilities represented by
each of the five model plants were assigned to the smaller model
plant that uses a HAP cleaner. An average MeCl2 usage rate was
determined for those facilities reporting its use as a cleaner,
and this average rate was applied to each model plant that used a
HAP cleaner, regardless of size.
For those model plants using a HAP cleaner, it was assumed
that 90 percent of the MeCl2 used as a cleaner is eventually
-emitted. The 10 percent was assumed to be contained in the
solid/liquid waste from the cleaning process that is collected
and discarded as hazardous waste.
Cost Parameters
Because many of the emission reduction technologies that
will be studied for the slabstock industry will involve process
changes or other pollution prevention techniques, it is necessary
2 Compilation of Air Pollutant Emission Factors. AP-42.
U.S. Environmental Protection Agency.
3 Protocol for Equipment Leak Emission Estimates.
EPA-453/R-93-026. U.S. Environmental Protection Agency. June
1993. Table 2-10.
-------
to
E
£
|H
c
0
•s
a
3
E
i_
o
IL
"c
2
d*
a.
"3
•o
o
c
.0
3
•a
O
OL
E
(8
o
U.
u
2
M
•8
03
CM
—
a
K-
tr
CO
c
Q
•a
2
E
o
E c
g <
CO rn
m <
at
as
M
3
0
CO
2
•c*
"2?
o
•o
CD
U
TJ
o
a.
E
o
u.
.c
M
0
CD
2
in
2
^
2
eo
Q_
CM
q^
,_
Q.
2
in
Q.
a.
CO
a.
CM
a.
2
£
^
~ ^
(0 "5
"5 a.
1-
•2 a
^*^
Q S?
u_ in
— CM
*••»
a "*!
Q
CO
TJ
^
OO^in^-N^CncOCOCO
raCMCMT-CM^-CMCOCM *-
rx.incoT-incMcooocoinco
COCMi-i-CMCMf-CMi- CM
oooKoooi^of.00
S^CO^CMSS^^^^^CM
OCOCOCMOCOCOOCO^fr'tO
CDh.«t-CMOI^OCOCMCMO
cocnenh»ococococMcococo
min I^CO^COCMCOCMOOCO
oooooooooooo
in-r-r-'t-int-incnininini-
oooooooooooo
§00000000000
ooooooooooo
COCOOOCMinCMCOinOCMCOCO
oooooooooooo
tOlCNJCMTj-CMOOOOOOOOOCM
oooooooooooo
^^cn^eo^i^incocMCM^
oomooooooooo
oomooooooooo
52
^
v»
0
CO
CO
't
CD
^
O
CO
0
0
3
8
o
co
o
o
in
!•«. CO
CM CO
CM in
en in
I". N.
CO CM
CO *
^ CM
CO CO
t- 0
O 0
m in
o en
o o
en eo
CO CO
0 0
o o
in <»
0 0
CO CO
nfn
\j
O O
CM CM
CM T-
O O
in co
o o
m CD
CO
CO
in
in
r-
CM
•«*•
CM
CO
O
o
in
en
0
CO
CO
o
o
CO
CO
o
CM
,_
O
0
Is-
CO O)
in o
CM CM
eo o
r* in
CM t-
h- O
CO T-
CM T-
o co
CM CO
^™
O CM
t CM
§s
co m
0 0
0 O
o o
^- eo
0 O
CO CO
1~ T»
CO CO
O CO
T-
o o
CM eo
CO CO
0 0
CM CO
CO CO
o
o
o
o
0
o
o
o
o
o
o
CM
^»
o
CO
CO
o
o
CO
o
CO
0
CM
o
§
CO
0
CO
CO fx-
co m
CM
i- CD
en ^t
o eo
* eo
^t o
CO CM
CO N-
CM O
0 0
r>» CD
m co
o o
f- en
**• co
0 0
o o
co in
o o
CO O
*~ CO
o o
CO O
(V. y—
o o
CO t
en en
o o
CO *
en en
0
0
o
o
o
o
o
o
o
o
0
CO
CD*
o
£
co"
o
o
CM*
O
o
Lrt
**t
~™
0
o
in
o
in
CM
in
CM
o
CM
O
c^
A
0
D
CO
in
CO
CO
0
eo
CO
in
T"
in
in
"5
O
••»
-------
8
to include baseline operational costs for the model plants. The
costs developed include the total annual chemical costs, the
total annual chemical costs for ABA-blown foam, and the total
annual operating costs. In addition, baseline costs associated
with the use of methylene chloride as a cleaner were needed.
In the development of the Cost Report, the PFA chemical
alternative workgroup provided standard chemical costs for the
foam grades included in the representative facility. The costs
used include the cost of polyol, toluene diisocyanate (TDI), and
additives. These costs assumed the following raw chemical costs:
$0.50 per pound for polyol, $1.00 per pound for TDI, and $0.40/lb
for MeCl2.
The model plant chemical costs were determined by
multiplying the amount of each grade of foam produced by the
grade-specific chemical cost. The ABA-blown foam chemical cost
includes only those grades that use ABA. The total facility
operating costs were calculated using the common industry
assumption that the chemical costs make up 80 percent of a
facility's total annual operating costs.
The cost of MeCl2 for cleaning was determined using the
$0.40 per pound cost cited above. The disposal cost of MeCl2-
contaminated waste was calculated assuming an industry estimate
of $800 per 55-gallon drum.
Molded Foam Facilities
While the basic processes are similar at all molded foam
facilities, there are two different types of equipment used to
pour the foam that create large differences in their HAP emission
potential. The two types of equipment are low pressure (LP) and
high pressure (HP) mixheads. LP mixheads require a solvent flush
between foam shots to remove residual foam, while HP mixheads do
not. Consequently, HAP emissions from LP facilities are usually
significantly higher than emissions from HP facilities. All of
the molded foam major sources were LP facilities, and all of the
HP facilities were area sources.
Four molded foam model plants were developed, one with a HP
mixhead, and three with LP mixheads. They are presented in
Table 3 . Only one model plant was created for HP mixhead
facilities since the other parameters and HAP emissions were not
found to be linked to production. The LP model plants differ
mainly in the amount of foam produced, and the amount of HAP used
to flush. The foam production range was determined in the same
way as described above in the slabstock section, as was the
average annual foam production.
The number of lines or carrousels was not found to be linked
in any representative or replicatable way to the amount of foam
produced. Therefore, the average number of carrousels for HP and
-------
TABLE 3. MOLDED FOAM MODEL PLANT PARAMETERS
Operating Parameters
Foam production range
(tons/yr)
Average foam «
production (tons/yr)
Number of carrousels
Operating schedule
Type of mixheads
HAP flush amount
(55 -gal drums)
Waste MeCl2 from flush
(55-gal drums)
HAP mold release agent
amount (gal/year)
HAP repair adhesive
amount (gal)
HAP content of
adhesive
Number of facilities
represented nationwide
Emissions (tons/yr)
Emissions from HAP
mixhead flush/plant
Emissions from HAP
mold release/plant
Emissions from HAP
adhes ive /plant
Cost Parameters
Disposal cost of waste
MeCl2
Cost of HAP-based mold
release agent
Cost of HAP-based
adhesive
HP Model
Plant
0-15,000
3,331
2
16 hrs/day
250 days/yr
HP
0
0
0
581
70%
27
0
0
2.093
0
0
$4,939
LP Model
Plant 1
0-99
26
5
8 hrs/day
250 days/yr
LP
19
2
41
0
0
109
5.14
0.15
0
$1,600
$198
0
LP Model
Plant 2
100-499
308
5
16 hrs/day
250 days/yr
LP
72
8
32
0
0
54
19.69
0.12
0
$6,400
$154
0
LP Model
Plant 3
aSOO
2718
5
16 hrs/day
250 days/yr
LP
177
18
831
66
70%
44
21.31
6.0
1.35
$14,400
$4,005
$561
-------
10
LP facilities was calculated and applied to each plant
respectively. The operating schedule of actual facilities
represented by the model plants was examined, and a typical
schedule was determined for each type.
As mentioned above, LP mixheads require flushing to remove
residual foam from the mixhead. The HAP flush amount for each
model plant was calculated from the average emissions from HAP
flush for facilities represented by each model plant, multiplied
by 1.1, and the weight per gallon of MeCl2. The emissions were
multiplied by 1.1 because the emissions reported represent only
90 percent of the amount of MeCl2 actually used. The remaining
10 percent is unrecoverable from the solid/liquid mixture
collected at the bottom of the containers that capture the flush.
The amount of HAP mold release agent used was calculated
using the average emissions from HAP-based mold release agents
for facilities represented by each model plant, and the HAP
weight per gallon of the model mold release agent. The mold
release agent chosen was indicated by vendors to have a
representative HAP content (75 percent by weight) and density of
those used by many foam facilities. No facilities using HP
mixheads reported any HAP emissions from mold release agents,
therefore the HAP model plant uses none. The amount of HAP-based
repair adhesives was calculated in the same manner, using the
70 percent by weight HAP content.
Emission and cost parameters
The emissions from HAP mixhead flush, mold release agent,
and adhesives, were all calculated in the same manner. The total
emissions from the real facilities in each model plant category
were divided by the number of facilities reporting emissions from
each of the sources.
The cost parameters were all provided by vendors or industry
personnel, as being representative of costs by the industry. The
disposal cost of waste MeCl2 was based on a cost of $800 per
55-gallon drum. The HAP-based mold release agent, and HAP-based
adhesive were based on costs of $4.82 and $8.50 per gallon,
respectively.
-------
O
•3
to
E
ci
e
o
+n
a
3
E
b.
o
u.
c
SL
a.
0
•a
o
u
•o
o
CL
E
(0
o
u
o
w
CO
CM
2.
"L.
a
"C~
CO
C
2
TJ
E
0)
2?
•— c
o «
M <
« m
CO <
CO
(0
TJ
ffi
M
3
0
0)
S
-c-
"oT
O
0)
o
3
?
0_
E
to
o
u.
c
N
(J
0
*
c
o
CO
3
E
Q
II
t
Q
m
n
fL
eo
2
CM
n
^_
Q.
^
in
n
a.
CO
2
CM
Q-
2
n
a-.
>,
•3
Q.
x:
Q.
&
i?
in
CM
—_^-
«=•
Q,
CO
TJ
u.
O
o
CO
CO
^.
CO
CO
o
o
0
CO
CO
in
o
in
o
in
m
0
o
CO
o
s
o
CO
0
o
CO
.
o
o
CO
en
**
fs.
CM
in
o
CM
O
5
CO
r^
o>
in
o
en
0
o
0
CO
o
CM
O
CM
CM
O
O
O
0
eo
CM
CO
£
o
CO
CO
•«*•
en
*
o
en
o
o
0
00
5
o
en
in
0
in
o
r^ini-f^i^cncocococMh*cocococn
•t-CMT-CMCOCM T-1-T- CMCM
T-incMcooocoineo^tcMinmeoo
coNint^eomr^ineococninini^in
•i-CMCMT-CM'.- CMi- CM T-
i^oooNor^ooor^r^r-NO
coineoooco-r-CMtineococM-
T-CMi-i-i-T- CM CMt-
CMOOOCOO<0'4-
-------
fa /TD JnCOrDOTdtCd Environmental Consulting and Research
MEMORANDUM
Date: June 17, 1996 :
«
Subject: Baseline Emissions for the Flexible. Polyurethane Foam
Production Industry
From: Amanda Williams, EC/R Incorporated
Phil Norwood, EC/R Incorporated
To: David Svendsgaard, EPA/OAQPS/ESD/OCG
The purpose of this memorandum is' to present the baseline
hazardous air pollutant (HAP) emissions .for the" flexible
polyurethane foam production source category. Two basic.
mechanisms were used to generate the baseline emission estimates
presented in this memorandum. The first was to directly use
information submitted by industry in response to an information
collection request (ICR) distributed by the Environmental
Protection Agency (EPA) . However, in several instances the ICR -
responses did not contain adequate information to allow the
direct determination of baseline emissions. In these cases,
nationwide baseline emission estimates were extrapolated from the
ICR responses. • .
. This memorandum is organized into three sections. The first
.section gives a summary of the ICR responses. The second section
provides a discussion of how "model plants," and other data from
the ICR responses, were used to determine baseline emissions.
The final section presents the baseline HAP emissions for this
source category. The flexible polyurethane foam source category
has been divided into three subciategories: slabstock foam,
molded foam, and rebond foam. In each of the sections of this
memorandum, these subcategories are discussed separately.
SUMMARY OF INFORMATION COLLECTION. REQUESTS (ICRs)
A primary basis for baseline emission estimates for this
industry-was information submitted to the Environmental'.
Protection Agency (EPA) by the flexible foam manufacturers in
response to information collection activities conducted under the
EPA's Section 114 authority. In July of 1993, the EPA sent a
"generic" ICR, approved by the Office, of Management .and Budget
(OMB), to all identified slabstock and .molded foam producers.
The July 1993 questionnaire was designed to obtain production}
emission, and emission control information from the manufacturers
of flexible polyurethane foam. The following sections summarize
3721-D University Drive • Durham, North Carolina 27707
Telephone: (919) 493-6099 . Fax: (919) 493-6393
-------
the HAP emissions information reported in these responses. A
complete summary of the ICR responses is provided in a separate
memorandum. x
Slabstock Foam
The ICRs were sent to 87 foam facilities that were believed
to produce flexible slabstock foam. Information was received
from 78 of these facilities, with the other nine reporting that
they do not produce flexible polyurethane foam. For the majority
of the reporting facilities emission, production, and other
facility data were for 1992.
The total HAP emissions reported by these facilities was
16,748 tons per year. The main emission points for flexible
slabstock foam were HAP auxiliary blowing agent (ABA)," equipment
cleaning, chemical handling, and on-site rebond operations. The
HAP emissions for each of the emission points are provided in
Table 1. The table also presents emissions broken out into the
individual HAP for each emission point. Attachment 1 contains
reported HAP emissions for each slabstock foam facility.
Emission information was also provided for on-site
fabrication operations at slabstock foam facilities. However,
this information is not included in Table 1, or in any further
discussion of baseline emissions, because fabrication operations
have been designated a separate source category (61 FR 28197).
Molded Foam
ICR's were sent to 73 facilities that were believed to
manufacture flexible polyurethane foam. Eighteen of these
facilities responded that they did not manufacture flexible
polyurethane foam, and 10 facilities either did not complete an
ICR, or provided incomplete information. Completed responses
were received for 46 molded foam facilities (one slabstock
facility reported that they also had molded operations,
increasing the count). The reported HAP emissions from molded
flexible polyurethane foam producers totalled 269 tons. The
largest emission points for flexible molded foam were mixhead
flush and foam repair. The other reported emissions points were
chemical handling, foam dispensing, in-mold coatings, demolding,
and equipment cleaning. Molded foam facilities also reported
several other small emissions points that were combined and
reported as emissions from miscellaneous chemical handling or
miscellaneous foam production. These sources were reported
infrequently and resulted in small HAP emissions.
1 Memorandum. Norwood, P., Williams, A., and Battye, B.,
EC/R Incorporated, to Svendsgaard, D., U.S. Environmental
Protection Agency. Summary of Flexible Polyurethane Foam
Information Collection Requests. January 24, 1994.
-------
H
ij
m
"Jj
01
C
O
4J
01
C
o
•H
m
m
•rH
u
Reported HAP
&*
O *
o
Q
H
m °
^
f\t
rf
2
^ r*
(u «
3 4) 0)
.Q r-l 73
-H P^
£ 00
C 04
M
Methyl
Chloroform
r-i
u
a)
2
I-H n
1 1 Q,
0 S
M O 1 J3
CN
0)
VD £) ^
N ^ - ' 0
cH
H
in
ef> «> in oo
M H vo H
H
ro
*•
O
(N
H
O
H
CN
H
H
•*
rt
in
^*
H
03
VO
H
to
U) IT! 0)
CO) C
•H iJ -H
•O C C
(8 0) O (0
O > -H 0)
i-l iH 4J H
C n) O U
£3 ^3
T3 ^ 4J
,-1 -O 0 tt) C
(BO) C >-l < .C 0)
o en m a cq JJ E .n
•H n) rt, O ft i-5
e ^ ft £ -H 3
0) O 6 <8 3 H
JS 4J 3 0 & O
CJ W O< fci U i-i
§
4J
in
G
to
A
JJ
m
m
0)
0)
i-i
•a
a>
o
ft
v
to
o
-H
0}
n
-H
0)
-H
1
O
o
4J
0)
3
TJ
m
4J
o
-------
The reported HAP emissions for each of the molded emission
points are provided in Table 2. The table also presents
emissions broken out into the individual HAP for each emission
point. Attachment 2 contains reported HAP emissions for each
molded foam facility.
The ICR responses were received from only a fraction of the
molded foam industry. As discussed in a separate EC/R
memorandum2, there are now estimated to be 228 molded facilities
nationwide. Therefore, it was necessary to extrapolate the
information from the 46 molded foam ICR responses to obtain
nationwide baseline emission estimates. This extrapolation is
discussed in the next section.
Rebond Foam
Information was received from 21 rebond foam operations that
were co-located at slabstock production facilities. The total
reported emissions from these rebond operations was 11 tons per
year. Ten of these tons were methylene chloride (MeCl2) and one
was toluene diisocyanate (TDI). The MeCl2 emissions were
reported from a single facility, which has since reported that
the use of this HAP has been discontinued.3
THE USE OF MODEL PLANTS AMD OTHER INFORMATION TO DETERMINE
BASELINE EMISSIONS
As discussed earlier, there were several instances where the
direct use of the ICR response data as the nationwide baseline
emissions was not appropriate. Therefore, it was necessary to
use the available information to estimate nationwide baseline
emissions. Two different methods were used: the extrapolation
of model plant emission estimates for primary emission sources,
and extrapolation of ICR emission estimates for minor emission
sources.
Model Plants
The molded and slabstock segments of the foam industry were
treated separately in the development of the model plants. In
both cases, model plants were developed based on available
information, including data in company responses to the ICRs,
2 Memorandum from Williams, A., EC/R Incorporated, to
Svendsgaard, D., U.S. Environmental Protection Agency. Flexible
Polyurethane Foam Molded Plants: New Count and Nationwide Model
Plant Representation. November 3, 1995.
3 Memorandum. Williams, A. and Norwood, P., EC/R
Incorporated, to Svendsgaard, D., U.S. Environmental Protection
Agency. Summary of November 28, 1995 Environmental Protection
Agency/Ohio Decorative Products Meeting. May 31, 1996.
-------
i
TT
m
o
ii
m
C
0
-H
tn
0}
's
W
CU
•o
0)
o
o.
0)
a
0)
.c
jj
0
a>
C
0)
3
rH
O
O
C
a
-H
"O
c
H
H
g
M
§
g
o<
u
0)
rH O
(B -
JJ O4
£2
4)
u
I
c
o
-H
m
-H
1
rH fl '*' f«) Ul r°
1111° ° 1 ° • • 1 ° 1
0 0 0 ° ° 0
£j O\ d rH fH
Illl II •!•••!
0 0 M 0 0
iH H , H _-
0 I I ° I l "! , I ° • *. •
00 VO Q 0
S VO VO
1 1 1 l t l l 1 1 •• 1 1
o n H
C^r1^«o o , , o , o , «
°'0'^°o ^''o'c'0
ro Q tn en c
C (8 (fl > < C -H
•HOUrH CJ3 -H C
rHiHOnt O 0)0) JJ (0
•OGJJ> -H 30 (fl 0)
C ID co jj en i— i (8 o rH
(^ *rj pQ U C &4 O 01 CJ CJ V4
XrHrHfi.X 3'H rHfi -H
(0 (0 (0 d *O CQ t3 0) *^ ^3 AJ (fl
rHUO « OCCTJOSTlrH CCU
(C -H -H tO H • J-l 4) 4) rH 0 • 0) 4)
U £ 6 fSt (j PJ pt r^ *Q O £ O 0 P^ jQ
-H a) a) E X to to !«; -H E i o a ,J
^CJUO-QS «Q22QH2g)gH
U b EL) b H
H1
•H
OD T3
§§
JJ O
^1
in
o O
O JJ
o 0)
a
si m
JJ rH
It)
ffl JJ
0) O
0) J->
rH
O
0) JJ
fe
«) T3
JJ
3 JJ
A O
o
&
a>
O
U
O
CO RS
C 0)
O -H
m
•H m
£ H
0) 0)
-------
observations made during site visits, and information received
from Polyurethane Foam Association (PFA) representatives,
vendors, manufacturers, and foam producers. This extrapolation
of model plant emissions to determine nationwide baseline
emissions is discussed below.
Slabstock Foam
The slabstock model plants were used in two ways to
determine natipnwide emissions. For HAP ABA emissions and
equipment cleaning, it is believed that the information provided
in the ICR responses accurately represents the nationwide
emissions. In these cases, the combination of model plant
baseline emissions and the estimate of the number of facilities
represented by each model plant were determined so that the
nationwide emissions calculated from the model plants matched the
ICR responses as closely as possible. Since the regulatory
alternative impacts are determined on a model plant basis, the
nationwide baseline emissions are based on the these estimates.
Table 3 shows the calculation of nationwide baseline HAP ABA
emissions. For HAP ABA emissions, the total reported HAP
emissions were 16,551 tons/yr. This consisted of MeCl2, methyl
chloroform, and propylene oxide. It is assumed that the use of
methyl chloroform as an ABA will be phased out, and replaced by
MeCl2 at baseline. Propylene oxide is contained in very small
amounts as a stabilizer in MeCl2/ and was not included in the
baseline emission estimates. Therefore, the only HAP ABA
emissions in the slabstock foam model plants are MeCl2, and the
nationwide total calculated from the is 16,250 tons/yr.
The calculation of nationwide baseline equipment cleaning
emissions was calculated in a similar manner. The total reported
emissions from this source was 135 tons/yr, with 25 of these tons
HAP's other than MeCl2. For the purpose of the baseline emission
estimate, it was assumed that all HAP emissions from equipment
cleaning were MeCl2 • All model plants were assumed to emit
5 tons MeCl2 per year for equipment cleaning, and it was assumed
that 26 facilities use MeCl2 as an equipment cleaner (6 MP1,
9 MP2, 5 MP3, 4 MP4, and 2 MP4). Therefore, the total baseline
HAP emissions from equipment cleaning is 130 tons/yr.
The ICR responses were not relied upon for baseline HAP
emissions from storage/unloading and equipment leaks. For these
sources, model plant emission estimates were calculated using
standard EPA emission estimating techniques. These model plant
estimates were multiplied by the number of actual facilities
represented by each of the model plants to obtain nationwide
4 Memorandum from Williams, A., EC/R Incorporated, to
Svendsgaard, D., U.S. Environmental Protection Agency. Flexible
Polyurethane Foam Model Plants. June 17, 1996.,
-------
TABLE 3. NATIONWIDE HAP ABA EMISSIONS CALCULATED
FROM SLABSTOCK FOAM MODEL PLANTS
Baseline HAP.
ABA Emissions
(tons/yr)
Number of
Facilities
Represented
Total HAP ABA
Emissions for
Model Plant
{ tons/yr)
Total
Nationwide HAP
ABA Emissions
(tons/yr)
Model Plant
1
55
19
1,045
2
165
28
4,620
3
330
14
4,620
4
335
11
3,685
5
380
6
2,280
16,250
estimates, which are in Table 4. More details on how these
emission estimates were calculated follows.
Storage and unloading. Storage and unloading emissions were
reported by some facilities in the ICRs. Because the majority of
storage tanks at foam facilities are located indoors, where
temperature is controlled, it was assumed that breathing loss
emissions were minimal. For the model plants, unloading (working
loss) emissions were calculated using AP-42 emission factors for
chemical storage tanks.5 Since some model plants assume storage
tank controls, the baseline HAP emissions consist of a
combination of controlled and uncontrolled emissions. This is
described in detail in the model plant memorandum cited earlier.
Equipment leaks. Emission information was submitted in the
ICR responses for pumps and valves. However, the assumptions
made in calculating these emissions (discussed below) were
inconsistent with typical EPA assumptions, and no information was
received for other components in HAP service (flanges/connectors,
open-ended lines, or pressure relief valves). Therefore, model
plant emissions from components in HAP service were calculated
using assumed component counts and synthetic organic chemical
5 Compilation of Air Pollutant Emission Factors. Volume I:
Stationary Point and Area Sources. 5th Edition. U.S.
Environmental Protection Agency. January 1995. Section 7.
-------
TABLE 4. NATIONWIDE SLABSTOCK STORAGE/UNLOADING AND
EQUIPMENT LEAK EMISSIONS CALCULATED FROM MODEL PLANTS
Emission Source
S t oracre /Unloadina
MeCl2'
TDI
Storage /unloading total
Equipment Leaks
MeCl2
Pumps
Valves
Flanges /connectors
Pressure relief valves
Open-ended lines
Total MeCl2
TDI
Pumps
Valves
Flanges /connectors
Pressure relief valves
Open-ended lines
Total TDI
Equipment leak total
Annual Nationwide
Emissions (tons/yr)
17
0.03
17
58
48
27
157
8
298
16
4
0
0
0
20
318
manufacturing industry (SOCMI) average emission factors.6 The
nationwide estimates were then calculated by multiplying the
model plant emissions by the number of facilities represented by
each model plant.
There is a significant difference in the reported pump and
valve HAP emissions from the ICR responses and the baseline
6 Protocol for Equipment Leak Emission Estimates
(EPA-453/R-93-026). U.S. Environmental Protection Agency.
Table 2-10.
-------
emissions estimated from the model plants. The primary reason
for this difference is that when the facilities did report
emissions for these components, they used hours of actual pouring
per year in the emission calculation (typically between 600 and
800 hours per year). The model plant emissions were calculated
based on 24 hours per day, 365 days per year (8760 hours per
year), because the potential for leaks is present whenever HAP
liquids are present in the equipment, not just when liquid is
flowing through the line.
«
Molded Foam
As noted earlier, ICR responses were received from only 46
of the estimated 228 nationwide molded foam facilities.
Therefore, it was necessary to extrapolate information from these
facilities to approximate nationwide HAP emissions. Two
different methods were used to accomplish this estimation. The
first was to calculate nationwide emissions using model plants,
as discussed below. The second was to extrapolate directly from
the ICR response totals, as discussed in the next section.
Emissions from three sources were consistently reported by
all molded foam producers. These sources were mixhead flush,
mold release agents, and adhesives used in foam repair. It was
therefore assumed that these sources were common to all molded
facilities. Due to this fact, as well as the fact that these
were the only emission sources where control was reported, these
were the only three emission sources included in the molded foam
model plants.
The model plant emissions were calculated by dividing the
total emissions from the reporting facilities represented by each
model plant by the number of facilities reporting emissions from
each of the sources. These emissions were then multiplied by the
number of facilities represented by each model plant to obtain
the nationwide baseline emission estimates shown in Table 5.
Other Information
There were many other small HAP emission sources identified
in the ICRs. However, the emissions were very small, and the
occurrence of the emission points was too inconsistent to
accurately create a model for these emissions. Therefore,
baseline HAP emissions were estimated by direct extrapolation of
the emission information reported in the ICR responses. This
extrapolation was based on the percentage of facilities reporting
emissions from each emission source, and an assumption that the
same percentage of the remainder of the industry would also
report comparable emissions from the same source. An example of
this calculation follows.
The 6.3 tons per year of HAP emissions from in-mold coatings
shown in Table 2 were reported by three facilities, or
-------
10
TABLE 5. NATIONWIDE MOLDED MIXHEAD FLUSH, MOLD RELEASE
AGENT, AND REPAIR ADHESIVE HAP EMISSIONS CALCULATED FROM
MODEL PLANTS
Emission Source
•f
Mixhead flush
Mold release agent
Repair adhesives
Annual
Nationwide
Emissions
(tons/yr)
2,561
287
116
6.5 percent of the total reporting facilities (3 -5- 46) . To
estimate nationwide emissions, the average facility emissions
(2.1 tons/yr) were multiplied by 6.5 percent of the estimated
nationwide facility population, as follows.
•"nationwide
= ( 2.1 tons/year} (228 faci2ities) (6.5%) = 3i tons/yr
facility
The nationwide baseline estimates calculated in this manner are
summarized in Table 6.
The 21 rebond facilities co-located with slabstock
production facilities reported a total of 1.0 tons per year of
HAP emissions. As noted earlier, one facility originally
reported emissions from a HAP-based mold release agent and a HAP
cleaner, but it has subsequently discontinued the use of these
products. Therefore, the total nationwide HAP emissions from the
production of rebond foam is 2.5 tons per year, which is a linear
extrapolation of the emission estimates for the 21 facilities to
the estimated 52 nationwide facilities.
BASELINE HAP EMISSIONS
The baseline HAP emission estimates, determined as described
in previous sections, are shown in Tables 7 and 8. Table 7
presents baseline emissions for slabstock polyurethane foam
production, and Table 8 presents baseline emissions for molded
foam production.
-------
11
TABLE 6. BASELINE HAP EMISSIONS FOR MOLDED FOAM PRODUCTION
CALCULATED BY DIRECT EXTRAPOLATION OF ICR RESULTS
Baseline Total HAP
Emission Source , Emissions (tons/yr)
Chemical Unloading/Storage 10
Equipment Leaks ' 55
Day Tanks 25
Foam Production
Dispensing 67
Demolding 12
In-mold Coating 32
Other Production 11
Equipment Cleaning 10
-------
12
TABLE 7. BASELINE HAP EMISSIONS FOR
SLABSTOCK FOAM PRODUCTION
Emission Source
«
Chemical Storage/Unloading
Equipment Leaks
Foam Production
ABA
Other
Equipment Cleaning
On- Site Rebond
TOTALS
Baseline HAP Emissions
(tons/yr)
Total
HAP'S
17
318
16,250
9
130
11
16,735
Individual
MeCl2
17
298
16,250
-
130
10
16,705
HAP'S
TDI
O.Oa
20
-
9
-
1
30
-------
13
TABLE 8. BASELINE HAP EMISSIONS FOR MOLDED FOAM PRODUCTION
Baseline Total HAP
Emission Source Emissions (tons/yr)
Chemical Unloading/Storage 10
Equipment 'Leaks 55
Day Tanks 25
Foam Production
Dispensing 67
Mixhead Flush 2,561
Mold Release Agent 287
Demolding 12
In-mold Coating 32
Other Production 11
Equipment Cleaning 10
Foam Repair 116
TOTAL 3,186
-------
£<
3 "**
o
o
p
o
O
a
P
d
p
o
ss
d 6
p p p p
o o d d
p
d
p p
d d
§82
odd
<*>MC'»rno4'fl;-^vO(--pp — «••-«««_• — p p rM p
oooododddddddddddddddddci
O
U.
U!
U
CO
03
0
S
Oi
E
•5 "o
I
>
u S
< S
II
o y
is
5 2!
u
II
co v> — »•«
O
a.
u
as
< , s
1 2«*.2
-------
15!
o =
u
e
(fl
CO
f c
H o
u
<
,
c
o
OS
O
S3
OS
u
I
q q q
odd
dddd
.JS
(5
u
5-0
2°
1i
p
o
o
o
o
d
o o
q q
d d
q rn
d d
O «M
q q
d d
dddddddddddddddddddddddd
ddddddddc
— • oj — >o
S
•« — r) —
HAP E
To
1 1
bst
-------
s
0
u.
a
a
a
o
5
i
£
3 g
< 1
tU 2
> ~
m w
S c
Z o
O S-
5jj «
li
0. c-j
< Ov
= 2
O
u
H
a.
U
as
CM
C
0
E
u
a
c
<
*
§
§
«
s
•s
H
"3
c
•f
2
<
H
^
o
8
o
5
H
1
§
a
*
Is
euH
i
<
&
5
c
0 S S
O C) O
t-
o ^
s
8O 0\ ts o
t*7 *o — -^ m c>i
O ~* -" O <»i -" O
S S
d o
SS8 8 S = S
o « cj o" d o d
*-4 O*««A v-14^0^^ ^ *^
O OOO NOOO O —
d odd dddd d d
WO 0 mo -,,00.000
o o *o oi c^ ^NorSor^
00-.«S«000«-r.«.
i
o
p-
ta
O «wi
« » %
* §1- i
• O IB JS
£ N 1 1 ^
^ 1 , 8.JI •§
= l = irr^ls1
II Mr
i.i§tfc5 |uuy8oSL.2
Plll|i!SI|li
illilUlllijia
^ %** w S^Z-S ^ S
W «Si -— g W > ^ ^2 » Q ' ^ S *
O o w*S®* g*g**^J i 6 ^ £
W£S^SBOOPP^| AflOc
<<^^UCJCjQQ Q W bn u* U« ft
J5 Q -^
O CO
0 0 C3
f* oo VM «^
0 £ in 5
0 0 >•
C mfc* C'
\ 1 ll
s i,l si^sl ss J u 1-5
I 1 . ? I
i iili««??at H fi, iltt ii!
SO o *• J5 -2 "cccG*soC(3O'« j^ £ &• c9®5 wfc« ^.S.S WQ
a **^ * ffl oiE^oooooop u« c *J o i ** S S & >S ^ *9 *§ 'o •§
"C O*SH • <^S3SSc3c3SnC*^t«l58o$yC §
S o O o*^H^*c&1*c:*ca o — c a ^ ° § 5 *^ ^ ® OO O O Q
&4tt*OSSK»2*5"S*S^t-t»S*S^^I^PHCuiwu5ioH^^^???^t—
s
d
^
«*
l
,,;
-------
InCOrDOTdtCd Environmental Consulting and Research
MEMORANDUM
Date: June 17, 1996 . . • •
Subject: MACT^Floors for Flexible Polyurethane Foam Production
From: Amanda Williams, EC/R Incorporated
Phil Norwood, EC/R Incorporateoyv
To: • David Svendsgaard, EPA/OAQPS/ESD/OCG
This memorandum presents the Maximum Available Control
Technology (MACT)"floors for the flexible polyurethane foam .
production source category. The. first section of -this memorandum
discusses the Clean Air Act (CAA) requirements for MACT floors,
followed by a discussion of necessary considerations in MACT
floor determinations. The final section presents the conclusions
of the MACT floor analyses.
CLEAN AIR ACT (CAA) REQUIREMENTS FOR MACT FLOORS .
Section 112(d) of.the CAA, -as amended in 1990, defines a
minimum .level of control referred to as the "MACT floor," for
standards established under Section 112(d). For new sources,
emission standards "shall not be less stringent than the emission
control that is achieved in practice by the best controlled
similar source." For existing sources, the emissions standards
must be at least as stringent as either "the average emission
limitation achieved by the best performing 12 percent of the
existing sources," or "the average emission limitation achieved
by the best performing 5 sources" for categories or subcategories
with less than 30 sources.
CONSIDERATIONS IN DETERMINING MACT FLOORS
There are several fundamental decisions 'that must be made
before the MACT floor can be determined. These decisions are
discussed below. . . ' .
Subcategorization
Since a separate MACT floor must be developed for each'
subcategory, the first thing that must be determined is if
subcategorization of the industry is warranted. As. discussed in
3721-D University Drive • Durham, North Carolina 27707
Telephone: (919) 493-6099 . Fax: (919) 493-6393
-------
a separate memorandum,x the flexible polyurethane foam
production source category was divide into three subcategories:
slabstock foam production, molded foam production, and rebond
foam production.
Major Source Determination
The EPA determined that for this source category, only major
sources would be used to develop MACT floors. Therefore, the
next step was to identify the major sources in each subcategory.
The facility-wide hazardous air pollutant (HAP) emission totals
reported in the Information Collection Request (ICR)
responses2'3 were used to identify the major sources within each
subcategory, along with a facility's "potential to emit" (PTE).
A facility's PTE is calculated by considering all the
emission source types at a facility, using assumptions that would
constitute maximum HAP emission potential such as maximum
operational hours, highest HAP content, etc. Inherent
limitations based on a facility's operations can be considered,
such as the production rate being limited by storage space.
However, operational practices that reduce emissions are not
considered unless they are due to an enforceable requirement.
For example, assume some facilities used a non-HAP solvent for
cleaning, and other similar facilities used a HAP solvent for the
same purpose. In the determination of PTE, it must be assumed
that all facilities use a HAP solvent, unless a facility is
prohibited from using the HAP solvent by an enforceable
requirement.
Within the molded foam segment, all facilities wigh high-
pressure (HP) mixheads reported HAP emissions below the major
source thresholds. It is not believed that any HP facilities
could be considered major sources based on their PTE. Only a
conversion from HP to low-pressure (LP) mixheads would increase
these facility's PTE above the major source threshold. This
1 Memorandum. Williams, A. and Norwood, P. EC/R
Incorporated to Svendsgaard, D. , Environmental Protection Agency.
Subcategorization of the Flexible Polyurethane Foam Production
Source Category. June 17, 1996.
2 Memorandum from Norwood, P., Williams, A., and Battye, B.
EC/R Incorporated, to Svendsgaard, D. U.S. Environmental
Protection Agency. Summary of Flexible Polyurethane Foam
Information Collection Requests. January 24, 1994.
3 Memorandum from Williams, A., EC/R Incorporated, to
Svendsgaard, D., U.S. Environmental Protection Agency. Baseline
Emissions for the Flexible Polyurethane Foam Production Industry.
March 8, 1996.
-------
conversion would be expensive, as well as impractical, requiring
significant operational and equipment changes.
Five LP facilities reported emissions greater than the major
source thresholds.2'3 The remaining facilities are also major
sources due to their PTE. While the reported HAP emissions were
below the major source thresholds for these facilities, no
enforceable requirements were reported that would prohibit any
facility from switching to a HAP solvent to flush their mixhead.
Based on the available information, it would be expected that the
combination of the use of a HAP mixhead flush and maximum
potential operation would cause HAP emissions at all LP molded
facilities to be above the major source level.
Seven slabstock facilities reported actual emissions below
the major source thresholds.2'3 However, it is possible for
these facilities to change their product mix, or types of foam
produced, in a manner that would make their HAP emissions greater
than the major source cutoffs. There were no enforceable limits
identified restricting their HAP emissions below major source
levels. Therefore, all slabstock production facilities were
considered to be major sources in this analysis.
It was assumed that no rebond foam production process
emitted HAP above the major source levels. However, the 21
rebond processes co-located with slabstock production operations
are considered major sources, since the plant-wide emissions are
above the major source thresholds. It was assumed that the
remaining 31 rebond facilities were area sources.
Grouping of Emission Sources
After the subcategories and major sources within them were
identified, the groups for which separate MACT floors were to be
determined were established. Under each subcategory, individual
emission points were separated into several general emission
source types. Additional grouping decisions were then made in
the determination of MACT floors within each emission source
type. Consideration was given to the following: equipment type,
equipment size, equipment contents, stream characteristics, and
other elements that can affect the emission potential or the
ability to reduce emissions from that point.
The following are the emission source groupings chosen for
molded facilities:
storage (including unloading emissions)
in-process vessels (includes day and mix tanks)
components in HAP service (e.g. pumps and valves)
in-mold coatings
foam reactant dispensing
mixhead cleaning
-------
• mold release agent application
• demolding
• foam repair
For slabstock facilities the following emission source
groupings were chosen:
• storage (including unloading emissions)
• in-process vessels (includes day tanks)
• components in HAP service
• ABA related emission sources (i.e. foam tunnel, curing,
foam storage)
• equipment cleaning
In addition, MACT floors were determined for three emission
sources at rebond operations.
• diisocyanate emissions from rebond production
• equipment cleaning
• mold-release agent application
Approach to Determining the MACT Floor
MACT floors were identified for each emission source
grouping within each subcategory. For existing sources, the MACT
floor levels were established by determining some measure of
central tendency of the emission control for the top 12 percent,
or top 5, facilities in each emission source type in each
subcategory. This "average" emission limitation is expressed in
several different manners for different emission source types.
When possible, each MACT floor for existing sources was
expressed as emission limits that represent the average emission
limitation achieved by the top 12 percent. Where the MACT floor
was determined to be a technology or work practice, engineering
judgement was used to select the performance criteria that best
characterized the "average" means of HAP reduction at the top 12
percent.
For new sources, the MACT floor levels were established by
determining the emission control for the best controlled facility
in the subcategory for each emission source type. The format of
the MACT floors for new sources varies in the manner they are
expressed, but are consistent with those of existing sources for
each emission source type (e.g. work practice standards,
equipment specifications, etc.).
MACT FLOOR CONCLUSIONS
Following are the MACT floor conclusions for all emission
source types identified in each subcategory. All emissions
-------
reported and used in calculating the MACT floors were taken from
the ICRs, and are generally based on 1992 information.2
Molded Foam
As mentioned previously, all HP molded facilities were
identified as area sources, and all LP facilities were identified
as major sources. Therefore, the MACT floors for molded foam are
based only on LP facilities. Since there are less than 30 LP
facilities, the MACT floor for each emission source type was
based on the top 5 performing facilities. The top five
facilities were determined on a case by case basis for each
emission source type; therefore, the same 5 facilities were not
always used in the floor determinations. In the LP molded foam
subcategory, information is available for 19 facilities.
Storage/unloading-
HAP emissions from storage and unloading at LP molded foam
facilities were reported to be less than 1 ton per year. Only
11 facilities provided information on their storage emissions,
and they all reported no control for these storage and/or
unloading emissions. Since all facilities reported no control,
the MACT floor for storage/unloading for both new and existing LP
molded foam facilities was concluded to be no control.
Mixhead flush
HAP emissions from mixhead cleaning occur when HAP solvents
are used to "flush" the mixhead between foam shots to remove
residual foam material. Total HAP flush emissions from this
source were reported at 205 tons/year, approximately 76 percent
of the total reported HAP emissions for the molded subcategory.
Unlike the other emission source types for the LP molded
subcategory, the identification of the five "best performing"
facilities for the mixhead flush emission source type was not
straightforward. The reported HAP emissions varied among
facilities from less than 1 ton per year to almost 60 tons per
year. In order to assist in the comparison of facilities,
several approaches were considered. The first was an emission
factor approach based on the reported HAP emissions per weight of
product. However, this approach did not provide a legitimate
means of comparison, because the number of flushes (and
consequently, the resulting HAP emissions) is dependent on the
number of "pieces" produced and not the weight of foam produced.
Thus, producers of small foam parts would have artificially high
HAP emission factors. Another approach was to simply consider
the annual reported HAP emissions. While this is more reflective
of a facility's HAP reducing activities, it does not take into
account substantial differences in the operating schedules
reported, or the size of a facility. Therefore, the annual flush
-------
emissions were divided by the annual hours of operation. This
HAP emissions per hour of operation factor was used to identify
the 5 "best performing" facilities.
None of the 5 facilities identified as the best performing
reported any control techniques in the ICR responses. In each
case, process-specific factors were responsible for the low
emissions. For example, one facility designed its molds to be
closer together than normal, reducing the frequency of flushing
needed. Another facility had such small pieces that the volume
of flush needed per shot was very small, resulting in lowered
total emissions. Therefore, the MACT floor for this emission
source type was determined to be the average emission limitation
of the best performing 5 facilities, or "no control." These
facilities are the best performing because of unique process
considerations that are not applicable at all LP molded foam
facilities.
Mold release agents
Approximately 3 percent (7.8 tons/yr) of the reported HAP
emissions from molded foam facilities was from the evaporation of
the HAP carrier solvent from mold release agents. When the mold
release agents are sprayed on the mold, the carrier is designed
to evaporate, leaving a waxy material on the mold to prevent the
foam from sticking.
Of the 18 facilities reporting the use of mold release
agents, 10 reported using a non-HAP based agent, resulting in
zero HAP emissions. The remaining eight facilities reported HAP
emissions, and no controls. Since the top 5 facilities all used
non-HAP based mold release agents, the floor for mold release
emissions for both new and existing sources is judged to be the
total elimination of the use of HAP-based mold release agents.
Foam repair
The main use of adhesives in molded foam facilities is for
the repair of voids and tears in the molded pieces. The
adhesives used are approximately 20 to 40 percent solids, while
the remainder consists of a solvent carrier, such as methyl
chloroform or MeCl2. The HAP emissions occur as this solvent
carrier evaporates after the adhesive is applied. There were
26.1 tons of HAP emissions reported from this source at molded
facilities.
Eight LP facilities did not report having any repair
operations. Four of the remaining facilities reported HAP
emissions from this activity, with no control identified. The
remaining seven facilities reported repair operations, but zero
HAP emissions. Since the top 5 facilities were repairing foam
without any HAP emissions, the MACT floor for foam repair for
-------
7
both new and existing sources was concluded to be the elimination
of HAP-based adhesives in repair operations.
In-process vessels, components in HAP service, in-mold
coatings, foam reactant dispensing, and demoldinq
In the ICRs, HAP emissions were reported for each of these
emission source types. The total reported emissions for all of
these combined 'was 25 tons/yr, which is approximately 9 percent
of the total reported molded foam HAP emissions. No control was
reported for any of these emission source types in the ICR
responses. Therefore, the floor for both new and existing
sources for these emission source types is concluded to be no
control.
Slabstock Foam
There are 78 slabstock foam facilities in this subcategory.
The MACT floor for each emission source type were based on the
top 12 percent of the subcategory (top 10 facilities). Total
reported HAP emissions for this subcategory were approximately
16,750 tons per year. The top performing facilities were
determined on a case by case basis for each emission source type,
therefore, the same facilities were not always used in the floor
determinations.
Storage/unloading
HAP emissions from storage/unloading accounted for less than
1 percent of the total reported slabstock HAP emissions
(39 tons/yr). Of the facilities reporting HAP ABA and/or TDI
storage breathing loss emissions, no control was reported for
either HAP. For HAP ABA unloading, 17 facilities reported using
vapor balancing for emission control. The remaining facilities
reported no control. For TDI unloading, 29 facilities reported
using vapor balancing. The remaining facilities reported using
no control. It was concluded that the floor for TDI and HAP ABA
storage/unloading at new and existing sources is vapor balance.
Components in HAP service
•HAP emissions from pumps and valves accounted for 16 tons of
the reported emissions per year. Thirty-three of the 77
facilities reporting TDI emissions from pumps and valves reported
using "canned pumps," a type of sealess pump. Since more than 10
plants reported canned pumps for TDI, the new and existing source
MACT floors for TDI pumps were concluded to be canned, or
"sealless" pumps. Four facilities reported using canned pumps
for MeCl2, and no other facilities reported any type of control.
A median-based approach was used to determine the existing source
floor for MeCl2 pumps. Since "no control" was most frequent in
-------
the top 10 list, the flopr was determined to be no control for
existing sources, and sealless MeCl2 pumps for new sources.
In addition, no facility reported the control of HAP
emissions from any other components in HAP service (valves,
connectors, etc.). Therefore, the new and existing source floors
for all components except pumps was concluded to be no control.
Equipment cleatiing
Methylene chloride is used as a cleaner to rinse and/or soak
foam machine parts such as mixheads and foam troughs. This use
resulted in 135 tons/yr of reported emissions.
Eight of the 73 slabstock facilities reporting equipment
cleaning operations use non-HAP products or other non-HAP
cleaning methods for cleaning of foam equipment. The remainder
used no control. A median-based approach was used to determine
the existing source floor for equipment cleaning. Since 8 out of
the top 10 facilities reported using a non-HAP cleaning method,
the floor for both new and existing sources was determined to be
the use of non-HAP cleaning solvents.
ABA emission sources
Methylene chloride (MeCl2) is the principal auxiliary
blowing agent (ABA) used. The role of the methylene chloride is
simply to volatilize and expand the foam, it does not directly
participate in the polyurethane reaction. Therefore, all of the
methylene chloride that is added to the process eventually is
emitted. The use of MeCl2 as an ABA was the largest emission
source of HAP's for slabstock facilities reported in the ICRs, at
over 14,372 tons (80 percent of the total HAP emissions from
slabstock facilities). In addition, methyl chloroform (another
HAP) was used by some facilities, resulting in over 2,078 tons of
estimated HAP emissions. There were several alternatives
identified in the ICRs that facilities are using to either reduce
or eliminate the use of MeCl2 as an ABA in the manufacture of
flexible slabstock polyurethane foam.
The mix of foam grades produced at a plant has a strong
influence on the amount of ABA that is used and emitted. There
are many grades of foam that can be produced without any ABA,
while for some soft and light foams, ABA usage can be as high as
24 parts per hundred parts polyol (pph), or almost 300 pounds per
ton of foam produced . Industry representatives have stressed
the need to take this difference into account in determining the
floor, emphasizing that low-ABA and high-ABA grades of foam are
not interchangeable, either from a production cost standpoint,
from an emission standpoint, or from an end-use standpoint.
-------
Existing sources. The EPA has agreed that differentiation
between foam grades is appropriate, and concluded that any ABA
emissions limitation should be a function of the grades produced.
Therefore, the following equation was developed to calculate the
allowable HAP ABA emissions from foam production:
emiss
allow
•E
(limit}) (polyol^
100
where,
emiss
n
Allowable emissions due to use of a HAP
ABA for a specified time period,
Megagrams
HAP ABA formulation limit for foam grade i,
parts ABA per 100 parts polyol
Amount of polyol used in the time period in
the production of foam grade i, pounds
Number of foam grades produced in the time
period
Using this equation, the MACT floor HAP ABA emissions level is
defined by determining a MACT floor set of HAP ABA formulation
limits.
In the ICR, foam producers were asked to provide formulation
information (i.e., parts HAP ABA per 100 parts polyol, or pph)
for all foam grades produced at the facility. Therefore, the EPA
was able to separate the formulation information by grade (where
a grade is represented by its density and indentation force
deflection, or IFD) .2 Foamers claimed all formulation
information confidential; therefore, the actual formulation
database and summary is not publicly available.
The foam grades were combined into density/IFD "groups."
The Polyurethane Foam Association (PFA) suggested the following
eight-group classification system:4
• IFD greater than 20 pounds, density greater than 1.4
pounds per cubic foot (pcf)
IFD greater than 20, density from 1.15 to 1.4 pcf
IFD greater than 20, density from 1.05 to 1.15 pcf
IFD greater than 20, density from 0.95 to 1.05 pcf
IFD greater than 20, density less than 0.95 pcf
IFD from 15 to 20, at any density
4 Letter from Sullivan, D., Hickory Springs Manufacturing
Company, to Svendsgaard, D., U.S. Environmental Protection
Agency. February 24, 1994. PFA-recommended subcategorization
strategy.
-------
10
• IFD from 10 to 15, at any density
• IFD less than 10, at any density
The EPA's initial attempt at determining the MACT floor HAP
ABA formulation limits was to simply calculate the average of the
lowest 12 percent of the formulations reported for each of the
grade ranges suggested by the PFA. However, this approach led to
inconsistent results (see summary of initial presumptive MACT
roundtable meeting5). Therefore, the approach described below
was developed and used to determine the MACT floor HAP ABA
formulation limitations.
This approach could simply be described as the determination
of a baseline, and the application of MACT floor reductions to
this baseline. The initial step in this approach was to
determine baseline formulations. As part of this analysis, PFA-
recommended foam grade groupings were re-examined.6 This
analysis, which used the formulation database to examine ABA
usage/emission trends by IFD and density, concluded that the PFA-
recommended needed revisions in two areas. The PFA-recommended
groupings assumed that (1) ABA usage was not dependent on density
for foam grades with IFDs less than 20 pounds, and (2) ABA usage
was not dependent on IFD for IFDs greater than 30 pounds. The
analysis found both of these assumptions to be inaccurate.
Therefore, all subsequent analysis was conducted on a 30-group
grid, using the five PFA-recommended density ranges, and six IFD
ranges (0-10, 11-15, 15-20, 21-25, 26-30, and 31+ pounds).
Again, an attempt was made to use the overall average of
formulation information submitted for each grade group. As
discussed above for the average of the top 12 percent, the
overall average formulations often did not follow a reasonable
pattern. For instance, the average ABA level would increase with
increasing IFD, and with increasing density. This problem was
primarily attributed to the low number of data points for several
density/IFD groups. Table 1 shows the number of plants
represented in the database for the 30 density/IFD groups.
5 Memorandum. Norwood, P. EC/R Incorporated to
Svendsgaard, D. U.S. Environmental Protection Agency. Summary of
May 23, 1995, Flexible Polyurethane Foam Presumptive MACT
Roundtable Meeting. June 14, 1995.
6 Memorandum from Norwood, P. EC/R Incorporated, to
Svendsgaard, D. U.S. Environmental Protection Agency. Status of
Flexible Polyurethane Foam Auxiliary Blowing Agent MACT Floor
Determinations. June 22, 1995.
-------
11
TABLE 1. NUMBERS OF PLANTS REPRESENTED IN
FORMULATION DATABASE
Table values
are numbers
of plants
reporting
formulation
information
in each group
0-10
11-15
16-20
F 21-25
D
26-30
31 +
Densi
0-
0.95
4
5
24
15
ty rang
0.96-
1.05
7
17
14
17
22
26
es (poui
foot)
1.06-
1.15
4
9
15
15
7
21
nds per
1.16-
1.40
7
12
20
36
cubic
1.41+
<9
12
19
23
31
36
In the development of EPA's Flexible Polyurethane Foam
Emission Reduction Technologies Cost Document,7 a representative
facility was created. The foam formulations used for this
representative facility were generated in a cooperative effort
between the EPA and the PFA, and the EPA believes they represent
typical formulations for the industry. Table 2 shows both the
average (or range) formulation information from the ICR
responses, and the representative facility formulation. From
this information, baseline formulation levels were selected for
each foam grade grouping, which are shown in Table 3.
The next step was to apply reductions, that represent MACT
floor reductions, to these baseline formulation values. The
amount of reduction achievable also varies by foam grade.
Numerous technologies exist that allow the production of higher-
density, higher-IFD foams with significantly less, or even no,
HAP ABA. However, the amount of HAP ABA reduction that can be
achieved for low-density, low-IFD, foam grades of acceptable
quality is much less. Therefore, the reductions had to be
determined on a grade-specific basis.
7 Flexible Polyurethane Foam Emission Reduction
Technologies Cost Analysis. EPA-453/R-95-011. U.S. Environmental
Protection Agency. September 1996.
-------
12
TABLE 2. BASELINE HAP ABA FORMULATIONS
Table
values in
parts ABA
per
hundred
parts
polyol
0-10
11-15
T
F 16-20
D
21-25
26-30
31 +
Density ranges (pounds per cubic
foot)
0-
0.95
(21)
(16-
18)
(16-
18)
10
(10)
(9-
10)
0.96-
1.05
22
(18)
19
(15)
14
ai-
13)
(12-
15)
8
(7)
(7-8)
1.06-
1.15
(20)
(13-
18)
14
(12-
14)
(12)
7
(6-8)
(4-5)
1.16-
1.40
(10)
(10)
(7-8)
5-6
(5-6)
2
(3)
1.41+
(2)
(2-6)
10-13
(6-8)
(4-5)
6-7
(5)
1-2
(2)
NOTES: Top numbers are the estimates
provided by the PFA and chemical
suppliers in comments on the cost
report. Numbers in parentheses and
italics are from the ICR data.
The problems discussed above, associated with insufficient
numbers of data points in certain density/IFD groups, would have
caused similar problems if reductions were determined for
individual groups. Therefore, groups were combined until at
least 30 data points were available. For instance, the six
groups with IFDs of 20 pounds or less and densities of 1.16 pcf
or less were combined. This resulted in 41 data points in this
combined group.
-------
13
TABLE 3. BASELINE HAP ABA FORMULATIONS
Table
values in
parts ABA
per
hundred
parts
polyol
0-10
11-15
16-20
F 21-25
D
26-30
31 +
Densil
0-
0.95
21
18
16
10
9
ty range
0.96-
1.05
20
19
14
13
8
7
js (pour
foot)
1.06-
1.15
20
18
14
12
7
5
ids per
1.16-
1.40
10
10
8
6
2
cubic
1.41+
6
6
6
5
5
2
For each combined group, the overall average formulation was
calculated, as well as the average formulation for the 12 percent
of the data points with the lowest HAP ABA formulations. Then
the reduction from the overall average to the top 12 percent
average was calculated. For example, if the overall average
formulation was 9 pph and the top 12 percent average was 5 pph,
the percentage reduction was calculated as follows :
PercentReduction =
(9 pph}
= 44
The results of the percentage reduction determination are
shown in Table 4. These percentage reductions were then applied
to the individual density/IFD group baseline formulation levels
in Table 2 to obtain the existing source MACT floor HAP ABA
formulation limitations, which are shown in Table 5. It should
be noted that this analysis resulted in equivalent HAP ABA
formulation limits for more than one density/IFD group.
Therefore, the result was actually 18 density/IFD groups in the
MACT floor HAP ABA formulation limits table.
-------
14
TABLE 4. MACT FLOOR PERCENTAGE REDUCTIONS
Table
values are
percentage
reduction
from
baseline
0-10
11-15
1 16-20
D 21-25
26-30
31+
Densil
0-
0.95
ty rang*
0.96-
1.05
is (pour
foot)
1.06-
1.15
ids per
1.16-
• 1.40
45
1 68
cubic
1.41+
75
100
New sources. In the ICR responses, several facilities did
not report any HAP ABA emissions. It could be concluded that the
new source HAP ABA MACT floor was the total elimination of HAP
ABA emissions. However, this approach would not consider the
differences in the amount of HAP ABA used for different grades,
since these plants did not produce a complete range of foam
grades. Therefore, the new source HAP ABA MACT floor formulation
limitations were determined by examining the lowest reported HAP
ABA formulation for each of the 30 density/IFD blocks.
Formulations for foam grades only produced in small amounts
were not considered. This analysis found that the production of
many foam grades were reported with no HAP ABA. However, the
results were not always logical. For instance, all foam grades
with densities between 0.96 and 1.05 pcf were reported to be
produced with no HAP ABA (with the exception of IFDs less than
15 pounds) , but there were no foam grades with densities between
1.06 and 1.15 pcf that were reported to be produced with no HAP
ABA. The EPA concluded that this was more a function of the
randomness of the foam grades reported, rather than the inability
to produce foams of densities between 1.06 and 1.15 pcf with no
HAP ABA. In fact, the Agency believes that if foam grades with
densities between 0.96 and 1.05 pcf can be produced with no HAP
ABA, then foam grades of corresponding IFDs with densities
greater than 1.05 pcf can also be produced with no HAP ABA. The
lack of sufficient data for the foam grades where the new source
MACT floor was not determined to be zero led the Agency to
-------
15
TABLE 5. MACT FLOOR HAP ABA FORMULATION
LIMITATIONS FOR EXISTING SOURCES
Table
values in
parts ABA
per hundred
parts
polyol
0-10
11-15
16-20
F 21-25
D
26-30
31+
Density ranges (pounds per cubic
foot) .
0-
0.95
12
10
9
6
5
0.96-
1.05
1.06-
1.15
11
8
7
4
4
1.16-
1.40
6
4
3
2
1
1.41 +
2
2
0
conclude that the new source MACT floor for these grades was
equal to the existing source MACT floor, as shown in Table 5.
Therefore, the EPA concluded that the MACT floor HAP ABA
formulation limitations for new sources are as shown in Table 6.
Rebond
Some slabstock facilities have rebond operations. Rebond is
the process where scrap foam is cut up and placed in a mold with
a small amount of TDI and treated with steam. This causes the
small pieces to adhere and form a solid cylinder of foam. This
cylinder is then peeled into sheets, which is mainly used as
carpet padding. A small amount of TDI is emitted during this
process. The HAP emissions from rebond operations accounted for
11 tons, or less than 1 percent of the total slabstock HAP
emissions. However, only 1 ton of these emissions was TDI, with
the remainder being MeCl2- These MeCl2 emissions were reported
by only one facility. They came from a mold release agent in the
rebond operation, and from cleaning of the rebond equipment.
No control for the TDI emissions was reported, and all TDI
emissions were calculated using standard industry emission
factors. Since all facilities reported no control for TDI, and
only one of the 22 rebond operations reported other HAP
-------
16
TABLE 6. MACT FLOOR HAP ABA FORMULATION
LIMITATIONS FOR NEW SOURCES
Emissions -
parts ABA per
hundred parts
polyol «
I
F
D
0-10
11-15
16-20
21-25
26-30
31+
Density ranges
0-
0.95
12
10
9
6
5
0.96-
1.05
(pounds per cubic foot)
1.06-
1.15
11
1.16-
1.40
6
0
1.41 +
emissions, it was concluded the floor for rebond at both new and
existing sources is "no control" for TDI emissions, and the
elimination of any HAP cleaners or mold release agents.
Summary
Table 7 summarizes the MACT floor conclusions for both new
and existing source for each emission source type.
-------
17
1
rH*
U
2
O
U
O
O
EH
u
CO
^
CD
M
X
W
B
01
0)
o
3
o
CO
3
0)
2
1
o:
o
s
b
U
01
4)
O
^
0
CO
O)
B
-H
AJ
CO
•H
X
H
i
fv*
Q
3
PH
B
u
CJ
g
o
CO
§
H
CO
co
H
*£
H
01 CO
AJ AJ
U U
3 3
•O T5
0 O
« a ft
T3 T3
0) a)
01 01
rH rH (B (8 rH
O 0 J3 £> 0
1H rl rl
AJ AJ ft ft AJ
C B < < B
o o 2 2 o
U U i I O
B B
ca 01
AJ AJ
0 0
3 3
•a -o
0 O
O, f^
•a T)
a> a)
co ca
18 18
•Q «Q
i i
O* CU
^ Si
M-l U-l
0 O
B B
rH rH O O rH
O O -H -H O
iH J-l AJ AJ rl
AJ AJ (6 (8 AJ
B B B B B
O O -rl -rl O
U U £ £ U
-H -H
0 0 rH rH O
x a H a z
-
o
"> E
rl (8 t7)
1) O C
m . 01 >M -H
AJ m 73
0) B rH ft -rH
B 0> tt) rt 01 O
•H Oi co a tn E
T3 18 to B 0)
18 X 0) B -H -O
O CO 0) > -H AJ
rH 3 CO rl (8 -
B rH (8 -H co tn o Cn
_ 3 w a> <8 OJAJUB
S --v rH ft 01 B -H
a o) T) a> 0) u ai T3 m
O 01 « rl r< OCrHB
fe (tj 01 rl O O CD
ri £ T} E a ft E a
•O O X rH (8 1 £ 1 01
« AJ -H O O BOfi-H
"0 CO S 2 fo HO-HT3
rH
0
Oi
J
01 W
01 >~i B
01 0 AJ O
rH rl U -H
(8 AJ 3 AJ
(5 C T3 «
01 0 O AJ
O ^ -rl
i ft £
O -H
<1) EH ftO Z fe
^J p.
O ri!
3 2
T3
O B
rl O CO
ft B
•a o
T3 0) -H
rH 0) 01 AJ
O 01 18 Q
r< 18 A AJ
AJ J3 -rl
01 B i BE
ft O CU O -H
£ U < -rl rH
3 a AJ
ft O (Q B
B >w AJ O
0)01 O -H -H
U 0) i £ AJ
BO) C -H (8
(8 rH CO O rH rH
rH 18 CU -rl 3
(8 0) < AJ BE
A CO a (8 O in
B -H 0
i-l 1 rl -H CO 4-1
o a) £ 01
ft H J3 -H -rl tf
18 Q AJ rH ECQ
> HO W W 3
0)
u
•rH
M
0)
01
01
O) ft B CO
-5 £ 13 g
•a (8 -H
(8 B 0) Q
O -H rH 01
i-H U -rl
§co £
AJ AJ 0)
B \ B B
B 0) ID fl) *3J
0 0) B En
PM <8 0 ft ri,
rl ft -H
M 0 E d D.
o AJ o & rt
o co u w a
AJ
Q
•3
1-1
01
a.
•a; -a
rH 2rH
0 0
rl
rH
u
CO
ft AJ
< B
rH 2 4)
O Cl
rl «« (8
AJ O
B 0)
O B co
U O (8
-H 0)
O AJ rH
B (8 0)
B >-i
1 -rl
£-0
M iH rH
Q rH O
EH W E
§
o
h
•o
c
o
e
OS
-------
f-m(~1 /
fi, /If InCOTDOTdtCd Environmental Consulting and Research
MEMORANDUM-
Date: June 17, 1996
« '
Subject: Regulatory Alternatives for New and Existing Sources in
the Flexible Po'lyurethane Foam Industry
From: Amanda'Williams, EC/R Incorporated
Phil Norwood, EC/R Incorporated^/
To.: David Svendsgaard, EPA/OAQPS/ESD/OCG
The purpose of this memorandum is to present regulatory
alternatives for Maximum Achievable Control Technology (MACT)
standards for new and existing sources in the flexible •
polyurethane foam industry. This memorandum 'is separated into
two sections. The first section describes the possible levels of
control for the individual emission source types at flexible
polynrethane foam facilities, along with the control options that
are available to meet each level of control. The second section
combines- these levels of control into regulatory alternatives.
The flexible polyurethane foam source category has been
divided into two subcategories: slabstock and molded foam
production. A separate set of regulatory alternatives was
developed for each subcategory.
POTENTIAL LEVELS OP CONTROL
This.section discusses levels of control that could be used
as the basis for developing regulatory alternatives for the
flexible polyurethane foam industry. For each .emission source
type, the potential. levels of control axe identified. •• For both
new and existing sources, the first level of control is'the MACT
"floor" level. The determination of MACT floors is discussed in
a separate memorandum.1 Levels of control more stringent than
the MACT. floor level are also presented.
For. each level- of control more stringent than the MACT. floor
level, the.control options available to meet the level are
presented. The control options discussed in this memorandum were
1 Memorandum. Norwood, P. and Williams, A. EC/R
Incorporated, to.Svendsgaard, D., U.S. Environmental Protection
Agency. MACT floor determination for Flexible Polyurethane Foam
Production. June 17, 1996.'
3721-D University Drive • Durham, North'Carolina 27707
Telephone: (919) 493-6099 - Fax: (919) 493-6393
-------
identified during one of two previous efforts: (1) information
obtained from industry in response to the Environmental
Protection Agency's (EPA's) information collection request (ICR),
and (2) information gathered in connection with EPA's document
entitled "Flexible Polyurethane Foam Emission Reduction
Technologies Cost Analysis."2
Molded Foam Facilities
«
Hazardous air pollutant (HAP) emissions- are attributable to
three predominant emission source types at molded foam
facilities: (1) HAP mixhead flushes, (2) HAP-based mold release
agents, and (3) HAP-based adhesives for foam repair. The control
options for each of these emission source types are discussed in
the following sections. Additional emission source types were
identified at molded facilities. However, emissions from each of
the additional sources were only reported by a few facilities.
In addition, emissions were very low and no control was reported.
Therefore, control options for these emission source types were
not included in any regulatory alternative.
Mixhead Flush
The MACT floor for this emission source type was identified
as no control for existing sources. For new sources, the MACT
floor was identified as the prohibition of the use of HAP flush
agents. There were two levels of control above the existing
source MACT floor identified: work practices that reduce HAP
emissions, and the prohibition of the use of HAP flush agents.
Work practices. Many foam facilities do not make any
attempt to capture or contain the emissions that occur when the
methylene chloride (MeCl2) used to flush the mixhead evaporates.
Placing a lid over open containers (typically 55-gallon drums),
and other work practices would reduce MeCl2 emissions from this
source. One facility reported in the ICR responses that they
cover the MeCl2 container, and use a solvent recovery system to
allow the re-use of the MeCl2 solvent. They also have a "closed-
loop system" for capturing the MeCl2 vapors from the area around
the 55-gallon drum used to capture the flush. This system
consists of a fan that draws the vapors generated in the flush
area through a carbon canister, which captures the solvent vapors
2 Flexible Polyurethane Foam Emission Reduction
Technologies Cost Analysis. EPA-453/R-95-011. U.S.
Environmental Protection Agency, Research Triangle Park, North
Carolina. September 1996.
-------
before the air is released to the atmosphere.3 This facility
estimates that this system reduces its MeCl2 emissions by
80 percent.4
Prohibition of HAP flush agents. Several methods were
identified that would eliminate the need to use a HAP-based
mixhead flush. One method is to change the type of mixhead used
to a high-pressure (HP) mixhead or a self-cleaning mixhead.
Either of these mixheads would eliminate the need for a HAP
flush, but they may not be feasible for smaller molded foam
manufacturers. The HP mixheads have two main disadvantages for
the smaller molders. First, the initial capital cost may be
prohibitive for small molders. Also, the low throughput range
required for smaller parts may be too low for the HP system to
achieve the necessary mixing of the foam ingredients. The self-
cleaning mixheads were not reported to be in use by any flexible
polyurethane foam facilities in the United States. They also
have a small throughput range and could not be used to
manufacture larger foam pieces.
While the alternative mixheads mentioned above have
limitations for small molders, the third option does not. The
third option is to replace the HAP-based flush with a non-HAP
based product. Several of these products were identified and
reported to be in use in the industry.
Mold Release Agents and Foam Repair
The MACT floor for both new and existing sources for these
two emission sources was identified as the total elimination of
HAP-based products. Therefore, no level of control above the
MACT floor is possible.
Other Molded Emission Sources
The MACT floors for new and existing sources were identified
as no control for the following emission source types: in-mold
coatings, storage/unloading, in-process vessels, components in
HAP service, foam froth dispensing, and demolding. No levels of
control above the MACT floor were identified for these emission
points at molded polyurethane foam facilities, with the exception
of in-mold coatings. The total amount of HAP emissions reported
from these sources is also relatively low, comprising only
3 Telecon. Williams, A., EC/R Incorporated to Majeski, D.,
Renosol Corporation. June 10, 1994. Methylene chloride capture
and recovery system.
4 Telecon. Williams, A., EC/R Incorporated, to Peck, D.,
Renosol Corporation. June 7, 1994. Methylene chloride capture
and recovery system.
-------
7 percent of the reported HAP emissions for molded foam
manufacturers.5
Slabstock Foam Facilities
At slabstock foam facilities, there are four primary HAP
emission source types: (1) the storage/unloading of HAP
compounds, (2) leaking components in HAP service, (3) the use of
a HAP as an equipment cleaner, and (4) the use of HAP auxiliary
blowing agents (ABA's). The levels of control for each of these
emission source types are discussed in the following paragraphs.
Storage/Unloading
The MACT floor for tank truck/railcar unloading of both
toluene diisocyanate (TDI) and HAP ABA at new and existing
sources was identified as either the use of a vapor balance or
carbon canister system. No control options that would result in
a level of control above the MACT floor were reported to be in
use in the industry.
The floor for both new and existing sources for storage was
determined to be no control. While floating roofs and other
traditional storage tank controls could be considered for this
industry, the size of the storage tanks at foam facilities is
almost always below the capacity thresholds of other rules like
the Hazardous Organic NESHAP (HON). It is therefore anticipated
that the costs and other impacts would not be reasonable for such
options. Therefore, no levels of control are included in the
regulatory alternatives for storage emissions.
Components in HAP Service (Equipment Leaks)
The MACT floor for new and existing sources for this
emission source type was determined to be leakless pumps for TDI
components (except for high pressure metering pumps), and no
control for all other components in HAP service. A level of
control identified above the MACT floor for new and existing
sources was a leak detection and repair (LDAR) program for all
other components in HAP service. The details of this LDAR
program would be created based on this industry. A third level
of control that was considered was leakless pumps for TDI
combined with the Subpart H equipment leak requirements from the
Hazardous Organic NESHAP (HON) for other components in HAP
service. However, the EPA decided that the complexity of the HON
requirements was not appropriate for inclusion in a regulatory
5 Memorandum. Williams, A., EC/R Incorporated, to
Svendsgaard, D., U.S. Environmental Protection Agency. Non-
confidential summary of Flexible Polyurethane Foam ICR Data.
February 10, 1995.
-------
alternative for the foam industry. The primary reason for this
decision was the relatively low number of components at foam
production facilities when compared to HON affected sources.
Equipment Cleaning
The MACT floor for both new and existing sources for this
emission source, were identified as the total elimination of
HAP-based products. No levels of control above the MACT floor
are possible.
Auxiliary Blowing Agent
There are many "grades" of flexible polyurethane slabstock
foam produced, each with slightly different end-uses that require
slightly different foam properties. Different grades can require
varying levels of HAP ABA. The levels of control discussed below
account for this variation.
Existing sources. The existing source MACT floor for HAP
ABA was determined to be a limit on the amount of HAP ABA
emissions. The limit, calculated using Equation 1, is based on
the grades of foam and amount of each grade produced at a
facility, and is determined using grade-specific HAP ABA
formulation limitations.
(limit.) (polyol,}
^ i-
where,
emissallow= Allowable emissions due to use of a HAP ABA
for a specified time period, Megagrams
HAP ABA formulation limit for foam grade i,
parts ABA per 100 parts polyol
Amount of polyol used in the time period in
the production of foam grade i, pounds
n = Number of foam grades produced in the time
period
The MACT floor HAP ABA formulation limitations, which are
shown in Table 1, were determined by applying a percentage
reduction to the baseline formulation values shown in Table 2.
The MACT floor ABA percentage reductions, which are shown in
Table 3, represent the reductions from baseline for the
12 percent of the facilities reporting the lowest HAP ABA
formulations (i.e., best performing facilities). More detail on
the calculation of the MACT floor HAP ABA formulation limitations
is provided in the MACT floor memorandum.6
Reference 1.
-------
TABLE 1. EXISTING SOURCE MACT FLOOR HAP ABA
FORMULATION LIMITATIONS
HAP ABA
Formulation
Limitations -
parts ABA per
hundred parts
polyol
IFD
0-15
16-20
21-25
26-30
31 +
Density ranges (pounds per cubic foot)
0-
0.95
12
10
9
6
5
0.96-
1.05
1.06-
1.15
11
8
7
4
1.16-
1.40
6
4
3
2
1
1.41 +
2
2
0
TABLE 2. BASELINE HAP ABA FORMULATIONS
Table values
in parts ABA
per hundred
parts polyol
IFD
0-10
11-15
16-20
21-25
26-30
31+
Density ranges (pounds per cubic foot)
0-
0.95
21
18
16
10
9
0.96-
1.05
20
19
14
13
8
7
1.06-
1.15
20
18
14
12
7
S
1.16-
1.40
10
10
8
6
2
1.41 +
6
6
6
5
5
2
-------
TABLE 3. PERCENTAGE REDUCTIONS FROM BASELINE
ACHIEVED BY THE BEST PERFORMING 12 PERCENT OF
FOAM FACILITIES
Percentage
reductions
1 0-30
IFD I 31+
Density ranges (pounds per cubic
foot) .
0- 0.96-
0.95 1.05
4
1.06-
1.15
5
1.16-
1.40
68
1.41 +
75
100
There are a variety of control options available and in use
in the industry to meet the MACT floor level of control for HAP
ABA emissions. These include chemical alternatives, forced
cooling, variable pressure foaming, acetone as an ABA, liquid
carbon dioxide as an ABA, and carbon adsorption.
For existing sources, an infinite number of potential levels
of control could be developed by varying the formulation limits
for foam grades with different densities and indentation
deflection force (IFD). However, there are no sound technical
grounds for many of these combinations. Three methods were
identified to produce levels of control more stringent than the
MACT floor, but less stringent than the total elimination of HAP
ABA emissions. For each of these methods, the format of the
control level would be a HAP ABA emission limit. The increased
stringency would be the result of using lower HAP ABA formulation
limitations to calculate the emission limit.
The "extended range method" was the straightforward
simplification of the MACT floor ABA. This method extended the
MACT floor IFD/density "blocks," and took the lowest MACT floor
HAP ABA formulation limitation represented in the combined
blocks. For example, in Table 1 there are four IFD/density
blocks with densities less than 1.15 pounds per cubic foot (pcf)
and IFDs less than 20 pounds. The corresponding HAP ABA
formulation limitations are 12, 11, 10, and 8 parts HAP ABA per
hundred parts polyol (pph). In creating the level of control
under the first method, these four blocks were combined and 8 pph
assigned as the HAP ABA formulation limitation. The HAP ABA
formulation limitations created using this method are provided in
Table 4.
-------
TABLE 4. HAP ABA FORMULATION LIMITATIONS BASED
ON EXTENDED GRADE GROUPS
Parts ABA
per hundred
parts
polyol
IFD
0-20
21-25
26+
Density ranges (pounds per cubic
foot)
0-
0.95
0.96-
1.05
1.06-
1.15
8
7
5
4
1.16-
1.40
4
1
1.41+
2
0
The "top three method" used the same procedure that was used
to determine the MACT floor HAP ABA formulation limitations,
except that the percentage reductions applied were the reductions
achieved by the best performing three facilities, rather than the
best performing 12 percent of the facilities. The percentage
reductions from baseline for the best performing three facilities
are shown in Table 5, and the resulting HAP ABA formulation
limitations are shown in Table 6.
TABLE 5. PERCENTAGE REDUCTIONS FROM
BASELINE ACHIEVED BY THE THREE BEST
PERFORMING FOAM FACILITIES
Percentage
reductions
IFD
0-30
31 +
Density ranges (pounds per cubic
foot)
0- 0.96-
0.95 1.05
1.06-
1.15
60
55
1.16-
1.40
76
1.41+
85
100
The "carbon adsorption method" also used the same procedure
that was used to determine the MACT floor HAP ABA formulation
limitations, except that percentage reductions reported from the
-------
TABLE 6. HAP ABA FORMULATION LIMITATIONS BASED
ON THREE BEST PERFORMING FOAM FACILITIES
Emiss
part
per h
pa
po:
=====
IFD
ions -
s ABA
undred
rts
Lyol
0-15
16-20
21-25
26-30
31 +
Density ranges (pounds per cubic
foot)
0-
0.95
0.96- 1.06-
1.05 1.15
8
7
6
4
6
5
3
1
1.16-
1.40
4
3
2
0.5
1.41 +
1
0
use of carbon adsorption7 were used in instances where the
percentage reduction of the best performing 12 percent of the
facilities (see Table 3) was less than the percent reduction for
carbon adsorption. This resulted in the HAP ABA formulation
limitations shown in Table 7.
Comparison of the three sets of HAP ABA formulation
limitations in Tables 4, 6, and 7 shows that the limitations are
similar for many grades of foam. The emission reduction that
would be achieved by each of these sets were calculated for the
cost document representative slabstock facility.8 As shown in
Table 8, there is little difference in the emission reduction
between the three sets. Since there is so little difference in
HAP ABA formulation limitations and the representative facility
emission reduction, EC/R concludes that these three sets truly
7 Memorandum. Williams, A. EC/R Incorporated, to
Svendsgaard, D., U.S. Environmental Protection Agency. Summary
of the April 26, 1995, conversation between EPA and Ohio
Decorative Products regarding the use of carbon adsorption to
control auxiliary blowing agent emissions at the Flexible Foam
Facility in Terrell, Texas. May 31, 1996.
8 "Flexible Polyurethane Foam Emission Reduction
Technologies - Cost Analysis. EPA-453/D-95-004. May 1995.
-------
10
TABLE 7. HAP ABA FORMULATION LIMITATIONS
BASED ON PERCENTAGE REDUCTION ACHIEVED BY
CARBON ADSORPTION
Emissions -
parts ABA
per hundred
parts
polyol
IFD
0-10
11-15
16-20
21-25
26-30
31+
Density ranges (pounds per cubic
foot)
0-
0.95
7
6
6
4
3
0.96-
1.05-
7
1.06-
1.15
6
5
5
3
2.5
4
2.5
2
1.16-
1.40
4
3
2
1
1.41 +
2
0
TABLE 8. REPRESENTATIVE FACILITY EMISSION REDUCTIONS FOR
HAP ABA FORMULATION LIMITATION OPTIONS
Option
MACT Floor
Intermediate Options
Extended Range
Top Three
Carbon Adsorption
Total Elimination
Representative
Facility Percent
Emission Reduction
53
67
69
70
100
-------
11
only represent a single level of control, hereafter referred to
as the intermediate level of control. The control options
necessary to meet the HAP ABA MACT floor discussed above can also
be used to meet this intermediate level of control.
The final recommended existing source level of control is
the complete elimination of HAP ABA emissions. The number of
control options available to achieve the complete elimination of
HAP ABA emissions is limited, but available information indicates
that at least three options, variable pressure foaming, acetone
as an ABA, and liquid carbon dioxide as an ABA, are available.
Each of these technologies is being used in full-scale production
in the United States to produce a complete range of foam grades.
TABLE 9. NEW SOURCE MACT FLOOR HAP ABA
FORMULATION LIMITATIONS
Emissions -
parts ABA per
hundred
parts
polyol
I
F
D
0-10
11-15
16-20
21-25
26-30
31+
Density ranges
0-
0.95
12
10
9
6
5
0.96-
1.05
(pounds per cubic foot)
1.06-
1.15
11
1.16-
1.40
6
0
1.41+
New sources. The new source MACT floor for HAP ABA was
determined to be a limit on the amount of HAP ABA emissions
calculated with Equation 1 using the new source MACT floor grade-
specific HAP ABA formulation limitations are shown in Table 9.
Using the same concept as discussed above for existing sources,
an intermediate level of HAP ABA emission reduction was
identified. For this new source intermediate level of control,
the HAP ABA formulation limitations are set to zero for the same
grades as the new source MACT floor limitations that were shown
in Table 9, while the formulation limitations for the other
grades are set equal to the existing source intermediate level of
control. The third level of control for new sources is the
complete elimination of HAP ABA emissions.
-------
12
Rebond
The MACT floor for HAP emissions at rebond facilities for
both new and existing sources was determined to be no control for
TDI/MDI (methylene diphenyl diisocyanate) emissions, and the
elimination of HAP-based cleaners and mold release agents. No
levels of control above the MACT floor were identified.
REGULATORY ALTERNATIVES
The following section presents and discusses the regulatory
alternatives developed for new and existing polyurethane foam
facilities. The amount of emission reduction achieved increases
with each alternative above the floor. It is also expected that
costs will increase with each more stringent alternative.
Molded Foam
For molded foam production, two existing source regulatory
alternatives above the MACT floor were developed. These
alternatives are summarized in Table 10. Alternative 1 would
require facilities to use work practices to reduce the HAP
emissions from mixhead flushing. The work practice requirements
may take many forms, one of which may be to simply require
operators to cover the barrel used to collect the HAP mixhead
flush. The other emission sources at the facility would be
require to control at the MACT floor level. Alternative 2
prohibits the use of any HAP-based mixhead flush. While TDI and
methylene diphenyl diisocyanate (MDI) could still be used in the
foam formulation, this alternative would practically eliminate
HAP emissions from molded foam facilities.
The MACT floor level of control for all applicable emission
sources at new sources is the prohibition of the use of HAP-based
products. Therefore, the MACT floor regulatory Alternative,
which is shown in Table 11, is the only one offered.
It should be noted that the EPA, in conjunction with
industry, State agencies, and other "partners," has made
Presumptive MACT (P-MACT) determinations for the Flexible
Polyurethane Foam Production Source Category.9 For molded
foam, Regulatory Alternative 3 (for existing sources), and
Regulatory Alternative 1 (for new sources) were selected as P-
MACT.
9 Memorandum. Williams, A. and Norwood, P., EC/R
Incorporated, to Svendsgaard, D., U.S. Environmental Protection
Agency. Summary of August 22, 1995 Flexible Polyurethane Foam
Production Presumptive MACT Roundtable Meeting. October 1995.
-------
13
TABLE 10. REGULATORY ALTERNATIVES FOR MOLDED FOAM
EXISTING SOURCES
Regulatory
Alternative
MACT Floor
«
1
2
Hixhead Flush
no control
work practice
HAP prohibition
Mold Release
Agents
HAP prohibition
t
;
Repair
Adhesives
HAP prohibition
t
*
TABLE 11. REGULATORY ALTERNATIVES FOR MOLDED FOAM -
NEW SOURCES
Regulatory
Alterative
MACT Floor
Mixhead Flush
HAP prohibition
Mold Release
Agents
HAP prohibition
Repair
Adhesives
HAP prohibition
Slabstock Foam
Two existing source alternatives'above the MACT floor were
developed for slabstock production. These alternatives are
presented in Table 12. Alternative la adds a unique LDAR program
for equipment leak emissions, and increases the level of control
for HAP ABA emissions to the intermediate emission limit.
Alternative la was selected as P-MACT.
Alternative Ib is approximately equivalent to Alternative la
in stringency, but incorporates a novel implementation approach
that would reduce the reporting, recordkeeping, and monitoring
burden on the industry. During the P-MACT process, industry was
concerned that the cost of controlling ABA emissions from
storage/unloading and equipment leaks was unreasonable, given the
relatively low emissions from these sources (around 50 tons per
year, or 0.2 percent). Under Alternative la, the amount of HAP
ABA allowed to be emitted from the entire facility would be
determined using the HAP ABA emission limit equation and
formulation limitations. This limit would then apply to the
entire facility, rather than only to the HAP ABA added at the
mixhead. In the absence of add-on control, the entire amount of
HAP ABA used is emitted. Therefore, the total amount of HAP ABA
used during the compliance time period would be compared to the
emission limit to determine compliance. Under this alternative,
the amount of ABA used could be determined using simple inventory
procedures, in lieu of more expensive LDAR techniques. This
approach would encourage the source to reduce storage and
-------
14
equipment leak emissions so more ABA would be available to be
used in foam formulations, while giving them considerable
flexibility.
Alternative 2 would totally eliminate HAP ABA emissions, and
would require controls for TDI storage/unloading and equipment
leaks.
There are« also two regulatory alternatives above the new
source MACT floor developed for new slabstock sources, which are
shown in Table 13. These alternatives mirror the existing source
alternatives discussed above, except that the new source HAP ABA
formulation limitations are used.
TABLE 12. REGULATORY ALTERNATIVES FOR SLABSTOCK FOAM -
EXISTING SOURCES
Reg.
Alt.
MACT
Floor
la
Ib
2
Storage/
Unloading
HAP ABA &
TDI -
vap bal/
carbon
t
Components in HAP
Service
TDI pumps - leakless
Other HAP components
- no control
TDI & HAP ABA pumps
- leakless
Other HAP components
- LDAR
Equipment
Cleaning
HAP
prohibition
+
HAP ABA
Emissions
Existing
source MACT
floor HAP ABA
emission limit
Intermediate
HAP ABA
emission limit
TDI - vapor balance, leakless pumps, and LDAR
HAP ABA - Intermediate HAP ABA emission limit for total facility
t
TDI pumps - leakless
Other TDI components
- LDAR
*
HAP ABA
prohibition
-------
15
TABLE 13. REGULATORY ALTERNATIVES FOR SLABSTOCK FOAM -
NEW SOURCES
Reg.
Alt.
MACT
Floor
la
Ib
2
Storage/
Unloading
HAP ABA &
TDI <-
vap tiki/
carbon
4
Components in HAP
Service
TDI pumps
- leakless
Other HAP components
- no control
TDI pumps
- leakless
Other HAP components
- LDAR
Equipment
Cleaning
HAP
prohibition
4
HAP ABA
Emissions
Existing
source MACT
floor HAP ABA
emission
limit
Intermediate
new source
HAP ABA
emission
limit
TDI - vapor balance, leakless pumps, and LDAR
HAP ABA - New Source intermediate HAP ABA emission limit for total
facility
TDI -
vap bal/
carbon
TDI pumps
- leakless
Other TDI components
- LDAR
+
HAP ABA
prohibition
-------
ffj
Environmental Consulting and Research
MEMORANDUM
Date: June 17, 1996
Subject: Estimated Regulatory Alternative Impacts for Flexible
. Polyurethane Foam Production
From: Phil Norwood, EC/R Incorporatec
Amanda Williams, EC/R Incorporated
To: David Svendsgaard, EPA/OAQPS/ESD/OCG
The purpose of this memorandum is to present the estimated
cost and primary environmental impacts of the hazardous air
pollutant (HAP) regulatory alternatives for existing sources.
These regulatory alternatives are under consideration by the
Environmental -Protection Agency (EPA) for the proposed flexible
polyurethane foam production National Emission Standard for HAP
(NESHAP) . This memorandum is organized as follows: the first
section presents the regulatory alternatives; the second section
provides the model -plant costs and HAP emission reductions; and
the final sections present the nationwide regulatory' alternative
costs and HAP emission reductions. There are no anticipated new.
source impacts for this source category. The industry has stated
that there is enough unused capacity at existing facilities to
handle any increased demand for foam products.1 Therefore, no
impacts are expected for new sources.
REGULATORY ALTERNATIVES
For purposes of the Foam Production NESHAP, the EPA has
separated, the flexible polyurethane foam production source
category into three subcategories: Slabstpck Foam Production and
Molded Foam Production. Rationale for this decision is provided
in a separate memorandum.2 .
1 Memorandum. Seaman, J., EC/R Incorporated, to
Svendsgaard, D., U.S. Environmental Protection Agency. Summary
of the March 7, 1996 Meeting Between the EPA and Polyurethane
Foam-Association Representatives. April 22, 1996.
2 Memorandum from Williams, A. and Norwood,. P.> EC/R
Incorporated, to Svendsgaard, D., U.S. Environmental Protection
Agency. Subcategorization of the Flexible Polyurethane Foam
Production Source Category. June 17, 1996.
3721-D University Drive .• Durham, North Carolina 27707
Telephone: (919) 493-6099 • Fax: (919) 493-6393
-------
For each subcategory, the first regulatory alternative
represents the maximum achievable control technology (MACT)
"floor" level of control. This level of control is the minimum
stringency for a NESHAP developed in accordance with section
112(d) of the Clean Air Act. Existing source regulatory
alternatives more stringent than the floor level were also
developed for each of these subcategories. Control options more
stringent than the new source floor levels were not identified
for either subcategory; therefore, no alternatives more stringent
than the new spurce floors were developed. Documentation of the
MACT floor determinations and explanation of regulatory
alternative development are provided in separate memoranda.3'4
*
Molded Foam Production
The regulatory alternatives for molded foam production are
provided in Tables 1 and 2. Each regulatory alternative contains
requirements for HAP emissions from three emission sources:
mixhead cleaning, or "flushing"; mold release agent usage; and
the use of HAP-based adhesives to repair damaged foam.
TABLE 1. REGULATORY ALTERNATIVES FOR MOLDED FOAM -
EXISTING SOURCES
Regulatory
Alternative
MACT Floor
1
2
Mixhead Flush
no control
work practice
HAP prohibition
Mold Release
Agents
HAP prohibition
*
*
Repair
Adhesives
HAP prohibition
l
*
Table 1 shows the three existing source regulatory
alternatives. Since the MACT floor prohibits the use of HAP-
based mold release agents and adhesives, the only emission source
with the potential for more stringent requirements is mixhead
flushing. The first regulatory alternative requires work
3 Memorandum, Williams, A. and Norwood, P., EC/R
Incorporated to Svendsgaard, D., U.S. Environmental Protection
Agency. MACT Floors for Flexible Polyurethane Foam Production.
June 17, 1996.
4 Memorandum, Williams, A. and Norwood, P., EC/R
Incorporated to Svendsgaard, D., U.S. Environmental Protection
Agency. Regulatory Alternatives for New and Existing Source in
the Flexible Polyurethane Foam Industry. June 17, 1996.
-------
practices to reduce mixhead flushing emissions, and the second
prohibits the use of HAP-based mixhead flushes.
TABLE 2. REGULATORY ALTERNATIVES FOR MOLDED FOAM -
NEW SOURCES
Regulatory
Alterative
MACT Floor*
Mixhead Flush
HAP
prohibition
Mold Release
Agents
HAP prohibition
Repair
Adhesives
HAP
prohibition
Table 2 shows the single new source regulatory alternative,
which represents the new source MACT floor. This alternative is
equivalent to existing source regulatory alternative 2.
Slabstock Foam Production
The regulatory alternatives for slabstock foam production
are provided in Tables 3 and 4. Attachment 1 provides more
detail on the HAP ABA limitations. Each regulatory alternative
contains requirements from four emission sources: storage/
unloading, equipment cleaning, equipment leaks, and auxiliary-
blowing agent (ABA) usage. The storage and equipment leak
alternatives specify separate requirements for toluene
diisocyanate (TDI), which is a reactant in the formation of
polyurethane foam, and HAP ABA. Methylene chloride (MeCl2) is
the HAP frequently used as both an ABA and as an equipment
cleaner. Throughout this memorandum, HAP ABA and MeCl2 are used
interchangeably.
As shown in Table 3, there are three existing source
regulatory alternatives for slabstock foam. The first
alternative beyond the MACT floor, which has two implementation
options (la and Ib), increases the stringency of the requirements
for equipment leak and ABA usage emissions. Option la requires
the combination of equipment modifications and the execution of a
leak detection and repair (LDAR) program to reduce equipment leak
emissions. It also includes a lower allowable HAP ABA emission
level. Option Ib is considered to be equivalent to la in the
level of stringency, but it provides the flexibility for a source
to select controls for storage/unloading, equipment leaks,
equipment cleaning, and HAP ABA usage. Option Ib would require
the same controls for TDI as Option la.
Option 2 prohibits HAP ABA emissions. This would, in
effect, prohibit the usage of any MeCl2 as an ABA. Since no HAP
ABA would be allowed, there is no need for HAP ABA storage or
equipment leak requirements.
-------
TABLE 3. REGULATORY ALTERNATIVES FOR SLABSTOCK FOAM -
EXISTING SOURCES
Reg.
Alt.
MACT
Floor
la
Storage/
Unloading
HAP ABA &
TDI -
vap bal/
carton
*
Components in HAP
Service
TDI pumps - leakless
Other HAP components
- no control
TDI pumps - leakless
Other HAP components
- unique LDAR
Equipment
Cleaning
HAP
prohibition
i
HAP ABA
Emissions
Existing
source MACT
floor HAP
ABA emission
limit
Intermediate
HAP ABA
emission
limit
Ib
TDI - vapor balance, leakless pumps
HAP ABA - Intermediate HAP ABA emission limit for total
facility
2»
TDI - vap
bal /carbon
TDI pumps -
leakless
*
HAP ABA
prohibition
Since the use/emission of HAP ABA is prohibited under regulatory
alternative 2, there are no requirements needed for
storage/unloading of HAP ABA or for equipment leaks in HAP ABA
service.
There are also two regulatory alternatives above the new
source MACT floor developed for new slabstock sources, which are
shown in Table 4. These alternatives mirror the existing source
alternatives discussed above, except that the new source HAP ABA
formulation limitations are used.
MODEL PLANT COSTS AND EMISSION REDUCTIONS
This section presents the model plant costs and primary
environmental impacts (i.e., HAP emission reductions) for
technologies needed to meet the levels contained in the
regulatory alternatives discussed earlier. While the bases for
the model plants are provided in a separate memorandum,5 the
baseline model plant parameters are provided in Attachment 2.
5 Memorandum. Williams, A., EC/R Incorporated, to
Svendsgaard, D., U.S. Environmental Protection Agency. Flexible
Polyurethane Foam Model Plants. June 17, 1996.
-------
TABLE 4. REGULATORY ALTERNATIVES FOR SLABSTOCK FOAM -
NEW SOURCES
Reg.
Alt.
MACT
Floor
la
Ib
2
Storage/
Unloading
HAP ABA &
TDI -
vap bal/
carbon
•
*
Components in HAP
Service
TDI pumps
- leakless
Other HAP components
- no control
TDI pumps
- leakless
Other HAP components
- LDAR
Equipment
Cleaning
HAP
prohibition
*
HAP ABA
Emissions
Existing
source MACT
floor HAP ABA
emission
limit
Intermediate
new source
HAP ABA
emission
limit
TDI - vapor balance, leakless pumps, and LDAR
HAP ABA - New Source intermediate HAP ABA emission limit for total
facility
TDI -
vap bal/
carbon
TDI pumps
- leakless
Other TDI components
- LDAR
i
HAP ABA
prohibition
The EPA document, "Flexible Polyurethane Foam Emission
Reduction Technologies - Cost Analysis,"6 was used as the basis
for the majority of the model plant costs. This document went
through various review phases by the EPA and the flexible
polyurethane foam industry. This document will hereafter be
referred to as the "Cost Document."
There are several situations where all or some portion of
the model plant annual costs are negative (i.e., cost savings).
Throughout this memorandum, cost savings will be denoted in
parentheses.
Molded Foam Production
There are four molded foam production model plants. One of
these model plants represents larger molded foam facilities using
high-pressure mixheads, primarily to produce automobile seats.
6 Flexible Polyurethane Foam Emission Reduction
Technologies Cost Analysis. EPA-453/R-95-011. U.S.
Environmental Protection Agency, Research Triangle Park, North
Carolina. September 1996.
-------
The remaining three model plants represent smaller producers that
use low-pressure mixheads to produce a variety of foam products.
The molded foam production model plant costs were developed
directly from the Cost Document, except that the costs were
adjusted to the characteristics of the model plants. All
technologies, except for work practices to reduce mixhead
flushing emissions, totally eliminate HAP emissions. These model
plant costs are applicable both to new and existing sources. The
following sections provide brief descriptions of the technologies
and model plant impacts estimations for each emission source.
More details regarding the molded foam model plant costs are
provided in Attachment 3.
Mixhead flushing
Model plant impacts were developed for four technologies to
reduce or eliminate mixhead flushing emissions: work practices
for regulatory alternative 1; and non-HAP flushes, high-pressure
mixheads, and self-cleaning mixheads for regulatory
alternative 2. Costs were developed for the work practice of an
emission suppression and solvent recovery system for the MeCl2
used to flush the mixhead. The emission reduction efficiency for
such a system was reported at around 75 percent.7 For the three
remaining technologies, the emission reduction was 100 percent.
Table 5 presents a summary of the model plant costs for mixhead
flushing.
Mold release agents
The MACT floor level of control for mold release agents is
the prohibition of the use of HAP-based mold release agents,
resulting in a 100 percent emission reduction. Model plant
impacts were developed for three technologies that can achieve
this level: reduced volatile organic compound (VOC) mold release
agents, naphtha-based mold release agents, and water-based mold
release agents. A summary of mold release agent model plant
costs is contained in Table 6.
Repair adhesives
The MACT floor level of control for repair adhesives is also
the prohibition of the use of HAP-based adhesives, resulting in a
100 percent emission reduction. Model plant impacts were
developed for three technologies that can achieve this level:
hot-melt adhesives, water-based adhesives, and hydrofuse
adhesive. Table 7 provides a summary of the repair adhesive
model plant costs.
Reference 6, page 4-9.
-------
TABLE 5. MOLDED FOAM MODEL PLANT COSTS FOR TECHNOLOGIES TO
REDUCE MIXHEAD FLUSHING HAP EMISSIONS
Costs (1994 dollars)
TecnnoJ.ogy gp
Model
Plant
LP Model
Plant 1
LP
Model
Plant 2
LP
Model
Plant 3
Non-HAP Flush
Capital Investment ($) $0 $0 $0 $0
Annual Cost ($/yr) $0 ($920) ($3,823) ($8,065)
Emission Reduction (tons/yr) 0 5.14 19.69 21.31
Cost Effectiveness ($/ton) $0 -a -a -a
High-pressure Mixhead
Capital Investment ($) $0 $658,125 $658,215 $658,125
Annual Cost ($/yr) $0 $163,815 $146,107 $112,535
Emission Reduction (tons/yr) 0 5.14 19.69 21.31
Cost Effectiveness ($/ton) $0 $31,871 $7,420 $5,281
Self-Cleaning Mixhead
Capital Investment ($) $0 $225,688 $225,688 $225,688
Annual Cost ($/yr) $0 $34,938 $17,231 ($16,341)
Emission Reduction (tons/yr) 0 5.14 19.69 21.31
Cost Effectiveness ($/ton) $0 $6,797 $875 -a
Solvent Recovery System
Capital Investment
Annual Cost ($/yr)
Emission Reduction
Cost Effectiveness
($)
(tons/yr)
($/ton)
$0
$0
0
$0
$47,250
$23,412
3.86
$6,073
$47,250
$10,131
14.77
$686
$47,250
($15,048)
15.98
_a
Cost effectiveness not calculated because net annualized cost is a
negative quantity (cost savings).
Slabstock Foam Production
There are five basic model plants for slabstock foam,
representing varying levels of production. Each basic model
plant is separated into facilities that use MeCl2 as an equipment
cleaner, and facilities that do not.
Several sources were used to estimate costs for the
slabstock foam production model plants. Information developed
for other EPA efforts was used for equipment leak and storage
tank impacts, supplemented by vendor quotes. The HAP ABA and
equipment cleaning costs were primarily derived from the Cost
Document. The following sections provide more discussion on the
derivation of impact estimates for each emission source type.
-------
TABLE 6. MOLDED FOAM MODEL PLANT COSTS FOR TECHNOLOGIES TO
REDUCE MOLD RELEASE AGENT HAP EMISSIONS
Costs (1994 dollars)
Technology
HP
Model
Plant
LP
Model
Plant 1
LP
Model
Plant 2
LP
Model
Plant 3
Reduced-VOC Agent
Capital Investment ($)
Annual Cost ($/yr)
Emission Reduction (tons/yr)
Cost Effectiveness ($/ton)
Naphtha-Based Agent
Capital Investment ($)
Annual Cost ($/yr)
Emission Reduction (tons/yr)
Cost Effectiveness ($/ton)
$0
$0
0
$0
$0
$50
0.15
$337
$0
$39
0.12
$328
$0
$1,023
6.00
$171
$0
$0
0
$0
$0
$375
0.15
$2,500
$0
$293
0.12
$2,439
$0
$7,599
6.00
$1,267
Water -Based Agent
Capital Investment
Annual Cost ($/yr)
Emission Reduction
Cost Effectiveness
($)
(tons/yr)
($/ton)
$0
$0
0
$0
$0
$48
0.15
$323
$0
$38
0.12
$315
$0
$981
6.0
$163
Storage/unloading
The MACT floor level of control for storage and unloading of
both TDI and HAP ABA is an equipment standard that requires
either a vapor balance system to return the displaced HAP vapors
to the tank truck or rail car, or a carbon canister through which
emissions must be routed prior to being emitted to the
atmosphere. The subsequent regulatory alternatives do not
contain more stringent requirements. However, since there are no
HAP ABA emissions allowed under regulatory alternative 2, there
will be no storage tanks containing HAP ABA under regulatory
alternative 2. While the storage/unloading emissions will be
zero, it is not appropriate to attribute this reduction to a
storage tank control program. Therefore, the emission reductions
are indirectly attributed to the HAP ABA requirements of
regulatory alternative 2.
The model plant impacts are based on the installation of
vapor balance. The basis for estimating vapor balance impacts
was the Background Information Document for the proposed gasoline
-------
TABLE 7. MOLDED FOAM MODEL PLANT COSTS FOR TECHNOLOGIES TO
REDUCE HAP EMISSIONS FROM THE USE OF FOAM REPAIR ADHESIVES
Technology
HP
Model
Plant
Costs (1994 dollars)
LP
Model
Plant 1
LP
Model
Plant 2
LP
Model
Plant 3
Hot-Melt Adhesive
Capital Investment {$) $6,804
Annual Cost ($/yr) $6,377
Emission Reduction (tons/yr) 2.09
Cost Effectiveness ($/ton) $3,047
Hydrofuse Adhesive
Capital Investment ($) $5,670
Annual Cost ($/yr) $738
Emission Reduction (tons/yr) 2.09
Cost Effectiveness ($/ton) $353
$0
$0
0
$0
$0
$0
0
$0
$0
$0
0
$0
$0
$0
0
$0
$6,804
$1,869
1.35
$1,384
$5,670
$1,001
1.35
$741
Water-Based Adhesive
Capital Investment
Annual Cost ($/yr)
Emission Reduction
Cost Effectiveness
($)
(tons/yr)
($/ton)
$0
($854)
2.09
_a
$0
$0
0
$0
$0
$0
0
$0
$0
($97)
1.35
_a
Cost effectiveness not calculated because net annualized cost is a
negative quantity (cost savings).
distribution NESHAP.8 This document asserts that the emission
reduction for vapor balance is 95 percent. The bulk plant model
plant costs in the referenced document include costs for vapor
balancing both incoming and outgoing loads. The unloading of TDI
and MeCl2 at flexible polyurethane foam facilities is comparable
to "incoming loads" at bulk plants. The capital cost (1990 base
year) of incoming loads at bulk plants ($7,981) was divided by
two (there were two tanks in the bulk plant model plant), and
adjusted to 1994 dollars using the Chemical Engineering Plant
Cost Index (368.1 H- 357.4).9 Therefore, the capital cost of
vapor balancing used in this analysis was $4,110 per storage
vessel. The annual costs were calculated with the following
elements:
8 Gasoline Distribution Industry (Stage I) - Background
Information for Proposed Standards. EPA-453/R-94-002a. U.S.
Environmental Protection Agency. Research Triangle Park, North
Carolina. January 1994. Pages 4-34 and 7-17.
9 Chemical Engineering Economic Indicators. Chemical
Engineering. June 1995. Page 158.
-------
10
• Operating and maintenance costs (3 percent of total
capital costs),
• Capital recovery costs (7 percent interest rate for
10 years, for a capital recovery factor of 14.24
percent), and
• Taxes and insurance (4 percent of total capital
investment).
In addition, recovery credits were included in the annual costs
to recognize the savings that will occur due to the TDI or MeCl2
that will no longer be lost to the atmosphere. The chemical
costs used to calculate recovery credits were $0.40 per pound for
MeCl2 and $1.00 per pound for TDI.
The slabstock foam production model plant costs for
storage/unloading emission control are provided in Table 8.
There are no costs for model plants 4 and 5 because all TDI and
MeCl2 storage tanks for these model plants were assumed to be
controlled at baseline. Also, TDI storage tanks at model plant 3
were assumed to be controlled. More detail on these model plant
impacts is provided in Attachment 4.
TABLE 8. SLABSTOCK FOAM MODEL PLANT COSTS
FOR VAPOR BALANCING
Costs (1994 dollars)
Model Model Model
Plant 1 Plant 2 Plant 3
Regulatory Alternative 1
Capital Investment
Annual Cost ($/yr)
Emission Reduction
Cost Effectiveness
($)
(tons/yr)
($/ton>
$8.220
$1,673
0.083
$20,244
$12,330
$2,402
0.247
$9,723
$4,110
$438
0.494
$887
Regulatory Alternative 2
Capital Investment
Annual Cost ($/yr)
Emission Reduction
Cost Effectiveness
($)
(tons/yr)
($/ton)
$4,110
$873
-0
$9,100,000
$8,220
$1,746
-0
$3,700,000
-------
11
Equipment cleaning
The MACT floor level of control for chemical cleaning is the
complete elimination of HAP emissions. The subsequent regulatory
alternatives do not contain more stringent requirements. While
there are several alternatives available to eliminate the use of
MeCl2 or other HAP's to clean the mixhead and other equipment,
model plant costs were developed for only one alternative: non-
HAP cleaners. Details of these model plant impacts are provided
in Attachment 5.
The amount of MeCl2 to clean the equipment is consistent for
all model plants. Therefore, the impacts shown below are
applicable for all model plants. The basis for the model plant
costs is the Cost Document.10
Capital Cost - $0
Annual Cost - ($275)/yr
Emission Reduction - 5.0 tons/yr
Cost Effectiveness not applicable
Equipment leaks
The MACT floor level of control for equipment leaks was
determined to be sealless pumps for TDI transfer pumps. The
first regulatory alternative adds a unique LDAR program for HAP
ABA components. Since regulatory alternative 2 does not allow
the emission of any HAP ABA (which, in effect, prohibits the use
of MeCl2 or any other HAP as an ABA) , this alternative only
contains the MACT floor requirement for TDI pumps.
MACT floor. For the MACT floor regulatory alternative, the
cost would simply be the cost of replacing existing TDI transfer
pumps with sealless pumps for model plant 1. All other model
plants have sealless TDI transfer pumps at baseline. The capital
cost of a sealless pump was estimated by a foam producer to be
$5,000 per pump.11 The annual cost was calculated as the
capital recovery (7 percent for 10 years) minus the recovery
credit. It was assumed that a sealless pump would achieve a
100 percent emission reduction. Therefore, the impacts of the
slabstock foam production MACT floor for equipment leaks for
model plant 1 are as follows:
Capital Cost - $5,000
Annual Cost - $l,265/yr
Emission Reduction - 0.17 tons/yr
Cost Effectiveness $7,600/ton
10 Reference 6, page 5-19.
11 Telecon, Norwood, P., EC/R Incorporated with Barger, S.,
Olympic Products. Discussing cost of sealless TDI pumps.
December 12, 1995.
-------
12
Regulatory alternative 1. As noted above, regulatory
alternative 1 includes an LDAR program for HAP ABA. The elements
of the program for which impacts were developed are provided in
Table 9, along with the emission reduction used for each type of
component. The percentage emission reductions are based on EPA's
Equipment Leak Protocol Document.12
TABLE 9. SLABSTOCK FOAM REGULATORY ALTERNATIVE 1
EQUIPMENT LEAK PROGRAM
Component
Control Options
Technology
for which
impacts
developed
Emission
reduction
TDI
Pumps
Sealless pumps for
transfer pumps
No control for
metering pumps
Sealless
pumps
100%
Other Components No control
MeCl2
Pumps
Valves
Connectors
Quarterly LDAR -
10,000 ppm leak
definition
OR
Sealless pumps
Quarterly LDAR - 10,000
ppm leak definition
Annual LDAR (see HON)
Open-ended lines Blind, cap, plug, or
second valve
Quarterly 45%
LDAR
Quarterly 67%
LDAR
Annual 93%
Second valve 100%
Costs from the impacts analysis for the proposed Hazardous
Organic NESHAP (HON)13 were used to estimate equipment leak
impacts for regulatory alternative 1, which are shown in
12 Protocol for Equipment Leak Emission Estimates. EPA-
453/R-93-026. U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina. June 1993. Page 5-9.
13 Hazardous Air Pollutant Emissions from Process Units in
the Synthetic Organic Chemical Manufacturing Industry --
Background Information for Proposed Standards. Volume IB:
Control Technologies. EPA-453/D-92-Ol6b. U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina.
November 1992. Pages 3-27 through 3-60.
-------
13
Table 10. The costs were updated from the 1989 base year to 1994
using the Chemical Engineering Plant Cost Index.14 Component-
specific impacts are provided in Attachment 6.
TABLE 10. SLABSTOCK FOAM REGULATORY ALTERNATIVE 1
EQUIPMENT LEAK MODEL PLANT IMPACTS
Costs (1994 dollars)
Model Model Model Model Model
Plant 1 Plant 2 Plant.3 Plant 4 Plant 5
Capital Investment
($)
Annual Cost ($/yr)
Emission Reduction
(tons/yr)
Cost Effectiveness
($/ton)
$12,544 $7,544 $7,544 $7,544 $7,431
$7,245 $5,980 $5,980 $5,980 $5,810
1.2 1.0 1.0 1.0 0.8
$6,193 $5,960 $5,960 $5,960 $6,996
Regulatory alternative 2. Since there are no HAP ABA
emissions allowed under regulatory alternative 2, there will be
no components in HAP ABA service. While the equipment leak
emissions will be zero, it is not appropriate to attribute this
reduction to an equipment leak control program. Therefore, the
only direct equipment leak impacts under this regulatory
alternative will be the TDI cost and emission reduction
associated with the MACT floor regulatory alternative. The HAP
ABA equipment leak emission reductions are indirectly attributed
to the HAP ABA requirements of regulatory alternative 2.
HAP ABA emissions
There are three levels of control for HAP ABA emissions.
The MACT floor and first regulatory alternative levels are
emission limits based on formulation limitations (see
Attachment 1) . Applying the two sets of formulation limitations
to the product mix of the model plants results in the emission
reductions shown in Table 11. More detail on the determination
of these emission reductions is provided in Attachment 7. The
second regulatory alternative requires the complete elimination
of HAP ABA emissions.
For each level of control, model plant impacts were
developed for several technologies. While there are numerous
technologies available to reduce HAP ABA emissions, the
14
Reference 9.
-------
TABLE 11.
14
MODEL PLANT HAP ABA REGULATORY ALTERNATIVE
EMISSION REDUCTIONS
Model
Plant
1
2
3
4
5
Baseline
HAP ABA
Emissions
(tons/yr)
55
165
330
335
380
HAP ABA
MACT Floor
31.3
93.8
184.0
195.9
220.4
Emission Reduction
(tons/yr)
Reg Alt 1 Reg Alt 2
37.9
113.7
222.7
237.7
268.0
55
165
330
335
380
effectiveness of individual technologies is widely disputed
within the foam industry. Therefore, EC/R made assumptions,
based on our knowledge of the industry, regarding the
technologies that could be used to meet each of the three HAP ABA
levels of control. Table 12 shows the technologies assumed for
each regulatory alternative level.
As can be seen in Table 12, it is assumed that some
technologies can be used to meet more than one level of control.
In these cases, it was assumed that the technologies would only
be used to the degree necessary to meet the level of the
regulatory alternative. In other words, although variable
pressure foaming can be used to totally eliminate the use of HAP
ABA, it was assumed that at the MACT floor level, the amount of
MeCl2 allowed would still be used and emitted.
The HAP ABA emission reduction technology costs from the
Cost Document provide the basis for the model plant costs.
However, as noted above, it was assumed that each technology was
used only to meet the level of the regulatory alternative. In
addition to changing the emission reduction, this also affected
the annual costs. The elements of the annual costs most .
frequently affected were the material cost savings from the
discontinued use of MeCl2 and the licensing fees, which were
often based on the amount of foam produced using the licensed
technology. The assumptions made in deriving the annual costs
are described below.
Chemical alternatives. It is assumed that the only
regulatory alternative that can be met solely by the use of
chemical alternatives is the MACT floor alternative. The capital
costs of the use of chemical alternatives are the same for all
-------
15
TABLE 12. TECHNOLOGIES ASSUMED TO ACHIEVE THE HAP ABA
REGULATORY ALTERNATIVE LEVELS
Regulatory Alternative
Technology
MACT Floor Level
Chemical alternatives
Carbon dioxide as an ABA
Acetone as an ABA
Variable pressure foaming
Forced cooling
Regulatory Alternative 1
Carbon dioxide as an ABA
Acetone as an ABA
Variable pressure foaming
Forced cooling
Regulatory Alternative 2
Carbon dioxide plus chemical
alternatives
Acetone as an ABA
Variable pressure foaming
Forced cooling plus chemical
alternatives
model plants. Therefore, the capital recovery and other indirect
annual costs (which are a function of the total capital
investment) are also uniform. The other contribution to the
annual cost is the materials cost. This is the cost of the
chemical alternatives minus the cost of the MeCl2 no longer used.
The model plant chemical alternative costs are summarized in
Table 13. Details of these costs are provided in Attachment 8.
Carbon dioxide as an ABA. It is assumed that the HAP ABA
requirements for the MACT floor and first regulatory alternative
can be met using carbon dioxide as an ABA. While there are other
carbon dioxide systems available, the model plant costs presented
for carbon dioxide as an ABA are costs of the licensed CarDio
technology. The model plant costs for CarDio are summarized in
Table 14, and details are provided in Attachment 9. The capital
costs for the installation of the CarDio technology are uniform
for all regulatory alternatives for all model plants. Therefore,
the annual capital recovery charges are also analogous for all
situations. Similarly, the carbon dioxide tank rental fee is the
same in all situations. The materials costs consist of the costs
of the liquid carbon dioxide minus the MeCl2 savings.
-------
16
to
p
H
EH
2
W
EH
a
*3
o
H
H
0
(4 O
O H
h EH
H B
CO H
2!
fe H
rtj CO
J CO
Ot H
W
O BQ
^•f -•
_
*E| 04
IT ^tf
o a
b
«
CJ
o
EH
CO
59
^5
^3
CO
.
m
H
• _
•l
>H
H
in
&
"
2 a
« *
H
r-l
0
•o
0
Ot
1-1
_ ro
* 0<
ii ^2
B *
s
§
H
Q,
H
ii
|mf
A.
M
tn
CN
1^
H
ro
v>
* M
t-
H
•W-
in
(N
H
m
•w-
in
(N
H
v>
in
^^
.
ro
^^
•w-
4J
C
0)
e
03
4)
>
n c
O H
0
rH rH
h «
4J
U ft
£j A
a u
Ol
o\
CO
^
ro
•
CN
O
N.
1
m
H
r-
H
in
H
•w-
(N
in
t
in
•w-
^
"57
^
>^,_
•o>
*•**
jj
m
s
iH
n)
3
^
.
o
V*
™
in
^
•H
j_)
U
0)
1-1
JJ
m
o
-------
17
O
J-l
y
MjJ
i4^
^J
Ol
M<
O
b
to
M
CO
o &
o o
H
t-t t-t
p* r1
Pv f •
3 ^
i. P
J Q
PU H
S
H 2
O O
O H
S CO
CO
Sj H
o S
fc.
KJJ
89
go,
CO rt
flQ kC
2
CO
^l»
H
w
J
§
in
g<
S
•<»<
&
s
«••.,
«>•
o
o\
o\
H
0)
JJ
a
o «•>
u o<
S
jj
§
H
CM
rH
O
•a
S
d
CM
^4
S
0 £J
° s r
m - o «
S M £
,
§ «•>
n JJ oo vo
_T ro CO
^ S w
«• **
1 § „ 5
• ^ -CM
s s « «
s »
"£
>. —
^ c
00 O
a jj
-^ o -^
JJ 0-
jj -~ C oi
C M O ffl
4) >i -H 4>
6 -- JJ C
4J O fl)
01 *- 3 >
0) 73 -H
> Jj 0) JJ
n C 01 PS u
0 M O fl)
0 U C «w
i-l i-H O >M
fc, oo o
S ro v> '
? •* N
«• £
0 H
2 « f
m vo
w - P- «
^ OD n i
J <*> N
w
VJ" %l— ^
if-:
m" - N *
Xj M (N 1
3 <* N
«• S
O .«
s s ^ -
a a 3 S
*> **
° S H
n £ m in
- " • r-
w ko" f
« S M H
x s «
"57
>. —
\ c
iH 01 O
C JJ
0 — 0 -v.
> -W- JJ *>
•rl •— -" ~-
JJ
« JJ ~- C 01
C C ^ O W
M 0) >i -H 0)
o e -^ jj c
4i JJ -W- U
<< 0) "O -H
> JJ fl) JJ
S C 01 oi u
b H O 0)
0 O C «M
JJ iH 0
« H
2. «•
v>
in tT
s i «,
? - n n
£ m ro i
S N
5 S
§ § . -
H " S »
* S
«> **
8 • S
• " in ui
Si's
«> w
"57
^ B
d 01 O
C JJ
« -^ O ^
> V> JJ -M-
•H iH — ' — ' -»
a «
« u jj — C ra
6-rt C M O n
8 0) s -H a)
o o e -v. jj c
JJ X JJ -0 U 0)
i-l O TO -" 3 >
<< O OJ T) -H
a « > jj o jj
>,3 > C 01 PS U
U iH -H H 0 0)
O Qi-U O C «W
JJ «) i-i 0 «M
« 0 C <8 H -H H
i-l vl M JJ R) O
S Q 9 -H 3 m JJ
n u 4i o» a -rt a
0 «H
•H
JJ
a
tn
0)
C
n)
m
•H
jj
01
o
u
•o
v
N
•H
i-l
5t annua
v/
c
0)
n
n)
u
4)
J2
T3
fl)
JJ
IB
rH
3
U
r- 1
(Q
U
JJ
O
m
a
4)
0)
•H
jj
u
4) •
<4-l —
14-1 D}
4) (71
C
JJ -H
0 >
O (0
U 01
a
-------
18
The licensing fee for Cardio is 1 percent of the chemical
cost for foams made with Cardio. The industry representative
states that the chemical cost for making Cardio was $0.72 per
pound. Therefore, to estimate the licensing fee for each
regulatory alternative for each model plant, it was necessary to
predict which foam grades each model plant would chose to make
using CarDio. It was assumed that each model plant would chose
to make the foams that had the largest amount of MeCl2
used/emitted until the necessary emission reduction was achieved.
The chemical qpsts and licensing fees were then calculated, based
on the weight of the selected grades produced. More detail on
this calculation is provided in Attachment 9.
It was assumed that the total elimination of HAP ABA
(regulatory alternative 2) could not be achieved using only
CarDio. This was because the base formulation would need more
than 3 parts MeCl2 per hundred parts polyol to allow the
substitution of carbon dioxide as an ABA. However, these low-ABA
foam grades could be produced using chemical alternatives.
Therefore, the combination of CarDio and chemical alternatives
was assumed to achieve the complete elimination of the use of HAP
ABA. The capital costs, capital recovery, and other indirect
annual costs for this combination were simply the sum of the
capital costs of CarDio and chemical alternatives.
For regulatory alternative 2, the procedure for calculating
the licensing fee for the foam grades made using Cardio was the
same as for the MACT floor and regulatory alternative 1 described
above. To calculate the material costs for the combination of
the two technologies, the material cost of making the foam grades
with CarDio (those with base formulations with greater than
3 parts MeCl2 per 100 parts polyol, or pph) was calculated and
added to the material cost of making the remaining foam grades
(less than 3 pph polyol grades) using only chemical alternatives.
Attachment 9 also illustrates this calculation.
Acetone as an ABA. It is assumed that acetone can be used
to meet the HAP ABA requirements for all three regulatory
alternatives. The model plant costs for acetone as an ABA are
summarized in Table 15, and detailed in Attachment 10. As with
CarDio, the capital costs, capital recovery, and other indirect
costs are the same for all model plants and for all regulatory
alternatives. The differences in annual costs are the result of
the differences in material costs and licensing fees. The
material costs were simply the cost of the acetone minus the
MeCl2 savings.
The licensing fee for acetone as an ABA operates on a graded
cost scale dependent on the amount of acetone used by the
facility. For the first 50,000 pounds of acetone used, the fee
is $0.16/lb, for the next 75,000 pounds the fee is $0.14/lb, and
for any additional acetone the fee is $0.12/lb. This fee is
subject to change with trends in acetone and MeCl2 costs. The
-------
19
licensing fee for each model plant was calculated using these
fees and the corresponding amount of acetone used for each model
plant.
Variable pressure foaming. It is assumed that the HAP ABA
requirements for all three - regulatory alternatives can be met
using variable pressure foaming technology. The capital costs
are consistent across all model plants for all regulatory
alternatives. Similarly, the utilities and labor costs, and
capital recovery and other indirect annual costs are also
consistent. Therefore, the only element that changes in the
variable pressure foaming model plant annual costs is the
material costs. Since there is not a need for additional
chemicals or other materials, this simply represents the cost
savings from the unused MeCl2. The variable pressure foaming
model plant costs are summarized in Table 16. Details are
provided in Attachment 11.
Forced cooling. It is assumed that the HAP ABA requirements
for the MACT floor and first regulatory alternative can be met
using forced cooling. While there are numerous forced cooling
systems in operation or under development in the United States,
the model plant costs presented are based on the Envirocure
technology. The model plant costs for forced cooling are
provided in Table 17. Details of these model plant costs are
provided in Attachment 12. The capital costs for the
installation of forced cooling are uniform for model plants 2
through 5 for all regulatory alternatives. The capital costs for
model plant 1 are lower, assuming that a smaller forced cooling
unit could be installed. Therefore, the annual capital recovery
charges and other indirect annual costs are analogous for all
regulatory alternatives. The utilities charges, which were
provided by the vendor, are also the same for all regulatory
alternatives. While the cost of the Envirocure technology would
include licensing fees, the model plant costs did not include
such fees.
It was assumed that the total elimination of HAP ABA
(regulatory alternative 2) could not be achieved using forced
cooling only. This assumption was made due to the many doubts
within the industry that low density, low internal force
deflection (IFD) foams of acceptable quality can be made using
forced cooling without any ABA. However, it was assumed that
these foam grades could be produced using the combination of
forced cooling and chemical alternatives. The capital costs,
capital recovery, and other indirect annual costs for this
combination were simply the sum of the capital costs of forced
cooling and chemical alternatives. More detail of this
calculation is provided in Attachment 12.
For regulatory alternative 2, as mentioned above, it was
assumed that forced cooling and chemical alternatives would be
used in tandem to make the low-density, low-IFD foam grades.
-------
20
ETONE
3
«
0
Dh
l*<
CQ
E-«
CQ H,
OS
UO
H
FH H
E U
§S
T Q
^§
MODEL
SSION
§H
fU]
o •*
h -^
f^
fad Q
CJ *
o -
Ms
KG
2
CQ
•
in
H
H
i-3
s
B
IH
in
g
2 1
e S3
H
rH
0
•0
o
at
2
•if-
«T - m «
3 5 H •
£ £
§ «
5 vo o
" H
«« - Tf «
£ H 00 •
2 n H
£ 2
o
o n
o oo oo —
- " « 5
O» 00 ON **
H «•
o .
0 rj CN
°. H "i £
** in lH
oj £ n H
H £? «>
•W- **
5 9
Q 0
C 4J
-^ O ^-
•CO- JJ i -H 0)
E ^ U C
JJ -co- O 0)
CO — 3 >
0) T3 -H
> JJ 4) JJ
H C 0} « O
OHO (U
O U C i
* ^ ^
*» 3
iS*
«T - f- *
en m M '
^ in
H i?
•CO- <*
__
u
>t —
\ C
H mo
C JJ
9 — O "v.
> *> 4.) •W-
•rt ^ — «-
JJ
« JJ — ti CO
C C ^ O 01
H O >t -H 0)
« E ^» JJ C
JJ JJ O 0)
H to — 3 >
4 « -a -H
> JJ 0) JJ
N C n o; o
MHO 0)
0 U C «w
JJ rH 0 <*-)
0 X) rH -H U
H jj nj 01
&-H 3 m JJ
ft C -H CO
• «J 3 6 o
Di CJ rtj W CJ
o "o
0 V
o co 0
•* ^ S *•
CT> CN •*> •
H H
•(O-
1 I
in o
« •>!•>«
3 S -0 '
£ £
0 £T
§ s
0 vo in
«« » vo «
S s H '
«• 2
o ...
§ S o
- M in vo
•» ^ «n •*
en r] w-
H "
«> *>
^
"M
>i .-~
Cl CO O
C JJ
o -~ o -^.
>• -CO- JJ •»•
•rl — •— —
JJ
« JJ ^v fi tO
e c ^ o to
k 0) >, -H a)
« E -^ jj a
JJ JJ <0- O tt)
rH CO — 3 >
< a> TJ -H
> JJ 4> JJ
IH C CD (U O
(4 H O 0)
O O C ,
JJ
-rl
I 1
•4J
C
1
4)
•H
JJ
(0
»
4)
C
as
CO
•H
jj
CO
o
0
•o
4)
N
•H
r-(
us
y
ns
.u
4)
c
4)
CO
3
n)
CJ
.8
'CJ
a>
.u
(0
i-H
3
U
rH
us
o
jj
o
a
a>
0)
4)
a
4)
>
•rl
JJ
CJ
4) •
H-l ~~
VM m
a> Cn
C
JJ -H
0) >
O nj
CJ m
<«
-------
21
CD
55
^_i
0
fa
H
g
CO
CO
W
K
fe
W
J
m
3
H
SB
K, r.
0 U
i
rn Q
H§
W«
O 2
O S
vj
t_ H
g CO
S CQ
"• 1— 1
r3 5
to H
r3 -<•
3 5
Q 3
I3
Sp,
5r§
s
o
fa
«
o
g
CQ
§
(•3
CO
•
vo
rH
W
-J
M
9
EH
in
1
£
'in ^*
Q 2^
J! g
rH
H
0
•o
o
Ot
0\
rH
a o
•" a
n S3
0
u
M
8
P*
rH
ffl
•M rj
•Q 01
0 2}
S *
rH
Q!
S3
o
O 0
O S
in N £ o)
- VO ™ •
i1
«/>
„ o
* 0 0
°. 2 * g
g « s "
in n« 2 <*>
- vo -w-
Tl< V>
•W-
o
o o
o •# 0 in
• N . *•
o » ., m
o N S
m in 2 ^
> vo rt -OT-
T*
•w-
o
0 0
O O f«l
» TJI 00 CS
o - • t^
O «i« ro »
in M o\ t^
- r-
•* -to
•w-
o
00 .
00 H
o* * 1 *
O ^ H ~
in r^- ro 2
- r** ^*
•ai in. V*
^* ^ff
v>
"E ^
^ C
00 O
C 4J
^ O "^
•w- AJ in-
*-" — — '
JJ — G to
C JH O M
0) >, -H «
6 \ 4J C
4J -W- O 0)
01 — 3 >
0) T3 -H
> U 0) 4J
rl C 0> K V
0 M O 0)
O O C
t o-
v>
o
o o
o oo _. ro
> r«. *"
o a\ £.
m o S «
- vo M
^< «•
•w-
o
0 O
0 00 p. 0
- (N ^ 01
o - ' t»
0 H M
in M ^ CN
- vo "
Tl
>i -~
^ C
rH COO
C 4J
0 — O ^~
> u — fi 03
SC rl O 01
0) >t -H 0)
o E "v. jj c
4J jj -y> o 0)
rH ffl — 3 >
«< W T3 -rl
> 4J 0) 4J
>. C m « o
rl H O 0)
0 U C H 0 M-l
« (0 rH -H U
i-H -U (0 CO
3 -rl 3 CO 4J
Dl Ol C -rl 0}
9
•* <»
•w-
o
O VD
O V 1^
v w in °°
g H 5 -i
in ro M H
* in
•» -w-
v>-
o
0 H
o ro ro
^ in N
o - o ^
o m £ -
in ro M H
x in
TJ> -W-
•w-
o
o vo
o oo r-
- ^" m t
o -So
0 «^ H -
in vo i<
- vo
•* -w-
•W-
o
o o
0 * n
•> •* 12
o - in ^
o in m *
in in '*)
» r^ "
_« J/S.
^* Vf
in-
? ^
^- C
r« no
§ £
> -W- 4J -W-
| )
« 4J — . C CO
C c M o m
u 0) >~i -H a)
o E ^~ w c
OJ iJ V5- U 0)
rH 01 — 3 >
4 0> T3 -H
> 4-> 0) 4J
N c co a o
rl M O 0>
O U C VH
•U rH O VM
a (8 rH -rl W
rH JJ 10 CO
&-H 3 n u
Ol C -rl CO
«
-------
22
o
55
H
O
O
U
Q
H
O
0
61
^.
O
CQ O
frl H
CQ H
O U
U D
EH W
§3 0*
2
i4 2
ft O
H
J CQ
H CQ
Q H
81
55 ^C
|s
A.
»*«
0
H
CQ
§
CQ
•
•^
H
W
•4
9
6-1
m
&
*•
*B J
1 1 /*.
• 8
O
u
rH
Oi
rH
• _
«O n
O &
36 *
H
Pj
S
O
0 0
O H _ t>
- n ^ r>
0 . ' 0
o r> °
o m £J H
- M ^ V>
(N
•w-
o
O 00
* ° H 01 <*>
• rn . *
§ « S "
O ^J1 . iH
- OJ ^
fS V>
•w-
0
0 0
°. s ° s
O » ^, f)
o 5 3 H
« (N " -W-
r» •
•w-
o
o o
O 00 I1
» H oo in
0 - • N
o in tn
O O cr» c>
cs v>
o
o o
00 M
• in ro on
O - • H
O M H
o vo m in
» H
H
•W-
£, _
"^ C
a o
C AJ
-~ o ^
4J «•
4-> ^- C <0
C ^ o m
0 >, -H 0
g ^ -U C
4J «• O 0
in — 3 >
0 -O -H
> 4J 0 4J
U C TO « 0
OHO 0
0 O C «W
H rH O VM
h (fl iH -H U
JJ (0 01
H -H 3 O jJ
Si 21 S ^ 8
rt n) c e o
2 o 3 w u
o
o o
O M _
r>& ^* *w\
o « ' •«
0 <* S r-
o a> JS
O
O GO
° S ^ CO
o - -^ oo
O CTl ' 00
0 0 l] <«•
* cs
o
o o
» ro ^ ro
o - ' in
O 0*4 x| OS
O H Vj -W-
• (N
N •«•
O
O O
O VO .^ TJ>
• n
o co 2 w
- (S H W-
N -OT-
•W-
O
0 0
O (N 00
O - • H
^5 f^ ^* *
o in n *r
- iH «•
H •
•w-
"^ ^
"^ 'c
TH mo
C 4J
• -~ O ^s.
> V> JJ «•
43
a jj ~ c o
e c ^ o to
M 0 >i -H 0
« e ^. jj c
4J jj • fj (JJ
•H tn — 3 >
r< 0 -0 -H
> JJ 0 JJ
>i C OJ pi U
V4 H O 0
O O C >w
4J rH 0 M-l
A 10 r-l -H W
rH 4J flj tQ
3 -H 3 0 JJ
&l ft fi -H 01
9 (tf 6 E O
US U i? W U
in
[^ 03
H °1 g J?
m a\ ~ vo
o n ^ «•
• (N
in
cs n
r» H
H ."1 « ^
<*! ^ « P-
O •* ^> t>
- M
rj -w-
in
(N VO
r^ ro
H * 0 g
r»> t~ J2 »o
o cs " «•
- (N
in
CN O
r- in on
s :• s •
O O I~l H
(N
in
N H
t" •* 1"
H - in o
ro t^- in ••
o vo m
* rH {/)•
H
•«/»•
17
-t: "5
C«i-l to O
a c JJ
a u -~ o •>.
>-g <* u v*
3 § "•" " "
«J3 JJ ^ fl 0
c u e n o tn
M 0 N -H 0
« a E -^ 4J c
JJ 3 JJ -w- U 0)
rH iH tO — 3 >
4 ft a a) T3 -H
« > JJ 0 JJ
s« > c m a u
U h-H M O 0
O S *> O C «w
JJ O « rH O "W
« O C « rH -H W
rH M M JJ 18 03
3 -H « -H 3 n jj
0) > 41 ft C -H 0}
0 CrH
-------
23
This resulted in a difference in the annual cost from the MACT
floor and regulatory alternative 1 described above: the
additional material cost of using chemical alternatives for the
low-density, low-IFD foam grades. Details on this calculation
are also contained in Attachment 12.
NATIONWIDE REGULATORY ALTERNATIVE COSTS AND HAP EMISSION
REDUCTIONS
This section presents the nationwide costs and HAP emission
reductions associated with the existing source regulatory
alternatives presented earlier. The basic approach used to
estimate these nationwide impacts was to apply the model plant
impacts presented in the previous section to those facilities
represented by the model plants.
In several instances, more than one technology could be used
to achieve the level of control required by the regulatory
alternative. In these cases, EC/R made assumptions regarding the
number of facilities represented by each model plant that would
use the various technologies. The following sections present
these assumptions, and describe the calculation of the nationwide
cost and HAP emission reductions.
Molded Foam Production
Only major sources of HAP will be subject to the Foam
Production NESHAP. Since the high-pressure molded model plant
and the smallest low-pressure molded model plant have emissions
below the major source thresholds, it was assumed that the
facilities represented by this model plant would not be affected
by the Foam Production NESHAP. It could be maintained that these
facilities, particularly the low-pressure facilities, have the
potential to emit major source levels of HAP. However, EC/R
assumed that these facilities would obtain federally enforceable
permit requirements limiting HAP emissions below major source
levels, rather than installing controls in accordance with the
Foam Production NESHAP. Therefore, the nationwide regulatory-
alternative impacts are based on low-pressure model plants 2
and 3. The following paragraphs briefly discuss how the model
plant impacts were used to estimate nationwide impacts. The
distribution of technologies used to estimate the molded foam
nationwide regulatory alternative costs by model plant is
provided in Table 18.
Mixhead flush
Regulatory alternative 1 requires work practices to reduce
mixhead flush emissions. As was shown in Table 5, the EPA
developed model plant costs for four technologies: one for
regulatory alternative 1 (solvent recovery) and three for
regulatory alternative 2 (non-HAP flushes, high-pressure
mixheads, and self-cleaning mixheads). While the three
-------
24
TABLE 18. DISTRIBUTION OP TECHNOLOGIES USED TO ESTIMATE THE
MOLDED FOAM NATIONWIDE REGULATORY ALTERNATIVE COSTS
BY MODEL PLANT
Number of Facilities Using the
Technology
Emission Source/Technology
Low-Pressure Low-Pressure
« Model Plant 2 Model Plant 3
Mixhead Flush
Reg Alt I
Solvent recovery 54 44
Reg Alt II
Non-HAP flush 49 35
HP mixheads 5 9
Mold Release Agents
MACT Floor
Reduced VOC 18 15
agents
Naphtha-based 18 14
agents
Water-based 18 15
agents
Repair Adhesives
MACT Floor
Hot-melt N/A 22
adhesives
Water-based N/A 22
adhesives
technologies that totally eliminate mixhead flush emissions could
also be used to comply with regulatory alternative 1, it was
assumed that no facility would totally eliminate HAP mixhead
flushes to comply with the work practice standard. Therefore,
the cost and HAP emission reduction for HAP mixhead flushes for
regulatory alternative 1 are entirely based on the application of
the solvent recovery model plant impacts to the 98 facilities
represented by low-pressure model plants 2 and 3.
-------
25
Regulatory alternative 2 prohibits the use of HAP mixhead
flushes. As noted above, model plant costs were developed for
three technologies that could be used to meet this requirement.
To determine nationwide costs, self-cleaning mixheads were not
considered an option, because they have significant limitations
and are currently not in use in the industry.
It was assumed that more facilities would use non-HAP
mixhead flushes than would use high-pressure mixheads, due to the
high capital cost of high-pressure mixheads. In addition, fewer
changes to the foam line are needed when converting to non-HAP
flushes. Therefore, it was assumed that 90 percent of low-
pressure model plant 2 facilities (49 facilities) and 80 percent
of low-pressure model plant 3 facilities (35 facilities) would
utilize non-HAP flushes, and the remainder would install high-
pressure mixheads. The different assumptions associated with the
two model plants are attributable to the assumption that a higher
percentage of the larger facilities would be able to incur the
capital cost of high-pressure mixheads.
Mold Release Agents
The emission limitation for mold release agents was the
prohibition of HAP-based mold release agents for all three
regulatory alternatives. As discussed earlier, model plant costs
were developed for three technologies that meet this level:
naphtha-based release agents, reduced-VOC release agents, and
water-based release agents. It was assumed that the majority of
facilities would choose either water-based or reduced-VOC release
agents, as it was assumed that many facilities could not switch
to naphtha-based release agents due to VOC emission limits. For
each model plant it was assumed that 1 percent would use naphtha-
based agents, and the remainder would be split evenly between the
other two options.
Repair Adhesives
The emission limitation for repair adhesives was the
prohibition of the use of HAP-based adhesives for all three
regulatory alternatives. There were three technologies for which
model plant costs were developed that meet this level: hot-melt
adhesives, water-based adhesives, and hydrofuse. Hydrofuse was
not considered in the regulatory cost analysis, because there are
no known facilities in this industry using this technology. As
there was no other information available regarding industry
preference, it was assumed that 50 percent of the facilities
would use water-based adhesives, and 50 percent would use hot-
melt adhesives.
Slabstock Foam Production
The following sections describe the derivation of impacts
for each of the four slabstock foam production emission sources.
-------
26
Storage/unloading, equipment leaks, and equipment cleaning
As discussed earlier, model plant costs and HAP emission
reductions were only developed for one technology for each
emission source. Therefore, the nationwide regulatory
alternative costs were simply determined by multiplying the model
plant costs for each technology by the number of facilities
represented by each model plant.
HAP ABA emissions
As discussed in the model plant section, there are a variety
of technologies that reduce or eliminate the use of HAP ABA.
Table 12 listed the assumptions regarding the technologies that
could be utilized to meet each of the regulatory alternatives.
In estimating the nationwide regulatory alternative costs, it was
necessary to make assumptions regarding the number of facilities
that would use each available technology to comply with the HAP
ABA requirements. The distribution of technologies used to
estimate the HAP ABA slabstock foam nationwide regulatory
alternative costs by model plant is provided in Table 19.
MACT floor. For the MACT floor regulatory alternative, it
was assumed that the majority of the facilities represented by
the smaller model plants would choose to comply through the use
of chemical alternatives. This is because of the low capital
costs associated with chemical alternatives, and the fact that
using this technology would result in less need for personnel
retraining. At the other end of the spectrum is variable
pressure foaming. Due to the high capital costs, it was assumed
that only two of the largest facilities would install this
technology.
It was assumed that most of the facilities not using
chemical alternatives would comply through the use of either
CarDio or forced cooling. The reduction of HAP ABA usage through
forced cooling is a technology that has already penetrated the
industry to a large degree.
While CarDio is a relatively new technology, it (and other
liquid carbon dioxide systems) has generated considerable
interest in the foam industry. Several companies that have
already begun the installation of CarDio.
While acetone is a relatively low-cost technology, it was
assumed that it would be used by a smaller number of facilities
due to two issues often cited by industry. These are
(1) anxieties surrounding the flammability of acetone, and
(2) the fact that they would be forced to pay licensing fees to a
competitor (Hickory Springs, a foam producer, holds the United
States patent for the use of acetone as an ABA) .
-------
27
W
B
W
H
Sfc
t-J 7
H§
CQ J
H ft
O J
H H
Q
Q 0
H S
CQ
>-, Sj
i-3 P*
m
CQ
H CQ
H H
O CQ
O O
« p *
i4 O
O
2 Izl
C3 E^
U H
H H
H <
5s
25 0s
0 U
H H
H J
g*
QJH
H Pi
*g
55*
O jJ
H D
CQ CD
CQ H
H «
w w
il
o
fa H
0 H
4
§*
H a
g|
M VJ
0 fa
H
tt «
H U
CQ O
H H
Q CQ
f^j
• 13
cr> CQ
r-t
H
ij
H
in
ft
s
fe
o
rH
C
S
•g ?
O ft
H S
(D
rt
HH
4J
Q)
Wl
c
-H
Q
D i
0)
O
t-\
0
ti
JS
o
o
H
H O CN -i 0) fa fc Q)
(0 O ft O X!
H U < > fa U
1
H rH CN CN
in CN o TJ<
vo m o in
® •* 0 VD
^ n o n
Di
C
•H
i— 1
O
0
o
V
HOC Tl
-HO 0)
•U Q JJ U
r-l fc 0) fa fc
rt! 03 U CM O
U rtj > fa
Cn
0
K
H H (N CN
n CN CN «*
in cs H vo
3 n H o,
2 rn o u>
r^
m
OJ
i
^^
<
£ +
0) (Q
J3 rH 4J
U OrH
o <;
+ U
HO) E
HOC T3 0)
-HO 0) J5
AJ Q 4J O U
H ^ (U fa r-l
d! (0 U ft O
U t£ > fa
tn
0
M
-------
28
Regulatory alternative 1. Table 12 reported that chemical
alternatives were not considered to be one of the technologies
capable of meeting the HAP ABA emission levels of regulatory
alternative 1. The assumption that was made regarding variable
pressure foaming for the MACT floor regulatory alternative was
maintained for regulatory alternative 1. Therefore, the
technologies available were acetone, forced cooling, and CarDio.
The high capital and annual costs associated with forced cooling
led to the assumption that few smaller facilities would select
this technology. Due to the limitations of acetone discussed
previously, it was assumed that the majority of smaller
facilities would select CarDio. For model plants 3 and 4, where
it was assumed that capital costs were less of a problem, a
smaller percentage were assumed to choose the CarDio technology.
For model plant 5, it was assumed that the four technologies
would be used in equal amounts.
Regulatory alternative 2. The rationale for the regulatory
alternative 2 assumptions was basically the same as that
discussed above for regulatory alternative 1 (noting of course
that CarDio and forced cooling also use chemical alternatives for
regulatory alternative 2) . The one exception is that it was
assumed that a few more large facilities would choose to spend
the resources to install variable pressure foaming under
regulatory alternative 2.
SUMMARY AMD DISCUSSION OF REGULATORY ALTERNATIVE COSTS
This section summarizes the regulatory alternative costs.
In addition to costs of the technologies to control HAP
emissions, facilities will also incur costs for the associated
monitoring, recordkeeping and reporting (MRR). For the purposes
of this analysis, these MRR costs were estimated to be 8 percent
of the control costs. Therefore, the total control costs
calculated using the model plant costs was multiplied by
108 percent to obtain the total cost of control for each
regulatory alternative.
Molded Foam Production
The nationwide regulatory alternative impacts for molded
foam production are provided in Table 20. As shown in Table 20,
the overall cost effectiveness values for all alternatives are
less than $1,300 per ton of HAP emission reduction. However, due
to the cost savings in controlling mixhead flush emissions under
regulatory alternative 1, the incremental annual cost from the
MACT floor regulatory alternative to regulatory alternative 1 is
negative, resulting in a negative incremental cost effectiveness.
The incremental cost effectiveness from regulatory alternative 1
to regulatory alternative 2 is $827 per ton of HAP emission
reduction.
-------
29
CQ
EH
CQ
O
O
P
H
EH
H
J
^4
^
K^
OS
t^
™jj
^5
M
£3
CD
W
P4
1
"
§
f*<
g
SB
•
o
M
J
s
rH
(0
AJ
O
EH
0
U
P Mr*
O -H-H
to «o n
Ql V
c 0 *S
0 K "o
•H <5
a
Q
•H
' 0
0
s. °
r» MI
In uJ
0 jj
0 m C
•« S 0
0 « 0)
Pi ^
C rH
H 5
•^ tag
•0
a J3
0 0
X 3
rt rH
•H h
0
•H
AJ
ti
C
0
rH
fr
O
AJ
(0
rH
0
co o r»
oo en I-H
VD O CO
en CN co
^ CO iH
H H <0
•co-to-
f
CO ^* GO
co co in
VD cn cn
cn co CN
^ CO *CO
H -CO-
•CO-
o VD cn
•co-o in
H 00
*. *
ro o
T* H
H
<£-,
AJ
AJ CQ
C O
cu u
E —
^
^»l*— ^
^^ C3
-^ CO O
>iO^
•^ AJ i 3 >
d) ^4 AJ -W
r< C C """
OHO
.rH T3 -H
h CO CO AJ
' 3 Otf U
C 0)
o u AJ c c3«w
rH rH CD rtj O *W
fa fO i-H O -H H
AJ (0 U rH CD
EH-H 3
u Cu c a
CO CD AJ
AJ -H CD
*C ro d Di O S O
2 u 3 s EH H u
CO CN CO
co in co
H O O
- - •
o r- in
CO VO
•CO-
o VD cn
•co-o in
H CO
«, •
m o
^* rH
H
^—^
M
H >,
0 — to-
nH^"
•4J AJ
(0 AJ CD
ceo
M 0) U
0 E —
H CD O >
rtj 0) M\
> AJ -CO
s, jj JH -_
HMO
0 O A-
A3 rH Ct
tt rO rH C
o CN cn
^* ro ro to
H CO CO- '
^ ^
CN rH
p»
•CO-
CN rH ro 0
^i VD cn H
cn VD !3
•CO-
H
^*
•co-
in o cn u
VO f^ VD r^I
cn CN in !S
— -CO-
ro
in
H
•CO-
^^
I*- rH
VO O "I A
r> in ii
ro H
CN
H
•CO-
^
l^l-"— '
"x^ r*
^- CO O
rl C AJ
AJ C
. rH 73 -H rH CO
- CO 1) AJ rH E
• 3 Pi U nS CO
e CO rM rM
S oil > c
-H H O M
H AJ tfl U rH 05
p -H 3
b) cu c ct
ro ca AJ
AJ -H CO
o ro c QJ o e o
« u S s EH ta u
fO CO ^^
H CO CO
co H in
- - 1
CN VD rO
c^ o in
O C- CO
-
vo
J£/^
CO ^* CO
oo co in
VD cn en
cn co CN
^i ro ^co
H -CO-
•CO-
o VD cn
co-o in
H 00
^ ^
ro o
^* rH
H •«
•co-
in oo cn
CN cn vo
H o r-
ro ^ o\
CN CN ro
en in ,
•H ~—
AJ AJ
(0 AJ CD
CCO
M CO U
0 E ~
in CN vo in
r- ro CN r-
r* ro ro ro
- - -
CT> CN H
in co-
r-
•CO-
CN H ro 0
^ vo cn *^I
en vo S
•CO-
H
^
•co-
in H cno
vo r^» VD *3«
^•^ k ^*» ^_^
en CN in 3
•CO-
ro
in
H
•CO-
r- H CN in
vo o co r-
00 O CN CO
- - -co- -
ro CN H
VD i O """^
^s. AJ -CO-
~~r
e tn
AJ O CQ
CD -H CO rH
. o AJ e co
JJAJrHJHUOCO AJ
rH CD O >i 3 > C
XlJ CO >H ^
. rH 13 -H rH (U
>AJ-CO-(0 COAJt-H £
>» C C "-
MHO
O U AJ
•U rH CC
• 3 DJ u ro CO
e 0) ,M rl
IdnJrHO -HWOH
rH AJ CO U rH CD
p-H 3
bi a c ce
ro CD AJ
AJ -rl CO
0 ro C Cd O E O
« U .< 2 EH W U
JJ
•H
• C
— 18
a) 3_
3)&4)
H 4) AJ
«-rl V4
(0 AJ O
<8 M-i
AJ cn
a o) 4)
0 C >
O -rt
— <8 AJ
(8
>,tn c
AJ -H >-l
•H 4) •
AJ AJ AJ 4)
C n «H >
(8 O (8 -H
3 O 4J
rH M C
0) (B 0 M
> 3 AJ 4)
H fi (8 AJ
U C rH ,-(
<8 (8 3 (8
tn m
4)rH 4) ID
C * r( 3
AJ 0
<8 C 4)-H
ID E AJ 4)
H 4) M
V4 >U CU
AJ O 0
[DC (13
O-H m £
O AJ JJ
4) C
rH a a) IM
* 3 6 O
3 (8 4)
§O rl 01
4J-H AJ
<8J33.fi
AJ-O 4) E
4) 4) rl 4)
C AJ rl
(8 4)-H
4)rH £ 3l
m 3 AJ o1
30 4)
(8 rH 4) rl
O (8 O
4) O C 4)
3 °^^
AJ 0) AJ
•O O
4) c tn o
AJ AJ AJ
18 0 O
rH O (8 rH
So) am
CEO
rH 4)-H -H
18 > AJ
O-rl rH C
AJ (8 4)
AJ O AJ 73
o a) c -H
M-I E 4)
tn 0) tt) >-l
(Q Vl (8
fl) AJ O
C ffl C 4)
0) O-H O
> O rl
H O3
AJrH C 0
O (8 W
4) AJ 4)
ij-l 4) (8 0
4) E -H
4) 4) CQ
AJ r*4 M CD
m o 4) -H
0 C J3 E
U M EH 4)
0 XI U
-------
30
Slabs took Foam Production
The nationwide regulatory alternative impacts for slabstock
foam production are provided in Table 21. There are two sets of
impacts shown for regulatory alternative 2. The first only takes
into account the "direct" HAP emission reductions associated with
the regulatory alternative emission requirements. However, as
discussed earlier, the elimination of the use and emission of HAP
ABA will also result in the elimination of HAP ABA emissions from
storage and equipment leaks. The second set of impacts include
these "indirect" HAP emission reductions.
The cost effectiveness of all three regulatory alternatives
are less than $600 per ton of emission reduction, with the
highest being the MACT floor level of control at $592 per ton.
Due to the incremental annual cost savings for the regulatory
alternative 1 HAP ABA requirements, the overall incremental cost
effectiveness from the MACT floor to regulatory alternative 1 is
negative. The incremental cost effectiveness from regulatory
alternative 1 to regulatory alternative 2 is $1,375 per ton,
considering the indirect emission reductions.
While the overall cost effectiveness of regulatory
alternative 2, and the incremental cost effectiveness from
regulatory alternative 1 to regulatory alternative 2, are within
ranges typically considered reasonable by the EPA, there are
other considerations that should be pointed out. Primarily,
there is substantial concern within the industry whether a
complete range of foams of acceptable market quality can be
produced without any MeCl2 ABA. The manufacturers of the HAP ABA
reductidn technologies maintain that the foam quality does not
suffer with the use of these technologies. However, the use of
these technologies in the total absence of the use of HAP ABA,
while still producing a complete product line, is very limited.
A second consideration is the issue of plant safety. Use of a
flammable solvent (acetone) as an ABA, and dangers associated
with the extremely exothermic nature of the foam polymerization
reaction, create potential fire hazards. While the designs of
these systems include safeguards against potential hazards, it
should be noted that the use of one of these technologies
resulted in a recent plant fire that consumed the entire
facility.
-------
31
CQ
CO
O
CJ
B
H
H
IM
3
H
H
3
»i
fti
o
*"j
2
5
CD
H
P4
§
v^
Pi
U
O
H
CO
CO
•
ts
w
J
§
W|
f^
I-)
0
4>
£
« m
§
03
G
0
« * t»
age
Jl R G
H 0
3 *
A "*O
M
a
u
« AJ
Oi C
C3 Al M
H w Q
H 0JX
0,0
•H 0
3 J
H
Ol
>«
?*o
2 *
n 0
2-3
rag
O H 00
i-i i< ro
o o ao
- .to
P- H
1« H
o p- in
o on i>
r» o ro
in •*
H in
«. ^^
^^
AJ
AJ CO
C 0
fl) CJ
E —
AJ rH h
m o >
4> u->~
^ 4_)
00
H
H
N ro oo
Tf p- VO
in r» CN
•<* On rH
in
c~
H
H
— . O
ro ro *8
on H '
vo
^
p-
•w-
on ro vo
in o
00 O
in oo
CN
•w-
vo in CN
on H ^
O CO
ro P-
H O-
rH
"to
-^"c
^ CD O
^ C AJ
?t O "^"^
\4J<0-
V^ ""^ *—'
•^^
G co
AJ o ro
CO -rl 0)
0 AJ G
CJ O 4)
. 3 >
i-H 'O-rl
« tu AJ
3 OS 0
S v
i§ O i*J
-rl W
rH CO
(B CO AJ
AJ -H 01
0 E 0
H W CJ
rr H 00
H P- P-
VO P- H
ro oo oo
CN CN H
(N co in
00 VO
vo
o p- •*
O if O
on ro vo
00 •«* P-
on CN T)<
vo vo
vo
•w-
o ~^~~
•w-o ro
in *»•
H in
*• VI
p- —
•w-
^> in H
in in ^"
P- •* H
CN on p-
oo oo ro
vo *4* m
i
0 --.
^ ^•^
•H —
^ -i-i^
(B AJ 01
C G O
rl tt) CJ
0 E —
JJ AJ rH M
•H CO O >
< 4) rl-V
> AJ W
>.G G —
MHO
O O AJ
AJ rH CD
O (B i— 1 O
H AJ A CJ
3-rl 3
& ft C K
0 R> G K
at u < 2
on oo o
Tf co rf O
on TC vo '
VO i-H
^ rH
ro
p-
<*
H CN VO
in vo ono
cn CN in '
H H
p-
vo
^ o cn
ro ro fl <
cn i-l > K
vo
^
p-
•w-
VO O CN H
on oo in cn
in in T>«
vo vo vo
O {fr W
in
•w-
vo in rsJa
On rH Tf S
0 ro 55
ro p-
H 10-
H
•w-
^1
^t^^
--- G
— no
H G AJ
r*i O "*"•»
*^*- AJ •
rH 4)
rH *O -H rH E
IB 4) AJ IB 4)
3 OS U k M
G 4) fl) CJ
G C «W > G
< O vw O H
•n H
rH CO
(0 CQ 4-J
AJ -H 01
O E 0
H W CJ
in o ro
p- on in
VO H P-
a> CN ro
vo on o
o in ao
•*/>
o — —
•w-O ro
in •*
H in
-•w
p- ~
o in «
o ro CN
o o co
in •<* H
cn CN w
•W-VJ-
o r~ vo
in •* vo
oo in ^J1
o vo
•w-
^-^
^4
•^
0— «•
^ *—*
•rl ^-^
AJ AJ
«J AJ 01
G G 0
rl 4) CJ
0 E —
AJ JJ rH t-l
H CO O >
«< 4) rf'v
> AJ -W
SC G —
MHO
0 CJ AJ
AJrH CO
0 (8 rH O
rH AJ (8 U
3-H 3
& ft c &
0 IB G S
« CJ rt S
ro ro vo P-
TT co on CN
an ro vo ao
in vo
on rH
ro
H
H
ro o vo H
vo in on 55
vo
..
p-
v>
cn ro vo H
in o on
00 O ^*
in oo vo
CN fV Vy
•w-
ro o •*«
H 00 rt
* «»
O H
P- VO
VO
•co-
rn
C
0
AJ
— CJ
>.— •§
^.C 4)
-^ co o a
r4 C AJ
>i O~^. C
~^ AJ V> O
«^~^ -H
^— ca
C ca ca
AJ O CO •-( -rl
CO -H 4) IB g
O AJ C AJ W
U CJ 4) G
1 3 > rH fl) AJ
rH -a -rl rH £ CJ
1C 4) AJ IB 4) 4)
3 P6 U V4 i-l rl
C 4) 4) U -H
H CM-l > GT)
•3 O •« O H C
•rl H H
rH CO
m co AJ ^
AJ -rl CO AJ
O E O -rl
H W U S
CN on H
00 O
00 VO 00
in vy 4/v
H
0 -O
1 1
O -0
1 1
in
UJ
H '
H
P" <"
• 1
VO
H
C
0
•H
AJ
U
3
•a
4)
Oi CO
CO i-H
G 4) (B
O G AJ
•H 4) C
CO > rH 4)
CO -rl rH g
•H AJ IB 4)
U 4) 4) U
W > G
ft VH O H
2
AJ
P4 CO
*4 O
En cj
-------
32
Footnotes for Table 21
a Cost effectiveness not calculated because net annual
cost is a negative quantity (cost savings).
b There are no incremental impacts since the requirements
of the regulatory alternative for the emission source
are identical to the requirements of the previous
alternative.
c Incremental cost effectiveness not calculated because
incremental annual cost is a negative quantity.
d There are no indirect emission reductions associated
with regulatory alternative 2 for this emission source.
e Since regulatory alternative 2 prohibits the emissions
of HAP ABA, there are no storage/unloading or equipment
leak requirements under this alternative for HAP ABA
storage vessels or components in HAP ABA service.
Therefore, the incremental cost effectiveness for these
emissions is not appropriate.
f There are no costs associated with these indirect
emission reductions, therefore cost effectiveness was
not calculated.
-------
ATTACHMENTS
Attachment ,
Ntimber Description of Attachment
1 HAP ABA Regulatory Alternative Requirements
2 Model Plant Information
3 Molded Foam Model Plant Costs
4 Slabstock Foam Vapor Balance Costs
5 Slabstock Foam Non-HAP Equipment Cleaner Costs
6 Slabstock Foam Equipment Leak Model Plant Costs
7 Slabstock Foam Model Plant HAP ABA Regulatory
Alternative Emissions
8 Slabstock Foam Model Plant Costs for Chemical
Alteratives
9 Slabstock Foam Model Plant Costs for CarDio
10 Slabstock Foam Model Plant Costs for Acetone
11 Slabstock Foam Model Plant Costs for Variable
Pressure Foaming
12 Slabstock Foam Model Plant Costs for Forced
Cooling
-------
ATTACHMENT 1
HAP ABA REGULATORY ALTERNATIVE REQUIREMENTS
The allowable HAP ABA emissions for a single month are
determined using the following equation:
allow.aoath, £, 10Q
where,
Allowable emissions due to use of a HAP auxiliary
blowing agent for month j, megagrams
polyolj = Amount of polyol used in the month in the
production of foam grade i, megagrams
n = • Number of foam grades produced in the month
limit; = HAP ABA formulation limit for foam grade i, parts
ABA per 100 parts polyol. For the MACT floor, the
HAP ABA formulation limits are obtained the table
on the following page. For regulatory
alternative 1, the HAP ABA formulation limitations
are obtained using the equation on the following
page.
1-1
-------
Attachment 1
HAP ABA Regulatory Alternative Requirements
MACT FLOOR HAP ABA FORMULATION LIMITATIONS
Table
values in
parts ABA
per hundred
parts
polyol
0-10
11-15
16-20
F 21-25
26-30
31+
Dens:
0-
0.95
12
10
9
6
5
Lty ranc
0.96-
1.05
IBS (pov
foot)
1.06-
1.15
11
8
7
4
4
mds per
1.16-
1.40
6
4
3
2
i
cubic
1.41+
2
2
0
EQUATION TO CALCULATE HAP ABA FORMULATION LIMITATIONS
FOR REGULATORY ALTERNATIVE 1
" -0.25CTFD) -19.1(--|-) - 16.2 (.DEN) -7.56(-i-) +36.5
For either alternative, the IFD and density of the foam will
be determined using standard industry quality control
techniques on a sample from the core of the foam bun.
1-1
-------
Attachment 1
HAP ABA Regulatory Alternative Requirements
The allowable emissions for the 12-month period are
calculated using the following equation:
12
where ,
emissaUow>12.monti1 = Allowable emissions due to the use of a HAP
auxiliary blowing agent for the previous 12-
month period, Megagrams
• Compliance with the HAP ABA emission requirements is
determined each month, by comparing the allowable emissions
for the previous 12 -month period with the actual HAP ABA
emissions for the same 12-month period. Allowable and
actual HAP ABA emissions are rounded to the nearest
megagram, with 0.5 megagrams rounded up.
• If add-on control (e.g., carbon adsorption, incineration,
etc.) is used to reduce emissions, the emissions after
control will have to be verified using source testing.
1-3
-------
-------
ATTACHMENT 2
MODEL PLANT INFORMATION
Molded model plant parameters 2-2
Slabstock model plant parameters
Basic parameters 2-3
Formulation, production, and cost parameters 2-4 thru 2-8
a-l
-------
li
A CM*
oo
CO
o o 3- eo o «* o
<» o *• eo o in <»
CD CM CO CO i-
en CM o *-
T- T- O CM
• • • •
o o
10
in
ui
a
o
•$
I
Q.
X
CO
CO N. CM
O O »*• O O O O>
«*0 * «»0 4»CO
co CM co a»
O O O) O)
o o
CM CM*
I
o
UJ
CO
m
1
S
o
O
§
•s »
<•» >- *
E
•o
S trf
I -^1
I ?£
0
o.
o»
I
o
a
O
!*„
ft
£ JC
« M
3 3
II
O TJ -O jc
2 S S •
j5 • a 3
0*^0
o §§
3*0
O o — w «
C "r o» »- w
!
00
JC c «
3 §,§
illilsl
l« «££ g5
W « « CM CM -X -O
S-g-gSO 2 «
" W g C9 C> TJ "5
sSS^o -
II
4
W* ^L
E 2-g
« o 5
O > 3
u_ < z
fCM CM
O O
3 O C0
Z 22
o
Q.
I
"5
M
o
-? i s.£r
C «O ru
-------
««
"£
1
"58
no T- r- ft o eo
$4.43
$800
$303.701
$0
20.070.000
17.508.000
33.713.000
OT-NOoa
no ^
iaoQO«o>0O>T-
r- « 0 0)
3
0
1
1
$4.4
$80
$303,70
$4.40
$20,074,40
$17.508.000
$33.718.000
$1,440
ONM
ob
OMM »2°^22
bo og(ori2«
48]
^ «- O O N O
1
£
7
•g
^o
o«*
.
1 n
o •-
2
*- to o i
o*
-:«B«»»or-»
M *» r.-» rf W o- T--
o •»«««<•
ONM n 10 o 10 « 2
oo onerinn
ONN nopionn
b o . M 0 n M MM
2s
OL
"8
a.
S
o
a o v n
H o.
I o
o ••
o2
n
NO n*-NOo«a«-ioooo«aaio
i no «- <-Nonaa«-
n v* o n a
a"
*§ '
5*^ |^-a
«»«*(
ONM oo»»
O)eo
O^
0 0-
OMM « »
bb 2
*• n 10 t-
£
a o
Ȥ
N-
iMO ^^-OQONT-loOOMOOOn
«T-IOO
*" ^cl
• ^•oooM»ioooia«ai
»-g »- T- n o in a o
a*
5S
******
bb
onn
b b
-------
a.
ui
a
o
-»«
ill
0 «
o
'**
«£ oj> »
«
3 If
S *•
O a
£ £
3
— •" —
III
in
« Q."-
ei
Si
to
Is
0
•o
E
O
S
IO
s
09
09
o
o
co
IO
o
CO
10
i
CM
CO
CM
o
CM
o
IO
o
IO
IO
IO
a>
g
oo
o
,_
o
CM
o
09
o
OD
co
o»
oo
OD
oo
o
,_
o
CM
o
r-
o
f^
09
s
o
o
*"
8
o
CM
oo
o
CM
03
o
s
s
CM
CM
9
8
§
oo
0
00
at
CO
s
0
o
o
0
§
OD
o
00
a
CM
oo
00
CM
N.
o
OD
8
o,
o
Ok
o
£
0
,_
8
o
a
o
a
o
CM
00
01
o
o
0
8
10
to
to
CM
o
CM
o
A
-------
N
H
D.
ui
o
o
'a 8 «•.
c P
c ™ 52
o
If?
S S E
2 *
?
" '
S •*
a
». -o _
1 8l
E o o
* ex —
si
i?
&s
o
3
CO
at
n
o
to
o
*~
o
CM
O
n
at
o
§
at
8
CM
CO
CO
r»
CM
CM
O
CM
O
o
o
IT-
o
-
CO
a>
i
CO
V
a
*•
o
CM
10
o
IO
o
§
CM
co
CM
»-
^
*~
O
CM
O
CM
O
1
CO
CO
§
o
CM
co
§
CM
O
CO
O
o
n
0
CM
co
CO
CO
o
^.
*~
o
CM
O
CM
,.
O
CM
i
CM
CM
CO
r»
^
o
CO
o
co
^.
o
CO
CM
•»
O
o
IO
o
o
ra
o
CO
CM
O
n
CM
s
IO
CM
CO
to
CO
o
CO
o
co
CO
o
n
CO
co
to
s
CM
CM
CM
o
co
o
CO
o
co
co
CO
CM
CM
CM
i
o
„
o
s
at
CO
0
o
CO
^
o
CM
O
CM
IO
O
CM
10
I
S
CO
V
CO
o
CM
O
co
IO
o
CO
IO
CM
n
IO
CO
•V
CM
"
O
o
10
o
(O
«o
CO
CM
IO
CM
,_
S
CO
o
co
o
to
o
CO
IO
s
CM
^.
o
s
o
^-
0
r-.
CM
a»
o
CM
O
*"
!
o
CM
CO
o
K
co
CM
to
to
o
i
o
CO
CO
3
co
K
v
at
at
o
o
o
o
CD
CO
o
CO
0
i
K
CM
CO
^
o
co
o
co
Ok
o
s
at
CM
CO
O
CM
^.
O
o
o
at
o
at
IO
CM
CO
co
o
Si
o
o
0
o
o
IO
10
CM
0
CM
O
CM
O
A
-------
CD
&
to
I-
Q.
§
"So
0 • "•
U
3 73
*t«
|S«
• • a
2 g
amount
produced
(tons/yr)
£ 10
to
i-2
•o
0
CM
a
I
o
o
v
o
8
co
o
CO
Oft
o
o
CO
0
i
10
IO
o
^
CM
o
o
co
o
o
o
o
CO
CO
CM
CO
IO
0
r«-
CO
A
o
o
CO
10
o
IO
o
CO
g
§
s.
co
o
8
o
CM
o
i
IO
5
™
o
IO
CM
CO
8
IO
o
CO
o
§
o
o
co
§
0
co
o
o
CM
0
CM
,_
o
CM
o
s
o
CO
-
•
•
^
i
CM
»•
g
^.
co
IO
8
8
CM
o
co
CM
IO
at
1
o
V-
^>
o
^
CD
'
g
co
o
CO
CO
to
Oft
CM
CO
co
0
o
o
8
CO
0
CO
0
CO
CO
at
at
CM
o
^
8
CO
0
CO
a>
o
CO
a»
co
i
co
CO
o
o
IO
o
Oft
o
a»
o
CM
at
CO
at
o
o
o
o
§
CM
&
o
CM
i
A
«»«*•
m
li!
» r* —
o e
9*
<0
II:
31-6
-------
o
(0
0.
UJ
Q
O
•*
S"~ 8 -C.
° *
e — -5
i f^i
o
1*1
gs|
s •
p
1
amount
produced
(tons/yr)
~ CM
*«
I3
O
O)
o
CO
N.
8
o
•
0
CO
o>
o
o
CO
at
in
r*
CM
CM
in
o
CM
CM
CM
O
O
0
o
0
o
s
CM
CM
CO
t
o>
o
in
o
in
o
as
CM
co
CM
CO
o
o
CM
O
0
CM
o
9
(O
CO
in
CM
co
o
in
in
s
o
o
co
o
CM
CO
CM
^•
V
CM
in
CM
0
o>
CM
O
CM
^
0
CM
in
CO
9
CO
o
t
o
o
CO
^.
0
CO
CM
0»
o
o
CO
CM
in
0
o>
to
o
n
CM
0
CM
s
CM
o
o
in
T-
(O
o
o
n
i
in
»
co
CO
'-
CM
0
o
CO
o
CO
to
in
a
in
in
in
CM
o
0
^
o
co
S
CO
CO
CO
CM
g
CM
0
CM
in
o
CM
in
0)
CM
CO
s
to
CO
o
o
CO
in
in
co
to
CO
CM
OB
CM
i
0
in
0
in
CM
CO
in
in
i
o
to
0
CM
S
in
in
o
CO
CO
o
N.
o
CO
f-
V)
CO
CM
o
o
0
CM
CO
o
CO
in
o
in
CO
o
§
co
CO
CO
o
CM
»-
0
o
0
CO
0
CO
o
CO
CM
^
s
O)
N
O
•
0»
o
s
o
0
a
^
CO
*
i
o
9
O
O
CD
in
9
in"
o
o
o
o
co"
in
CM
0
CM
O
A
!§§§§ §§§§g
of V
A
I-
-------
|3|
W
olo
,1
10
CJ
Q
o
n
IO
IO
CO
ICM
cvi
co no
CVI
loco
CO 01
IO
3833
--
CO ICO
toco
CM
Ol
c\i|Q
colo
10
Ol
lio
colto
1(0
*
o» i!S f«.
I
-------
ATTACHMENT 3
MOLDED FOAM MODEL PLANT COSTS
Mixhead flush technologies
Non-HAP flushes 3-2
High-pressure mixheads 3-3
Self-cleaning mixheads 3-4
Solvent recovery system 3-5
Mold release agent technologies
Reduced VOC mold release agents 3-6
Naphtha-based mold release agents . 3-6
Hater-based mold release agents 3-7
Foam repair adhesives technologies
Hot-melt adhesives 3-8
Water-based adhesives 3-8
Hydrofuse adhesive 3-9
3-1
-------
"(p 00
•o —
SI
CM
o o o o
in
«
eo
o
o
o o in r- 001
. O
r*. o
in *
CM* CD"
O Q
00 O
CO (O
o o
o o n en
•» v* CM to
en
z
O
0
LLJ
OC
Z
o
«o
CO
CO
2
CO
1
I
CL
O
55,
o o o <*• o>
1» «• CM i- h.
O O O O O
o"
CO
o
o
<
COSTS FOR MIXHEAD
t-
z
a.
_i
UJ
a
O
2
n
o
M
a
C
CL
X
i
c
o
>
0
ECHNOL
H-
2
CO
Ul
z
E
u
ts
8
»;
E
a. c
'11
o =
•o 5
Purchase
Direct ins
J5
a
indirect in
(pefjdaris jopiieA)
CO!
coi
o:
Ol
-J!
z:
(O
O
O
o
0
materials
1
Ba
tS W
o o
J5 0
•2 t>
M 0)
* .fe
£
o
u
"a
"a.
a
u
n
o
O>
o
o
IS
administr
ICTION (TONS/YR)
ENESS ($/TON)
Q P
MISSION
OST EFFI
UJ U
co
en
I
c
(0
-s
I
O)
3-
-------
(P CO
SS
CM
CO
CO
o
o
UJ
o
o
2
5
<
O
u.
Q
UJ
O
0» ^
11
2 Q.
0.
O C
•o ^
0.
o o u) m
O O CM CM
in_ co_ eo_ i-_
to" in" to" co"
CM o CM in
in »- ••-•
•r- CM eo eo eo:
r- co_ in_ ^ CMI
co"
a
I
^
o>
D)
I
S«
m
+
x
5
s?
CO
o
•o
UJ
1
UJ
z
_l
<
Ou
O O O O Ol
<*«*ITJ « w
Zl S « £
— w c —
_i
n «
0)
u
c
maintena
materials
0)
£
75
0
£
7/5
(0
J2
To
Indirect Co
>,
0)
§
u
£
5
'5.
a
u
s.
u
0)
_>
75
administr
5TION (TONS/YR)
u
D
a
UJ
DC
EMISSION
J
O
Si
col
COI
z1!
UJI
>l
l_,
01
UJI
U.I
u_,
Ul
55'
o
o
(C
a
I
c
_«
i
o
-------
^ CO
II
Q_
"3 CM
I!
o_
CO
O
O
S
Q.
UJ
a
o
o
u.
Q
UJ
O
V C
•a jo
Q.
X
O O 00 00
in »- CM co
in T- o co
o" «o oT in
oo co ^ CM
••- V> CM
O O 00 CO
in *- CM oo
u> »-_ o CM
o o o o
h. O
o o
in
n
in
a
o
CO - COI
(O CO ^ €3^ O> uj !•» j
^t T^ CM* O) *i eo~l
vn» eo ¥* co w-t
o o
o o o o o
«» «• «» *»
Z
O
I
o
111
(C
Z
o
w
OT
i
UJ
Z
07
D
UJ
X
C
O
U.
CO
o
O
UJ
Q
O
J-a 5 «2
-J Z! (D M .£
O
X
u
Si S
".
a
o
com
coi 5
Oi-i
I 3?
Tf OT
CM 0)
oc
Ǥ
§£
i- «»
2C^
ff °S!
C
0)
0) O
.
2 c -
<8 o
n 3 i= o
Li r* •" ^
o a> ^
To Js O ± .2
fe « T; JS -S
O ^* O SI p-
• « 01 Q. C
« .t n TJ
-
4) C
t- C
_c
.
n TJ
o «
J >l
OC uj|
2 M i
9 uji
«? H-l
2 coi
5 O!
UJ 01
-------
fl) CO
CM
CO
CO
O
U
IU
Q
O
O
u.
Q
IU
O
O
2
Q) *~
P
^ 0.
o c
•o .2
a.
I
o o o o
o to a> m
a> in_ ao_ CM_
r«r rJ •••- isT
n <«• «^ Tt-
0000
O (O OJ UJ
oo in oo CM
N is." ^ |-T
m *H
co_ co_ co Tt ^ o
eo" en ^ **
CO
>«
0
§
TECHNOLOQY: Solvent Rec
CAPITAL INVESTMENT
£T
i>
£
J
U)
+
X
JO
S?
eo
-1-
^
O
•o
c
»
o
k»
^o
^ --
capital recovery (14.24% - 7
overhead (60% of labor costs
Cl)
TOTAL ANNUAL COST
'R)
»-
administrative charges (4% o
f — ~
7KZ<
EMISSION REDUCTION (TON!
COST EFFECTIVENESSJ$/TO
o
o
I
c
a
cn
-------
CO
£
o
o
1
0.
1
.^
Ul
o
0
•o
TECHNOLOGY: Reduce
o
Y—
UJ
2
L»
CO
UJ
>
_J
1
u
_J
t-
o
CAPITAL INVESTMENT
•o
ANNUALCQSTS
Direct cost (vendor supplie
CO
CM
o_
«»
O)
CO
V*
O
UJ
V*
o
V*
materials
Indirect Costs
O O CO
V> Vt CM
o_
«»
O O O)
<«• i» CO
«»
O O O
v> iA m
!>.
T- CO
6 n
0 «»
£"
>• -^
o? Z
*0 ^
Z2
o t:
EMISSION REDUCTION (T
COST EFFECTIVENESS ($
o
«»
L^
T^
111
2
t—
CO
UJ
z
<
c fc
& <
a Q
0 _j
m <
2 *—
•S o
2 i-
2
"5
E
v
o
M
a
JQ
1
m
TECHNOLOGY: Naphthi
CAPjTALjNVESTMENT
ANNUAL COSTS
en o o en (o r<*-
en «» «» en co
in uj CM.
r** ^» *~ •
If* V> »\
'
co o o co CM cni
en v* i» en T- co:
CM CM n *•'
4» «» ° CM'i
<0>j
i
1
u> O O UJ uj O:
t*. V> If* t*~ T- Ol
eo co x.: in;
*» <* ° CM'!
ff\ \
trr!
O O O O O
.
M Z'
C/J TT
— 22!
^ o t:;
Direct cost (vendor supplie
materials
Indirect Costs
capital recovery
overhead
EMISSION REDUCTION (T
COST EFFECTIyENESS ($
-------
CO
CO
o
u
UJ
Q
o
g
u.
Q
UJ
Q
O
2
o) eo
H
^ 0.
~5 CM
Ig
0) ^
p
2 0.
« c
0.
I
« O
Z
O
5
D
Q
UJ
EC
Z
O
CO
CO
UJ
Z
UJ
a
UJ
CO
UJ
i- *- O COI
oo eo o CO!
O) O) rri ^*'
ao oo CM in
CO CO T- T-
00 OO UJ CO
«3- ^t- i- CM
O O O O
0)
O)
(0
(A
ce
o
UJ
I
UJ
Z
o
CO
O
o
Z
Z
uj £
tc
Q
2
o
E
•o
e
(A
IB
ce
O
u.
" S
i- 2
w m
8 s
ODEL PLANT
(3
O
_j
O
Z
X
O
UJ
Z!
UJ!
CO!
UJ!
>;
_ii
-------
Cn CM
CO f-
o
«»
o o o
o:
«»i
U)
CO
o o o o o
6
o o * en eoi
«» «• m o 01
co
O
O
Z
(A
0
'35
0
•o
m
"0
E
i
«•
o
X
>
O
o
_J
o
z
X
o
UJ
•2>
o
5
in
2
m
o
•o
0
ro
IS uj
o a.
._ - 3s
S|&
UJ: £ c
21.9--2
& ^
UJ
a.
<
o
en
0
N. 0
cr =
0 2
•n ^«
Z! 0 c
— o» —
_il a o
£!•§ £
&«sl
<|0- £
01
CO.
CO'
o
o
<:
Z'
<,
a
a
3
U)
^
•o
a
"in
O
U
««
U
w
5
materials
in
.2
3
j»
^n
O
0
"o
0
T3
_C
*
cvi
^
covery
0
5
"5.
(0
u
o
UJ
u.
u.
UJ
CO
o
o
a
a
$
C3
0
_j
O
Z
X
o
UJ
H-
Z!
UJi
2!
CO!
UJ:
>i
^i
APITAL If
O!
UJ
UJ
Z
a.
O
co
O
o
en
0
"w
O
•o
(0
•D
0
0)
a
ja
£z
Z 01
oti
COI
coi
0!
0|
_ii
_
ta
0
U
"o
0
0
materials
in
U>
O
O
"3
0
^
_c
>«
0
§
o
0
1
Q.
«
O
overhead
z
o
1-
o
0
Ul
oc
MISSION
UJ
CO
coi
UJI
Zl
ujl
>i
gi
UJI
UL1
u.;
y.
COI
O!
Ol
3-8
-------
il
0.
•3 CM
I!
CL
o o o
O f- t^-
in" w in"
* o o o
CO
CO
CO
O
O
UJ
o
o
Q
UJ
O
o
•o
o o o
r«. N- *- in T-I
o CM o n ti
oo CM o ^ r*-1
o o o o o
*» <«• «> o »
o o o o o
o
O C
•Q «0
05:
a.
X
o o o
o r* f^
Tt CM CO
(O
en
CM
o
co
in
V>
o
3
Q
IU
a:
z
g
CO
CO
Z
01
at
CO
UJ
x
a
OL «
UJ £
<
in
UJ
CO
UJ
"•
CO
a
O
O)
"S
v£
U)
+
X
a
n
o
M UJ
O CL
ziSS.
uji E =
O
_i
<
r«- co en
CM co o
CM r» „;
CO
O
O
Z
<
O
CO)
m
CD
o
cc
Sg
O^i
^ B> -^
CM CO ^
-4.' O> l_>
UJ
Q
O
O
z
X
o
UJ
III' Q) (0
>' -H t)
z: a .s
-JIM O
-------
-------
ATTACHMENT 4
SLABSTOCK FOAM VAPOR BALANCE COSTS
u>
o.
_ 00 •»
A O CM i- -
§£SJt5-»
D. O » * iS
3
HI
(0
(0
2
IU
o
<
cc
o
1
•5
s
r»
_e
g
2
g
•Q
cn
S
ci.5
o
»»
t~
o
•§
J3
"5
•s
o
o
•o
§
i»
5 c
a*
ft
£ «
2 c
ii
•O TJ
§§
n
o.
CM
OL
s
in
T- to CM in
CM o
co
O
eo
co
s
o
I
CM
IO
6
C
Soo
-------
-------
I
o
o
5
d
8
§
I
»n
i
* <
1
BL
5 <
_ (D
S "
1
a
S SS
S 8f
^ <»
•e
S SS
S 8f
W *•
«»«.
0 00
** f 5
S SS
S 8|
Se
S SS
» 2 8|
•i
u
w (
2 ;
s }
u j
i i
i z
° ^
Z J
s *
Ik 1 9
* S u
8 i ^|
"• - §fl*l
d 3 ^Jl|?
§ i Iliil
a u|
-------
-------
ATTACHMENT 6
SLABSTOCK FOAM EQUIPMENT LEAK MODEL PLANT COSTS
Summary of model plant: equipment leak costs 6-2
Model plant component counts 6-3
Component-specific baseline emissions 6-4
MACT floor component-specific emissions 6-5
Regulatory alternative 1 component-specific emissions 6-6
Regulatory alternative 2 component-specific emissions 6-7
Component-specific costs 6-8 through 6-10
6-1
-------
JO
0.
s
o
y.
.s
O
o
co
"35
*
JB
Q_
U
2 ^ Q.
0.
O -
UJ co
i II
UJ
Q
O
CM O CO
CO «» CO
£ I
CM O CD
s~s
ccf 1&
CM O (O
CO *» CO
^- £
to **
CO
8
$2 81:
S~''
CM O O 00
co <* in Q
O) •«— CO
N.
v*
O O O
CO ' CO
OJL CO
in"
O CM O CO
8S~S
in co" **
co S2|2
^ <» S
<» CM
*»
CM O O CO 00 CO CD
co «» in o en co co
° " "
in CM co
CO
CO
o
o
cc «,
2 «
Q o
coO
(0
o
u
(0
o
O c
• "5 o g
.t; =••§«>
^JN*!!!*
fe O o fc o ^ 2 »
J5
— C
r8
£».s c 8
* £ ~ n"i
.2 IS
E o
LU O
< « «
** l_ ^ Ul — *^ *M ^"
0'o.^S « S.Soo
UJOotoSQ-—^*
•** _~ UJ j— .^ ^» ^ «B» ^P"
CC.
w c ?? J=
c
u> £
JEi
T
O
r» <»
0)
cc
co
1
UJ
o
U
il
t
2
a
E
a
0
c/
C
C
U
a
6-3-
-------
I
1
o
Q.
I
OJ
8
HJ i- f CM
s
03 .- »- CM
*
< T- V- CM
8
3
a
«-
(0 *- r- CM
< i- »- CM
MODEL PLANT DATA
MeCI2 transfer pumps
MeCI2 metering pumps
Total MeCI2 pumps
CO r- *
co i- *r
«•«-•<»•
CO T- TJ-
CO T- ^>
co »- •»
CM i- CO
CM »- CO
i- »- CM
»- -r- CM
TDI transfer pumps
TDI metering pumps
TDI pumps total
CM IO
co T-
CM (O
CO i-
CM (O
CO »-
CM tO
CO T-
CM (O
CO T-
CM (O
CO t-
*• «o
CM t-
T
CO
10
TDI open-ended lines
MeCI2 open -ended line
NUMBER OF PLANTS
G-3
-------
r»: p cp CM p »- ^cqpcoppph; in in o
pSOgfe "££ *soj5ddd,s: ^doj
g - -
§ 8 <& 5 888 P S3 8 3 _ _ _ _.,_.
p CO CO Or^i-; O CO p CO O O. O. O \^ P ^ T— pcpocjopppp
odd odd ddddddddcM
'^ ^^ O) ^5 tO ^O *™ C9 ^3 C*J ^5 O O GO ^^ CO O)
CO GO CO OCOCO ^CMOlOOOO9>COxru)
CO CO ^« C^ ^m ^~ CO tO C3 CO C^ O O C3 CO CO ^
odd odd d d d d d d d d CM W W
I
^r
g
Q toSSS 888 £888888853
i CI?£l?'>: C?'T'~ o.*°. °. ^joo.po.0.60.
:£ I odd odd dddoo'dddcMr^
O
w
09
S~" m 3 3 S 888 £ S3 8 $ 8
COCOf-; OT^T- OCOOCOO
„ odd odd dodo'dodo
E
^ S33S 888 S?38S?888glS3
0) CO CO h- p -r-f f; O CO O CO O O O O O CO
I odd odd o d d o d d d d|c\i
UJ
o I^SSS 888 S88S888S
Q. ICOCOI^ 0^^ °. *P P *"? P P P P
odd odd d d d o" d d d O*|CM
O
lm33S 88S S?38S888S^3
CO CO f**» ^ T™1 CO O tO O CO O O C) O CM CO
ddo d d d d d d d d d d d CM •*-'
|<33S 883 c^?38S888S^
'cqcoi^ ^ T co pcppcoppppCMcq
ddo* d o* o* o" o' d o" o" d d d CM *•"
(0
z
OT
W
538.
§•£
ias
^f-2
s*
O
-------
t
i
CO
CO
CO
UJ
Q.
CO
Q.
O
O
• o o o o o o>
-i !»•; o cq pop
J N d r^ d co co
i CM co in *- »-
Ssss
co co h*
goo
d in oi
,0
CM
in. *»; cp 04 o c\i
^ ^ co co co
T i- in
Sv O CO (O ^ CO O CO
^3 {3 co co ^^ CM Cj in
coco o ^ •*- o co o co
ooo ooo oooooooo
COCO O »- •»- OCOOCOOOO'O
ooo ooo oooooooo
CO CD N CM
*- v- O O1^'* OCOOCO
ooo ooo oooooooo
S co co 8 888
co co N; p *- •«-
odd
8883888$
pcopcopppc
d d o" d d d d d o" d o*
2 SS8
odd
88
3
CO
S
CO
S
ooo oooooooo
odd
88
£8
O CO
8
CO
SS
ooo oooooooo
VJ
0
* *
8|!|
niill
K CM CM CM
< UJ 4) *
2552
(A
(A O.
i-£
E = •=
a exfl
Q. o, o
*.g w
"6 ! c
l|i
43 t Q.
OOO
(4
s!
s
If
= c
TJ "D
CD
E£!
CM
c\
csi
CM
-------
i
(0
CO
CO
tu
o
il
a.
CO
UJ
O
a.
O
o
in in in o o en
oo«
co
u> t-
CM in r*. pop •vtppcnpppp o>OcV]
pcopp
OOO OOO OOOOOOOO
v O f^ o) o CM
CM CM_ C3 »-; »-; pcopp
_
odd odd d d d d o* d o d
CM CM
VO
01
*- T- O CO O O
OOO OOO OOOOOOOO
^CM
CM CM •»
8«0 '-CM
25 f- o>
»- i- o co
OOO OOO OOOOOOOO
88 i^g8»8
'-'- O CO O O O
OOO OOO OOOOOOOO
88 ^S8 S
»-'- OCOOO
OOO OOO OOOOOOOO
CM CM
88 SS8KS88
»-^ O CO O O O O O
OOO OOO OOOOOOOO
odd odd dddddddo
^^?3 888 8888888
CMCM^| O^17" OcOOpppO
odd odd ddddddo'o
§CM Q in o o o
en O CM o O O
co o o o p p
odd odd dddddddo
CO
III
co £ i
co a a
5-g
Ul
-------
t
s,
(I)
V)
CO
UJ
o
a.
CO
I
I
a.
8
p p p pop
* He o>
t-
C T
g§
c-i
II
i
tr
-------
COSTS USED IN EQUIPMENT LEAK IMPACTS ANALYSIS
Capital and Annual Costs b v Componentfor Equipment Modifications
Pressure Relief Valves
Capital Cost
Rupture disk assembly
Annual Indirect Cbsts
Capital recovery
Misc charges (4% of TCI)
Total indirect costs
Annual Direct Costs
Maintenance charges (5% of TCI)
Total Annual Costs
Open—ended lines
Capital Cost
Gate valve
Indirect Annual Costs
Capital recovery
Misc charges (4% of TCI)
Total indirect costs
Direct Annual Costs
Maintenance charges (5% of TCI)
Total Annual Costs
$4,070 per PR-valve
$2,251 per PR-valve per year
$163 per PR-valve per year
$2,414 per PR-valve per year
$204 per PR-valve per year
$2,618 per PR-valve per year
$106 per line
$15 per line per year
$4 per line per year
$19 per line per year
$5 per line per year
$25 per line per year
6-8
-------
COSTS USED IN EQUIPMENT LEAK IMPACTS ANALYSIS
Capital and Annual Costs by Component for LDAR
Information used in LDAR cost calculations
Subcontractor fee
initial monitoring $2.50 per component
subsequent monitoring $2.00 per component
Labor cost for repair $2250 per hour
Mon itoring instrument costs
capital cost
capital recovery
annual miscellaneous (4% of TCI)
total indirect annual cost
annual maintenance (5% of TCI)
total direct annual cost
Total Annual Cost
Pumps in light liquid service
Monitoring frequency
initial leak freq. (new programs)
Existing leak frequency
uncontrolled
Quarterly - 10,000 ppm
Pumps needing additional repair
Time needed for additional repair
Cost of new pump seal
InffiaJmonitoring
Initial monitoring costs
Initial repair costs-labor
Initial repair costs-pump seals
Subsequentmon itoring
incremental monitoring cost
incremental repair cost-labor
annual maintenc-pump seals
annual misc charges
administrative/support costs
$6,732
$1,412
$269
$1,682
$4,280
$4,280
$5,962
per facility
per facility per year
per facility per year
per facility per year
per facility per year
per facility per year
4 times per year
20% leakers
7.48% leakers
3.75% leakers
75% of total leakers
16 hours per pump
$186
$2.50 per pump
$54.00 per pump
$27.96 per pump
$56.50 per pump
$8.00
$40.50
$20.97
$16.78
$67.90
$154.15
per pump
per pump
per pump
per pump
per pump
per pump
per year
per year
per year
per year
per year
per year
£-1
-------
COSTS USED IN EQUIPMENT LEAK IMPACTS ANALYSIS
Valves in light liquid service
Monitoring frequency
Initial leakfreq. (new programs)
Existing leak frequencies
Uncontrolled
Quarterly-10.OOOppm
Valves needing additional repair
Time needed for additional repair
Initial monitoring
Initial monitoring costs
Initial repair costs-labor
Subsequentmonitoring
incremental monitoring cost
incremental repair cost-labor
administrative/support costs
4 times per year
6.5% leakers
4.34% leakers
1.60% leakers
25% of total leakers
4 hours
$2.50 per valve
$1.46 per valve
$3.96 per valve
$8.00 per valve per year
$1.44 per valve per year
$13.22 per valve per year
$22.66 per valve per year
CAPITAL RECOVERY FACTORS
Interest Rate =
Time Period (yrs)
6
2
10
7%
Cap. Rec.
Factor
Application
0.2098
0.5531
0.1424
Monitoring Equipment
Rupture Disks
Control Equipment
G-/0
-------
ATTACHMENT 7
SLABSTOCK FOAM MODEL PLANT HAP ABA
REGULATORY ALTERNATIVE EMISSIONS
1-1
-------
ca
C ot
P JS Ot
IE §
J5 *• w
a o JB
et o E
B U. uj
O
5|
a
CM
IO
CM
«
«>
CM
CM
CO
0»
CM
J3
,-
CM
CO
OB
CM
^
CO
v>
,.
CM
CO
IO
CM
IO
,.
04
•»
CD
T-
CD
v.
CM
CD
10
»-
CM
v-
co
IS,
»-
CO
o
CM
CO
co
o
CM
•r-
co
o
o
0
^f
o
*•
o
0
o
o
o
o
CO
o
IO
o
CM
o
o
o
IO
o
CM
0
o
o
o
o
o
o
o
o
o
o
o
0
o
o
o
o
o
o
o
o
CO
o
CM
o
0
o
CO
o
CM
o
o
o
o
o
o
o
o
o
CD
o
CM
0
0
o
o
o
o
0
0
o
o
0
o
*- 01
fs. |s.
*- co
N> CO
co ^~
CM n
IO
o
o
EC
UJ EC O.
o
«
a.
§
5 -a
w _
o •
**
Si °
« *
•^ a
a
ill
c -a c
g 2 S
O #
U. 10
. — e\
ft
3
e
a
CO
10
3
D
0
CO
0)
e
o
a>
IO
CM
CM
3
3
q
o
o
a
^
2
0
IO
o
u
o
fs.
CO
?
3
O
CM
q
c
o
•v
co
o
ao
o
CO
q
e
CO
CO
2
3
O
CM
*-
C
CO
CM
'"•
O
o
CO
T-
e>
CO
CO
to
3
T*
O
co
CM
e
CM
CM
CM
CD
O
(O
O
CO
CO
ff
eo
co
o
CM
O
o
CO
o
e
co
O
CM
O
O
,
c
co
CO
CO
o
o
CM
IO
e<
IO
CO
•»-
CD
3
o
CO
to
V
IO
CO
V-
CM
N
T-
0
IO
c
u
CD
o
^
3
»™
o
CO
c
CO
o
*-
0
CM
*-
0
r.
o
r
o
•q-
o
10
e\
CO
c
CO
CM
CM
co
0
V.
CO
c
a
o
o
o
3
^
0
CO
c
a
09
CM
h»
0
F.
«.
i
|s.
0
^
8
•^
c
a>
o
^
o
o
o
3
IO
IO
CM
IO
c
A
IO
10 g
sf
•o 5 a
0 3 CO
*~!.S
2P
sS
.2,2
i
^
I1
in
e i
-------
o
0>
v JZ
±: E
CO
CO
o
o
o
CM
Y-
O
0
o
o
o
o
o
f
*•
IO
»•
CM
O
o
o
CM
CM
O
O
o
o
o
0
0
0
o
o
o
0
m. *~. #
T- C"> O
10 ^ CD
o
CM CD ^
•»- CO CD
tt>
CM
H
Z
a.
UJ
Q
O
s
1*?
« a "P
s •
o
£1
0 °
a
^"^
'c C9 "5
3 « -5
§11
o 3?
u. £
t?
oS
0
•3
a
o
«0
o
o
CM
o
«
CD
O
C
a
«D
t>-
CM
CM
o
CM
o
0
o
o
CD
•»
o>
o
CM
IO
O
IO
o
CM
•~-
*
O
CM
O
CM
O
0
CM
o
o
CM
CO
O
CM
O
CO
O
O
co
o
CD
o
J
o
CM
O
CM
,_
cv
CO
h-
N.
o
CO
o
CO
_
0
a
o
0
10
o
o
CO
§
CM
C
CN
CD
«D
CD
0
03
O
CO
co
B
CO
CM
CM
O
D
O
co
o
^
CM
CM
0
CD
S
„
O
^
o
0
n
o
CM
o
CM
10
o
CM
IO
CD
V
03
N
O
O
10
c
IT
CD
^>
CM
O
to
CO
o
IO
c
1(1
CM
*~
O
c
a
o
CM
*"
O
o
co
o
a>
0
o
o
o
o
§
in
»-
in
CM
0
CM
c\
A
•5 -a s.
t (p a>
uj CC a.
to
IO
•o
fl « m
o ^ a
f- »
o D
>,
•5 p
a. P
fi &
o o
fit-
I
I
g> O)
§8
= o
CM
1-3
-------
«
0
«t
f JB
5ifi
1 *-
e E
Is 3
£"•2 oj
5 E *
M Hi —
»- 2
o J E
O
in
CM
in
o
v
CM
«0
1*.
N
fs
o
^
oo
CO
in
in
CO
co
^
oo
N.
o
CO
CO
^.
*
o
O)
o
a
o
o
o
3
V
CM
in
CM
o
CM
1
A
0
CO
CO
•o
— 09
I^S
"5*5
a. P
55
^^
je
.a
E £
Io
c o
If
co
-------
*tD
T- J8
- E
5 ?
S 1
Is 3
*** O
o c e
« l5 -2
•5 »_ *&
3 O •£
0» § g
O
N-
O>
IO
0
CM
CM
CO
co
(s.
co
CO
0
CM
H^
CO
CO
o
CO
(O
l»
in
(V,
CM
fc
Q~
to
CO
o
in
o
CO
en
o
o
eo
en
in
o
CM
CM
CM
|
O
O
o
0
CO
(^
*~
en
0
in
o
in
o
CO
^
*"
0
CM
0
O
CM
o
in
(s.
CM
co
s
in
o
n
0
0
n
o
CM
in
CM
„.
*~
0
CO
CM
0
CM
,_
O
CM
co
r-»
*~
K
0
o
CO
^
o
CO
o
co
CM
in
S
(0
o
eo
CM
o
CO
CM
o
in
(O
o
"
co
o
CO
CO
eo
h*
CM
0
in
in
§
co
o
CO
in
in
CM
o
o
^.
o
CO
n
CM
eo
o
CO
CM
0
CM
in
o
CM
in
to
«B
3
0
CO
in
0
CO
in
CM
en
CM
O
en
CO
o
in
o
in
to
in
_
so
co
o
to
0
to
in
in
^
0
CO
eo
0
r-
0
co
f^
CM
O
O
o
CM
O
O
CM
O
o
in
o o
E o
^T
CO
-------
il
e °
b «ff 09
S £ e
S, °l
* fifi
K .
t-
o
in
0
CM
in
oo
CM
«O
O
CD
CB
CO
oo
Ot
co
CD
CO
(0
00
,.
o
oo
in
T-
in
CM
in
V
N.
ID
,_
O
oo
0)
CO
•^
»-
o
«D
D
CO
O
CD
CO
r»
in
5T
»-
CO
O
o
o
CD
CO
O
O
O
0
o
o
in
in
CM
CM
o
o
o
V.
in
CM
o
o
o
o
o
o
o
o
0
o
o
o
o
o
o
o
o
o
o
o
o
«.
in
CM
o
o
o
CD
N.
CM
O
O
o
o
o
o
0
o
o
CD
N.
CM
O
O
o
o
o
o
o
o
o
o
o
o
O O *
CM OB W
-Sg
o
n
CO
0
c
at
M
CM
CM
i
'
o
o
0
V
0
CD
t.
O
u
o
N.
•.
•
•»-
CM
q
o
CM
o
^»
ft*
*•
• •»
) a
0 CM
3 ,-
O O
0 C
4
0
s.
in
CO
.-
c
^
>
to
n
o>
CM
C
ci
e»
M
«9
n
co
CO
o
cr
c
09
^
1 CM
> o
> in
r v
0 ^
3 C
1% 4|
oo
>
CO
n
CM
in
c
in
CM
i
03
a
CO
r
in
c
in
M
CM
n
a>
'
in
o
u
n
CO
i
^
CO
c
«
CO
<0
i
^
c
n
in
M
O
E
s
oo
c
c
CD
O
CM
OO
C
CO
OO
p
00
o
o
o
0
c\
oo
c
0
to
>
n
T
a>
c
CD
in
S
co
v
a>
c
c
o
o
o
3
D
CD*
CM
O
O
CM
A
O
ao
•o
•5*
a.
S
o
-------
ATTACHMENT 8
SLABSTOCK FOAM MODEL PLANT
COSTS FOR CHEMICAL ALTERNATIVES
MACT FLOOR REGULATORY ALTERNATIVE
page
Grade-specific model plant materials costs 8-2 through 8-6
Model plant costs 8-7
-------
a.
ui
o
o
--8
9 * S "C
ife*
**
S~ o -o
C P ^*"
"l~
__
5^1
2 • 2
8 S S
gl •
7
S 2,1
o "5
• a
S
** 0 •=•
l|s
too
0 ^ **
" a.—
o #
u. m
Si
*«
Q *"
0
•O
6
O
1
a>
CM
O
in
in
CO
CM
*»
CO
in
o
•
S
o
CO
at
o
o
CO
O)
CD
in
CO
S
o
g
a>
in
CM
CM
o
o
o
o
o
CM
O>
CO
2
co
CO
o
(O
a
•*
a>
"
o
in
o
in
o
i
CM
CO
O
O
o
in
co
•in
CO
CO
CO
"
o
o
CM
•
in
o
CM
in
at
at
CD
in
o
S!
03
*"
CO
o
3
in
o
CO
in
8
S
i
CM
f*
*
CO
*~
CM
O
CM
»-
O
in
o
in
CO
o
?
in
S
0
^
*
co
o
,-
§
o
CO
o
CO
CO
CO
CO
CO
at
CO
«D
*»
«D
O
,_
O
CM
O
^
O
§
o
co
co
co
CM
O
"*
O
o
^
o
,_
o
o
o
at
o
S
o
0>
o
CM
CO
a
2
o
o
o
i
in
CM
in
CM
o
CM
O
A
5* » <»• CD
co in co co
« f* 09 o in
ECM O •»- CO
CM !*• CM «O
**^*
.£ O *•»
•»«»«»
a
i
• ' S •— **
o
-------
CM
UJ
g
* — »
"i "* § «•
3 e >
c e e -c
«£ ««
o-g
*«
a 8-c
ic^
c £ «»
•I fll
"5
o
111
2 3 E
ij ' '
1 si
Si
2
*"§<=
Ml
SU
si
~ ffl
^e
g?
Is
9
•o
0
O
ID
O>
CO
m
a
CO
o>
eo
o
«D
O
^
0
0
n
a>
0
0
a
a
R
S
o
to
n
CM
»•
o
N
CM
CM
O
(M
O
O
O
»•
O
to
^
»•
«"
CO
a
0
o
o
o
CO
o
co
o
co
CO
CO
CO
K
§
«D
0)
r»
r-
CM
V
co
f«.
O
CO
o
CO
a>
o
CO
a
m
o
in
»
*»
a
CM
CO
*•
0
CM
-
O
CO
o
a
o
s
in
CM
co
co
0
CM
*»
in
s
o
CM
«»
0
O
o
o
s
in
CM
o
CM
O
CM
O
A
tn co «o •»• eo
£ o> CM o m
« CM O »- »-
£co" v co" «o"
(O CM (O O
a *» f* co o>
^ CO* tt>" O
° *»*»5
••> •» •» ••
*^ir*
• e e e o
e g o o o
V tiif*: V
§ « K V- «i
i — 10 ID K
•*'*«> «o o
*~z
a
1
w/o M«CI2 Cta
ABA cost
chant coat
ABA foam
Total coal
-------
Q.
si
§
Mm
-5 « 8
3 e 5
III*
o-g
I**
3 o "g
* 5 ""
o
5
l|l
s s §
o •
gS
7
a* o
& £
O 2
9 a
—
1|1
Q 3 41
E||
o 5
u. in
SI
t«
S3
Q
fi
a
CM
in
CM
S
CO
CM
en
S
0
o
o
8
in
in
CO
*»
*
in
CM
o
in
CM
CD
8
in
o
co
o
o
CO
0
CO
CD
^
%
0
co
CO
o
03
V-
8
CM
O
CM
^_
O
CM
^
S
CD
O
in
in
CO
in
*»
o
co
**"
0
o
CO
o
co
^.
o
CO
•»
in
CO
S
w
CM
CM
O
«»
„.
CD
in
o
o
in
S
CM
O
n
CM
CO
S
CM
«»
O
•£
fs.
o
o
CO
g
en
o
CO
CO
CM
CO
1
CO
at
CD
co
CD
£
CO
CO
o
o
in
S
o>
o
•V
a>
o
CM
CO
CD
S
CO
o
SI
S
CO*
4^
o
o
o
8
CM*
in
CM
o
CM
0
A
ft <• CO CO •"
S CM CO 03 »•
a co ^r in co
ECO" V in o*
* CM CM 03
g »- CD CO_CM
o ** "* JT S
******
t. w ^ w
• o a o o
c o o o o
s a o o o
• » os'iC 10"
9 S 5 fi X
• Ot 09 O A
•S «* v - .c
•*•*»*»
CO
I
!
c
Il|!^
fr < o
-------
z
a.
UJ
o
O
2
*4 **
iǤo
||e|
o -g
• _ g^
c ° -5
g | $»
o
If I
S Sf
o •
g~
S ^
« a
2 -c
* a
a
amount
produced
(tons/yf)
a #
tL in
t«
Q *""
5
o
v
CO
0
o>
S
a
CM
O
o
CO
«3
co
o
*•
0
in
in
o
CO
O)
o
o
CO
o>
^
in
in
in
CM
in
CM
CM
in
o
CM
CM
CM
O
O
o
o
o
CM
CO
CM
ffl
O
01
CM
CM
CO
t-
o>
*-
o
in
o
in
o
to
CM
oo
CM
S
CM
CO
CM
CO
^
^
0
o
CM
o
o
CM
0
V
5
S
00
0)
CO
o>
CO
CD
jr
K
o
o
CO
^.
o
CO
to
in
S
*»
CM
0)
O
*»
O
CO
CM
in
o
CD
<0
O
CO
CM
0
CO
CM
f,.
CM
CO
03
CO
O
CM
g
co
o
in
03
o
o
CO
CO
o
CO
CO
U)
1
«
*
co
co
•»
CM
0
in
in
o
CO
o
co
^
o>
CO
oo
in
r*.
in
in
in
CM
0
o
„
o
•f
^.
CM
CM
V
S
o
0>
CO
co
CO
CO
o
CO
CM
o
CM
in
o
CM
in
^
CM
O
IO
V
co
in
to
CD
o
o
CO
in
0
CO
in
^
co
o»
CM
0
~
CO
CO
CO
o
at
CM
OS
CM
0
OS
4*
in
in
^
oo
o
^
0
n
£
o
CD
CO
in
i?
CO
K
CM
O
*•
O
O
CM
co
0
0
CO
CM
S
in
CO
to
in
0
in
03
o
•
CD
O
S
^
to
S
«
i
T-
*»
O
0
0
0
CO
CO
o
CO
o
co
^
CO
CO
g
5
in
o»
i^
o
o
CO
CD
o
CO
O)
CM
03
CO
n
in
o»
o
o
0»
CD
*
,.
i
O
0>
o
a
o
1
«»
§
a
o
in
*»
o
o
o
o
N
CO*
in
CM
o
CM
o
CM
O
A
a T if) tn at
S CM r- CO *-
• CM •* CO O
c o o o co
^ JA K « v
o o> * ^
^**^
• o o o o
^ 5. °. °. °.
JsisI
«»«•«•
a
e
|
8
N g v
• a ° J *
S u ^ < 1
^ ^* n 1C
•S to £ < t—
J < o
-------
8H
ft
ffi £!
in
g
o
O
§3
|
5
-------
og
1
(0
w
UJ
< I
I ^
0 a
>- tu
§ 5
i 6
2 o
= d
uJ 1
i i
O p 90
• 5 * «
«•» O «4 *.
SB *»«»«
o e on
a> c- « M
« 0
8-
- ICf T-- .-•
2 s:
CM « I
o
ri
o o O n
«0 t * CM
no CM_K
8 •» >HS
SS8S
«9 O Of |*»
S!" " '
«> J»g 5
a is;
«O I
n_ o CM K
8 •» «»«
o o
3 S8SS;
7 e CM CM ~ '
a o co 9 o » r-
.. . g S 58C-5
«rf-_- n Vr-'r-* »-•
-------
-------
ATTACHMENT 9
SLABSTOCK FOAM MODEL PLANT COSTS FOR CARDIO
4
page
Model plant costs 9-2
Description of CarDio licensing costs 9-3 through 9-4
Description of costs for CarDio + Chem Alts 9-5 through 9-6
-------
I
1
SSS!
On <
s's \
SSfiS CV CM 10 p I- 10 O Q CM CM CM O m CO
OOn V) f*» O CM O C9OO^* C9 f<» IO CS CD
ce CM i- co* See »• »-w CM «-
«» «*«»
§S 8"
-
•To to"
S" w a" "•*
** &
STg g CM CM CMC? tOC?
isle it*"5
M 4» •»•»«•
to lie CM
n n CM o
oils
CO O O CM O »- f» O
.- S o in in « CM oS _
o "" ~
5r •»•» A 5 — ~
e • »«- -
&88S SKSS2
ocpon ^^»TCM«-
o cuciic7nS
CM n r> o N
«" V aT o" rt" «tf •" ^ |J to*
o CM CM *•*»«» 3 o C »•
*«» i S "* «»«»Ji
•* ^* <^_ ^^
n »-«-«
<>
1
IU
e
S
a
88S8
on n
-
o
m rt & .- f>
^to^S
->.•« of
s
U
|SS£ 82S 5
S CO O CM S?2*"
££££ ess
I
- iff
u. O go,
w Q STJ
i 1! 31s
i 6
! § ?
I i
ssi
IT 5
I g
5 2
8ij i
f
•S. t» J
2g
C UJ
SO.
UJ
iu U
jl
11
51
I
oil
83
53 Q
Is
1
l
uiu
-------
DESCRIPTION OF CARDIO LICENSING COSTS CALCULATION
The licencing costs for CarOio are l percent of the total
chemical costs for foams made with CarDio technology. It is
estimated that the chemical cost for making CarDio foam was $0.72
per pound. Therefore, to estimate the licensing fee for each
regulatory alternative for each model plant, it was necessary to
predict which foam grades each model plant would chose to make
using CarDio. It was assumed that each model plant would chose
to make the foams that had the largest amount of MeCl2
used/emitted until the necessary emission reduction was achieved.
The following tables provide details of these assumptions for
each regulatory alternative. The model plant foam grade-specific
emissions and production amounts referred to are provided on
pages 2-4 through 2-8 of Attachment 2.
CarDio licensing coats to meet the MACT Floor
Model
Plant
1
2
3
4
5
Foam Grades
Produced using
CarDio
0930-1120, 1820
0930-1120, 1820
0930-1015, 1030,
1520, 1820
0930, 1010, 2030,
1120, 1230, 1520,
1820, 1930
0930-1015, 1030,
1130, 1230,
1820,1930
Weight of
Foam
Produced
(Ibs/yr)
760,000
2,280,000
4,800,000
6,620,000
7,980,000
Chemical
cost at
$0.72 per
pound ($/yr)
$547,200
$1,641,600
$3,456,000
$4,766,400
$5,745,600
Annual
Liscensing
Fees
($/yr)
$5,472
$16,416
$34,560
$47,664
$57,456
1-3
-------
DESCRIPTION OF CARDIO LICENSING COSTS CALCULATION (continued)
CarDio licensing costs to meet Regulatory Alternative i
Model
Plant
1
2
3
4
5
Foam Grades
Produced using
« CarDio
MACT floor +
1230, 1520
MACT floor +
1230, 1520
MACT floor +
1020, 1120
MACT floor +
1015, 1130
MACT floor +
1830, 1330
Weight of
Foam
Produced
(Ibs/yr)
1,040,000
3,120,000
5,600,000
7,720,000
10,260,000
Chemical
cost at
$0.72 per
pound
($/yr)
$748,800
$2,246,400
$4,032,000
$5,558,400
$7,387,200
Annual
Liscensing
Fees
($/yr)
$7,488
$22,464
$40,320
$55,584
$73,872
CarDio licensing coata to meet the Regulatory Alternative 2
Model
Plant
1
2
3
4
5
Foam Grades
Produced using
CarDio
All except
1340, 1440,
1540, 1640,
1740, 1840,
1940, >2020
Weight of
Foam
Produced
(Ibs/yr)
2,400,000
4,800,000
9,400,000
10,460,000
12,160,000
Chemical
cost at
$0.72 per
pound
($/yr)
$1,728,000
$3,456,000
$6,768,000
$7,531,200
$8,755,200
Annual
Liscensing
Fees
($/yr)
$17,280
$34,560
$67,680
$75,312
$87,552
-------
DESCRIPTION OF COSTS FOR CARDIO PLUS CHEMICAL ALTERNATIVES FOR
REGULATORY ALTERNATIVE 2
It was assumed •that the total elimination of HAP ABA
(regulatory alternative 2) could not be achieved using only
CarDio. This was because the base formulation would need more
than 3 parts MeCl2 per hundred parts polyol to allow the
substitution of carbon dioxide as an ABA. However, these low-ABA
foam grades could be produced using chemical alternatives.
Therefore, the combination of CarOio and chemical alternatives
was assumed to achieve the complete elimination of the use of HAP
ABA. The capital costs, capital recovery, and other indirect
annual costs for this combination were simply the sum of the
capital costs of CarOio and chemical alternatives.
For regulatory alternative 2, the procedure for calculating
the licensing fee for the foam grades made using CarDio was the
shown on page 9-4. To calculate the material costs for the
combination of the two technologies, the chemical costs
associated with the substitution of carbon dioxide for methylene
chloride was added to the material cost of making the remaining
foam grades using only chemical alternatives (see pages 8-2
through 8-6 of Attachment 8). The following table shows the
chemical alternative costs in more detail, followed by a table pm
page 9-6 which shows how the total annual material costs were
calculated.
Chemical Alternative Costs for Selected Grades vhea used with
CarDio to meat the requirements of Regulatory Alternative 2
Model
Plant
1
2
3
4
5
Foam Grades
Produced using
Chem Alts
1340, 1440,
1540, 1640,
1740, 1840,
1940, >2020
Baseline
Chemical
Costs
($/yr)
$1,542,100
$4,521,692
$7,402,830
$11,952,207
$18,033,005
Chem Alts
Chemical
Costs
($/vr)
$1,553,218
$4,534,955
$7,447,648
$12,028,625
$18,128,565
Incrementa
1 Material
Costs for
Chem Alts
($/yr)
$11,118
$13,263
$44,868
$76,418
$95,560
-------
DESCRIPTION OF COSTS FOR CARDIO PLUS CHEMICAL ALTERNATIVES FOR
REGULATORY ALTERNATIVE 2 (continued)
Total Materials Costs for CarDio plus chemical
aeet th« requirements of Regulatory Alteraativ<
Alternatives to
i 2
Model
Plant
1
2
3
4
5
Incremental
materials cost of
C02 versus MeCl2
($/yr)
($37,926)
($113,854)
($233,905)
($227,860)
($260,576)
Additional
Material Costs
for Chem Alts
($/yr)
$11,118
$13,263
$44,868
$76,418
$95,560
Total material
cost
($/yr)
($26,808)
($100,591)
($191,037)
($151,442)
($165,016)
-------
ATTACHMENT 10
SLABSTOCK FOAM MODEL PLANT COSTS FOR ACETONE
W
8
£
si
a
o
a
U)
n
»s:
i •
a. '
•a
° !
m
I5
J
^
•o
o
»
28!
§
1
0
«!
ffli
"* <^l
*S .
S
a.
Q
* <
O
1
Z
1
O '
^
g
O
IU
2
O
A EMISSI
5
s
o
Ik
(0
H
C0
u
MODEL PLANT
IU
U
w
<
TECHNOLOGY:
§000
owo
f» n o
•» CM *•
«- »
§000
owo
p. n o
•• *" *
co n ft
w »
OOOO
SS"§
S n S
•» «*
OOOO
oowo
r>. n o
« n S
«* *»
OOOO
g«-*s
«• CM «/
ca n ft
w w
§000
owo
r>. n o
— CM j
SS 2
<• «
oooo
gs-§
— CM •
«• M
OOOO
oowo
i-. n o
" •* »
on ft
»- w —
•» «*
OOOO
oowo
^ n o
•» CM •>
— *» —
§000
owo
r* n o
«• CM ^
« n ft
JT ** ^
K
Z
111
I
IU
>
« 2
•i *~
1 I
s' ^
Si_ i-
•^s
1 1 O
z'l
s' a c a
CAPITAL INVEST
Purchased equi
Direct inslallatio
Indrect installat
1 of contfo
Ik
ci •
r*~l ^
n CM «*
*» **
sslsl
— W «* CM «»
it **
O «- O 00 0
CM CO O CO S
P» CO « I*. U»
CD" m" CM f^ CM
Si
3* ••" Q CO O
CM CO O CO O
o in CM r. CM
2** **«»•*
tt.
* •- o o o
ej co 8 CM S
» in CM m CM
5****;;**
«">- o o o
SCO 8 CM S
co in *c* m
* in CM in CM
« «• «t> ^ «i>
in co o S 8
<- CD in « in
co in CM in CM
St*
55838
*- co m in »
<-*••»«»«»
n
•i *
materials
utilities
maintenance m
licensing
maintenance lal
Indrect Costs
So o n o sr
o Z r«. CM »-
ca> in r^ * CM CM
r~" — f." f. <*
S.****5
•POO cTo G?
CM B Z r- CM —
!-" — f." r-" i»
CM 4C* 4ft ^
CM O O O O> CO
CM w w n "—
•» }»
slilsss
&SSS *
So Q in «r oT
B Z ID co o
IV." - ^ - *»
•* J»
CM O CO CD ca CO
*•* *• fs ^ si
CM «•>«• n
«o Q g n» »
CM O CO CO Ol O>
CD m r» r* *t
r- — p» co
•»
« 0 o <5 •» »
« tn r» r- «»
i»- — r. co
CM «•.«•><*
•»
CM B 8 M n CM
o » r. — —
CM •»*» JJ 4*
e in r- — «-
CM MM S w
CO
O
U
O
~
1 I
2 "
5^5
?f* 11
sj» u -~ t w
~|5 §S
capital recovery
overhead (6% o
adminiskative c
EMISSION REDU
COST EFFECTIVE
o «• o o o
v co B r. B
V CD «I CO «
in in CM co CM
a won <•
tc^
c? v- o o o
» co 8 r» 8
m m CM co CM
«s <•«* n <•
£ *
c* *»
tt
S S 8 S 8
o» «i m «o m
o *»*»«*»
«»
S — o o o
0 o a o
*- a « « n
a *n «M •» n «»
O CD O O O
^ o to 09 m
» «" w csf CNI
N •»•»««»
e
Q *- O O 0
Sao o v O
a « *» «o
n n w «o «si
§**•**»**
—
Sco 8 — B
CD in in in
10 n CM co CM
o *»»» — v»
tt **
CM «• a O Q
Sao B f*- B
CD m o in
•^ in CM 4D CM
ss.
30 o h- O
CO U CD «
CM <•«•*»«•
«
0
±1
C
o
u
"&
9
•1
c:
*
If
~3\ °-
5i a •
i!s | '
«i c E 3
•— • • •
g'i S SB
°'f- lifij
«J, O 0 «• • — •
?^|5cSco
iiiiuii
M O *B O| «> «A
o ••
O O C3 ^* CO f*
CM O «D 9 CD U)
r-.' - is." «».
So a o co CM
8 e CM n n
CD in r- CM CM CM
CM M I* m ~"
CM o S tM n n
O IB r-. CM CM CM
S •»•» S "*
o Q Q nn ccT
CM O CO O CM ^
a 10 r« in CM CM
^" ^» «*»" co" jft
CM «•> «» *r
«. w.
o o o n n CO-
CM O «O O CM ^
o m r* Si CM CM
CM *» •• »
<• «»
o Q Q o « n
CM O CD « •- «•>
r." -" iC •»
0 o o CD » r>
o in t* n *•
h." - IS." •*
CM «•> «•
•»
S§?5S2
fj — !>." CM" **
«• ** w
o g o in co •» n
h-
CO
O
U
3
^
! i
i< «^ w?
71.1 §g
S? u "™" ^ *
» » • z «»
« 2 5 o to
= £1 g.?
capital recovery
overhead (0% o
adminisk alive c
EMISSION REDU
COST EFFECTIVE
_
!
u
b
•
native II lev
1
—
,
ANNUAL COSTS
t~ — Q Q O O
CM CO B CM B «•
CM co in c0 *n
o in CM o CM
~** •*!•**
P — o o g o
CM CO B CM B «•
O M CM O CM >
CM w M in v»
s -
CM 5 8 O 8 •»
CM co m h. m
o> «•> «•> v t»
V *»
CM co in r» in **
• <*«•«••»
*
» — o r» o o
n CD o «r B w
n co in o K>
v H> CM «<> CM
i* **
M? »- Q h» Q O
n co B » B <•
n co m o K)
^ m CM * CM
«- ** %•
r» — cs K p o
Sco B ID B «»
co in CM in
in n CM in CM
a. •>
P- 0 •«• 0 0
SCO 8 CO O 44>
CD in CM m
•n in CM in CM
CD «* •» CM 4*
•» w
8 S in 5 in **
«- in CM a CM
S-
S— o 01 55 o
o co o n o *a%
» 10 m * »
« •»«•>«»«*
a
ۥ
a
8 -1 8
1 E ^1
1 J5 Sl-j
f «.ili2c!
illlslis
li?:si^£l|
S8S?S^
*p m r-» « n n
r-' *." .< *-' £
*» —
CM 8 8 *r oo CN
h* *~- IN_ i~ ^*
M ija^ n a
•o n F«* *N. « «
CM «* «•> O *"
* e
CM a CD m n O
CD » r>- r» n n
CM «* •» 0 ~
tt
« O 0 O O ff
CM B Z CM n o
o » t- in n n
r-" » r-T a>" Si
CM 4»«» <>
«* Si
CM 8 S CM n O
w *»
o Q Q n in f^"
CM o Z en CD n
^-" »-i«." CM" JS.
•* tt
eoo c7«n C1
CM 8 «9 g CD n
!--' - i>J CM' S.
CM •» •» CM
"* . tt
88 8 §S 8
o in f* n *•
r-" — t-~ «" **
CMMWCM
o g g CD in Q
o in r- n »
CM <• *» CM
fe
8
3
Z
! I
Sue
£-* If
7*# §1
rf u *•** ^ "~^
S 8 j z«»|
=.= .? S ?.
capital recovery
overhead (0% o
administrative c
EMISSION REDU
COST EFFECTIVE
i
j
^
i
i
i
a
I
c
n
-a
i
Ol
-------
-------
ATTACHMENT 11
SLABSTOCK FOAM MODEL PLANT COSTS FOR VARIABLE PRESSURE FOAMING
8S§ SSgSSS
o o •- 0 3 o — CM OD
Ssa 8'28'a si
X-a- SttUS
too o o o » o '
•«»•-. 0 O o O CM »-
f2S8 S
•» ~" *»0»
— o o oooooini
ooo ocoor-cool
K. «t *". ". *. °. •*. ° "-I
n 10 co 0(00 in ^'
8=s IsHS -|
» - »~t««
ooo ocTooor*
(MOO OOONCMCM
0019
» O CO
«»"* —
3"o o"
gss
£***•
i§§
o «o *-
r*k «>» CM
J» «*«»
0 9 O «• M •
S2S3 Si
• «».— 0
o o o o e —
o o o CM a «
0 w O Ith •• CM
SCO O CM CO
— 3 » •»
O •» »- 0
«•—•«»•»
§0*0 o o •*•
CO O CM tt 0
S o r. »- CM
ej n g CM n
•»-»•
So o o » «t
0 O V 0 V
0 0 O CM ^ IO
O co g CM n
O 4^ *- 0
O 0*0 o » n
O 0 O » 0 f
0 0 o CM w «
snss s
O 4* «- 0
«•> — «»«•.
o o o o « n
O ID O O a N
0 0 o » ^
9 ^- 0 CM «i>
*»—»»«»
^ to *•
rss
a***
ooo
« o o
o" w>~ co*
S <- CM
•~ «* «»
o"o S
« O 0
O « (O
E** —
ooo
2S2
0 in n
t «»«*,
0*0 3
ooo
0" » CO"
f» *• CM
£*«
ooo
So o
0 ^
C* v CM
«,«•<»
0 0 O O CM T*
S " S S N*
s*=s
O O O O « «5
SSgcMCMS
S2S8 Si
0 «• «- 0
4» "«»•» '
SO* O O 0 CO
o o co n 2
0 S o CM CM n
S " 8 8 Si
5-»S
O O O O CO O
O ID O 00 CM A
0 0 O CM CM A*
O CO Q *• CM
5 — US **
O O* O O CO O
O « O 0 CM S
OB 2 O CM CM r-
o" n o" — CM"
SS2S «*
•» — •»*»
§O O O » "
0 O 0 -- CO
0 3 O » »• CM
S 28 S S
t» ~"l»«»
1^ 0 ^
co on co
O «- CM
««•«.
•TOO
(BOO
0 0 *•-
^ 0 CO
|»e
i?O o"
01 O O
0 0 »•
» S "
««»«»
a o o
§S2
(0 00 CO
2***
ofo a
ooo
o> o »-.
ri OB co
0 ^ CM
tt "
» o o
moo
tt •"
• o5 o o o <•)
9S3-S «
0 «».- «
§o o e w r-
oo o ^ co 0
0 35 o en n «
?co o ^ «•
— 3 co •*
S^SS
o 0*0 0 m r-
o w o ^ co 0
0 0 o m n «
S 2 3 n «•
0 <» jj «
o o o •- o co
SOO O CO "«»«»
§0 o o in r-.
« o 0 0 »
0 0 O * *- O
S — 3 S 4*
o «* ~ 0
4* -~«* *»
1C
u
5
ri
o
i o
i 1
I i
i i
w m
< CO
a ui
I £
§ S
u. £
m <
« i
8 >
z 5
< §
«: §
- i
OD
g
o
8
o"o o" oo"oo«n
900 OQOOOCM
o 10 — eo 3 o « i~
iDoo
5 «j —
o
oi
oco^
o « t-
82
EC
a
aj
31
• t o
2i o
1!
Ill;
UJt • =
>:-o a'
1^-
^|I,
i,2a.
o
ooo
voo
S 03 —
ooo^«*
o o o n v
3 0 V I-
000 Q 0*0 Q — ~
YOO OCOOOC9«
o «o — co 3 o ? t-
a
O
0
ol
?!
81
•81
-;
.
!-!c
8?
1
1
o
i
#,
f
zO
ot
"
°i
§|
5l
u C
—
f c
— UJ
|g
tU O
OOO O O O O i
SOO O S O CM
0 »- 0 0 O •-
8"288"
5§§ gggSSS
««>*-. a * o_ <^ w
o 10* n o « o" o» o"
n*-«v 9*-<5« CM
ss.**^ S-fi-wS **
Voo* oo"o«Bin
noo ooococp
O — OJ 3 C3 •» f-
81
-------
-------
ATTACHMENT 12
SLABSTOCK FOAM MODEL PLANT COSTS FOR FORCED COOLING
page
Model plant costs 12-2
Description of costs for Forced Cooling + Chem Alts 12-3
-------
o o
or or
II
or or
88s ggsag
n 9 40 O A N w
P Pi 5"
•> 5 « 01 o
goo o o o B n
n «• o <5 <•» a »
» •> •> S oi MK
*" 9 *" 2 2
KM as?
f8« 8*882
55 ft** "
o o o n
n £- B N
n o 01 r*
of
or
2S8S
CT 0 01 f.
or
or
o o o'oi « a
2**5S 08
"* »
o n i
of — a* '
I
1
or or
or or
fo t»«f Von --•
g ss ass *
or a l» «» «»
on « o CT *-
|S aga -
o •> o o o « « n
SSM igs.ss
i"8 S So"
O « 9 «
0 r* v 01
n 0 01 K
or
of
CD O O O «D O O M) *»
r> •» CM o *-€>*• rt r
5" *"a 2' = ""0<
g |S asa
rt *» oi o E • 2 '
n a » « oi •>'
3 S3 2s;
«* ?«» 5 «»s
I
o
o
Gl
8
O
1C
o
or or
o
s
i'g
or or
«»*»
or or
or or
fSS
fgS gggSol
94 N, «B O W *- **
*S a la 5"
•» *» «»
KS
18* iiISS
*"8"S **
S|SR.
S or
o o • n
S ^ <6 01
0 0 OJ ^
or or
s ia' isft'
8*R sss§l
S IS fSi* "
o'o o o o o
-~- — " o o
• K 8 oi
<9 O 01 K.
or or
S£88
S o oj r.
IQ «" —' ~"
S «»«* o
*•
ssg; sssss
to n w>
or or
5 5 §58
O
s:
o <
§
o
5
s 3
OR
C
dDf
OSTS F
FORCED CO
ENT (VtDf I
z fc &
2 2 w
1 § I
id i
I i
IA
I
'o o
"
sg
8" iff cf of*
4» « 9 10 4*
|°S |§SS?
o" «f of o" g
SS88
« o««^
?OO"* 09*-IO^
won s«*«>;
n ooi
•» n *» » •»
?o o » a> o «- »
•» o s; s «» » N n a CM »
NT
hased equipment
-------
DESCRIPTION OF COSTS FOR FORCED COOLING PLUS CHEMICAL
ALTERNATIVES FOR REGULATORY ALTERNATIVE 2
It was assumed that the total elimination of HAP ABA
(regulatory alternative 2) could not be achieved using forced
cooloing. This assumption was made due to the many doubts within
the industry that low density, low IFD foams of acceptable
quality can be made by forced cooling without any ABA. However,
it was assumed that these foam grades could be produced using the
combination of forced cooling and chemical alternatives. The
capital costs, capital recovery, and other indirect annual costs
for this combination were simply the sum of the capital costs of
forced cooling and chemical alternatives.
For regulatory alternative 2, it was assumed that forced
cooling and chemical alternatives would be used simultaneously to
make the low-density, low-IFD foam grades. This resulted in two
differences in the annual cost from the MACT floor and regulatory-
alternative 1 costs. One is the additional material cost of
using chemical alternatives for the low-density, low-IFD foam
grades, which is shown below.
Chemical Alternative Costs for Selected Grades when used with
forced cooling to meet the requirements of Regulatory
Alternative 2
Model
Plant
1
2
3
4
5
Foam Grades
Produced using
Chem Alts
0930, 1010,
1015
0930, 1010,
1015
0930, 1010
0930, 1020
0930, 1020
Baseline
Chemical
Costs
($/yr)
$248,165
$744,495
$1,405,005
$1,508,977
$1,768,809
Chem Alts
Chemical
Costs
($/yr)
$253,479
$760,438
$1,433,154
$1,542,486
$1,807,781
Incremental
Annual
Materials
Costs
($/yr)
$5,314
$15,943
$28,149
$33,509
$38,972
-------
fd Xj? TnCOTDOTdtCd Environmental Consulting and Research
MEMORANDUM
Date: September 24, 1996
Subject: Development of Equation to Calculate Auxiliary Blowing
Agent; Formulation Limitation.
From: . Phil Norwood, EC/RjN
Steve Fudge, EC/R
To: David Svendsgaard, EPA/OAQPS/ESD/OCG
The purpose of this memorandum is to discuss the development
of an equation to calculate the hazardous air pollutant (HAP) •
auxiliary blowing agent (ABA) formulation limitations for the
National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Flexible Polyurethane Foam Production. This memorandum is
separated into two sections. The first provides background,.
followed by a discussion of the development and selection of the
equation..
BACKGROUND .
For Flexible Polyurethane Foam NESHAP, the Environmental
Protection Agency (EPA) considered three levels of control for
the reduction of HAPs used as ABAs in the- production of slabstock
foam.1 The maximum achievable control technology (MACT) "floor"
level of control and the first- regulatory alternative consisted
of HAP ABA formulation- limitations, which were used to calculate
an.allowable HAP emissions level based on the product mix. The
second regulatory alternative required' the complete elimination
of HAP ABA.
In the analysis of regulatory alternatives, HAP ABA
formulation limitations for the MACT floor and first regulatory
alternative were presented tabularly. The MACT floor HAP ABA
formulation limitations are shown in Table 1. As discussed in
the regulatory alternatives memorandum, three methods were used
to develop alternatives between the MACT floor and the total
elimination of HAP ABA emissions: (1) extending the MACT floor
grade ranges, (2) basing the limitations on the emission
reductions achieved by the .top three facilities, and
(3) basing the limitations on the reductions believed-achievable
1 Memorandum. Williams, A. and Norwood, P., EC/R
Incorporated, to Svendsgaard, D., U.S. Environmental Protection
Agency. Regulatory Alternatives for New and Existing Sources in
the Flexible Polyurethane Foam Industry. June 17, 1996.
3721-D University Drive • Duriiam, North Carolina 27707
Telephone: (919) 493-6099 • Fax: (919) 493-6393
-------
TABLE 1. EXISTING SOURCE MACT FLOOR HAP ABA
FORMULATION LIMITATIONS
HAP A
Formula
Limitati
parts AB
hundred
polyc
IFD
BA
tion
ons -
A per
parts
A
0-15
16-20
21-25
26-30
31+
Density ranges (pounds per cubic foot)
0-
0.95
12
10
9
6
5
0.96-
1.05
1.06-
1.15
11
8
7
4
1.16-
1.40
6
4
3
2
1
1.41+
2
2
0
by carbon adsorption. The limitations achieved by each of these
methods were similar, as were the predicted emission reductions
for a representative facility. This led the EPA to consider
these as a single "intermediate" level of control. The EPA
subsequently selected this intermediate level of control for
proposal. The HAP ABA formulation limitations generated by the
extended range method are shown in Table 2. The "top three
facility" limitations are shown in Table 3. Due to the
TABLE 2. HAP ABA FORMULATION LIMITATIONS BASED
ON EXTENDED GRADE GROUPS
Part
per h
pa
po.
IFD
s ABA
undred
rts
Lyol
0-20
21-25
26+
Density ranges (pounds per cubic
foot)
0-
0.95
0.96-
1.05
1.06-
1.15
8
7
5
4
1.16-
1.40
4
1
1.41+
2
0
-------
TABLE 3. HAP ABA FORMULATION LIMITATIONS BASED
ON THREE BEST PERFORMING FOAM FACILITIES
Emissions -
parts ABA
per ^undred
parts
polyol
IFD
0-15
16-20
21-25
26-30
31+
Density ranges (pounds per cubic
foot )
0-
0.95
0.96- 1.06-
1.05 1.15
8
7
6
4
6
5
3
1
1.16-
1.40
4
3
2
0.5
1.41+
1
0
similarities between the limitations created by the top three
facilities and carbon adsorption approaches, the table created by
the carbon adsorption emission reduction was not considered in
subsequent analyses.
<„
During the presumptive MACT process, concern was expressed
by the foam industry that the use of this table could result in
some potentially damaging consequences.2 The concern was
related to the production of grades "on the border" of a foam
grade grouping. For instance, if a foam was poured as a 1.15
pound per cubic foot (pcf) density and a 23 pound indentation
force deflection (IFD) , the HAP ABA formulation in Table 2 is 7
parts HAP ABA per hundred parts polyol (pph) . However, if the
core density of the actual foam was 1.17 pcf, the formulation
limit that would be used in the allowable emissions calculation
would be 4 pph. This significant drop would make compliance
difficult. Therefore, the industry suggested that the EPA
attempt to develop an equation that eliminates the large drops in
HAP ABA formulation limitations across the foam grade groupings
2 Memorandum. Williams, A., and Norwood, P., EC/R
Incorporated, to Svendsgaard, D., U.S. Environmental Protection
Agency. Summary of the August 22, 1995 Flexible Polyurethane
Foam Production Presumptive MACT (P-MACT) Roundtable Meeting.
September 27, 1996.
-------
in the table.3 The EPA agreed that an equation would be
preferable to the table, since an equation would be more user-
friendly and would provide a more continuous and logical
relationship between foam grades and HAP ABA limitations. This
memorandum reports on the development of such an equation.
DEVELOPMENT AND SELECTION OF THE EQUATION
The established goal was that the formulation limitations
calculated using an equation correspond to the formulation
limitations in one of the intermediate level HAP ABA formulation
limitation tables (Tables 2 and 3), while "smoothing" the
transition across foam grade groupings. Instead of using the
actual raw data, a data set was created containing foam grades
and the corresponding formulation limitations from the table.
This data was then input into the SAS® REG procedure with a list
of eight variables, all using either the IFD or density (DEN).
These variables are shown in Table 4.
TABLE 4. VARIABLES USED IN DEVELOPMENT OF HAP ABA EQUATION
IFD
DEN
I/IFD
1/DEN
IFD*DEN
IFD/DEN
DEN/IFD
1/(IFD*DEN)
The SAS REG procedure fits linear regression models by
least-squares. Subsets of independent variables that "best"
predict the dependent variable can be determined by various
model-selection methods. Two model-selection methods were used
to produce equations I and 2 from the extended range table
(Table 2). Those methods are the forward-selection and the
stepwise-selection.
The forward-selection technique begins with no variables in
the model. For each of the independent variables, F statistics
are calculated that reflect the variable's contribution to the
model if it is included. The p-values for these F statistics are
compared to a preset significance level, SLENTRY. If no F
statistic has a significance level greater than SLENTRY, then the
3 Letter from Sullivan, D., Hickory Springs Manufacturing
Company, to Norwood, P., EC/R Incorporated. Status of the MACT
floor for auxiliary blowing agents. July 21, 1995.
-------
method stops. Otherwise, the variable with the largest F
statistic is added to the model.
The step-wise method is like the forward method except that
variables already in the model do not necessarily stay there.
Variables are added to the model using the same procedure as
outlined above. After a variable is added, however, the stepwise
method looks at all the variables already included in the model
and deletes any variable that does not produce an F statistic
significant at«the preset value of SLSTAY. Only after this check
is made and any necessary deletions accomplished can another
variable be added to the model. The process ends when none of
the variables outside the model has an F statistic significant at
the SLENTRY level and every variable in the model is significant
at the SLSTAY level, or when the variable to be added to the
model is the one just deleted.
= -0.25(IFD) -I9.l(-_.) - 16 .2 (DEN] -7.56(--) +36.5
X/ZSlV
Equation (1)
ABAliaic = -Q.aS(IFD) + Q.0089(IFD)2 - 41.0K—|-) + 1* . 01 (-i_T) + 0.104(DEN)(IFD) +5.14
DEN
Equation (2)
In addition, Equation 3 was created from the table generated from
the three best performing facilities (Table 3) using the step-
wise method.
ABAliail: = -0.345 (IFD) -12.9(—-) -16.6 (DEN) -6.58 (DEN) + 0 .118 (IFD) (DEN) +34.4
Equation (3)
As discussed in the regulatory alternatives memorandum, the
limitations were created by applying a percentage reduction to a
set of baseline formulation values. Using this approach, an two-
equation approach was also created. The first equation
calculated the baseline formulation value for the grade, which
was then multiplied by the percentage reduction, determined by
the second equation. These equations are included as Equations 4
and 5.
-------
* -0.955(JF£>) - 33.1(DEN) - 8.35( —-J + 0.482(JF£) (DEN) + 64.7
DEN
Equation (4)
l-(-1521.27(r>£N) + 554 .79 (DEN) a - 345 .17 (——) + 0.199(IFD) (DEN) +1369.47
DEN
Equation (5)
SELECTION OF EQUATION
Three primary criteria were used to select the equation to
be included in the proposed regulation: (1) agreement with the ~
emission reduction achieved by the intermediate level of control
HAP limitation table (s) for a representative facility,
(2) performance across all foam grades, and (3) simplicity of the
equation. Table 5 compares the residual HAP limitations and HAP
ABA emission reductions for the equations (and intermediate
tables), using the representative slabstock foam plant from EPA's
Cost Report.4 As can be seen in the table, the HAP ABA emission
reductions for all equations are comparable to those achieved by
the intermediate tables. Therefore, all meet the first criteria.
Figures 1 through 4 show the performance of the equations
across a range of foam grades. As can be seen from Figures 1 and
3, Equations 1 and 3 have perform well across all foam grades.
This means that the HAP ABA limitation gradually and smoothly
decreases with increasing density and IFD. As seen in Figures 2
and 4, Equation 2 and the two equation approach (Equations 4 and
5) did not perform satisfactorily.
The application of the final criteria, simplicity, to
Equations 1 and 3, led to the selection of Equation 1 due to the
number of variables. Therefore, Equation 1 is used in the
proposed rule to calculate HAP ABA formulation limitations.
However, it will be necessary to clarify that all negative values
would be set equal to zero.
4 Flexible Polyurethane Foam Emission Reduction
Technologies Cost Analysis. EPA-453/R-95-011. U.S.
Environmental Protection Agency, Research Triangle Park, North
Carolina. September 1996.
-------
H
1
Q.
s ~
UJ
(A
UJ
CC
Q.
UJ
OC
Q
UJ
_J
Q.
Q.
<
Z
LU
i
w
LU
CC
O
I
o
UJ
U.
O
Z
O
CO
CC
<
Q.
O
O
in
CD
(A
'^1
3 «
LU *
• CO
CL §
£ HI
O
2 CM
I §
3 I
C 3
o a
7 LU
CO
3 ,_
I I
u_ tg
g I
< ^
a.
I CO .»
o"S
H- i-
"•i
+J
s s
8 s
s- °
CD
CC
CO
f\
I)
in
in
^>
in
8
o>
/-
^x
1
r--
CO
CO
00
00
o
q
o
0
CO
^
CO
CO
CO
in
q
in
0
in
CO
s.
CD
CO
3
o
I
CO
CO
in
CO
^-
8
q
i
m
in
CO
CO
CO
%
T—
§
CO
CM
^I
CO
T—
8
T-
8
CO
CM
CO
CM
T_
8
CM
^—
CM
*•
f
CM
T_
8
CO
i
*-
^
o
in
d
^_
§
CO
o
o
o
o
in
d
o
§
*
T~
0
CM
T-
,-
O
s
in
i
o
o
o
,-
o
c
in
|
o
0
o
o
o
o
in
i
o
o
0
o
o
§
CO
i
o
o
o
o
o
§
I*-;
1
o
T1"
o
T-
o
a
CO
OC
o
0
o
,-
o
o
CO
CO
o
s
o
o
o
o
o
§
CO
I
0
o
o
,-
o
8
o>
i
o
o
o
o
o
9
O)
I
o
o
o
o
o
a
A
o
CM
A
vP
fc
h»
A
•8
CO
§
h.
v^
CO
VS-
js,.
CO
^5
CO
vO
CD
_c
"55
< %
s
-------
q
evi
00
*" O T-
c >
JO o to
I I
OP «
I
0)
§
i !
(D <
C <
O 0.
0> * N
C & T-
O c
fl I
'c «^
5 -f^
< rf **
CD as.
a
M
3
O)
OOOOOOOOOOOOOOOOOOOOOOO
ooooooooooooooooooooooo
ooooooooooooooooooooooo
ooooooooooooooooooooooo
T-t-T-T-ooooooooooooooaoooo
nOCMCMClT-T-OOOOOOOOOOOOOOOO
nomncMeviT-r-^oooooooooooooo
2
0>
N
0)
CO
2
CO
01
,3
§
I
"5
o>
e
8
(0
CO
o
el
o
a
o
I
2
"5
w
.0
"5
1
w"
o
o
!
M
_c
o
E
o
in
-------
CM
C
O
«
3
o-
0>
(0
W
o
(0
3
O
c
2
E
CD
CM
£
O)
O
oi
0)
CO
« ^
JL
5
l?w
"" S
o o
< &
. a
(TO
5«
o o
Q.
!O CO CM CM •<- i-
n n CM CM CM T-
I I I I I I I I I
OOOOT-t-f-T~OOOOT-i-CMCM
I I I I I I I I I
OOOOOr-T-OOOOOi-T-CMCM
I I I I I I I I
I I I I
covnin^tmcocMCM
•»- CM CM CO
o
c
s
m
v>
o
s
(Ocotnin^-tmmcMCMCM
CM CM CM CO
rvcooioio^t^nnojcMcveM
CM io^^-^-^-'t^>^t
-------
10
o
cvi
OJ
CO
c
JO
«
3
C7
0)
(0
as
3
10
O
CO
CP
Q>
C
.o
1*3
CB
m
a.
CO
2
3
O)
O T-
"5 to
a. ^
n
CB
a
o
o
O
a.
ooooooooooooooooooooooo
ooooooooooooooooooooooo
ooooooooooooooooooooooo
ooooooooooooooooooooooo.
i-7-*-OOOOOOOOOOOOOOOOOOOO
CMCMCMOIi-T-T-i-OOOOOOOO O O O O O O't<±*
COmCMCMCMCMi-t-T-OOOOOOOOOOO O O O
<
a.
r
a
c
o
«s
2
il
< a
m
01
e
a
n
o o
a.
10
§«
o
s
to
a
m
o
a
o
"5
a>
o
c
O.\O
to
I
to
«--i- oob.
0)
to
o
a
tr
a>
to"
o
o
3
O
a
o
E
o
to
-------
11
in
T3
c
(0
*•
w
c
.2
«55
(8
3
CT
O
)
w
"5
M
2
•v
c
.2
(3
3
OP
O
c
o
1
AS
E
<
CD
$
^<
I
•
*•
0
^
3
O)
il
o
CM
•
^"
«
CO
^J
N
»~
« (o
=• •
o *•
15 m
a ,j
S
a
a
2 «
o ^
»• t"
^m
9
a.
<•
I «
< .
a. ^
£
£
£ CM
£ *-
C
JO
+&
S
"5 9+*
i o '
il
< a
» 3
2? »e
T w^
•c w *"
0
a
n
•Q
§0)
od
a
^^
>,
tf
0)
g*.
Do
in m in
»fn fn
(D «D
^ T- ^
O O O
O O O
o o o
o o o
BO CO CM
^ ^ CO
in in «t
CD
K CO CO
in w TJ-
m m TJ-
o evj *
*• ^ i—
inininminininininininininininininininin
•^ f^ «w_ i^_ |^ i^ «M **> 0n art flrt rtN fl^ fl> n\ /T\ ^^ ^^ ^^ ^>
p* r^ r"* P* p* r"» «0 00 *** «u w0 w/ w« wJ OJ w3 ^J vJ ^ ^
f-CMCMCMCMcocococo^t^t^-^ttninincocotoco
OOOOOOOOT-i-T-CMCMCMCMCOOOCOCO<4-
OOOOOOOOOOOOOOOOOO^-i-
oooooooooooooooooooo
COCOCOCMCMCMCMCMT-v-T*^— T-OOOOOOO
^•^t^COCOCOCMCMCMCMi-'t-i-'t-OOOOOO
ininOOOOO
^•^•COCOCOCOCMCMCMCMi-T-^-T-OOOOOO
^•^•eOCOCOCOCMCMCMCMT--r-^i-OOOOOO
COCOOCM*C0COOCM*tOCOOCM*
£
CO
0)
To
Q)
S
CO
O)
o
c
of
5
2
€0
?
•**
g;
CO
o
3=
2
E
Q_
15
3
•D
CO
£
o
n
(0
S1
c
2
"5
>.
m
c
JO
"5
{jr
Q
tn
0
U
c
2
M
CI
0
E
o
in
^
-------
TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1. REPORT NO.
EPA-453/R-96-009a
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Hazardous Air Pollutant Emissions from the Production of
Flexible Polyurethane Foam - Supplementary Information
Document for Proposed Standards
5. REPORT DATE
September 1996
6. PERFORMING ORGANIZATION CODE
7. AUTHOR®
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Emission Standards Division (Mail Drop 13)
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANTNO.
68-D6-0008
12. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This document contains memoranda providing rationale and information used to develop the Flexible
Polyurethane Foam Production proposal package. The data and information contained in these
memoranda were obtained through literature searches, industry meetings, plant visits, and replies to
section 114 questionnaires sent to industry.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Fidd/Group
Air Pollution
Hazardous air pollutants
Emission reduction
Flexible Polyurethane Foam
Hazardous air pollutants
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (Report)
Unclassified
21. NO. OF PAGES
213
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rer. 4-77) PREVIOUS EDITION IS OBSOLETE
-------
us
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
------- |