EPA-453/R-95-011
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-453/R-95-011
September 1996
Air
&EPA
Flexible Polyurethane Foam
Emission Reduction Technologies
Cost Analysis
ENVIRONMENTAL
PROTECTION
\ AGENCY
DALLAS, TEXAS
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FLEXIBLE POLYURETHANE FOAM
EMISSION REDUCTION TECHNOLOGIES
COST ANALYSIS
ct
a,
Emission Standards Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
- - Office of Air and Radiation
-" Office of Air Quality Planning and Standards
M Research Triangle Park, North Carolina 27711
O September 1996
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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.
11
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ENVIRONMENTAL PROTECTION AGENCY
Flexible Polyurethane Foam Emission Reduction
Technologies Cost Analysis
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
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TABLE OF CONTENTS
Page
LIST OF TABLES vi
LIST OF FIGURES ...... ........ viii
1.0 INTRODUCTION 1-1
1.1 PURPOSE OF DOCUMENT 1-1
1.2 DOCUMENT CONTENTS ...... 1-2
2 .0 BACKGROUND 2-1
2.1 INDUSTRY DESCRIPTION 2-1
2.2 FOAM GRADES AND APPLICATIONS 2-2
2.3 CHEMISTRY OF POLYURETHANE FOAM PRODUCTION 2-3
2.4 BLOWING AGENTS ....... 2-4
2.5 FOAM QUALITY MEASUREMENTS .... ...2-6
2.6 CURRENT ENVIRONMENTAL RELEASES ..........2-6
2.7 REFERENCES FOR CHAPTER 2.0 2-9
3.0 REPRESENTATIVE FACILITIES 3-1
3.1 DEVELOPMENT OF REPRESENTATIVE FACILITY PARAMETERS . 3-1
3.2 DEVELOPMENT OF REPRESENTATIVE FACILITY COSTS . . .3-1
3.3 REFERENCES FOR CHAPTER 3.0 ...... 3-8
4.0 EMISSION REDUCTION TECHNOLOGIES AND COSTS: MOLDED
FOAM 4-1
4.1 ALTERNATIVES TO HAP MIXHEAD FLUSHES 4-1
4.1.1 Non-HAP Mixhead Flushes 4-2
4.1.2 High-Pressure (HP) Mixheads 4-3
4.1.3 "Self-Cleaning" Mixhead ......... 4-6
4.1.4 Solvent Recovery Systems ... 4-9
4.2 ALTERNATIVE MOLD RELEASE AGENTS 4-11
4.2.1 Reduced-VOC Mold Release Agents .... 4-11
4.2.2 Naphtha-based Release Agents ..... 4-12
4.2.3 Water-based release agents ...... 4-12
4.3 ALTERNATIVE ADHESIVES 4-17
4.3.1 Hot-Melt Adhesives 4-17
4.3.2 Water-Based Adhesives ......... 4-18
4.3.3 Hydrofuse 4-21
4.4 REFERENCES FOR CHAPTER 4.0 4-23
IV
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TABLE OF CONTENTS
(continued)
5.0 EMISSION REDUCTION TECHNOLOGIES AND COSTS: SLABSTOCK
FOAM 5-1
5.1 ALTERNATIVES TO METHYLENE CHLORIDE AS AN ABA . . . 5-1
5.1.1 Acetone or hydrocarbons with 5 carbons
or less as ABA 5-2
5.1.2 Liquid CO2 as an ABA 5-5
5.1.3 Foaming in a Controlled Environment . . . 5-6
5.1.3.1 Variable Pressure Foaming (VPF) . . 5-8
5.1.3.2 Controlled Environment Foaming
(CEF) 5-9
5.1.4 Forced-Cooling 5-13
5.1.5 Chemical Modifications 5-15
5.2 EQUIPMENT CLEANERS 5-18
5.2.1 Steam Cleaning 5-18
5.2.2 Non-HAP Cleaners 5-21
5.3 REFERENCES FOR CHAPTER 5.0 5-24
6.0 SUMMARY 6-1
6 .1 MOLDED FOAM 6-1
6.2 SLABSTOCK FOAM 6-4
6.3 REFERENCES FOR CHAPTER 6.0 6-7
v
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LIST OF TABLES
TABLE 2-1 SUMMARY OF HAP EMISSIONS FROM FLEXIBLE
POLYURETHANE FOAM PRODUCTION - 1992 2-7
TABLE 3-1 REPRESENTATIVE SLABSTOCK FACILITY PARAMETERS . . .3-2
TABLE 3-2 FORMULATION INFORMATION FOR THE
REPRESENTATIVE SLABSTOCK FACILITY 3-3
TABLE 3-3 REPRESENTATIVE MOLDED FACILITY PARAMETERS ..... 3-4
TABLE 3-4 CONTRIBUTIONS TO TOTAL CAPITAL INVESTMENT 3-6
TABLE 3-5 CONTRIBUTIONS TO TOTAL ANNUAL COST . . .. . . . .3-7
TABLE 4-1 REPRESENTATIVE FACILITY COSTS FOR NON-HAP
MIXHEAD FLUSHES ........... 4-4
TABLE 4-2 REPRESENTATIVE FACILITY COSTS FOR HIGH
PRESSURE MIXHEADS 4-7
TABLE 4-3 REPRESENTATIVE FACILITY COSTS FOR
SELF-CLEANING MIXHEADS 4-8
TABLE 4-4 REPRESENTATIVE FACILITY COSTS FOR
SOLVENT RECOVERY SYSTEMS ............ 4-10
TABLE 4-5 REPRESENTATIVE FACILITY COSTS FOR
REDUCED-VOC MOLD RELEASE AGENTS 4-13
TABLE 4-6 REPRESENTATIVE FACILITY COSTS FOR
NAPHTHA-BASED MOLD RELEASE AGENTS . 4-14
TABLE 4-7 REPRESENTATIVE FACILITY COSTS FOR
WATER-BASED MOLD RELEASE AGENTS ......... 4-16
TABLE 4-8 REPRESENTATIVE FACILITY COSTS FOR
HOT-MELT ADHESIVES 4-19
TABLE 4-9 REPRESENTATIVE FACILITY COSTS FOR
WATER-BASED ADHESIVES ... 4-20
TABLE 4-10 REPRESENTATIVE FACILITY COSTS FOR
HYDROFUSE ADHESIVE ..... ... 4-22
TABLE 5-1 REPRESENTATIVE FACILITY COSTS FOR ACETONE
AS AN ABA 5-4
TABLE 5-2 REPRESENTATIVE FACILITY COSTS FOR CARDIO™ . . . .5-7
TABLE 5-3 REPRESENTATIVE FACILITY COSTS FOR
VARIABLE PRESSURE FOAMING ..... 5-10
VI
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LIST OF TABLES
(continued)
TABLE 5-4 REPRESENTATIVE FACILITY COSTS FOR
CONTROLLED ENVIRONMENT FOAMING 5-12
TABLE 5-5 REPRESENTATIVE FACILITY COSTS FOR
ENVIRO-CURE® 5-16
TABLE 5-6 REPRESENTATIVE FACILITY CHEMICAL COSTS FOR
CHEMICAL MODIFICATIONS 5-19
TABLE 5-7 REPRESENTATIVE FACILITY COSTS FOR
CHEMICAL MODIFICATIONS 5-20
TABLE 5-8 REPRESENTATIVE FACILITY COSTS FOR
NON-HAP CLEANERS 5-23
TABLE 6-1 SUMMARY OF REPRESENTATIVE FACILITY COSTS FOR
MOLDED FOAM EMISSION REDUCTION TECHNOLOGIES . ... 6-3
TABLE 6-2 SUMMARY OF REPRESENTATIVE FACILITY COSTS
FOR SLABSTOCK FOAM EMISSION REDUCTION
TECHNOLOGIES 6-4
Vll
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LIST OF FIGURES
FIGURE 2-1 Polyurethane Foam Production Reactions . . . .2-4
Vlll
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1.0 INTRODUCTION
1.1 PURPOSE OF DOCUMENT
This document describes the costs of hazardous air pollutant
(HAP) emission reduction technologies for flexible polyurethane
foam production facilities. The U.S. Environmental Protection
Agency (EPA) reviewed information from the information collection
request (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. The EPA looked at
many possible technologies, but narrowed this report to include
only technologies that are currently being used, or those under
investigation that are generally considered to be promising. The
EPA also realizes that there are many technologies being
developed that may later prove to be applicable to this industry.
In no way does the EPA intend this document to be an endorsement
of any one technology. The intent of this report is to examine
some proven emission reduction technologies for this industry,
and some of the costs associated with the installation, and use,
of these technologies. Information on cost and emission
reduction potential, as well as process and operational
information, was compiled for each technology. Information was
collected from chemical manufacturers, product vendors, trade
associations, foam producers, and other sources. The majority of
the information was gathered by telephone communication.
Once the information was collected, it was analyzed and
applied to "representative" facilities to evaluate the capital
and operational costs, as well as the emission reduction and cost
effectiveness, of each alternative. In several instances, the
information provided was insufficient to permit an analysis of
the total capital investment and total annual costs. Therefore,
certain assumptions were necessary to allow the calculation of
the representative facility costs. Where possible, assumptions
1-1
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were based on statements or partial information from industry and
other contacts.
1.2 DOCUMENT CONTENTS
The comments of the vendors, manufacturers, and foam
producers who had contributed to the original analysis were
collected, and these have been incorporated into this document.
A preliminary draft of this document was distributed industry-
wide for review. Any comments received were evaluated and
incorporated where appropriate. Chapter 2 provides background on
the industry. Chapter 3 describes the development of
"representative" molded and slabstock facilities, and the
calculation of representative facility costs. Chapters 4 and 5
provide brief descriptions for each technology, along with costs
for the representative facilities. Chapter 6 summarizes the
analysis.
1-2
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2.0 BACKGROUND
2.1 INDUSTRY DESCRIPTION
The term "polyurethane" is applied to a general class of
polymers in which molecular chain segments are bound together
with urethane linkages. Polyurethanes are used to produce an
extremely wide range of products, including solid plastics,
adhesives, coatings, rigid foams, and flexible foams. Flexible
foams represent by far the largest application for polyurethanes,
accounting for over half of the total U.S. production of
polyurethanes.-1 Flexible polyurethane foam is used in
furniture, bedding, automobiles, packaging materials, and carpet
underlay.2 The flexible polyurethane foam industry can be
divided into two major segments: slabstock foam production and
molded foam production. Slabstock foam is produced in large
"buns" that range in size from 100 cubic feet to over 5000 cubic
feet. After they cure, the buns are cut, glued, or otherwise
"fabricated" into the particular shapes and sizes for the desired
end-use. Fabrication operations may be carried out by the
slabstock plant itself, or by the foam purchaser.
Another type of on-site operation at some slabstock
facilities is rebond. Rebond is a process that combines ground
scrap foam pieces and toluene diisocyanate (TDI) under steam and
pressure to create a bonded material. This material is
predominantly used to produce carpet underlay. The largest uses
of slabstock foams are in furniture, carpet underlay, automotive,
and bedding.3
In molded foam production, the foam polymerization reaction
is carried out in a mold in the shape of the desired product.
This minimizes the need for fabricating the foam, although
shaping and gluing operations may still be required. Molded foam
is used primarily in the transportation market for car seats,
cushions, and energy-absorbing panels; however, it is also used
for novelty items, in office furniture, and in medical
products.4
2-1
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Total slabstock foam production in 1992 was approximately
550,000 tons. At the end of 1992, there were 25 companies
engaged in slabstock foam production, operating about 78 foam
plants. Three large companies account for over half of the total
U.S. production.
The production of molded foam is more difficult to quantify,
because there are many small plants. The Society of the Plastics
Industry, Inc. (SPI) reported production of molded foam at
215,000 tons in 1989. A recent survey of the foam industry by
the EPA's Emission Standards Division (BSD) identified 49 plants
producing molded foam. However, these plants accounted for only
about half of the molded foam production reported by SPI in 1989.
Estimates of the total number of plants producing molded foam
range up to 200. The molded producers identified tended to be
either quite large, or quite small. In the EPA/ESD survey,
almost half of the 49 plants surveyed reported production rates
less than 500 tons per year.
2.2 FOAM GRADES AND APPLICATIONS
Flexible polyurethane foam is produced in a wide range of
grades which are usually 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.5
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.
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. Indention force deflection is expressed in pounds (per 50
square inches), and can range from 10 pounds to over 100 pounds.
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
2-2
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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 padding, and other heavy-duty
applications.
2.3 CHEMISTRY OF POLYURETHANE FOAM PRODUCTION
Polyurethanes are made by reacting a polyol with a
diisocyanate. For slabstock foam production, the polyol is
typically a polyester or a polyether with two or more hydroxyl
groups, and the diisocyanate is usually a mixture of 2,4- and
2,6- isomers of toluene diisocyanate (TDI), with the ratio being
80 percent 2,4- to 20 percent 2,6-. Molded foam producers
frequently use methylene diphenyl diisocyanate (MDI) rather than
TDI.
Polyurethane foams are made by adding water to the polyol
and diisocyanate mixture. Once the ingredients are mixed, two
main polymerization reactions occur. 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 (C02) . The amine then reacts with
another isocyanate to yield a substituted urea linkage. These
reactions are illustrated in Figure 2-1.
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. Catalysts balance the
isocyanate/water and isocyanate/polyol reactions, and assist in
driving the polymerization reaction to completion.
The C02 formed in the initial reaction acts as the "blowing
agent" and causes the bubbles to expand. The bubbles eventually
come into close contact, forming a network of cells separated by
2-3
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{R}-N=C=O + H2O -> {R}-NH2
Isocyanate
H H
{R}-NH0 + {R2}-N=C=0 -» {R}~N, ,N~{R2}
/ \c/
O
Reactions of isocyanate with water
O
{R}-N=C=0 + {P}-OH ->• (R)-N-C
Isocyanate Polyol
Reaction of isocyanate with polyol
X0-{P}
Figure 2-1. Polyurethane Foam Production Reactions
thin membranes. 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."
The more water added and CO2 formed, the more expanded the
polymer network, and the lower the resultant density. However,
the reaction of isocyanate with water is very exothermic. The
addition of too much water can cause the foam to scorch or even
auto-ignite.
The final polymer is composed of the urethane and urea
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.
The amount of each ingredient used in a foam formulation
varies, depending on the grade of foam desired. Foam
formulations are generally expressed by the number of parts (by
weight) of each component used, per 100 parts polyol.
2.4 BLOWING AGENTS
The gas which expands the polyurethane polymer to produce a
foam is termed a "blowing agent." As noted in the previous
2-4
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section, one result of the isocyanate-water reaction is the
liberation of C02 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 C02 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 C02 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 are more widely used in the
production of slabstock foams than in the production of molded
foams. The amount of ABA required depends on the grade of foam
being produced and the ABA used. Auxiliary blowing agents 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.
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 completely phased
out its use. Methylene chloride, a listed HAP, has replaced
CFC-11 as the principal ABA. The consumption of methylene
chloride for slabstock ABA applications in 1992 was approximately
2-5
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14,500 tons. The second largest volume ABA in 1992 was
1,1,1-trichloroethane (TCA), at approximately 2,000 tons. Since
the role of the ABA is simply to vaporize and expand the foam, it
does not directly participate in the polyurethane reaction.
Therefore, all of the ABA that is added eventually is emitted.
Releases of HAP ABA's to the atmosphere are substantial (over
16, 800 tons in 1992) .
2.5 FOAM QUALITY MEASUREMENTS
In their evaluations of technologies to reduce or eliminate
blowing agents, foam producers are sensitive to any potential
degradation in foam quality. A number of physical properties are
measured as indicators of foam quality. These include
resilience, hysteresis, dynamic fatigue, air flow, tensile
strength, elongation, compression set, and tear strength. These
properties are determined using American Society for Testing and
Materials (ASTM) Standard Test Methods for Flexible Cellular
Materials - Slab, Bonded, and Molded Urethane Foams (D 3574-91) .
2.6 CURRENT ENVIRONMENTAL RELEASES
Emissions to the atmosphere constitute the major
environmental release from flexible polyurethane foam
manufacturing. The bulk of emissions from the industry result
from the use of ABAs, mainly in the manufacture of slabstock
foam. However, substantial emissions also result from the use of
organic solvents in adhesives and equipment cleaning operations.
Table 2-1 gives a summary of emissions from different operations
in slabstock and molded foam production. The emissions reported
for hazardous air pollutants in Table 2-1 are based on a recent
survey of these emissions by the EPA's Emission Standards
Division.6'7
There are no process wastewater discharges from this
industry. The water used in the foam reaction is entirely
consumed in that reaction. Water is used in some cases for non-
contact cooling of foam reactants, but no discharges are reported
from these systems.
Solid waste generated by foam production processes is
minimized, because most scrap is used in rebond operations. Foam
2-6
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TABLE 2-1. SUMMARY OF HAP EMISSIONS FROM FLEXIBLE
POLYURETHANE FOAM PRODUCTION - 1992a
Emission Source
Total
emissions
(tons/yr)
Primary chemicals
Slabstock foam
Blowing agent
Fabrication
Chemical storage
and handling
Rebond operations
Slabstock foam
total
Methylene chloride,
16,968 methyl chloroform
1,401 Methyl chloroform
49 Methylene chloride, TDI
11 Methylene chloride, TDI
18,429
Molded foam
Equipment flushing
and cleaning
Mold release
Chemical storage
and handling
In-mold coating
Foam repair
Other
Molded foam
total
205 Methylene chloride
8 Methylene chloride
12 MDI, TDI
6 MEK, Toluene
27 Methyl chloroform
10 MDI, methylene chloride
268
INDUSTRY TOTAL
18,697
Data Source: Non-Confidential Summary of Flexible Polyurethane Foam
Information Collection Request (ICR) Data, prepared by EC/R Inc.
February 10, 1995.
2-7
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production lines occasionally produce bad batches, which are
unsuitable even for rebonding. If this material contains free,
unreacted TDI, it must be treated as a hazardous waste under the
Resource Conservation and Recovery Act (RCRA). In addition, some
solvent waste subject to RCRA is produced from equipment cleaning
operations. These wastes are generally shipped off-site for
treatment or disposal.
Q
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2.7 REFERENCES FOR CHAPTER 2.0
1. SPI. 1990 End-Use Market Survey on the Polyurethane
Industry in the U.S. and Canada. The Society of the
Plastics Industry - Polyurethane Division.
2. Reference 1.
3. Reference 1.
4. Reference 1.
5. Kreter, P.E. 1985. Polyurethane Foam Physical Properties
as a Function of Foam Density. In: Proceedings of the SPI
- 32nd Annual Technical/Marketing Conference. The Society
of the Plastics Industry, Inc., Polyurethanes Div. pp. 129-
133.
6. Norwood, L.P., et al (EC/R Inc.). Summary of Flexible
Polyurethane Foam Information Collection Requests (ICRs).
Presented at a meeting of EPA and the Polyurethane Foam
Association. February 2, 1994.
7. Williams, A. (EC/R Inc.) Updated Estimates of HAP
Emissions from Slabstock Foam Production. Letter to Lou
Peters, Polyurethane Foam Association. February 8, 1994.
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3.0 REPRESENTATIVE FACILITIES
3.1 DEVELOPMENT OF REPRESENTATIVE FACILITY PARAMETERS
One purpose of this analysis was to estimate the impacts of
the targeted emission reduction technologies on any individual
facility. In order to conduct this study, "representative"
slabstock foam and molded foam facilities were developed. The
representative facilities only include those parameters needed to
estimate representative facility costs.
In general, the parameters for the representative facilities
were based on information provided in response to the ICR.1
Where possible, the parameters are averages of the ICR responses
In some instances, assumptions were made based on knowledge
gained during plant visits. In other cases, parameters are based
on detailed information from an individual facility. For the
representative slabstock foam facility, Polyurethane Foam
Association (PFA) members provided input that affected the
representative facility foam formulations. Table 3-1 shows the
representative slabstock foam facility, Table 3-2 shows
formulation information for the representative slabstock foam
facility, and the representative molded foam facility is
described in Table 3-3.
3.2 DEVELOPMENT OF REPRESENTATIVE FACILITY COSTS
There were no specific precedents to follow in the
development of representative facility costs for process
modifications. The OAQPS Control Cost Manual provided general
guidance on the estimation of total capital investment and annual
costs .2
Total capital investment includes three basic elements: (1)
purchased equipment costs, (2) direct installation costs, and
(3) indirect installation costs. Total capital investment may
also include costs for land, working capital, and off-site
facilities. The total annual cost consists of three elements:
(1) direct costs, (2) indirect costs, and (3) recovery credits.
3-1
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TABLE 3-1. REPRESENTATIVE SLABSTOCK FOAM FACILITY PARAMETERS
Value
Basis
OPERATING PARAMETERS
Foam produced
Operating schedule
Number of lines
Speed of line
Line electricity use
MeCl2 used as ABA
MeCl2 used as cleaner
Waste MeCl2 from
cleaning
Amount of foam
fabricated
Amount of adhesive
used for fabrication
HAP content of
adhesive
Number of spray booths
Fabrication operating
schedule
7,500 tons/yr
4 hrs/day actual
pouring
225 days/yr
1 (Maxfoam™)
15 feet/min
120 kW
325 tons/yr
5 tons/yr
2 55-gal
drums/yr
3,520 tons/yr
10,679 gallons
70%
16 hours/day 225
days/yr
ICR average
ICR averages, plant visits
plant visits, ICR
plant visits
provided by foamer
calculated using formulations in Table
3-2
EPA assumption
foamer estimate that 10 percent by
volume of total MeCl2 used as cleaner is
not recoverable
based on a facility that provided
detailed adhesive usage information
based on a facility that provided
detailed usage information
based on a facility that provided
detailed adhesive usage information
plant visits, ICR
plant visits, ICR
COST PARAMETERS
Total chemical cost
ABA-blown chemical
cost
Operating costs
Cost of MeCl2
Disposal cost of waste
MeCl2
Cost of HAP adhesive
$10.9 million/yr calculated from information provided by
PFA chemical alternative informational
work group
calculated from information provided by
PFA chemical alternative informational
work group
calculated using the total chemical
cost and the PFA assumption that 80
percent of total costs are chemical
costs
provided by industry representatives
vendor estimate
$9 .88 million/yr
$2.72 million/yr
$0.40/lb
$800 per
55-gal drum
$8.5/gal
vendor quote
EMISSIONS
MeCl2 from ABA
MeCl2 emissions from
cleaning
HAP emissions from
fabrication
325 tons/yr all used is emitted
4.5 tons/yr 90 percent of used (remainder is waste)
43 tons based on a facility that provided
detailed adhesive usage information
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TABLE 3-2. FORMULATION INFORMATION FOR THE
REPRESENTATIVE SLABSTOCK FOAM FACILITY3
Grade Density
(pcf)
0930
1010
1015
1020
1030
1120
1130
1230
1330
1340
1440
1520
1530
1540
1640
1740
1820
1830
1840
1930
1940
0.9
1.0
1.0
1.0
1.0
1.1
1.1
1.2
1.3
1.3
1.4
1.5
1.5
1.5
1.6
1.7
1.8
1.8
1.8
1.9
1.9
2.0
IFD amount MeCl2
(25%) produced (pph polyol)
(tons/yr) (
30
10
15
20
30
20
30
30
30
40
40
20
30
40
40
40
20
30
40
30
40
>20
TOTALS
440
220
360
230
680
370
170
610
300
110
180
170
510
390
220
170
160
510
570
240
150
740
7,500
10
22
19
14
8
14
7
5
6
2
2
13
6
2
1
1
10
6
1
7
1
0
MeCl2
emitted
'tons/yr)
29.3
32.3
44.4
21.5
34.0
33.3
7.4
20.3
11.0
1.5
2.4
14.2
20.4
5.2
1.5
1.1
10.7
18.7
3.8
11.2
1.0
0.0
325
Assuming 67 percent of foam weight is polyol.
3-3
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TABLE 3-3. REPRESENTATIVE MOLDED FOAM FACILITY PARAMETERS
Value
Basis
OPERATING PARAMETERS
Type of foam products
Foam produced
Number of lines
(carrousels)
Operating schedule
Type of mixheads
Mixhead delivery
MeCl2 used as mixhead
flush
Waste MeCl2
Amount of mold release
agent used
HAP content of mold
release agent
Number of repair
stations
Amount of adhesive
used for foam repair
HAP content of
adhesive
COST PARAMETERS
Cost of MeCl2
Disposal cost of waste
MeCl2
Cost of HAP-based mold
release agent
Cost of Adhesive
EMISSIONS
MeCl2 emissions from
mixhead flush
HAP emissions from
mold release agents
HAP emissions from
foam repair
non-automotive specialty
parts
800 tons/yr
3 total (1 does not use
HAP-based mold release
agents)
2 lines - 8 hrs/day
1 line - 15 hrs/day
240 days/yr
low-pressure
9 to 26 Ibs/min
135 55-gal drums/yr
13 55-gal drums/yr
1,688 gal/yr
75
345 gal/yr
70%
$0.40/lb
$800/
55-gal drum
$4.82/gallon
$8.50 per gallon
37.1 tons/yr
4.6 tons/yr
1.34 tons/yr
ICR and plant visits indicate
these types of facilities were
larger emitters
based on detailed facility data
based on detailed facility data
based on detailed facility data
ICRs
based on discussion with foamer
regarding appropriate throughput
ICR average
foamer estimate that 10 percent
by volume of total MeCl2 used as
cleaner is not recoverable
based on a facility that
provided detailed mold release
agent information
based on a facility that
provided detailed mold release
agent information
site visits, ICRs
based on a facility that
provided detailed adhesive usage
information
based on a facility that
provided detailed adhesive usage
information
Chemical marketing reporter
foamer estimate
vendor quote
vendor quote
90 percent of used (remainder is
waste)
calculated
calculated
3-4
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In the OAQPS manual, most components of the total capital
investment are based on the purchased equipment costs. While the
cost factors in the manual were developed for specific types of
add-on control, the factors for incinerators and carbon adsorbers
were used to estimate the total capital investment of the control
technologies in this evaluation, unless detailed information was
provided.
It was assumed that several items (instrumentation,
foundations and support, insulation for ductwork, painting,
engineering, construction and field expenses, contractor fees, a
performance test, and a model study) would not be included in the
total capital investment, unless specific costs for these items
were provided by the vendor. Therefore, the total capital
investment was calculated as shown in Table 3-4. For each type
of polyurethane foam emission reduction technology, the
information provided by the vendor(s) was evaluated to determine
which of the items shown in Table 3-4 were included in the
information provided, and to determine which additional items
needed to be estimated.
The calculation of the total annual costs was also based on
the OAQPS manual. Table 3-5 shows the items considered in the
calculation of total annual costs. As with the total capital
investment, other contributions to the total annual costs were
determined based on the information provided by vendors and
fearners.
3-5
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TABLE 3-4. CONTRIBUTIONS TO TOTAL CAPITAL INVESTMENT
DESCRIPTION
Cost Factor
Purchased Equipment Costs (PEC)
Equipment
Sales Tax
Freight
Total PEC
Direct Installation Costs (DC)
Handling and erection
Electrical
Piping
Total DC
Indirect Installation Costs (IDC)
Start-up
Contingencies
Total IDC
Total Capital Investment = PEC + DC + IDC
0.03*A
0.05*A
B
0.14*B
0.04*B
0.02*B
0.20*B
0.02*B
0.03*B
0.05*B
Equipment costs provided by vendor and/or foamer.
3-6
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TABLE 3-5. CONTRIBUTIONS TO TOTAL ANNUAL COST
Description
Method for Calculation
Direct Costs (DC)
Materials
Utilities
Maintenance materials
Replacement parts
Operating labor
Supervisory labor
Maintenance labor
Waste treatment
Indirect Costs (IDC)
Capital recovery
Overhead
Administrative charges
Recovery Credits (RC)
Total Annual Cost = DC + IDC
provided9
electric use provided
electric cost = $0.04/kw-h
provided
provided
amount provided
labor rate = $20/hr
15 percent of oper. labor
amount provided
labor rate = $20/hr
provided or calculated
7 percent interest rate
equipment life varied, but
default was 10 years
60 percent of all labor
costs
4 percent of total capital
investment
provided or calculated
- RC
"Provided" means information was provided by vendor and/or
fearner.
3-7
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3.3 REFERENCES FOR CHAPTER 3.0
1. B. Jordan, EPA:ESD, to flexible polyurethane foam producers.
July 30, 1993. Section 114 information collection requests
(ICRs).
2. U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards. OAQPS Control Cost Manual, Fourth
Edition. EPA 450/3-90-006. January 1990.
3-1
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4.0 EMISSION REDUCTION TECHNOLOGIES AND COSTS: MOLDED FOAM
In this chapter, the results of information gathering
efforts are presented for molded foam. This discussion is
organized by emission source. A brief description of each
emission source is provided, followed by discussions and
representative facility costs for all emission reduction
technologies applicable to that source.
Information was obtained for emission reduction technologies
for three HAP emission sources at molded foam facilities. The
sources are (1) mixhead flushing, (2) mold release agents, and
(3) adhesives for foam repair. Each of these sources are
discussed in the following sections. Since the same HAP-based
adhesives are also used in slabstock foam fabrication, there is a
section that includes costs of alternative adhesives for both
molded foam repair and slabstock foam fabrication.
4.1 ALTERNATIVES TO HAP MIXHEAD FLUSHES
Methylene chloride (MeCl2) from flushing of low-pressure
mixheads was the largest emission source for flexible molded foam
manufacture. According to the emissions estimates presented in
the ICR responses, over 75 percent (203 tons/yr) of the HAP
emissions from molded foam facilities were from this
application.1 With low-pressure mixheads, the chemical streams
enter the mixing chamber at approximately 40 to 100 pounds per
square inch (psi), and are blended by rotating mixer blades
before being released or "shot" into the mold.2 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. This residual froth is also a problem due to the
precision required in the volume of the foam shot.
Several technologies were found to have the capability of
reducing or eliminating this source of HAP emissions for the
molded foam producer. These technologies are described in detail
4-1
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below and include non-HAP flushes, high-pressure mixheads,
self-cleaning mixheads, and solvent recovery units. To make the
costs as conservative as possible, it was assumed that no effort
is made to prevent the evaporation of the waste MeCl2 flush at
the representative facility. The portion that does not evaporate
(see Table 3-1) must be disposed of as a hazardous waste.
4.1.1 Non-HAP Mixhead Flushes
Three non-HAP solvent-based flushes were identified and
investigated. The solvents they contain are primarily cyclic
amide, ethyl ester, glutarate ester, and other esters.3'4 One
product's major component is D-limonene, with small amounts of
terpene hydrocarbons.5 The important characteristics of
alternative flushes are that they are quick-drying, quick
cleaning, and non-reactive with the foam raw ingredients.
All three flushes identified are direct replacements for
MeCl2, meaning that changing to these flushes typically requires
no equipment or operational changes. This is an advantage in
that no additional capital, utility, maintenance, or operational
costs are required. However, the manufacturers discourage the
use of seals and o-rings made of materials such as PVC, neoprene,
and butyl rubber with these non-HAP mixhead flushes.6'7'8
All three solvent-based flushes eliminate HAP emissions, but
the solvents in them are still classified as VOC. However, all
three products have significantly lower evaporation rates, with
maximum vapor pressures of 2 mm mercury (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, if the solvent is filtered for solids, the non-
HAP flushes can be reused 2 to 5 times, or more. Methylene
chloride can only be reused if it is distilled.9'10'11
There are also savings in disposal costs of the waste
material, as the spent flush from these products is not
classified as a hazardous waste, unlike MeCl2. A foamer using
one of these products estimated that the disposal costs were
approximately $60 for a 55-gallon drum versus $600 for disposal
of a 55-gallon drum of MeCl2.12 A manufacturer of one of these
4-2
-------
products stated that the disposal cost for a drum of MeCl2 was
$800.13 To be conservative, the disposal costs used in the
representative facility calculation were $800/drum for MeCl2, and
$60/drum for non-HAP flushes.
The costs of applying this system to the representative
molded foam plant are presented in Table 4-1. Approximately the
same volume of non-HAP flushes are required as would be necessary
with the use of MeCl2. These non-HAP products are more expensive
than MeCl2 on a volume basis. A 55-gallon drum of MeCl2 costs
approximately $244, while costs of the non-HAP flushes range from
$382 to $1,375 a drum.14'15-15 For representative facility
costs, an average cost of $838 per drum was used. In calculating
the representative facility costs, to be conservative, it was
assumed that the non-HAP products are reused 3 times, meaning
only 45 drums are needed, as compared to 135 drums of MeCl2.
4.1.2 High-Pressure (HP) Mixheads
Low-pressure mixheads can be replaced with high pressure
(HP) mixheads to eliminate HAP emissions. Three manufacturers of
HP mixheads were contacted. HP mixheads mixes the foam
components by impingement of the high pressure streams within its
mixhead at pressures up to 3000 psi, as compared to typical low
pressure systems at 40 to 100 psi.17'18 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 appropriate for manufacturers of
small parts, as the low throughput rate required for these parts
may be too low for the HP system to achieve the necessary mixing.
When a low pressure mixhead is flushed with solvent,
polyurethane in the mixhead is lost. One vendor estimated the
cost of the lost polyurethane to the foam manufacturer to be
4-3
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TABLE 4-1. REPRESENTATIVE FACILITY COSTS FOR
NON-HAP MIXHEAD FLUSHES
Capital Investment9
Total Capital Investment $0
Annual Costs
Direct Costs3
Materials13 $4,770
Waste treatment0 $-7,700
Indirect Costs $0
Total Annual Cost $-2930
Emission Reductiond (tons/yr) 37.10
Cost Effectiveness ($/ton) $-79
a As discussed above, since these products are direct
replacements for MeCl2, there were no additional capital costs
(equipment or installation, nor any additional annual costs
for labor or maintenance) identified.
b Material costs were calculated as follows:
cost of MeCl2: (135 drums @ $244/drum) = $32,940/yr
cost of alternative = (45 drums @ $838/drum) = $37,710/yr
$37,710 - $32,940 = $4,770
c Waste treatment costs were calculated as follows:
MeCl2 treated: 13 drums @ $800/drum = $10,400/yr
altern. : 45 drums @ $60 = $2,700/yr
2,700 - 10,400 = -7,700
d A small amount of VOC may be emitted due to the use of these
alternatives.
4-4
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$1.00/lb.19 The use. of HP mixheads eliminates this cost,
resulting in a cost savings. It was not possible to calculate
this cost on a facility-wide basis without further information.
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 deliver 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 the increased pressure.20-21'22
The cost of HP replacement systems ranges from $75,000 to
$200,000, depending on the size of the system, the required
throughput, and the sophistication of the system.23'24'25'26
Based on detailed information from two manufacturers, an average
price of $97,500 per system was used for the representative
facility.27'28 The machines are typically delivered as complete
units, ready for connection. The cost of the systems includes:
- metering pumps, and auxiliary equipment (e.g., pressure
indicators, pressure relief valve)
- high pressure filter on diisocyanate feed line between the
metering unit and mixhead
- HP mixhead
- hydraulic manifold
- day-tank assembly
- a stored program controlled system with a control desk
It is assumed that there are no changes in energy requirements,
as the vendor stated that the new pumps required for the
increased pressure would not cause a significant increase in the
amount of energy used.29 There are increased maintenance costs
involved in using a HP mixhead versus a low pressure mixhead.
Because of the very high pressures involved, there is
considerable wear on the injection components. One foamer
indicated that the increased maintenance cost is about $10,000
per year for each mixhead, as compared to a low-pressure
mixhead.30 A small cost savings would be seen, as only a small
4-5
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amount of polyurethane material is lost when using this type of
mixhead versus a low pressure mixhead. However, this cost
savings was not included for the representative facility. The
costs of applying this system to the representative molded foam
plant are presented in Table 4-2.
4.1.3 "Self-Cleaning" Mixhead
Another alternative to HAP mixhead flushing is a self-
cleaning tapered-screw mixhead. The mixhead uses a tapered
mixing screw in a tapered chamber. The screw rotates rapidly to
provide thorough mixing of the raw materials. For cleaning, the
screw moves forward again, at a faster rate, and removes the
residue from the mixing chamber.31
This technology is only applicable for molded foam systems
manufacturing small parts.32 The throughput for this mixhead
ranges from 2 to 16 Ib/min, which is in the lowest range for
manufacturers of non-automotive seating foam parts. However,
for most material systems, HP mixheads would normally be the
preferred technology for throughputs above approximately
9 Ib/min.33 Consequently, the self cleaning mechanical mixhead
is most applicable at the lower half of the throughput range.34
The vendor did state that there is at least one flexible foam
molder using this technology in New York; however, the EPA was
unable to confirm this information.35 The ICR responses did not
identify any flexible molded foam producer using or investigating
the self-cleaning mixhead technology.
The cost of this equipment, new, is approximately $100,000.
The cost of a conversion kit, which only includes the new mixhead
and the drive system, is approximately $35,000. Modifications
would need to be made to the existing metering and control
systems.36'37
The costs of applying this system to the representative
molded foam plant are presented in Table 4-3. A small cost
savings would be seen, as only a small amount of polyurethane
material is lost when using this type of mixhead, as opposed to a
low pressure mixhead. However, this cost was not included for
the representative facility. No increases in operating costs
4-6
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TABLE 4-2. REPRESENTATIVE FACILITY COSTS FOR
HIGH PRESSURE MIXHEADS
Capital Investment
Purchased equipment costsa $315,900
Direct installation costsb $63,180
Indirect installation costsc $15,795
Total Capital Investment $394,875
Annual Costs
Direct Costsd $0
Maintenancee $30,000
Materialsf $-32,940
Waste treatment9 $-10,400
Indirect Costs
Capital Recovery11 $56,230
Administrative Charges1 $15,795
Total Annual Cost $28,685
Emission Reduction (tons/yr) 37.1
Cost Effectiveness ($/ton) $773
a $97,500 * 3 = $292,500
292',500 * [292,500' * (0.03 tax + 0.05 freight)] = $315,900
b $315,900 * (0.14 hardware and erection +0.04 electrical +0.02
piping)= $63,180
c $315,900 * (0.02 start-up + 0.03 contingency) = $15,795
d There were no additional annual costs for labor identified.
e $10,000 * 3 = $30,000
£ This technology eliminates any need for MeCl2, so there is a
material cost savings of $32,940
9 This technology eliminates any need for MeCl2, so there is a
waste treatment savings of $10,400/yr
h $394,875 * 0.1424 (7% for 10 yrs) = $56,230
1 $394,875 * 0.04 = $15,795
4-7
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TABLE 4-3. REPRESENTATIVE FACILITY COSTS FOR
SELF-CLEANING MIXHEADS
Capital Investment
Purchased equipment costs3
Direct installation costsb
indirect installation costs0
Total Capital Investment
Annual Costs
Direct Costsd
Materials6
Waste treatment*
Indirect Costs
Capital Recovery9
Administrative charges'1
Total Annual Cost
Emission Reduction (tons/yr)
Cost Effectiveness ($/ton)
$108,450
$21, 690
$5,423
$135,563
$-32,940
$-10,400
$19,304
$5,423
$-18,613
37.1
$-502
a $35,000 * 3 = $105,000
105,000 + [105,000 * (0.03 tax)] + $300 freight = $108,450
(Freight cost taken from Klockner-Desman letter, January 5,
1995.
b $108,450 * (0.05 hardware and erection + 0.13 electrical + 0.02
piping)= $21,690
c $108,450 * (0.02 start-up + 0.03 contingency) = $5,423
a There were no additional annual costs for labor or maintenance
identified.
e This technology eliminates any need for MeCl2, so there is a
savings of $32,940
£ This technology eliminates any need for MeCl2, so there is a
waste treatment savings of $10,400
g $135,563 * 0.1424 (7% for 10 yrs) = $19,304
h $135,563 * 0.04 = $5,423
4-8
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were identified. There were no significant operational,
maintenance, or utility usage differences identified by the
vendor.
4.1.4 Solvent Recovery Systems
Two facilities were contacted that had solvent recovery
systems in place.38'39 In both systems, 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° Fahrenheit (F).
The solvent vapors are flashed off and go to a condenser where
they cool and are collected for re-use. The solids from the
still, containing scrap foam and other contaminants, are
collected for disposal.40 Both systems had a recovery rate of
about 70 to 80 percent. The cost of the still system ranges
between $20,000 and $40 , 000 .41'42
One of the systems had an additional step to reduce
emissions at the capture area.43 The three molded foam lines
that use solvent flush are equipped with a "closed-loop system"
for capturing the MeCl2 vapors from the area around the 55-gallon
drum that is used to capture the flush. This system consists of
a fan that draws the vapors generated in the flush area through a
carbon filter, which captures the solvent vapors before the air
is released to the atmosphere. The cost for this system is
between $500 and $2000 per line. The carbon filter needs to be
replaced approximately once a month at an estimated cost of $100
to $200.44
Table 4-4 presents the estimated representative facility
costs. The capital costs used were $30,000 for the still system
and $1,000 per line for the recovery system. One foam
manufacturer stated that it would take an additional 2 hours per
day to load and unload the system.45 A carbon disposal cost of
$150 per month was used.46 While there would be increased
utility and maintenance costs, sufficient information was not
available to allow for a reasonable estimate of these costs. One
foamer indicated that the cost of the disposable bags used to
4-9
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TABLE 4-4. REPRESENTATIVE FACILITY COSTS FOR
SOLVENT RECOVERY SYSTEMS
Capital Investment
Purchased equipment costs3 $35,640
Direct installation costsb $7,128
indirect installation costs0 $1,782
Total Capital Investment $44,550
Annual Costs
Direct Costs
Materials'3 $-24,705
Utilities6
Maintenance materials6
Replacement parts6 insufficient information
,, . . T i_ e to estimate
Maintenance labor6
Operating laborf $9,600
Supervisory labor3 $1,440
Waste treatment11 $-6,000
Indirect Costs
Capital Recovery1 $6,344
Overheadj 6,624
Administrative chargesk $1,782
Total Annual Cost $-4,915
Emission Reduction (tons/yr)1 27.8
Cost Effectiveness ($/ton) $-177
a [$30,000 + ($1,000 * 3)] = 33,000
33,000 + [33,000 * (0.03 tax + 0.05 freight)] = $35,640
b $35,640 * (0.14 hardware and erection + 0.04 electrical + 0.02
piping)= $7,128
c $35,640 * (0.02 start-up + 0.03 contingency) = $1,782
a Savings of 75 percent of MeCl2 costs due to recovery: $32,940
* 0.75 = $24,705
e It is assumed that there would be additional utility and
maintenance costs, but sufficient information was not provided to allow an
estimation of these costs.
£ 2 hours/day * 240 days/yr * $20/hr = $9,600
g $9,600 * 0.15 = $1,440
h Savings of 75 percent of MeCl2 disposal costs due to recovery: $10,400 *
0.75 = $7,800. Added cost of carbon disposal = $150/month * 12 months =
$1,800. Total disposal costs = $1,800 - $7,800 = $-6,000
1 $44,550 * 0.1424 (7% for 10 years) = $6,344
j ($9,600 + $1,440) * 0.60 = $6,624
k $44,550 * 0.04 = $1,782
1 37.1 tons * 0.75 = 27.8 tons/yr
4-10
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hold the solvent flush waste and to transport these bags to the
dumpster was approximately $30/dozen.47 Because it was not
possible to determine the consumption rate of these bags, this
cost was not included in the representative facility
calculations. An MeCl2 recovery efficiency of 75 percent was
used.
4.2 ALTERNATIVE MOLD RELEASE AGENTS
According to the emissions estimates presented in the ICR
responses, approximately 3 percent (7.9 tons) of the HAP
emissions from molded foam facilities were due to the evaporation
of the carrier solvent from mold release agents.48 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 or
wax in a solvent carrier. This solvent carrier is often composed
of MeCl2 or 1,1,1-trichloroethane (methyl chloroform). The
carrier evaporates, leaving the resin, which prevents the foam
from sticking to the mold. Alternatives being used or
investigated by the industry include water-based agents, naphtha-
based agents, and reduced-VOC solvent agents. The following
sections discuss these three options.
4.2.1 Reduced-VOC Mold Release Agents
The reduced-VOC mold release agents are produced through
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. The one vendor that was contacted
stated that the reduced VOC carrier solvent used was a non-HAP;
however, it was unclear if the solvents used in most reduced-VOC
mold release agent formulations are HAP.49 The vendor stated
that most users have seen a reduction in mold release agent
consumption of 20 to 50 percent after switching to the
reduced-VOC release agents.50 No equipment changes are
necessary in switching to this type of release agent, and no
significant operator training or mold temperature changes are
necessary.
4-11
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The representative facility costs are presented in
Table 4-5. The price per gallon of this reduced-VOC agent is over
twice as much as that for traditional solvent-based agents, at
$9.31 per gallon.51'52 However, much of this material cost is
offset by the reduction in usage.53 For the representative
facility, an average usage reduction of 35 percent was assumed,
and a HAP emission reduction of 100 percent was used.
4.2.2 Naphtha-based Release Agents
Naphtha-based release agents are composed of resins in a
hydrocarbon naphtha carrier solvent. Naphtha typically comprises
at least 90 percent of the mold release agent.54 While naphtha
is not a HAP, it is listed as a VOC.
The cost of naphtha-based release agents was reported by two
sources as ranging from $11.90 to $17.50 per gallon, so an
average cost of $14 .70/gallon was used.55'56 Foam manufacturers
have found that a smaller amount of mold release agent is needed
when naphtha-based agents are substituted for HAP-based
agents.57 Because it was not possible to quantify this
reduction, a conservative estimate of a 5 percent reduction in
usage was chosen for the calculation of the representative
facility costs shown in Table 4-6. One commenter stated that by
using a low pressure, high volume gun in conjunction with a fluid
regulator, they have been able to reduce consumption by 30
percent.58 There were no necessary process or equipment changes
identified, nor any increase in maintenance or labor costs.
4.2.3 Water-based release agents
Using water-based mold release agents is a more complicated
substitution than using naphtha or reduced-VOC solvent based
agents.59'60 However, unlike the other two alternatives, water-
based mold release agents totally eliminate organic emissions.
All water-based mold release agent manufacturers spoken to
emphasized that selection of a water-based release agent is
customer-specific, and that the correct selection can require
time and several trials before the appropriate product is
found.61'62 However, one vendor commented that customers with
multiple facilities can use the same product, and scale-up
4-12
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TABLE 4-5. REPRESENTATIVE FACILITY COSTS FOR
REDUCED-VOC MOLD RELEASE AGENTS
Capital Investment3
Total Capital Investment $0
Annual Costs
Direct Costs3
Materials'3 $2,077
Indirect Costs $0
Total Annual Cost $2,077
Emission Reductionc (tons/yr) 4.6
Cost Effectiveness ($/ton) $452
a As discussed above, since these products are direct
replacements for HAP-based release agents, there were no
additional capital costs (equipment or installation)
identified. No additional annual costs for labor or
maintenance were identified.
b Material costs were calculated as follows:
HAP-based: $4.82/gal * 1688 gal = $8,136
Reduced-VOC: $9.31/gal * 1097 gal = $10,213
$10,213 - $8,136 = $2077/yr
c HAP emissions will be replaced by VOC emissions, but at a rate
of 40% of the HAP emissions (1.8 tons/yr VOC emissions)
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TABLE 4-6. REPRESENTATIVE FACILITY COSTS FOR NAPTHA-BASED
MOLD RELEASE AGENTS
Capital Investment3
Total Capital Investment $0
Annual Costs
Direct Costs3
Materials13 $15,443
Indirect Costs $0
Total Annual Cost $15,443
Emission Reduction0 (tons/yr) 4.6
Cost Effectiveness ($/ton) $3,359
a As discussed above, since these products are direct
replacements for HAP-based release agents, there were no
capital (equipment or installation) costs identified. There
were no additional annual costs for labor or maintenance
identified.
b Material costs were calculated as follows:
HAP-based: $4.82/gal * 1688 gal = $8,136/yr
Naptha-based: $14.70/gal * 1604 gal = $23,579/yr
$23,579 - $8,136 = cost $15,443/yr
c HAP emissions will be replaced by an approximately equal
level of VOC emissions.
4-14
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following implementation at one facility is greatly reduced as
the product is implemented at the other facilities. This reduces
the average facility scale-up costs for an individual
customer.63 The developmental procedures can be costly in time,
as well as in scrap foam, during the transitional period.64
However, the up-front developmental procedures may eventually
result in additional benefits and cost reductions.
There are 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 retraining may be
necessary. However, the spray retraining can benefit the foam
producer by giving the producer an opportunity to teach the
production line operators to reduce use levels, resulting in
further cost reductions.65 Mold temperature changes may also be
necessary when switching to some water-based agents, due to the
higher evaporation temperature of water. One vendor was
identified that stated that their technology does not require an
increase in mold temperature, or increased drying time, which is
another change discussed below.66 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.67'68
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.69
The cost of the water-based agents is higher per gallon than
HAP-based agents, at $6.00 per gallon.70 The usage of water-
based release agents, as compared to HAP-based agents, seemed to
vary from case to case, so it was assumed that the usage was
equivalent for the representative facility costs shown in
Table 4-7.
4-15
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TABLE 4-7. REPRESENTATIVE FACILITY COSTS FOR
WATER-BASED MOLD RELEASE AGENTS
Capital Investment3
Total Capital Investment $0
Annual Costs
Direct Costsa
Materials13 $1,992
Indirect Costs $0
Total Annual Cost $1,992
Emission Reduction (tons/yr) 4.6
Cost Effectiveness ($/ton) $433
a As discussed above, since these products are direct
replacements for HAP-based release agents, there were no
capital (equipment or installation) costs identified. There
were no additional annual costs for labor or maintenance
identified. No costs could be estimated for development and training, but
there will be costs for these items.
b Material costs were calculated as follows:
HAP-based: $4.82/gal * 1688 gal = $8,136/yr
Water-based: $6.0/gal * 1688 gal = $10,128/yr
$10,128 - $8,136 = cost $l,992/yr
4-16
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4.3 ALTERNATIVE ADHESIVES
HAP-based adhesives are used in both slabstock and molded
foam facilities. In slabstock foam facilities, spray adhesives
are used to glue fabric-to-foam, or foam-to-foam. In the
slabstock industry, only about 40 percent of the fabrication is
done "in-house," and not all fabrication involves gluing.71
Fabrication covers the broad range of die cut parts, cut parts,
as well as glued parts. Adhesives used for fabrication accounted
for 1,382 tons, or 7.5 percent of the total HAP emissions from
slabstock foam facilities. Normally, these adhesives are
approximately 20 to 40 percent solids, while the remainder
consists of a solvent carrier, such as methyl chloroform or
MeCl2.
The main use of adhesives in molded foam facilities is for
the repair of voids and tears in the molded foam pieces. There
were 26 tons of HAP emissions (less than 10 percent) reported at
molded foam facilities from this source in the ICR responses.72
Three alternatives were identified that eliminate HAP
emissions from the use of adhesives. These are (1) hot-melt
adhesives, (2) water-based adhesives, and (3) Hydrofuse. Each is
discussed in the following sections.
4.3.1 Hot-Melt Adhesives
Hot-melt adhesives are sold as solids that are melted in a
tank system before being used. They are then sprayed on like
solvent-based adhesives. They have a quick drying, or "tack,"
time. This feature has both advantages and disadvantages. The
main advantage is that the quick tack time allows for a faster
production time than many other adhesives. The main disadvantage
is that the adhesive may cease to be sticky before the assembly
is complete. However, the tack time varies between
manufacturers, 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.73 An additional problem
is that hot melt adhesives tend to produce hard seams, which are
not acceptable in a soft, flexible foam product.
4-17
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Hot-melt adhesives do not contain any HAP; however, very
small amounts of low molecular weight hydrocarbons may be emitted
at the application temperatures. There is also a decrease in the
amount of adhesive needed for the same amount of foam.74
Because it was not possible to quantify this reduction, a
conservative estimate of 15 percent reduction was used, based on
information received from vendors.
The costs for using hot-melt adhesives at both the slabstock
and molded foam representative facilities are presented in
Table 4-8. The tanks to melt the adhesives cost approximately
$3,000 per tank, and the hot-melt adhesive costs approximately
$20.30 per gallon.75 There is a small electricity cost for the
glue tanks.76 There were no direct installation costs, as the
equipment does not need any additional erection, wiring, or
piping. There were no additional maintenance or labor costs
identified.
4.3.2 Water-Based Adhesives
The largest advantage of water-based adhesives is that all
HAP have been replaced by water, and there is a complete
elimination of organic emissions. A major drawback is the slower
drying times of these adhesives, which may create a need for
larger drying areas. To solve this problem, some fabrication
operations use an additional heat source to speed up the
evaporation of the water, which would increase the utility costs,
due to operation of the heat lamps. However, there are no other
equipment or operational changes necessary to replace HAP-based
adhesives with water-based. Only one vendor provided a cost per
gallon for water-based adhesives. He stated that the average
cost is approximately $7.00 per gallon.77
The costs of this alternative for the representative
slabstock and molded foam facilities are presented in Table 4-9.
The increased utilities cost was not determined, but it is
expected to be minimal. The usage was found to be the same for
water-based adhesives as for HAP-based. It was assumed that no
additional heat source was used at the representative facility,
4-18
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TABLE 4-8. REPRESENTATIVE FACILITY COSTS FOR
HOT-MELT ADHESIVES
Capital Investment
Purchased equipment costsa
Direct installation costs
indirect installation costsb
Total Capital Investment
Annual Costs
Direct Costs0
Materials'3
Utilities6
Indirect Costs
Capital Recoveryf
Administrative charges9
Recovery Credits
Total Annual Cost
Emission Reduction11 (tons/yr)
Cost Effectiveness ($/ton)
a $3,000 * 6 = $18,000
18,000 + [18,000 * (0.03 tax + 0.05 freight)] =
Slabstock
$19,440
0
$970
$20,410
$93,491
$149
$2,906
$816
$0
$97,362
43
$2,264
$19,400
Molded
$6,480
0
$340
$6,820
$3,015
$50
$971
$273
$0
$4,309
1.34
$3,216
(slabstock)
$3,000 * 2 = $6,000
6,000 + [6,000 *(0.03 tax + 0.05 freight)] = $6,480 (molded)
b $19,400 * (0.02 start-up + 0.03 contingency) = $970 (slabstock)
$6,804 * (0.02 start-up + 0.03 contingency) = $340 (molded)
c There were no additional annual costs for labor or maintenance
identified.
d HAP-based: 10,679 gal @ $8.50/g = $90,772 (slabstock)
Hot-melt: 9,077 gal @ $20.30/g = $184,263 (slabstock)
HAP-based: 345 gal @ $8.50/g = $2,933 (molded)
Hot-melt: 293 gal @ $20.30/g = $5,948 (molded)
e 1725 watts/1000 = 0.1725 kw * 16 hr = 2.76 kw-h/d
2.76 kw-h/d * 225 d/yr = 621 kw-h/yr *$0.04/kw-h =
$24.84/yr/spray station
£ $20,410 * 0.1424 (7% for 10 yrs) = $2,906 (slabstock)
$6,820 * 0.1424 (7% for 10 yrs) = $971 (molded)
g $20,410 * 0.04 = $816 (slabstock)
$6,820 * 0.04 = $273 (molded)
h A small amount of VOC may be emitted due to the use of this
alternative
4-19
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TABLE 4-9. REPRESENTATIVE FACILITY COSTS FOR
WATER-BASED ADHESIVES
Capital Investment Slabstock Molded
Total Capital Investment3 $0 $0
Annual Costs3
Direct Costs
Materials13 $-15,699 $-508
Utilities0
Indirect Costsd
Total Annual Cost $-15,699 $-508
Emission Reduction (tons/yr) 43 1.34
Cost Effectiveness ($/ton) $-365 $-379
a As discussed above, since these products are direct
replacements for HAP-based adhesives, there were no capital
costs (equipment or installation), identified. There were no
additional annual costs for labor, maintenance, or waste
treatment identified.
b HAP-based: $8.50/g * 10,679g = $90,772 (slabstock)
Water-based: $7.03/g * 10,679g = $75,073 (slabstock)
75,073 - 90,772 = -15,699 (slabstock)
HAP-based: $8.50/g * 345g = $2,933 (molded)
Water-based: $7.03/g * 345g = $2,425 (molded)
2,425 - 2,933 = -508 (molded)
c Unable to quantify
d No indirect costs identified
4-20
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due to the unavailability of information on the use of heat
sources for this application.
4.3.3 Hydrofuse
Another water-based alternative to spray-applied
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.78
This process does require process and equipment changes.
Equipment alterations will include changing to new spray guns,
and assuring that all equipment parts that come in contact with
the adhesive 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
to which it is applied, and it dries almost instantly.79
The costs for using Hydrofuse at both the slabstock and
molded foam representative facilities are presented in
Table 4-10. There were no direct installation costs, as the
equipment does not need any additional erection, wiring, or
piping. There were no additional maintenance or labor costs
identified. The cost of the spray equipment ranges for $2,000 to
$3,000 ($2,500 used for analysis) and the adhesive's material
cost is approximately 6 percent less than HAP-based adhesives.80
The usage for hydrofuse is less than for HAP-based adhesives, but
the percentage difference was not quantified.
4-21
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TABLE 4-10. REPRESENTATIVE FACILITY COSTS FOR
HYDROFUSE ADHESIVE
Capital Investment Slabstock Molded
Purchased equipment costs3 $16,200 $5,400
Direct installation costs $0 $0
indirect installation costsb $810 $270
Total Capital Investment $17,010 $5,670
Annual Costs
Direct Costs0
Materials* $5,446 $176
Utilities6
Indirect Costs
Capital Recovery£ $2,422 $807
Administrative charges9 $680 $227
Total Annual Cost $8,548 $1,210
Emission Reduction (tons/yr) 43 1.34
Cost Effectiveness ($/ton) $199 $903
a $2,500 * 6 = $15,000
15,000 * [15,000 * (0.03 tax + 0.05 freight)] = $16,200
(slabstock)
$2,500 * 2 = $5,000
5,000 * [5,000 * (0.03 tax + 0.05 freight)] = $ 5,400
(molded)
b $16,200 * (0.02 start-up + 0.03 contingency) = $810 (slabstock)
$5,400 * (0.02 start-up +0.03 contingency) = $270 (molded)
c There were no additional annual costs for labor or maintenance
identified.
d HAP-based: 10,679 gal @ $8.50/g = $90,772 (slabstock)
Hydrofuse: $90,772 * 0.94 = $85,326 (slabstock)
90,772 - 85,326 = 5,446
HAP-based: 345 gal @ $8.50/g = $2,933 (molded)
Hydrofuse: $2,933 * 0.94 = $2,757
2,933 - 2,757 = 176
e Unable to determine
f $17,010 * 0.1424 (7% for 10 yrs) = $2,422 (slabstock
$5,670 * 0.1424 (7% for 10 yrs) = $807 (molded)
9 $17,010 * 0.04 = $680 (slabstock)
$5,670 * 0.04 = $227 (molded)
4-22
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4.4 REFERENCES FOR SECTION 4.0
1. A. Williams, EC/R Inc., to D. Svendsgaard, EPA:ESD:OCG.
February 10, 1995. Non-confidential summary of Flexible
Polyurethane Foam Information Collection Request (ICR) Data.
2. Herrington, R., and K. Hock. Flexible Polyurethane Foams.
Dow Plastics, 1991. p. 5.15.
3. Dynaloy, Inc. Material Safety Data Sheet. Transmitted to
EC/R Inc. via facsimile on April 26, 1994.
4. 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.
5. 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.
6. Reference 3.
7. Reference 4.
8. Reference 5.
9. Reference 3.
10. Reference 4.
11. Reference 5.
12. Telecon: A. Williams, EC/R Inc., to T. Conway, Conway
Industries. April 28, 1994.
13. G. Williams, Nu-Foam Products, Inc., to D. Svendsgaard,
EPA:ESD:OCG. January 9, 1995. Letter transmitting comments
on the cost analysis prepared by EPA.
14. Telecon: A. Williams, EC/R Inc., to P. Esemplare, Dynaloy,
Inc. April 22, 1994.
15. Telecon: A. Williams, EC/R Inc., to C. Borgeson, Huron
Technologies, Inc. April 27, 1994.
16. Telecon: A. Williams, EC/R Inc., to S. Ferdelman, Chem
Central. April 28, 1994.
17. F. Solomon, Miles Hennecke Machinery Corp., to A. Williams,
EC/R Inc. July 12, 1994. Facsimile transmitting price
information on HP mixheads.
4-23
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18
19
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32,
33,
34
35
36
37
A. Williams, EC/R Inc., to D. Svendsgaard, EPA:ESD:OCG. May
27, 1994. Memorandum discussing information gathered from
manufacturers of HP mixheads.
G. Lewis, Klockner Desma Sales and Service, Inc., to D.
Svendsgaard, EPA:ESD:OCG. January 5, 1995. Letter
transmitting comments on the cost analysis prepared by EC/R
Inc.
to M. Pritchard, Admiral
to F. Solomon, Hennecke
to M. Mangold, Foamex, LP.
Telecon: A. Williams, EC/R Inc
Corp. May 25, 1994.
Telecon: A. Williams, EC/R Inc
Machinery. May 25, 1994.
Telecon: A. Williams, EC/R Inc
April 12, 1994.
Reference 20.
Reference 21.
Telecon: A. Williams, EC/R Inc., to R. Hogue, Krauss Maffei
Corp. May 25, 1994.
R. Hogue, Krauss-Maffei Corp., to A. Williams, EC/R Inc.
June 1, 1994. Letter transmitting cost information .
Reference 21.
Reference 26.
Reference 21.
M. Mangold, Foamex, LP, to D. Svendsgaard, EPA:ESD:OCG.
January 10, 1995.
Telecon: A. Williams, EC/R Inc., to G. Lewis, Klockner
Ferromatik Desma. May 18, 1994.
Reference 31.
Reference 22.
Reference 19.
Reference 31.
Reference 31.
Telecon: A. Williams, EC/R Inc., to G. Lewis, Klockner
Ferromatik Desma. July 15, 1994.
4-24
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38.
39.
40.
41.
42.
43
44,
45,
46
47,
48,
49,
50.
51,
52,
53,
54
55
56
Telecon: A. Williams, EC/R Inc., to D. Peck, Renosol Corp.
June 7, 1994.
Telecon: A. Williams, EC/R Inc., to S. Smoller, E-A-R
Specialty Corporation. June 10, 1994.
Reference 38.
Reference 39.
Telecon: A. Williams, EC/R Inc., to D. Majewski, Renosol
Corp. June 10, 1994.
Reference 42.
Reference 42.
S. Smoller, E-A-R Specialty Composites, to A. Williams, EC/R
Inc. December 21, 1994. Letter transmitting comments on
EPA's draft cost analysis.
Reference 42.
S. Smoller, E-A-R Specialty Composites, to D. Svendsgaard,
EPA:ESD:OCG. December 21, 1994. Letter transmitting
comments on EPA's December 9, 1994 draft cost analysis of
the alternatives for reducing HAP emissions in this
industry.
Reference 1.
Telecon: A. Williams, EC/R Inc.
Products. April 21, 1994.
Telecon: A. Williams, EC/R Inc.
Products. July 11, 1994.
Reference 49.
Reference 50.
Reference 50.
Telecon: A. Williams, EC/R Inc,
Corp. July 14, 1994.
Reference 54.
to J. Robinson, Air
to J. Robinson, Air
to M. Gromnicki, Swenson
H. Mauersberger, Foam Design, to S. Wyatt, EPA:OAQPS:ESD.
June 1, 1995. Letter transmitting comments on the May 1995
preliminary draft of the "Flexible Polyurethane Foam
Emission Reduction Technologies Cost Analysis."
4-25
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57. Telecon: A. Williams, EC/R Inc., to D. Majewski, Renosol
Corp. July 19, 1994.
58. Reference 56.
59. Reference 49.
60. Telecon: A. Williams, EC/R Inc., to C. Asuncion, Air
Products. April 20, 1994.
61. Reference 49.
62. Reference 60.
63. R. Santo, Air Products, to S. Wyatt, EPA:OAQPS:ESD. June 8,
1995. Letter providing additional comments on the May 1995
preliminary draft of the "Flexible Polyurethane Foam
Emission Reduction Technologies Cost Analysis."
64. Reference 60.
65. R. Santo, Air Products, to D. Svendsgaard, EPA:ESD:OCG.
January 16, 1995. Letter transmitting comments on EPA's
December 9, 1994 cost analysis of alternatives for reducing
HAP emissions in this industry.
66. Reference 63.
67. Reference 49.
68. Reference 60.
69. Reference 60.
70. R. Santo, Air Products, to D. Svendsgaard, EPA:ESD:OCG.
January 16, 1995. Letter transmitting comments on the
product and cost data of alternatives for reducing or
eliminating HAP's in the manufacture of flexible
polyurethane foam, as determined by EPA.
71. Reference 1.
72. Reference 1.
73. H.B. Fuller Company, Technical Data Sheet on Hot Melt
Adhesive (Product No. HL-6278).
74. Telecon: A. Williams, EC/R Inc., to D. Kehr, H.B. Fuller
Company. June 22, 1994.
75. Reference 74.
76. Telecon: A. Williams, EC/R Inc., to D. Brauen, Nordson
Corp. June 27, 1994.
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77. Telecon: A. Williams, EC/R Inc., to M. Lechowicz, Midwest
Industrial Chemical Co. June 22, 1994.
78. H.B. Fuller Company Technical Data Sheet for Hydrofuse
(Product No. WC-0686-A 770). June 22, 1994.
79. Reference 74.
80. Telecon: P. Norwood, EC/R Inc., to A. Abraham, H.B. Fuller
Co. July 28, 1994.
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5.0 EMISSION REDUCTION TECHNOLOGIES AND COSTS: SLABSTOCK FOAM
Information was obtained for emission reduction technologies
for three HAP emission sources at slabstock foam facilities.
These are (1) auxiliary blowing agent (ABA) usage, (2) equipment
cleaning, and (3) adhesives for fabrication. Emission reduction
technologies for ABA reduction/replacement and equipment cleaning
are discussed in the following sections. Alternative adhesives
for slabstock foam fabrication were discussed in the molded foam
section.
5.1 ALTERNATIVES TO METHYLENE CHLORIDE AS AN ABA
Methylene chloride is the principal ABA used in the
production of slabstock flexible polyurethane foam. The role of
the MeCl2 is simply to vaporize and expand the foam, it does not
directly participate in the polyurethane reaction. Therefore,
all of the MeCl2 that is added eventually is emitted. The use of
MeCl2 as an ABA was the largest emission source of HAP reported
in the ICR responses, at over 14,600 tons, accounting for over 79
percent of the total HAP emissions from slabstock foam
facilities.I
Several alternatives were identified that either reduce or
eliminate the use of MeCl2 as an ABA in the manufacture of
slabstock foam. The technologies identified were the use of
acetone, hydrocarbons with 5 carbons or less, such as pentane, or
liquid CO2 as an ABA, foaming in a controlled environment, forced
cooling, and chemical modifications. These alternatives are
discussed in the following sections. The optimal solution for
some facilities may be a combination of one or more of the above
alternatives, however, the cost discussions will only address
using individual alternatives.
It should be pointed out that slabstock foam grades of
identical density and firmness made by different chemical or
mechanical techniques do not necessarily have the same strength,
durability, or other quality properties. It is the opinion of
several foam manufacturers that certain technologies discussed in
5-1
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this chapter may diminish the quality of some foam grades.
However, the best way to determine comparability of foam quality
properties is through in-use testing, and no quantification data
has ever been submitted by any industry members to reinforce this
view. Therefore, due to a lack of test data comparing the foam
properties of the same grades of foam made by different methods,
the EPA's analysis assumes that foam properties are comparable,
unless detailed information was provided that stated otherwise.
5.1.1 Acetone or hydrocarbons with 5 carbons or less as ABA
In response to environmental concerns over the use of MeCl2,
Hickory Springs developed and patented a technology in 1992 to
allow the use of acetone as an ABA. One of acetone's biggest
advantages is that it only requires 55 percent (by weight) as
much acetone as MeCl2 to blow the same amount of foam.2 Another
advantage is that acetone typically costs less per pound than
MeCl2. Current estimates of chemical costs for slabstock foam
manufacturers are $0.30/lb for acetone versus $0.40/lb for
MeCl2.3 This factor, combined with the reduced usage, can result
in large chemical cost savings. The chemical cost savings is
somewhat counteracted by the licensing fee. This licensing fee
operates on a graded scale depending on the amount of acetone
used by the facility. For the first 50,000 pounds of acetone
used, the fee is $0.16 per pound, $0.14/lb for the next 75,000
pounds, and $0.12/lb for any additional acetone. This fee is
subject to change with trends in acetone and MeCl2 costs.4
Because of the high flammability of acetone, it is necessary
to make certain equipment modifications in order to use acetone
as an ABA. The largest costs of switching to acetone from MeCl2
are due to this increased flammability. These modifications
include:
The foam tunnel needs to be completely enclosed.
The lighting needs to be explosion-proof.
The motors that run the conveyor need to be moved
outside the foam tunnel (the cost is in moving the
motors and putting on longer shafts).
5-2
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Electric bun saws need to be replaced by
explosion-proof saws.
There must be an auxiliary power generator for the
ventilation fans.
Air flow in the tunnel area must be increased, due
to an insurance requirement.
Storage tanks for acetone must be fire-rated,
completely diked, and placed away from the other
buildings. This modification is a large part of
the conversion cost.
A low-level metering system may be necessary as
some foam formulations only require 1-3 parts per
hundred of acetone, and traditional metering
systems do not go that low.
Hickory Springs estimated the cost of the equipment plus
installation of the above items to be $194,000.5
Acetone is not a HAP, and has recently been delisted as a
VOC (60 FR 31633). The costs of applying this system to the
representative slabstock foam plant are presented in Table 5-1.
All capital, labor, and licensing costs were provided by Hickory
Springs.6
Hydrocarbons with 5 carbons or less, such as pentane or
butane, are currently in use as an ABA alternative by at least
one facility. These chemicals have similar properties as
acetone, including increased flamability over MeCl2. However, it
is important to note that these chemicals may be volatile organic
compounds (VOC), which would reduce the environmental benefits of
switching to them over other options. A detailed analysis of
this technology was not done due to incomplete information.
Retrofit installation costs were provided by one manufacturer as
follows:
Purchased equipment costs $250,000
Direct installation costs $300,000
Indirect installation costs $125,OOP
Total capital investment $675,000
5-3
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TABLE 5-1. REPRESENTATIVE FACILITY COSTS FOR ACETONE AS AN ABA
Capital Investment
Purchased equipment costs3 $161,700
Direct installation costs3 $32,300
indirect installation costs3
Total Capital Investment $194,000
Annual Costs
Direct Costs
Materials13 $-152,600
Utilities0 $5,881
Maintenance materials6 $2,500
Licensing6 $46,460
Maintenance laborf $2,500
Indirect Costs
Capital Recovery51 $27,626
Overhead11 $1,500
Administrative charges1 $7,760
Total Annual Cost $-58,373
Emission Reduction (tons/yr) 325
Cost Effectiveness ($/ton) $-180
a Hickory Springs estimated a total capital investment of
$194,000. The EPA estimated the cost of purchased equipment at
$161,700, and total installation at $32,300.
b 325 tons MeCl2 * 0.55 = 179 tons/yr acetone (358,000 Ibs).
358,000 Ibs * $0.3/lb = $107,400 for acetone/yr
325 tons/yr MeCl2 = 650,000 Ibs
650,000 Ibs * $0.40/lb = $260,000 for MeCl2/yr.
$107,400 - $650,000 = $-152,600 (savings)
c 3 fans * 7.5 hp/fan * 8760 hr/yr = 197,100 hp-h/yr
197,100 hp-h/yr * 0.746 kw-hr/hp-h = 147,037 kw-hr/yr
1992 electricity cost/hr = $0.040/kw-h
147,037 kw-h/yr * $.04/kw-h = $5,881/year electricity cost
d Quoted by D. Sullivan, Hickory Springs Manufacturing Co.
e Licensing fee for 358,000 Ib/yr:
50,000 Ib * $0.16 = $8,000
75,000 Ib * $0.14 = $10,500
233,000 Ib * $0.12 = $27,960
total licensing fee = $46,460
£ Quoted by D. Sullivan, Hickory Springs Manufacturing Co.
9 $194,000 * 0.1424 (7% for 10 yrs) = $27,626
h $2,500 * 0.6 = $1,500
i $194,000 * 0.04 = $7,760
5-4
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5.1.2 Liquid C02 as an ABA
A procedure for using liquid C02 as the ABA in slabstock
foam manufacture called CarDio™ has been developed by the Cannon
Group, and is patented worldwide, available under license by
Foaming Technologies Cardio B.V. There is currently one full
scale CarDio™ unit in operation in the United States, and
another four plants are planned to be installed and in operation
by the end of the third quarter of 1995.7
The largest benefit of CarDio™ is that it completely
eliminates HAP emissions.8 Another benefit is the chemical cost
savings, as C02 is less expensive than MeCl2, and it only
requires 33 percent as much C02 as MeCl2 to produce the same
amount of ABA-blown foam.9
The CarDio™ system operates by adding liquid C02 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.10
The retrofit kit consists of:11
- CO2 metering pump assembly with mass flowmeter
- Polyol/activator booster pump assembly
- C02/polyol premixing unit
- CarDio™ mixing head
- Necessary pipework and valves
- Flushing system
- Laydown device
- Controls
5-5
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The costs of applying this system to the representative
slabstock foam plant, as provided by the vendor, are presented in
Table 5-2. The cost of the retrofit kit for the representative
facility is approximately $375,000, excluding installation.
However, the EPA did receive a comment from one company using
this system that stated they have found the capital costs to be
higher.12 The liquid C02 costs approximately $85 to $120 per ton
depending on usage, and the necessary tank can be rented for $500
per month.13 Not all foam formaulations can be made with the
CarDio™ process, as there is a minimum C02 requirement to attain
a stable froth. This amount will vary depending on the size of
the machine, but for this analysis a cut-off point of 3 ppm MeCl2
was used to determine which foam grades at the representative
facility could not be made using CarDio™14 The pouring time was
assumed to be the same for CarDio™ as for Maxfoam™. The
increased energy costs, estimated at 100 to 120 KW, are for the
electricity to run the booster pump assembly, and to keep the C02
cool. There is a licensing fee, which is 1 percent of the
chemical cost for Cardio™ made foam, which the industry
representative stated was $0.72/lb.15 There were no increased
labor or maintenance costs identified.16
5.1.3 Foaming in a Controlled Environment
The idea that foam expands more under conditions of
decreased atmospheric pressure is not new. 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.
5-6
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TABLE 5-2. REPRESENTATIVE FACILITY COSTS FOR CARDIO™
Capital Investment
Purchased equipment costs3 $405,000
Direct installation costsb $24,300
indirect installation costs0 $0
Total Capital Investment $429,300
Annual Costs
Direct Costs
Materials'* $-235,832
Utilities6 $3,600
Carbon dioxide tank rentalf $6,000
Licensing9 $66,528
Indirect Costs
Capital Recovery11 $61,132
Administrative charges1 $17,172
Total Annual Cost $-81,400
Emission Reduction (tons/yr)j 309
Cost Effectiveness ($/ton) $-263
a $375,000 +[375,000 * (0.03 tax + 0.05 freight)] = $405,000
b $405,000 * 0.06 = $24,300
c Included in Cannon's licensing agreement
d 325 tons MeCl2 * .33 = 107 tons CO2
107 tons C02 * $102.5/ton = $10,968
308.5 tons MeCl2/yr = 617,000 Ibs
617,000 Ibs * $0.40/lb = $246,800 for MeCl2/yr
$10,968 - $246,800 = -$235,832
e Additional electricity costs: 100 kw * 900 hr = 90,000 kw-h
90,000 kw-h * $0.04/kw-h = $3,600/yr
£ tank rental $500/month
9 (7,000 Ibs foam * .66) * 2000 = 9,240,000 Ibs foam
$0.72/lb * 9,240,000 Ibs = $6,652,800 * 0.01 = $66,528
h $429,300 * 0.1424 (7% for 10 yrs) = $61,132
1 $429,300 * 0.04 = $17,172
3 HAP emission reduction replaced by around 108 tons/yr of CO2. Only 95
percent reduction as not all foam will be made using C02.
5-7
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5.1.3.1 Variable Pressure Foaming (VPF)
The VPF system technology is owned by Prefoam, and Foamex
International is an equity holder in the company and has
contributed a patent (U.S. 4,777,186) to Prefoam. The patent
covers the use of foaming in a chamber with overpressure. The
process is available for license from Prefoam. 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. The
mixhead is outside the chamber, and the chemicals are pumped into
the chamber, into a trough, and onto the foam machine
fall-plates. The enclosed chamber is fitted with a fan which
evacuates the vapors generated during the reaction and pumps them
through carbon bed absorbers. When the desired length of foam is
produced, an automatic cut-off saw cuts the bun. This bun is
then passed into a second airlock chamber, which is at the same
pressure as the foaming chamber. This airlock chamber is fitted
with a second fan and carbon bed absorber. Once the cut bun has
completely entered the airlock system, the airlock is closed from
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.
The main procedural advantages over a conventional Maxfoam
line are that the system is fully automated, and the pressure can
be adjusted and kept consistent from run to run. This automation
results in products with density and hardness properties that are
easily reproducible. Variable pressure foaming allows for the
total elimination of ABAs. In addition, the carbon absorbers in
the foaming and airlock chambers can be expected to practically
eliminate the toluene diisocyanate (TDI) emissions (5 tons/yr
reported by industry in ICR responses) from the foaming
process .17'18
The conversion of an existing facility to VPF will involve
the installation of a new foaming chamber, revisions to the
5-8
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existing line, and an extended shutdown period. Cost information
for VPF was obtained directly from Foamex.19'20 The total
capital investment for conversion of a Maxfoam line to VPF was
estimated at between $4.0 and $5.0 million dollars ($4.5 million
was used for the representative facility). This estimate
included installation and start-up costs. The higher end of the
range would be for long block (200 ft) production. The cost can
be reduced by shortening block length or lowering of overpressure
or vacuum required.21 However, this is offset somewhat by a
savings in chemical costs due to the elimination of the need for
MeCl2 and for labor savings due to the increased automation.22
The costs of applying this system to the representative
slabstock foam plant are presented in Table 5-3. Other potential
cost savings for this system were identified but not included in
the analysis due to insufficient information. For some
facilities there would be a cost savings from the elimination of
state and federal taxes imposed on ABA's. There may also be
reduction or elimination of premium polyols such as high
resilience and polymer grafted polyols. This may result a cost
savings of $.20 per pound of polyol used. There is also a
reduction in the top skin thickness when VPF is used, resulting
in improved prime foam yield. The savings will vary with
facility production.23
5.1.3.2 Controlled Environment Foaming (CEF)
FOAM ONE company has developed and patented a polyurethane
foam manufacturing process, which is called Controlled
Environment Foaming (CEF). The CEF process is a discrete block
production method which uses a containment vessel to control the
pressure and temperature during foaming.
The system consists of two molds (as large as 10 feet long
by 9 feet wide by around 4 feet tall). One mold is inside a
pressure-controlled containment vessel, and the other is outside
this vessel. During production, foam is poured into the mold
inside the containment vessel, which is lined with a flexible
polyethylene film liner. The foam reaction is allowed to take
place under the controlled conditions of the containment vessel.
5-9
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TABLE 5-3. REPRESENTATIVE FACILITY COSTS FOR
VARIABLE PRESSURE FOAMING
Total Capital Investment*1
Annual Costs
Direct Costs
Materials13
Utilities0
labord
Indirect Costs
Capital Recovery6
Overhead^
Administrative charges3
Total Annual Cost
Emission Reduction (tons/yr)
Cost Effectiveness ($/ton)
$4,500,000
$-260, 000
$15, 600
$-23,100
$640,800
$-13,860
$180,000
$539,440
325
$1,660
a Provided by Foamex. Assumed to include all direct and indirect
installation costs.
b 325 tons MeCl2 * 2000 Ibs/ton * $0.40/lb = $260,000
c Provided by Foamex.
d Provided by Foamex
e $4,500,000 * 0.1424 (7% for 10 yrs) = $640,800
£ $-23,100 * 0.6 = $-13,860
9 $4,500,000 * 0.04 = $180,000
5-10
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While the foaming is occurring in the mold in the containment
vessel, the finished block in the other mold is removed, and the
mold is prepared for production of the next block. This
operation allows the production of up to 10 blocks per hour,
which is equivalent to around 2 linear feet per minute.24
In addition to the complete elimination of ABA, there are
other advantages to 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.25
While there are low energy requirements and low maintenance
expenses, the production rate is considerably slower than a
traditional Maxfoam line.26 Therefore, it would take longer to
make the same amount of foam on a CEF machine. A possible
approach is to produce only the foams requiring ABA on a CEF
machine, while continuing to produce other foams on a Maxfoam
machine. For the representative facility cost calculations, it
was assumed that the 6,760 tons of foam produced with an ABA
would be produced on the CEF machine, and that the 740 tons that
did not require ABA would continue to be produced on a Maxfoam
machine. It was calculated that the representative slabstock
foam plant would need to operate 16 hours/day using the CEF
system to produce the same amount of formerly ABA-blown foam.
The costs of applying this system to the representative
slabstock foam facility are presented in Table 5-4. The
estimated cost of the CEF equipment provided by the vendor was
$250,000. In the annual cost calculations, it was assumed that 2
additional operators were needed, and that the energy
requirements were approximately equal to a Maxfoam line.27 It
is assumed that any additional maintenance costs for the CEF
system would be offset by the reduced maintenance on the Maxfoam
line due to the reduction in its use.
5-11
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TABLE 5-4. REPRESENTATIVE FACILITY COSTS FOR
CONTROLLED ENVIRONMENT FOAMING
Capital Investment
Purchased equipment costs3
Direct installation costsb
indirect installation costs0
Total Capital Investment
Annual Costs
Direct Costs'1
Materials6
Operating laborf
Supervisory labor9
Utilities11
Indirect Costs
Capital Recovery1
Administrative chargesj
Total Annual Cost
Emission Reduction (tons/yr)
Cost Effectiveness ($/ton)
$270, 000
$54, 000
$13,500
$337,500
$-260, 000
$144,000
$21,600
$12,960
$48,060
$13,500
$-19,880
325
$-61
a $250,000 + [250,000 * (0.03 tax + 0.05 freight)] = $270,000
b $270,000 * (0.14 hardware and erection + 0.04 electrical +
0.02 piping) = $54,000
c $270,000 * (0.02 start-up +0.03 contingencies) = $13,500
a Any additional maintenance costs for the CEF system were
assumed to be offset by the reduced maintenance on the Maxfoam
line due to the reduction in its use
e Savings from the elimination of methylene chloride as ABA
£ 2 operators * 16 hrs/day * 225 days/yr * $20/hr = $144,000/yr
9 $144,000 * 0.15 = $21,600/yr
h Additional electricity costs: 120 kw * 12 hr/day * 225 days/yr
= 324,000 kw-h/yr
324,000 kw-h * $0.04/kw-h = $12,960/yr
1 $337,500 * 0.1424 (7 percent for 10 years) = $48,060
3 $337,500 * 0.04 = $13,500
5-12
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5.1.4 Forced-Cooling
The two primary functions of an ABA are to reduce the
density of the foam and to provide cooling effects. Increasing
the amount of water in the formulation will reduce the foam
density, but increases the exothermicity of the reaction, which
can lead to bun scorching or even auto-ignition after the bun
exits the foam tunnel. The cooling of the bun by mechanical
means can eliminate this potentially dangerous situation, while
allowing the production of low density foams.
Information was obtained and reviewed on two different
patented types of forced-cooling techniques that are in
full-scale operation: Enviro-Cure® by Grain Industries and
Rapid-Cure® by General Foam. The EPA is also aware of other
companies experimenting with similar forced cooling processes.
Since the Enviro-Cure® technology is fully operational at several
facilities across the United States, the following discussion
focuses on this system.
Many of the Enviro-Cure® systems in operation in the United
States are installed on Vertifoam® lines. Vertifoam® is a
vertical, rather than horizontal foam line.28 Grain is the only
company currently using Vertifoam® in the United States. Grain
has also retrofit a traditional Maxfoam system, designed and
installed by Cannon USA, with Enviro-Cure® to produce foam blocks
up to 60 feet long. This type of retrofit is described in the
following section, but the general Enviro-Cure® principle is
applicable to the Vertifoam® system as well.
The Maxfoam Enviro-Cure® system is an enclosure with an
associated conveyor system, which is put in place after the
traditional slabstock foam pouring line. The cut blocks from the
Maxfoam machine are transferred to the unit, where a special
multi-slat conveyor system transports the block through the
cooling enclosure.29 There is a slight delay before th$ foam
enters the enclosure to allow the block to stabilize prior to
cooling. Controlled air is passed through the block by means of
a vacuum process after the blocks are inside the enclosure. The
vacuum process cools the blocks by convection and conduction.30
5-13
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The heat transfer to the cooling process air is handled by
exhausting some air to the atmosphere, and by recirculating some
back through the Enviro-Cure® process. Airflow is controlled
over the whole length of the block to ensure a consistent flow
through the block for even cooling. This air flow consistency
results in a foam bun that is more uniform, meaning that the
properties are more consistent between the outer portion of the
bun and the core.31
There are some differences in the forced cooling systems.
The Enviro-Cure® system for Vertifoam® is limited to producing
short blocks because of the Vertifoam® block length limitations.
However, Enviro-Cure® can be used on a Maxfoam system for
producing blocks of any given length as set prior to
construction. Rapid-Cure® can be used both in-line to produce
continuous blocks, or off-line to produce blocks limited to the
length of the off-line conveyor. The basis for choosing one
system over the other depends at least partly on the type of
business in a specific plant and the plant layout. General Foam
states that the projected capital costs for Rapid Cure® are less
than for Enviro-Cure®, varying mainly with the size of carbon bed
used, which in turn depends on production rates and amounts.32
No other detailed costs were provided. Enviro-Cure® provides no
exhaust purification.
The cost information used for the representative facility
was obtained from a paper written by Cannon-Viking, the
manufacturers of the Enviro-Cure® machine.33 The cost of the
Enviro-Cure® system will depend upon the layout of the facility,
and can range from $500,000 to 2.2 million dollars. The cost
depends mainly upon facility layout and the length of the buns to
be produced. For a complete Maxfoam conversion, the cost can
range from 1 to 2.2 million dollars.34'35 A cost of $2 million
was used for the representative facility, assuming that the
retrofit would need to be extensive. This 2 million dollars
included all direct and indirect installation costs. EPA assumed
that all the foam requiring ABA would be made using the Enviro-
Cure® system, so there would also be material cost savings from
5-14
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the elimination of MeCl2. However, the MeCl2 savings will be
offset by increased formulation costs in many cases. To maintain
equal density in the absence of MeCl2/ additional water is used,
which requires the use of more TDI. The need for additional TDI
is reduced somewhat by either using a lower TDI index, or by
adding other additives to maintain the lower IFD associated with
the use of MeCl2.36 These additives are discussed in the next
section of this report. An industry representative indicated
that analysis has indicated that the increased formulation costs
were approximately equal to the savings in MeCl2 cost.37
As mentioned previously, the process is patented by Grain,
and its use will entail a licensing fee of 1.5 percent of the raw
material costs for all Enviro-Cured foams. The costs for the
representative facility are presented in Table 5-5.
5.1.5 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 the amount of ABA used for foam
softening.38 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 formation of secondary
crosslinkers such as allophanates and biurets. One of the
additives studied softens foam by changing the reactivity of the
diisocyanate groups of the TDI isomers so that the resulting
polyurea segments of the foam are altered.39
These chemical modification technologies can allow the
elimination of ABA for foams with densities greater than
1.0 lb/ft3, and IFDs greater than 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
5-15
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TABLE 5-5. REPRESENTATIVE FACILITY COSTS FOR ENVIRO-CURE®
Capital Investment
Purchased equipment costs3 $2,000,000
Total Capital Investment $2,000,000
Annual Costs
Direct Costsb $0
Utilities0 $18,400
Materials6 $0
Licensing Fee6 $148,219
Indirect Costs
Capital Recoveryf $284,800
Administrative chargesg $80,000
Total Annual Cost $531,419
Emission Reduction (tons/yr) 325
Cost Effectiveness ($/ton) $1, 635
a Includes direct and indirect installation costs
b There were no additional labor or maintenance costs identified
c Based on Enviro-Cure® paper entitled "Cannon Enviro-Cure®
Equipment Applied to the Vertifoam and Maxfoam Processes."
d Material cost savings of $260,000 is offset by increased polyol costs (see
text)
e 0.015 * $9,881,263 = $ 148,219
f $2,000,000 * 0.1424 (7% at 10 yrs) = $284,800
9 $2,000,000 * 0.04 = $80,000
5-16
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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 MeCl2, 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, 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. The specific needs will depend on the existing situation
at each facility. Estimates of purchased equipment costs for
these improvements ranged from $5,000 to $50,000. For the
representative facility costs, it was assumed that the following
improvements are necessary:
Storage tank $ 5,000
Plumbing $ 2,000
Pump $ 4,000
Metering system $12,500
TOTAL $23,500
The costs are based on information provided by the PFA-member
chemical suppliers.40
The annual costs will include the material cost of the
chemical alternative (minus the cost of the MeCl2 no longer
needed), and the capital recovery of the necessary improvements.
The chemical costs and ABA reduction potential of these chemical
technologies are different for each foam grade. Grade-specific
information provided by PFA-member chemical suppliers was used.
Table 5-6 compares the standard formulations and the chemical
alternative formulations. Arithmetic averages of the information
5-17
-------
provided by the chemical suppliers were used to calculate the
totals in Table 5-6. The chemical alternatives represented
include Dow's XUS15216.00 polyol, Arco's DP-1022 additive and
F-1500 polyol, OSi's GEOLITE®91 and 201 modifiers, and
Goldschmidt's Ortegol® modifier.
The total representative facility costs for using chemical
alternatives are shown in Table 5-7. Since much of the
information related to chemical alternatives was claimed as
confidential business information (CBI), there is not an
attachment related to this technology.
5.2 EQUIPMENT CLEANERS
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 six tons of emissions (less than 1 percent of total
slabstock foam HAP emissions).41 The two alternatives
identified to eliminate these HAP emissions were steam cleaning
and non-HAP cleaners. To make the costs as conservative as
possible, it was assumed that no effort is made to prevent the
evaporation of the MeCl2 used for cleaning. The portion that
does not evaporate (see Table 3-3) must be disposed of as
hazardous waste.
5.2.1 Steam Cleaning
Three flexible polyurethane foam slabstock plants were
identified in the ICR database that use steam to flush hoses,
mixheads, and other pouring equipment. All three identified were
owned by Ohio Decorative Products, and it was indicated that this
is becoming a company-wide practice. The costs of switching
varied between the plants contacted, as one utilized steam
already produced on-site for another function (producing rebond
foam), while the other had to purchase a generator specifically
for steam production.42'43 The reacted foam scrap from both
operations was collected and shredded for use in either the on-
site rebond operation, or sent off-site to a rebond operation.
For the facility that already had a source of steam, the
conversion cost was only about $200, which was mostly for
5-18
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5-19
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TABLE 5-7. REPRESENTATIVE FACILITY COSTS FOR
CHEMICAL MODIFICATIONS
Capital Investment
Purchased equipment costs3 $25,380
Direct Installation Costsb $5,076
Indirect Installation Costsc $1,269
Total Capital Investment $31,725
Annual Costsd
Direct Costs
Materials6 $270,397
Indirect Costs
Capital Recovery^ $4,518
Administrative charges3 $1,269
Total Annual Cost $276,167
Emission Reduction11 (tons/yr) 147
Cost Effectiveness ($/ton) $1, 879
a $23,500 + [23,500 * (0.03 tax + 0.05 freight)] = $25,380
b $25,380 * (0.14 handling and erection + 0.04 electrical + 0.02
piping) = $5,076
c $25,380 * (0.02 start-up +0.03 contingency) = $1,269
d There are no additional annual costs for operating labor,
maintenance, utilities, or waste treatment.
e $11,168,420 - $10,898,023 = $270,397 (See Table 5-6)
f $31,725 * 0.1424 (7% for 10 years) = $4,518
g $31,725 * 0.04 = $1,269
h 325 tons - 178 tons = 147 tons (see Table 5-6)
5-20
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hoses.44 The facility using a gas-fired mobile steam generator
estimated their costs to be between $3,000 and $5,000.45
The use of steam for equipment cleaning may be a cost
effective method of HAP emission reduction. However, no one was
able to provide any estimate of the additional energy costs
needed to generate the steam, the costs of maintenance materials,
labor, and replacement parts, or the amount of additional
operating labor needed. Since the items listed above could make
up a large portion of the total annual costs, and the fact that
no information, or statements that could lead to informed
assumptions, was available, representative facility costs were
not developed for steam cleaning.
5.2.2 Non-HAP Cleaners
There were several alternative cleaners identified that were
not HAP-based. The solvents they contain are furanone, cyclic
amide, ethyl ester, other esters, N-Methylepyrrolidone (NMP), and
D-limonene.46-47
All three cleaners identified, Strip-TZ®, Foamflush, and
Dynasolve, are direct replacements for MeCl2, meaning that they
typically require no equipment or operational changes. This is
an advantage as there are no additional utility, maintenance, or
operational costs. However, the manufacturers discourage the use
of seals and o-rings made of certain materials such as PVC,
neoprene, and butyl rubber with non-HAP cleaners.48
All three non-HAP solvent-based cleaners eliminate HAP
emissions, but the solvents they contain may still be classified
as VOC. Like the non-HAP mixhead flushes discussed in the molded
foam section, 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.
The costs of applying these products to the representative
slabstock foam plant are presented in Table 5-8. Approximately
the same volume of non-HAP cleaners is needed as would otherwise
be needed of MeCl2. These non-HAP products are more expensive
than MeCl2 on a volume basis. The three vendors of non-HAP
5-21
-------
cleaners contacted provided costs ranging from $310 to $1,375 per
55-gallon drum, while 55 gallons of MeCl2 costs approximately
$175 (at $0.25 per pound).49 For the representative facility
costs, an average cost of $919 per drum of the non-HAP cleaner
was used. In calculating the representative facility costs, it
is assumed that the non-HAP products are reused 3 times, meaning
only around 370 gallons (6.7 drums) are needed, as compared to
the equivalent of 20 drums of MeCl2.
5-22
-------
TABLE 5-8. REPRESENTATIVE FACILITY COSTS FOR NON-HAP CLEANERS
Capital Investment3
Total Capital Investment $0
Annual Costs
Direct Costs3
Materials13 $2,009
Waste treatment0 $-1,320
Indirect Costs $0
Total Annual Cost $689
Emission Reduction3 (tons) 4.5
Cost Effectiveness ($/ton) $153
a As discussed above, since these products are direct
replacements for MeCl2, there were no capital (equipment or
installation) costs identified. There were no additional
annual costs for labor or maintenance identified.
b Material costs were calculated as follows:
cost of MeCl2: (17 drums @ $244/drum) = $4,148/yr
cost of alternative: (6.7 drums @ $919/drum) = $6,157/yr
$6,157 - $4,148 = $2,009/yr
c Waste treatment costs were calculated as follows:
MeCl2 : (17 drums * .10) @ $800/drum = $l,360/yr
altern. : (6.7 drums * .10) @ $60/drum = $40/yr
This assumes that 10% of these substances will be
non-recoverable, due to contamination, and will need
to be properly disposed of.
d HAP emissions will be replaced by a small amount of VOC
emissions from the use of these products
5-23
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5.3 REFERENCES FOR CHAPTER 5.0
1. A. Williams, EC/R Inc., to D. Svendsgaard, EPA:ESD:OCG.
February 10, 1995. Non-confidential summary of Flexible
Polyurethane Foam Information Collection Request (ICR) Data.
2. Telecon: P. Norwood, EC/R Inc., to D. Sullivan, Hickory-
Springs Manufacturing Co. July 14, 1993.
3. Telecon: A. Williams, EC/R Inc., to D. Sullivan, Hickory
Springs Manufacturing Co. May 7, 1994.
4. Reference 3.
5. Telecon: A. Williams, EC/R Inc., to D. Sullivan, Hickory
Springs Manufacturing Co. May 6, 1994.
6. Reference 3.
7. B. Collins, Cannon U.S.A., to A. Williams, EC/R Inc. June
9, 1995. Facsimile Transmitting Comments on the May 1995
preliminary draft of the "Flexible Polyurethane Foam
Emission Reduction Technologies Cost Analysis."
8. Florentine, C., T. Griffiths, M. Taverna, and B. Collins.
Auxiliary Blowing Agent Substitution in Slabstock Foams.
Paper produced by Cannon. Received by EC/R Inc. on June 15,
1994.
9. B. Collins, Cannon USA, to A. Williams, EC/R Inc. June 15,
1994. Letter transmitting information on the CarDio™
Process.
10. Reference 8.
11. Reference 9.
12. S. Watson, Carpenter Co., to S. Wyatt, EPA:OAQPS:BSD. July
10, 1995. Letter transmitting comments on the May 1995
preliminary draft of the "Flexible Polyurethane Foam
Emission Reduction Technologies Cost Analysis."
13. Reference 9.
14. Reference 7.
15. Reference 7.
16. Telecon: A. Williams, EC/R Inc., to B. Collins, Cannon USA.
July 19, 1994.
17. L. Spellmon, Foamex, to B. Jordan, EPA:ESD. October 25,
1993. Letter discussing Variable Pressure Foaming (VPF).
5-24
-------
18. R. Hay, Foamex International Inc., to A. Williams, EC/R Inc.
June 1, 1995. Letter transmitting comments on the May 1995
preliminary draft of the "Flexible Polyurethane Foam
Emission Reduction Technologies Cost Analysis."
19. L. Spellmon, Foamex, to A. Williams, EC/R Inc. July 7,
1994. Letter transmitting cost information on the variable
pressure foaming technology.
20. Reference 18.
21. Reference 18.
22. Reference 18.
23. Reference 18.
24. S. Carson. Controlled Environment Foaming: Manufacturing a
New Generation of Polyurethane Foam. Prepared for FOAM ONE.
25. Reference 24.
26. Telecon: D. Ramazzotti, Edge-Sweets Co., to A. Williams,
EC/R Inc. July 1, 1994.
27. Telecon: A. Williams, EC/R Inc., to D. Ramazzotti, Edge-
Sweets Co. July 20, 1994.
28. B. Collins, and C. Fawley. Cannon Enviro-Cure® Equipment
Applied to the Vertifoam and Maxfoam Processes. Presented
to the Polyurethanes World Congress 1993 - October 10-13,
1993. p. 176.
29. B. Collins, and C. Fawley. Cannon Enviro-Cure® Equipment
Applied to the Vertifoam and Maxfoam Processes. Presented
to the Polyurethanes World Congress 1993 - October 10-13,
1993. p. 179.
30. B. Collins, and C. Fawley. Cannon Enviro-Cure® Equipment
Applied to the Vertifoam and Maxfoam Processes. Presented
to the Polyurethanes World Congress 1993 - October 10-13,
1993. p. 180.
31. B. Collins, and C. Fawley. Cannon Enviro-Cure® Equipment
Applied to the Vertifoam and Maxfoam Processes. Presented
to the Polyurethanes World Congress 1993 - October 10-13,
1993. p. 181.
32. H. Stone, General Foam, to D. Svendsgaard, EPA:ESD:OCG.
December 20, 1994. Letter transmitting comments on EPA's
draft cost analysis.
5-25
-------
33. B. Collins, and C. Fawley. Cannon Enviro-Cure® Equipment
Applied to the Vertifoam and Maxfoam Processes. Presented
to the Polyurethanes World Congress 1993 - October 10-13,
1993.
34. B. Collins, and C. Fawley. Cannon Enviro-Cure® Equipment
Applied to the Vertifoam and Maxfoam Processes. Presented
to the Polyurethanes World Congress 1993 - October 10-13,
1993. p. 182.
35. M. Crawford, Grain Industries, to A. Williams, EC/R Inc.
June 9, 1995. Letter transmitting comments on the May 1995
preliminary draft of the "Flexible Polyurethane Foam
Emission Reduction Technologies Cost Analyis."
36. Reference 33.
37. Reference 33.
38. Flexible Polyurethane Foam (Slabstock) Assessment of
Manufacturing Emission Issues and Control Technology,
Polyurethane Foam Association, May 17, 1993.
39. Meeting notes from June 9, 1994 meeting between PFA-member
chemical suppliers and the EPA, to discuss chemical
alternatives to ABAs.
40. Reference 39.
41. Reference 1.
42. Telecon: A. Williams, EC/R Inc., to B. Janicek, Flexible
Foam Products. May 17, 1994.
43. Telecon: A. Williams, EC/R Inc., to G. Williams, Nu-Foam
Products. May 18, 1994.
44. Reference 43.
45. Reference 43.
46. Dynaloy, Inc. Material Safety Data Sheet on Dynasolve CU-5
(XUS-5). Transmitted via facsimile to A. Williams, EC/R
Inc., from S. Riddick, Dynaloy, Inc. July 20, 1994.
47. C. McDaniel, Urethane Technologies, Inc., to A. Williams,
EC/R Inc. April 28, 1994. Information sheet on Strip-TZ®
biodegradable solvent.
48. Reference 47.
49. Reference 47.
5-26
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6 . 0 SUMMARY
Tables 6-1 and 6-2 summarize the representative facility
costs for the emission reduction technologies included in this
analysis for molded and slabstock foam, respectively.
Conclusions of this analysis are discussed in this section.
The technologies investigated can be grouped into three
basic categories: (1) chemical substitutions, (2) alternative
process equipment, and (3) combinations of (1) and (2). The
implementation of these types of technologies will result in
partial or total changes in the existing polyurethane foam
production methods.
There are special challenges in attempting to estimate the
costs of these changes. In general, the capital costs of
conversion were readily obtainable. However, several elements of
the annual cost were particularly difficult to obtain or
estimate. These include the operating labor, utility costs, and
maintenance and repair costs. Therefore, the level of
uncertainty in some of the annual cost estimates is relatively
high.
Two other considerations of these process-modifying
technologies that are extremely difficult to incorporate into
costs are (1) site-specific applicability problems, and
(2) changes in product quality. A process modification may not
be technically feasible for the products and processes at one
facility, while it may work quite well at a facility producing a
relatively similar foam product.
6.1 MOLDED FOAM
The three emission source types at molded foam facilities
studied in this analysis (mixhead flushing, mold release agents,
and foam repair) account for approximately 88 percent of the
total HAP emissions reported in the ICR responses.1 This
analysis shows that there are cost-effective options for
completely eliminating HAP emissions from these three sources at
molded foam facilities. However, as noted above, there may be
6-1
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limitations, due to product differences, that cannot be
adequately included in a simplified cost analysis.
The telephone conversations with vendors and foamers
revealed that small molded foam facilities that continue to use
large amounts of HAP's tend to be extremely specialized. Each
has unique technical and economic considerations that must be
considered in the application of many of the technologies
studied. Therefore, a technology may be generally considered to
be cost-effective, but it may not be truly cost effective for a
specific molded foam facility.
For mixhead flushing, this analysis shows three options with
cost-effectiveness values less than $800 per ton that totally
eliminate the use of HAPs for mixhead flushing. However, two of
the three, non-HAP flushes and self-cleaning mixheads, are not in
widespread use in this industry. This could be an indicator that
there are technical problems in their application, or that there
are prohibitive costs that are not reflected in this analysis.
Another explanation offered by vendors was that these options are
relatively new and just have not had time to penetrate the
market. Also, while this analysis shows the high-pressure
mixheads to be cost-effective, there are technical limitations
for some product lines, and many small molded foam companies are
not able to bear the initial capital investment.
There are also many technical challenges associated with the
elimination of HAPs in foam repair adhesives and mold release
agents. However, the extensive utilization of non-HAP products
for these functions leads to the conclusion that the technical
hurdles can be overcome.
6.2 SLABSTOCK FOAM
The emission source types included in this analysis for
slabstock foam (ABA usage, equipment cleaning, and fabrication)
make up over 99 percent of the total HAP emissions reported in
the ICR responses.2 This analysis shows that cost-effective
solutions exist to completely eliminate HAP emissions from these
sources, which would virtually eliminate all HAP emissions at
slabstock foam facilities.
6-4
-------
The use of equipment cleaning technologies that use no HAP's
is common. The use of non-HAP and water-based adhesives is also
widespread, although challenges remain in the production methods
for these products. For these two emission sources, the EPA
believes that it can be concluded that HAP's could be totally
eliminated with demonstrated, cost-effective technologies.
However, the total elimination of HAP ABA presents numerous
problems that are not reflected in the representative facility
costs. Many of these problems are associated with foam product
quality. For instance, a complete range of foam grades can be
produced using forced-cooling techniques without any ABA.
However, it is generally agreed that the low-density foams
produced in this manner would not be of an acceptable quality for
the United States market.
Proponents of variable pressure foaming, controlled
environment foaming, and liquid C02 as an ABA maintain that the
foam quality of all grades will be acceptable. However, since
none of these technologies has been in full-scale operation in
the United States for an extended period of time, it is too early
to draw conclusions regarding the technical feasibility of
operation, or the acceptability of products in the United States
market.
Acetone as an ABA is the only alternative studied in this
analysis that (1) completely eliminates HAP ABAs, and (2) has
been demonstrated in full-scale production in the United States.
However, there are limitations in the application of this
technology. One is the increased safety hazard due to the
flammability of acetone. Another is that this is not a
"pollution prevention" option, since MeCl2 emissions are being
replaced by acetone emissions. This may be of less concern if
acetone is no longer considered to be photochemically reactive.
Pentane as an ABA has also been demonstrated in the United
States, but it was not included in this analysis.
Chemical alternatives have been widely demonstrated in the
reduction of HAP emissions from the use of ABAs. The costs for
chemical alternatives probably represent the most realistic
6-5
-------
estimate of costs in this analysis. These costs take into
account technical limitations and product quality, since the
formulations used are representative of actual formulations
currently used in the industry.
The fundamental conclusion that can be drawn from this
preliminary analysis is that cost-effective solutions that
essentially eliminate HAP emissions from flexible polyurethane
foam facilities are available. Technical feasibility and product
quality issues will need to be addressed, but they do not appear
to be insurmountable at this time.
6-6
-------
6.3 REFERENCES FOR CHAPTER 6.0
1. A. Williams, EC/R Inc., to D. Svendsgaard, EPA:ESD:OCG.
February 10, 1995. Non-confidential summary of Flexible
Polyurethane Foam Information Collection Request (ICR) Data.
2. Reference 1.
6-7
-------
TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1. REPORT NO.
EPA-453/R-95-011
2.
4. TITLE AND SUBTITLE
Flexible Polyurethane Foam Emission Reductic
Cost Analysis
m Technologies
7. AUTHOR(S)
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
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
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
September 1996
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D6-0008
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This document describes the costs of hazardous air pollutant emission reduction technologies for
flexible polyurethane foam production facilities. The information in this document provides the
background for the estimate of impacts for the proposed National Emission Standards for Hazardous Air
Pollutant Emissions from Flexible Polyurethane Foam Production (40 CFR 63, Subpart III).
17.
KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Ah- Pollution
Hazardous air pollutants
Emission reduction
Flexible Polyurethane Foam
18. DISTRIBUTION STATEMENT
Release Unlimited
b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group
Hazardous air pollutants
19. SECURITY CLASS (Report) 21. NO. OF PAGES
Unclassified 86
20. SECURITY CLASS (Page) 22. PRICE
Unclassified
EPA Form 2220-1 (ReT. 4-77) PREVIOUS EDITION IS OBSOLETE
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