United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Tnangle Park, NC 27711
EPA-456/B-98-001
December 1998
www. epa. gov 'tin uatw 'foam'foampg. html
EPA
Plain Language Guide to the Flexible
Polyurethane Foam Production NESHAP
40 CFR 63, Subpart III
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Plain Language Guide to the
Flexible Polyurethane Foam Production
NESHAP
40 CFR 63, Subpart III
Prepared for:
Information Transfer and Program Integration Division (ITPID)
Program Implementation and Review Group (PIRG)
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
Prepared by:
EC/R, Incorporated
2327 Englert Dr., Suite 100
Durham, NC27713
December 31, 1998
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What is the legal status of this guide?
The Office of Air Quality Planning and Standards (OAQPS) and the Office of Enforcement
and Compliance Assistance (OECA) of the U. S. Environmental Protection Agency (EPA)
have reviewed this document and approved it for publication.
When using this document, remember that it isn't legally binding and doesn't replace the final
rule - "National Emission Standard for Hazardous Air Pollutants for Flexible Polyurethane.
Foam Production" (published in the Federal Register, 10/7/98, 63 FR 53980) or any State,
local or tribal rules that may apply to your facility.
This document isn't intended, nor can you rely on it, to create any rights enforceable by any
party in litigation with the United States, The EPA may change this document at any time
without public notice.
This document includes only requirements from the final rule published in the Federal Register
10/7/98. 63 FR 53996.
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Thank You
This document was prepared by a joint partnership among the Environmental Protection
Agency (EPA, or we), State and local agencies for air pollution control, trade associations, and
organizations who produce flexible polyurethane foam. At the time of publication, the
development team had the following members:
Shaun Burke, EPA Region V
Joelle Burleson, NC DEQ
Umesh Dhloakia, EPA, Region II
Mozafar Ghaffari, EPA. Region II
Chrys Lemon, Mclntyre Law Firm
Pern' Luckett. The Murawski Group
Maria Malave. EPA. OECA. OC
Janet McDonald, EC/R Incorporated
Jim Mclntyre, Mclntyre Law Firm
Phil Norwood. EC/R Incorporated
Barrett Parker, EPA, OAQPS. ITPID
Lou Peters, Polyurethane Foam Association
Stephen P. Risotto. Halogenated Solvents Industry Alliance. Inc.
David Svendsgaard, EPA, OAQPS, ESD
Jim Szykman. EPA, OAQPS. ESD
Dianne Walker. EPA. Region III
Ingrid Ward EPA. OAQPS. ITPID
Man Ann Warner. EPA. OAQPS. ITPID
We thank those people for their participation. Their technical insights, experiences, and
suggestions were essential to this guide's development.
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Contents
Chapter 1 - Introduction
Why should I use this document? 1
Is there anything I should know before using this document? 1
How do I get copies of this document? 1
We want your feedback 2
Chapter 2 - What this rule covers - An Overview
Why was the rule written? 4
How do I know if I'm subject to this rule0 4
When do 1 need to comply? 5
Are any processes exempt0 5
How do I know if 1 have a covered process0 6
Does this rule apply to fabrication of foam? 6
What are my requirements for slabstock foam0 6
What are my requirements for molded and rebond foam0 7
Chapter 3 - Complying with requirements for slabstock foam
What do the Slabstock sections of the rule cover? 8
What is exempt under these sections of the rule? 10
What compliance options do I have? 10
What monitoring must I do? 11
What records must I keep? 12
What reports must 1 submit? 13
iii.
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Contents
What test methods am I required to use? 14
How do I show compliance? 14
Is an inspection checklist available? 14
Chapter 4 - Complying with requirements for molded foam
What does the Molded section cover? 66
What is exempt under this section? 66
What compliance options do I have? 68
What monitoring must I do? 68
What records must I keep? 69
What reports must I submit? '. 69
How do I show compliance? 69
Is an inspection checklist available0 69
Chapter 5 - Complying with requirements for rebond foam
What does the Rebond section cover0 72
What is exempt under this section? 72
What compliance options do I have? . .' 74
What monitoring must I do? 74
What records must I keep? 75
What reports must I submit? 75
How do 1 show compliance? 75
Is an inspection checklist available? 75
iv
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Contents
Chapter 6 - Calculations and procedures
How do I calculate Hazardous Air Pollutants used (HAP,^ to see if I'm
exempt from the rule? 77
How do I calculate HAP Auxiliary Blowing Agent (ABA)
formulation limit for a grade of foam? 80
How do I calculate allowable HAP ABA emissions to comply using
the emission point specific limit? 82
If I'm complying using the emission point specific limit without a recovery device,
how do I calculate actual monthly HAP ABA emissions? 86
If I'm complying with the emission point specific limit using a recovery device.
how do I calculate actual emissions? 88
If I'm complying with the sourcewide emission limit.
how do I calculate allowable emissions'7 90
If I'm complying \\ith the sourcewide emission limit without using a recovery device.
how do I calculate actual sourcewide HAP emissions'7 91
If I'm complying with the sourcewide emission limit using a recover.1 device.
how do I calculate actual emissions? 92
How can I check my slabstock process for leaks0 95
Chapter 7 - Notification and reporting
\\Tiat do 1 have to report and when0 99
How can I change the date my reports are due9 99
Where do I send my reports? 99
Where do 1 submit my Alternative Program? 100
Can I get example reporting forms? 101
Initial Notification Report . 101
Application for Approval of Construction or Reconstruction . . . 110
Precomphance Report 115
v
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Contents
Notification of Compliance Status 121
Semiannual Compliance Report 124
Change in Selected Emission Limit and Compliance Method 128
Annual Compliance Certification 129
Chapter 8 - Other requirements and information
Who administers this regulation? .......................................... 130
Do I need atitle V permit? ............................................... 130
How do I change my permit to include this rule? .............. . ................ 131
What portions of the General Provisions apply? . . ....... ..................... 131
Chapter 9 - Getting additional help
Where do I go for help9 '. ................................................ 132
Can I get more information on the Web? ............ ......................... 133
Is there a list of commonly asked questions? .................................. 135
Chapter 10 - Supplemental information for State or local agencies and
Tribes
How many plants may need to meet emission limits? ............................ 136
Are plants in Indian Country regulated by the State? ............................ 136
How much HAP emissions will the rule reduce? ............................... 137
Figures
Figure 3.1 - A Typical Process for Slabstock foam Production ........................ 9
Figure 3.2 - Option 1, Emission Point Specific Limit ........................... 15
Figure 3.3 - Option 2. Sourcewide Emission Limit ............................. 16
VI
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Contents
Figure 3.4 - Option 1 and 2, Diisocyanate Emissions 17
Figure 3.5 - Option 1, HAP ABA Equipment Leaks 18
•
Figure 4.1- A Typical Process for Molded foam Production 67
Figure 5.1- A Typical Process for Rebond foam Production 73
Figure 10.1 - Slabstock Flexible Polyurethane-Foam Plants 141
Tables
Table 3.1 - Monitoring Requirements for Slabstock foam Production 19
Table 3.2 - Recordkeeping Requirements for Slabstock foam Production 28
Table 3.3- Checklist for Inspecting Slabstock foam Plants 38
Table 4.1- Checklist for Inspecting Molded foam Plants 70
Table 5.1- Checklist for Inspecting Rebond foam Plants 76
Table 6.1 - Foam Grades Produced by The Example Facilities 96
Table 6.2 - HAP ABA Formulation Limits for Foam Grades
Produced by The Example Facilities 97
Table 6.3 - Allowable HAP ABA Emissions for Foam Grades
Produced by The Example Facilities 98
Table 7.1- Report due dates 102
Table 7.2 - Reporting Requirements 104
Table 9.1 - EPA Regional Air Division Offices 134
Table 10.1 - 1993 U.S. Slabstock foam Plant List 138
Appendices
A - Contents for Subpart III. Final Rule 142
vn
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Chapter 1 - Introduction
Why should I use this document?
This document can help plant owners and operators (you) understand the Flexible Polyurethane
Foam Production NESHAP (also known as Subpart III) by helping you determine four main
things:
• if the rule applies to your plant and process
• what compliance options are available
• what to monitor, record and report
• dates by which you must meet requirements
Is there anything I should know before using this document?
When using this uocument. remember that it doesn't replace the final rule and covers only
requirements published on or before 12/31/98. You should keep up with new requirements printed
after this date by periodically checking the ' ,
Federal Register and the Code of Federal ,, . , , , , , , , ,. ,
6 keep informed of rule changes bv checking the
Regulations (CFR) \ ou can download Federal Register
Federal Register notices by going to the .
Government Printing Office (GPO) website
at ww.access.gpo.gov su_docs aces aces]40.html.
We've included a copy of the final rule in Appendix A (as published in the Federal Register.
10/7/98, 63 FR 53980). so you can reference the rule while you're using this document.
How do I get copies of this document?
You can get copies of this document in four ways:
• EPA's Unified Air Toxics Website (www.epa.gov/ttnuatM-). Look under Rules and
Implementation, flexible polyurethane foam, or www.epa.gov ttn uatw foatnfoampg.html
• Library Services Office, (MD-35), U.S. EPA; Research Triangle Park; NC 27711, or
www. epa.gov nallibra-ols.html (limited supply)
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• National Technical Information Services (NTIS), 5285 Port Royal Road. Springfield, VA
22161, or 1-(800)- 553-6847, or www.fedworld.gov/ntis/ntishome.htm! (NTIS will charge
you a fee for this document)
• National Center for Environmental Publications and Information, 1 -(800)-490-9198 or
www. epa.gov/ncepihom/index. html
We want your feedback
To serve you better, we've included a survey on the usefulness of this document. If you'd like to
participate, please fill out the survey on page 3 and return it to the address indicated. We'll keep
your responses confidential if you desire, but use them to help us improve future documents.
Help us publish better documents by filling out our
swrvev
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Survey on the Plain Language Guide to the Flexible Polyurethane Foam
Production NESHAP
Please help us gauge this document's usefulness by completing this short form. We'll keep your responses confidential if you
desire, but use them to help improve future documents. Check this box if you would like us to keep your responses
confidential D
1. What type of business do you work for? (check one of the following)
Manufacturing D Contractor D Tribe o Government (specify Federal, State, local)
Other
2. What are your job responsibilities? (check any that apply)
Plant Operator n Maintenance D Plant Manager D Environmental Staff D
Regulator n Other:
3, How did you hear about this guidance? (check any that apply)
Co-worker n EPA TTN via dial up modem D EPA TTN via the Web D Other
Please check the box under the number that most closely shows your agreement with the following statements
1= Strongly Agree to 5 = Strongly Disagree
Statement
The guidance was timely.
The document provides a good overview of the rule.
The document provides the type of information my organization needs to comply.
The guidance helped us achieve compliance more quickly than if we had developed our
own.
We have incorporated parts of tlu's document into our own policy documents.
The format of this document was well organized and easy to understand. ,
1
2
3
4
5
N/A
4. What did you like about this document or what helped you the most? (be as specific as you can)
5. What did you not like about this document or what helped you the least? (be as specific as you can)
6. What would you change about this document (e.g. formats: excluding information or including things that you didn't
see in the document)?
7. Overall, did you find this document to be:
extremely useful n very useful D so-so useful D not useful at all D
8. Other comments:
Provide additional comment on the back of this form or on a separate sheet of paper.
Return survey to: ATTN: Flexible Polyurethane Foam Implementation Contact, U.S. Environmental Protection Agency (EPA),
Research Triangle Park (RTF) MD-12, Research Triangle Park, NC 27711. or fax (919) 541-2664
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Chapter 2 - What this rule covers - An Overview
Why was this rule written?
We wrote the rule to reduce emissions of hazardous air pollutants and achieve the environmental
benefits intended by the Clean Air Act (CAA) of 1990.
Our research has shown that emissions from a typical production plant may include a number of
HAPs. We've estimated that methylene chloride accounts for more than 98 percent of the total
HAP emissions from flexible polyurethane foam plants and is the primary HAP affected by the
rule.
Some of the HAPs that might be emitted during the production of flexible polyurethane foam
include:
methylene chloride
1.2- propylene oxide
• 2.4- toluene diisocyanate
diethanolamine
• methanol
• methyl chloroform
• methylene diphenyl diisocyanate
• methyl ethyl ketone
• toluene
How do I know if I'm subject to this rule?
You're subject to this rule if your plant meets all of the following:
• is a major source of HAPs
• produces flexible polyurethane (slabstock or molded) or rebond foam
• emits a HAP
• doesn't qualify for one of the exemptions
For a list of regulated HAPs. check our Unified Air Toxics Website (UATW) at
http://www. epa. gov,ttn/uat\v.l 88polls. txt.
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If you have an enforceable limit on your facility' that restricts your emissions to <10 tons per year
of any single HAP and <25
tons per year of multiple
HAPs, your facility- would not Your facility is a major source if it can potentially emit
be a major source and not tons per year of a single HAP or 2 25 tons per year of all
subject to this rule. If, HAPs.
however, you determine that =
you're a major source, some
processes at your plant may still be exempt from the rule. These exemptions are listed below.
When do I need to comply?
If your facility is an existing source, you must comply by 10/8/01, which is three years and a day
after the rule's effective date of 10/7/98. The effective date is the date the final rule was published
in the Federal Register. If you're a new source, comply before you begin operating.
If your initial startup Then you're1... And must comply ...
is ...
on or before 12-27-96 an existing source by 10/8/01
after 12-27-96 a new source upon initial startup
'When determining if a source is new or existing, the General Provisions (40 CFR 63.
Subpan A, §63.2) requires us to use the proposal date of the rule as the cut-off date. In
the case of Subpart El, the rule was proposed on 12/27/96.
Are any processes exempt from the rule?
Your process is exempt if it's any of the following:
a research and development process 1Jyour process is exenipi, make
exclusively dedicated to fabricating flexible >™ document M*-v " '5
polyurethane foam
a slabstock foam operation where your plantwide
HAPs used are less than five tons per year. You must use §63.1290(c)(3) to calculate
HAP used.
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This last exemption - the slabstock foam operation where your whole facility (plantwide) uses less
than five tons per year (tpy) of HAP, is based on your usage of HAP, rather than the amount of
HAP emitted. You can claim this exemption only if your slabstock foam production and foam-
fabrication processes are the only processes at the plant site that emit HAP and emissions from
your facility are <5 tpy. The exemption applies only to Subpart III and does not effect other CAA
rules, for example other NESHAPs that apply to your facility. See Chapter 6 for an example of
how to calculate this exemption.
Note: Although foam fabrication isn 't covered by the rule, you 'II need to include emissions
from your fabrication process to claim this exemption.
How do I know if I have a covered process?
The rule defines the terms "flexible polyurethane foam production." "slabstock," "molded." and
"rebond" foam based on a typical process. Compare your process with thesy definitions in the
rule.
If your operation doesn't fit one of the definitions exactly, use your judgment and talk to your
State, local or Tribal agency for air pollution control. If all else fails, your EPA Regional Office
can help you render a judgement on applicability.
Does this rule apply to fabrication of foam?
Your process for fabricating flexible pohwethane foam \\ill fall under a different rule - the
Flexible Polyurethane Foam Fabrication NESHAP. We expect to publish this rule in 2000.
Definition. The rule defines "foam fabrication " as a operation for
cutting or bonding flexible pohurethane foam pieces together or to
other substrates. T>pical bonding techniques include gluing, taping.
and flame lamination.
What are my requirements for slabstock foam?
The rules for producing slabstock foam cover the two major uses of HAP in the slabstock process:
diisocyanates used as a reactant in making foam §ee chapter 3 for
UAD j -i- ui •' /-ADA\ j r details about vour
HAP used as an auxmarv blowing agent (ABA) and for ,. •..
° ° ^ > compliance options
equipment cleaning for slabstock foam
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You must control diisocyanate emissions from all of the following types of equipment:
• storage vessels
• transfer pumps
other components in service (such as connectors, valves, pressure-relief devices, etc.)
Definition. The rule defines diisocyanate as a compound containing
two isocyanate groups per molecule The most common diisocyanate
compounds used in the flexible polyurethane foam industry are
toluene diisocyanate (TDI) and methylene diphenyl diisocyanate
(MDI).
You must control HAP ABA emissions from all of the following equipment and processes:
• storage vessels
• equipment leaks
• the production line
• equipment cleaning
Depending on which compliance option you choose, you'll have to meet one or more of the
following requirements:
• use control equipment
• meet limits on point or sourcewide emissions
• restrict or eliminate the use of some materials
• inspect and monitor equipment for leaks
What are my requirements for molded and rebond foam?
If you have a molded or rebond foam plant.
you can't use a HAP or HAP-based See Chapter 4 & 5 for details about your
products to clean your equipment or use it compliance options for molded and rebond foam
as a mold-release agent. :
The only exception is your molded foam plant using diisocyanates during startup or maintenance to
flush the mixhead and associated piping. If you use diisocyanates for flushing, you must contain
the diisocyanate in a closed-loop system and reuse it in production.
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Chapter 3 - Complying with requirements for slabstock foam
What do the Slabstock sections of the rule cover?
Your slabstock foam production plant is covered under §§63.1293-1299 of the rule if your process
meets all of the following conditions:
• emits a HAP
• is a slabstock foam production process
• is located at a plantsite that is a major source of HAPs
• is not exempt
The slabstock sections of the rule cover vessels for storing diisocyanates, pumps for transferring
them, and other dnsocyanate components you have in service (such as connectors, valves, pressure-
relief valves, etc.) These sections also cover vessels for storing HAP auxiliary blowing agents
(ABA). HAP ABA equipment leaks, HAP ABA emissions from the production line, and HAP
ABA emissions from equipment cleaning.
Definition. Slabstock flexible polyurethane foam means
"flexible polyurelhane foam that is produced in large
continuous buns that are then cut into the desired size
and shape "
Definition. Slabstock flexible polyurethane foam
production line means "all portions of the flexible
polyurethane foam process from the mixhead to the point
in the process where the foam is completely cured "
Definition. Flexible polyurethane foam process means
"equipment used to produce a flexible pohiirethane foam
product. It includes raw material storage; production
equipment and associated piping, ductwork, etc.; and
curing and storage areas."
About this Chapter:
• Whenever you see "§,"
we are referring to the
section number of the
rule. You can go to thai
section in the rule for
more information
• HTien you see a
definition, it conies
straight from the rule
Figure 3.1 (on page 9) shows a typical process for producing slabstock foam.
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Figure 3.1
A Typical Process for Slabstock-Foam Production
Process Description:
Flexible slabstock-foam is produced as a large continuous "bun." Raw chemicals are
unloaded into storage vessels. The chemicals are then pumped to a mixing head where
they are blended and form a reacting chemical mixture. The amount of each chemical
sent to the mixing head is computer controlled and monitored on flow meters. The
mixture is discharged through the mixing head into a trough or onto a moving conveyor
belt, where the reactions continue. From this point the reacting mixture moves into the
foam conveyor tunnel. The mixture quickly spreads evenly across the tunnel. The
foam reaches its maximum height, or "full rise," about 25 feet from the mixing head
nozzle. Additional time on the conveyor after full rise is required to allow the
polymerization reactions to be completed. The bun then moves towards the cutoff saw.
After being cut, the buns are cured and then stored. Cured buns are either sent to bun
customers or to trimming and fabrication operations. Trimming and fabrication
operations and bun customers are not covered by this rule.
Raw Chemical
Unloading
Process Diagram:
Mixing head
and Valve*
Foam Conveyor Tunnel
Equipment
Cleaning
To Trimming
and Fabrication *
Bun Caring, and Storage
To "Bun" Cnctooun
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What is exempt under these sections of the rule?
Your slabstock facility is exempt from the rule if HAP used at your foam production and
fabrication facility is no more than five tons per year or if your process exclusively does either of
the following [§63.1290]:
• fabricates foam
• does research and development
Definition. Research and development process means "a laboratory or pilot plant
operation whose primary purpose is to conduct research and development into new
processes and products, where the operations are under the close supervision of technically
trained personnel, and which is not engaged in the manufacture or products for commercial
sale except in a de minimis manner."
Definition. Foam fabrication process means "an operation for cutting or bonding flexible
polyurethane foam pieces together or to other substrates."
You must use §63.1290(c)(3) of the rule (Equation 1) to calculate if your facility uses less than
five tons per year HAP. Your facility will be able to take the five ton per year exemption only if
your slabstock foam production and foam fabrication"""' processes are the only processes at the
plant site that emit HAP. See Chapter 6 for examples on how to calculate this exemption.
Note: Although foam fabrication isn 't covered by fie rule, you 'II need to include
emissions from your fabrication process to claim this exemption.
What compliance options do I have?
If you produce slabstock foam, you have three main regulator}' options:
Option 1: meet limits on HAP Auxiliary Blowing Agent (ABA) emissions (e.g. emission
point specific limit) and control diisocyanate emissions [§§63.1295 - 63.1298, §63.1294]
• Option 2: meet a sourcewide emission limit and control diisocyanate emissions. Option 2
applies to plants that use only one HAP as an ABA and an equipment cleaner [§63.1299.
§63.1294] .
• Option 3: request an alternate means of emission limitation under §63.1305(d). Your
request max- be submitted in your Precompliance Report, your Application for Approval of
Construction or Reconstruction, or at any other time. See Chapter 7 for additional
information [§63.1305(d). §63.1309(b)f
10
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To summarize, your options are as follows:
If...
your slabstock
foam plant is
regulated under
Subpart in
And you ...
use multiple
HAPsasan
ABA and
equipment
cleaner
use only one
HAP as an ABA.
and equipment
cleaner
want to use an
alternative
means of
emission
limitation
Then use the following options ...
Option 1: comply with §63.1294
(diisocyanate emissions)
and
§63.1295 through 63.1298 (emission
point specific limits)
Option 2: comply with §63.1294
(diisocyanate emissions)
and
§63.1299 (sourcewide emission limit)
Option 3: complywith §63.1305
(alternative means of emission
limitation)
For more
information,
see figures ...
3.2, 3. 4 and
3.5
3.3 and 3.4
Not in table.
see
§63.1305(b)
Your specific requirements under Options 1 and 2 differ based on the type of equipment or
processes at your plant. Depending on the option you choose, you may be required to monitor one
or more pieces of equipment or processes. Each equipment or process you monitor may have
subsequent options you can choose. Clearly understanding all your available options and sub-
options can get confusing. To help you understand your choices, we've included several figures.
Figure 3.2 (on page 15) outlines your requirements if you choose Option 1. Figure 3.3 (page 16)
outlines your requirements if you choose Option 2. Finally. Figure 3.4 (page 17) outlines your
requirements for controlling diisocyanate emissions under Options 1 and 2.
What monitoring must I do?
Your monitoring requirements \\ill depend on the compliance options you select. If you choose
Option 1, your main types of monitoring include one or more of the following:
• diisocyanate equipment leaks and repairs made on transfer pumps and other components in
diisocyanate service [§63.1294(b)]
HAP ABA and diisocyanate vapor balancing (vapor-return line) used for storage vessels
[§63.1295(b), §63.1294(a)]
• HAP ABA and diisocyanate carbon-adsorption systems used for storage vessels
[§63.1295(c), §63.1303(a), §63.1294(a)]
11
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• HAP ABA and polyol added to the foam production line at the mixhead OR an alternate
monitoring program under §63.1303(b)(5) [§63.1303(b), §63.1303(b)(5)]
• HAP ABA recovery monitoring device used (you must develop a monitoring program and
get it approved prior to it's use) [§63.1303(c), §63.1303(c)(6)]
• HAP ABA level in storage vessels [§63.1303(d)J
• HAP ABA added to storage vessels OR an alternate monitoring program under
§63.1303(e)(4) [§63.1303(e), §63.1303(e)(4)]
• Equipment leaks and repairs made to HAP ABA pumps, valves, connectors, pressure-
relief devices, and diisocyanate transfer pumps and other components in diisocyanate
service [§63.1296(a)-(e), §63.1294(b)]
If you choose the alternative monitoring program for HAP ABA and polyol added to the
foam production line at the mixhead. you'll need to request and obtain approval from the EPA
before you use your alternate. This is because we've chosen not to delegate §63.1303(b)(5) to
your State, local or Tribal agency for air pollution control. See Chapter 7 for additional
information [§63.1303(b)(5), §63.1309(b)].
Also see Chapter 7 for information on where to submit your alternative monitoring program
for HAP ABA added to storage vessels, and. where to submit your HAP ABA recovery
monitoring program [§63.1303(e)(4), §63.1303(c)(6)].
If you choose Option 2. your main types of monitoring include one or more of the following:
« diisocyanate vapor-balancing used for storage vessels [§63.1294(a)j
• diisocyanate carbon-adsorption systems used for storage vessels [§63.1294(a)]
• diisocyanate equipment leaks and repairs made on transfer pumps and other components in
diisocyanate service [§63.1294(b)]
• emissions from HAP ABA storage vessels, equipment leaks, the production line and
equipment cleaning [§63.1299]
• emissions from recovery devices (§63.1299(e)]
§63.1303 of the rule explains the requirements for each type of monitoring, except for vapor
balancing and leak detection and repair, which are in §63.1294-1296. Table 3.1 (on page 19) also
gives you details about your monitoring requirements under Option 1 and 2.
What records must I keep?
For slabstock-production. you must keep one of more of the following types of information:
12
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records on storage vessels
records on equipment leaks Maintain records for at
least five years
records on HAP ABA and polyol added to
equipment
records on recovery devices
copies of data sheets on equipment cleaners
records on your use of vapor-return lines
The types of records required depend on whether you decide to comply with a specific emission
point (Option 1 - emission point specific limit) or the sourcewide limits (Option 2). Your
recordkeeping will also vary according to the control options you're using. Table 3.2 (on page 28)
details these recordkeeping requirements as does §63.1307 of the rule.
What reports must I submit?
You must submit up to seven types of reports on each slabstock foam plant:
• an initial notification sent in within 120 days after the effective date of the rule
(§§63.1306(a). 63.9(b)]
• an application for approval for construction or reconstruction sent in as soon as practical
before construction [§§63.1306(b). 63.5(d)]
• a pre-compliance report sent in at least 12 months prior to the rule's compliance date
[§63.1306(c)]
• a notification of compliance status sent in within 180 days after the rule's compliance date
[§63.1306(d)]
• semiannual compliance reports sent in within 60 days after each 180 day period, \\ith the
first report due 240 days after the notification of compliance status [§63.1306(e)]
an annual compliance certification sent in yearly [§63.1306(g)]
The seventh report is also necessary if want to change the option you are using to meet the
emission limit or compliance method. You must send a notification of your intent to switch options
at least 180 days prior to making the change [§63.1306(f)]. For example, if you wanted to "switch
from the rolling-annual to the monthly compliance method for your HAP ABA production line.
you'd need to make notification at least 180 days prior to making the change.
Chapter 7 gives you more details on the reporting requirements above, as well as additional
reporting information including dates and example forms. The forms are optional, but you max
find them useful.
13
-------
What test methods am I required to use?
You'll need to use the following two test methods if you produce Slabstock foam:
• use EPA Test Method 21 to monitor leaks from HAP ABA pumps, valves, connectors,
pressure-relief devices, and open-ended valves or lines [§63.1304(a)]
• use the American Society for Testing and Materials (ASTM) D3574 to determine the
density and IFD of each grade of foam produced [§63.1304(b)]
You can download a list of the latest ASTM versions by going to www.astm.org and
clicking on "Search for ASTM standards." then continue as prompted. You can also order
ASTM methods by calling (610) 832-9585.
How do I show compliance?
You can show compliance with §§63.1293-1299 by doing all of the following:
• control diisocyanate emissions from storage vessels, transfer pumps, and other components
using the options in Figure 3.4 [Option 1 and 2, §63.1294]
• control HAP ABA emissions from either one of the following:
»• storage vessels, equipment leaks, the production line, and equipment cleaning as
described in Figures 3.2 and 3.5 (e.g. emission point specific limit) [Option 1.
§63.1295-1298]
OR
* your entire slabstock production process if you use only one HAP as an ABA and
an equipment cleaner (e.g. sourcewide emission limit) as described in Figure 3.3
[Option 2. §63.1299]
• do the monitoring described in Table 3.1
• maintain the records described in Table 3.2
• submit the reports described in Chapter 7
You must meet all of these requirements, otherwise, you'll be in violation of §§63.1293-1299.
Check §63.1308 of the rule for more information.
Is an inspection checklist available?
We've included an inspection checklist in Table 3.3 (on page 38) to help you check your slabstock
foam plant for compliance with the rule.
14
-------
Figure 3.2
Option 1
Emission Point Specific Limit
If you chose Option 1 (S63.1293(a)) of the Slabstock standard, you must comply with S63.1294 through 63.1298, emission point specific
limitations. This figure summaries your regulatory options.
Option 1
Requirements
863.1294
diisocyanate
emissions
See Figure 3.4 for
regulatory options
available
£63. 1 295
HAP ABA Storage
Vessels
Option 1
You have two options
Comply with all requirements
£63.7296
HAP ABA equipment
leaks
See Figure 3.5 for
regulatory options
available
563.1297
HAP ABA emissions
for the production
line
(583.1298
HAP ABA emissions
from equipment
cleaning
Option 2
Option 1
Option 2
S63.1295(b)
(1) equip the storage
vessel with a vapor -
return line (vapor-
balance system) from
the storage vessel to the
tank truck or rail car;
(2) inspect the vapor -
return line for leaks
during each unloading
event;
(3) repair any detected
eak before next
unloading.
363.129S(c)
(1) equip the storage
vessel with a carbon
adsorption system
meeting S63 1303(a);
(2) route displaced
vapors through activated
carbon before discharging
into the atmosphere;
(3) replace existing
carbon with fresh carbon
before next unloading if
you detect a .
breakthrough.
g63.1297(a)(1)
(1) determine compliance
on rolling annual basis,
(2) compare actual HAP
ABA emissions to allowable
emissions for each
:onsecutive 12-months;
(3) base your allowable
HAP ABA emissions on
production for the 12-month
period;
[4) determine compliance
for each month for the
previous 12 months.
S63.1297(a)(2)
(1) determine
compliance on a
monthly basis,
(2) compare actual HAP
ABA emissions to
allowable HAP ABA
emissions each month;
(3) base your allowable
HAP ABA emissions on
production for the
month.
Vot/ have two options1
You have one option
(1) Don't use HAP,
or a HAP-based
material as an
equipment cleaner.
1 if you elect'to change options,
you must notify your regulatory
agency no later than 180 days prior
to the change [863.1297(aX2)]
15
-------
Figure 3.3
Option 2
Sourcewide Emission Limit
If you choose Opt/on 2 (663.l293(b)) of the Slabstock standard, you must comply with 5563.1294 and
63.1299, sourcewide emission limitations. This figure summarizes your regulatory options.
This option provides a sourcewide emission limit. You can use this option only if you use one HAP as
an ABA and equipment cleaner.
Option 2
Requirements
Comply with all requirements.
663.1294
(diisocyanate
emissions)
See Figure 3.4 for
regulatory options
available
S63.1299
(source-wide
emission limitation)
The rule regulates three kinds of emissions:
HAP ABA storage and equipment leak
emissions; HAP ABA emissions from the
production line; and HAP ABA emissions
from equipment cleaning
Option 1
S63.1299(a)
(1) determine compliance on rolling
annual basis.
(2) compare actual source-wide HAP
emissions to allowable source-wide
emissions for each consecutive 12-
months;
[3) base your allowable source-wide
HAP emissions on production for the
12-month period;
[4) determine compliance each month
for the previous 12 months;
;5) if you're using a recovery device,
following 563.1299(e) for determining
your actual sourcewide emissions
and 563.1299(d) for determining
allowable HAP emissions.
Vou have two options1
Option 2
S63.1299(b)
(1) determine compliance
on a monthly basis
'2) compare actual HAP
emissions to allowable
HAP emissions each
month;
3) base your allowable
source-wide emissions on
production for the month.
4) if you're using a
recovery device, following
S63.1299(e) for determining
your actual sourcewide
emissions and 563.1299(d)
for determining allowable
HAP emissions.
if you elect to change options, you must notify your regulatory agency no later than 180 days prior to the change
16
-------
Figure 3.4
Option 1 and 2
Diisocyante Emissions
If you choose Option 1 or 2 of the Slabstock standard, you're required to comply with 863.1294, diisocyanate emission. This figure summarizes
your regulatory options.
.1294
diisocyanate emissions
Option 1
S63.1294(a)
diisocyanate storage
vessels
863.
Comply with
1294(b)
transfer pumps in
diisocyanate service
You have two options
S63.1294(a)(1)
(1) during loading
operations, equip the
storage vessel with a
vapor- return line
(vapor-balance
system) from the
storage vessel to the
tank truck or rail car;
(2) inspect for leaks
during each unloading
(3) repair leak before
next unloading.
Option 2
S63.1294(a)(2)
[1) equip the storage
vessel with a carbon-
adsorption system
meeting 863.1303(a);
;2) route displaced
vapors through
activated carbon
before discharging into
the atmosphere;
[3) replace existing
:arbon with fresh
carbon before next
unloading if
you detect
a breakthrough.
Option 1
all requirements
S63.1294(c)
Other components in
diisocyanate service
You have two options
#63.1294(b)(1)
(1) install
sea//ess pump
Option 2
363.1 294(b)(2)
(1) install submerged
Dump;
(2) completely immerse
pump in DEHP, DWP or
other neutral oil;
(3) visually inspect pump
weekly for leaks,
'4) repair any leak
within 15 days after
detection2
;5) make first attempt to
repair leak
witnin o days
after detection.
You have one option
(1) if you find evidence
of a leak, repair the leak
within 15 days after
detection ,
(2) make first attempt
to repair leak within 5
days after detection.
1 by visual, audible, olfactory or oth<
method
2 563. 1296(f),
"Delay of repair" prov
allowed IT appiicaoie
17
-------
Figure 3.5
Option 1
HAP ABA Equipment Leaks
If you choose Option 1 of the Slabstock standard, you must comply with 563.1296, HAP ABA leaks from equipment. This figure summarizes your
options.
S63.1296
HAP ABA equipment leaks
Comply with all requirements
S63.1296(a)
transfer pumps
You have two options
Option 1
I Option 2
S63.1296(a)(1)
(1) install
sealless pump
S63.1296(a)(2)
;1) monitor pump
quarterly for leaks using
EPA Method 21;
[2) check pumps weekly
For indications of liquids
dripping from the pump
seal;
(3) repair leak within 15
days after detection1;
(4) make first attempt to
repair leak within 5 days
after detection.
S63.1296(b)
valves
(1) monitor valve
quarterly for leaks
using EPA Method
212;
(2) repair leak within
15 days after
detection1;
(3) make first attempt
to repair leak within 5
days after detection.
S63.1296(c)
connectors
You have one option
You have one option
(1) monitor connector annually
for leaks using EPA Method 21;
(2) if opened or had a seal
broken, monitor connector for
leaks within 3 months after being
eturned to service;
(3) if leak is found, monitor
connector for leaks within the
first 3 months after repair;
(4) repairleak within 15 days
after detection12;
(5) make first attempt to repair
eak within 5 days after detection.
663.1296(d)
pressure-relief devices
S63.1296(o)
open-ended valves
or lines
You nave one option
(1) if evidence of leak is found,
monitor pressure-relief device
within 5 days using EPA
Method 21*
[2) repair leak within 15 days
after detection1;
(3) make first attempt to repair
leak within 5 days after
detection.
You have one opt/on
(1) equip open-ended valve or
ine (which is in service) with a
cap, blind flange, plug, or
second valve4;
2) keep the open end sealed
at all times except during
operation, maintenance or
repair;
3) if you use a second valve,
:lose the process fluid valve
before the second valve;
4) you may leave double block
and bleed valves open during
aperations that require venting
between block valves5.
863.1296(f), "Delay of repair" provisions allowed if applicable
! 663.1296 provides some exemptions for unsafe and difficult to monitor
1 By visual, audible, olfactory or any other detection method
4 Except open-ended valves or line in an emergency (863.1296(e)(5))
5 Valves must be equipped with cap, blind flange, plug, or second valve at all other times.
18
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production
If your emission.
point is....
And you have
chosen, as your
overall
compliance
strategy, the...
And you arc
using the
following control
option ... Then you must monitor as described below ,
According to
these sections of
the rule...
Diisocyanntc Emission point Vapor h;il;ii)cc Look, listen, ;iiul otherwise check for leaks in the v;ipor-rcturn line each time diisocyanntc is
storage vessels specific limit unloaded from ;i tank (ruck or rail c;ir into (he storage tank.
§63.1294(8X1X0
(Option I or 2)
OR
Kepair leaks found before the next unloading event.
§63.1294(aXlXiO
Sourccwidc emission
limit
Carbon-adsorber Measure IIAI' or organic concentrations in (he exhaust-vent stream or outlet stream's exhaust
from the carbon-adsorption system during each unloading of diisocyanatc from a tank truck or
rail car If diisocynnatc is unloaded more often than once a month, you must monitor only one
unloading event per month.
OR
Instead of monthly monitoring, you can monitor al the frequency you've established during the
design analysis as long as the monitoring is performed within 20 percent of the carbon
replacement interval.
§63.1303(aXl)
§63.1303(aX2)
Measure IIAP concentration using 40 CFR part 60, Appendix A, Method 18 over at least a 5- §63.1303(aX3)
minute period while the storage vessel is being filled .
Measure organic concentration using 40 CFR part 60, Appendix A, Method 25A over at least a
5-minutc period while the storage vessel is being filled.
§63.1303(aX4)
You must replace existing carbon with fresli carbon prior to the next unloading event if you §63.1294(aX2)
detect breakthrough.
19
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
If your emission
point is. .. .
Transfer pumps
in diisocyanatc
service
And you have
chosen, as your
overall
compliance
strategy, the . . .
Emission point
specific limit
OR
And you arc
using the
•following control
option . . . Then you must monitor as described hclow . . .
Scnllcss pump None
According to
these sections of
the rule...
(Option 1 or 2)
Sourcewidc emission
limit
Submerged pump Immerse each pump in bis(2-ethylhcxyl)phthalate (DHI IP, CAS# 118-81 -7),
2(mcthyloclyl)phthnlatc (D1NP, CAS #68515^18-0), or another neutral oil.
Look at each pump at least once a week to be sure it isn't leaking.
if you find a leak, attempt your first repair within 5 calendar days and repair it within 15
calendar days unless you have determined that your equipment meets the delay of repair
allowances in §63.1294(d)
§63.1294(bX2Xi)
§63.1294(bX2XH)
§63.1294(bX2Xiii)
Note: First attempt at repair should include tightening of packing gland nuts and checking
the seal flush to see if it is operating at design temperature and pressure.
20
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
If your emission
point is....
And you have
chosen, as your
overall
compliance
strategy, the...
And you arc
using the
following control
option...
Then von must monitor as described below
According to
these sections of
the rule...
Oihef
components in
diisocyanatc
service
Emission point N/A
specific limit
None, hut if von find a lc;>k, yon must make your first attempt to repair it within 5 calendar days
mid repair it within 1 5 calendar clays unless you have determined that your equipment meets the
delay of repair allowances in §63.!2%(f)
§63.1294(c)
(Option 1 or 2)
OR
Sourcewide emission
limit
HAP ABA
storage vessels
Hmission point
specific limit
Vapor balancing or
carbon-adsorber
Monitor the amount ofl IAP AHA in the storage vessel weekly using a level-measurement
device Calibrate the level-measurement device initially and at least once per year. Unless you
visually read the device with permanent graduated marks, such as for a gauge glass, the device
must have cither a digital or printed output.
§63.1303(d)
(Option 1)
Monitor the amount ofl !AP ABA added to the storage vessel each time there is a delivery. You
may determine the amount of IIAI' ADA added by using a level-measurement device, monitoring §63.1303(e)
the flow rate, or measuring the weight. If the amount of HAP ABA added is determined using a
scale, it must be approved by your State or local agency or checked once per year by a registered
scale technician. §63.1303(e) describes each of these options.
line rule also allows you to develop and submit for approval an alternative monitoring plan for
determining the amount of I lAt' ABA added to the storage vessel. §63.1303(e)(4)
21
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
And you have
chosen, as your
V»-. . . overall
If your cmissmn comp|iancc
point is.... strategy, the...
And you arc
using the
following control
option ... Then you must monitor as described below,
According to
these sections of
the rule...
Vapor balance Look, listen, and otherwise check for leaks in the vapor-retum line each time the HAP ABA is §63.1295(bXl)
unlomlcd from a tank truck or rail care into the storage tank.
If you detect a leak, repair it by the next unloading event.
§63.1295(bX2)
Carbon-adsorber Measure IIAP or organic concentrations in the exhaust-vent stream or outlet stream's exhaust
from the carbon-adsorption system during each unloading of diisocyanate from a tank truck or
rail car. If diisocyanate is unloaded more often than once a month, you must monitor only one
unloading event per month.
OR
Instead of monthly monitoring, you can monitor at the frequency you've established during the
design analysis as long as the monitoring is performed within 20 percent of the carbon
replacement interval.
§63.1303(aXl)
§63.1303(aX2)
Measure I IAP concentration using 40 CFR part 60, Appendix A, Method 18 over at least a 5- §63.1303(aX3)
minute period while the storage vessel is being filled .
Measure organic concentration using 40 CFR part 60, Appendix A, Method 25A over at least a §63.1303(aX4)
5-mimite period while the storage vessel is being filled.
You must replace existing carbon with fresh carbon prior to the next unloading event if you §63.1295(c)
detect breakthrough.
22
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
And you have
chosen, as your
„ . overall
If your emission compliancc
point is.... strategy, the...
And you arc
using the
following control
option ... Then you must monitor as described below,
According to
these sections of
the rule...
HAP ABA Emission point
equipment leaks, specific limit
pumps
Sea! less pump
None
(Option 1)
Other types of Monitor e;\ch pump quarterly using lil'A Method 21 to detect leaks. If you measure an
pumps instrument rending of 10,000 parts per million (ppm) or more, you have a leak.
§63.1296(8X2X0;
§63.1304(a)
Look at each pump every calendar week to see if liquids arc dripping from the pump's seal.
§63.1296(aX2X»)
If you find a leak, attempt your first repair within 5 calendar days and repair it within 15
calendar days unless you've determined your pump meets the delay of repair under §63.1296(0-
§63.1296(aX2X»i)
Note: Your flr.il attempt to repair should include tightening of packing land nuts and
ensuring the seal flush is operating at it's design pressure and temperature.
HAP ABA Emission point
equipment leaks, specific limit
valves
(Option 1)
Valves not
designated as
Unsafc-to monitor
or
Monitor each valve quarterly using EPA Method 21 to detect leaks. If you measure an
instrument reading of 10,000 parts per million (ppm) or more, you have a leak.
If you find a leak, attempt your first repair within 5 calendar days and repair it within 15
Difficult-to-tnonitor calendar days unless you have determined that your equipment meets the delay of repair
allowances in §63.1296(0-
Note: Yoitr first attempt to repair should include tightening of bonnet bolls, replacement of
bonnet bolts, lightening gland nuts and lubricating the packing.
§63.1296(b)(l);
§63.1304(a)
§63.1296(bX2)
23
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
If you remission
point is....
And you have
chosen, as your
overall
compliance
strategy, the...
And you arc
using the
following control
option ...
Then vou must monitor as described below,
According to
these sections of
the rule...
Unsafc-to-rnonilor
valves
I Jnsafc-to-monitor valves arc those where monitoring could expose personnel to an immediate
danger situation. You must have a written plan for monitoring valves identified as unsafe-to-
monitor. Monitor and repair leaks according to the written plan, which is at least as soon as
practicable.
§63.1296(bX3)
Difficult-to-monitor
valves
Difficult-to-monitor valves arc those where the valve cannot be monitored without elevating the
monitoring personnel more than 2 meters above a support surface or where the valve is not
accessible at any time in a safe manner. You must have a written plan for monitoring valves
identified as difficult-to-monitor. Monitor and repair leaks according to the written plan, which
is ;il least once every calendar year.
§63.1296(bX4)
HAP ABA
equipment leaks,
connectors
fOntion H
Emission point
specific limit
Connectors nol
designated as
Unsafc-to monitor
or
Unsafc-to-rcp;iir
Monitor each connector annually using EPA Method 21 to detect leaks.
If the connector has been opened or the seal is broken, you must monitor it using EPA Method 21
no Inf^r than 1 months ntlcr vou stnrt nsino il ;i0,iin
§63.1296(cXlXi);
§63.1304(a)
Whenever you repair a connector, you must monitor it using EPA Method 21 for leaks within 3
months after the repair.
§63.1296(cXlX");
§63.1304(a)
If you find a leak, attempt your first repair within 5 calendar days and repair it within 15
calendar days unless you have determined that your equipment meets the delay of repair
allowances in §63.12%(f)
§63.1296(cXlX»i);
§63.1304(a)
24
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
If your emission
point is....
And you have
chosen, as your
overall
compliance
strategy, the...
And you arc
using the
following control
option ...
Then \OH must monitor as dcscrihcd below ,
According to
these sections of
the rule;;;
Unsafc-to-inonitor
Unsafe-to-monitor valves arc those where monitoring could expose personnel to an immediate
danger situation. You must have a written plan for monitoring connectors identified as unsafe-
lo-monilor. Monitor ••ind repair leaks according to the written plan, which is at least as soon as
practicable.
§63.l296(cX3)
I Jnsafe-to-rcpair I Jnsafe-to-repair valves are those where repair personnel would be exposed to an immediate
danger situation. You must have a written plan for monitoring connectors identified as unsafe-to-
rcpair. Monitor and repair leaks according to the written plan, which is at least within 6 months
after the leak was detected
§63.l296(cX4)
HAP. ABA
equipment leaks
pressure-relief
devices
Emission point N/A
specific limit
None, unless you see, hear, or smell a leak. If you detect a leak, then you must monitor within 5
days using HPA Method 21 . If you measure an instrument reading of 10,000 parts per million
(pymi) or more, you have a teak.
§63.1296(dXl);
§63.1304(a)
(Option 1)
If you find a leak, attempt yov\r first repair within 5 calendar days and repair it within 15
calendar days unless you have determined that your equipment meets the delay of repair
allowances in §63.1296(0-
§62.1296(dX2)
HAP ABA
equipment leaks,
open-ended
valves or lines
(Option 1)
Emission point
specific limit
N/A
None, but you must make sure that a cap, blind flange, plug, or second valve is appropriately
scaled, except for emergency-shutdown system, at all times when you're not operating,
maintaining or repairing the system. If your valve or Itlic has a second valve, make sure that the
valve on the process fluid end is closed before the second valve.
§63.1296(e)
25
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
If your emission
point is. . . .
HAP ABA
Production line
And you have
chosen, as your
overall
compliance
strategy, the . . .
Emission point
specific limit.
And you are
using the
following control
option . . .
Recovery device
Then -on must monitor as
described below . . .
Monitor the cumulative amount of HAP AHA recovered by the solvent-recovery device each
month using equations 2 and 4.
Actordirigto
these sections of
the rule ...
§63.1297(e);
§63.1297(eXl)
(Option 1)
rolling annual or
monthly compliance
alterative
You must submit a HAP ABA monitoring and rccordkeeping program for approval. The program §63.1303(cX6)
must contain information found in §63.1303(cXlM5)-
(You must make
notification to switch
between the monthly
and yearly
alternatives)
All options other Continuously monitor the amount of HAP ABA and polyol added at the mixhead when foam is
than recovery being poured. For polyol added to the mixhead, you can use pump revolutions or flow rate for
device the measurement. For HAP ABA added to the mixhead, you can use flow rate. You must
measure at the beginning and end of the production of each grade of foam within a run of foam.
'Hie rule also allows you to develop and submit for approval an alternative monitoring plan for
determining the amount of HAP ABA and polyol added to the foam production line at the
mixhead. The plan must be approved by the KPA prior to it's use.
§63.1297(b);
§62.1297(c);
§63.1303(b)
§63.1303(bX5)
HAP ABA
equipment
cleaning
(Option I )
Emission point NA
specific limit
None, but you must make sure that you don't use a HAP or HAP-based materials as an
equipment cleaner.
§63.1298
26
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
If your emission
point is....
And you have
chosen, as your
overall
compliance
strategy, the,..
And you arc
using the
following control
option...
Then vou must monitor as described below ,
According to
these sections of
the rule...
HAP ABA
storage vessels,
equipment leaks,
production line,
and equipment
cleaning
Sourccwide emission Recovery device
limit,
rolling annual or
monthly compliance
alterative
Monitor the actual and allowable cumulative amount of I JAP ABA recovered by the solvent-
recovery device each month using Equations 6 and 7
You must submit a I JAP AHA monitoring and recordkeeping program for approval before you
wish to begin using the program 'Hie program must contain information found in
§63.l303(c)(l)-(.S).
§63.1299(d);
§63.1299(eXl)
§63.1303(cX6)
(Option 2)
All options other Calculate actual source-wide IIAP emissions for a month using Equation 5. Calculate actual
than recovery source-wide I IAP emissions lor each consecutive 12-month period by summing actual monthly
device source-wide I IAP emissions for each of the individual 12 months.
Calculate allowable source-wide I IAP emissions for each individual month by using equation 6.
Calculate allowable source-wide I IAP emissions for a consecutive 12-month period by summing
allowable monthly source-wide I IAP emissions for each individual 12 months in the period.
§63.1299(c)
§63.l299(d)
27
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If your emission
point is...
Diisocyanatc storage
vessels
(Option 1 or 2)
And you have
chosen, as your
overall
compliance
strategy, the . . .
Kmission point
specific limit
OR
And vou
are u.sinj;
the
following
control
option . . .
All options
Vapor
balancing
Then you must keep records as dcscrihcd hclow ...
Keep a list of diisoevanatc storage vessels, along with a record of the type of control used
lor each storage vessel.
Dates and limes of each unloading event.
Dates and times of each inspection of the vanor-rcturn line.
According to these
sections of the rule
.»' *' * : . .
§63.1307(aXl)
§63.1307(aX4XiX«i);
§63.1307(0
Source wide
emission limit
Dates and times when you detect a leak in the vapor-retum line.
Dates and times when you repair a leak in the vapor-relum line.
Carbon-
adsorption
Dates and times when you monitor the system for carbon breakthrough.
Monitoring device reading each time monitored.
Date when you replaced the carbon.
Carbon-
adsorption -
design
analysis
monitoring
Record the systems design analysis.
Dates and times when you monitor the system for carbon breakthrough.
Monitoring device reading each time you monitor.
Date when you replaced the carbon.
§63.1307(aX3)(i);
§63.1307(aX3)(iii)
§63.1307(aX3Xii);
§63.1307(aX3)(iii),
§63.1303(aX2)
28
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If your emission
point is...
Transfer pumps in
dihocyanatc service
(Option 1 or 2)
And you have
chosen, as your
overall
compliance
strategy, the ...
Emission point
specific limit
OR
sourccwide
emission limit
And you
arc using
the
following
control
option ... Then you must keep records as described below . . .
All options. For each pump, date of installation and type of control.
except
seal less
pumps If you detect a leak, you must record and identify on the equipment the following
information:
• Instrument and operator identification numbers
• Kniiinment identification number
According to these
sections of the rule
-« ;*.*
§63.1307(bX2)
§63.1307(bX3Xii)
Date you detected the leak and the dates of each attempt to repair the leak
Repair methods applied in each attempt to repair the leak
Words "above leak definition" if maximum leak reading is equal to or more than the
leak definition for the equipment
Words "repair delayed" and the reason for the delay if not repaired within 15 calendar
days
Date you expect to successfully repair the leak if not repaired within 15 calendar days
Date you repaired the leak
Date you removed the identification
29
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If your emission
point is ...
Other components in
diisocyanatc service
(Option 1 or 2)
And you have
chosen, as your
overall
compliance
strategy, the . . .
Emission point
specific limit
OR
Sourcewidc
emission limit
And you
arc using
the
following
control
option . . .
All options
Then you must keep records as described below . . .
List of components in diisocvnmitc service.
If you detect a leak, you must record and identify on the equipment the following
information:
Instrument and operator identification numbers
• KrlllintnrMlf irlfVltiflrfitmn MlllnVw'r
According to these
sections of the rule
-* *.«
§611307(bXl)(i)
§63.1307(bX3X")
Date you detected the leak and the dates of each attempt to repair the leak
Repair methods applied in-cach attempt to repair the leak
Words "above leak definition" if maximum leak reading is equal to or more than the
leak definition for the equipment
Words "repair delayed" and the reason for the delay if not repaired within 15 calendar
days
Date you expect to successfully repair the leak if not repaired within 15 calendar days
Date you repaired the leak
Date you removed the identification
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If your emission
point is ...
HAP ABA storage vessels
(Option 1 )
And you have
chosen, as your
overall
compliance
strategy, the ...
Emission point
specific limit
And you
arc using
the
following
control
option . . .
All options
Vapor
balancing
Then you must keep records as described below . . .
A list of HAP AHA storage vessels, along with a record of the type of control used for each
storage vessel.
Dates and times of each unloading event.
Dates and times of each inspection of the vapor-return line.
According to these
sections of the rule
* « •
§63.1307(aX2)
§63.1307(aX4);
§63.1307(f)
Carbon-
adsorption
Carbon-
adsorption -
design
analysis
monitoring
.Dales and limes when you detect a leak in the vapor-return line.
Dates and times when you repair a leak in the vapor-return line.
Dales and times when you monitor the system for carbon breakthrough.
Monitoring device reading each time you monitor.
Date when you replaced the carbon.
Records of the systems design analysis.
Dates and times when you monitor the system for carbon breakthrough.
Monitoring dc.vicc reading each time you monitor.
Date when you replaced the carbon.
§63.1307(aX3Xi);
§63.1307(aX3Xiii)
§63.1307(aX3Xii);
§63.1307(aX3Xiii);
§63.1303(aX2)
31
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
Tf your emission
point is . . .
HAP ABA Equipment
Leaks (e.g. transfer pumps,
And you have
chosen, as your
overall
compliance
strategy, the . . .
Emission point
specific limit
And you
arc using
the
following
control
option . . , Then you must keep records as described below . . .
All oplions List ol components in HAP AHA service.
According to these
sections of the rule
. . .
§63.1307(bXlXii)
valves, connectors,
pressure-relief devices, and
open-ended lines)
(Option 1)
All oplions,
except
seaI less
pumps
It you detect a leak, you must record and identify on the equipment the following
information:
Instrument and operator identification numbers
Equipment identification number
Dale you detected the leak and the dates of each attempt to repair the leak
Repair methods applied in each attempt to repair the leak
Words "above leak definition" if maximum leak reading is equal to or more than the
leak definition for the equipment
Words "repair delayed" and the reason for the delay if not repaired within 15 calendar
days
Date you expect to successfully repair the leak if not repaired within 15 calendar days
Date you repaired the leak
Date you removed the identification
§63.1307(bX3XH)
32
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If your emission
point is...
And you have
chosen, as your
overall
compliance
strategy, the...
And you
arc using
the
following
control
option...
According to these
sections of the rule
Then you must keep records as described below,
HAP ABA Production line
(Option 1)
Emission point All options Record the following daily:
specific limit, . |'oam nms, with a list of the grades produced during each nm
rolling annual or • Amount of polyol added to the slabstock foam production line at the mixhead for each
monthly nm (not required for grades of foam where you've designated the formulation limit for
compliance 1IAP ABA as 7,ero)
alterative • Results of the density and FFD testing for each grade of foam produced during each run
of foam (must he recorded within 10 days of production; not required for grades of
.foam %vlicrc you've designated the formulation limit for HAP ABA as zero)
Record the following monthly:
• Listing of all foam grades produced during the month
Residual 11AP formulation limit for each foam grade produced
• Total amount of polyol used in the month for each foam grade produced (not required
if zero is the HAP ABA formulation limit)
• Total allowable 11AP ABA emissions for the month
Total amount of IIAP ABA added to the lirrc at the mixhead during the month
§63.1307 (
§63.1307(cXlX»)
If you're using rolling-annual compliance, also record the following:
Sum of the total allowable I IAP ABA emissions for the month and the previous 11
months
Sum of the total actual I IAP ABA emissions for the month and the previous 11 months
§63.1307(cXlXiii)
33
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
And you
And you have arc using
chosen, as your the
overall following According to these
IF your emission compliance control sections of the rule
point is... strategy* the ... option... Then you must keep records as described below...
Also keep all of (ho following records: §63.I307(c)(lXiv)
Records of calibrations Tor each device used to measure polyol added at the mixhead
• Records of all calibrations for devices used to measure the amount of HAP ABA in
storage vessels
34.
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If your emission
point is. ..
HAP ABA Production line
(Option 2)
And you have
chosen, as your
overall
compliance
strategy, the ...
Sourcewide limit.
rolling annual or
monthly
compliance
alternative
And you
arc using
the
following
control
option . . .
All options
Then you must keep records as descrihcd below ...
Record (he following daily:
Foam runs, with a list of the grades produced during each run
Results of the density and IFD testing for each grade of foam produced during each run
of foam (must he recorded within 10 days of production; not required for grades of
foam where you've designated the formulation limit for HAP ABA as zero)
• Amount of polyol added to the slahstock foam production line at the mixhead for each
run (not required for grades of foam where you've designated the formulation limit for
MAP ABA as zero)
According to these
sections of the rule
• •• *
§63.1 303 (cX2)(i)
Record the following weekly:
• storage tank level
Record the following monthly:
• Listing of all foam grades produced during the month
Residual HAP formulation limit for each foam grade produced
• Total amount of polyol used in the month for each foam grade produced (not required
if zero is the HAP ABA formulation limit)
• Total allowable HAP ABA and equipment cleaning emissions for the month
Total actual sourccwide JIAP ABA emissions for the month
• Amounts of HAP AHA in the storage vessel at the beginning and end of the month
• Amount of each delivery of I IAP ABA to the storage vessel
§63.1303(cX2XH)
§63.1303(cX2Xiii)
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If your emission
point is...
And you have
chosen, as your
overall
compliance
strategy, the...
And you
arc using
the
following
control
option ...
Then you must keep records as described below ,
According to these
sections of the rule
If using rolling-annual compliance, also record the following:
Total allowable 1IAP AHA and equipment cleaning HAP emissions for the month and
the previous 11 months
Tola! actual IIAI' ABA and equipment cleaning HAP emissions for the month and the
previous I I months
Records of all calibrations for each device measuring polyol added at the mixhead
Records of all calibrations for each device used to measure the amount of HAP ABA in
the storage vessel
Also keep all of the following records:
Records of calibrations for each device used to measure polyol added at the mixhead
• Records of all calibrations for devices used to measure the amount of HAP ABA in
storage vessels
• Records to verify that all scales used to measure the amount of HAP ABA added to the
storage vessel meet the requirements of §63.1303(eX3)
§63.I303(cX2Xiv)
§63.1307(cX2Xv>-
(vii)
HAP ABA Recovery
device
(Option 1 or 2)
Emission point
specific limit
OR
Sourcewide limit
N/A
Copy of the monitoring and rccordkecping program for recovered HAP ABA.
Certification of the monitoring device's accuracy.
Records of periodic calibration of the monitoring devices.
Records showing results of parameter monitoring.
Amount of HAP ABA recovered each time it is measured.
§63.1307 (d)
36
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If your emission
point is...
HAP ABA Equipment
cleaning
And you have
chosen, as your
overall
compliance
strategy, the ...
Emission point
specific limit
And you
arc using
the
following
control
option . . .
N/A
Then you must
keep records as described
below . . .
Product data-sheet for each equipment cleaner used, including HAP content, in kg of
I lAP/kp solids (Ib
HAP/lb solids).
According to these
sections of the rule
• :••:•
§63.1 307 (e)
(Option 1)
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants
Facility Name:
Facility Location:
Facility TRI ID #:
Person Conducting Evaluation:
Date of Evaluation:
This inspection checklist is broken up into eleven sections as follows:
Section Pa£e Option
I. Applicability 38
n. Diisocyanate storage vessels 39 1 or 2
El. Diisocyanate transfer pumps 42 1 or 2
IV. Other diisocyanate components in service 44 1 or 2
V HAP ABA storage vessels 45 1
VI. HAP ABA equipment leaks 49 1
VB HAP ABA production line 54 1
VEL HAP ABA equipment cleanig 59 . 1
DC. Sourcewide emission limit 60 2
X. Testing - 64 1 or 2
XI. Reporting 65 1 or 2
Section I: Applicability checklist (All Options)
A. Applicability
Note: If you answer YES to any Section A questions, don't continue. Your slabstock Comments
foam process isn?t covered . •-.-.;
1 Is your facility exclusively dedicated to the fabrication of flexible D Yes D No
polyurethane foam? §63.1290(c)(l)
2 Is your slabstock process devoted solely to research and development D Yes D No
of new products and processes? §63.1290(c) (2)
3 Are your plantwide HAP emissions, as calculated using Equation 1, D Yes D No
no more than five tons per year? §63.1290(c)(3)
38
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section II: Diisocyanate storage vessels checklist (Option 1 or 2)
. B. Requirements for Diisocyanate Storage Vessels
Comments
1 Does each diisocyanate storage vessel have a vapor-return line
(vapor-balancing system) or a carbon-adsorption system?
§63.1294(a)
D Yes D No
No. vessels with vapor-
return line:
No. vessels with carbon-
adsorption:
For each diisocyanate storage vessel with a vapor-return line, are
you visually inspecting for leaks each time diisocyanate is unloaded
from the tank truck or rail car? §63.1294(a)(l)(i)
n Yes D No
Date of last unloading:
Date of last visual
inspection:
For each diisocyanate storage vessel with a vapor-return line, did
you repair any leaks found before the next unloading event?
§63.1294(a)(l)(ii)
D Yes D No
Date of leak:
Date leak repaired:
Date next loading event:
No. vessels with leaks:
No. vessels repaired:
For each diisocyanate storage vessel with a carbon-adsorption
system, do you route displaced vapors through activated carbon?
§63.1294(a)(2j
D Yes - D No
For each carbon-adsorption system, do you replace the carbon after
you find the breakthrough and before the next unloading9
§63.1294(a)(2)
D Yes D No
Date ofbreakthrough:
Date of Carbon
Replacement:
Date of Next Unloading:
No. vessels with
breathrough:
C. Monitoring Requirements for Ditsocyanate Storage Vessels Comments
'SKIP, this section if you don't use a carbon-adsorption system on your storage vessels
1 Do you monitor the HAP or organic concentration in the exhaust-
vent stream or outlet stream's exhaust from the carbon adsorption
system during each unloading (or once a month if loading occurs
more often than monthly)? Or, do you monitor at a regular interval
established in your design analysis? §63.1303(a)(\),(T)
D Yes D No
No. storage vessels
measured at the carbon
adsorption system:
No. vessels using design
analysis:
39
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
C. Monitoring Requirements for Diisocyanate Storage Vessels Comments
SKIP this section if you don't use a carbon-adsorption system on your storage vessels
If you monitor the HAP concentration in the carbon-adsorption
system's exhaust, do you follow Method 18 and make the
measurement for at least one 5-minute interval while the vessel is
being filled? §63.1303(a)(3)
D Yes D No
Value Method 18:
If you monitor the organic concentration in the carbon-adsorption
system's exhaust, do you follow Method 25A and make the
measurement for at least one 5-minute interval while the vessel is
being filled? §63.1303(a)(4)
D Yes D No
Value Method 24:
For each carbon-adsorption system monitored according to
intervals in a design analysis, have you replaced the carbon at the
specified interval? §63.1303(a)(2)
D Yes D No
Design's Replacement
Interval:
Last Replacement of
Carbon:
D. Recordkeeping Requirements for Diisocyanate Storage Vessels
Comments
1 Do you have a list of diisocyanate storage vessels that includes the
type of control for each storage vessel? §63.1307(a)(l)
•D Yes D No
No. of storage vessels
No. of controls used:
If you're complying with the requirements for diisocyanate storage
vessels using carbon-adsorption, do you keep the following records?
§63.1307 (a) (3,
• Dates and times when you monitor the system for carbon
breakthrough
• Reading from the monitoring device each time you monitor it
• Date when your replaced the carbon
No. vessels using carbon-
adsorption:
D Yes D No
D Yes D No
D Yes n No
If you're complying with the requirements for diisocyanate storage
vessels using carbon-adsorption with alternative monitoring, do
you keep the following records? §63.1307(a)(3j
• Records of design analysis
• Dates and times when you monitor the system for carbon
breakthrough
Reading from the monitoring device each time you monitor it
• Date when you replaced the carbon
D Yes D No
D Yes D No
D Yes D No
D Yes D No
No. vessels using carbon
adsorption:
40
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
D. Recordkeeping Requirements for Diisocyanate Storage Vessels Comments
4 If you're complying with the diisocyanate storage using a vapor- No. vessels using vapor-
return line, do you keep the following records? §63.1307(a)(4). return:
§63.1307ff)
• Dates and times of each unloading event
• Dates and times of each inspection of the vapor-return line
• Dates and times each time you used the vapor-return line
• Dates and times you detect a leak in the vapor-return line
• Dates and times when you repair a leak in the vapor-return line
41
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section III: Diispcyanate transfer pump checklist (Option 1 or 2)
E. Requirements for Diisocyanate Transfer Pumps
Comments
1 Is each transfer pump in diisocyanate service either seailess or
submerged? §63.1294(b)
D Yes D No
No. of seailess pumps:
No. submerged pumps:
2 Have you completely immersed each submerged pump in bis(2- D Yes D No Submerging oil used:
ethylhexyl)phthalate (DEHP, CAS #118-81-7),
2(methyioctyl)phthalate (DINP, CAS #68515^8-0), or another
neutral oil? §63.1294(b)(2)(i)
3 Do you visually monitor each submerged pump weekly to detect D Yes n No Date last wkly inspection:
leaks? §63.12~94(b)(2)(ii)
4 When you detect a leak from a submerged pump, do you first D Yes D No Date Leak Detected.
attempt to repair it within 5 calendar days and actually repair it •
within 15 calendar days unless you've determined that your Date First Attempt at
equipment meets the delay of repair definition in §63.1294(d)? Repair:
§63.1294(b}(2)(iii)
' Date Leak Repaired:
. No. of pumps with leaks:
5 Does your first attempt to repair a leaking submerged pump include: D Yes D No
tightening of packing gland nuts and checking the seal flush to see if .
it is operating at design temperature and pressure?
§6S.1294(bH2tfiii)(Bj
F. Recordkeeping Requirements for Diisocyanate Transfer Pumps Comments
Complete this section only if you used submerged pumps ' : •
1 Do vou have a list of all submerged transfer pumps in diisocyanate D Yes D No No. transfer pumps:
service, including the date of installation and type of control0
§^.1307(b)(2)
1 For each submerged transfer pump that's leaking, do you attach to D Yes D No No. pumps with tags:
the equipment a readily visible identification number?
J63.1307^)(3)ft)(A)_•
3 For each submerged transfer pump that's leaking, do you remove the n Yes D No
tag only after you've repaired the pump? §63.1307(b)(3)(i)(C)
42
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
F. Recordkeeping Requirements for DUsocyanate Transfer Pumps
Complete this section only if you used submerged pomps
Comments
For each submerged transfer pump in diisocyanate service, do you
keep the following records each time you detect a leak
§63.1307(b)(3)Cii)
• Instrument and operator identification numbers and the
equipment identification number
• Date you detected the leak and dates of each attempt to repair
the leak.
• Repair methods applied in each attempt to repair the leak.
• Words "above leak definition" if applicable
• Words "repair delayed" and the reason for the delay if not
repaired within 15 calendar days. Date you expect to repair the
leak if not repaired within 15 calendar days
• Date you repaired the leak
• Date vou removed the identification
No. pumps in diisocyante
service:
D Yes D No
D Yes D No
D Yes D No
D Yes D No
D Yes D No
D Yes. D No
D Yes D No
43
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section IV: Other diisocyanate components checklist (Option 1 or 2)
<*. Requirements for Other Component? in Diisocyanate Service
Comments
1 If you detect a leak from other components in diisocyanate service,
do you first attempt to repair the leak within 5 calendar days and
actually repair it within 15 calendar days unless you've determined
that your equipment meets the delay of repair definition in
63.1296(f)? §63.1294(c)
D Yes D No
Date Leak Detected:
Date First Attempt
at Repair:
Date Leak Repaired:
No. of components with
leaks:
H. Recordkeeping Requirements for Other Components in Diisocyanate Service
Comments
1 Do you have a list of all other components in diisocyanate service?
§63.1307(bjfi)
D Yes D No
No. of components in
service:
2 For each other component in diisocyanate service that's leaking, do
you attached to the equipment a readily visible identification
number0 §63.1307(bj(3)(ijlA)
n Yes n No
No. components tags:
For each other component in diisocyanate service that's leaking, do
\ou remove the tag only after you've repaired the leak?
'§63.1307(b)(3)(i)(Q
D Yes D No
For each other component in diisocyanate service, do you keep the
following records each time you delect a leak §63.1307(b)(3j(ii)
• Instrument and operator identification numbers and the
equipment identification number
• Date you detected the leak and dates of each attempt to repair
the leak.
• Repair methods applied in each attempt to repair the leak.
• Words "above leak definition" if applicable
• Words "repair delayed" and the reason for the dela\ if not
repaired within 15 calendar days. Date you expect to repair the
leak if not repaired within 15 calendar days
• Date you repaired the leak
• Date you removed the identification
D Yes D No
n Yes D No
D Yes
D Yes
D Yes
D Yes
D Yes
D No
D No
D No
n No
D No
44
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section V: HAP ABA storage vessel checklist (Option 1)
Requirements for HAP ABA Storage Vessels
Comments
1 Have you equipped each HAP ABA storage vessel with a vapor
return line (vapor-balance system) or a carbon-adsorption system?
§63.1295(a)
D Yes n No
No. vessels with vapor-
retum line:
No. vessels with carbon-
adsorption:
For each HAP ABA storage vessel with a vapor-return line, is the
line connected from the storage vessel to the tank truck or rail car
during each unloading? §63.1295(b)
D Yes D No
For each HAP ABA storage vessel with a vapor-return line, do you
inspect (visual, audible, olfactory, or other detection method) for
leaks each time HAP ABA is unloaded from the tank truck or rail
car17 §63.1295(bi(li
D Yes D No
Date Last Unloading:
Date last visible inspection:
For each HAP ABA storage vessel with a vapor-return line, if you
found a leak, did you repair ii before the next unloading event?
§63.1295 rbj(2)
D Yes D No
Date of leak:
Date Leak Repaired:
Date Subsequent
Unloading:
No. of vessels with leaks:
No. of vessels repaired:
For each HAP ABA storage vessel with a carbon-adsorption
system, do you route displaced vapors through activated carbon
before discharging into the atmosphere? §63.1295lc)
Yes D No
For each carbon-adsorption system, do you replace the carbon after Q Yes D No
you find breakthrough and before the next unloading? §63.1295 fc)
Date of breakthou°h:
Date of carbon replacement:
Date of Subsequent
Unloading:
No. vessels with
breakthrough:
45
-------
Table 3.3 Checklist for inspecting Slabstock Foam Plants (cont'd)
J. Monitoring Requirements for HAP ABA in Storage Vessels
Comments
1 Do you determine the amount of HAP ABA in each storage vessel D Yes D No Method used:
weekly? §63.1303(d)
Bfcfie Last Measurement:
2 Do you monitor the amount of HAP ABA in each storage vessel with D Yes D No
a level-measurement device? §63.1303(d) • • .
3 Did you calibrate each level-measurement device initially and then D Yes D No Done of Annual
annually? § 63.1303(d)(l) Calibration:
4 Unless the level-measurement device is a visually read device, such D Yes D No Type of output.
as a gauge glass, does the device have a digital or printed output?
$63J303(d)& _ __
5 If the level-measurement device is a visually read device, does it D Yes D No
have permanent graduated markings to show the HAP ABA level in
the storage tank? §63.1303(d)(3)
K. Monitoring Requirements for HAP ABA added to Storage Vessels Conments
1 Do you monitor the amount of HAP ABA added to a storage vessel D volume No vessels using volume:
by measuring the volume, weight or by an alternative monitoring n weight
program? §63.130S(e) D alternate No-, vessels using weight:
No. vessels using alternate:
2 If you measure using volume, do you record the volume of HAP n Yes D No ' Daiie Last Delivery':
ABA in each storage vessel before and after each delivery?
§63. ISOStej/lj Volume before last delivery:
Vofame after last delivery:
3 If you measure using the volume of HAP ABA delivered, does your D Yes D No
measurement device follow the requirements outlined in section J of
trus checklist?^6.iJ.?fo'(e;<7;
4 If measuring using volume, is volume flow rate measured using a " D Yes D No Device Accuracy:
device with an accuracy of ±2.0% ? §63.1303(e)(2)
5 If measuring using volume, did you calibrate your device initially D Yes D No Daae Initial Calibration:
and at least once ever.- 6 months? §63.1303(e)(2)
Date Last 2 Calibrations: -
46
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
K Monitoring Requirements for HAP ABA added to Storage Vessels
Comments
If measuring weight, do you measure by calculating the difference of D Yes D No
the full weight of the transfer vehicle prior to unloading and the
empty weight of the transfer vehicle after unloading? §63.1303(e)(3)
Date of last transfer:
Wt of last full transfer
vehicle:
Wt of last empty transfer
vehicle.
If measuring weight, is your scale approved by your State or local
agency using procedures in Handbook 44 or is it certified once per
year by a registered scale technician? §63.1303(e)(3)(i) and (ii)
D Yes D No
No. scales approved by
State:
No. scales approved by
technician:
If your using an alternative monitoring program, have you
submitted the plan for approval? Has the plan been approved?
§63.1303 (e'i (4)
D Yes D No
Date Plan Submitted:
Date Plan Approved:
L Monitoring Requirements for Storage Vessels with Carbon-Adsorption Comments
SKIP this section if you don't use a carbon-adsorption system on your storage vessels
1 Do you monitor the HAP or organic concentration in the exhaust-
vent stream or outlet stream's exhaust from the carbon adsorption
system during each unloading (or once a month if loading occurs
more often than monthly)? Or. do you monitor at a regular interval
established in your design analysis':' §63.1303(at(l).(2)
D Yes D No
No. storage vessels
measured at the carbon
adsorption system:
No. vessels using design
analysis:
If you monitor the HAP concentration in the carbon-adsorption
system's exhaust, do you follow Method 18 and make the
measurement for at least one 5-minute interval while the vessel is
being filled" §63.1303
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
M. Recordkeeping Requirement for HAP ABA Storage Vessels
Comments
1 Do you have a list of HAP ABA storage vessels that includes the
type of control for each storage vessel? §63.1307(a)(2)
D Yes D No
No. vessels using emission
point specific limit:
If you're complying with the requirements for HAP ABA storage
vessels using carbon-adsorption, do you keep the following records?
§63.1307(a)(3)
• Dates and times when you monitor the system for carbon
breakthrough
• Reading from the monitoring device each time you monitor it
• Date when your replaced the carbon
No. vessels using carbon-
adsorption:
D Yes D No
D Yes D No
D Yes D No
If you're complying with the requirements for HAP ABA storage
vessels using carbon-adsorption with alternative monitoring, do
you keep the following records? §63.1307(a)(3)
• Records of design analysis
• Dates and times when you monitor the system for carbon
breakthrough
• Reading from the monitoring device each time you monitor it
• Date when you replaced the carbon
No. vessels using carbon
adsorption:
D Yes D No
D Yes D No
D Yes D No
D Yes D No
If you're complying with the HAP ABA storage using a vapor-return
line, do you keep the following records? §63.1307(a)(4),§63.13Q7(f)
• Dates and times of each unloading event
• Dates and times of each inspection of the vapor-return line
• Dates and times of each use of the vapor-return line
• Dates and times you detect a leak in the vapor-return line
• Dates and times when you repair a leak in the vapor-return line
D Yes D No
D Yes D No
D Yes D No
D Yes n No
No. vessels using vapor-
retum:
48
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section VI: HAP ABA equipment leaks checklist (Option 1)
N. Requirements for HAP ABA Equipment Leaks Comments
Note: Equipment leak requirements are for transfer pumps, valves, connectors, pressure-
relief devices and open-ended lines
I Is each pump in HAP ABA service either sealless or monitored for D sealless
leaks? §63.1296(a) . D monitored
No. sealless pumps:
No. pumps monitored:
if you 're using a sealless pump, skip item 2-4 and go to 5
1 Do you monitor each pump quarterly by using Method 21 and d Yes D No Last Quarterly Inspection:
weekly by visual inspection? §63.1296(a)(2)(i),(ii); §63.1304(a)
Value Method 21:
3 If you detect a pump leak, do you first attempt to repair it within 5 D Yes D No Date Leak Detected:
calendar days and actually repair it within 15 calendar days unless
you've determined your pump meets the delay of repair under Date First Attempt at
'§tt.U9f>(rSl§63.i296(a,(2>(ui; - Repair:
Date Leak Repaired:
' No . of pumps with leaks:
•1 Does your first attempt to repair a leaking pump include: tightening D Yes D No
of packing gland nuts and ensuring the seal flush is operating at it's
design pressure and temperature0 §63.1296(a/(2)(iii)(B')
5 Do you monitor each valve quarterly using Method 21? D Yes D No Last Quarterly Inspection:
$63.1296
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
N. Requirements for HAP ABA Equipment Leaks Comments
Note: Equipment Leak requirements are for transfer pumps, valves, connectors, piessure-
relief devices And operKnded Ibes
8 For each valve you've designated as unsafe-to-monitor. do you have
a written plan that requires monitoring as often as possible and •
repair of leaks as soon as possible? §63.1296(b)(3)(i\)
D Yes D No
No. of unsafe-to-monitor
valves:
Note: unsafe-to-monitor valves are those valves that can't be
monitored because personnel would be exposed to an immediate
danger situation. §63.1296(b)(3)(i)
Do you monitor and repair each unsafe-to-monitor valve according to D Yes D No
your written plan? §63.1296(b)(3)(iii) and (iv)
Date Last Monitored:
Ran Requirements for
Monitoring:
Date Leak Last Detected:
Date Leak Repaired
Plan Requirements
for Leak Repair
10 For t.-.- h valve you've designed as difficult-to-monitor. do you have a
written plan that requires monitoring at least once per calendar year
and repair of leaks as soon as possible? §63.1296(b)(4)(iii)
D Yes D No
No. of difficult-to-monitor
valves:
Note: difficull-to-monitor valves are those valves that can't be
monitored without elevating personnel more than 2 meters
above a support surface or the valve is not accessible at any time
in a safe manner. Your valve must be an existing source or a
ne\\ source where you have designed <3% of your valves as
diiTicult-to-monitor. §65.1296(b)(4i(i). (ii)
11 Do you monitor and repair each difficult-to-monitor valve according
to your written plan"7 §63.1296(b)(4)(ivj and (\)
U Yes D No
Plan Requirements for
Monitoring:
Date Last Monitored:
Plan Requirements for Leak
Repair:
Date Leak Last Detected:
Date Leak Repaired:
50
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
N. Requirements for HAP ABA Equipment Leaks Comments
Note: Equipment leak requirements are for transfer pumps, valves, connectors, pressure-
relief devices and open-ended lines
12 Do you monitor each connector annually using Method 21?
§63.1296(c)(l); §63.1304(a)
U Yes D No
No of connectors monitored
using Method 21:
Date Last Monitored:
Value Method 21:
13 If you've opened a connector or broken its seal, do you monitor it D Yes O No Date Connector
for leaks within the first 3 months after it's used for HAP ABA Opened/Seal Broken:
again? §63.1296(c) (1) (iij
Date Connector Monitored:
No. Connectors
Opened/Seal Broke:
14 If you've detected a leak, do you monitor the connector within the D Yes D No Date Leak Detected:
first 3 months after its repair"" §63.1296(c)(l)(iii)
Date Leak Repaired:
Date Leak Monitored:
No. Connectors with Leaks::
15 If you detect a connector leaking, do you try to repair it within 5 n Yes n No Date Leak Detected:
calendar days and repair it within 15 calendar days unless you've
determined your pump meets the delay of repair under §63.1296! IT Date First Attempt at
§63.1296(cj(2\ Repair:
16 For each connector designated as unsafe-to-monitor. do vou have a n Yes D No No. unsafe-to-monitor
written plan that requires monitoring as often as possible and repair connectors:
of leaks within 6 months0 §6S.I296(c)(3), fc)(-!jdi)
Note: unsafe-to-monitor connectors are those that can't be
monitored because personnel would be exposed to an immediate
danger situation. §63.]296(c)(S)(i)
17 Do you monitor and repair each unsafe-to-monitor connector
according to your written plan? §63.1296(c)(3)(ii)
D Yes D No
Plan Requirements for
Monitoring:
Date Last Monitored:
51
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
N. Requirements for HAP ABA Equipment Leaks Comments
Note: Equipment leak requirements are for transfer pumps, valves, tonnectors, pressure-
relief devices and open-ended lines
Plan Requirement for Leak
Repair:
18 For each connector designated as unsafe-to-repair. do you repair the D Yes n No
connector as soon as possible but no later than 6 months after you
detected the leak? §63.1296(c)(4)(ii)
Date Leak Detected:
Note: unsafe-to-repair connectors are those that can't be
repaired because personnel would be exposed to an immediate Date Leak Repaired:
danger situation. §63.1296(c)(4)(i)
19 If you find evidence of a potential leak by visual, audible, or D Yes D No Date Potential Leak Last
olfactory detection, do you monitor the pressure-relief device using Detected:
Method 21 within 5 caiendar days? §63.1296(d)(l); §63.1304(a)
pate Monitored:
Results Method 21:
20 If you detect a leak a pressure-relief device, do you first attempt D Yes D No No. pressure-relief devices
repair it within 5 calendar days and actually repair it within 15 with leaks:
calendar days unless you've determined your pump meets the delay
of repair under §63.1296(f)? §63.1296(d)(2) Date Leak Detected:
Date First Attempt at
Repair:
Date Leak Repaired:
21 Have you equipped each open-ended valve or line in HAP ABA D Yes D No
service (except those in an emergency-shutdown system designed to
open automatically during a process upset) with a cap, blind flange,
plug, or a second valve? §63.1296(e)fi)
22 Do you keep open-ended valve or line sealed at all times, except D Yes D No
when in use or during maintenance or repair? §63.1296(e)(l)(ii)
23 For each open-ended vahe or line with a second valve, do you close n Yes D No No. valves or lines with
the valve on the process fluid end before closing the second valve? second valve:
§63.1296
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
O. Recordkeeping Requirements for HAP ABA Equipment Leaks Comments
2 For each component in service that's leaking, do you attached to the O Yes D No No. components with tags:
equipment a readily visible identification number?
For each component in service that's leaking, do you remove the tag D Yes D No
only after you've repaired the equipment or after 2 successive
quarters of no leaks if your equipment is a valve?
§63.1307(b)(3}(i)(C)
Do you keep the following records for components in service?
§63.1 307 (bj
Instrument and operator identification numbers and the D yes n -^j0
equipment identification number
Date you detected the leak and dates of each attempt to repair
the leak. D Yes D No
Repair methods applied in each attempt to repair the leak. D * es D ^°
Words "above leak definition" if applicable D Yes D ^°
Words "repair delayed" and the reason for the delay if not D Yes D ^°
repaired \\ithin 15 calendar days. Date you expect to repair the
leak if not repaired within 15 calendar days
Date you repaired the leak _ y Q N
Date vou removed the identification Y n N
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
53
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section VII: HAP ABA production line checklist (Option 1)
P Requirements for HAP ABA Emissions from the Production lane
Comments
1 Do you determine compliance with the HAP ABA emission limits D rolling-annual
from the production line by using a rolling-annual or monthly n month]v
basis? §63.1297(a)
No. lines using rolling-
annual:
No. lines using monthly:
2 If you switch between the rolling-annual and monthly compliance D Yes D No Date switched options:
options, do you make notification 180 calendar days prior to making
the change0 §63.1297(a)(3)
Date of notification:
3 If you determine compliance on a rolling-annual basis, and don't D Yes D No Value actual HAP ABA:
use a recover) device, are actual HAP ABA emissions for each
consecutive 12-month period less than allowable HAP ABA
emissions for the same consecutive 12-months° §63.1297(b) Value allowable HAP ABA:
4 If you determine compliance on a rolling-annual basis, and don't D Yes D No Value actual HAP ABA for
use a recovery device, do you calculate actual HAP ABA emissions last 12 months:
as the sum of actual monthly HAP ABA emissions for each 12 month
,period? $63.1297(b,fl •
Value allowable HAP ABA:
5 If you determine compliance on a rolling-annual basis, and don't D Yes D No Value Equation 2:
use a recovery device, do you use Equation 2 in §63.1297(b>(2i to <•
calculate allowable HAP ABA emissions on the production for the
12-month period0 §63.1297<2>: S63.1297(c)W
6 If you determine compliance monthly, and don't use a recovery D Yes D No Value actual HAP ABA:
device, do you compare actual HAP ABA emissions to allowable
RAP ABA emissions for each month0 Do you determine actual by
using HAP ABA added to the production line at the mixhead0 Value allowable HAP ABA
§6U29~
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
P. Requirements for HAP ABA Emissions from the Production Line
Comments
10 Except for formulation limits of zero, do you determined a HAP D Yes D No No. grades produced:
ABA formulation limit for each grade of foam produced?
Formulation limit value:
11 Except for formulation limits of zero, for each existing source, do D Yes D No Value equation 3:
you use Equation 3 in §63.1297(d) to calculate HAP ABA
formulation limit? J63.1297(d)(l)
12 Except for formulation limits of zero, for each new source, do you D Yes n No Value equation 3:
use Equation 3 in §63.1297(d) to calculate the HAP ABA
formulation limit for each grade of foam with a density of 0.95
pound per cubic foot or less? §63.1297fd)(2)(i)
13 Except for formulation limits of zero, for each new source, do vou D Yes D No Value equation 3:
use Equation 3 in §63.1297(d) to calculate the HAP ABA
formulation limit for each grade of foam with a density of 1.4
pound per cubic foot or less and an Indentation Force Deflection
(IFD) of 15 pounds or less0 §63.1297(d)(2)(ii)
14 Except for formulation limits of zero, for each new source, with a D Yes D No Density:
foam grade density greater than 0.95 pounds per cubic foot and an
FD greater than 15 pounds, is the HAP ABA formulation limit
zero0 §63.1297(d)(2}(iii> ^^"^l
15 Except for formulation limits of zero, for each new source with a D Yes D No Density:
foam grade density greater than 1.40 pounds per cubic foot, is the
HAP ABA formulation limit zero? $63.1297(dj(2tftvj
Formulation limit:
16 Except for formulation limit* of zero, do you determine the IFD and D Yes D No Last production start date
density for each foam grade within 10 working days of its production
using §63.1304(b.iV (63.1297(d>(3j
Last IFD and density
determination:
17 If you're using a recovery -device and determine compliance on a D Yes D No Value equation 2:
rolling-annual or monthly basis, do you calculate allowable HAP
ABA emissions using Equation 2 in §63.1297(e) monthly?
§63.1297'(e)
18 If vou're using a recovery -device and determine compliance on a D Yes P No Value equation 4:
rolling-annual or monthly basis, do you calculate actual monthly
HAP ABA emissions according to Equation 4 in §63.1191 (ef!
§63.1297 (e)(l)
19 If you're using a recovery-device and determine compliance on a O Yes D No No. recovery-devices used:
rolling-annual or monthly bash, have you submitted a HAP ABA
monitoring program for approval? §63.1297(e)(2);§63.1303(c)
Date plan submitted:
55
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Q. Monitoring Requirements for HAP ABA Emissions from the Production Line when a Comments
Recovery Device is Used
SKIP this section if you don't use a recovery device
1 Have you sent a recovered HAP monitoring and recordkeeping plan n Yes D No
in for approval? §63.1303(c)
Date Sent:
Date Approved: '
Does your equipment have a device showing the cumulative amount
of HAP ABA recovered by the solvent-recovery device each month?
§63.1303(c)(l)
D Yes D No
Last cumulative monthly
. value:
Has the manufacturer certified the device to be accurate within +/-
2.0 percent0 §63.1303(cj(]j
D Yes D No
Device accuracy:
Do you measure after fully recovering the HAP ABA (i.e.. after
separating it from water introduced into the HAP ABA during
regeneration)? §6.\ 1303(c)f2)
D Yes D No
R. Monitoring Requirements for HAP ABA and Pohol added to the Production Line at the Comments
mixhead ,
1
•>
3
4
5
6
Do you continuously monitor the amount of HAP ABA added at the D Yes D No
mixhead when foam is being poured or monitor under an alternative
monitoring program0 §63.1303(bj((l)(ij
When monitoring HAP ABA added, do you measure using flo\v D Yes D No
ra\e"§63.1303(b)(iljtiij
When measuring HAP ABA added, does your monitoring device D Yes D No
have an accuracy to within ±2.0 percent of the HAP ABA being
measured^1 §65.130$'bi(3i
When measuring HAP ABA added, did you calibrate your D Yes D No
measuring device initialh and at least once each month?
§65.1303(b)(3i(iii
Are vou measuring HAP ABA at the beginning and end of a run of D Yes D No
foam for the production of each grade of foam? §63.1303(b)(4)
Do you continuously monitor the amount of polyol added at the D Yes D No
mixhead according to the rule or an alternative monitoring
program? §63.1303(b)(l)(i)
Device Accuracy;
Date Initial Calibration:
Date Last 2 Calibrations:
Value last beginning run
Value last end run:
56
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
R. Monitoring Requirements for HAP ABA and PoJyol added to the Production Line at the Comments
mixhead
7 If you're monitoring the amount of polyol, are you measuring using D Yes D No No. monitoring using
pump revolutions or flow rate? §63.1303(b)(2) revolutions:
.No. monitoimg using flow
rate:
8 If your monitoring the amount of polyol, does your monitoring device D Yes D No Device Accuracy:
have an accuracy to within ±2.0 percent of the HAP ABA being
measured? §63.13 03 (b) (3}
9 If your monitoring the amount of polyol, did you calibrate your D Yes D No Date Initial Calibration:
measuring device initially and at least every 6 months?
§63.1303(b)(3)(i)
Date Last 2 Calibrations:
10 Are you measuring polyol at the beginning and end of a run of foam D Yes D No Last beginning value:
for the production of each grade of foam? §63.1303(b)(4)
Last end value:
11 If your using an alternative monitoring program, have you c Yes n No Date Plan Submitted
submitted the plan for approval? Has the plan been approved?
§63.1303(b)(S)
Date Plan Approved:
S. Recordkeeping Requirements for HAP ABA at the Production Line Comments
1 Do you have a list of HAP ABA Production lines? §63.1307(b)(ii) D Yes C No
2 If you're complying using the rolling-annual or monthly
compliance option, do you keep the following production-line
records daily0 §6$.1307(c,fl)(is
• Foam run log. with a list of the grades produced during each run
• Amount of polyol added to the production line for slabstock
foam at the mixhead for each run D Yes D No
• Results of the density and IFD testing for each grade of foam
produced during each run of foam (not required on grades of a Yes D No
foam for which you've designated a zero formulation limit for
HAP ABA)
57
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
S. Recordkeeping Requirements for HAP ABA at the Production Line
Comments
3 If you're complying using the rolling-annual or monthly
compliance option, do you keep the following records for each
month? §63.1307 (c)(l)(ii)
• Listing of all foam grades produced during the month
• Formulation limit for HAP ABA on each foam grade produced
Total allowable HAP ABA emissions for the month
• Total amount of HAP ABA added at the mixhead during the
month
Total amount of polyol used in the month for each foam grade4
produced (not required on grades of foam for which you've
designated a zero formulation limit for HAP ABA)
D Yes D No
D Yes D No
D Yes D No
D Yes D No
D Yes D No
If you're complying using the rolling-annual or monthly
compliance option, do you keep the following records for each
month? §63.1307
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section VIII: HAP ABA equipment cleaning checklist (Option 1)
U. Requirements for HAP ABA Equipment Cleaning Comments
1 Are your cleaning operations free of HAP or HAP based materials? O Yes D No
§63.1298
V. Recordkeeping Requirements for HAP ABA Equipment Cleaning Comments
1 Do you have a product data-sheet for each equipment cleaner you D Yes D No
used? Does the product data-sheet include the HAP content, in kg of
HAP/kg solids (or Ib of HAP/lb of solids)7 §63.1307(e)
D Yes D No
59
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section IX: Sourcewide emission limit checklist (Option 2)
W. Requirements for Sourcewide Emission Limit Comments
Note: Hiis includes emissions irom HAP ABA storage and equipment leaks, HAP ABA
emissions from the production line and equipment cleaning
1 Do you use rolling-annual or monthly methods to comply with the D annual
sourcewide allowable limits on HAP ABA emissions? §63.1299
2 If you determine compliance on a rolling-annual basis and don't use D Yes D No Actual sourcewide value:
a recovery device, are actual sourcewide HAP ABA emissions from
the facility (including storage, equipment leaks, production line, and Allowable sourcewide
equipment cleaning) less than the sourcewide allowable HAP ABA value:
emissions for each consecutive 12-month period? §63.1299(aj
3 If you determine compliance on a rolling-annual basis and don't use D Yes D No Value Equation 6:
a recovery device, do you calculate allowable HAP emissions for 12
consecutive months using equation 6? §63.1299(a); §63.1299(d>
4 If you determine compliance on a rolling-annual basis and don't use D Yes D No Value Equation 5:
a recover) device, do you use Equation 5 in §63.1299(c; to calculate
the actual, monthh sourcewide HAP emissions? §63.1299(c)/Ij
5 If you determine compliance on a rolling-annual basis and don't use D Yes D No Last weekly value:
a recovery device, do you determine the amount of HAP ABA in a ,
storage vessel weekly by monitoring using a level measurement
device''§63.1299(c>'(2j~: §63.1303(d)
6 If you determine compliance on a rolling-annual basis and don't use D Yes D No Last monthly value:
a recovery device, do you determine the amount of HAP ABA added
to the storage vessel monthly by summing the individual HAP ABA
deliveries thai occur in thai month0 §63.}299(c>(3>; §63.1303
60
U.S. EPA Headquarters Library
Mai! code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460 -
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
W. Requirements for Sourcewide Emission Limit Comments
Note: This includes emissions from HAP ABA storage and equipment leaks, BAP ABA
emissions from the production line and equipment cleaning
11 If you don't use a solvent-recovery device and you determine D Yes D No Last monthh value:
compliance on a monthly basis, do you determine the amount of
HAP ABA added to the storage vessel monthly by summing the
individual HAP ABA deliveries that occur in that month?
§63.1299(c)(3); §63.1303(e)
12 If you determine compliance on a rolling-annual or monthly basis D Yes D No Value Equation 6:
and you use a solvent-recovery device, do you use Equation 6 to
calculate the allowable HAP emissions for each month? §63.1299(e)
13 If you determine compliance on a rolling-annual or monthly basis D Yes D No Value Equation 7:
and you use a solvent-recovery device, do you use Equation 7 to
calculate actual, monthly, HAP ABA emissions? §63.1299(e)(l) .
14 If you determine compliance on a rolling-annual or monthly basis D Yes D No Submittal date:
and you use a solvent-recovery device, have you submitted a HAP Approval date'
ABA monitoring program for approval? §63.1299(e)(2); §63.1303fcj
X. Monitoring Requirements for Sourcewide Emissions when a Recovery Device is Used Comments
SKIP this section if you don't use a recovery device
1 Have you sent a recovered HAP monitoring and recordkeeping plan D Yes D No Date Sent:
in for approval? §65.1303(c)
Date Approved:
2 Does your equipment have a device showing the cumulative amount D Yes D No Last cumulative monthK
of HAP ABA recovered by the solvent-recovery device each month9 value:
§63.1303(0(1,
? Has the manufacturer certified the device to be accurate within -*•/- D Yes D No Device accuracy
2.0 percent0 §63.130}d>
-4 Do you measure after fully recovering the HAP ABA (i.e., after O Yes D No
separating it from water introduced into the HAP ABA during
regeneration)? §63.1303(c)(2j
61
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Y. Recordkeeping Requirements for Sourcewide Emissions Comments
•
1 If you're complying using rolling-annual or monthly compliance
option, do you keep the following production-line records daily?
§63.1303(c)(2)(i)
• Foam run log, with a list of the grades produced during each run D Yes D No
• Amount of polyol added to the production line for slabstock D Yes D No
foam at the mixhead for each run (not required if zero is the
formulation limit for HAP ABA)
• Results of the density and IFD testing for each grade of foam n y n y,
produced during each run of foam (not required on grades of
foam for which you've designated a zero formulation limit for
HAPABA)
2 If you're complying using rolling-annual or monthly compliance
option, do you keep weekly records of the storage tank level0
If \ou're complying using rolling-annual or monthly compliance
option, dc vou keep the following records monthly?
.
. D Yes D No
• List of all foam erades produced during the month
D Yes- D No
• Formulation limit on residual HAP for each foam grade
produced
• Total amount of polyol used in the month for each foam grade C } es D No
produced (not required if zero is the formulation limit for RAP
ABA| ' C Yes c No
Total allowable HAP ABA and equipment-cleaning emissions
for the month
• Total actual source\vide emissions of HAP ABA for the month
Amounts of H.AP ABA in the storage vessel at the beginning """ '""
and end of the month
• Amount of each delivery of HAP ABA to the storage vessel c Yes D No
If complying by the rolling-annual or monthly option, do you keep
the following" §65.1307(cjf2)(vj - (viij
• Records of all calibrations for each device used to measure
polyol added at the mixhead D \ es . D No
• Records of all calibrations for each device used to measure ._. y _ »,
amount of HAP ABA in the storage vessel
• \Vntten confirmation of State or local approval of scales, or the
registered scale technician's report for all scales used to D Yes D No
measure the amount of HAP ABA added to storage vessels
62
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Y. Recordkeeping Requirements for Sonrcewide EmiitioBS Comments
5 If you're complying using the rolling-annual option, do you keep the
following records monthly? §63.1307(c)(2)(iv)
• Total allowable HAP ABA and equipment-cleaning emissions of n yes n No
HAP for the month and the previous 11 months.
• Total actual HAP ABA and equipment-cleaning emissions of
HAP for the month and the previous 11 months. D Yes D No
Z. Recordkeeping Requirements for Sourcewide Emissions when a Recovery Device is Used Comments
SKIP this section if you don't use a recovery device
1 If you're complying using a recovery device, do you keep the
following records? §63.1307'(d)
• Copy of your monitoring and recordkeeping program for D Yes D No
recovered HAP ABA
Certification of the monitoring device's accuracy D Yes D No
• Records of periodic calibration of the monitoring device D Yes D No
Records of parameter-monitoring results D Yes D No
Amount of HAP ABA recovered each time YOU measure it D > es D No
63
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Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section X: Testing checklist (Options 1 or 2 as required)
AA. Testing Requirements
Comments
1 For each time you use Method 21, is the instrument's response factor D Yes D No
based on the fluid's average composition, rather than on the
individual VOC in the stream? §63.1304 (a)(2)
2 If the source stream contains nitrogen, air, or other inerts that aren't D Yes D No
HAP or VOC. do you calculate the average stream response factor on
an inert-free basis? §63.1504 (a)(2)
3 Do you calibrate the detection instrument before each use on the day D Yes D No Date Last Use:
of its use according to Method 21, Appendix A, of 40 CFR Part 60?
§63.1304 (at (3) Date Last Calibration:
4 Are calibration gases zero air (less than 10 ppm of hydrocarbon in D Yes D No Calibration gas used:
air)0 §63.1304 (a) (4,
5 Are calibration gases a mixture of methane and air at a concentration D Yes D No
of about 1.000 ppm for all transfer pumps and 500 ppm for all other
equipment0 $63.130-1 (a>(4.i
6 '!' the insirument design allows for multiple concentrations of gas. is D Yes D No
the lower concentration no higher than 2.000 ppm methane and the
higher concentration no higher than 1.000 ppm methane0 §63.130-1
fan'4,
1 Do you monitor when the equipment is in HAP ABA service, with an D Yes D No
acceptable surrogate volatile organic compound that isn't a HAP
ABA. or with any other detectable gas or vapor0 §63.1304 iaj(5/
8 If the instrument used for monitoring doesn't meet the performance D Yes D No Value average response
criteria in Method 21. do you adjust readings by multiplying the factor:
average response factor for the stream0 §63.1304
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section XI: Reporting Requirements (Options 1 or 2)
BB
1
2
3
4
5
6
7
S
Reporting Requirements
Did you send in an initial notification form? §63.1306(a) D Yes Q No
Have vou applied for approval of construction or reconstruction? D Yes Q No
§63.1 306 fbj
Did you send in a precompliance report? §63.1306(c) D Yes G No
Did you send in a notification of compliance status? Q Yes D No
§63.'l306(d)(4)
Do you send in semiannual compliance reports no later than 60 D Yes G No
days after the end of the 1 80-day period? §63. 1306(e)
Do you submit an annual compliance certification? §63.1306(& D Yes G No
If you switch from emission point specific limit to sourcewide D Yes D No
limit, or vice versa, did vou make rotification before changing9
§63.1306(fj
If vou switch from rolling-annual to monthly, or vice versa, did EJ Yes G No
you make notification before changing0 §63. 1306(0
Continent* ^'^ • :\ V ' ']
Date submitted:
Date submitted:
Date submitted:
Date submitted:
Date end of period:
Date submitted:
Date first certification
due:
Date certification
submitted:
Date Notification
•-Submitted:
Date Limit
Switched:
Date Notification
Submitted:
Date Method Switched:
Additional comments:
65
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Chapter 4 - Complying with requirements for molded foam
What does the Molded section cover?
§63.1300 of the rule covers your molded foam process if your process meets all of the following
conditions:
• emits a HAP
• is a molded foam production process
• is located at a plantsite that is a major source of HAPs
• is not exempt
Definition A molded flexible poly-urethane process
means "a flexible polyurethane foam that is produced by
shooting the foam mixture into a mold of the desired
shape and size. Molded foam is primarily used in
automobile, furniture, packaging, textiles and fiber
manufacturing "
Figure 4.1 (on page 67) shows a typical process for molded foam.
About this Chapter:
• Whenever you see "§. " we are
referring to the section number
of the rule. You can go to that
section in the rule for more
• information
» When you see a definition, it
comes straight from the rule
What is exempt under this section?
Your molded foam process is exempt if it's devoted exclusively to either of the following
[§631290]: ''
• fabricating molded foam
conducting research and development
Definition. Research and developmem process means "a laboratory1 or pilot plant operation
whose primary purpose is to conduct research and development into new processes and
products, where the operations are under the close supervision of technically trained personnel.
and which is not engaged in the manufacture of products for commercial sale except in a dc
minimis manner."
Definition. Foam fabrication process means "an operation for cutting or bonding flexible
pol\-urethane foam pieces together or to other substrates."
66
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Figure 4.1
A Typical Process for Molded-Foam Production
Process Description:
Raw chemicals are unloaded into storage vessels. The chemicals are then pumped to a
pouring head. The molds are sprayed with a mold release agent and preheated. After the
chemicals are added to the mold, the mold is closed and heated to accelerate the cure. As
the molds are opened, the product is taken out, and the mold is cleaned. Foam pieces
removed from the mold are then crushed. Crushing breaks open the cells that release
carbon dioxide, and holes are repaired. The piece is then ready for packaging and sale.
Raw Chemical
Unloading
Process Diagram:
Mold
Raw Chemical
Dispensing
from Pouring Head
&ppljcaiion of Release Agent
Mold Conditioning
Mold Opening and Emptying
Foam
Product
67
-------
What compliance options do I have?
You have two compliance options for molded foam.
Option 1: do not use HAP-based materials in any of the following ways [§63.1300(a), (b)]:
»• as an equipment cleaner to flush the mixhead (except for diisocyanates)
* as an equipment cleaner elsewhere in the process
* as a mold-release agent
Definitions. i
i
mold-release agent means "any material (when applied to j
the mold surface) which prevents sticking of the foam part !
to the mold."
HAP-based means "any compound used as an equipment
cleaner or mold-release agent that contains five percent (by
weight) or more of HAP."
mixhead means "a device that mixes two or more
component streams before dispensing the foam producing :
mixture to the desired container."
The rule does allow you to use diisocyanates (but no other HAP) for flush cleaning the mixhead
and associated piping. However, if you do use diisocyanates for flushing, you must meet all of
the following conditions [§63.1300(a)]:
> flushing occurs only during startup or maintenance
» diisocyanates are contained in a closed-loop system
»• diisocyanates are reused in production
Option 2: you may submit an alternative means of emission limitation under §63.1305. You
can submit your request in your Precompliance Report, your Application for Approval of
Construction or Reconstruction, or at any other time, as long as it contains the information
required in §63.1305. Your request must be approved by the EPA before you use it. See
Chapter 7 for additional information.
What monitoring must I do?
None for molded foam production.
68
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What records must I keep?
You must keep two basic pieces of information for each molded foam process [§63.1307(g), (h)]:
a product data-sheet (e.g., MSDS) for each solvent and mold-release agent you use
• the HAP content for each solvent or mold-release agent you use (in kg of HAP/kg solids or
Ib HAP/lb solids)
What reports must I submit?
You must submit four t\pes of reports on each molded foam plant:
• an initial notification [§§63.1306(a), 63.9(b)]
• an application for approval for construction or reconstruction [§§63 1306(b). 63.5(d)]
• a notification of compliance status [§63.1306(d)]
• an annual compliance certification [§63.1306(g)J
For additional reporting information including dates and example forms, see Chapter 7. The forms
are optional, but you may find them useful.
How do I show compliance?
You can show compliance with §63.1300 by following all these requirements [Table 5 of the rule]:
• don't use a HAP -based material as an equipment cleaner (except for diisocyanates)
[§63.1300(a)]
• don't use a KA.P-based mold-release agent [§63.1300(b)j
« maintain product data-sheets for each solvent you use [§63.1307(g)J
• maintain product data-sheets for each mold-release agent you use [§63.1307(h)]
You will violate §63.1300 if you do any of the following [§63.1308(e)]:
• fail to meet the requirements in §63.1300
• use a HAP-based material in the molded foam process (except for diisocyanates)
• use a HAP-based mold-release agent
Is an inspection checklist available?
We've included an inspection checklist in Table 4.1 (on page 70). You can use the checklist when
you check your foam plant for compliance with the rule.
69
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Table 4.1 Checklist for Inspecting Molded foam Plants
Facility Name:
Facility Location:
Facility TRI ID #:
Person Conducting Evaluation:
Date of Evaluation:
A. HAP Usage Comments
Note: If you answer NO to ALL questions in Section A, don't proceed Your molded
foam process isn't covered because you don't use HAPs.
1 Do you use HAPs as an equipment cleaner to flush the mixhead or
associated piping9 §63.1 SCO (a)
D Yes o No
You may use diiscyanates as an equipment cleaner if you follow
procedures in section B. If you use diisocyanates as an equipment
cleaner, complete section B.
2 Do you use HAPs as an equipment cleaner elsewhere in the process? D Yes D No
§6S.1300(a)
3 Do you use HAPs as a mold-release agent? §63.1300 (b) D Yes D No
B. Flush Cleaning with Diisocyanates Comments
1 Do you use diisocyanates as an equipment cleaner to flush the D Yes D No
mixhead^ §63.1300(a)
2 Do you use diisocyanates as an equipment cleaner to flush associated G Yes D No
piping? §63.150(ji'ai
3 Do you use diisocyanates only during startup or maintenance? C Yes D No
§63.1SOOia
4 Are diisocyanates contained in a closed-loop system? §63.1300(a> D Yes D No
5 Do you reuse diisocyanates in production"7 §63.1300 fai d Yes D No
C. Recordkeeping Comments
1 Do you have product data-sheets for each compound used? 63.130 7(g) D Yes D No
2 Is HAP data available for each compound you use (expressed in kg of D Yes D No
HAP/kg solids or Ib HAP/lb solids)? §63.1307(g)
3 Do vou have product data-sheets for each mold-release agent use? D Yes D No
§63.1307 (li)
70
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Table 4.1 Checklist for Inspecting Molded foam Plants (cont'd)
C. Recordkeeping
Comments
4 Is HAP data available for each mold-release agent you use (expressed d Yes D No
in kg of HAP/kg solids or Ib HAP/lb solids)? §63.1307(h)
D. Reporting
Comments
Did you submit an initial notification? §63.1306(a)
D Yes D No Date last submitted:
2 Have you applied for approval of construction or reconstruction?
§63.1306(b)
D Yes D No Date last submitted:
3 Did you submit a notification of compliance status? §63.1306(d)(4) D Yes D No Date last submitted:
-1 Did \ou submit an annual compliance certification? §63.]306(gi
D Yes D No Date last submitted:
Additional comments:
71
-------
Chapter 5 - Complying with requirements for rebond foam
What does the Rebond section cover?
§63.1301 of the rule covers your process for rebond foam your process meets all of the following
conditions:
• is located at facility that is a major source of HAPs
• uses a HAP
• is a rebond foam production process
• is not exempt
Definition. Rebond foam means "the foam resulting
from a process of adhering small particles of foam
together to make a usable cushioning product. Various
adhesives and bonding processes are used. A typical
application for rebond foam is for carpet underlay.'
About this Chapter:
• MTienever you see "§," we are
referring to the section number
of the rule. You can go to thai
section in the rule for more
information
• HTien you see a definition, ir
comes straight from the rule
§63.1301 covers these parts of your rebond foam process:
• storage areas for raw materials
• production equipment and associated piping, ductwork, etc.
• curing and storage areas
Figure 5.1 (on page 73) shows a typical process for rebond foam.
What is exempt under this section?
Your rebond foam process, or portions of your process, are exempt if it's devoted exclusively to
either of the following: [§63.1290(c)]
• fabricating rebond foam
• conducting research and development
72
-------
Figure 5.1
A Typical Process from Rebond-Foam Production
Process Description:
Bulk foam scrap is ground into suitable small pieces. The shredded pieces are fimneled into a
storage container. The pieces are then loaded into a blend tank- where a binder is added, which
usually is a prepolymer of poly ol and diisocyanate. After addition of the catalyst and thorough
mixing, the foam/binder mixture is placed in a mold, compressed, and kept compressed during
curing with heat and steam. After die rebonded-foam is set, it is cut and packaged.
Bulk Foam
Scrap
Catalyst
Storage
Vessel
Binder
Chemical
Storage
Vessel
Process Diagram:
To Cutting
and ~
Packaging
Compressor Conveyor
73
-------
' Definition. Research and development process means "a laboratory or pilot
plant operation whose primary purpose is to conduct research and
development into new processes and products, where the operations are
under the close supervision of technically trained personnel, and which is not
engaged in the manufacture of products for commercial sale."
Definition. Foam fabrication process means "an operation for cutting or
bonding flexible polyurethane foam pieces together or to other substrates.''
What compliance options do I have?
You have two compliance options for your rebond foam process.
• Option 1: do not use HAP-based materials in any of the following ways [§63.1301(a). (b)]:
»• as an equipment cleaner
*• as a mold-release agent
Definitions.
mold-release agent means "any material (when applied to
the mold surface) which prevents sticking of the foam part
to the mold."
HAP-based means "any compound used as an equipment
cleaner or mold-release agent that contains five percent
(by weight) or more of HAP "
Option 2: you may submit an alternative means of emission limitation under §63.1305. You
can submit your request in your Precompliance Report, your Application for Approval of
Construction or Reconstruction, or at any other time, as long as it contains the information
required in §63.1305. Your request must be approved by the EPA before you use it. See
Chapter 7 for additional information.
What monitoring must I do?
None for rebond foam.
74
-------
What records must I keep?
You must keep two basic pieces of information for each rebond foam process [§63.1307(g), (h)]:
• a product data-sheet for each solvent and mold-release agent you use
• the HAP content for each solvent or mold-release agent you use (in kg of HAP/kg solids or
Ib HAP/lb solids)
What reports must I submit?
You must submit four t>pes of reports for each rebond foam plant:
• an initial notification [§§63.1306(a), 63.9(b)]
• an application for approval of construction or reconstruction [§§63.1306(b). 63.5(d)]
• a notification of compliance status [§63.1306(d)]
• an annual compliance certification [§63.1306(g)]
For additional reporting information including dates and example forms, see Chapter 7. The forms
are optional, but you may find them useful.
How do I show compliance?
You can show compliance with §63.1301 by meeting all of the following conditions [Table 5 of the
rule]:
• don't use a HAP-based material as an equipment cleaner [§63.1301 (a)]
• don't use a HAP-based mold-release agent [§63.1301(b)]
• maintain product data-sheets for each solvent you use [§63.1307(g)]
• maintain product data-sheets for each molded release agent you use [§63.1307(h)]
You will violate §63.1300 if you do any of the following [§63.1308(e)J:
• fail to meet the requirements in §63.1301.
• use a HAP-based material in the rebond foam process
• use a HAP-based mold-release agent
Is an inspection checklist available?
We've.included an inspection checklist in Table 5.1 (on page 76). You can use the checklist when
you check your foam plant for compliance with the rule.
75
-------
Table 5.1 Checklist for Inspecting Rebond foam Plants
Facility Name:
Facility Location:
Facility TRI ID #:
Person Conducting Evaluation:
Date of Evaluation:
A. HAP Usage Comments
Note: IfyicniMSAv^NOtoALLquesticmsmSectionA.don'tproceed. Yourrebond
foam process isn't covered because JXHI don't use HAPs.
1 Do you use HAPs as equipment cleaners? §63.1301(a)
1 Do you use HAPs as a mold-release agent? §63.1301(b)
D Yes D No
D Yes D No
B. Recordkeeping
Comments
1 Do you have product data-sheets available for each compound used? D Yes D No
§63.1307(gi
2 Is HAP data available for each compound use (expressed in kg of
HAP/kg solids or Ib HAP/lb solids)'7 §63.1307(g)
D Yes D No
3 Do you have product data-sheets for each mold-release agent you use9 D Yes D No
f 63.1307 fh/
A Is HAP data available for each mold-release agent you use? D Yes D No •
(expressed in kg of HAP/kg solids or Ib HAP/lb solids)0 §63.1307(lij
C. Reporting
Comments
1 Did you submit an initial notification form? §63.1306fa/
D Yes D No
D Yes D No
Date last submitted
Date last submitted
2 Have you applied for approval of construction or reconstruction?
§63.1306(bj
3 Did you submit a notification of compliance status? §63.1306(dj(4j D Yes D No
4 Did you submit an annual compliance certification? §63.1306(g) D Yes D No
Date last submitted:
Date last submitted:
Additional comments:
76
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Chapter 6 - Calculations and procedures
How do I calculate HAPused to see if I'm exempt from the rule?
If your slabstock foam production process is at a facility that uses less than five tons per year of
HAP (HAPusJ, it may be exempt from the rule [§63.1290(c)(3)]. HAP^ refers to the amount of
HAP chemicals used, not to HAP emissions.
is the total amount of HAP (excluding
diisocyanate used as a reactant) that the facility Use Equation 1 to see if your facility uses less than 5
consumes. This exemption is only allowed if tons per year of HAP
your slabstock foam production and foam-
fabrication processes are the only processes at
the plant site that emit HAP.
In other words, this includes all HAP ABA used in the production of slabstock foam, all HAP
cleaners used at the plant site, and all HAP adhesives used in foam fabrication operations at the plant
site. It does not include diisocyanates used as a reactant to make the slabstock foam. It includes
HAP used in all parts of the plant, including the ones that aren't producing slabstock foam Equation
1 of the rule. §63.1290(c)(3), contains the HAP^ calculation. Following are two examples of
facilities that are trying to take advantage of this exemption.
Example 1
Assumptions:
The plant site includes two lines, for slabstock foam production and foam-fabrication
operations.
Both slabstock production lines are equipped with liquid carbon dioxide ABA systems, but
one line still uses 625 gallons per year of methylene chloride for specialty applications
• 100 gallons of methylene chloride are used each year to clean the slabstock mixhead
• The foam fabrication operation uses 1,300 gallons of adhesive XYZ with the following
properties:
Density of adhesive - 9.8 Ib/gal
Methylene chloride content of adhesive - 60 weight percent
77
-------
Equation 1 from the Rule:
•H>
11+ 2000
where.
HAPmed = amount of HAP ? excluding toluene diisocyanate reactants. used at the plant
site for slabstock foam production and foam fabrication, tons per year
, = volume of methylene chloride used as an ABA i at the facility - 625 gal
per year
- density of methylene chloride ABA - 10.4 pounds per gal
m = number of HAP ABAs used - 1
VOLclear, = volume of methylene chloride used as an equipment cleaner - 100 gal
per year
Dtieai._, = density of methylene chloride equipment cleaner. 10.4 pounds per gal
\VTRAFc,ea, k = HAP content of methylene chloride equipment cleaner - 100 weight percent
n = number of HAP equipment cleaners used - 1
VOLai,k = volume of adhesive XYZ used - L300 gal per year
DadhA = density of adhesive XYZ - 9.8 pounds per gal (from MSDS)
ai- •, = methylene chloride content of adhesive XYZ - 60 weight percent (from
MSDS)
= number of adhesives used - 1
HAP = (^5)(10.4) + (100)(10.4)(1..Q) + (1,300)(9.8)(0.60) =
used 2.000
Therefore, for Example 1. mis plant's production lines for slabstock foam would not be exempt from
the rule under §63.1290(b)(5). since the total HAP used is greater than 5 tons per year.
78
-------
Example 2
Assumptions:
The plant site includes a production line for slabstock foam and foam-fabrication operations.
The slabstock production line uses acetone as an ABA.
No HAPs are used as equipment cleaners.
The foam-fabrication operation uses 1,200 gallons of the water-based adhesive DEK plus
2.500 gallons of adhesive ABC with the following properties:
Density of adhesive - 10.1 Ib/gal
Methylene chloride content of adhesive - 70 weight percent
= [£ (TOI^X/W +£ (VOLclean)(DcleanJ(WTHApclean,)
2000
where:
amount of HAP. excluding TD1 reactants. used at the plantsite for slabstock
foam production and foam fabrication, tons per year
= volume of HAP ABA used at the facility - N/A
D^ = density of HAP ABA - N/A
m = number of HAP ABAs used - 0
V9L.;ear, = volume of HAP used as equipment cleaner -NA
D,,,.^ = density of HAP equipment cleaner. N/A
H\P content of equipment cleaner - N/A
= number of HAP equipment cleaners used - 0
= volume of adhesive ABC used - 2.500 gal /yr
density of adhesive ABC -10.1 pounds per gal (from MSDS)
= methylene chloride content of adhesive ABC - 70 weight percent (from
MSDS)
VOLadi.DEF = volume of adhesive DEF used-1,200 gal AT
density of adhesive DEF - N/A
= HAP content adhesive ABC - 0 weight percent
= number of adhesives used - 2
79
-------
HAP - (0)(0) + (0)(0)(0) + [(1,000)(10.2)(0.70) + (1,000)(0)(0)] _
used 2,000 ' y
Therefore, for Example 2, the slabstock foam process would be exempt from the regulation
according to §63.1290(c)(3) since the total HAP used is less than 5 tons per year.
How do I calculate the HAP ABA formulation limit for a grade of
foam?
The HAP ABA formulation limit is used to calculate the allowable HAP ABA emissions (if your
using the emission point specific compliance
option) and the allowable sourcewide HAP
emissions (if using the sourcewide compliance l!se Efatio" 3 to cal(ulate the
x formulation limit
option). _
Equation 3 of the rule [§63.1297(d)(l)] contains the HAP formulation limit. To determine the limit
for a foam grade, you need the Indentation Force Density (IFD) in pounds and the density in pounds
per cubic foot (pcf). Following are two examples of determining this limit.
Example 3
Assumption:
• You want to make a foam with a density of 1 .2 pounds per cubic foot (pcf) and an IFD of 28
pounds.
Equation 3 from the rule:
- 16.2(DEN) -
7.56(— — ) + 36.5
DEN
where:
ABAj^mjt = HAP ABA formulation limitation, parts HAP ABA allowed per hundred
parts polyol (pph).
IFD = Indentation force deflection of the foam grade you want to produce -
28 pounds.
80
-------
DEN = Density of the foam grade you want to produce -1.2 pounds per cubic foot
(pcf).
Note: The IFD and density used in the determining the HAP ABA formulation limit are the values
measured using ASTM D3574 (in accordance with §63.1304(b)) after the production of the foam
grade, and not the planned IFD and density'.
* -0-25(28) -19.1(^1) -16.2(1.2)-
28
7.56(_L) + 36.5 = 3 pph
1.2
Therefore, the limit for foam with a density of 1.2 pcf and an IFD of 28 pounds is 3 parts HAP ABA
per 100 parts polyol.
Example 4
Assumption:
• You want to make a foam with a density1 of 2.1 pcf and an IFD of 30 pounds.
Using Equation 3 from the rule (see above), where:
ABAjjmjt = HAP ABA formulation limitation, parts HAP AJ3A allowed per hundred
parts polyol (pph).
IFD = Indentation force deflection of the foam grade you want to produce -
30 pounds.
DEN = Density of the foam grade you want to produce -2.1 pounds per cubic foot
(pcf). '
The HAP ABA formulation limitation would be calculated as follows.
= -0.25(30) ~19.1(-)- 16.2(2.1) -
7.56(—)+36.5 = -9 pph
Paragraph §63.1297(d)(l) states that the HAP ABA formulation limit is zero for any grade of foam
if the result of the equation is negative. Therefore, the limit for foam with a density of 2.1 pcf and an
IFD of 30 pounds is 0 parts HAP ABA per 100 parts polyol.
81
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How do I calculate allowable HAP ABA emissions to comply using
the emission point specific limit?
The allowable level of HAP ABA emissions depends on the mix of foam grades you produce during
the compliance period. Use Equation 2 of
the rule [§63.1297(b)(2)] to calculate it.
Except in cases where a recovery device is Use Equation 2 to calculate allowable HAP ABA
used, the allowable level of HAP ABA emissions
emissions is equal to the maximum amount
of HAP ABA you can use because 100
percent of the ABA used volatilizes and is emitted. Calculate allowable HAP ABA emissions for
each individual month using the following equation:
Equation 2 from the rule:
m
e™issallow,month = £
7=1
n (limiti)(pofyolj)
£ 100
7
where:
emissa;:cw-mon,:. = Allowable HAP ABA emissions from the slabstock affected source for
the month, pounds
m = Number of production lines foi slabstock foam at the affected source
n = Number of foam grades produced in the month on foam-production line
J
limit = HAP ABA formulation limit for foam grade i. parts HAP ABA per 100
parts polyol
polyol = Amount of polyol used in the month in producing foam grade i on foam-
production line j. pounds
To determine the allowable emissions of HAP ABA. use these three basic steps.
Step 1: Determine the HAP ABA formulation limitation for each grade
Step 2: For each month, determine the amount of polyol used to produce each grade
Step 3: Calculate the allowable RAP ABA emissions for each month
The rule allows two options: monthly and rolling-annual compliance. Under the monthly
compliance, compare actual HAP emissions to the allowable HAP emissions for each month. Under
rolling-annual compliance, compare the allowable HAP ABA emissions for 12 consecutive months to
the actual HAP ABA emissions for the same period. The allowable HAP ABA emissions for 12
82
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consecutive months are the sum of allowable monthly HAP ABA emissions for each of the 12
months in the period. Therefore, if you're using rolling-annual compliance, follow the three steps
above and then:
Step 4: Sum the allowable HAP ABA emissions for each month in the 12-month period.
Example 5 below shows the calculation of allowable HAP ABA emissions using these four steps.
Example 5:
Assumption:
• For June 2002. a slabstock foam facility manufactures the mix of foam grades sho\vn in
Table 6.1 (on page 86), using the amount of polyol for each grade shown in Table 6.3 (page
88).
Step 1 for Example 5
The first step in calculating allowable HAP ABA emissions is to determine the HAP ABA
formulation limit for each grade. Examples 3 and 4 showed how the HAP ABA formulation limit is
calculated.
Additional examples of how to calculate the HAP ABA formulation limit are below They show the
calculation of HAP ABA formulation limit for foam grade 0930 (density of 0.9 pcf and IFD of 30
Ibs) and foam grade 1540 (density of 1.5 pcf and IFD of 40 Ibs). These two foam grades are shown
in Table 6.1. Using Equation 3 from the rule (see Example 3). the HAP ABA formulation limit for
the 0930 foam grade is calculated as follows:
ABAijmjf= -0.25(30) - 19.1(^-) - 16.2(0.9)-
7.56(—)-36.5 - 5 pph
Therefore, the HAP ABA formulation for foam grade 0930 is 5 pph.
For foam grade 1540? the calculation is as follows:
ABAjimit = -0.25(40) - 19. U^) - 16.2(1.5) -
7.56(—) + 36.5 = -3 pph
83
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As previously explained, the HAP ABA formulation limit is zero for any grade of foam where the
result of the equation is negative. Therefore, the HAP ABA formulation for foam grade 1540 is 0
pph. Table 6.2 (on page 87) provides the HAP ABA formulation limitations for all of the foam
grades produced by this example facility.
Step 2 for Example 5
The second step in determining the HAP ABA formulation limit is to obtain the amount of polyol
used for each grade of foam during the compliance period. In this case, the amount of polyol used by
foam grade is shown in Table 6.3
Step 3 for Example 5
The third step is to calculate the allowable HAP ABA emissions for the month. Do this by using
Equation 2 found in §63.1297(b)(2) of the rule.
Equation 2 from rule::
m
emissallow,month =
7=1
n (Iimitj)(pofyolj)
7=1
100
J
Where:
emissallo\v.month
m
polyol
n
limit
Allowable HAP ABA emissions from the slabstock foam
production source for the month, pounds.
Number of slabstock foam production lines.
Amount of polyol used in the month in the production of foam grade
i on foam-production line j. pounds.
Number of foam grades produced in the month on foam production
line j.
HAP ABA formulation limit for foam grade i. parts HAP ABA per
100 parts polyol.
Calculate the total allowable HAP ABA emissions from the slabstock foam source for a month, by
added together the allowable HAP ABA emissions for each foam grade. Following are examples of
allowable HAP ABA emissions for foam grades 0930 and 1540.
For foam grade 0930. where:
ermssallow.month.0930 =
Allowable HAP ABA emissions from the slabslock foam
production source for the month for foam grade 0930, pounds.
84
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m
Number of slabstock foam production lines that produce grade
0930 - 1
Amount of polyol used in the month in the production of foam
grade 0930 - 13,300 pounds.
HAP ABA formulation limit for foam grade 0930 - 5 parts
HAP ABA per 100 parts polyol
( 5 pounds HAP ABA allowed} ,,_ ,nA " , ,. ,,. ,
l09,0= — (13,300/70««fifr polyo!)= 665 pounds
\ IQQpounds polyol )
For foam grade 1540. where:
emissauow mont}j
m
p0]vol
Allowable HAP ABA emissions from the slabstock foam
production source for the month for foam grade 1540, pounds
Number of slabstock foam production lines that produce grade
1540- 1
Amount of polyol used in the month in the production of foam
grade 1540 - 20,000 pounds.
HAP ABA formulation limit for foam grade 1540 - 0 pans
HAP ABA per 1 00 parts polyol
unds polyol
0
Table 6-3 provides the amount of polyol used and the allowable HAP ABA emissions for the month.
for each grade of foam in Example 5. Table 6-3 shows the total allowable HAP ABA emissions for
the example facility during June 2002 would be 4.320 pounds.
Step 4 for Example 5
You have two options on the compliance period you \\ill use for HAP ABA emission limits - annual
(i.e., rolling 12 month) or monthly. How you complete Step 4 will depend on which compliance
option you choose.
85
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Step 4 Using Annual Compliance Option for Example 5
Annual compliance is a rolling 12-month period. If you choose the annual option, the allowable
HAP ABA emissions for the 12-month period would be the allowable HAP ABA emissions for the
month (determined as discussed in Step 3 above), plus the allowable HAP ABA emissions for the
previous 11 months. Here is an example.
Assumption:
• The allowable HAP ABA emissions for June 2002 was 4,320 pounds (as calculated in Step
3 above)
• The allowable HAP ABA emissions (in pounds) for the previous 11 months are:
May 2002 - 4.112; April 2002 - 3,789; March 2002 - 2,125; February 2002 - 5,552;
January 2002 - 4,001; December 2001 - 3,222; November 2001 - 2,247; October 2001 -
1.785;'September 2001 - 3,555; August 2001 - 4,885; and July 2001 - 2J53.
Therefore, the total allowable HAP ABA emissions for the previous 11 months (e.g. July 2001
through May 2002) is 38.026 pounds. This value is added to the June 2002 monthly allowable
emissions of 4.320 pounds. This gives you a total allowable HAP ABA emissions of 42.346 pounds
for the 12-month compliance period.
Step 4 Using Monthly Compliance Option for Example 5
If you choose the monthly option, then the allowable HAP ABA emissions for the compliance period
(i.e.. the month) would be determined as discussed above, which is 4,320 pounds.
If I'm complying using the emission point specific limit without
using a recovery device, how do I calculate actual monthly HAP
ABA emissions?
If you aren't using a recovery device to reduce HAP ABA emissions, your actual HAP ABA
emissions are equal to the amount of
HAP ABA vou add at the mixhead. r _ , . . . „, _
_ . : . . If vou re not using a recover device, the actual HAP
Determine the latter amount by ABA emisswns are equal to the amounl ofHAPABA
monitoring the HAP ABA pump added at the mixhead
revolutions or flow rate. Following is an
example of how to calculate actual HAP
ABA emissions for the facility in Example 5.
86
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Example 6
Assumption:
• The example facility discussed in Example 5 added 4,420 pounds of methylene chloride at
the mixhead during June 2002 (i.e., the same month for which the allowable HAP ABA
emissions were determined in Example 5).
Therefore, the actual HAP ABA emissions for June 2002 are 4,420 pounds. To determine if you are
in compliance for the compliance period, compare the actual HAP ABA emissions to the allowable
HAP ABA emissions. Following are examples of this comparison for the two compliance options.
Example 6 Using Annual Compliance Option
Annual compliance is a rolling 12-month period. If you choose the annual option, then the actual
HAP ABA emissions for the compliance period (i.e., the 12-month period) vrould be the actual HAP
ABA emissions for the month (4,420 pounds for our example 5 facility) plus the actual HAF ABA
emissions for the 11 previous months. For example.
Assumption:
• The actual HAP ABA emissions (in pounds) for the previous 11 months are:
May 2002 - 3.514; April 2002 - 4,002; March 2002 - 2,052; February 2002 - 5.100;
January 2002 - 3,750; December 2001 - 3,810; November 2001 - 2,440; October 2001 -
1.750;"September 2001 - 3,226; August 2001 - 4,500; and July 2001 - 2,666.
Therefore, the total actual HAP ABA emissions for the previous 11 months (e.g. July 2001 through
May 2002) is 37.278 pounds. This value is added to the total actual HAP ABA emissions of 4.420
pounds for June 2002 to obtain the total actual HAP ABA emissions for the 12-month compliance
period (41.698 pounds).
To determine compliance, you will now compare the-total actual HAP ABA emissions for the 12-
month period (41.698 pounds) to the total allowable HAP ABA emissions for the same period
(42.346 pounds) Since the actual emissions are less than the allowable emissions for the 12
month period, you are in compliance. This is true even though for five month out of the 12 months
(November 2001, December 2001, March 2002, April 2002, and June 2002), your actual HAP ABA
emissions exceeded the allowable HAP ABA emissions. This demonstrates the flexibility of the 12-
month compliance period.
87
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Example 6 Using Monthly Compliance Option
If you choose the monthly option, compare the total actual HAP ABA emissions for the month
(4,420 pounds), to the allowable HAP ABA emissions for the month (4,320 pounds). Since the
actual emissions are greater than the allowable emissions for the month, you are out of
compliance. You would also have been out of compliance for November 2001, December 2001,
March 2002, and April 2002.
If I'm complying with the emission point specific limit using a
recovery device, how do I calculate actual emissions?
If you're using a recovery device to reduce HAP ABA emissions, the actual HAP ABA emissions are
equal to the amount of HAP ABA you add at
the mixhead minus the amount of HAP ABA ., , . . . .
Ifvou use a recovery device, vour actual emissions
recovered, bse Equate 4 of the rule Qre £qua, to the amount offuPABA added at the
[§63.1297(e)( 1)] to calculate actual HAP mixhead minus the amount of HAP ABA recovered.
ABA emissions when a recovery device is i~se Equation 4 of the rule to calculate actual
used. 'emissions.
When a recovery device is used, the
parameters needed to determine the actual HAP ABA emissions are the amount of HAP ABA added
at the mixhead and the amount of HAP ABA recovered. Following is an example of actual emissions
when using a recovery device for the facility used in Example 5.
Example 7
Assumption:
« Assume that the example facility discussed in Example 5 added 26.000 pounds (2500
gallons at 10.4 Ibs/gal) of methylene chloride at the mixhead and recovered 21.840
pounds (2100 gallons at 10.4 Ibs/gal) of methylene chloride in June 2002.
The actual HAP ABA emissions for June 2002 would be calculated as follows.
Equation 4 from the rule:
Eactual ~ Eunc ~ HAPABArecovere(j
88
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where:
^actual = Actual HAP ABA emissions after control, pounds/month.
EUDC = Uncontrolled HAP ABA emissions - 26,000 pounds
HAPABArecovere(j = HAP ABA recovered - 21,840 pounds
Therefore, the actual HAP emissions for June 2002 would be 4,160 pounds.
To determine whether you are in compliance for the compliance period, compare the actual HAP
ABA emissions to the allowable HAP ABA emissions. Following are examples of this comparison
for the two compliance options.
Example 7 Using Annual Compliance Option
Annual compliance period is a rolling 12-month period. Therefore, if you choose the annual option.
the actual HAP ABA emissions for the compliance period (i.e., the 12-month period) would be the
actual HAP ABA emissions for the month (4.160 pounds) plus the actual HAP ABA emissions for
the 11 previous months. Following is an example.
Assumption:
• The actual HAP ABA emissions (in pounds) for the previous 11 months are:
May 2002 - 3,514; April 2002 - 4,002; March 2002 - 2.052: February 2002 - 5,100:
January 2002 - 3.750: December 2001 - 3.810; November 2001 - 2.440; October 2001 -
1.750: September 2001 - 3,226; August 2001 - 4,500: and July 2001 - 2,666.
Therefore, the total actual HAP ABA emissions for the previous 11 months (e.g. July 2001 through
May 2002) is 37.278 pounds. This value is added to the total actual HAP ABA emissions of 4.160
pounds for June 2002 to obtain the total allowable HAP ABA emission's for the 12-month
compliance period (41.438 pounds).
To determine compliance, compare the total actual HAP ABA emissions for the 12-month period
(41,438 pounds), to the total allowable HAP ABA emissions for the same period (42,346 pounds)..
Since the actual emissions are less than the allowable emissions for the 12 month period, you
are in compliance. This is true even though for four month out of the 12 months (November 2001.
December 2001, March 2002, and April 2002) your actual HAP ABA emissions exceeded the
allowable HAP ABA emissions. This demonstrates the flexibility of the 12-month compliance
period.
89
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Example 7 Using Monthly Compliance Option
If you choose the monthly option, then compliance is determined by comparing the total actual HAP
ABA emissions for the month (4,160 pounds), to the allowable HAP ABA emissions for the month
(4,320 pounds). Since the actual emissions are less than the allowable emissions for the month,
you are in compliance. However, you would have been out of compliance for November 2001,
December 2001, March 2002, and April 2002.
If I'm complying with the sourcewide emission limit, how do I
calculate allowable emissions?
If you're complying with the sourcewide emission limit, the allowable sourcewide HAP emission
level depends on the mix of foam grades produced during the compliance period. Equation 6 of the
rule [§63.1299(d)] contains the allowable sourcewide HAP emission limit calculation. The allowable
sourcewide HAP emission limit is determined in exactly the same manner as the allowable HAP
ABA emission limit would be if complying using the emission point specific limitations That is.
Equation 6 (which calculates the sourcewide HAP limit) and Equation 2 (which calculates the HAP
ABA emission limit) are identical.
Example 8
Assumptions' ^"se ^uat'on ^to calculate allowable
sourcewide limits
• A facility produces the same foam grades as
those shown in Table 6.1.
• In June 2002. the facility used the amount of polyol for each foam grade shown in Table 63
Therefore, the allowable sourcewide HAP emissions for the facility for June 2002 are 4.320 pounds.
This level would be calculated exactly as shown in Example 5.
There are two choices regarding the compliance period for the sourcewide HAP emission limitation -
annual (i.e.. rolling 12 month) or monthly.
Example 8 Using Annual Compliance Option
The annual compliance period is a rolling 12-month period. Therefore, if you choose the annual
option, then the allowable sourcewide HAP emissions for the compliance period (i.e.. the 12-month
period) would consist of the allowable sourcewide HAP emissions for the month plus the allowable
sourcewide HAP emissions for the 11 previous months. For example.
90
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• The allowable sourcewide HAP emissions (in pounds) for the previous 11 months are: May
2002 - 4,112; April 2002 - 3,789; March 2002 - 2,125; February 2002 - 5,552; January
2002 - 4,001; December 2001 - 3,222; November 2001 - 2,247; October 2001 -1,785;
September 2001 - 3,555; August 2001 - 4,885; and July 2001 - 2,753.
The total allowable sourcewide HAP emissions for the previous 11 months (e.g. July 2001 through
May 2002) is 38,026 pounds. This value is added to the total allowable sourcewide HAP emissions
of 4,320 pounds for June 2002 to obtain the total allowable sourcewide HAP emissions for the 12-
month compliance period. (42,346 pounds).
Example 3 Using Monthly Compliance Option
If you choose the monthly option, then the allowable sourcewide HAP emissions for the compliance
period (i.e., the month) would be 4.320 pounds.
If I'm complying with the sourcewide emission limit without using
a recovery device, how do I calculate actual sourcewide HAP
emissions?
If you're comphing with the sourcewide emission limit, your actual sourcewide HAP emissions are
determined by doing a material balance on the HAP ABA storage vessels. The inputs needed to
determine the sourcewide emissions are the
amounts of HAP ABA in all the storage rf . , . c . -
^s If YOU re not using a recovers device, use Equation .>
vessels at the beginning of the month and at to calcu,ate acwa, emissions
the end of the month You will also need the
amount of HAP AEA added to each storage
vessel during the month.
Equation 5 of the rule [§63.1299(c)(l)] is used to calculate actual sourcewide HAP ABA and
equipment emissions.
Example 9
Assumptions:
• The facility discussed in Example 8 has two storage vessels for methylene chloride, each
able to hold 10.000 gallons. Following are the data you need to calculate the actual.
monthly, sourcewide emissions of HAP.
91
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Amount of MeCl in tank at beginning of month (Ibs)
Amount of MeCl in tank at end of month (Ibs)
Amount of MeCl added to tank (Ibs)
Tankl
1,046
47,300
50,000
Tank 2
80,064
78,400
0
Equation 5 from the rule:
PWEactual = £ (STi,begin ~ STi,end
n
where:
^ ^actual
n
ST].begin
ST:. end
ADD,
Actual sourcewide HAP ABA and equipment cleaning HAP emissions
for a month, in pounds/month.
Number of HAP ABA storage vessels - 2.
Amount of HAP ABA in storage vessel 1 at the beginning of the month.
1,046 pounds.
Amount of HAP ABA in storage vessel 1 at the end of the month.
47,300 pounds.
Amount of HAP ABA added to storage vessel 1 during the month.
pounds - 50.000 pounds.
Therefore, the actual sourcewide HAP emissions for June 2002 are 5.140 pounds.
If I'm complying with the sourcewide emission limit using a
recovery device, how do I calculate actual emissions?
If you're complying with the sourcewide emission limitations using a recovery device, your actual
sourcewide HAP emissions are calculated
by performing a material balance on the
HAP ABA storage vessels and
subtracting the amount of HAP ABA
recovered. To do the calculation, you'll ~~~
need to know the amount of HAP ABA in
all the storage vessels at the beginning of the month and at the end of the month, the amount of HAP
ABA added to each storage vessel during the month, and the amount of HAP ABA recovered during
the month.
If you 're using a recovery device, use Equation 7 to
calculate actual sourcewide HAP emissions
92
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Equation 7 of the rule [§63.1299(e)] is used to calculate actual sourcewide HAP emissions when a
recovery device is used.
Example 10:
Assumptions:
• For the facility discussed in Example 8, assume the following storage vessel data for June
2002.
Amount of MeCl in tank at beginning of month
Obs)
Amount of MeCl in tank at end of month (Ibs)
Amount of MeCl added to tank (Ibs)
Tankl
2,346
26,832
40,000
Tank 2
40,000
77,000
50,000
Lets assume that our example facility recovered 24,250 pounds of methylene chloride in June 2002
Equation 7 from rule
recovered
where:
-actual
= Actual sourcewide HAP emissions after control, pounds/month.
n
E (STi,begin ~ STi,end + ADDi
= Uncontrolled sourcewide HAP emissions =
HAPABArecovered = HAP ABA recovered, 24,250 pounds/month.
Therefore, the actual sourcewide HAP emissions for June 2002 are 4,264 pounds.
To determine whether you are in compliance for the compliance period, compare the actual
93
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sourcewide HAP emissions to the allowable sourcewide HAP emissions. Following are examples of
this comparison for the two compliance options.
Example 10 Using Annual Compliance Option
•
Annual compliance period is a rolling 12-month period. Therefore, if you choose the annual option.
the actual sourcewide HAP emissions for the compliance period (i.e., the 12-month period) would be
the actual sourcewide HAP emissions for the month (4,264 pounds) plus the allowable HAP ABA
emissions for the 11 previous months. For example.
Assumptions:
• The actual sourcewide HAP ABA emissions (in pounds) for the previous 11 months are:
May 2002 - 3,514; April 2002 - 4,002; March 2002 - 2,052; February 2002 - 5,100;
January 2002 - 3,750; December 2001 - 3.810; November 2001 - 2.440; October 2001 -
1.750; September 2001 - 3,226; August 2001 - 4,500; and July 2001 - 2,666.
The total actual sourcewide HAP ABA emissions for the previous 11 months (e.g. July 2001
through May 2002) is 37,278 pounds. This value is added to the total actual HAP ABA emissions of
4.264 pounds for June 2002 to obtain the total actual HAP ABA emissions for the 12-month
compliance period (41.542 pounds).
To determine compliance, the total actual sourcewide HAP emissions for the 12-month period
(41.542 pounds), are compared to the total allowable sourcL wide HAP emissions for the same period
(42.346 pounds). Since the actual emissions are less than the allowable emissions for the 12
month period, you are in compliance This is true even though for four of the 12 months
(November 2001. December 2001. March 2002. and April 2002) the actual sourcewide HAP
emissions exceeded the allowable HAP ABA emissions for the month. This demonstrates the
flexibility of the 12-month compliance period.
Example 10 Using Monthly Compliance Option
If you choose the monthly option, then compliance is determined by comparing the total actual
sourcewide HAP emissions for the month (4,264 pounds) to the allowable HAP ABA emissions for
the month (4,320 pounds). Since the actual emissions are less than the allowable emissions for
the month, you are in compliance.
94
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How can I check my slabstock process for leaks?
The EPA Publication, APT! Course SI:417, Controlling VOC Emissions from Leaking Process
Equipment (EPA 450/2-82-015), gives helpful information on how to sample equipment and where
leaks may be. You can get information on how to get a copy of this self-instructional course by
going to http:/,/wH>w.epa.gov/oar/oaqps/eog/.
95
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Table 6.1 Foam Grades Produced By The Example Facility
This table shows the density and IFD for example foam grades, some of which are used in
Chapter 6 examples for calculating HAP emissions.
Grade
930
1010
1015
1020
1030
1120
1130
1230
1330
1340
1440
1520
1530
1540
1640
1740
1820
1830
1840
1 930
1940
>2020
Density
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
2.5
IFD
flbs)
30
10
15
20
30
20
30
30
30
40
40
20
•30
40
40
40
20
30
40
30
40
25
96
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
-------
Table 6.2 HAP ABA Formulation Limitations For Foam Grades
Produced By The Example Facility
This table shows the HAP ABA formulation limitations that have been calculated for various
grades of foam.
Grade
930
1010
1015
1020
1030
1120
1130
1230
1330
1340
1440
1520
1530
1540
1640
1740
1820
1830
1840
1930
1940
>2020
Density
(pcf)
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
>2.5
HAP ABA
jjr0 Formulation
(Ibs) Limitation
(pph)
30
10
15
20
30
20
30
30
30
40
40
20
30
40
40
40
20
30
40
30
40
>25
5
8
8
7
5
. 6
4
3
1
0
0
1
0
0
0
0
0
0
0
0
0
0
97
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TABLE 6.3 Allowable HAP ABA Emissions For Foam Grades
Produced By The Example Facility
This table shows the allowable HAP ABA emissions, calculated for various grades of foam.
Grade
930
1010
1015
1020
1030
1120
1130
1230
1330
1340
1440
1520
1530
1540
1640
1740
1820
1 830
1840
1930
1940
>2020
Density
(pcO
0.9
1.0
1.0
1.0
1.0
1.1
1.1
1.2
1.3
!•?
1.4
1.5
1.5
1.5
1.6
1.7
1.8
1.8
1.8
1.9
1.9
>2.5
DT>
Obs)
30
10
15
20
30
20
30
30
30
40
40
20
30
40
40
40
20
30
40
30
40
>25
HAP ABA
Formulation
Limitation
(DDh)
5
8
8
7
5
6
4
3
1
0
0
1
0
0
0
0
0
0
0
0
0
0
Totals
Amount of
polyol used in
the month
(pounds)
13,300
6,600
6,700
6,500
13,500
6,600
10,000
16,500
10,000
9,500
10,750
7,000
7,560
20,000
19.500
21,000
9rOOO
8,500
22,000
10,000
16,500
85,000
335,950
Allowable
HAP ABA
Emissions
(pounds)
665
528
536
455
675
396
400
495
100
0
0
70
0
0
(I
0
0
(1
0
0
0
0
4,320
98
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Chapter 7 - Notification, reporting and alternate monitoring plans
What do I have to report and when?
You will need to complete several different types of notifications and reports based on the type of
process at your plant. The term, reports, is used in this section to include both notifications and
reports. Table 7.1 (on page 102) shows what reports you must submit and when they are due.
Table 7.2 (page 104) gives you details about what should be included in these reports.
How can I change the date my reports are due?
Under the General Provisions, §63.10(a)(5), you may request a change in the date you submit your
reports. You and your EPA Regional Office or State, local or Tribal agency for air pollution control
(from now on referred to as "State") must mutually agree to the change and the change can't affect
the frequency that you report. For example, semiannual reports for an existing Slabstock foam
facility are required in June and December of 2004. You may request that these dates be changed to
some other time frame, such as one that coincides with your title V operating permit notifications.
This doesn't change your reporting frequency since you're still submitting your semiannual reports
twice per year.
Changes to reporting dates can begin 1 year after the compliance date (that is, reports required after
10/8/02 can be changed) Reports due before 10/8/02 can't be changed and must be reported by the
date shown in Table 7.1. Contact vour State for more information
Where do I send my reports?
The General Provisions §63.9(a) and §63.10(a) require you to submit reports to your State or your
EPA Regional Office or both (dual reporting). Whom you send your reports to depends on whether
your State has been granted the authority to implement the Flexible Polyurethane Foam Production
NESHAP. .
You'll need to submit reports in one of the following ways:
• to your EPA Regional Office if your State has not been delegated the authority to implement
and enforce the Flexible Polyurethane Foam Production NESHAP
99
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• to your State with a copy to your EPA Regional Office, if your State has been granted
delegation and we haven't waived the dual reporting requirement
• to your State if it's been granted delegation and we've waived the dual reporting requirement
Not all State agencies have been granted delegation. Also, as of this publication, our Region I, III,
Vin and X offices haven't waived the dual reporting requirement under §63.9 and §63.10. This
means if your plant is in Region I (CT, ME, MA, NH, RI, VT), Region ID (DE, MD, PA, VA, WV,
District of Columbia), Region VIII (CO, MT, ND, SD, UT, WY), or Region X (AK, ID, WA OR),
you'll need to submit your reports to your State, local or Tribal agency and the EPA Regional
Office. You'll find a list of our Regional Offices and their addresses in Chapter 9.
You should check with your EPA Regional Office or State for the latest information on submitting
reports.
Where do I submit my Alternative Programs?
There are two types of alternative programs under the rule.
The first is the alternative means of emission limitation under §63.1305. You would use this
compliance method in cases where you believe you have a better approach than what is required in
the rule for controlling and monitoring HAP emissions at your plant. If you use this approach, you
will develop your own overall compliance strategy and submit it for approval. Since we haven't
delegated the approval of this alternative to your State agency, you'll send your alternative means of
emission limitation program, to your EPA Regional Office for review and approval. You can do this
by using your Precompliance Report, your Application for Approval of Construction or
Reconstruction, or at any other time as long as the request includes all the information required under
§63.1305(b). Your request must be approved as described in §63.6(g) before you can use the
alternate emission limit.
The second type of alternative program is the alternative monitoring program. You can choose to
develop an alterna?;\ e monitoring program for HAP Auxiliary Blowing Agent (ABA) and polvol
added to the foam production line at the mixhead fS63.1303(b)(5V|. and HAP ABA added to storage
vessels f §63 1303(e)(4)]. This means that you would be developing your own compliance strategy
for monitoring these two sections of the rule and submit it for approval. You can send in your
alternative monitoring program by using your Precompliance Report, your Application for Approval
of Construction or Reconstruction, or at any other time as long as the request includes all the
information under §63.1303(b)(5) and §63.1303(e)(4).
We haven't granted delegation of the alternative monitoring program under §63.1303(b)(5) to your
State agency. This means that you'll submit your request to determine the HAP ABA and polvol
added to the line at the mixhead to your EPA Regional Office for review and approval.
100
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However, your request for determining HAP ABA added to storage vessels under §63.1303(e)(4)
should be submitted as you would any other reports. Your request must be approved before you can
use the alternative program. If your regulatory agency doesn't notify you of any objections to your
alternative program within 45 days after they receive it, your program will be deemed approved.
If you're using a recovery device to reduce HAP ABA emissions, you're also required under
§63.1303(c)(6) to develop and submit a recovery HAP ABA monitoring and recordkeeping
program. This means that you'll send in a program (plan) that describes what type of recover,
device you've installed and how you'll monitor whether the device is operating properly. You can
send in your plan by using your Precompliance Report, your Application for Approval of
Construction or Reconstruction, or at any other time as long as it includes all the information under
§63.1306(c)(6). You should send in your plan as you would any other report. Your plan must be
approved before you can use it. If your regulatory agency doesn't notify you of any objections
within 45 days after they receive it, your plan will be deemed approved.
Can I get example reporting forms?
We've included example forms for all reports this rule requires. You'll find the following example
reports in this chapter:
• Initial Notification Report 108
• Application for Approval of Construction or Reconstruction 110
• Precompliance Report 115
• Notification of Compliance 121
• Semi-annual Compliance Report 124
• Change in Selected Emission Limit and Compliance Method 128
• Annual Compliance Certification 129
You may use these forms for reporting, but you don't have to use them. You may want to check
with your State agency to make sure they don't have their own forms, or. if you do use these forms.
check to see if they meet your State requirements first.
101
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Table 7.1 - Report Due Dates
If you have—
And need to submit a ...
Then submit the report
before...
An existing Slabstock. Initial Notification Report (§63.1306(a)] 2/4/99
Molded or Rebond plant (120 days after the effective
date)
Application for Approval of Construction or As soon as practicable before
Reconstruction, if reconstructing after 10/7/98 reconstruction is planned to start
(effective date) (§63.5(d)] but no sooner than 10/7/98
(effective date)
Application for Approval of Construction or
Reconstruction, if reconstruction started before As soon as practicable before
10/7/98 (effective date), but, your initial startup reconstruction is planned to start
was after 10/7/98 (effective date) (§63.5(d)] but no later than 12/6/98
(60 days after the effective dale}
Notification of Compliance (§63.1306(d)] 4/6/02
(180 days after the compliance
date)
Annual Compliance Certification [§63.1306(g)] Annually - can submit with
semi-annual report
An existing Slabstock Precompliance Report [§63.1306(cj] 10/8/00
plant (12 months before compliance
date)
(These requirements an- in Initial Semi-annual Compliance Report 12/2/02 (include information
addition to the above; (§63.1306(e)] from 4/6/02 - 10/3/02)
Compliance period is for 180 days (240 days (240 days after Notification of
minus 60 days allowed to submit report/ Compliance)
Subsequent Semi-annual Compliance Reports 6/2/03 (include information from
(§63.1306(e)] 10/4/02-4/3/03):
180 day (6 month) period starts after the 12/2/03 (include information
initial semiannual compliance report. from 4/4/03 - 10/3/03):
6/2/04 (include information from
10/4/03 - 4/3/04);
12/2/04 (include information
from 4/4/04-10/3/04): etc.
(60 days after each 180 day-
period)
102
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Table 7.1 - Report Due Dates (cont'd)
If you have...
And need to submit a...
Then submit the report
before...
Change in Selected Emission Limit and
Compliance Method (§63.1306(fXl),(2)]
180 days before the change
takes effect
(720 days after the effective
date)
A ne\v Slabstock.
Molded
or Rebond plant
Initial Notification Report (§63.1306(a)]
2/4/99 or 120 days after initial
startup or use your construction
permit
Application for Approval of Construction or
Reconstruction, if constructing after 10/7/98
(effective date) |§63.5(d)]
Application for Approval of Construction or
Reconstruction, if reconstruction started before
10/7/98 (effective date), but. your initial startup
was after 10/7/98 (effective dale/ (§63.5(d)]
As soon as practicable before
construction is planned to start
but no sooner than 10/7/98
(effective date)
As soon as practicable before
construction is planned to start
but no later than 12/6/98
(60 days after the effective date}
Notification of Compliance [§63.1306(d)]
Annual Compliance Certification [§63.13Go(g;]
240 days after initial startup
Annually - can submit with semi-
annual report
A neif Slabstock plant Precompliance Report [§63.1306(c)]
10/7/00 or 12 months after initial
startup, whichever is later
(These requirements are in Initial semi-annual Compliance Report
addition to the above/ [§63.1306(ej]
240 days after the notification of
compliance is due
Subsequent senu'-annual Compliance Reports
[§63.1306(e)]
240 days after the Initial semi-
annual Compliance Report and
even 60 days after the end of
each 180 day period thereafter
Change in Selected Emission Limit and
Compliance Method [§63.1306(f)(l),(2)]
180 days before the change takes
effect
103
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Table 7.2 Reporting Requirements
If you arc submitting
an...
Initial Notification
Report
[slabstock, molded and
rcbond foam plants]
then submit by... and include the following information ...
120 days aflcr the
effective date or 120
day.s.aflcr rule applies
to your facility
Name and address of owner or operator.
Address (physical location) of the facility.
Compliance date.
I !rief description of nature, si/.c, design, and method of operation.
Identify each'point of emission for each hazardous air pollutant.
Statement of whether you're a major or area source.
according to these
sections of the rule...
§63.1306(a); §63.9(b)
Application for
Approval of
Construction or
Reconstruction
[slabstock, molded and
rcbond foam plants]
Before construction or Applicant's name and address.
reconstruction
§63.1306(b);§63.5(d)
Notification of intent to construct or reconstruct
Address (physical location) of the facility.
Identify the standard you're subject to.
Date that you expect to start construction or reconstruction.
Date that you expect to finish construction or reconstruction.
Date you expect to start operating (initial startup).
Type and amount of HAP you're emitting or expect to emit.
l;or construction, description of proposed nature, size, design, method of operation and
emission controls and other information under §63.5(d)(2).
For reconslruction, brief description of the facility, parts to he replaced and emission
controls and other information under §63.5(d)(3).
104
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Table 7.2 Reporting Requirements (cont'd)
If you are submitting
an...
Prccompliancc Report
[slabstock foam plants]
then submit by... and include the following information ...
12 months before Whether you'll comply using tlie emission point specific limit or sourcewidc emission
compliance chile limit
Whether you'll comply on a rolling-annual or monthly basis.
I )estriplion of how you'll monitor IIAP AHA or polyol added at the mixhcad.
Notice of your intent to use a recovery device.
A copy of your program for continuous monitoring and rccordkecping on recovered HAP
AHA, if complying using a recovery device.
If complying vvilh the sourcewidc emission limit:
• description of how you'll determine the amount of HAP ABA in a storage vessel
• description of how you'll monitor the amount of HAP ABA added to a storage
vessel during a delivery
Information on your alternative monitoring program found in §63.1303(b)(5)(iHiv)> if
applicable.
according to these
sections of the rule..,
§63.1306(c)
Notification of
Compliance Status
[slabstock, molded and
rcbond foam plants]
Within 180 days after
compliance date
List of your diisocyanatc storage vessels, and controls used for each.
Type of control used for each transfer pump in diisocyanatc service.
Ifcomplying with the emission point specific limits:
• List of IIAP ABA storage vessels, along with control used for each
• List of pumps, valves, connectors, pressure-relief devices, and open-ended valves
or lines in I IAP ABA service
• List of any modifications to equipment in HAP ABA -service you've made to
comply with §63.1296
§63.1306(d)
105
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Table 7.2 Reporting Requirement (cont'd)
If you arc submitting
an...
then submit by... and include the following information .
according (o these
icctionsof the rule-
Semiannual Compliance Scmiannually no later If you're using rolling-annual compliance, report the allowable and actual HAP ABA §63.1306(e)
Report than 60 days after Ihe emissions (or allowable and actual sourccwidc 1IAP emissions) for each 12-month period
end of the 180-day ending on each of the six months in the reporting period (not required for initial semi-
period, annual compliance report).
[slabstock foam plants)
If you're using monthly compliance, report allowable and actual HAP ABA emissions (or
allowable and actual sourccwidc HAP emissions) for each of the six months in the
reporting period.
If you're using a carbon-adsorption system, report unloading events that occurred after
you detected a breakthrough and before you replaced the carbon.
Any equipment leaks you didn't repair.
Any leaks in vapor- return lines you didn't repair.
Change in Selected
Emission Limit
180 days before a
change takes effect
Notify your regulatory agency that you're switching from complying with the emission §63.1306(f)(l)
point specific limit to the sourccwidc emission limit (or vice versa).
[slabstock foam plants]
Change in Selected
Compliance Method
180 days before a
change takes effect
Notify your regulatory agency that you're switching from monthly to rolling-annual §63.1306(f)(2)
compliance (or vice versa).
[slabstock foam plants]
106
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[slabstock, molded or
rcbond fo;im plants]
Table 7.2 Reporting Requirement (cont'd)
If you arc submitting
an...
Annual Compliance
Certification
then submit by... and include the following information . . .
Annually Statement (lint your facility complies with each applicable requirement of the rule.
according to these
sections of the rule..
§63.1306(g)
107
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Example
Initial Notification Report
This is a sample notification form that you can use to comply with 40 CFR 63.1306(a).
Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for Flexible Polyurethane
foam Production. Initial Notification is being made in accordance with §63.1306(a)
and §63.9(b).
1. Print or type the following information for each plant in which you produce flexible polyurethane foam
(slabstock and molded) or rebond foam [§63.9(b)(2)(i)- (ii)]:
Owner/Operator/Title.
Street Address
City State Zip Code.
Plant Name
Plant Contact/Title
Plant Contact Phone Number (optional)_
Plant Address (if different than owner/operator's).
Street Address
City State Zip Code:
2. Show your anticipated compliance date [§63.9(b)(2)(iii)]:
j (Insert compliance date)
Upon startup Anticipated startup date
3. Check which affected source(s) (as defined by 40 CFR 63.1290) exist at your plant (optional):
J Slabstock flexible polyurethane foam production
3 Molded flexible polyurethane foam production
3 Rebond foam production
4. Briefly describe your sources nature, size, design, and method of operation, including its designed
operating capacity. [§63.9(b)(2)(iv)J:
108
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Example Initial Notification Report (Cont'd)
5. Identify each point of emission for each Hazardous Air Pollutant (HAP). If you cant do this definitively
yet, do a preliminary identification. If you need more lines, copy this page [§63.9(b)(2)(iv)].
Please indicate if the information below is: Q Definitive Q Preliminary
Source ID
Source Location
Source
Description
Operation Performed
6. My plant is a major source of Hazardous Air Pollutants (HAPs)
Yes
Q No
NOTE: Only major sources of HAPs are regulated under this rule [§63.9(b)(2)(v)]. If you are not a
major source, you are not subject to the rule and don't need to submit this initial notification. You
should, however, keep documentation on how you determined you were an area source and maintain
those records on file at your plant.
A major source is a facility that may emit more than 10 tons per year of any one hazardous air pollutant
(HAP) or 25 tons per year of multiple HAPs. All other sources are area sources. Whether a source is
a major or area source depends on all HAP emission-points inside the pant's fenceline. not just the
flexible polyurethane foam or rebond foam production facilities.
End of Initial Notification Form
109
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Example
Application for Approval of Construction or Reconstruction
This is a sample notification form that you can use to comply with 40 CFR 63.5(d).
Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for Flexible Polyurethane
foam Production. Notification is being made in accordance with §63.5(d)
[§64.5(d)(1)(ii)(D)J
Description: Your Application for Approval of Construction or Reconstruction falls under the General
Provisions, §63.5(d). This section requires anyone constructing or reconstructing a major
source after the effective date of a standard (in this case 10/7/98) to obtain written
approval to construct or reconstruct the source.
By this we mean, approval is required if you do any one of the following:
construct a new major affected source
reconstruct a major affected source
reconstruct a source that becomes a major affected source
This means that if you construct a new source or reconstruct an existing source that is
subject to the rule and that source a major source of HAPs, you will need to submit an
Application for Approval of Construction or Reconstruction. You can find a definition of
construction and reconstruction in the General Provisions, §63.2.
Use a separate form for each construction or reconstruction you are planning.
1. Print or type the following information for each affected source you're constructing or reconstructing
). (C)]:
Owner/Operator/Title.
Street Address
City ; State ZipCode:_
Plant Name (optional) __
Plant Contact/Title (optional)_
Plant Contact Phone Number (optional)
Plant Address (if different than owner/operator's).
Street Address
City ; State Zip Code:.
110
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Example
Application for Approval of Construction or Reconstruction (cont'd)
2. • I intend to (check only one. use a separate sheet of paper for each separate construction or reconstruction)
G construct a new major affected source
G reconstruct a major affected source
G reconstruct a source that has become a major affected source
3. Describe the type of source you are constructing or reconstructing (optional):
4. I expect to begin construction or reconstruction on (mm/dd/yy) [§64.5(d)(1)(ii)(E)]
I expect to finish construction or reconstruction on (mm/dd/yy) [§64.5(d)(1)(ii)(F)]
I expect to startup on (mm/dd/yy) [§64.5(d)(1)(ii)(G)]
5. Complete this section only if you plan on constructing a new major affected source. All others go to
6 [§64.5(d)(2)].
(a) Describe the size and design capacity of the source you're constructing and at what capacity you
intend to operate:
(b) Identify the type and quantity of Hazardous Air Pollutants (HAPs) emitting after the construction,
the pollution control equipment you intend on using, if any, and it's control efficiency. If you can't
do this definitively, do a preliminary identification.
Please indicate if the information below is: Q Definitive Q Preliminary
111
-------
Example
Application for Approval of Construction or Reconstruction (cont'd)
Note: If you do a preliminary identification, you must submit actual data as soon as practical after it
becomes available, but, no later than your notification of compliance status.
Source ID:
Emission
Point ID
(if applicable)
HAP(s) emitted
Emissions
( units1)
Air Pollution
Control Device
(if applicable)
Control Efficiency of
Control Device
(% efficiency)
1 use the same units, percent reductions or averaging times that are required in the subpart
(c) Include with your submittal any technical information such as calculations you made to determine
your estimated emissions.
6. Complete this section only if you plan on reconstructing an existing major affected source or
reconstructing a source that becomes a major affected source after reconstruction. All others go to 7
[§64.5(d)(3)].
(a) Describe they type of components that you're replacing:
(b) Identify the type and quantity of HAPs emitting after the reconstruction, the pollution control
equipment you currently use and intend on using, if any, and it's control efficiency. If you can't do
this definitively, do a preliminary identification.
Please indicate if the information below is: Q Definitive
Preliminary
112
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Example
Application for Approval of Construction or Reconstruction (cont'd)
Note: If you do a preliminary identification, you must submit actual data as soon as practical after it
becomes available, but, no later than your notification of compliance status.
Source ID:
Emission
. Point ID
(if applicable)
HAP(s)
emitted
Emissions
( units1)
Air Pollution
Control Device
Currently Used
(if applicable)
Planned
Air Pollution
Control
Device
(if applicable)
Control
Efficiency of
Control
Device
(% efficiency)
1 use the same units, percent reductions or averaging times that are required in the subpart
(c) Include with your submittal any technical information such as calculations you made to determine
your estimated emissions.
(d) A discussion of any economic or technical limits you'll have in complying with this subpart after
reconstruction. If you don't plan on having any economic or technical limits after reconstruction,
go to 7.
(i) Discuss what your economic or technical limits will be, how they effect your compliance under
this subpart, what subparts will be effected, and" what alternate methods of compliance you
plan on using:
(ii) My estimated fixed capital cost to reconstruct the affected source is: $ .00
113
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Example
Application for Approval of Construction or Reconstruction (cont'd)
(iii) The estimated life of my affected source after reconstruction is: , years
(iv) If I were to forgo reconstruction and construct a entirely new affected source, comparable with
the one I am reconstructing, my fixed capital costs would be: $ .00
7. End of form.
End of Application for Approval of Construction or Reconstruction
114
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Example
Precompliance Report
This is a sample notification form you can use to comply with 40 CFR 63.1306(c)
Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for Flexible
Polyurethane foam Production. This Precompliance Report is being made for my
slabstock foam facility in accordance with §63.1306(c).
1. Print or type the following information for each plant in which you produce slabstock foam:
Owner/Operator/Title.
Street Address
City State ZipCode:_
Plant Name
Plant Contact/Title
Plant Contact Phone Number (optional)
Plant Address (if different than owner/operator's)
Street Address
City State . Zip Code:_
2. Check which compliance option you're choosing for your slabstock facility (check all that app/y)
[§63.1306(c)(2)]:
J Emission point limit described in §63.1293(a) [§63.1306(c)(1)J
check which option you're choosing [§63.1306(c)(2)J
J I'll comply on a rolling-annual basis under §63.1297(b)
J I'll comply on a monthly basis under §63.1297(c)
3 Sourcewide emission limit described in §63.1293(b) [§63.1306(c)(1>]
check which option you're choosing [§63.1306(c)(3)]
3 I'll comply on a rolling-annual basis under §63.1299(a)
CJ I'll comply on a monthly basis under §63.1299(b)
115
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Example Precompliance Report (Cont'd)
3. Describe how you'll monitor HAP ABA or polyol added at the mixhead. If you're developing an
alternate monitoring program, go to 4 [§63.1306(c)(4)J:
4. Fill out only if you plan to use an alternate monitoring program for HAP ABA or polyol added at the
mixhead. Otherwise, go to 5 [§63.1306(c)(4)]:
If you intend to use an alternate monitoring program for HAP ABA or polyol added at the mixhead
under §63.1303(b)(5), you develop and submit an alternative monitoring program for approval.
You can use this precompliance report for submitting your monitoring program if you're an existing
source. If you're a new source, you can use your Application for Approval of Construction or
Reconstruction. You may also submit a monitoring program after the compliance date. Alternate
monitoring programs must be approved before you can use the alternate.
(a) I have attached an alternate monitoring program:
3 Yes (don't fill out the rest of 4, go to 5)
3 No (fill out the information below)
(b) Describe the parameter you'll monitor to continuously measure the amount of HAP ABA or polyol
added at the mixhead while you're pouring foam [§63.1303(b)(5)(i)]:
(c) Describe how you'll record results, and how you'll convert them into the amount of HAP ABA or
polyol delivered to the mixhead [§63.13031 (b)(5)(ii)]:
116
-------
Example Precompliance Report (Cont'd)
(d) Provide data to show the monitoring device is accurate to within ±2.0 percent [§63.1303(b)(5)(iii)]:
(e) Describe what you'll do to maintain accurate results from parameter monitoring. Make sure your
procedures at least include calibration of all monitoring devices [§63.1303(b)(5)(iv)]:
Fill out this section only if you plan to use a recovery device to comply with §63.1297 or 63.1299.
Otherwise, go to 6 [§§63.1306(c)(5), (c)(6)]:
If you intend to use a recovery device to reduce HAP ABA emissions, under §63.1303(c)(6) you must
develop and submit a recovery HAP ABA monitoring and recordkeeping program for approval.
You can use this precompliance report for submitting your monitoring program if you're an existing
source. If you're a new source, you can use your Application for Approval of Construction or
Reconstruction. You may also submit a monitoring program after the compliance date. Alternate
monitoring programs must be approved before you can use the alternate.
(a) I have attached a program to monitor and keep records on recovered HAP ABA:
ij Yes (don't fill out the rest of 5, go to 6)
j No (fill out the information below)
(b) Describe the solvent-recovery device you've installed, calibrated, maintained, and operated
according to the manufacturer's specification and that shows the cumulative amount of HAP ABA
recovered by the device during each month. Make sure the manufacturer certifies this device to
be accurate to within ± 2.0 percent [§63.1303(c)(1)]:
117
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Example Precompliance Report (Cont'd)
(c) Describe where the monitoring will occur. Make sure the location allows you to measure the HAP
ABA after you've fully recovered it [§63.1303(c)(2)J:
fully recovered means after separation from water introduced into the HAP ABA during regeneration
(d) Describe the parameter you'll monitor and the times you'll monitor it [§63.1303(c)(3)J:
(e) Provide data to show that the monitoring device is accurate to within ±2.0 percent [§63.1303(c)(4)]:
(f) Describe how you'll maintain accurate results from parameter monitoring. Make sure your
procedures at least include periodic calibration of all monitoring devices [§63.1303(c)(5)]:
118
-------
Example Precompliance Report (Cont'd)
6. For sources complying with the sourcewide emission limit, describe how you'll determine the amount
of HAP ABA in a storage vessel [§63.1306(c)(7)]:
7. For sources complying with the sourcewide emission limit, describe how you'll monitor the amount of
HAP ABA added to a storage vessel during a delivery. If you're developing an alternate monitoring
program, go to 8 [§63.1306(c)(8)]:
8. Fill out only if you plan to use an alternative monitoring program for HAP ABA added to a storage
vessel during delivery. Otherwise, go to 9 [§63.1306.(c)(8)]:
If you intend to use an alternate monitoring program for HAP ABA added to a storage vessel
during loading, under §63.1303(e)(4) you must develop and submit an alternative monitoring
program for approval.
You can use this precompliance report for submitting your monitoring program if you're an existing
source. If you're a new source, you can use your Application for Approval of Construction or
Reconstruction. You may also submit a monitoring program after the compliance date. Alternate
monitoring programs must be approved before you can use the alternate.
(a) I have attached an alternative monitoring program for HAP ABA added to a storage vessel during
loading:
j Yes (don't fill out the rest of 8, go to 9)
j No (fill out the information below)
(b) Describe the parameter you'll monitor to determine the amount of HAP ABA added to the storage
vessel during a delivery [§63.1303(e)(4)(i)]:
119
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Example Precompliance Report (Cont'd)
(c) Describe how you'll record the results and how you'll convert them into the amount of HAP ABA
added to the storage vessel during a delivery [§63.1303(e)(4)(ii)]:
(d) Provide data to show the monitoring device is accurate to within ±2.0 percent [§63.1303(e(4)(iii)]:
(e) Describe how you'll maintain accurate results from monitoring. Make sure your procedures at
least include periodic calibration of all monitoring devices [§63.1303(e)(4)(iv)]:
End of Precompliance Report
120
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Example
Notification of Compliance Status
This is a sample notification form which you can use to comply with 40 CFR 63.1306(d)
Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for
Flexible Polyurethane foam Production. Notification of compliance status
is being made in accordance with §63.1306(d).
1. Print or type the following information for each slabstock, molded, or rebond process (optional)
Owner/Operator/Title
Street Address
City State Zip Code:
Plant Name
Plant Contact/Title
Plant Contact Phone Number (optional)
Plant Address (if different than owner/operator's).
Street Address
City State . Zip Code:
2. Fill out only if you produce Slabstock foam. Otherwise, go to 3 [§63.1306(d)]:
(a) List your diisocyanate storage vessels and the type of control you use [§63.1306(d)(1)]:
Diisocyanate Storage Vessel
Type of control
121
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Example Notification of Compliance Status (cont'd)
(b) If transfer pumps are in diisocyanate service, record the type of control you'll use for each transfer
pump [§63.1306(d)(2)]:
Transfer pump in diisocyanate
service
•
Type of control
(c) My slabstock processes are complying with the emission point specific limit under §§63.1294
through 63.1298:
3 Yes
Q No
/f yes, provide the following information; otherwise, go to 3:
(c1) List your HAF ABA storage vessels, and the type of control you use [§63.1306(d)(3)(i)]:
HAP ABA Storage Vessels
Type of control
122
-------
Example Notification of Compliance Status (cont'd)
(c2) List your pumps, valves, connectors, pressure-relief devices, and open-ended values or lines in
HAP ABA service [§63.1306(d)(3)(ii)]:
Equipment List
Q pump G valve
Q open-ended valve
Q pump G valve
G open-ended valve
Q pump G valve
JG open-ended valve
G pump G valve
G open-ended valve
Type
G pressure-relief device
or line G connector
G pressure-relief device
or line Q connector
Q pressure-relief device
or line Q connector
G pressure-relief device
or line G connector
(c3) List any modifications you made to equipment in HAP ABA service to comply under §63.1296
[§63.1306(d)(3)(iii)]:
Equipment Description
Modification Made
3. Fill out only if you produce Molded foam. Otherwise, go to 4 [§63.1306(d)(4)]:
check all that apply
G My affected source for molded foam complies with §63.1300
G My molded foam processes at the effected source comply with §63.1300
4. Fill out only if you produce Rebond foam. Otherwise, go to 5 [§63.1306(d)(5)]:
check all that apply
G My affected source for rebond foam complies with §63.1301
G My rebond foam processes at the affected source comply with §63.1301
End of Notification of Compliance Status
123
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Example
Semi-Annual Compliance Report
This is a sample notification form that you can use to comply with 40 CFR 63.1306(e).
Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for
Flexible Polyurethane foam Production. This semiannual report
is being made for my Slabstock foam facility in accordance with §63.1306(3).
and covers a 6 month period from to •
1. Print or type the following information for each slabstock foam process (optional):
Owner/Operator/Title ; ;
Street Address
City State Zip Code:
Plant Name
Plant Contact/Title
Plant Contact Phone Number (optional).
Plant Address (if different than owner/operator's)
Street Address
City ; State Zip Code:
2. If your slabstock foam source is following rolling-annual compliance under §63.1297 or §63.1299,
record the following. Otherwise, go to 3. If this is your initial semi-annual compliance report, go to 3;
the information in 2 isn't required.
List the allowable and actual HAP ABA emissions (or allowable and actual sourcewide HAP emissions)
for each 12-month period ending on each of the six months in the reporting period [§63.1306(e)(1)].
Example: if you're submitting a July 2000 semiannual report, you would send emission information from January-
June 2000 and July-December 1999.
U.S. EPA Headquarters Library
Mail code 3201
Washington
124
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Example Semi-Annual Compliance Report (cont'd)
Type of Affected source:,
Type of emission limit used:
G actual HAP ABA emission or
Q sourcewide HAP emissions
Reporting
Period
January
February
March
April
May
June
July
August
September
October
November
December
Reporting
Year
-
allowable emissions
( units)
actual emissions
f units)
3. If your slabstock source is following monthly compliance under §63.1297 or §63.1299, record the
following. Otherwise, go to 4.
List the allowable and actual HAP ABA emissions (or allowable and actual sourcewide HAP emissions)
for each of the 6 months in the reporting period [§63.1306(e)(2)].
125
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Example Semi-Annual Compliance Report (cont'd)
Affected source:
Type of emission limit used:
G actual HAP ABA emission or Q sourcewide HAP emissions
Reporting
Period
January
February
March
April
May
June
July
August
September
October
November
December
Reporting
Year
allowable
emissions
f units)
actual emissions
f units)
4. If your slabstock source is using a carbon-adsorption system to comply with the storage-vessel
provisions in §63.1294(a) or §63.1295, record the following. Otherwise, go to 5.
Identify any unloading event that occurred after you've detected breakthrough and before you
replaced the carbon [§63.1306(e)(3)]:
Unloading Event
Date
Breakthrough Comments
126
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Example Semi-Annual Compliance Report (cont'd)
5. If your slabstock source had equipment leaks that you didn't repair according to §63.1294(b)(2)(iii);
§63.1294(c); §63.1296(a)(2)(iii); §63.1296(b)(2); §63.1296(b)(3)(iv); §63.1296(b)(4)(v); §63.1296(c)(2)
• §63.1296(c)(4)(ii); or §63.1296(d)(2). record the following. Otherwise, go to 6.
Identify any equipment leaks you didn't repair [§63.1306(e)(4)]
Type of
Equipment Leak
Date
Leak
Detected
Applicable Section
of Rule
(as indicated above)
Comments
6. If your slabstock source had leaks in the vapor-return line leaks that you didn't repair according to
§63.1294(a)(1)(ii) or §63.1295(b)(2), record the following.
Identify any leaks in the vapor-return line that you didn't repair [§63.1306(e)(5)]
Type of Vapor-
Return Line
Date
Leak
Detected
Applicable Section
of Rule
(as indicated above)
Comments
End of Semiannual Report
127
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Example
Change in Selected Emission Limit and Compliance Method
Make notification to change the selected emission limit and compliance method for your slabstock
foam process by requesting the change in writing (using a letter, memorandum, or a similar
document). Make notification at least 180 days before the change and include the following based on
the type of notification you're making [63.1306(f)(1)]:
I. If your complying with §63.1293
My [identify affected source} is complying with §63.1293. We currently comply
using the emission point specific limit but will be switching to the sourcewide emission limit on
[identify date].
or
My [identify affected source} is complying with §63.1293. We currently comply
using the sourcewide emission limit but will be switching to the emission point specific limit on,
[identify date].
II. If your complying with §63.1297 or §63.1299
My [identify affected source] is complying with § [identify §63.1297 or
§63.1299] . We're currently using the rolling-annual compliance period but will be switching to the
rolling-monthly on [identify date].
or
My [identify affected source] is complying with § [identify §63.1297 or
§63.1299] . We're currently using the rolling-monthly compliance period but will be switching to the
rolling-annually on [identify date].
End of Change in Selected Emission Limitation and Compliance Method
128
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Example
Annual Compliance Certification
This is a sample notification form that you can use to comply with 40 CFR 63.1306(g).
Applicable Rule: 40 CFR Part 63, Subpart III - National Emission Standards for Flexible
Polyurethane foam Production. I'm certifying compliance annually under
§63.1306(g) and §63.1306.
You may use compliance certifications required in your State or local operating permit program to
satisfy this reporting requirement as long as the compliance certification is consistent with §63.1308
[§63.1306(g)(2)].
1. Print or type the following information for each slabstock, molded or rebond process:
Owner/Operator/Title ;
Street Address
City State Zip Code:
Plant Name :
Plant Contact/Title
Plant Contact Phone Number (optional)_
Plant Address (if different than owner/operator's)
Street Address
City State Zip Code:_
I certify that my slabstock foam n molded foam n Rebond foam n is in compliance with
each applicable requirement in §63.1308, Compliance Demonstration, of the Flexible Polyurethane
Foam NESHAP (40 CFR 63, Subpart III). For operations that are not in compliance, provide a
description of your noncompliant operations.
Signature of Responsible Official: ; [§63.1306(g)(3)]
Title of Responsible Official:
129
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Chapter 8 - Other requirements and information
Who administers this regulation?
Your State or local agency for air pollution control, or your EPA Regional Office, will regulate you. If your
plant is in Indian Country, and your eligible Tribe or your EPA Regional Office will regulate you. You may
be regulated by one or more agencies depending on whether they've been granted delegation of this rule.
Definition. An eligible Tribe means "a Tribe that has been
determined by the EPA to meet criteria for being treated in the same
manner as a State, pursuant to the regulations implementing section
301(dX2)oftheAct"
Not all States have been granted delegation, or. if they have been granted delegation, they may not have been
delegated all portions of the rule. Our EPA Regional Offices may also have retained certain rights even after
delegation (for example, you may continue to have dual reporting requirements as explained in Chapter 7).
You should check with your EPA Regional Office or State for the latest information.
Do I need a title V permit?
You'll need a title V permit if you're subject to the Flexible Polyurethane Foam Production NESHAP since.
under title V. you must get a permit if your facility is a major source. The Flexible Polyurethane Foam
Production NESHAP applies to major sources.
To determine if your facility is a major source, you'll need to calculate your HAP emissions from your entire
facility, not just your foam operations. If you don't have federally enforceable limits in a State permit, you
must calculate your emissions by determining your potential emissions. If you need help determining if your
facility is a major source or what your potential emissions are. see the definitions in the Operating Permits
Rule §70.2. or visit our title V policy and guidance page at wvnv.epa.gov/ttn/oarpg/t5main.html.
130
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How do I change my permit to include this rule?
If you've already been issued a final titie V permit and you have three or more years left on your permit, your
permitting authority will reopen your permit within 18 months of the publication date of the final rule or final
amendments. If you have less than three years left on your permit, update your permit during your renewal
period. If your permit hasn't been issued in final form, update your application or draft permit.
To summarize, your options are as follows:
If a new rule is effective1-2 Then...
and you have...
not been issued a final title V permit update your permit application or draft permit
less than three years left on your update your title V permit during renewal
permit
three or more years left on your permit your permitting authority' will reopen your permit
within 18 months after the publication date of the
final rule or final amendments
1 The rule's effective date is the date the final rule is published in the Federal Register (which is 10/7/98 for
this rule).
:This also applies if existing rules are modified and final amendments are published in the Federal Register.
Title V permitting rules may change after the publication of this document. Keep abreast of any changes by
checking the Federal Register or visit our title V websites at ww.epa.gov/ttn oarpgt5main.html and
1. epa.gov/oar-'oaqps'permits .
What portions of the General Provisions apply?
The General Provisions were published in the Federal Register on March 16. 1994 (Volume 59. page 12408)
and apply to all NESHAPs, including the flexible polyurethane foam rule.
This means that when you became subject to this rule, you also became subject to the General Provisions
Some sections in this rule over-ride the General Provisions. You'll find that Table 2 of the final rule shows
you which sections of the General Provisions apply to this rule and which don't. General Precision
requirements, except for notification and reporting are not addressed in this document.
131
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Chapter 9 - Getting additional help
Whom can I ask for help?
You can go to a lot of places for help, including all of the following:
• your State, local or Tribal agency for air pollution control
• your State's Small Business Assistance Program (SBAP)
• local, regional, or national trade associations
• your EPA Regional Office
State and local contacts can change frequently. To get the most current contact information, go to the
STAPPA/ALAPCO website (ww. 4clecmair.org) and then the membership director}-. The directory will give
you the latest contact points for major air programs (that is, emission standards for toxic air pollutants,
ozone, etc.) at the State and local level.
If you have questions about this rule, you should
contact your State, local or Tribal agency before
calling 'the EPA. Their rules may be more stringent
than Federal requirements.
Trade Associations representing the flexible polyurethane foam industry are listed below. Trade associations
sometimes have rule information for their members.
Trade Association
Telephone #
Address
Carpet Cushion Council
(203)637-1312
Society of the Plastics Industry, Inc. (202) 974-5362
Pohwethane Division
Polvurethane Foam Assoc.
(973)633-9044
26 Arcadia Rd., Suite 8
Old Greenwich, CT 06870
1801 "K" Street
600K
Washington, DC 20006
P.O. Box 1459
Wayne, NJ 07474
132
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Many States have a Small Business Assistance Program. If you're a small business and don't know who
your SBAP is, you can call EPA's Control Technology Center Hotline at (919) 541-0800 or visit EPA's SBAP
at www.epa.gov/oar/oaqps/sbap for help.
Contact numbers for EPA's Regional Air Division Offices may also change frequently. To obtain the most
up-to-date information, you may want to visit your Regional Office's website. Table 9.1 (on page 134) lists
each of our Regional Offices, the Air Toxics Division Phone and Address, and the Regions internet home
page. Make all written inquiries to the attention of "NESHAP (insert rule name) Contact."
Can I get more information on the Web?
You can get a wealth of information on the World Wide Web (WWW). Some of the more popular ways to
get information on this rule include:
• EPA's Unified Air Toxics Website (www.epa.gov/ttn/uatw)
You can download copies of preambles, regulations, background information documents, policy
memos, and other guidance materials here. All rule pages can be found under the Rules and
Implementation page. Flexible polyurethane foam can be found under
vnrw. epa. gov/ttn/uatw/foam/foampg. html.
• EPA's Applicability Determination Index (ADI) (http://es.epa.gov/oeca/eptdd/adLhtml)
EPA's Office of Enforcement and Compliance Assurance (OECA) posts memos dealing with
applicability and compliance at this site.
• OECA Compliance Assistance Centers (http://www.epa.gov/epahonte/business.htm)
You can find information on compliance with federal regulations at this site. There are centers for
printing, automotive services and repair, agriculture, and metal finishing industries. We plan to add
centers for the chemical industry, printed wiring board manufacture, transportation, and local
governments.
STAPPA/ALAPCO home page (http://wtvw.4cleanair.org)
STAPPA/ALAPCO is the State and Territorial Air Pollution Program Administrators (STAPPA)
and Local Air pollution Control Officials (ALAPCO) organization. STAPPA/ALAPCO has
members representing each State and local agency' for air pollution control.
You can get air pollution information at this site, including a document entitled "Communicating
Air Quality: A Compendium of Resources." It lists educational materials on air pollution that State
and local agencies have created.
133
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Table 9.1
EPA Regional Air Division Offices
EPA Region States Covered Division Phone and Address
Phone
Home Page
Region
CT, ME, MA, NH,
RI&VT
Office of Environmental Stewardship
(OES)
1 Congress Street, Suite 1100
Boston, MA 02114-2023
Division of Environmental Planning and
Protection
290 Broadway, 21st Floor
New York, NY* 10007-1866
(617)918-1510
www. epa. gov/region 1
Region II
NJ, NY, Puerto
Rico & Virgin
Islands
(212) 637-3735
www.epa.gov/region2
Region
DE, MD, PA, VA,
WV&DC
Air Protection Division, 3AP111
650 Arch Street
Philadelphia, PA 19103-2029
(215)814-2056
www. epa, gov/region3
Region IV
AL, FL, GA, KY,
MS, NC, SC&TN
Air, Pesticides and Toxics Management
Division
345 Courtland Street, NE
Atlanta, GA 30365
(404) 562-9077
www. epa.gov/region4
Region V
IL, IN, Ml, Wl, MN
&OH
Air and Radiation Division
77 West Jackson Blvd.
Chicago, IL 60604-3507
(312)353-2212
www. epa. gov/region 5
Region VI
AR, LA, NM, OK &
TX
Multimedia Planning and Permitting
Division
1445 Ross Avenue
Dallas. TX 75202-2733
(214)665-7200
www. epa. gov/region6
Region VII IA, KS, MO & NE
Air. RCRA and Toxics Division
726 Minnesota Avenue
Kansas Citv. KS 6610]
(913)551-7097
www. epa. gov/region 7
Region VIII
CO, MT, ND, SD,
UT&WY
Office of Enforcement, Compliance and
Environmental Justice (ECEJ)
999 18th Street, 1 Denver Place! Suite 500
Denver, CO 80202-2405
(303)312-7028
www. epa.gov/region 8
Region IX
AZ, CA, HI, NV,
American Samoa,
& Guam
Air Division
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1219
www. epa.gov/region9
Region X
AK, ID, WA & OR
Office of Air Quality
1200 Sixth Avenue
Seattle, WA 98101
(206)553-1505
www. epa. gov/region 10
134
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Is there a list of commonly asked questions?
For a list of questions and answers about the final rule, you'll find EPA's "Hazardous Air Pollutant
Emissions from the Production of Flexible Polyurethane Foam — Basis and Purpose Document for Final
Standards, Summary of Public Comments and Responses, July, 1998 (EPA-453/R-97-008b) useful. You can
download the document by going to our UATW Flexible Polyurethane Foam page at
www.epa.gov/ttn/uatw/foam/foampg.html.
135
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Chapter 10 - Supplemental information for State and local agencies and Tribes
How many plants may need to meet emission limits?
According to information we collected in 1993, we estimated that approximately 77 slabstock, 21 rebond,
and 98 molded foam production plants might be affected by this rule.
You can find a list of slabstock plants that may be affected by the rule in Table 10.1 (on page 138).
Unfortunately, we don't have a list of molded and rebond foam plants. When looking at Table 10.1, realize
that our information is from 1993 and some of the plants may have closed or been redesignated as area
sources. We've included the list as a reference for you, not as an official or complete list of regulated plants.
You can see how many slabstock plants are in your state by going to Figure 10.1 (page 141).
EPA's "Enabling Document: Source Identification Procedures for Sources
Subject to Regulations Under Section 112(d) of the Clean Air Act as Amended
in 1990 ", September 20, 1996 (otherwise known as the "Cookbook"), can
help you identify the steps you can take to locate more sources.
You can download the cookbook by going to
WM-w.epa.gov Tftrwarw eparules.html, scroll down until you see "MACT
Implementation Strategy'". The cookbook is in Appendix G of this document.
Are plants in Indian country regulated by the State?
Generally. State rules aren't enforceable in Indian country. When we delegate authority to States under
section 112(d). the authority to regulate doesn't extend to Indian country unless the delegation agreement
says so.
We encourage tribes to develop the capacity to administer section 112(d) programs and to request delegation.
If we don't delegate the authority to carry out section 112(d) rules to an eligible Tribe, the EPA Regional
Office will be the regulatory authority.
136
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How much HAP emissions will the rule reduce?
We estimate that full implementation of the rule will reduce HAP emissions by about 13,800 tons annually.
Breaking this down, we think that 11,500 tons annually (69%) will be reduced from slabstock foam producers
and 2,300 tons annually (73%) from molded foam producers.
We believed that all rebond foam producers are already complying with the NESHAP requirements, so we
don't estimate any additional reductions from this subcategory.
Estimated National HAP Emission Reductions
20000
15,000 -
10.000
5,000 -
SObotocK FOWT,
Molded Poam
• Britxe RegjotOT D Alter Regdaoon
137
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Table 10.1
1993 U.S. Slabstock Foam Plant List
STATE
ARKANSAS"*"""
COMPANY
LOCATION
CALIFORNIA
DELAWARE
FLORIDA
GEORGIA
ILLINOIS
INDIANA
IOWA
KANSAS
MARYLAND
Foamex (formerly Grain Industries)
Hickory Springs Manufacturing Co.
Ludwig, Inc.
Foamex (formerly Grain Industries)
Foamex (formerly Grain Industries)
Carpenter Company
Carpenter Company
Foamex, L.P.
Foamex, L.P.
Future Foam. Inc.
Hickory Springs Manufacturing Co.
E-A-R Division
Flexible Foam Products
Foamex. L.P.
Omnifoam. Inc.
Austin Urethane, Inc.
Foamex (formerly Grain Industries)
Foamex, L.P.
Hickory Springs Manufacturing Co.
Woodbridge Foam
Burkart Foam. Inc.
General Foam Corp.
No-Sag Foam Products
Foamex (formerly Grain Industries)
E-A-R Specialty Composites
Carpenter Company
Flexible Foam Products
Foamex, L.P.
Foamex, L.P.
Foamex, L.P.
Foamex. L.P.
Future Foam, Inc.
Future Foam, Inc.
William T. Burnett and Co.
Fort Smith
Fort Smith
Waldo
Compton
SanLeandro
Lathrop
Riverside
Orange
San Bernadino
Fullerton
Commerce
Newark
Miami
Orlando
Miami
Americus
Newman
Conyers
Americus
Lithonia
Cairo
Bridgeview
West Chicago
Elkhart
Indianapolis
Elkhart
Elkhart
Auburn
Elkhart
Fort Wayne
Laporte
Council Bluffs
Newton
Baltimore
138
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Table 10.1
Slabstock foam Plant List (cont'd)
STATE
COMPANY
JLOCATION
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
NEVADA
NEW JERSEY
NORTH CAROLINA
OHIO
OREGON
PENNSYLVANIA
TENNESSEE
Crest Foam Industries
Armaly Brands
Plastomer Corp.
General Foam of Minnesota
Hickory Springs Manufacturing Co.
MPI, Inc.
Vitafoam (formerly Olympic Products Co.)
Superior Product Sales, Inc.
Vitafoam, Inc.
Foamex (formerly Grain Industries)
Carpenter Company
Foamex, L.P.
Universal Urethanes, Inc.
Crest Foam Industries
General Foam Corp.
Foamex (formerly Grain Industries)
Carpenter Company
Foamex, L.P.
Hickory Springs Manufacturing Co.
North Carolina Foam Industries, Inc.
North Carolina Foam Industries
Prestige Fabricators. Inc.
Vitafoam, Inc.
Vitafoam (formerly Olympic -Products Co.)
Flexible Foam Products
Scottdel, Inc.
Hickory Springs Manufacturing Co.
Foamex (formerly Grain Industries)
Foamex, L.P.
Foamex, L.P.
General Foam Corp.
Foamex, L.P.
Newburyport .
Walled Lake
Livonia
St. Paul
Verona
Coldwater
Tupelo
Plantersville
Tupelo
Verona
Verona
Verona
N. Las Vegas
Moonachie
East Rutherford
Conover
Conover
Cornelius
Conover
Mount Airy
Mount Airy
Asheboro
High Point
Greensboro
Spencerville
Swanton
Portland
Easton
Cony
Eddy stone
West Hazelton
Milan
139
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Table 10.1
Slabstock foam Plant List (cont'd)
STATE
COMPANY
JLOCATION
TEXAS
VIRGINIA
WASHINGTON
WISCONSIN
Foamex, L.P.
Nu-Foam Products, Inc.
Carpenter Company
Flexible Foam Products
Foamex, L.P.
Texas Fibers Branch 1708
Carpenter Company
Foamex (formerly Grain Industries)
Future Foam, Inc.
Morristown
Chattanooga
Temple
Terrel
Mesquite
Brenham
Richmond
Kent
Middleton
140
-------
0
Figure 10.1
Slabstock Flexible Polyurethane foam Plants (77 plants)
No. Plant Sites
(per Regional Office);
Rl-1
R2-2
R3-7
R4-26
R5-17
R6-8
R7-5
R8-0
R9-9
RIO-2
141
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Appendix A- Subpart III, final rule
Contents for Subpart III, Final Rule
Applicability
Is m\ facility regulated under this Subpart?
What is an affected source?
Are any processes exempt?
How do I calculate if HAPOKd is <5 tpy?
§63.1290(a)
§63.1290(b)
§63.1290(c)
§63.1290(c)(3)
Compliance Schedule
How long do I have to come into compliance with the rule?
§63.1291
Definitions and nomenclature
What are some commonly terms used in this Subpart?
§63.1292
Standards for slabstock flexible polyurethane foam production
What are the emission limitation options?
What options do I have if 1 only use one HAP?
§63.1293
§63.1293(b)
Standards for diisocyanate emissions for slabstock production
What are the control requirements for diisocyanate storage vessels?
What are the requirements during unloading?
What are the control requirements for diisocyanate transfer pumps?
What are the requirements for other diisocyanate components?
When can I delay repair of diisocyanate equipment leaks?
§63.1294
§63.1294(a)
§63.1294(b)
§63.1294(c)
§63.1294(d)
142
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
-------
Contents for Subpart III, Final Rule (cont'd)
Standards for HAP ABA storage vessel emissions for slabstock production
What are the control requirements for HAP ABA storage vessels? §63.129S(a)
What are the vapor balancing requirements? §63.1295(b)
What the are requirements for carbon adsorption systems? §63.1295(c)
Standards for HAP ABA equipment leaks for slabstock production
What are the control options for pumps?
What are the leak detection requirements for pumps?
What are the leak detection requirements for valves?
What are the leak detection requirements for connectors?
What are the leak detection requirements for pressure-relief devices?
What are the requirements for pressure-relief devices?
When can I delay repair of HAP ABA equipment?
§63.1296(a)
§63.1296(a)
§63.1296(b)
§63.1296(c)
§63.1296(d)
§63.1296(e)
§63.1296(f)
Standards for HAP ABA emissions from slabstock production lines
What are the compliance options for production lines? §63.1297(a)
What are the lequirements for rolling-annual compliance? §63.1297(b)
What are the requirements for monthly compliance? §63.1297(c)
How do I determine the HAP ABA formulation limitations? §63.1297(d)
What are the requirements for solvent-recovery devices? §63.1297(e)
Standards for HAP equipment cleaning emissions from slabstock production
When can I use a HAP or a HAP-based material as an equipment cleaner? §63.1298
Standards for sourcewide HAP ABA emissions from slabstock production lines
What are the compliance options? §63.1299
What are the requirements for rolling-annual compliance? §63.1299(a)
143
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Contents for Subpart III, Final Rule (cont'd)
What are the requirements for monthly compliance?
How do I determine actual sourcewide HAP emissions?
How do I determine allowable sourcewide HAP emissions?
What are the requirements for solvent-recovery devices?
§63.1299(b)
§63.1299(c)
§63.1299(d)
§63.1297(e)
Standards for molded foam production
What molded processes are regulated?
Can HAPs be used as an equipment cleaner?
What must I do if I use diisocyanates for flushing?
Can HAPs be used as a mold-release agent?
§63.1300
§63.1300{a)
§63.1300(a)
§63.1300{b)
Standards for rebond foam production
What rebond processes are regulated?
Can HAPs be used as an equipment cleaner?
Can HAPs be used as a mold-release agent?
§63.1301
§63.1301(a)
§63.1301 (b)
Applicability to Subpart A requirements
What sections of the General Provisions apply to me?
Do I have to develop a Start-up, Shutdown and Malfunction Plan?
§63.1302
Table 2
§63.1302
Table 2
Monitoring requirements
What are the requirements for storage vessels carbon adsorption systems?
What are the requirements for HAP ABA and polyol added at the mixhead?
What are the requirements for solvent-recovery?
How do I monitor HAP ABA in the storage vessel?
How do I monitor HAP ABA added to the storage vessel?
§63.1303(a)
§63.1303(b)
§63.1303(c)
§63.1303(d)
§63.1303(e)
144
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Contents for Subpart III, Final Rule (cont'd)
Testing requirements
What test methods must I use for equipment leaks?
What test methods must I use for IFD and density?
§63.1304(a)
§63.1304(b)
Alternate means of emission limitation
How can I get approval for an alternative means of emission limitation?
How soon can I use the alternative emission limitation?
§63.1305
§63.1305(d)
Reporting Requirements
Do I have to submit an initial notification report?
If I install a new source or reconstruct an existing source, what are my requirements?
Is a precompliance report required for slabstock sources?
Do I have to submit a notification of compliance status?
If I have a slabstock source, do I have to report any inforntatien senuawnually?
What notifications must I make if I change my slabstock emission limit?
What notifications must I make if I change m\ slabstock compliance method?
Do I have to submit annual reports?
§63.1306(a)
§63.1306(b)
§63.1306(c)
§63.1306(d)
§63.1306(e)
§63.1306(0(1)
§63.1306(0(2)
§63.1306(g)
Recordkeeping requirements
What storage vessel records must I keep?
What equipment leak records must I keep?
What HAP ABA records must I keep?
What recovery device records must I keep?
Do I have to keep product data sheets for equipment cl
§63.1307(a)
§63.1307(b)
§63.1307(c)
§63.1307(d)
§63.1307(e)
145
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Contents for Subpart III, Final Rule (cont'd)
What records are required for unloading?
What records do I need for solvents used for flushing the mixhead and associated piping?
What records do I need for mold-release agents?
§63.1307(0
§63.1307(g)
§63.1307(h)
Compliance demonstrations
How do I demonstrate compliance for my slabstock facility?
How do I demonstrate compliance for my slabstock facility if I am using emission point specific
limitations?
How do I demonstrate compliance for my molded source?
How do I demonstrate compliance for my rebond source?
§63.1308(b)
§63.1308(c)
How do I demonstrate compliance for my slabstock facility if I am using sourcewide limitations? §63.1308(d)
§63.1308(e)
§63.1308(e)
Delegation of authority
What sections unuer this Subpart have not been delegated to my State or local agency?
§63.1309
146
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Wednesday
October 7, 1998
Part II
Environmental
Protection Agency
40 CFR Parts 9 and 63
National Emission Standards for
Hazardous Air Pollutants for Flexible
Polyurethane Foam Production; Final
Rule
Preamble language pages 53980-53996
Final Rule pages 53996-54014
-------
53980 Federal Register/Vol. 63. No. 194/Wednesday. October 7. 1998/Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Parts 9 and 63
[FRL-6163-9]
RIN 2060-AE86
National Emission Standards for
Hazardous Air Pollutants for Flexible
Polyurethane Foam Production
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Final rule.
SUMMARY: This action promulgates
national emission standards for
hazardous air pollutants (NESHAP) for
hew and existing plamsites that
manufacture flexible polyurethane
foam. These standards are estimated to
reduce HAP emissions from all existing
sources of flexible polyurethane foam
manufacturing by over 12.5'JO Mg/yr.
This represents a 70 percent reduction
from baseline. This action also
promulgates amendments to 40 CFR
part 9. 40 CFR part 9 is amended by
revising tlir- tables to reflect OMB
approvals under the Paperwork
Reduction Act.
DATES: Fffernve date: October 7. 1998.
The incorporation by reference of
certain publications listed in the
regulations is approved by the Director
of the Office of the Federal Register as
of October 7. 1998.
Compliance dates: Existing sources—
October 8. 2001. New scum es at initial
start-up.
ADDRESSES: Docket Docket No. A 95-
48. containing information considered
by the EPA in development of thf
promulgated standards, is available for
public inspection between 8:00 a.m. to
5:30 p.m., Monday through Frida\. at
the following address in room Ml 500.
Waterside Mall (ground floor): U.S.
Environmental Protection Agency. 401
M Street S.W.. Washington. DC 204GO.
telephone number (202) 260-7548. A
reasonable fee may be charged for
copying docket materials
FOR FURTHER INFORMATION CONTACT: For
further information concerning
applicability and rule determinations.
contact the appropriate State or local
agency representative. If no State or
local representative is available, cotitact
the EPA Regional Office staff listed in
the Supplementary Information section
of this preamble. For information
concerning the analyses performed in
developing this rule, contact Mr. David
Svendsgaard. Organic Chemicals Group.
Emission Standards Division (MD-13).
Office of Air Quality Planning and
Standards. U.S. EPA. Research Triangle
Park. North Carolina 27711. telephone
number (919) 541-2380. facsimile
number (919) 541-3470. electronic mail
address "svendsgaard.dave@epa.gov".
SUPPLEMENTARY INFORMATION: The initial
notification contains general facility
Information and a brief process
discription.
Initial notification: Provide to F.PA by
February 4, 1999.
Notification of compliance status:
Existing sources must provide EPA a
notification of compliance status by
April 6. 2002. New sources must
provide EPA a notification of
compliance status within the 180 days
after initial startup.
For further information concerning
applicability and rule determinations.
contact the appropriate State or local
agency representative. If no State or
local representative is available, cotitact
the following EPA Regional Office staff.
Director. Office of Environmental
Stewardship. Attention: Air
Compliance Clerk. U.S. F.PA Region 1
(SEA). JFK Federal Building. Boston.
MA 02203. (617) 565-3432
Umesh Dholakia. U.S. EPA Region II.
290 Broadway. New York. NY 10007
1866. (212)637-4023
Dianne WaJker. U.S. EPA Region III
(3AP11). 841 Chestnut Building.
Philadelphia. PA 19107. (215) 566-
3297
Leonardo Ceron. U.S. EPA Region IV.
Atlanta Federal Center. 61 Forsyth
Street. NE. Atlanta, GA 30303 3104.
(404) 562-9129
Shaun Burke. U.S. EPA Region \ (AE-
17J). 77 West Jackson Street. Chicago.
1L 60604. (312) 353-5713
John Hepola, U.S. EPA Region-VI. 1445
Ross Avenue. Suite 1200. Dallas. TX
75202-2733.(214) 665-7220
Gary Schlicht. U.S. EPA Region VII. 726
Minnesota Avenue. Kansas City. KS
66101. (913) 551-7097
Heather Rooney. U.S. EPA Region VIII.
999 18th Street. Suite 500. Denver. CO
80202-2466.(303) 312^6971
Kenneth Bigos. U.S. EPA Region IX. 75
Hawthorne Street. San Francisco. CA
94105. (415)744-1240
Andrea Wu 11 enweber. U.S. EPA Region
X. 1200 Sixth Avenue. OAQ 107.
Seattle. WA 98101-1128. (206) 553-
8760
Regulated Entities
Entities regulated by this action are
flexible polyurethane foam production
facilities. Typically, these entities are
designated as SIC 3086. Regulated
. categories and entities include:
Category . Examples of regulated entities
Industry Producers of slabstock, mold-
i ed, and rebond flexible poly-
| urethane foam.
i
This table is not intended to be
exhaustive, but rather provides a guide
for readers regarding entities likely to be
regulated by this action. This table lists
the types of entities that the EPA is now
aware could potentially be regulated by
this action. Other types of entities not
listed in the table could also be
regulated. To determine whether a
facility is regulated by this promulgated
action, examine the applicability criteria
in section 63.1290 of the rule. For
questions regarding the applicability of
this action to a particular entity, consult
the person listed in the preceding FOR
FURTHER INFORMATION CONTACT section.
Judicial Review
National emission standards for
polyurethane foam production were
proposed in the Federal Register on
December 27. 1996 (61 FR 68406).
Today's Federal Register action '
announces the F.PA's final decision on
the rule. Under section 307(b)(l) of the
Act. judicial review of the final rule is
available by filing a petition for review
in the U.S. Court of Appeals for the
District of Columbia Circuit within 60
days of today's publication of this final
rule. Under section 307(b)(2) of the Act.
the requirements that are the subject of
today's notice may not be challenged
later in civil or criminal proceedings
brought by the F.PA to enforce these
requirements.
The following outline is provided to
aid in reading the preamble to the final
rule.
I Summary of Considerations Made in
Developing This Standard
A Background and Purpose of the
Regulation
B. Source of Authority
C . Stakeholder and Public Participation
II. Summary of Promulgated Standards
A. Standards for Molded and Rebond
Flexible Polyurethane Foam Production
B. Standards for Slabstock Flexible
Polyurethane Foam Production
C. Standards for Diisocyanate Emissions
from Slabstock Flexible Polyurethane
Foam Production
D. Standards for HAP ABA Emissions from
Slabstock Flexible Polyurethane Foam
Production
E. Monitoring Requirements
F Testing Requirements
G. Alternative Means of Emission
Limitation
H. Applicability of General Provisions
I Reporting Requirements
J. Recordkeeping Requirements
III. Summary of Impacts
A Facilities Affected by These NESHAP
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Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations 53981
B. Air Impacts
C. Other Environmental Impacts
D. Energy Impacts
E. Cost Impacts
F. Economic Impacts
IV. Significant Comments and Changes to the
Proposed Standards
A. Public Response to EPA Request for
Comment
B. Other Rule Changes in Response to
Public Comments
C. Other Changes to the Proposed
Regulation
V. Administrative Requirements
A. Docket
B. Executive Order 12866
C. Applicability of Executive Order 13045
D. Paperwork Reduction Act
E. Regulatory Flexibility Act
F. Submission to Congress and the
Comptroller General
G. Unfunded Mandates
H. Executive Order 12875: Enhancing
Intergovernmental Partnerships
I Executive Order 13084: Consultation and
Coordination With Indian Tribal
Governments
J. Clean Air Act
K. National Technology Transfer and
Advancement Act
I. Summary of Considerations Made in
Developing Tliis Standard
A. Background and Purpose of The
Regulation
The Clean Air Act was created in part
"to protect and enhance the quality of
the Nation's air resources so as to
promote the public health and welfare
and the productive capacity of its
population." [Clean Air Act. section
lOl(bHl)] Section 112(b). as revised in
61 FR 30816 (June 18. 1996). lists 188
hazardous air pollutants (HAP) believed
to cause adverse health or
environmental effects. Section 112(d)
requires that emission standards be
promulgated for all categories and
subcategories of "major" sources of
these HAP and for many smaller "area'
sources listed for regulation, pursuant to
section 112(c). Major sources are
defined as those that emit or have the
potential to emit at least 10 tons per
year of any single HAP or 25 tons per
year of any combination of HAP.
On July 16. 1992 (57 FR 31576). the
EPA published a list of categories of
sources slated for regulation. This list
included the flexible polyurethane foam
production source category regu'ated by
the standards being promulgated today.
The statute requires emissions standards
for the listed source categories to be
promulgated between November 1992
and November 2000. On December 3.
1993. the F.PA published a schedule for
promulgating these standards (58 FR
63941). Standards for the flexible
polyurethane foam production source
category covered by this rule were
proposed on December 27.1996 (61 FR
68406).
For the purpose of this rule, the F.PA
has separated the flexible polyurethane
foam production source category into
three subcategories. These subcategories
are slabstock. molded, and rebond
flexible polyurethane foam production.
In the 1990 Amendments to the Clean
Air Act, Congress specified that each
standard for major sources must require
the maximum reduction in emissions of
HAP that the EPA determines is
achievable, considering cost, non air
quality health and environmental
impacts, and energy requirements. In
essence, these Maximum Achievable
Control Technology (MACT) standards
would ensure that all major sources of
toxic air pollutants achieve the level of
control already being achieved by the
better controlled and lower emitting
sources in each category. This approach
provides assurance to citizens that each
major source of toxic air pollution will
be required to employ good control
measures to limit its emissions.
Available emission data, collected
during the development of this rule.
shows that pollutants that are listed in
section 112(b)(l) and are emitted by
flexible polyurethane foam production
sources include methylene chloride.
2.4 toluene diisocyanate. methyl
chloroform, methylene diphenyl
diisocyanate. propylene oxide.
diethanolamine. methyl ethyl ketone.
methanol. and toluene. Metlwlene
chloride comprises over 98 percent of
the total HAP emissions from this
industry. Following is a summary of the
potential health effects associated with
exposure to methylene chloride that
will be reduced by the standard.
The acute (short-term) effects of
merhylene chloride inhalation in
humans consist mainly of nervous
system symptoms such as decreased
visual and auditory functions. These
effects appear to be reversible once
exposure ceases. Short term exposure to
high concentrations of methylene
chloride also irritates the nose and
throat. The effects of chronic (long-term)
exposure to methylene chloride in
humans involve the central nervous
system, and include headaches.
dizziness, .nausea, and memory loss.
Animal studies indicate that inhalation
of methylene chloride affects the liver.
kidney, and cardiovascular system.
Developmental or reproductive effects
of methylene chloride have not been
reponed in humans, but limited animal
studies have reported lowered fetal
body weights in rats exposed to
inhalation.
Human data are considered
inadequate to prove cancer caused by-
exposure to methylene chloride; animal
studies have shown increases in liver
and lung cancer and benign mammary
gland tumors following the inhalation of
methylene chloride. Methylene chloride
is classified as Group'B2. probable
human carcinogen of relatively low-
carcinogenic potency.
As noted earlier, there are other HAP
emitted by flexible polyurethane foam
production facilities. While the
magnitude of emissions of these
pollutants is dwarfed by those of
methylene chloride, it is important to
note, that the F.PA has not undertaken a
risk assessment of these facilities.
Therefore, it is possible that other HAP.
such as diisocyanates. may also pose
risks of concern. The seriousness of
risks remaining after imposition of the
final MACT standards will be examined
at a later date, as provided for under
Section 112(f) of the Clean Air Act.
The Crean Air Act strategy avoids
dependence on a detailed and
comprehensive risk assessment as a pre
requisite for controlling air toxics. In
addition, this is not a "significant" rule
as defined by Exr-cutive Order 12866.
and a specific benefits analvsis is nut
required. Because of these issues, a
detailed and intensive risk assessment
of potential effects from HAP emitted
from flexible foam production plants is
not included in this rulemaking.
The effects of HAP vary in severity
based on the level and length of
exposure and are influenced by source
specific characteristics such as emission
rates and local meteorological
conditions. The extent and degiee to
which the health effects may be
experienced is dependent upon: (II the
ambient concentrations observed in thf
area (e.g.. as influenced b> emission
rates, meteorological conditions, and
terrain): (2) the frequency and duration
of exposures: (31 characteristics of the
exposed individuals (e.g.. genetics. ag(.
pre-existing health conditions, and
lifestyle), which vary significantly with
the population: and (4) pollutant
specific characteristics (e.g.. toxicity.
half life in the environment.
bioaccumulation. and persistence!.
Due to the volatility and relative]-,,
low potential for bioaccumulation of
these pollutants, air emissions are not
expected to deposit on land or water
and cause subsequent adverse health or
ecosystem effects.
Tlie final standards give existing
sources 3 years from the date of
promulgation to comply. Subject to
certain limited exceptions, this is the
maximum amount of time allowed
under the Clean Air Act. New sources
are required to comply with the
standard upon initial startup. The EPA
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53982 Federal Register/Vol. 63. No. 194/Wednesday. October 7, 1998/Rules and Regulations
believes these standards to be
achievable for affected sources within
the lime provided.
Included in the final rule are methods
for determining initial compliance, as
well as monitoring, recordkeeping. and
reporting requirements. All of these
components are necessary to ensure that
sources will comply wirh the standards
both initially and over time. However,
the F.PA has made every effort to
simplify the requirements in the rule.
Two of the HAP used and emitted by
the flexible polyurethane foam industry
(2.4-toluene diisocyanate and propylene
oxide) are subject to the risk
management program rule requirements
under section 112(r) of the 1990 Clean
Air Act Amendments. The risk
management program rule was
published in the Federal Register on
June 20. 1996 (61 FR 31668). Facilities
handling a listed substance in quantities
greater than a threshold amount must
comply with the risk management
requirements by June 21. 1999. The list
of substances and threshold quantities
were published in the Federal Register
on January 31. 1994 (59 FR 4478).
B. Source of Authority
The amended Clean Air Art requires
the EPA to promulgate nations!
emission standards for sources of HAP.
Section 112(d) provides that these
standards must reflect "* * * the
maximum degree of reduction in
emissions of the HAP * ' * that the
Administrator, taking into consideration
the cost of achieving such emission
reduction, and any nonair quality health
and environmental impacts and energy
requirements, determines is achievable
for new or existing sources in the
categorv or subcategoty to which such
emission standard applies. * ' ""[42
LJ.S.C. 7412(d)(2)l. This level of control
is referred to as the maximum
achievable control technology (MAC i"i.
The Clean Air Act goes on to establish
the least stringent level of control for
M.ACT: this level is termed the "MACT
floor."
For new sources, the standards for a
source category or subcategory "shall
not be less stringent than the emission
control that is achieved in practice by
the best controlled similar source, as
determined by the Administrator"
[section 112(d)(3)]. Existing source
standards shall be no less stringent than
the average emission limitation
achieved by the best performing 12
percent of the existing sources for
source categories and subcategories with
30 or more sources, or the average
emission limitation achieved by the best
performing 5 sources for sources or
subcategories with fewer than 30
sources [section 112(d)(3)]. These two
minimum levels of control define the
MACT floor for new and existing
sources.
been made to the standards between
proposal and promulgation. Section IV
of this preamble discusses some of the
major changes made to the standards.
C. Stakeholder and Public Participation II. Summary of Promulgated Standards
Numerous representatives of the
flexible polyurethane foam production
industry' were consulted in the
development of this standard. Industry
representatives have included trade
associations and flexible foam
producers responding to Information
Collection Requests. The F.P.A also
received input from representatives
from State and Regional environmental
agencies. Representatives from other
interested F.PA offices and programs
participated in the regulatory
development process as members of the
Work Group. The Work Group was
involved in the regulatory development
process, and was given opportunities to
review and comment on the standards
before proposal and promulgation.
Therefore, the F.P.A believes that the
impact on other FPA offices and
programs has been adequately
considered during the development of
these standards. Finally, industry
representatives, regulatory' authorities.
environmental groups, and the public as
a whole had the opportunity to
comment on the proposed standards
and to provide additional information
during the public comment period that
followed proposal.
The standards were proposed in the
Federal Register on December 27. 1996
(61 FR 68406). The preamble and Basis
and Purpose Document for the proposed
standards described the rationale for the
proposed standards. Public comments
were solicited at the time of proposal.
To provide interested individuals the
opportunity for oral presentation of
data, views, or arguments concerning
the proposed standards, a public
hearing was offered at proposal.
However, the public did not request a
hearing and. therefore, one was not
held. The public comment period was
from December 27. 1996 to February 25.
1997. A total of 12 comment letters were
received. Commenters included
industry representatives and State
agencies. The comments were carefully
considered, and changes were made in
the proposed standards when
determined by the F.P.A to be
appropriate. A detailed discussion of
these comments and responses can be
found in the Basis and Purpose
Document for Final Standards, which is
referenced in Section V.A. of this
preamble. The summary of comments
and responses in the Basts and Purpose
Document for the Final. Standards serves
as the basis for the revisions that have
HAP emissions frotrt tlie following
types of emission points (i.e., emission
source types) are being covered by the
final standard: storage vessels.
equipment, leaks, production line.
mixhead flush, mold release agents, and
auxiliary blowing agent (ABA) use. The
HAP emitted and emission points
required to be controlled by these
standards vary according to whether the
facility produces slabstock. molded, or
rebond flexible polyurethane foam.
The affected source is defined as each
process that produces flexible
polyurethane or rebond foam, emits a
HAP, and is located at a major source
plant site. A process consists of raw
material storage: production equipment
and piping, ductwork, and other
associated equipment: and curing and
storage areas. The regulations do not
apply to processes dedicated
exclusively to the fabrication {i.e..
gluing or otherwise bonding foam pieces
together) of flexible polyurethane foam
or to research and development.
Existing sources subject to the
regulation are required to comply
within three years of the effective date
of the regulation, and new sources
would be required to comply at initial
startup. Following is a description of the
requirements of the standards.
A. Standards far Molded and Rebond
Flexible PoJyurethane Foam Production
At new and existing molded arid
rebond flexible polyurethane foam
facilities subject to the rule, the use of
HAP or HAP based products as
equipment cleaners or mold release
agents is prohibited. The one exception
to this prohibition is that diisocyanates
may be used at molded foam facilities
to flush the mixhead and associated
piping during periods of startup or
maintenance, as long as such solvents
are contained in closed loop systems
and are re used in production. Molded
and rebond foam producers are required
to submit an initial notification and
maintain records to demonstrate that the
equipment cleaners and mold release
agents used are not HAP based.
B. Standards for Slabstock Flexible
Polyurethane Foam Production
The requirements for slabstock foam
facilities are separated into two basic
categories: (1) diisocyanates used as a
reactant in the foam process: and (2)
HAP used as an auxiliary blowing agent
(ABA) and for equipment cleaning. The
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Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations 53983
diisocyanate HAP used in the
production of slabstock foam is almost
always 2.4-toluene diisocyanate (TDI).
and the HAP used as an ABA and
equipment cleaner is almost always
methylene chloride. The rule covers
emissions from two types of TDI
emission points storage vessels and
equipment leaks. HAP ABA emissions
from the following process points are
covered: storage vessels, equipment
leaks, the foam tunnel, and equipment
cleaning.
C. Standards for Diisocyanate Emissions
From Slabstock Flexible Polyurethane
Foam Production
The standards cover emissions of
diisocyanate from storage vessels and
equipment leaks. For new and existing
sources, there are two compliance
options for storage vessels. The vessel
can be equipped with a vapor return
line that returns vapors displaced
during storage vessel filling to the tank
truck or rail car. During each unloading
event, the vapor return line must be
inspected for leaks. If a leak is detected.
it must be repaired before the next
unloading event. The second option is
to equip the storage vessel with a system
in which displaced vapors are routed
through a carbon adsorption system
prior to being discharged to the
atmosphere. Storage vessels equipped
with carbon adsorption systems must
monitor the outlet of the carbon system
to detect breaktlirough. If breakthrough
is detected, the carbon must be replaced
before the next unloading event.
Transfer pumps in diisocyanate
service must be either sealless pumps.
or submerged pump systems that are
visually monitored weekly to detect
leaks. Any transfer pump leaks detected
must be repaired within ] 5 calendar
days. Diisocyanate leaks for other
components in diisocyanate service
(valves, connectors, and pressure relief
valves) detected by visual, audible, or
any other detection method must be
repaired within 15 calendar days, as
well.
D. Standards for HAP ABA Emissions
From Slabstock Flexible Pohurethane
Foam Production
This regulation requires that owners
or operators comply with requirements
for each of four types of emission points
(HAP ABA emissions from storage
vessels, equipment leaks, and the
production line, and HAP emissions
from equipment cleaning). These
limitations are described below.
However, since the same HAP.
methylene chloride, is frequently used
as both an ABA and as an equipment
cleaner, this rule allows owners and
operators flexibility in complying with
the HAP ABA and equipment cleaning
provisions. As an alternative to the
emission point specific limitations, the
owner or operator can elect to comply
with a source wide emission limitation.
Owners or operators selecting the
source-wide emission limitation must
maintain the combined emissions from
all of these sources below the required
level. While this option is slightly more
stringent, than the emission point
specific limitations, the EPA believes
the flexibility it provides will prove to
be beneficial for sources selecting this
alternative.
1. HAP ABA Storage Vessel
Requirements
The requirements for HAP ABA
storage vessels are similar to the
diisocyanate storage vessel requirements
discussed above. Storage vessels can be
equipped with either a vapor return line
to the tank truck or railcar. or a carbon
adsorption system. The requirements for
new and existing sources are identical.
2. HAP ABA Equipment Leaks
These standards contain requirements
for pumps, valves, connectors, pressure
relief devices, and open ended valves or
lines in HAP ABA sen-ice at new and
existing sources.
Pumps and valves must be monitored
quarterly for leaks using Method 21. 40
CFR part 60. appendix A. where a leak
is defined as an instrument reading of
10.000 pans per million or greater.
Leaks must be repaired within 15
calendar days after their detection.
Alternatively, leakless pumps can be.
used. Valves that are designated as
unsafe to monitor must be monitored as
frequently as possible, and difficult to
monitor valves must be monitored once
per year.
Connectors must be monitored
annually using Method 21. unless the
connector has been opened or the seal
broken. In these cases, the connector
must be monitored within 3 months
after being returned to HAP ABA
service. As with the other components.
a leak is defined as an instrument
reading of 10.000 parts per million or
greater, and a leak must be repaired
within 15 calendar days. Connectors can
also be designated as unsafe to monitor.
in which case they must be monitored
as frequently as possible.
Pressure relief devices must be
monitored using Met hod 21 if evidence
of a potential leak is found by visual.
audible, olfactory, or any other
detection method. If a leak is found
(10.000 parts per million), it must be
repaired within 15 calendar days. Each
open ended valve or line in HAP ABA
service must be equipped with a cap.
blind flange, plug, or a second valve.
3. HAP ABA Emissions from the
Production Line
The rule includes an emission limit
for HAP ABA emissions from the
production line at affected slabstock
facilities. There are two options for
complying with the requirements for
HAP ABA emissions from the
production line rolling annual
compliance or monthly compliance.
When using a rolling annual basis.
compliance is determined each month.
based on the previous 12-month period.
Under the monthly compliance
alternative, compliance is based on the
previous month. Both options require
comparing actual HAP ABA emissions
to allowable HAP ABA emissions.
Rolling Annual Compliance. This
regulation recognizes the variability in
HAP ABA emissions for different grades
of foam, where a grade of foam is
determined by its density and
indentation force deflection (1FD).
Therefore, the allowable emission level
is dependent on the mix of foam grades
produced during the 12 month
compliance period. The nucleus of the
HAP ABA emission limitation
provisions is the HAP ABA formulation
limitation equation, which determines
an allowable amount of HAP ABA for
each grade of foam. For existing sources.
this equation is:
ABA,,mil=-0.25 (IFD)-19.1
IFD;
-16.2 (DEN)-7.56
1
VDEN,
1 + 36.5
Where:
ABAj,mi, - HAP ABA formulation
limitation, parts HAP ABA allowed
per hundred parts polyol (pph)
IFD =•- Indentation force deflection (25
percent), pounds
DEN - Density, pounds per cubic foot
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53984 Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
Therefore, for each foam grade produced
during the 12 month period, the owner
or operator must determine the HAP
ABA formulation limitation. This
equation was developed using actual
formulation data from the best
performing foam production facilities.
Negative values are not intended to be
used in calculating allowable emissions.
That is, zero is the formulation
limitation if the results of the
formulation limitation equation are
negative.
For new sources, the equation is used
to determine the HAP ABA formulation
limitation for a limited number of
grades. However, the formulation
limitation for many higher-density.
higher IFD foams is automatically set to
zero. The following table*describes how
the HAP ABA formulation limitation for
new sources is determined.
Values in
parts ABA
per
hundred
parts
polyol
IFD
0-10
11-15
16-20
21-25
26-30
31 +
Density ranges (pounds per cubic
foot)
0-
0.95
0.96- 1.06-
1.05 1.15
1.16-
1.40
Use Equation
0
1.41 +
For any foam grade, the owner or
operator has the option to designate the
HAP ABA formulation limitation as
zero. The henefii to such a designation
is that the IFD and densitv testing
requirements, as well as tti
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Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations 53985
for the 12 previous months. An
advantage of the monthly compliance
approach is that a violation of the
allowable monthly HAP limitation
constitutes up to 30 days of violation for
that compliance period, whereas a
violation of the allowable annual total of
HAP calculated in any given month
constitutes up to 365 days of violation
for that compliance period. This
alternative is allowed because it is more
stringent than the rolling annual
compliance approach. In addition, as
with the rolling average compliance
approach, the use of HAP ABA recovery1
devices is permitted with the monthly
compliance approach.
4. Equipment Cleaning HAP Emissions
Affected sources complying with the
emission point specific limitations are
prohibited from using a HAP. or a HAP
based product, as an equipment cleaner.
5. Source-wide Emission Limitation
Alternative
This alternative allows the owner or
operator to choose which of the HAP
ABA emission sources to control.'but is
only available for sources using no more
than one HAP as an ABA and
equipment cleaner in the process. In
other words, an owner or operator could
choose not to control HAP ABA storage
vessels and equipment leaks, and
instead achieve a higher.HAP ABA
emission reduction from the production
line. Alternatively, an owner or operator
could choose to control emissions from
equipment leaks and storage to "save"
as much HAP ABA as possible for use
in the production line. In addition,
under the source wide alternative, a
facility could utilize a HAP equipment
cleaner, as long as the HAP used as the
equipment cleaner is the same chemical
as the HAP ABA. However, the
equipment cleaning HAP emissions
must be offset by emission reductions
from one of the HAP ABA emission
sources.
An owner or operator electing to
comply with the source wide emission
limitation for HAP ABA and equipment
cleaning determines compliance by
comparing actual emissions from the
three HAP ABA emission sources and
from equipment cleaning with an
allowable emissions level. Compliance
is determined each month for the
previous 12-month period.
The allowable emissions level is
determined using the same procedures
discussed above for HAP ABA
emissions from the production line.
Therefore, the total HAP ABA and
equipment cleaning HAP emissions
allowed under this alternative are
equivalent to the allowed HAP ABA
emissions from the production line if
the emission point specific alternative is
selected.
The actual HAP ABA and equipment
cleaning emissions are determined by
performing a material balance at the
HAP ABA storage vessel, using the
following equation:
PWEactual = JT (ST, begm -ST.. md + ADD,)
Where:
ctua) - Actual source wide HAP
ABA and equipment cleaning HAP
emissions for a month, pounds/
month
ST,.b*gm - Amount of HAP ABA in
storage tank i at thp beginning of the
month, pounds
ST.. ,nd - Amount of HAP ABA in
storage tank i at the end of thf
month, pounds.
ADD, - Amount of HAP ABA added to
storage tank i during the month.
pounds
n - Number of HAP ABA storage vessels
Weekly monitoring of the level of HAP
ABA in the storage vessels is required.
thus providing the amounts for the
beginning and end of month to be used
in the above equation. In addition, the
amount of each HAP ABA delivery must
be determined. The requirements for the
monitoring of HAP ABA storage vessel
levels and the amount of HAP ABA
added during each delivery are
discussed later in this section. Emission
reductions achieved by recovery devices
can be accounted for by monitoring the
amount of HAP ABA recovered.
As with the emission point specific
limitation for HAP ABA from the
production line, the source-wide
emission limitation includes a monthly
compliance alternative.
E. Monitoring Requirements
This regulation contains monitoring
requirements for five situations: (1) _
storage vessels complying using carbon
adsorption systems: (2) polyol and HAP
ABA added to the production line at the
mixhead: (3) recovered HAP ABA when
a recovery device is used: (4) the
amount of HAP ABA in a storage vessel:
and (5'i the amount of HAP ABA added
to a storage vessel.
1. Storage Vessel Complying Using
Carbon Adsorption Systems
Storage vessels equipped with carbon
adsorption systems must monitor either
the concentration of HAP or the
concentration of organic compounds at
the exit of the adsorption system.
Measurements of HAP concentration
must be made using Method 18
Appendix A of 40 CFR 60 and
measurements of organic compound
concentrations must be made using
Method 25A. Outlet concentration
measurements must be made monthly
(or each time the vessel is filled, if
filling occurs less frequently than
monthly). Alternatively, the owner or
operator can implement an alternative
monitoring program where monitoring
of HAP or organic compound
concentrations during vessel filling
must be conducted at an interval no
greater than 20 percent of the carbon
replacement interval, which is
established using a design analysis.
2. Polyol and HAP ABA Monitoring at
the Mixhead
All slabstock facilities must
continuously monitor the amount of
polyol added to the slanstork foam
production line at the mixhead when
foam is being poured to allow the
calculation of allowable emissions. The
regulation contains two options for
continuously monitoring the polyol
added: (1) a device installed and
operated to monitor and record pump
revolutions per minute, or (2) a flow rate
monitoring device installed and
operated to measure the amount of
polyol added at the mixhead. Either of
these devices must be calibrated at least
once each 6 months, and must have an
accuracy to within ± 2 percent. The
owner or operator can develop an
alternative monitoring program to
monitor the amount of polyol added at
the mixhead. The components of an
alternative monitoring plan must
include, at a minimum: (1) description
of the parameter to be monitored to
measure the amount of HAP ABA or
polyol added at the mixhead: (2) a
description of how the monitoring
results will be recorded, and how the
results will be converted into amount of
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53986 Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
HAP ABA or polyo' delivered to the
mixhead: (3) data demonstrating that the
monitoring device is accurate to within
± 2.0 percent; and (4) procedures to
ensure that the accuracy of the
parameter monitoring results is
maintained. These procedures shall, at a
minimum, consist of periodic
calibration of all monitoring devices. An
alternative plan must be submitted to
the Administrator for approval.
In addition, if an owner or operator
elects to comply with rhe emission
point specific limitations, the amount of
HAP ABA added to the slabstock foam
production line at the mixhead must be
continuously monitored when foam that
contains HAP ABA in the formulation is
Being poured. The requirements for
monitoring the amount of HAP ABA
added are the same as discussed above
for polyol. except that the device must
be calibrated at least once per month.
3. Recovered HAP ABA Monitoring
The rule also includes monitoring
requirements for slabstock facilities
using a recovery device to reduce HAP
ABA emissions. The amount of HAP
ABA recovered is determined by using
a device that monitors the cumulative
amount of HAP ABA recovered b\ the
recover}' device. This device must be
installed, calibrated, maintained, and
operated according to the
manufacturer's specifications, and must
be certified by the manufacturer to be
accurate to within ± 2.0 percent. The
rule requires the owner or operator to
develop a recovered HAP ABA
monitoring and recordkeeping plan and
submit it to the EPA for approval.
4. Monitoring to Determine Amount of
HAP ABA in a Storage Vessel
For slabstock sources complying with
the source wide alternative, the amount
of HAP ABA in a storage \ essel must be
monitored weekly using a level
measurement device. The level
measurement device must be calibrated
initially and at least once per year
thereafter. If the level measurement
device produces an output signal, it
must have either a digital or printed
output. If the level measurement device
is a visually-read device (i.e.. gauge
glass), it must have permanent
graduated markings to indicate HAP
ABA level in the storage tank.
5. Monitoring to Determine the Amount
of HAP ABA Added to a Storage Vessel
The amount of HAP ABA added to a
storage vessel during a delivery must be
determined using any one of four
options. The first option requires that
the amount of HAP ABA in the storage
vessel be measured before and after the.
loading, provided that the level
measurement device meets the
requirements discussed above in section
"I1.E.4". The second option requires that
the volume of HAP ABA added to the
storage vessel be determined by
monitoring the flow rate using a device
with an accuracy of 98 percent or
greater, and which is calibrated at least
once every six months. The third option
allows the owner or operator to
calculate the weight of HAP ABA added
by determining the difference between
the full weight of the transfer vehicle
prior to unloading into the storage
vessel and the empty weight of the
transfer vehicle after unloading has been
completed. This weight must be
determined using a scale approved by
the State or local agencies.using the
procedures contained in the National
Institute of Standards and Technology
Handbook 44. or a scale determined to
be in compliance with the requirements
of the National Institute of Standards
and Technology Handbook 44 at least
once per year by a registered scale
technician. The final option for
determining the amount'of HAP ABA
added to a storage vessel allows the
owner or operator to develop an
alternative monitoring program. The
alternative monitoring program must
include, at a minimum, a description of
the parameter to be monitored to
determine the amount of the addition, a
description of how the results of tl e
monitoring will be recorded ^nd
converted into the amount of HAP ABA
added, data demonstrating the accuracy
of the monitoring measurements, and
procedures for ensuring that the
accuracy of the monitoring
measurements is maintained.
Alternative monitoring programs must
be submitted to the EPA for approval.
F. Testing Requirements
There are two instances where the use
of test methods is required. First, for
slabstock owners or operators
complying with the emission point
specific requirements for HAP ABA
equipment leaks, testing must be
conducted using Method 21 of 40 CFR
pan 60. subpart.A.
Second, all slabstock affected sources
must test each grade of foam produced
during a single production "run" to
verify the IFD and density, as these are
integral inputs into the equation to
determine the HAP ABA formulation
limitation. This rule requires these
parameters to be determined using
American Society for Testing and
Materials (ASTM) D3574 using a sample
of foam cut from the center of the foam
bun. The maximum sample size for
which the IFD and density is
determined shall not be larger than 24
inches by 24 inches by 4 inches. IFD
and density testing is not required for
foam grades for which the owner or
operator has designated thie HAP ABA
formulation limitation as zero. The IFD
and density testing results must be
conducted and recorded within 10
working days of the date the foam was
produced.
G. Alternative Means of Emission
Limitation
This regulation also contains
provisions to allow an owner or
operator to request approval to use an
alternative means of emission
limitation. Examples of alternative
means of emission limitation could be
the reduction of HAP ABA by a
combustion device, use of a storage tank
control not mentioned in the regulation.
or an alternative program to reduce HAP
ABA equipment leak emissions. The
request, which may be submitted in the
precompliance report for existing
sources, the application for constniction
or reconstruction for new sources, .or at
ar.y other time after the initial
compliance, must include a complete
description of the alternative means of
emission limitation and documentation
demonstrating equivalency with the
requirements in the regulation. The
ow:ner or operator can begin using the
alternative means of emission limitation
upon approval of the request by the
Administrator.
H. Applicability of General Provisions
The General Provisions for Part 63 (40
CFR part 63. subpart A) create the
technical and administrative framework
for implementing national emission
standards established under section 112
of the Clean Air Act. The General
Provisions establish baseline applicable
requirements for activities such as
performance testing, monitoring.
notifications, recordkeeping. and
reporting. They also implement
statutory provisions such as compliance
dates for new and existing sources and
preconstruction review requirements.
The General Provisions apply to all
sources that are affected by Part 63
standards, including the standard for
flexible polyurethane foam production.
However, individual standards may
override certain requirements in the
General Provisions. This regulation
contains a table outlining the sections of
the General Provisions that are
applicable to the standard for flexible
polyurethane foam production. It also
outlines sections of the General
Provisions that are being overridden or
not incorporated. The performance test
requirements: monitoring requirements:
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Federal Register/Vol. 63, No. 194/Wednesday. October 7, 1998/Rules and Regulations 53987
and startup, shutdown, and malfunction
plan requirements of the General
Provisions do not apply to this standard.
Most of the other requirements in the
: General Provisions do apply.
/. Reporting Requirements
This regulation requires the submittal
of seven types of reports: (1) initial
notification. (2) application for approval
of construction or reconstruction. (3)
precompliance report. (4) notification of
compliance status. (5) semi-annual
compliance reports. (6) other reports,
and (7) annual compliance
certifications. These reports are briefly
described below.
1. Initial Notification
Each owner or operator of an affected
source must submit an initial
notification to the Administrator within
120 days after promulgation of the rule.
This initial notification must contain an
identification of the facility that is
subject to the regulation, the name and
address of the owner or operator of the
subject facility, and a brief description
of the production process.
2. Application for Approval of
Construction or Reconstruction
Owners or operators constmcting a
new affected source, or reconstructing
an existing affected source, must submit
an application for approval of
construction or reconstruction. This
application must contain identification
information such as location, owner/
operator, and the anticipated
completion and start-up dates. The
application must also contain a
description of the planned process and
how compliance will be achieved. The
application must be submitted as soon
as practicable before the construction or
reconstruction is planned to commence.
A permit application can take tbe place
of this report.
3. Precompliance Report
One year before the compliance date.
each existing owner or operator of an
existing slabstock facility must submit a
precompliance report. This report must
contain notification of whether
compliance will be achieved using the
emission point specific HAP ABA and
equipment cleaning emission limitation
or the source wide emission limitation.
The report must also indicate if either
of the following compliance options are
going to be utilized:
• If compliance will be achieved on a
monthly basis for either the emission
point specific limitation for HAP ABA
emissions from the production line or
the source wide emission limitation.
• If a recovery device will be used to
reduce HAP ABA emissions.
This report must also contain a
description of how the amount of polyol
and HAP ABA (If required) added at the
mixhead will be monitored. If the owner
or operator is developing an alternative
monitoring plan, the plan must be
submitted with the precompliance
report. In addition, owners or operators
of slabstock flexible polyurethane
production facilities using a recovery
device to reduce HAP ABA emissions
must include a description of the HAP
ABA monitoring and recordkeeping
program to determine the amount of
HAP ABA recovered in the
precompliance report.
Each owner or operator of an affected
source complying with the source wide
emission limitation must submit a
description of how the amount of HAP
ABA in a storage vessel will be
determined, and a description of how
the amount of HAP ABA added to a
storage vessel during a delivery will be
monitored. If the owner or operator is
developing an alternative monitoring
program for the determination of HAP
ABA added to a storage vessel, this
program must be submitted witli the
precompliance report.
The rule specifies that if the
Administrator does not notify the owner
or operator of objections to an
alternative monitoring program or a
recovered HAP ABA monitoring and
recordkeeping program within 45 days
after its receipt, the program is
automatically assumed to be approved.
4. Notification of Compliance Status
Each owner or operator of a new or
existing slabstock affected source must
submit a notification of compliance
status report 180 days after the
compliance date. This report must
contain notification of the compliance
status of diisocyanate storage vessels
and diisocyanate transfer pumps. In
addition, this report must contain
compliance information for HAP ABA
storage vessels and equipment in HAP
ABA service.
5. Semi annual Reports
Each slabstock owner or operator
must submit semi-annual reports. For
affected sources complying with the
rolling annual compliance provisions
(for either the emission point specific
. HAP ABA limitations or the source
wide emission limitation), the report
must contain the allowable and actual
HAP ABA emissions (or allowable and
actual HAP ABA and equipment
cleaning HAP emissions) for each of the
12 month periods ending on each of the
six months in the reporting period. For
affected sources complying with the
monthly compliance alternative, the
report must contain the allowable and
actual HAP ABA emissions (or
allowable and actual HAP ABA and
equipment cleaning HAP emissions) for
each of the six months in the reporting
period. Affected sources complying
with the storage vessel provisions of
§63.1294(a) or §63.1295 using a carbon
adsorption system must include
unloading events that occur after
breakthrough is detected where the
carbon in the system is not replaced.
Any equipment leaks that were not
repaired in accordance with the rule
requirements must also be included in
the semi annual compliance report.
6. Other Reports
A slabstock owner or operator must
provide a report to the Administrator
indicating the intent to change the
selected compliance alternative
(emission point specific limitations or
source-wide emission limitation). This
report must be submitted at least 180
days prior to the change.
Similarly, the intent to switch the
compliance method (rolling annual or
monthly) must be reported. This report
must be submitted at least 180 days
prior to the change.
7. Annual Compliance Certifications
Each affected source is required to
submit, a compliance certification
annually. Each compliance certification
must be signed by a responsible official
of the company that owns or operates
the affected source.
./. Rerordkeeping Requirements
Records must be completed in a form
suitable and readily available for
expeditious inspection and review, and
must be kept for a period of 5 years. At
a minimum, the most recent 2 years of
data must be retained on-site.
Records are required for storage
vessels, equipment leaks, and HAP
ABA. If the owner or operator complies
with the source wide emission
limitation, no records are required for
HAP ABA storage vessel controls (see
section "I.J.I" below) or controls for
equipment in HAP ABA service (see
section "1.J.2" below).
1. Storage Vessel Records
All slabstock affected sources must
maintain records listing all diisocyanate
storage vessels and the type of control
utilized to comply with the regulation.
For the storage vessels complying
through the use of a carbon adsorption
system, the records must include the
design parameters of the system and the
monitoring records.
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53988 Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
2. Equipment Leak Records
All slabstock affected sources must
maintain a list of components in
diisocyanate service, and a description
of the control utilized for each transfer
pump. If the affected source is
complying with the emission point
specific limitations, records listing each
component in HAP ABA service must
also be maintained.
When a leak, as defined in the rule,
is detected for any component, the
component must be marked with a
readily visible identification until the
leak is repaired. For valves, the
identification must remain until 2
successive quarters have passed where
no leak is detected. Records must be
kept specifying when the leak was
detected, when it was repaired, and
when the identification was removed.
3. HAP ABA records
All slabstock affected sources must
keep records integral to the calculation
of allowable emissions. These include a
daily log of foam runs and daily records
of the amount of polyol added at the
mixbead for each grade of foam. The
results of the density and IFD testing for
each grado must be recorded wi'hin 10
working days of the production of the
foam. Polyol usage and densitvIFD
testing records are not required for those
foam graJes for which the owner or
operator has designated the HAP ABA
formulation limitation as zero. Monthly.
a cumulative record must be maintained
listing the foam grades containing HAP
ABA produced during the month, along
with the total amount of polyol used for
each foam grade, and the corresponding
allowable HAP ABA !or HAP ABA and
equipment cleaning) emissions level. If
complying on an annual rolling basis.
the allowable HAP ABA (or HAP ABA
and equipment cleaning) emissions
level for the previous 12 consecutive
months must also be recorded each
month.
For affected sources complying with
the emission point specific limitation
for HAP ABA emissions from the
production line, records must be kept
regarding the amount of HAP ABA
added at the mixhead each day. In
addition, there must also be a
cumulative HAP ABA usage record for
each month, and a cumulative record for
the previous 12 consecutive months (if
complying on an annual rolling basis).
For affected sources complying with
the source-wide emission limitation.
monthly records must be kept regarding
the actual HAP ABA and equipment
cleaning emissions, as measured at the
storage vessel. Also required are weekly
records of the HAP ABA storage vessel.
levels and records of the amount of HAP
ABA added to die storage vessel during
each delivery. If complying on an
annual rolling basis, monthly records
must be kept of the actual cumulative
HAP ABA and equipment cleaning
emissions for the previous 12 months.
If an affected source uses a recovery
device to reduce HAP ABA emissions.
records must be kept regarding the
amount of HAP ABA recovered. In
addition, records of all required
calibrations must be maintained.
III. Summary of Impacts
This section identifies the facilities
affected by these NESHAP. It also
presents the air. non-air environtnental
(waste and solid waste), energy, cost.
and economic impacts resulting from
the control of HAP emissions under this
rule.
A. Facilities Affected by These NESHAP
It is estimated tbat 176 sources will be
subject to the regulation. This number
includes 57 slabstock foam facilities. 21
facilities with slabstock and rebond
processes, and 98 molded foam
facilities. It is estimated that 130
molded foam facilities are area sources.
and will not be subject to this rule. It is
also estimated that all rebond facilities
not collocated with a slabstock foam
process are area sources.
B. Air Impacts
These standards are estimated to
reduce HAP emissions from all existing
sources of flexible polyurethane foam
manufacturing by over 12.500 Mg/yr.
This represents a 70 percent reduction
from baseline. This includes over 10.400
Mg/yr from slabstock foam production
(69 percent reduction from baseline)
and over 2.100 Mg/yr from molded foam
production (73 percent reduction from
baseline). No reduction is expected from
rebond foam production, 'since it is
believed that the entire industry has
already stopped using HAP cleaners and
mold release agents.
C. Other Environmental Impacts
The Agency estimates that there will
be minimal secondary environmental
impacts from this regulation. There
could be a slight increase in volatile
organic compound (VOC) air emissions
if facilities switch from a HAP based
product to a non HAP VOC based
product for equipment cleaning, mold
release agents, and mixhead flushes.
Wastewater could contain minor
amounts of HAP if carbon adsorption
systems are used to comply with the
HAP ABA limitations, but the Agency
believes the use of such systems will be
rare. The only potential hazardous
waste impact would be due to the
disposal of spent carbon adsorption
canisters used to control storage vessels.
The Agency does not believe these
impacts to be significant.
D. Energy Impacts
Due to the use of several control
technologies in both slabstock and
molded foam, there will be some
increase in the amount of energy used
by this source category. The impact will
vary depending on which control
technology is chosen by each facility.
but is not expected to be significant.
E. Cost Impacts
Cost impacts include the capital costs
of new equipment that reduces HAP
emissions, the cost of energy required to
operate the equipment, operation and
maintenance costs, as well as cost
savings. Also, cost impacts include the
costs of monitoring, recordkeeping. and
reporting associated with the
promulgated standards. Average cost
effectiveness ($/Mg of pollutant
removed) is also presented as part of
cost impacts and is determined by
dividing the annual cost by the annual
emission reduction.
For the molded subcategory. the
estimated total capital investment is
$5.9 million, and the total estimated
annual cost is around $715.000 per year.
The total annual HAP emission
reduction is 2.100 Mg/year. resulting in
a cost effectiveness of $350/Mg pet year.
For the rebond subcategory. it is
anticipated that there will be no cost or
environmental impacts, since it is
believed that every facility already
complies with these provisions. Thi
regulation will prohibit the future use of
HAP based cleaners and mold release
agents in this industry.
For the slabstock subcategory. the
total estimated capital investment is
around $68 million, and the total
estimated annual cost is $7.3 million
per year. The total annual HAP emission
reduction is over 10.400 Mg/yr.
resulting in a cost effectiveness of
around $700/Mg per year.
Therefore, the total capital investment
for this regulation is estimated at $74
million. The total estimated annual cost
is $8.1 million per year. The total
emission reduction is over. 12.500
Mg/yr. resulting in an overall cost
effectiveness of around $650/Mg per
.year.
F. Economic Impacts
An economic impact analysis of these
standards was prepared to evaluate
primary7 and secondary impacts on: (1)
the slabstock and molded foam sectors
of the flexible polyurethane foam
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Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations 53989
production industry: (2) consumers: and
(3) society.
For the slabstock foam sector of the
industry, the total annualized social cost
(in 1994 dollars) of this promulgated
regulation is $7.18 million. Market price
is estimated to increase by 2.20 percent.
and the corresponding decrease in
market output is estimated to be 1.08
percent! Employment loss is estimated
to be 1.09 percent (i.e., 96 jobs).
For the molded foam sector, impacts
on price and output are estimated to be
smaller than those predicted for the
slabstock market. The total annualized
social cost (in 1994 dollars) of the
promulgated standards fo- the molded
foam subcategory is $0.71 million. Price
is estimated to increase by 1.14 percent.
and the corresponding decrease in
market output is estimated to be 0.56
percent. Employment loss in the molded
sector is estimated to be 0.67 percent (37
jobs).
However, given the predicted changes
in market price and output, the industry
will experience increases in the value of
shipments (i.e.. industry profits).
because estimated price increases more
than offset the lower production
volumes. Since no significant export or
import markets exist for the industry
(due to prohibitive transportation costs).
no impacts on foreign trade are
expected.
The analysis also predicts the number
of plant closures that may result from
the imposition of compliance costs on a
facility. For the analysis, a worst.-case
assumption is adopted that the facilities
with the highest emission control costs
are the least efficient producers in the
market. Actual plant closures will be
less than that predicted if plants with
the highest emission control costs are
not the least efficient producers in the
industry. In addition, the outcome of
predicted closures is sensitive to the
wide variety of emission control
technologies assigned to the model
plants. If the control technology
assigned to the representative model
plant is different than that which would
be chosen by an actual facility, the
analysis could overestimate the number
of predicted plant closures. Therefore, a
sensitivity analysis was performed to
test the outcome of closures based on
the assignment of control technology to
model plants. For the slabstock sector.
plant closures are estimated to range
from 1 to 3 facilities for this standard.
For the molded foam sector, closures are
estimated to be zero for this
promulgated standard (a sensitivity
analysis was not performed for the
molded foam production subcategory).
Given the significant amount of
restructuring currently occurring in the
industry (mergers, buy-outs, and shut-
downs), the number of facility closures
that will result from the regulation is
likely to be minimal.
IV. Significant Comments and Changes
to the Proposed Standards
In response to comments received on
the proposed standards, changes have
been made to the final standards. While
several of these changes are
clarifications designed td make the
EPA's intent clearer, a number of them
are changes to the requirements of the
proposed standards. Public comment
was received on several issues that the
EPA raised in the proposal preamble.
The public also commented on other
issues. In addition, some changes were
made to ensure that the regulations are
"permit friendly." A summary of the
substantive comments and changes
made since the proposal are described
in the following sections. The rationale
for these changes and detailed responses
to all public comments are included in
the Basis and Purpose Document for the
final standards. Additional information
is contained in the docket for these final
standards. (See ADDRESSES section of
this preamble.)
A. Public Response w EPA Request for
Cammeni
In the proposal preamble, the EPA
specifically requested comment on the
following issues: (1) the need for a
federally enforceable mechanism for
limiting potential to emit (PTE) at
flexible polyurethane foam production
sources: (2) controlling TD1 emissions
from slabstock flexible foam production
lines: (3) the burdens of the monthly
averaging time option for compliance
with the emission limitation for
slabstock flexible foam production lines:
(4) monitoring in HAP ABA storage
vessels: (5) the prohibition on the use of
HAP-based adhesives: and (6) the
number of affected facilities. No public
comments were received on the number
of affected facilities in the flexible
polyurethane foam production source
category. Public comments on the
remaining five issues are summarized
below.
1. Federally Enforceable Meciianism
The proposed regulation contained
provisions for obtaining a federally
enforceable limitation on PTE. which
would allow sources to maintain
emissions below the major source
threshold amount. It also included
recordkeeping and reporting
requirements for sources obtaining the
federally enforceable emission
limitation. One commenter urged the
EPA to identify the criteria for
establishing area source status, while
others objected to the requirements that
an area source maintain supporting
documentation, stating that facilities
should not be required to keep records
to prove they are not subject to the
regulation.
The FPA agrees that criteria for area
source status should be included within
the regulation, rather than the general
criteria In the proposed rule. Therefore.
§ 63.1290(c) has been revised to add
specific criteria for identifying slabstock
sources with potential emissions below
the major source threshold levels.
Slabstock flexible polyurethane foam
producers may elect to use a total of less
than 5 tons of total HAP at the entire
plant site, including uses as an auxiliary
blowing agent, an equipment cleaner.
and as an adhesive in foam fabrication
operations. The addition of these
specific.criteria will ease the
administrative burden for both State and
local agency regulators and sources by
reducing the need for case by cast?
determination of area or synthetic minor
source status. This option is not
available to slabstock processes located
at plant sites that have HAP using
processes other than slabstock foam
production and foam fabrication. Also.
due to the large number of potential
uses of HAP at molded foam facilities.
such criteria are not included fot
molded foam facilities.
The Agency agrees with the
commenters that recordkeeping
requirements should be sufficiently
detailed to ensure that PTE limits ate
practically enforceable: however, the
EPA recognizes that State and local
agencies should establish such
recordkeeping requirements. In the
consideration of these comments, the
EPA determined that it is not
appropriate for the rule to requite
specific records at facilities that are not
subject to the regulation. Therefore. th<-
rule only requires that records he kept
to verify the HAP usage.
2. TDI emissions from Slabstock
Production I ines
The proposed rule did not require
control of 2.4 toluene diisocyanate (TDI)
emissions from the foam product ioti
line. At proposal, the EPA requested
comment on the feasibility and
necessity of additional controls for TDI
emissions from the foam line.
Four commenters responded to ihe
EPA's request for comments on this
item. Three of the commenters
supported the EPA in proposing no
control for TDI emissions from the foam
production line. All three commenters
noted that TDI emissions from foam
production are very small. Two of these
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55990 Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
commenters also indicated the lack of
currently available control technologies
to address these emissions and the high
costs of utilizing technologies that are
common in other applications.
However, one commenter believed
additional controls for TDI were needed.
This commenter urged the EPA to assess
applicable work practices or equipment
standards that would reduce TDI and
other emissions from the production
line and other emission points not
covered under the current rule.
The EPA agrees with the three
commenters who believe that the
regulation should not control TDI
emissions from the production line. The
primary reasons for this opinion are the
low level of emissions and the high
costs of control. The EPA recognizes the
concerns related to the health effects of
TDI. even at relatively low
concentrations. However, nationwide
TDI emissions from the foam tunnel at
slabstock polyurethane foam production
facilities are estimated to be less than 10
tons per year. A tvpical plant emits
around ] '10 of a ton per year. In
addition. TDI is present in exhaust
streams in very low concentrations.
typically less than 1 part per million
(ppmV Currently available control
technologies common to other
applications are not suited to the cost
effective removal of lo\v concentrations
of TDI from a high velocity exhaust
stream.
Prior to proposal, the FPA determined
that the floor for the control of TDi \\as
no control. Further, no controls
techniques were identified in practice to
allow the consideration of levels mote
stringent than the floor. After proposal.
the FPA re-investigated technologies for
the control of TDI emissions from the
foam production line by contacting
vendors of control equipment, as well as
air pollution regulatory agencies in
other countries. Based on that
additional analysis, the FPA concludes
that the MACT floor is no control.
Despite indications of the existence of
cost effective TDI control technologies.
none of these efforts identified am
technology for TDI that the Agency
believed could be cost effectively
applied to the foam tunnel in a
slahstock foam production facility.
In the future, the F.PA will conduct a
section 112(f) residual risk assessment
of the flexible polyurethane foam
industry. In a section 112(f) residual risk
assessment, a regulated industry is
evaluated based on the risks it still
poses to people and the environment. If
the assessment determines that
unacceptable health risks are still
related to the industiy. the EPA will
impose additional requirements on the
industry.
The EPA does not feel it is
appropriate to require additional
recordkeeping or reporting in this rule
to support a future risk assessment, as
suggested by the commenter. The EPA
will obtain the necessary information at
the time of the risk assessment.
3. Monthly Averaging Time
Tlie proposed rule allowed for two
averaging time formats for compliance
with the requirements for HAP ABA
emissions from the production line and
source-wide HAP ABA and equipment
cleaning emissions: (1) rolling annual
compliance |§63.1297(a)(l)l: and (2)
compliance determined for each
individual month. [§G3.1297(a)(2)l At
proposal, the EPA requested comments
on any burdens caused by inclusion of
the monthly compliance alternative in
the proposed regulation.
Two commenters responded to the
EPA's request for comments on this
item. Neither commenter reported any
burdens associated with inclusion of the
monthly compliance alternative.
However, both commenters were
concerned about the potential for being
assessed penalties based on 365 days of
violations when using the rolling annual
compliance alternative, even if the
actual number of non compliance days
was much less.
In response to the seasonal variation
of the production of slabstock foam, the
EPA based the proposed HAP ABA
emission requirements on a 12 month
period, where compliance would be
determined each month for the previous
12 months. While industry recogni7ed
the flexibility of this 12 month
averaging period, they were concerned
regarding the enforcement of such
provisions. The concerns expressed at
that time were analogous to those made
by these commenters.
In response to these concerns, the
EPA included the monthly compliance
alternative in the proposed regulation.
This alternative, while reducing
flexibility, eliminates the potential for
violations for a 365 day period. Since no
comments were received indicating that
the inclusion of two averaging time
options was inappropriate or
burdensome to either affected sources or
enforcement agencies, both averaging
periods were retained in the final ruje.
In response to the commenters'
concern about penalties associated with
the 12 month averaging option, the EPA
points out that the rule cannot specify
a penalty structure, but can only include
the definition of a violation. Clearly, a
violation of the HAP ABA (or source-
. wide) requirements of this rule occurs
when the actual emissions exceed the
allowable emissions. In the case of a
violation, the State or local enforcement
agency (and in some cases the EPA
Regional Office) will determine the
penalty for a violation.
In conclusion, the commenters
continue to be concerned with the
potential penalties associated with the
12 month averaging time. The EPA
continues to believe that the monthly
averaging time is a viable alternative
available to all affected sources, and that
each ow-ner or operator will have to
weigh the added flexibility of the 12-
month averaging period with the
potential for higher penalties associated
with this option.
4. Monitoring in HAP ABA Storage
Vessels
If a facility is complying with the
source wide alternative for HAP ABA
and HAP equipment cleaners, actual
emissions are measured by conducting a
monthly material balance at the HAP
ABA storage vessel. An input to this
determination is the amount of HAP
ABA in the storage tank. The proposed
rule at §63.1303(d) contained criteria
for the devices that could be used to •
measure the level of HAP ABA in the
vessel. Gauge glasses and simple floats
would not have fit these criteria. At
proposal, the EPA requested comment
on the monitoring requirements and
whether the use of gauge glasses, float
systems, and other visually read
systems should be allowed.
^ All the commenters that provided
input on this issue felt that visually read
level measurement systems, which are
"standard" in the industiy. should be
allowed. They believed that visually
read measurement systems were
sufficiently accurate, and that the
competitive nature of the industry
dictated that facilities eliminate raw
material loss. Due to the need to manage
chemical use. visually read level
measurement systems in conjunction
with existing inventory7 controls provide
necessary compliance records.
Upon reviewing these comments and
collecting additional information on this
issue by conducting a survey of storage
tank level measurement device vendors.
contacting foam trade organizations and
foam producers, and visiting a foam
plant and observing first hand the use
: of visually read level measurement
devices to determine the storage tank
level, the EPA agreed that these
visually read devices should be
allowed. The EPA now believes that the
use of gauge glasses and float systems
will not result in significantly greater
errors in level measurement than
devices that meet the proposed
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Federal Register/Vol. 63, No. 194/Wednesday. October 7, 1998/Rules and Regulations 53991
requirements. For example, an error
analysis based on typical 10.000 gallon
storage vessels and an error in
measurement of 0.5 inches indicates
that the error is approximately 3.27
cubic feet or 24.5 gallons (0.5 percent)
for a vertical tank at half capacity. For
horizontal tanks at half capacity, the
error is approximately 8.8 cubic feet or
65.8 gallons (1.3 percent). In order to
minimize the potential for human error.
the final rule requires that all visually-
read measurement devices have
permanent graduated markings from
which the level will be read. This
practice should eliminate any error
associated with the use of non-fixed
measuring tools, such as tapes or rulers.
Therefore, in the final rule, paragraph
G3.1303(d) requires that devices that are
used to measure the level in the storage
vessel be calibrated initially and at least
. once per year. If the device produces an
output signal, it must have either a
digital or printed output, if the device
is a visually-read device, it must have
permanent graduated markings.
5. Prohibition on the Use of HAP based
Adhesives
The EPA requested comment on the
technical feasibility of prohibiting the
use of HAP-based adhesives for foam
repair in molded foam production. Two
responses to this request were received.
The first cammenter reported that HAP
free adhesives have not been successful
in all applications. The commenter
recommended a review process that
would allow a facility to use HAP based
mold release agents if they
demonstrated that product quality
suffered with the use of HAP-free
adhesives. The second commenter was
also concerned about the proposed
prohibition, and recommended that the
EPA defer consideration of HAP-based
adhesives until development of the
foam fabrication NESHAP.
The EPA acknowledges the
commenters' concern that HAP free
adhesives may not be successful in all
applications. In further conversations
after proposal of the regulations.
adhesive manufacturers indicated that
the molded foam production source
category was not a major market for
their products. The EPA therefore agrees
with the second commenter that
consideration of HAP based adhesives
should be deferred until development of
the foam fabrication NESHAP. The
proposed provisions at 63.1300(c)
prohibiting the use of HAP based
adhesives to repair foam products in a
molded flexible polyurethane foam
source have been removed. The Agency
expects to consider use of HAP based
molded foam repair adhesives in the
development of the flexible
polyurethane foam fabrication NESHAP.
0. Orher Rule Changes in Response to
Public Comments
1. IFD and Density Testing
The proposed rule required that the
indentation force deflection (IFD) and
density be tested for every grade of foam
produced. It also required that the
amount of polyol used be monitored for
every foam grade, and that records of
this usage be maintained. A comment
was received stating that there was no
benefit to testing foams or monitoring
and keeping records of the amount of
polyol added for grades that do not have
any ABA in the formulation.
For each specific grade, the allowable
emissions are calculated using the
formulation limitation (which is
calculated using the IFD and density of
the grade) and the amount of polyol
used to produce the grade. The
calculation of the allowable HAP ABA
emissions is unrelated to the amount of
HAP ABA added to the formulation for
that grade. The amount of HAP ABA
added represents the actual emissions.
Therefore, if a facility produced a
particular grade (e.g.. Grade A) with a
formulation limitation greater than zero.
but used no HAP ABA. then emission
"credits" would be generated. This
"credit" would then allow the owner or
operator to use an amount of HAP ABA
higher than the formulation limitation
for another grade (e.g.. Grade B). If no
testing of the grade, or records of polyol
used, were kept for Grade A. then
credits would not be generated to allow
the production of Grade B with the
desired amount. Therefore, the F.PA sees
considerable benefit in testing and
keeping records for all grades that have
formulation limitations greater than
zero.
However, the F.PA does believe that
the burden can be reduced by
eliminating the requirement that any
IFD or density testing be conducted for
grades where the owner or operator
designates the formulation limitation as
zero. This decision is reflected in the
final rule.
2. Definition of Flexible
One comment was received regarding
the adjective "flexible" in the term
"flexible polyurethane foam". The
commenter (1V-D-07) noted that while
"flexible polyurethane foam" is defined
in the rule, the definition did not
address "the degree of flexibility or
rigidity associated with the foam." The
commenter believed that their "foam in
place" operation is intended to be
included within the scope of the
proposed rule. However, the foam.
which is sprayed into boxes to provide
a protective cushioning layer for
shipment of products, is "quite rigid in
nature". The commenter requested
clarification regarding the meaning of
flexible.
The EPA agrees that there is a need to
clarify "flexible" as it is used in the
definition of flexible polyurethane foam.
and has added language to the
definition provided in the rule, as
follows:
" Flexible polyurethane foam means a
flexible cellular polymer containing
urea and carbamate linkages in the
chain backbone produced by reacting a
diisocyanate, polyol, and water. Flexible
polyurethane foams are open-celled,
permit the passage of air through the
foam, and possess the strength and
flexibility to allow repeated distortion
or compression under stress with
essentiaHy complete recovery upon
removal of the stress."
By comparison, rigid polyurethane
foams are closed celled, do not allow
the passage of air through the foam, and
do not distort or compress under stress
until there is sufficient stress to crush
the foam. Rigid foams that have been
crushed do not. recover to their original
shape.
Based on information provided by the
commenter, the EPA is unable to
definitively determine if the foam
produced is flexible polyurethane foam
and if the commenter's process is
subject to the rule. However, it is
believed that the "foam in place"
process described is a molded foam
process and would be subject to the
rule, if the foam produced meets the
revised definition of flexible
polyurethane foam cited above.
3. HAP ABA Emission Calculation
One commenter noted that there was
a typographical error in the equation as
published in the preamble. The first
term should appear as "-25QFD)." Two
commenters noted that the HAP ABA
formulation equation results in a
negative (<0) value for the ABA
limitation in some cases. One
commenter felt that this was a result of
a typing error in the published equation.
The second commenter was concerned
that it would be "possible for certain
foam grades to calculate a negative
monthly ABA. thus reducing the total
ABA and misrepresenting the intent of
the ABA formulation limitation
equation." This commenter
recommended that the minimum
amount of ABA be limited to zero (0) for
averaging purposes
The EPA recognizes that there w as a
typographical error in the equation as
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53992 Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
published in the preamble. The first
term in the equation 25(1FD) should be
preceded by a negative sign. The
proposed regulatory language was
correct. The final rule and the rule
summary in the preamble for the
promulgated regulation include the
correct equation.
However, the commenter was
incorrect in assuming that an error in
the published equation resulted in the
equation yielding negative values. The
equation indeed results in negative
values for some combinations of density
and indentation force deflection (IFD).
The EPA did not intend for these
negative values to be used in calculating
allowable emissions. Rather, the intent
was for the foam manufacturer to use
zero if the calculated HAP ABA
formulation limitation was negative.
However, the proposed regulation did
not state this intention, and the Agency
recognizes that this situation would
clearly lead to confusion. Therefore, in
accordance with the commemer's
suggestion, the EPA has revised the
regulation to clearly state that zero shall
be the formulation limitation if the
results of the formulation limitation
equation are negative A new table has
been added to §G3.1297(dj(2) to clarify
the new source formulation limitation
requirements.
4. State Delegation
One comment was received
requesting clarification as to what
authorities, if any. have been delegateci
to States. The commenter reported thai
in soinp instances, the F.PA has
specified within given Pan 63 standards
that certain authorities were not to be
delegated to States
The proposal regulation was silent on
the implementation and enforcement
authorities that may be delegated to
States. The EPA agrees that the
regulations should specify which
authorities are and are not delegated to
State and local permitting authorities.
§63.1308 has been added to the
regulations to identify these authorities.
The new provisions clarify that the
authority to approve alternative
monitoring plans and emission
limitations shall be retained by the EPA
Administrator and not transferred to a
State or local permitting authority. The
Administrator must approve alternative
programs required in §63.1303(b)(5) for
monitoring HAP ABA and polyol added
to the foam production line at the
mixhead. Alternative emission
limitations allowed under §63.1305(d)
must also be approved by the
Administrator. These requirements are
in keeping with longstanding EPA
policy that emission limits to satisfy
Clean Air Act requirements for
protecting the public health, as well as
the monitoring to demonstrate
compliance with those limits, must be
determined by the Administrator.
C. Other Changes to the Proposed
Regulation
In addition to the changes in response
to public comments discussed above,
changes to the proposed rule have been
made to clarify the requirements of the
regulations. These changes do not add
emission standards or requirements to
the regulation. In general, they specify
aspects of the regulations that were not
included in sufficient detail in the
proposed rule. The effect of these
changes will be to assure compliance
with the standards while providing
flexibility and regulatory certainty for
affected sources, as well as for
permitting and enforcement agencies.
The changes are related to a test method
for carbon adsorption and a continuous
compliance demonstration.
The proposed rule required
monitoring of HAP or organic
compounds from storage vessel carbon
adsorption systems to determine
breakthrough. However, the rule did not
indicate the test method to use if the
owner or operator elected to monitor
organic compound concentration.
Section 63.1303(aj(4) now specifies the
use of Method 25A for measuring '
organic emissions from carbon
adsorption systems. This change
clarifies the compliance requirements
for carbon adsorption system use.
The regulation has been revised to
clarify what constitutes compliance
with the nile. No new emission
standards or work practice requirements
have been added to the regulations.
While the compliance requirements
could be inferred from the proposed
regulation, the final rule now directly
states the specific actions needed and
the records required to demonstrate
compliance, absent credible evidence to
the contrary. These changes will ensure
compliance to protect the public health.
ensure the practical enforceability of the
standards, identify the permit terms and
conditions implementing the standards.
and provide regulatory clarity for
affected sources. They are in keeping
with the Agency's priorities for
streamlining the regulatory process and
minimizing the burden on affected
sources by clearly defining compliance
terms.
Section 63.1308 summarizes what
indicates compliance with the standards
in §63.1293 63.1301. absent credible
evidence to the contrary, as well as what
constitutes a violation of the standard.
(or each requirement in the rule. Facility
owners will not have to speculate on
how compliance with a particular
requirement may be interpreted. For
regulating agencies, these provisions
identify the terms and conditions that
could be included in the permit. The
provisions thus increase regulatory
certainty, minimize the amount of time
spent developing and reviewing permit
terms, and ensure enforceability.
The provisions of §§63.1306"(g) and
63.1308 do not. and are not intended to.
alter or affect the requirements of 40
CFR part 70 for the purposes of
addressing the requirements of this
subpart. or any applicable requirements.
in part 70 permits. Sources required to
have a Title V operating permit musi
submit annual compliance certifications
consistent with § 70.6(c)(5) applicable to
all permit terms and conditions, which
include applicable requirements such as
subpart III. The certification
requirements of part 70 require a
statement frotn part 70 sources that.
based on information and belief formed
after reasonable inquiry, the statmenfs
and information in certifications--'
including annual compliance
certifications--are true, accurate, and
complete (40 CFR 70.5(d) and 71.5(d}).
While a pan 70 compliance certification
may be used to satisfy the requirements
of §63.1306 (g) (see §63.1306(g)(2)) the
annual compliance certification
required by §63.1306(g) may not be
used to satisfy the compliance
certification requirements of part 70. for
purposes of part 70 permits that include
subpart III as an applicable requirement.
In addition to the clarifying changes
noted above, the EPA has removed the
requirement that each facility develop.
maintain, and implement'a startup.
shutdown, and malfunction plan.
The General Provisions include the
requirements for a startup, shutdown.
and malfunction plan in §63.6(e)(3). A
table of the proposed rule indicated that
the provisions of § 63.6 were applicable
to flexible polyurethane foam
production affected sources. In the
exercise of improving the clarity of the
rule, the EPA decided that it would be
more apparent to affected sources if the
provisions related to the startup.
shutdown, and malfunction were
included in this rule, rather than simply
referring to subpart A. However, in
adding these provisions, the EPA
concluded that they were not
appropriate for the flexible
polyurethane foam production industry.
Therefore, the final rule has removed
the requirement that flexible
polyurethane foam affected sources
create and implement a startup.
shutdown, and malfunction plan. This
is indicated by a "NO" in the General
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Federal Register/Vol. 63, No. 194/Wednesday. October 7, 1998/Rules and Regulations 53993
Provisions table (Table 2) of the final
rule for §63.6(e)(3). The rationale for
this conclusion is briefly discussed
below.
The fundamental problem in applying
the General Provisions startup.
shutdown, and malfunction provisions
to flexible polyurethane foam
production facilities is defining a
startup and a shutdown. The foam
production process is intermittant in
nature and. based on the EPA's
knowledge of the industry, every foam
production process will undergo at least
one routine "startup" and one routine
"shutdown" per day. The EPA never
intended that these routine activities be
addressed by the startup, shutdown, and
malfunction plan.
The intent of the startup, shutdown.
and malfunction plan is to identify
methods to reduce excess emissions that
may occur during these events when air
pollution is emitted in quantities greater
than anticipated by the standard. Given
the comprehensive approach of subpart
III to regulate emissions by restricting
the amount of HAP used, the F.PA does
not believe that, for foam production
facilities, startups, shutdowns, or
malfunctions provide the opportunity
for excess emissions noi already
anticipated in the regulation. Finally, as
discussed in section I.A. two of the HAP
used and potentially emitted during
malfunctions by the flexible
polyurethane foam industry (2.4-toluene
diisocyanate and propylene oxide) are
subject to the risk management program
rule requirements under section 112(r)
of the 1990 Clean Air Act Amendments.
V. Administrative Requirements
A. Docker
A record has been established for this
rulemaking under docket number A 9:1
48. The record includes printed, paper
versions of comments and data
submitted electronically. A public
version of this record, which does not
include any information included as
CBI, is available for inspection from
8:00 a.m. to 5:30 p.m. Monday Friday.
excluding legal holidays. The public
record is located in the Air ft Radiation
Docket & Information Center. Room
Ml500. 401 M Street SVV. Washington.
DC 20460.
Response to Comment Document. The
response to comment document for the
promulgated standards contains: (1) A
summary of the public comments made
on the proposed standards and the
Administrator's response to the
comments: and (2) a summary of the
changes made to the standards since
proposal. The document may be
obtained from the U.S. F.PA Library
(MD-35). Research Triangle Park. Nordi
Carolina 27711. telephone (919) 541-
2777. It may also be obtained from the
National Technical Information
Services. 5285 Port Royal Road,
Springfield. Virginia 22151. telephone
(703) 487-4650. Please refer to
"Hazardous Air Pollutant Emissions
from the Flexible Polyurethane Foam
Production Industry—Basis and Purpose
Document for Final Standards.
Summary of Public Comments and
Responses" {EPA-453/R-97-008b.
December 1997). This document is also
located in the docket (Docket Item No.
V-B-1) and is available for
downloading from the Technology
Transfer Network (TTN). The TTN is
one of the EPA's electronic bulletin
boards. The TTN provides information
and technology exchange in various
areas of air pollution control. The
service is free except for the cost of a
phone call. Dial (919) 541-5742 for up
to a 14,400 bps modem, or connect
through the internet to the following
address: "www.epa.gov/ttn/oarpg". If
more information on the Technology
Transfer Network is needed, call the
HELP line at (919) 541-5384.
Previous Background Documents.
Other materials related to this
rulemaking are available for review in
the docket. The Basis and Purpose
Document, which contains the rationale
for the various components of the
standard, is available in the docket and
on the TTN. This document is entitled
"Hazardous Air Pollutant Emissions
from the Production of Flexible
Polyurethane Foam -Basis and Purpose
Document for Proposed Standards."
September 1996. and has been assigned
document number EPA-453/D-9S-
OOSa.
Some of the technical memoranda
have been compiled into a single
document, the Supplementary
Information Document (SID), to allow
interested parties more convenient
access to the information. The SID is
available in the docket (Docket No. A-
95-48 Category Hl-B). and. in limited
supply, from the EPA Library by calling
(919) 541-2777. The document is
entitled Hazardous Air Pollutant
Emissions from the Production of
Flexible Polyurethane Foam
Supplementary Information Document
for Proposed Standards. October 1996.
and has been assigned document
number EPA-453/D-96-009a.
B. Executive Order 12866
Under Executive Order 12866 (58 FR
5173. October 4. 1993). the EPA must
determine whether the regulatory action
is "significant" and therefore subject to
Office of Management and Budget
(OMB) review and the requirements of
die Executive Order. The Executive
Order defines "significant regulatory
action" as one that is likely to result in
standards that may:
(1) Have an annual effect on the
economy of $100 million or more or
adversely affect in a material way. the
economy, a sector of the economy.
productivity, competition, jobs, the
environment, public health or safety, or
State, local, or tribal governments or
communities;
(2) Create a serious inconsistency or
otherwise interfere with an action taken
or planned by another agency:
(3) Materially alter the budgetary
impact of entidement. grants, user fees.
or loan programs or the rights and
obligations of recipients thereof; or
(4) Raise novel legal or policy issues
arising out of legal mandates, the
President's priorities, or the principles
set forth in the Executive Order.
It has been determined that this rule
is not a "significant regulatory action"
under the terms of Executive Order
12866 and is therefore not subject to
OMB review.
C. Applicability of Executive Order
13045
Executive Order 13045. entitled
"Protection of Children from
Environmental Health Risks and Safety
Risks" (62 FR 19885. April 23. 1997).
applies to any rule that the F.PA
determines (i) is "economically
significant." as defined under Executive
Order 12866. and (2) the environmental
health or safety risk addressed by the
rule has a disproportionate effect on
children. If the regulatory action meets
both criteria, the Agency must evaluate
the environmental health or safety
effects of the planned rule on children
and explain why the planned regulation
is preferable to other potentially
effective and reasonably feasible
alternatives considered by the Agenc\
This final rule is not subject to
Executive Order 13045 because it is not
an economically significant regulatory-
action as defined by Executive Order
12866. and it does not address an
environmental health or safety risk that
would have a disproportionate effect on
children.
D. Paperwork Reduction Act
The Office of Management and Budge;
(OMB) has"approved the information
collection requirements contained in
this rule under the provisions of the
Paperwork Reduction Act. 44 U.S.C.
3501 etseq. and has assigned OMB
control number 2060 0357.
The public reporting burden for this
collection of information is estimated to
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53994 Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
average 101 hours per respondent per
year. The average burden for the 78
affected slabstock foam producers is
somewhat higher than this estimate, due
to their monthly recordkeeping and
semiannual reporting requirements.
while the average burden for the 98
affected molded foam manufacturers is
less than 101 hours, since they are only
re.quired to submit an initial one-time
notification of compliance. No cost
burden associated with the purchase of
new equipment or technology is
estimated to result from this collection
of information. These estimates include
time for reviewing instructions.
searching existing data sources.
gathering and maintaining the data
needed, and completing and reviewing
the collection of information.
An Agency may not conduct or
sponsor, and a person is not required to
respond to. a collection of information
unless it displays a currently valid OMB
control number. The OMB control
numbers for FPA regulations are listed
in 40 CFR Part 9 and 48 CFR Chapter
If). The EPA is amending the table in 40
CFR Part 9 of currently approved 1CR
control numbers issued by OMB for
various regulations to list the
information requirements contained in
this final rule.
F. Regulatory Flexibility An
The FFA has determined that it is not
necessary to prepare a regulatory
flexibility analysis in connection with
this final rule. The FPA has also
determined that this rule will not have
a significant economic impart on a
substantial number of small entities.
Due to insufficient data on the
ownership of the plants in the flexible
poiyurethane foam industry, an analysis
of each parent company in the industry
was not feasible. Consequently, the FPA
used data collected in the section 11 1
survey to evaluate the impact on small
businesses based on model facilities.
That analysis indicates that there is a
total of approximately 121 businesses
(31 slabstock. 90 molded) that are
affected by the promulgated regulation.
of which approximately 71 are small
businesses (18 slabstock. 53 molded).
The calculation of average compliance
costs as a percent of revenues is less
than one percent for nearly all model
facilities in the analysis. The analysis
also indicates a potential for business
closures ranging from 0 to 3 of the total
number of estimated entities. However.
because there is insufficient data to
determine the exact size of the plants
that may close, the analysis cannot
determine if these impacts will occur at
small businesses. Given the results of
the analvsis and the use of worst case
assumptions in the closure analysis, the
EPA believes that the effect of the
promulgated regulation on small
businesses will be minimal.
Pursuant to section 605(b) of the
Regulatory- Flexibility Act. 5 U.S.C.
605(b). as amended. Pub. L. 104-121,.
110 Stat. 847. the EPA certifies that this
rule will not have a significant
economic impact on a substantial
number of small entities and therefore
no initial regulatory flexibility analysis
under section 604(a) of the Act is
required.
F. Submission to Congress and the
Comptroller General
The Congressional Review Act. 5
U.S.C. 801 et seq.. as added by the Small
Business Regulatory Enforcement.
Fairness Act of 1996, generally provides
that before a rule may take effect, the
agency promulgating the rule must
submit a rule report, which includes a
copy of the rule, to each House of the
Congress and to the Comptroller General
of the United States. The EPA will
submit a report containing this rule and
other required information to the U.S.
Senate, the U.S. House of
Representatives, and the Comptroller
General of the United States prior to
publication of the rule in the Federal
Register. This rule is not a "major rule"
as defined by 5 U.S.C. 804(2). "
G. Unfunded Mandates
Title II of the Unfunded Mandates
Reform Act of 1995 (UMR.A). P.L. 104-
4. establishes requirements for Federal
agencies to assess the effects of their
regulatory actions on State, local, and
tribal governments and the private
sector. Under section 202 of the UMRA.
the FPA generally must prepare a
written statement, including a cost
benefit analysis, for proposed and final
rules with "Federal mandates" that may-
result in expenditures to State, local,
and tribal governments, in the aggregate.
or to the private sector, of $100 million
or more in any one year. Before
promulgating an EPA rule for which a
written statement is needed, section 205
of the UMRA generally requires the EPA
to identify and consider a reasonable
number of regulatory alternatives and
adopt the least costly, most cost
effective or least burdensome alternative
that achieves the objectives of the rule.
The provisions of section 205 do not
apply when they are inconsistent with
applicable law. Moreover, section 205
allows the EPA to adopt an alternative
other than the least costly, most cost-
effective, or least burdensome
alternative if the Administrator
publishes with the final rule an
explanation why that alternative was
not adopted. Before the EPA establishes
any regulatory requirements that may
significantly or uniquely affect small
governments, including tribal
governments, it must have, developed
under section 203 of the UMRA a small
government agency plan. The plan must
provide for notifying potentially
affected small governments, enabling
officials of affected small governments
to have meaningful and timely input in
the development of EPA regulatory-
proposals with significant Federal
intergovernmental mandates, and
informing, educating, and advising
small governments on compliance with
the regulatory requirements.
The EPA has determined that this rule
does not contain a Federal mandate that
may result in expenditures of $100
million or more for State, local, and
tribal governments, in aggregate, or the
private sector in any one year, nor does
the rule significantly or uniquely impact
small governments, because it contains
no requirements that apply to such
governments or impose obligations
upon them. Thus, the requirements of
the UMR.A do not apply to this rule.
H. Executive Order 12875: Enhancing
Intergovernmental Partnerships
Under Executive Order 12875. the
EPA may not issue a regulation that is
not required by statute and that creates
a mandate upon a State, local or tribal
government, unless the Federal
government provides the funds
necessary to pay the direct compliance
costs incurred by those governments. If
the mandate is unfunded, the EPA must
provide to the Office of Management
and Budget a description of the extent
of EPA's prior consultation with
representatives of affected State, local
and tribal governments, the nature of
their concerns, copies of any written
communications from the governments.
and a statement supporting the need to
issue the regulation. In addition.
Executive Order 12875 requires the EPA
to develop an effective process
permitting elected officials and other
representatives of State, local and tribal
governments "to provide meaningful
and timely input in the development of
regulatory proposals containing
significant unfunded mandates."
Today's rule implements
requirements specifically set forth by
the Congress in Section 112 of the Clean
Air Act without the exercise of any
discretion by the EPA. Accordingly, the
requirements of section 1 (a) of
Executive Order 12875 do not apply to
this rule.
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Federal Register/Vol. 63, No. 194/Wednesday. October 7, 1998/Rules and Regulations 53995
/. Executive Order 13084: Consultation
and Coordination Witii Indian Tribal
Governments
Under Executive Order 13084. the
EPA may not issue a regulation that is
not required by statute, that
significantly or uniquely affects the
communities of Indian tribal
governments, and that imposes
substantial direct compliance costs on
those communities, unless the Federal
government provides the funds
necessary to pay the direct compliance
costs incurred by the tribal
governments. If the mandate is
unfunded, the EPA must provide to the
Office of Management and Budget, in a
separately identified section of the
preamble to the rule, a description of
the extent of EPA's prior consultation
with representatives of affected tribal
governments, a summary of the nature
of their concerns, and a statement
supporting the need to issue the
regulation. In addition. Executive Order
13084 requires the EPA to develop an
effective process permitting elected and
other representatives of Indian tribal
governments "to provide meaningful
and timely input in the development of
regulatory policies on matters that
significantly or uniquely affect their
communities."
Today's rule implements
requirements specifically set forth by
the Congress in Section 112 of the Clean
Air Act without the exercise of any
discretion by the EPA. Accordingly, the
requirements of section 3(b) of
Executive Order ] 3084 do not apply to
this rule.
J. Clean Air Act
In accordance with section 117 of the
Act. publication of this rule \vas
preceded by consultation with
appropriate advisory committees.
independent experts, and Federal
departments and agencies.
flits regulation will be reviewed 8
years from the date of promulgation.
This review will include an assessment
of such factors as evaluation of the
residual health risks, any overlap with
other programs, the existence of
alternative methods, enforceability,
improvements in emission control
technology and health data, and the
recordkeeping and reporting
requirements.
K. National Technology Transfer and
Advancement Act
Section 12 of the National Technology
Transfer and Advancement Act of 1995
(NTTAA) requires federal agencies to
evaluate existing technical standards
when developing new regulations. To
comply with the NTTAA. the EPA must
consider and use "voluntary consensus
standards" (VCS). if available and
applicable, when developing NESHAP
and other programs and policies unless
doing so would be inconsistent, with
applicable law or otherwise impractical.
A VCS is a technical standard
developed or adopted by a legitimate
standards developing organization. The
NTTAA defines "technical standards"
as "performance-based of design-
specific technical specifications and
related management systems practices."
According to NTTAA's legislative
history, a "technical standard" pertains
to "products and processes, such as
size, strength, or technical performance
of a product, process or material." A
legitimate standards developing
organization must produce standards by-
consensus and observe the principles of
d-je process, openness, and balance of
interests.
Examples of organizations generally-
regarded as voluntary consensus
standards bodies include the American
Society for Testing and Materials
(ASTM). International Organization for
Standardization (ISO). International
Electrotechnical Commission (IEC).
American Petroleum Institute" (API).
National Fire Protection Association
(NFPA) and the Society of Automotive
Engineers (SAE).
The well known American National
Standards Institute (ANSI) evaluates the
standards development processes of
these bodies, and when requested by-
one of them, certifies standards meeting
the above criteria as American National
Standards. Such a designation is an
important indicator for determining
whether a given standard qualifies as a
legitimate VCS.
In developing the flexible
polyurethane foam regulation, the EPA
searched for potentially useful VCS.
This search included the use of the
National Standards System Network and
the National Center for Standards for
Certification Information. The Agency
also conducted extensive conversations
with the affected industry and other
stakeholders. In response to this
information, the regulation includes two
VCS- ASTM D3574 and National
Institute of Standards and Technology7
.Handbook 44. ASTM D3574 is used to
determine IFD and density of slabstock
foam buns. Transfer vehicle weight may
be determined by using the procedures
contained in the National Institute of
Standards and Technology Handbook
44. These VCS were selected for
incorporation by reference because they
provide the proper information with
sufficient accuracy for this rule.
The EPA is not required to give
deference under NTTAA to a standard
that does not qualify as a VCS. Sight
gauges and other level measurement
devices, which are commonly used in
the industry, do not qualify as VCS.
However, the Agency did elect to utilize
such devices to measure HAP ABA
added to storage vessels in slabstock
flexible polyurethane foam facilities.
These requirements are described in
Section II C.4. of this preamble. The
decision to adopt common industry
practices reflects the Agency's
commitment to reduce costs to the
private sector where technically feasible
and in accordance with Clean Air Act
requirements.
List of Subjects in 40 CFR Parts 9 and
63
Environmental protection. Air
pollution control. Hazardous
substances. Incorporation by reference.
Reporting and recordkeeping
requirements.
Dated: September 15 1998.
Carol M. Browner,
Administrator
For the reasons set out in the
preamble, parts 9 and 63 of title 40.
chapter 1 of the Code of Federal
Regulations are amended as follows:
PART 9—[AMENDED]
1. The authority citation for part 9
continues to read as follows:
Authority: 7 US C 135etseq 136-13Cy.
15 U.S.C 2001. 2003. 2005. 200G 2G01-2671
21 U.S.C. 33Ij 346a 348: 31 U.SC 9701. 33
U.S.C. 1251 etseq 1311 1313d 1314 1318
1321. 132G. 1330 1342 1344 1345 (d) and
(e), 1361: E.O 11735 38 FR 21213. 3 CFk
1971-1975 Compp 973 42US.C. 241
242b, 243 24G 300f. 300g 300g-l 300g-2
300g-3, 300g-4, 300g-5 300g-C 300j-1
300j-2. 300j-3. 300j-4. 300j-9. 1857 efsey
6901-G992R. 7401-7G71q 7542 9601-9G57
11023. 11048
2. Section 9.1 is amended by adding
the new entries to the table under the
indicated heading in numerical order to
read as follows:
§ 9.1 OMB approvals under the Paperwork
Reduction Act.
40CFR:citation
OMB con-
trol No.
63.1290—63.1309 2060-0357
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53996
Final rule start
Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
National Emission Standards for
Hazardous Air Pollutants for Source
Categories3
* at * * * K
PART 63—NATIONAL EMISSION
STANDARDS FOR HAZARDOUS AIR
POLLUTANTS FOR AFFECTED
SOURCE CATEGORIES
3. The authority citation for part 63
continues to read as follows:
Authority: 42 LI.S.C. 7401. el. seq
Subpart A—General Provisions
4. Section 63.14 is amended by
revising paragraph (b) introductory text,
and adding paragraphs (b)(20) and (e) to
read as follows:
§63.14 Incorporation by reference.
* » * * X
(b) The materials listed below are
available for purchase from at least one
of the following addresses: American
Society for Testing and Materials. 100
Barr Harbor Drive. West Conshohocken.
PA 19428 2959: or Universiu
Microfilms International. 300 North
Zeeb Road. Ann Arbor. MI 48106.
* * i at x
(20) AST'M D3574-91. Standard Test
Methods for Flexible Cellular
Materials Slab. Bonded, and Molded
1 Jrethane Foams. 1RR approved for
§ 63.1304 (b).
(e) The materials listed below are
available for purchase from the National
Institute of Standards and Technology.
Springfield. VA 22161. (800) 553-6847.
(1) Handbook 44. Specificiations.
Tolerances, and Other Technical
Requirements for Weighing and
Measuring Devi res J998. IRR approved
for § 63.1303 (e) (3).
(2) [Reserved]
5. Part 63 is amended by adding
subpart III to read as follows:
Subpart III—National Emission Standards
for Hazardous Air Pollutants for Flexible
Polyurethane Foam Production
Sec.
63.1290 Applicability.
63.1291 Compliance schedule.
63.1292 Definitions
63.1293 Standards for slabstock flexible
polyurethane foam production.
63.1294 Standards for slabstock flexible
polyurethane foam production—
diisocyanate emissions.
63.1295 Standards for slabstock flexible
polyurethane foam production—HAP
ABA storage vessels.
63.1296 Standards for slabstock flexible
polyurethane foam production—HAP
ABA equipment leaks.
63 1297 Standards for slabstock flexible
polyurethane foam production—HAP
ABA emissions from the production line.
63.1298 Standards for slabstock flexible
polyurethane foam production—HAP
emissions from equipment cleaning.
63.1299 Standards for slabstock flexible
polyurethane foam production—source-
wide emission limitation.
631300 Standards for molded flexible
polyurethane foam production
63.1301" Standards for rebond foam
production
63.1302 Applicability of subpart A
requirements.
63.1303 Monitoring requirements
631304 Testing requirements
631305 Alternative means of emission
limitation
63.1306 Reporting requirements
63.1307 Recordkeeping requirements
63 1308 Compliance demonstrations
63.1309 Delegation of authority
Appendix to Subpart III—Tables
Subpart III—National Emission
Standards for Hazardous Air Pollutants
for Flexible Polyurethane Foam
Production
§63.1290 Applicability.
(a) The provisions of this subpart
apply to each new and existing flexible
polyurethane foam or rebond foam
process that meets the criteria listed in
paragraphs (a)(l) through (3) of this
section.
(1) Produces flexible polyurethane or
rebond foam;
(2) Emits a HAP. except as provided
In paragraph (c)(2) of this section: and
(3) Is located at a plant site that is a
major source, as defined in §63.2 of
subpart A.
(b) For the purpose of this subpart. an
affected source includes all processes
meeting the criteria in paragraphs (a)(l)
through (a) (3) of this section that are
located at a contiguous plant site, with
the exception of those processes listed
in paragraph (c) of this section.
(c) A process meeting one of the
following criteria listed in paragraphs
(c)(l) through (3) of this section shall
not he subject to the provisions of this
stibpart:
(1) A process exclusively dedicated to
the fabrication of flexible polyurethane
foam:
(2) A research and development
process: or
(3) A slabstock flexible polyurethane
foam process at a plant site where the
total amount of HAP. excluding
diisocyanate reactants. used for
slabstock foam production and foam
fabrication is less than or equal to five
tons per year, provided that slabstock
foam production and foam fabrication
processes are the only processes at the
plant site that emit HAP. The amount of
non-diisocyanate HAP used. HAPused
shall be calculated using Equation 1.
Owners or operators of slabstock foam
processes exempt from the regulation in
accordance with this paragraph shall
maintain records to verify that total non
diisocyanate HAP use at the plant site
is less than 5 tons per year (4.5
megagrams per year).
HAPused = £
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Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations 53997
§83.1292 Definitions.
AH terms used in this subpart shall
have the meaning given them in the Act,
in subpart A of this part, and in this
section. If a term is defined in subpart
A and in this section, it shall have the
meaning given in this section for
purposes of this subpart.
Auxiliary blowing agent, or ABA.
means a low boiling point liquid added
to assist foaming by generating gas
beyond &at resulting from the
isocyanate-water reaction.
Breakthrough means that point in the
adsorption step when the mass transfer
zone (i.e., the section of the carbon bed
where the HAP is removed from the
carrier gas stream) first reaches the
carbon bed oudet as the mass transfer
zone moves down the bed in the
direction of flow. The breakthrough
point is characterized by the beginning
•of a sharp increase in the outlet HAP or
organic compound concentration.
Calibrate means to verify the accuracy
of a measurement device against a
known standard. For the purpose of this
subpart. there are two levels of
calibration. The initial calibration
includes the verification of the accuracy
of the device over the entire operating
range of the device. Subsequent
calibrations can be conducted for a
point or several points in a limited
range of operation that represents the
most common operation of the device.
Canned motor pump means a pump
with interconnected cavity housings.
motor rotors, and pump casing. In a
canned motor pump, the motor bearings
run in the process liquid and all seals
are eliminated.
Carbon adsorption system means a
system consisting of a tank or container
that contains a specific quantity of
activated carbon. For the purposes of
this subaprt. a carbon adsorption system
is used as a control device for storage
vessels. Typically, the spent carbon bed
does not undergo regeneration, but is
replaced.
Connector means flanged, screwed, or
other joined finings used to connect two
pipe lines or a pipe line and a piece of
equipment. A common connector is a
flange. Joined fittings welded
completely around die circumference of
the interface are not considered to be
connectors for the purposes of this
subpart.
Cured foam means flexible
polyurethane foam with fully developed
physical properties. A period of 12 to 24
hours from pour is typically required to
completely cure foam, although
mechanical or other devices are
sometimes used to accelerate the curing
process.
Curing area means the area in a
slabstock foam production facility
where foam buns are allowed to fully
develop physical properties.
Diaphragm pump means a pump
where the driving member is a flexible
diaphragm made of metal, rubber, or
plasdc. In a diaphragm pump, there is
no packing or seals that are exposed to
the process liquid.
Diisocyanate means a compound
containing two isocyanate groups per
molecule. The most common
diisocyanate compounds used in the
flexible polyurethane foam industry are
toluene diisocyanate (TOI) and
methylene diphenyl diisocyanate (MDI).
Flexible polyurethane foam means a
flexible cellular polymer containing
urea and carbamate linkages in the
chain backbone produced by reacting a
diisocyanate, polyol. and water. Flexible
polyurethane foams are open celled.
permit the passage of air through the
foam, and possess the strength and
flexibility to allow repeated distortion
or compression under stress with
essentially complete recovery upon
removal of the stress.
Flexible polyurethane foam prore.s.s
means the equipment used to produce a
flexible polyurethane foam product. For
the purpose of this subparr. the flexible
polyurethane foam process includes raw
material storage: production equipment
and associated piping, ductwork, etc.:
and curing and storage areas.
Foam fabrication process means an
operation for cutting or bonding flexible
polyurethane foam pieces together or to
other substrates.
Grade of foam means foam with a
distinct combination of indentation
force deflection (1FD) and density
values.
HAP ABA means methylene chloride.
or any other HAP compound used as an
auxiliary blowing agent.
HAP-based means to contain 5
percent (by weight) or more of HAP.
This applies to equipment cleaners (and
mixhead flushes) and mold release
agents. The concentration of HAP may
be determined using F.PA test method
18, material safety data sheets, or
engineering calculations.
High pressure mixhead means a
mixhead where mixing is achieved by
impingement of the high pressure
streams within the mixhead.
Indentation Force Deflection QFD)
means a measure of the load bearing
capacity of flexible polyurethane foam. •
IFD is generally measured as the force
(in pounds) required to compress a 50
square inch circular indentor foot into a
four inch thick sample, typically 15
inches square or larger, to 25 percent of
the sample's initial height.
In diisocyanate service means a piece
of equipment that contains or contacts
a diisocyanate.
In HAP ABA service means a piece of
equipment that contains or contacts a
HAP ABA.
Initial startup means the first time a
new or reconstructed affected source
begins production of flexible
polyurethane foam.
Isocyanate means a reactive chemical
grouping composed of a nitrogen atom
bonded to a carbon atom bonded to an
oxygen atom: or a chemical compound.
usually organic, containing one or more
isocyanate groups.
Magnetic drive pump means a pump
where an externally mounted magnet
coupled to the pump motor drives the
impeller in die pump casing. In a
magnetic drive pump, no seals contact
the process fluid.
Meterwg pump means a pump used to
deliver rfactants. ABA. or additives to
the mixhead.
Mixhead means a device that mixes
two or more component streams before
dispensing foam producing mixture to
the desired container.
Molded flexible polyurethane foam
means a flexible polyurethane foam that
is produced by shooting the foam
mixture into a mold of the desired shape
and size.
Mold release agent means any
material which, when applied to the
mold surface, serves to prevent sticking
of the. foam pan to the mold.
Plant site means all contiguous or
adjoining property that is under
common control/including properties
that are separated only by a road or
other public right of way Common
control includes properties that air-
owned, leased, or otherwise operated by
the same entity, parent entity.
subsidiary, or any combination thereof.
Polyol. for the purpose of this subpart.
means a polyether or polyester polymer
with more than one reactive hydroxyl
group attached to the molecule.
Rebond foam means the foam
resulting from a process of adhering
small particles of foam (usually scrap or
recycled foam) together to make a usable
cushioning product. Various adhesives
and bonding processes are used. A
typical application for rebond foam is
for carpet underlay.
Rebond foam process means the
equipment used to produce a rebond
foam product. For the purpose of this
subpart. the rebond foam process
includes raw material storage:
production equipment and associated
piping, ductwork, etc.: and curing and
storage areas.
Reconstructed source means an
affected source undergoing
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53998 Federal Register/Vol. 63. No. 194/Wednesday. October 7, 1998/Rules and Regulations
reconstruction, as defined in subpart A.
For the purposes of this subpart. process
modifications made to reduce HAP ABA
emissions to meet the existing source
requirements of this subpart shall not be
counted in determining whether or not
a change or replacement meets the
definition of reconstruction.
Recovery device means an individual
unit of equipment capable of and used
for the purpose of recovering chemicals
for use. reuse, or sale. Recovery devices
include, but are not limited to. carbon
adsorbers, absorbers, and condensers.
Research and development process
means a laboratory or pilot plant
operation whose primary purpose is to
conduct research and development into
new processes and products, where the
operations are under the close
supervision of technically trained
personnel, and which is not engaged in
the manufacture of products for
commercial sale except in a de minimis
manner.
Run of foam means a continuous
production of foam, which may consist
of several grades of foam.
Sealless pump means a canned motor
pump, diaphragm pump, or magnetic
drive pump, as defined in this section.
SlabsTock flexible pnlyurethane foam
means flexible polyurethane foam that
is produced in large continuous buns
that are then cut. into the desired size
and shape.
Slabstork flexible pnlyureThane foam
production line includes all portions of
the flexible polyurethane foam process
from the mixhead to the point in the
process where the foam is completely
cured.
Storage vessel means a tank or other
vessel that is used to store diisocyanate
or HAP ABA for use in the production
of flexible polyurethane foam. Storage
vessels do not include vessels with
capacities smaller than 38 cubic meters
(or 10.000 gal Ions).
Transfer pump means all pumps used
to transport diisocyanate or HAP ARA
that are not metering pumps.
Transfer vehicle means a railcar. tank
truck, or other vehicle used to transport
HAP ABA to the flexible polyurethane
foam facility.
§63.1293 Standards for slabstock flexible
polyurethane foam production.
Each owner or operator of a new or
existing slabstock affected source shall
comply with §63.1294 and either
paragraph (a) or (b) of this section:
(a) The emission point specific
limitations in §§63.1295 through
63.1298: or
(b) For sources that use no more than
one HAP as an ABA and an equipment
cleaner, the source wide emission
limitation in §63.1299.
§ 63.1294 Standards for slabstock flexible
polyurethane foam production—
diisocyanate emissions.
Each new and existing slabstock
affected source shall comply with the
provisions of this section.
(a) Diisocyanate storage vessels.
Diisocyanate storage vessels shall be
equipped with either a system meeting
the requirements in paragraph (a)(l) of
this section, or a carbon adsorption
system meeting the requirements of
paragraph (a) (2) of this section.
(1) The storage vessel shall be
equipped with a vapor return line from
the storage vessel to the tank truck or
rail car that is connected during
unloading.
(i) During each unloading event, the
vapor return line shall be inspected for
leaks by visual, audible, or any other
detection method.
(ii) When a leak is detected, it shall
be repaired as soon as practicable, but
not later than the subsequent unloading
event.
(2) The storage vessel shall be
equipped with a carbon adsorption
system, meeting the monitoring
requirements of § 63.1303(a). that routes
displaced vapors through activated
carbon before being discharged to the
atmosphere. The owner or operator shall
replace the existing carbon with fresh
carbon upon indication of breakthrough
before the next unloading event.
(b) Transfer pumps in diisocyanate
service. Each transfer pump in
diisocyanate service shall meet the
requirements of paragraph (b)(l) or
(b)(2) of this section.
(1) The pump shall be a sealless
pump: or
(2) The pump shall be a submerged .
pump system meeting the requirements
in paragraphs (b)(2)(i) through (Hi) of
this section.
(i) The pump shall be completely
immersed in bis(2-ethylhexyl)phthalate
(DEHP. CAS #118-81-7).
2(methyloctyl)phthalate (D1NP. CAS
#68515-48-0). or another neutral oil.
(ii) The pump shall be visually
monitored weekly to detect leaks,
(iii) When a leak is detected, it shall
be repaired in accordance with the
procedures in paragraphs (b) (2) (iii) (A)
and (B) of this section, except as
provided in paragraph (d) of this
section.
(A) The leak shall be repaired as soon
as practicable, but not later than 15
calendar days after it is detected.
(B) A first attempt at repair shall be
made no later than 5 calendar days after
the leak is detected. First attempts at
repair include, but are not limited to.
the following practices where
practicable:
(I) Tightening of packing gland nuis.
(^ Ensuring that the real flush is
operating at design pressure and
temperature.
(c) Other components in diisocyanate
service. If evidence of a leak is found by
visual, audible, or any other detection
method, it shall be repaired as soon as
practicable, but not later than 15
calendar days after it is detected, except
as provided in paragraph (d) of this
section. The first attempt at repair shall
be made no later than 5 calendar days
after each leak is detected.
(d) Delay of repair. (1) Delay of repair
of equipment for which leaks have been
detected is allowed for equipment that
is isolated from the process and that
does not remain in diisocyanate service.
(2) Delay of repair for valves and
connectors is also allowed if:
(i) The owner or operator determines
that diisocyanate emissions of purged
material resulting from immediate
repair are greater than the fugitive
emissions likely to result from delay of
repair, and
(ii) The purged material is collected
and destroyed or recovered in a control
device when repair procedures are
effected.
(3) Delay of repair for pumps is also
allowed if repair requires replacing the
existing seal design with a sealless
pump.'and repair is completed as soon
as practicable, but not later than 6
months after the leak was detected.
§ 63.1295 Standards for slabstoc k flexible
polyurethane foam production—HAP ABA
storage vessels.
Each owner or operator of a new or
existing slabstock affected source
complying with the emission point
specific limitation option provided in
§63.1293(a) shall control HAP ABA
storage vessels in accordance with the
provisions of this section.
(a) Each HAP ABA storage vessel shall
be equipped with either a vapor balance
system meeting the requirements in
paragraph (b) of this section, or a carbon
adsorption system meeting the
requirements of paragraph (c) ol this
section.
(b) The storage vessel shall be
equipped with a vapor balance system.
The owner or operator shall ensure that
the vapor return line from the storage
vessel to the tank truck or rail car is
connected during unloading.
(1) During each unloading event, the
vapor return line shall be inspected for
leaks by visual, audible, olfactory, or
any other detection method.
(2) When a leak is detected, it shall be
repaired as soon as practicable, but not
later than the subsequent unloading
event.
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Federal Register/Vol. 63, No. 194/Wednesday. October 7, 1998/Rules and Regulations 53999
(c) The storage vessel shall be
equipped with a carbon adsorption
system, meeting the monitoring
requirements of § 63.1303(a), that routes
displaced vapors through activated
carbon before discharging to the
atmosphere. The owner or operator shall
replace the existing carbon with fresh
carbon upon indication of breakthrough
before the next, unloading event.
§63.1296 Standards for slabstock flexible
polyurethane foam production—HAP ABA
equipment leaks.
Each owner or operator of a new or
existing slabstock affected source
complying with the emission point
specific limitation option provided in
§G3.1293(a) shall control HAP ABA
emissions from leaks from transfer
pumps, valves, connectors, pressure
relief valves, and open ended lines in
accordance with the provisions in this
section.
(a) Pumps. Each pump in HAP ABA
service shall be controlled in
accordance with either paragraph (a)(l)
or (a) (2) of this section.
(I) The pump shall be a sealless
pump, or
(2) Each pump shall be monitored for
leaks in accordance with paragraphs
(a)(2)(i) and (ii) of this section. Leaks
shall be repaired in accordance with
paragraph (a)(2)(iii) of this section.
(i) Each pump shall be monitored
quarterly to detect leaks by the method
specified in §63.1304(a). if an
instrument reading of 10.000 pans per
million (ppm) or greater is measured, a
leak is detected.
(ii) Each pump shall be checked by
visual inspection each calendar week
for indications of liquids dripping from
the pump seal. If there are indications
of liquids dripping from the pump se^l.
a leak is detected.
(iii) When a leak is detected, it shall
be repaired in accordance with the
proceduresin paragraphs (a)(2)(iii)(A)
and (B) of this section, except as
provided in paragraph (f) of this section.
(A) The leak shall be repaired as soon
as practicable, but not later than 15
calendar days after it is detected.
(B) A first attempt at repair shall be
made no later than 5 calendar days after
the leak is detected. First attempts at
repair include, but are not limited ro.
the following practices, where
practicable:
(1) lightening of packing gland nuts.
(3 Ensuring that the seal flush is
operating at design pressure and
temperature.
(b) Valves. Each valve in HAP ABA
service shall be monitored for leaks in
accordance with paragraph (b)(l) of this
section, except as provided in
paragraphs (b)(3) and (4) of this section.
Leaks shall be repaired in accordance
with paragraph (b)(2) of this section.
(1) Each valve shall be monitored
quarterly to detect leaks by the method
specified in § 63.1304 (a). If an
instrument reading of 10.000 parts per
million or greater is measured, a leak is
detected.
(2) When a leak is detected, the owner
or operator shall repair the leak in
accordance with the procedures in
paragraphs (b)(2)(i) and (ii) of this
section, except as provided in paragraph
(f) of this section.
(i) The leak shall be repaired as soon
as practicable, but not later than 15
calendar days after it is detected.
(ii) A first attempt at repair shall be
made no later than 5 calendar days after
the leak is detected. First attempts at
repair include, but are not limited to.
the following practices where
practicable:
(A) Tightening of bonnet bolts:
(B) Replacement of bonnet bolts:
(C) Tightening of packing gland nuts:
and
(D) Injection of lubricant into
lubricated packing.
(3) Any valve that is designated as an
unsafe-to monitor valve is exempt from
the requirements of paragraphs (b)(l)
and (2) of this section if:
(i) The owner or operator of the valve
determines that the valve is unsafe to
monitor because monitoring personnel
would be exposed to an immediate
danger as a consequence of complying
with paragraphs (b)(l) and (2) of this
section: and
(ii) The owner" or operator of the valve
has a written plan that requires
monitoring of the valve as frequently as
practicable during safe to monitor
times. The plan shall also include
requirements for repairing leaks as soon
as possible after detection.
(iii) The owner or operator shall
monitor the unsafe to-monitor valve in
accordance with the written plan, and
(iv) The owner or operator shall repair
leaks in accordance with the written
plan.
(4) Any valve that is designated as a
difficult to monitor valve is exempt
from the requirements of paragraphs
(b)(l) and (2) of this section if:
(i) The owner or operator of the valve
determines that die valve cannot be
monitored without elevating the
monitoring personnel more than 2
meters above a support surface or it is
not accessible at any time in a safe
manner:
(ii) The process within which the
valve is located is an existing source, or
the process within which the valve is
located is a new source that has less
than 3 percent of the total number of
valves designated as difficult to
monitor: and
(iii) The owner or operator of the
valve develops a written plan that
requires monitoring of the valve at least
once per calendar year. The plan shall
also include requirements for repairing
leaks as soon as possible after detection.
(iv) The owner or operator shall
monitor the difficult to monitor valve in
accordance with the written plan, and
(v) The owner or operator shall repair
leaks in accordance with the written
plan.
(c) Connectors. Each connector in
HAP ABA service shall be monitored for
leaks in accordance with paragraph
(c)(l) of this section, except as provided
in paragraph (c)(3) of this section. Leaks
shall be repaired in accordance with
(c)(2) of this section, except as provided
in paragraph (c)(4) of this section.
(1) Connectors shall be monitored at
the times specified in paragraphs
(c)(l)(i) through (iii) of this section to
detect leaks by the method specified in
§G3.1304(a). If an instrument reading of
10.000 ppm or greater is measured, a
leak is detected.
(i) Each connector shall be monitored
annually, and
(ii) Each connector that has been
opened or has otherwise had the seal
broken shall be monito?-ed for leaks
within the first 3 months after being
returned to HAP ABA service
(iii) if a leak is detected, the connector
shall be monitored for leaks in
accordance with paragraph (c)(l) of this
section within the first 3 months aftet
its repair.
(2) When a leak is detected, it shall be
repaired in accordance with the
procedures in paragraphs (c)(2)(i) and
(ii) of this section, except as provided in
paragraph (c)(4) and paragraph (f) of this
section.
(i) The leak shall be repaired as soon
as practicable, but no later than 15
calendar days after the leak is detected.
(ii) A first'attempt at repair shall be
made no later than 5 calendar days after
the leak is detected.
(3) Any connector that is designated
as an unsafe to monitor connector is
exempt from the requirements oi
paragraph (c)(l) of this section if:
(i) The owner or operator determines
that the connector is unsafe to monitor
because personnel would be exposed to
an immediate danger as a result of
complying with paragraph (c)(l) ot this
section: and
(ii) The owner or operator has a
written plan that requires monitoring of
the connector as frequently as
practicable during safe to- monitor
periods.
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54000 Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
(4) Any connector that is designated
as an unsafe to repair connector is
exempt from the requirements of
paragraph (c)(2) of this section if:
(i) The owner or operator determines
that repair personnel would be exposed
to an immediate danger as a
consequence of complying with
paragraph (c)(2) of this section: and
Jii) The connector will be repaired as
soon as practicable, but not later than 6
months after the leak was detected.
(d) Pressure relief devices. Each
pressure-relief device in HAP ABA
service shall be monitored for leaks in
accordance with paragraph (d)(l) of this
section. Leaks shall be repaired in
accordance with paragraph (d){2) of this
section.
(1) Each pressure-relief device in HAP
ABA service shall be monitored within
5 calendar days by the method specified
in § 63.1304 (a) if evidence of a potential
leak is found by visual, audible.
olfactory, or any other detection
method. If an instrument reading of
10.000 ppm or greater is measured, a
leak is detected.
(2) When a leak is detected, the leak
shall be repaired as soon as pracricablp.
bur not later than 15 calendar days after
it is detected, except as provided in
paragraph (f) of this section.
The owner or operator shall make a
first attempt at repair no later than f>
calendar days after the leak is detected.
(el Open ended valves or lines. (l)(i)
Each open ended valve or line in HAP
ABA service shall be equipped with a
cap. blind flange, plug, or a second
valve, except as provided in paragraph
(e)(4) of this section.
(ii) The cap. blind flange, plug, or
second valve shall seal the open end at
all times except during operations
requiring process fluid flo\\ through i he-
open ended valve or line, or during
maintenance or repair.
(2) Each open-ended valve or line
equipped with a second valve shall be
operated in a manner such that the
valve on the process fluid end is closed
before the second valve is closed.
(3) When a double block and bleed
system is being used, the bleed valve or
line may remain open during operations
that require venting the line between the
block valves but shall comply with
paragraph (e)(l) of this section at all
other times.
(4) Open-ended valves or lines in an
emergency shutdown system which are
designed to open automatically in the
event of a process upset are exempt
from the requirements of paragraphs
(e)(l). (2). and (3) of this section.
(i) Delay of repair. (I) Delay of repair
of equipment for which leaks have been
detected is allowed for equipment that
is isolated from the process and that
does not remain in HAP ABA service.
(2) Delay of repair for valves and
connectors is also allowed if:
(i) The owner or operator determines
that emissions of purged material
resulting from immediate repair are
greater than the fugitive emissions likely
to result from delay of repair, and
(ii) The purged material is collected
and destroyed or recovered in a control
device when repair procedures are
effected.
(3) Delay of repair for pumps is also
allowed if repair requires replacing the
existing seal design with a sealless
pump, and repair is completed as soon
as practicable, but not later than 6
months after the leak was detected.
§ 63.1297 Standards for slabstock flexible
polyurethane foam production—HAP ABA
emissions from the production line.
(a) Each owner or operator of a new
or existing slabstock affected source
complying with the emission point
specific limitation option provided in
§63.1293(a)(l) shall control HAP ABA
emissions from the slabstock
polyurethane foam production line in
accordance with the provisions in this
section. Compliance shall be
determined on a rolling annual basis as
described in paragraph (a)(l) of this
section. As an alternative, the owner or
operator can determine compliance on a
monthly basis, as described in
paragraph (a) (2) of this section.
(1) Rolling annual compliance. In
determining compliance on a rolling
annual basis, actual H.AP ABA
emissions shall be compared to
allowable HAP ABA emissions for each
consecutive 12-month period. The
allowable HAP ABA emission level
shall be calculated based on the
production for the 12-month period.
resulting in a potentially different
allowable level for each 12 month
period. Compliance shall be determined
each month for the previous 12-month
period. The compliance requirements
are provided in paragraph (b) of this
section.
(2) Monthly compliance alternative.
As an alternative to determining
compliance on a rolling annual basis, an
owner or operator can determine
compliance by comparing actual HAP
ABA emissions to allowable HAP ABA
emissions for each month. The
allowable HAP ABA emission level
shall be calculated based on the
production for the month, resulting in a
potentially different allowable level
each month. The requirements for this
monthly compliance alternative are
provided in paragraph (c) of this
section.
(3) Each owner or operator electing to
change between the compliance
methods described under paragraphs
(a)(l) and (a) (2) of this section shall
notify the Administrator no later than
180 calendar days prior to the change.
(b) Rolling annual compliance. At
each slabstock foam production source
complying with the rolling annual
compliance provisions described in
paragraph (a)(l) of this section, actual
HAP ABA emissions shall not exceed
the allowable HAP ABA emission level
for a consecutive 12-month period. The
actual HAP ABA emission level for a
consecutive 12-month period shall be
determined using the procedures in
paragraph (b)(l) of this section, and the
allowable HAP ABA emission level for
the corresponding 12 month period
shall be calculated in accordance with
paragraph (b)(2) of this section.
(1) The actual HAP ABA emissions for
a 12 month period shall be calculated as
the sum of actual monthly HAP ABA
emissions for each of the individual 12
months in the period. Actual month1 y
HAP ABA emissions shall be equal to
the amount of HAP ABA added to the
slabstock foam production line at th<3
mixhead. determined in accordance
with § 63.1303(b). unless a recovery
device is used. Slabstock foam
production sources using recovery
devices to reduce H.AP ABA emissions
shall determine actual monthly HAP
ABA emissions using the procedures in
paragraph (e) of this section.
(2) The allowable HAP ABA
emissions for a consecutive 12-month
period shall be calculated as the sum of
allowable monthly HAP ABA emissions
for each of the individual 12 months in
the period. Allowable HAP'ABA
emissions for each individual month
shall be calculated using Equation 2.
emiss
'allow, month
.1=] Vi=l
(limit,) (polyol,)
100
(Equation 2)
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Federal Register/Vol.'63, No. 194/Wednesday. October 7, 1998/Rules and Regulations 54001
Where:
.nth - Allowable HAP ABA
emissions from the slabstock foam
production source for the month.
pounds.
m - Number of slabstock foam
production lines.
polyolj - Amount of polyol used in the
month in the production of foam
grade i on foam production line j,
determined in accordance with
paragraph (b)(3) of this section.
pounds.
n = Number of foam grades produced in
the month on foam production line
j-
limit, - HAP ABA formulation limit for
foam grade i. parts HAP ABA per
100 parts polyol. The HAP ABA
formulation limits are determined
in accordance with paragraph (d) of
this section.
(3) The amount of polyol used for
specific foam grades shall be based on
the amount of polyol added to the
slabstock foam production line at the
mixhead. determined in accordance
with the provisions of §63.1303 (b).
(c) Monthly compliance alternative.
At each slabstock foam production
source complying with the monthly
compliance alternative described in
paragraph (a) (2) of this section, actual
HAP ABA emissions shall not exceed
the corresponding allowable HAP ABA
emission level for the same month. The
actual monthly HAP ABA emission
level shall be determined using the
procedures in paragraph (c)(l) of this
section, and the allowable monthly HAP
ABA emission level shall be calculated
in accordance with paragraph (c){2) of
this section.
(1) The actual monthly HAP ABA
emissions shall be equal to the amount
of HAP ABA added to the slabstock
foam production line at the mixhead.
determined in accordance with
§G3.1303(b). unless a recovery device is
used. Slabstock foam production
sources using recovery devices to
reduce HAP ABA emissions shall
determine actual month!v HAP ABA
emissions using the procedures in
paragraph (e) of this section.
(2) The allowable HAP ABA
emissions for the month shall be
determined in accordance with
Equation 2 of this section.
(d) HAP ABA formulation limitations.
For each grade, the HAP ABA
formulation limitation shall be
determined in accordance with
paragraphs (d)(l) through (d)(3) of this
section. For any grade, the owner or
operator may designate zero as the HAP
ABA formulation limitation and not
determine the HAP ABA formulation
limitation in accordance with
paragraphs (d)(l) through (d)(3) of this
section.
(1) For existing sources, the HAP ABA
formulation limitation for each grade of
slabstock foam produced shall be
determined using Equation 3 of this
section. Zero shall be the formulation
limitation for any grade of foam where
the result of the formulation limitation
equation (Equation 3) is negative (i.e..
less than zero).
ABA,™, = -0.25(IFD)-19.l| -16.2 (DEN)-7.56
j+ 36.5
(Equation 3)
Where:
,,,,- HAP ABA formulation
limitation, parts HAP ABA allowed
per hundred pans polyol (pph).
IFD - Indentation force deflection.
pounds. '
DF.N - Density, pounds per cubic font.
(2) For new sources, the HAP ABA
formulation limitation for each grade of
slabstock foam produced shall be
determined as described in paragraphs
(d)(2)(i) through (d)(2)(iv) of this section
and in Table 1 of this subpart.
(i) For each foam grade with a density
of 0.95 pounds per cubic foot or less, the
HAP ABA formulation limitation shall
be determined using Equation 3. Zero
shall be the formulation limitation for
any grade of foam where the result of
the formulation limitation equation
(Equation 3 of this section) is negative
(i.e.. less than zero).
(ii) For each foam grade with a
density of 1.4 pounds per cubic foot or
less, and an IFD of 15 pounds or less.
the HAP ABA formulation limitation
shall be determined using Equation 3.
(iii) For each foam grade with a
density greater than 0.95 pounds per
cubic foot and an IFD greater than 15
pounds, the HAP ABA formulation
limitation shall be zero.
(iv) For each foam grade with a
density greater than 1.40 pounds per
cubic foot, the HAP ABA formulation
limitation shall be zero.
(3) With the exception of those grades
for which the owner or operator has
designated zero as the HAP ABA
formulation limitation, the IFD and
density for each foam grade shall he
determined in accordance with
§63.1304(b) and recorded in accordance
with §63.1307(c)(l)(i)(B) or
§63.1307(c)(2)(i)(B) within 10 working
days of the production of the foam.
(e) Compliance using recovery
devices. If a recovery device is used to
comply with paragraphs (b) or (c) of this
section, the owner or operator shall
determine the allowable HAP ABA
emissions for each month using
Equation 2 in paragraph (b)(2) of this
section, and the actual monthly HAP
ABA emissions in accordance with
paragraph (e)(l) of this section. The
owner or operator shall also comply
with the provisions of paragraph (e)(2)
of this section.
(1) The actual monthly HAP ABA
emissions shall be determined using
Equation 4:
»ctual
-HAPABArecowed (Equation 4)
Where:
E.ciu.1 - Actual HAP ABA emissions
after control, pounds/month.
EUW - Uncontrolled HAP ABA
emissions, pounds/month.
determined in accordance with
paragraph (b) (1) of this section.
HAPABAr«ov«r«d - HAP ABA recovered.
pounds/month, determined in
accordance with paragraph (e)(2) of
this section.
(2) The amount of HAP ABA
recovered shall be determined in
accordance with § 63.1303(c).
§ 63.1298 Standards for slabstock flexible
polyurethane foam production—HAP
emissions from equipment cleaning.
Each owner or operator of a new or
existing slabstock affected source
complying with the emission point
specific limitation option provided in
§63.l293(a)(l) shall not use a HAP or a
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540D2 Federal Rcgister/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
HAP-based material as an equipment
cleaner.
§ 63.1299 Standards for slabstock flexible
polyurethane foam production—source-
wide emission limitation.
Each owner or operator of a new or
existing slabstock affected source
complying with the source wide
emission limitation option provided in
§63.1293(b) shall control HAP ABA
storage and equipment leak emissions.
HAP ABA emissions from the
production line, and equipment
cleaning HAP emissions in accordance
with the provisions in this section.
Compliance shall be determined on a
rolling annual basis in accordance with
paragraph (a) of this section. As an
alternative, the owner or cperator can
determine compliance monthly, as
described in paragraph (b) of this
section.
(a) Rolling annual compliance. Under
the rolling annual compliance
provisions, actual source wide HAP
ABA storage and equipment leak
emissions. HAP ABA emissions from
the production line, and equipment
cleaning HAP emissions are compared
to allowable source wide emissions for
each consecutive 12-month period. The
allowable source wide HAP emission
level is calculated based on the
production for the 12 month period,
resulting in a potentially different
allowable level for each 12-month
period. While compliance is on an
annual basis, compliance shall be
determined monthly for the preceding
12-month period. The actual source
wide HAP emission level for a
consecutive 12-month period shall be
determined using the procedures in
paragraphs (c)(l) through (4) of this
section, unless a recovery device is
used. Slabstock foam production
sources using recovery devices shall
determine actual source-wide HAP
emissions in accordance \vith paragraph
(e) of this section. The allowable HAP
emission level for a consecutive 12
month period shall be determined using
the procedures in paragraph (d) of this
section.
(b) Monthly compliance alternative.
As an alternative to determining
compliance on a rolling annual basis, an
owner or operator can determine
compliance by comparing actual HAP
emissions to allowable HAP emissions
for each month. The allowable source
wide emission level is calculated based
on the production for the month.
resulting in a potentially different
allowable level each month. The actual
monthly emission level shall be
determined using the procedures in
paragraphs (c)(l) through (3) of this
section, unless a recovery device is
used. Slabstock foam production
sources using recovery devices shall
determine actual source-wide HAP
emissions in accordance with paragraph
(e) of this section. The allowable
monthly HAP ABA emission level shall
be determined in accordance with
Equation 6.
(c) Procedures for determining actual
source wide HAP emissions. The actual
source wide HAP ABA storage and
equipment leak emissions. HAP ABA
emissions from the production line, and
equipment cleaning HAP emissions
shall be determined using the
procedures in this section. Actual
source-wide HAP emissions for each
individual month shall be determined
using thf procedures specified in
paragraphs (c)(l) through (3) of this
section.
(1) Actual source-wide HAP
emissions for a month shall be
determined using Equation 5 and the
information determined in accordance
with paragraphs (c)(2) and (3) of this
section.
PWE.cn,.! = 1(ST,. begm - ST, md + ADD,) (Equation 5)
Where:
iuai - Actual soijrre wide HAP
ARA and equipment cleaning HAP
emissions for a month, pounds
month.
n - Number of HAP ABA storage
vessels.
ST,. b«gm -- Amount of HAP ABA in
storage vessel i at the beginning of
the month, pounds, determined in
accordance with the procedures
listed in paragraph (c)(2) of this
section.
ST.. „* - Amount of HAP ABA in
storage vessel i at the end of the
month, pounds, determined in
accordance with the procedures
listed in paragraph (c)(2) of this
section.
ADD, - Amount of HAP ABA added to
storage vessel i during the month.
pounds, determined in accordance
with the procedures listed in
paragraph (c)(3) of this section.
(2) The amount of HAP ABA in a
storage vessel shall be determined by
monitoring the HAP ABA level in the
storage %'essel in accordance with
§63.1303(d).
(3) The amount of HAP ABA added to
a storage vessel for a given month shall
be the sum of the amounts of all
individual HAP ABA deliveries that
occur during the month. The amount of
each individual HAP ABA delivery
shall be determined in accordance with
§63.1303(e).
(4) Actual source-wide HAP
emissions for each consecutive 12
month period shall be calculated as the
sum of actual monthly source wide HAP
emissions for each of the individual 12
months in the period, calculated in
accordance with paragraphs (c) (1)
through (3) of this section.
(d) Allowable source-wide HAP
emissions for a consecutive 12-month
period shall be calculated as the sum of
allowable monthly source wide HAP
emissions for each of the individual 12
months in the period. Allowable source
wide HAP emissions for each individual
month shall be calculated using
Equation 6.
emss
illow. month
. (limit,) (polyol,)
100
j (Equation 6)
Where:
emiss.iiow, month - Allowable HAP A.BA
storage and equipment leak
emissions, HAP ABA emissions
from the production line, and
equipment cleaning HAP emissions
from the slabstock foam production
source for the month, pounds.
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Federal Register/Vol. 63, No. 194/Wednesday. October 7, 1998/Rules and. Regulations 54003
m - Number of slabstock foam
production lines.
polyoli - Amount of polyol used in the
month in the production of foam
grade i on foam production line j.
determined in accordance with
§ 63.1303(b), pounds.
n - Number of foam grades produced in
the month on foam production line
' J-
limit, = HAP ABA formulation limit for
foam grade i. pans HAP ABA per
100 parts polyol. The HAP ABA
formulation limits are determined
in accordance with § 63.1297(d).
(e) Compliance using recovery-
devices. If a recovery device is used to
comply with paragraphs (a) or (b) of this
section, the owner or operator shall
determine the allowable source-wide
HAP emissions for each month using
Equation 6 in paragraph (d) of this
section, and the actual monthly source
wide HAP emissions in accordance whh
paragraph (e)(l) of this section. The
owner or operator shall also comply
with the provisions of paragraph (e)(2)
of this section.
(1) Actual monthly source-wide HAP
emissions shall be determined using
Equation 7.
-HAPABArecowed (Equation 7)
Where:
E.ctu.1 - Actual source wide HAP
emissions after control, pounds/
month.
Eunc - Uncontrolled source wide HAP
emissions, pounds/month.
determined in accordance with'
paragraph (c) (1) through (3) of this
section.
HAPABArecov,r.d - HAP ABA recovered.
pounds/month, determined in
accordance with paragraph (e) (2) of
this section.
(2) The amount of HAP ABA
recovered shall be determined in
accordance with § 63.1303(c).
§63.1300 Standards for molded flexible
polyurethane foam production.
Each owner or operator of a ne\v or
existing molded affected source shall
comply with the provisions in
paragraphs (a) and (b) of this section.
(a) A HAP or HAP-based material
shall not be used as an equipment
cleaner to flush the mixhead. nor shall
it be used elsewhere as an equipment
cleaner in a molded flexible
polyurethane foam process, with the
following exception. Diisocyanates may
be used to flush the mixhead and
associated piping during periods of
startup or maintenance, provided that
the diisocyanate compounds are
contained in a closed loop system and
are re-used in production.
(b) A HAP-based mold release agent
shall not be used in a molded flexible
polyurethane foam source process.
§ 63.1301 Standards for rebond foam
production.
Each owner or operator of a new or
existing rebond foam affected source
shall comply with the provisions in
paragraphs (a) and (b) of this section.
(a) A HAP or HAP-based material
shall not be used as an equipment
cleaner at a rebond foam source.
(b) A HAP-based mold release agent
shall not be used in a rebond foam
source.
§ 63.1302 Applicability of subpart A
requirements.
The owner or operator of an affected
source shall comply with the applicable
requirements of subpart A of this part.
as specified in Table 2 of this subpart.
§63.1303 Monitoring requirements.
Owners and operators of affected
sources shall comply with each
applicable monitoring provision in this
section.
(a) Monitoring requirements for
storage vas.se/ carbon adsorption
systems. Each owner or operator using
a carbon adsorption system to meet the
requirements of §G3.1294(a) or .
§63.1295 shall monitor the
concentration level of the HAP or the
organic compounds in the exhaust vent
stream (or outlet stream exhaust) from
the carbon adsorption system at the
frequency specified in (a)(l) or (2) of
this section in accordance with either
(a) (3) or (4) of this section.
(1) The concentration level of HAP or
organic compounds shall be monitored
during each unloading event, or once
per month during an unloading event if
multiple unloading events occur in a
month.
(2) As an alternative to menthly
monitoring, the owner or operator can
set the monitoring frequency at an
interval no greater than 20 percent of
the carbon replacement interval, which
is established using a design analysis
described below in paragraphs (a)(l)(i)
through (iii) of this section.
(i) The design analysis shall consider
the vent stream composition.
constituent concentration, flow rate.
relative humidity, and temperature.
(ii) The design analysis shall establish
the outlet organic concentration level.
the capacity of the carbon bed. and the
working capacity of activated carbon
used for the carbon bed. and
(iii) The design analysis shall
establish the carbon replacement
interval based on the total carbon
working capacity of the carbon
adsorption system and the schedule for
filling the storage vessel.
(3) Measurements of HAP
concentration shall be made using 40
CFR part 60. appendix A. Method 18.
The measurement shall be conducted
over at least one 5 minute interval
during which the storage vessel is being
filled.
(4) Measurements of organic
compounds shall be made using 40 CFR
part 60, Appendix A. Method 25A. The
measurement shall be conducted over at
least one 5 minute interval during
which the storage vessel is being filled.
(b) Monitoring for HAP ABA and
poJyo] added to the foam production
line at the mixhead. (I) The owner or
operator of each slabstock affected
source shall comply with the provisions
in paragraph (b)(l)(i) of this section.
and. if applicable, the provisions of
paragraph (b)(l)(ii) of this section.
Alternatively, the owner or operator
may comply with paragraph (b) (5) of
this section.
(i) Owners or operators of all
slabstock affected sources shall
continuously monitor thp amount of
polyol added at the mixhead when foam
is being poured, in accordance with
paragraphs (b)(2) through (4) of this
section.
(ii) Owners or operators of slabstock
foam affected sources using the
emission point specific limitation
option provided in §G3.1293(a)(l) shall
continuously monitor the amount of
HAP ABA added at the mixhead when
foam is being poured, in accordance
with paragraphs (b)(2)(ii). (b)(3). and
(b)(4) of this section.
(2) The owner or operator shall
monitor either:
(i) Pump revolutions: or
• (ii) Flow rate.
(3) The device used to monitor the
parameter from paragraph (b)(2) shall
have an accuracy to within +/-2.0
percent of the HAP ABA being
measured, and shall be calibrated
initially, and periodically, in
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54004 Federal Register/Vol. 63, No. 194/Wednesday, October 7. 1998/Rules and Regulations
accordance with paragraph (b)(3)(i) or
(ii) of this section.
(i) For polyol pumps, the device shall
be calibrated at least once each 6
months.
(ii) For HAP ABA pumps, the device
shall be calibrated at least once each
month.
(4) Measurements must be recorded at
the beginning and end of the production
of each grade of foam within a run of
foam.
(5) As an alternative to the monitoring
described in paragraphs (b)(2) through
(4) of this section, the owner or operator
may develop an alternative monitoring
program. Alternative monitoring
programs must be submitted to the
Administrator for approval in the
Precompliance Report as specified in
§ 63.1306 (c) (4) for existing sources or in
the Application for approval of
construct ion or reconstruction for new
sources. If an owner or operator wishes
to develop an alternative monitoring
program after thp compliance date, the
program shall be submitted to the
Administrator for approval before the
owner or operator wishes to begin using
the alternative program. If the
Administrator does not notify the owner
or operator of objections to the program.
or any part of the program, within 45
days after its receipt, the program shall
be deemed approved. Until the program
is approved, the owner or operator of an
affected source remains subject to the
requirements of this subpan. The
components of an alternat ive
monitoring program shall include, at a
minimum, the items listed in
paragraphs (b)(5)(i) through (iv! of this
section.
(0 A description of the parameter to
be continuously monitored when foam
is being poured to measure the amount
of HAP ABA or polyol added at the
mixhead.
(ii) A description of how the
monitoring results will be recorded, and
how the results will be convened into
amount of HAP ABA or polyol delivered
to the mixhead.
(iii) Data demonstrating that the
monitoring device is accurate to within
+/-2.0 percent.
(iv) Procedures to ensure that the
accuracy of the parameter monitoring
results is maintained. These procedures
shall, at a minimum, consist of periodic
calibration of all monitoring devices.
(c) Recovered HAP ABA monitoring,
The owner or operator of each slabstock
affected source using a recovery device
to reduce HAP ABA emissions shall
develop and comply with a recovered
HAP ABA monitoring and
recordkeeping program. The
components of these plans shall
include, at a minimum, the items listed
in paragraphs (c)(l) through (5) of this
section. These plans must be submitted
for approval in accordance with
paragraph (c)(6) of this section.
(1) A device, installed, calibrated.
maintained, and operated according to
the manufacturer's specifications, that
indicates the cumulative amount of
HAP ABA recovered by the solvent
recovery device over each 1-month
period. The device shall be certified by
the manufacturer to be accurate to
within <•/-2.0 percent.
(2) The location where the monitoring
will occur shall ensure that the
measurements are taken after HAP ABA
has been fully recovered (i.e.. after
separation from water introduced into
the HAP ABA during regeneration).
(3) A description of the parameter to
be monitored, and the times the
parameter will be monitored.
(4) Data demonstrating that the
monitoring device is accurate to within
+ /— 2.0 percent.
(5) Procedures to ensure that the
accuracy of the parameter monitoring
results is maintained. These procedures
shall, at a minimum, consist of periodic
calibration of all monitoring devices.
(6) Recovered HAP ABA monitoring
and recordkeeping programs must be
submitted to the Administrator for
approval in the Precompliance Report as
specified in §63.1306(c)(G) for existing
sources or in the Application for
approval of construction or
reconstruction for new sources. If an
owner or operator wishes to develop a
recovered HAP ABA monitoring
program after the compliance date, the
program shall be submitted to the
Administrator for approval before the
owner or operator wishes to begin using
the program. If the Administrator does
not notify the owner or operator of
objections to the program within 45
days after its receipt, the program shall
be deemed approved. Until the program
is approved, the owner or operator of an
affected source remains subject to the
requirements of this subpart.
(d) Monitoring of HAP ABA in a
storage vessel. The amount of HAP ABA
in a storage vessel shall be determined
weekly by monitoring the HAP ABA
level in the storage vessel using a level
measurement device that meets the
criteria described in paragraphs (d)(l)
and either (d)(2) or (d)(3) of this section.
(1) The level measurement device
must be calibrated initially and at least
once per year thereafter.
(2) With the exception of visually-
read level measurement devices (i.e..
gauge glass), the device must have either
a digital or printed output.
(3) If the level measurement device is
a visually read device, the device must
be equipped with permanent graduated
markings to indicate HAP ABA level in
the storage tank.
(e) Monitoring of HAP ABA added to
a storage vessel. The amount of HAP
ABA added to a storage vessel during a
delivery shall be determined in
accordance with either paragraphs
(e)(l). (2), (3), or (4) of this section.
(1) The volume of HAP ABA added to
the storage vessel shall be determined
by recording the volume in the storage
vessel prior to the delivery and the
volume after the delivery, provided that
the storage tank level measurement
device used to determine the levels
meets the criteria in (d) of this section.
(2) The volume of HAP ABA added to
the storage vessel shall be determined
by monitoring the flow rate using a
device with an accuracy of ± 2.0
percent, and calibrated initially and at
least once each six months thereafter.
(3) The weight of HAP ABA added to
the storage vessel shall be calculated as
the difference of the full weight of the
transfer vehicle prior to unloading'into
the storage vessel and the empty weight
of the transfer vehicle after unloading
into the storage vessel. The weight shall
be determined using a scale meeting the
requirements of either paragraph
(e)(2)(i) or(ii) of this section.
(i) A scale approved by the State or
local agencies using the procedures
contained in Handbook 44.
Specifications. Tolerances, and Other
Technical Requirements for Weighing
and Measuring Devices 1998
(incorporation bv reference—see
§63.14).
(ii) A scale determined to be in
compliance with the requirements of the
National Institute of Standards and
Technology Handbook 44 at least once
per year by a registered scale technician.
(4) As an alternative to the monitoring
options described in paragraphs (e)(l)
through (e) (3) of this section, the owner
or operator may develop an alternative
monitoring program. Alternative
monitoring programs must be submitted
to the Administrator for approval in the
Precompliance Report as specified in
§ 63.1306(c) (4) for existing sources or in
the Application for approval of
construction or reconstruction for new
sources. If an owner or operator wishes
to develop an alternative monitoring
program after the compliance date, the
program shall be submitted to the
Administrator for approval before the
• owner or operator wishes to begin using
the alternative program. If the
Administrator does not notify the owner
or operator of objections to the program
within 45 days after its receipt, the
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Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations 54005
program shall be deemed approved.
Until the program is approved, the
owner or operator of an affected source
remains subject to the requirements of
this subpart. The components of an
alternative monitoring program shall
include, at a minimum, the items listed
in paragraphs (e)(3)(i) through (iv) of
this section.
(i) A description of the parameter to
be monitored to determine the amount
of HAP ABA added to the storage vessel
during a delivery.
(ii) A description of how the results
will be recorded, and how the results
will be converted into the amount of
HAP ABA added to the storage vessel
during a delivery.
(iii) Data demonstrating that the
monitoring device is accurate to within
±2.0 percent, and
(iv) Procedures to ensure that the
accuracy of the monitoring
measurements is maintained. These
procedures shall, at a minimum, consist
of periodic calibration of all monitoring
devices.
§ 63.1304 Testing requirements.
Owners and operators of affected
sources shall use the test methods listed
in this section, as applicable, to
demonstrate compliance with this
subpart.
(a) 7esr method and procedures in
deiermine equipment leaks. Monitoring.
as required tinder §63.1296. shall
comply with the following
requirements:
(1) Monitoring shall comply with
Method 21 of 40 CFR pan 60." appendix
A.
(2) The detection instrument shall
meet the performance criteria of Method
21 of 40 CFR pan 60. appendix A.
except that the instrument response
factor criteria in section 3.1.2(a) ol
Method 21 shall be for the average
composition of the source fluid, rather
than for each individual VOC in the
stream. For source streams that contain
nitrogen, air. or other inerts which are
not HAP or VOC. the average stream
response factor shall be calculated on an
inert-free basis. The response factor ma\
be determined at any concentration for
which monitoring for leaks will be
conducted.
(3) The instrument shall be calibrated
before use on each day of its use by the
procedures specified in Method 21 of 40
CFR part 60. appendix A.
(4) Calibration gases shall be:
(i) Zero air (less than 10 ppm of
hydrocarbon in air): and
(ii) A mixture of methane and air at
a concentration of approximately. 1.000
ppm for all transfer pumps: and 500
ppm for all other equipment, except as
provided in paragraph (a) (4) (iii) of this
section.
(iii) The instrument may be calibrated
at a higher methane concentration (up to
2.000 ppm) than the leak definition
concentration for a specific piece of
equipment for monitoring that piece of
equipment If the monitoring
instalment's design allows for multiple
calibration gas concentrations, then the
lower concentration calibration gas shall
be no higher than 2,000 ppm methane
and the higher concentration calibration
gas shall be no higher than 10.000 ppm
methane.
(5) Monitoring shall be performed
when tlie equipment is in HAP ABA
service, in use with an acceptable
surrogate volatile organic compound
which is not a HAP ABA. or is in use
with any other detectable gas or vapor.
(6) If ho instrument is available onsite
that will meet the performance criteria
specified in section 3.1.2(a) of Method
21 of 40 CFR Part 60. appendix A. the
readings from an available instrument
may be adjusted by multiplying by the
average response factor for the stream.
(b) Test method w determine foam
properties. The IFD and density of each
grade of foam produced during each run
of foam shall be determined using
ASTM D3574- 91. Standard Test
Methods for Flexible Cellular
Materials Slab. Bonded, and Molded
(incorporation by reference—see
§63.14). using a sample of foam cut
from the center of the foam bun. The
maximum sample size for which the JFD
and density is determined shall not be
larger than 24 inches by 24 inches bj 4
inches. For grades of foain where the
owner or operator has designated the
HAP ABA formulation limitation as
zero, the owner or operator is not
required to determine the IFD and
density in accordance with this
paragraph.
§63.1305 Alternative means of emission
limitation.
An owner or operator of an affected
source may request approval to use an
alternative means of emission
limitation, following the procedures in
this section.
(a) The owner or operator can request
approval to use an alternative means of
emission limitation in the
precompliance report for existing
sources, the application for construction
or reconstruction for new sources, or at .
anv time.
(b) This request shall include a
complete description of the alternative
means of emission limitation.
(c) Each owner or operator applying
for permission to use an alternative
means of emission limitation under
§63.6(g) shall be responsible for
collecting and verifying data to
demonstrate the emission reduction
achieved by the alternative means of
emission limitation.
(d) Use of the alternative means of
emission limitation shall not begin until
approval is granted by the
Administrator in accordance with
§63.6(g).
§63.1306 Reporting requirements.
Owners and operators of affected
sources shall comply with each
applicable reporting provision in this
section.
(a) Initial notification. Each affected
source shall submit an initial
notification in accordance with
§63.9(b).
(b) Application for approval of
construction or reconstruction. Each
owner or-operator shall submit an
application for approval of construction
or reconstruction in accordance with the
provisions of §63.5(d).
(c) Precompliance report. Each
slabstock affected source shall submit a
precompliance report no later than 12
months before the compliance date.
This report shall contain the
information listed in paragraphs (oil!
through (c)(8) of this section, as
applicable.
(1) Whether the source will comply
with the emission point specific
limitations described in §63.1293(a\ or
with the source-wide emission
limitation described in §G3.1293(b).
(2) For a source complying with the
emission point specific limitations.
whether the source will comply on a
rolling annual basis in accordance with
§63.1297(b). or will comply with the
monthly alternative for compliance
contained in §63.1297('d.
(3) For a source complying with the-
source wide emission limitation.
whether the source will comply on a
rolling annual basis in accordance \\ iih
§ 63.1299(a). or w^ill comply with the
monthly alternative for compliance
contained in §G3.1299(b).
(4) A description of how HAP ABA
and/or polyol added at the mixhead will
be monitored. If the owner or operator
is developing an alternative monitoring
program, the alternative monitoring
program containing the information in
§63.1303(b)(5)(i) through (iv) shall b-
subniitted.-
(5) Notification of the intent to use a
recovery device to comply with the
provisions of § 63.1297 or § 63.1299.
(6) For slabstock affected sources
complying with § 63.1297 or § 63.1299
using a recovery device, the continuous
recovered HAP ABA monitoring and
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54006 Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
recordkeeping program, developed in
accordance with §G3.1303(c).
(7) For sources complying with the
source-wide emission limitation, a
description of how the amount of HAP
ABA in a storage vessel shall be
determined.
(8) For sources complying with the
source wide emission limitation, a
description of how the amount of HAP
ABA added to a storage vessel during a
delivery will be monitored. If the owner
or operator is developing an alternative
monitoring program, the alternative
monitoring program containing the
information in §G3.1303(e)(4)(i) through
(iv) shall be submitted.
(9) If the Administrator does not
notify the owner or operator of
objections to an alternative monitoring
program submitted in accordance with
(c)(4) or (c)(G) of this section, or a
recovered HAP ABA monitoring and
recordkeeping program submitted in
accordance with (c)(7) of this section.
the program shall be deemed approved
45 days after its receipt by the
Administrator.
(d) Notification of compliance status.
Each affected source shall submit a
notification of compliance status report
no later than 180 days after the
compliancy date. For slabstork affected
sources, this report shall contain the
information listed in paragraphs (d)(l)
through (Ti of this section, as applicable.
This report shall contain thf
information listed in paragraph (d)(4) of
this section for molded foam processes
and in paragraph (di(5) for rebond foam
processes.
(1) A list of diisocyanate storage
vessels, along with a record of the type
of control utilized for each storage
vessel.
(2) For transfer pumps in diisocyanaie
service, a record of the type of control
utilized for each transfer pump.
(3) If the source is complying with the
emission point specific limitations of
§§63.1294 through 63.1298. the
information listed in paragraphs (b)(3)(i)
through (iii) of this section.
(i) A list of HAP ABA storage vessels.
along with a record of the type of
control utili/ed for each storage vessel.
(ii) A list of pumps, valves.
connectors, pressure-relief devices, and
open-ended valves or lines in HAP ABA
service.
(iii) A list of any modifications to
equipment in HAP ABA service made to
comply with the provisions of
§63.1296.
(4) A statement that the molded foam
affected source is in compliance with
§63.1300. or a statement that molded
foam processes at an affected sogrce are/
in compliance with § 63.1300.
(5) A statement that the rebond foam
affected source is in compliance with
§ 63.1301. or that rebond processes at an
affected source are in compliance with
§63.1301.
(e) Semiannual reports. Each
slabstock affected source shall submit a
report containing the information
specified in paragraphs (e)(l) through
(5) of this section semiannually no later
than 60 days after the end of each 180
day period. The first, report shall be
submitted no later than 240 days after
the date that the Notification oif
Compliance Status is due and shall
cover the 6 month period beginning on
the date that the Notification of
Compliance Status Report is due.
(1) For slabstock affected sources
complying with the rolling annual
compliance provisions of either
§63.1297 or §63.1299. the allowable
and actual HAP ABA emissions (or
allowable and actual source-wide HAP
emissions) for each of the 12-month
periods ending on each of the six
months in the reporting period. This
information is not required to be
included in the initial semi annual
compliance report.
(2) For sources complying with the
monthly compliance alternative of
either §63.1297 or § 63.1299. the
allowable and actual HAP ABA
emissions (or allowable and actual
source-wide HAP emissions) for each of
the six months in the reporting period.
(3) For sources complying with the
storage vessel provisions of §63.1294 (a)
or § 63.129f> using a carbon adsorption
system, unloading events that occurred
after breakthrough was detected and
before the carbon was replaced.
(4) Any equipment leaks that were not
repaired in accordance with
§63.1294(b)(2)(iii).§63.1294(c).
§63.1296(a)(2)(iii). (b)(2). (b)(3)(iv).
(bi(4)(v). (C)(2J. (c)(4)(ii). and (d)(2).
(5) Any leaks in vapor return lines
that were not repaired in accordance
with§63.1294(a)(l)(ii)or
§63.1295(b)(2).
(t) Other reports. (1) Change in
selected emission limitation. An owner
or operator electing to change their
slabstock flexible polyurethane foam
emission limitation (from emission
point specific limitations to a source
wide emission limitation, or vice versa).
selected in accordance with §63.1293.
shall notify the Administrator no later
than 180 days prior to the change.
(2) Change in selected compliance
method. An owner or operator changing
the period of compliance for either
§63.1297 or §63.1299 (between rolling
annual and monthly) shall notify the
Administrator no later than 180 days
prior to the change.
(g) Annual compliance certifications.
Each affected source subject to the
provisions in §§ 63.1293 through
63.1301 shall submit a compliance
certification annually. ,
(1) The compliance certification shall
be based on information consistent with
that contained in §63.1308 of this
section, as applicable.
(2) A compliance certification
required pursuant to a State or local
operating permit program may be used
to satisfy the requirements of this
section, provided that the compliance
certification is based on information
consistent with that contained in
§ 63.1308 of this section, and provided
that the Administrator has approved the
State or local operating permit program
under part 70 of this chapter.
(3) Each compliance certification
submitted pursuant to this section shall
be signed by a responsible official of the
company-that owns or operates the
affected source.
§63.1307 Recordkeeping requirements.
The applicable records designated in
paragraphs (a) through (c) of this section
shall be maintained by owners and
operators of all affected sources.
(a) Storage vessel records. (I) A list of
diisocyanate storage vessels, along widi
a record of the type of control utili7ed
for each storage vessel.
(2) For each slabstock affected source
complying with the emission point
specific limitations of §§ 63.129-1
through 63.1298. a list of HAP ABA
storage vessels, along with a record of
the type of control utilized for each
storage vessel.
(3) For storage vessels complying
through the use of a carbon adsorption
system, paragraph (a)(3)(i) or (ii). and
paragraph (a)(3)(iii) of this section.
(i) Records of dates and times when
the carbon adsorption system is
monitored for carbon breakthrough and
the monitoring device reading, when the
device is monitored in accordance with
§63.1303(a):or
(ii) For affected sources monitoring at
an interval no greater than 20 percent of
die carbon replacement interval, in
accordance with § 63.1303(a)(2). the
records listed in paragraphs (a)(3)(ii)(A)
and (B) of this section.
(A) Records of the design analysis.
including all the information listed in
§63.1303(a)(2)(i) through (iii). and
(B) Records of dates and times when
the carbon adsorption system is
monitored for carbon breakthrough and
the monitoring device reading.
(iii) Date when the existing carbon in
the carbon adsorption system is
replaced with fresh carbon.
(4) For storage vessels complying
through the use of a vapor return line.
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Federal Register/Vol. -63, No. 194/Wednesday, October 7, 1998/Rules and Regulations 54007
paragraphs (a)(4)(i) through (ill) of this
section.
(i) Dates and times when each
unloading event occurs and each
inspection of the vapor return line for
leaks occurs.
(ii) Records of dates and times when
a leak is detected in the vapor return
line.
(Hi) Records of dates and times when
a leak is repaired.
(b) Equipment leak records. (I) A list
of components as specified below in
paragraphs (b)(l)(i) and (ii).
(1) For all affected sources, a list of
components in diisocyanate service.
(ii) For affected sources complying
with the emission point specific
limitations of §§63.1294 through
63.1298. a list of components in HAP
ABA service.
(2) For transfer pumps in diisocyanate
service, a record of the type of control
utilized for each transfer pump and the
date of installation.
(3) When a leak is detected as
specified in §63.1294(b)(2)(ii).
§G3.1294(c). §63.1296(a)(2). (b)(l).
(c)(l), and (d)(l). the requirements listed
in paragraphs (b)(3)(i) and (ii) of this
section apply:
(i) Leaking equipment shall be
identified in accordance with the
requirements in paragraphs (b)(3)(i)(A)
through (C) of this section.
(A) A readily visible identification.
marked with the equipment
identification number, shall be attached
to the leaking equipment.
(B) The identification on a valve may
be removed-after it has been monitored
for 2 successive quarters as specified in
§G3.1296(b)(l) and no leak has been
detected during those 2 quarters.
(C) The identification on equipment.
other than a valve, may be removed after
it has been repaired.
(ii) The information in paragraphs
(b)(2)(ii)(A) through (H) shall be
recorded for leaking components.
(A) The instrument and operator
identification numbers and the
equipment identification number.
(B) The date the leak was detected
and the dates of each attempt to repair
the leak.
(C) Repair methods applied in each
attempt to repair the leak.
(D) The words "above leak definition"
if the maximum instrument reading
measured by the methods specified in
§ 63.1304 (a) after each repair attempt is
equal or greater than the leak definitions
for the specified equipment.
(E) The words "repair delayed" and
the reason for the delay if a leak is not
repaired within 15 calendar days after
discovery of the leak.
(F) The expected date of the
successful repair of the leak if a leak is
not repaired within 15 calendar days.
(G) The date of successful repair of
the leak.
(H) The date the identification is
removed.
(c) HAP ABA records. (1) Emission
point specific limitations-rolling
annual compliance and monthly
compliance alternative records. Each
slabstock affected source complying
with the emission point specific
limitations of §§63.1294 through
63.1298, and the rolling annual
compliance provisions of
§63.1297(a)(l). shall maintain the
records listed in paragraphs (c)(l)(i). (ii).
(iii). and (iv) of this section. Each
flexible polyurethane foam slabstock
source complying with the emission
point specific limitations of §§63.1294
through 63.1298. and the monthly
compliance alternative of
§63.1297(a)(2). shall maintain the
records listed in paragraphs (c)(l)(i). (ii).
and (iv) of this section.
(i) Daily records of the information
listed below in paragraphs (c)(l)(i)(A)
through (C) of this section.
(A) A log of foam runs each day. For
each run. the log shall include a list, of
the grades produced during the run.
(B) Results of the density and IFD
testing for each grade of foatn produced
during each run of foam, conducted in
accordance with the procedures in
§ 63.1304 (b). The results of this testing
shall be recorded within 10 working
days of the production of the foam. For
grades of foatn where the owner or
operator has designated the HAP ABA
formulation limitation as zero, the
owner or operator is not required to
keep records of the IFD and density.
(C) The amount of polyol added to the
slabstock foam production line at the
mixhead for each run of foam.
determined in accordance with
§63.1303(b).
(ii) Monthly records of the
information listed in paragraphs
(c)(l)(ii)(A) through (E) of this section.
(A) A listing of all foam grades
produced during the month.
(B) For each foam grade produced, the
HAP ABA formulation limitation.
calculated in accordance with
§63.1297(d).
(C) With the exception of those grades
for which the owner or operator has
designated zero as the HAP ABA
formulation limitation, the total amount
of polyol used in the month for each
foam grade produced.
(D) The total allowable HAP ABA
emissions for the month, determined in
accordance with § 63.1297(b)(2).
(E) The total amount of HAP ABA
added to the slabstock foam production
line at the mixhead during the month.
determined in accordance with
§63.1303(b).
(iii) Each source complying with the
rolling annual compliance provisions of
§ 63.1297(b) shall maintain the records
listed in paragraphs (c)(l)(iii)(A) and (B)
of this section.
(A) The sum of the total allowable
HAP ABA emissions for the month and
the previous 11 months.
(B) The sum of the total actual HAP
ABA emissions for the month and the
previous 11 months.
(iv) Records of all calibrations for
each device used to measure polyol and
HAP ABA added at the mixhead.
conducted in accordance with
§63.1303(b)(3).
(2) Source-wide limitations rolling
annual compliance and monthly
compliance alternative records. Each
slabstock affected source complying
with the source wide limitations of
§63.1299. and the rolling annual
compliance provisions in §G3.1299(a).
shall maintain the records listed in
paragraphs (c)(2)(i) through (c)(2)(viii of
this section. Each flexible polyurethane
foam slabstock source complying with
the source wride limitations of § 63.1299.
and the monthly compliance alternative
of §63.1299(b), shall maintain the
records listed in paragraphs (c)(21(ii
through (c)(2)(iii) and paragraphs
(c)(2)(v) through (c)(2)(vii) of this
section.
(i) Daily records of the information
listed in paragraphs (c)(2)li)(A) through
(C) of this section.
(A) A log of foam runs each day. For
each run. the log shall include a list of
the grades produced during the run.
(B) Results of the density and IFD
testing for each grade of foam produced
during each run of foam, conducted in
accordance with the procedures in
§G3.1304(b). The results of this testing
shall be recorded within 10 working
days of the production of the foam. For
grades of foam where the the owner 01
operator has designated the HAP ARA
formulation limitation as zero, the
owner or operator is not required to
keep records of the IFD and density.
(C) With the exception of those grades
for which the owner or operator has
designated zero as the HAP ABA
formulation limitation, the amount of
polyol added to'the slabstock foam
production line at the mixhead for each
grade produced during each run of
foam, determined in accordance with
§63.1303(b).
(ii) For sources complying with the
source-wide emission limitation, weekly
records of the storage tank level.
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54008 Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
determined in accordance with
§63.1303(d).
(Jii) Monthly records of the
information listed below in paragraphs
(c)(2Hiii)(A) through (E) of this section.
(A) A listing of all foam grades
produced during the month.
(B) For each foam grade produced, the
residual HAP formulation limitation.
calculated in accordance with
§63.1297(d).
(C) With the exception of those grades
for which the owner or operator has
designated zero as the HAP ABA
formulation limitation, the total amount
of poryol used in the month for each
foam grade produced.
(D) The total allowable HAP ABA and
equipment cleaning emissions for th»
month, determined in accordance with
§G3.1297(b)(2).
(E) The total actual source-wide HAP
ABA emissions for the month.
determined in accordance with
§ 63.1299(c) (1). along with the
information listed in paragraphs
(c)(2)(iii)(E)U) and (2) of this section.
(1) The amounts of HAP ABA in the
storage vessel at the beginning and end
of the month, determined in accordance
with §63.1299(c)(2): and
(2\ The amount of each delivery of
HAP ABA to the storage vessel.
determined in accordance with
§ 63.1299 (c) (3).
(iv) Each source complying with the
rolling annual compliance provisions of
§63.1299(a) shall maintain the records
listed in paragraphs (c)(2l(iv)(A) and (B)
of this section.
(A) The sum of the total allowable
HAP ABA and equipment cleaning HAP
emissions for the month and the
previous 11 months.
(B) The sum of the total actual HAP
ABA and equipment cleaning HAP
emissions for the month and the
previous 11 months.
(v) Records of all calibrations for each
device used to measure polyol added at
the mixhead. conducted in accordance
with§63.1303(b)(3).
(vi) Records of all calibrations for
each device used to measure the amount
of HAP ABA in the storage vessel.
conducted in accordance with
§63.13u3(d)(l).
(vii) Records to verify that all scales
used to measure the amount of HAP
ABA added to the storage vessel meet
the requirements of §G3.1303(e)(3). For
scales meeting the criteria of
§63.1303(e)(3)(i). this documentation
shall be in the form of written
confirmation of the State or local
approval. For scales complying with
§63.1303(e)(3)(ii). this documentation
shall be in the form of a report provided
by the registered scale technician.
(d) The owner or operator of each
affected source complying with
§ 63.1297 or § 63.1299 through the use
of a recovery device shall maintain the
following records:
(1) A copy of the recovered HAP ABA
monitoring and recordkeeping program.
developed pursuant to § 63.1303(c):
(2) Certification of the accuracy of the
monitoring device.
(3) Records of periodic calibration of
the monitoring devices.
(4) Records of parameter monitoring
results, and
(5) The amount of HAP ABA
recovered each time it is measured.
(e) The owner or operator of an
affected source subject to § 63.1298 of
this subpart shall maintain a product
data sheet for each equipment cleaner
used which includes the HAP content.
in kg of HAP/kg solids (Ib HAP/lb
solids).
(f) The owner or operator of an
affected source following the
compliance methods in §63.1308(b)(l)
and (c)(l) shall maintain records of each
use of a vapor return line during
unloading, of any leaks detected during
unloading, and of repairs ofleaks
detected during unloading.
(g) The owner or operator of an
affected source subject to § 63.1300 or
§63.1301 of this subpart shall maintain
a product data sheet for each compound
other than diisocyanates used to flush
the mixhead and associated piping
during periods of startup or
maintenance, which includes the HAP
content, in kg of HAP/kg solids (Ib HAP'
Ib solids), of each solvent other than
diisocyanates used to flush the mixhead
and associated piping during periods of
startup or maintenance.
(h) The owner or operator of an
affected source subject to § 63.1300 or •
§63.1301 of this subpart shall maintain
a product data sheet for each mold
release agent used that includes the
HAP content, in kg of HAP/kg solids (Ib
HAP/lb solids), of each mold release
agent.
§63.1308 Compliance demonstrations.
(a) For each affected source.
compliance with the requirements listed
in paragraphs (a)(l) through (a) (2) of this
section shall mean compliance with the
requirements contained in §§63.1293
through 63.1301. absent any credible
evidence to the contrary.
(1) The requirements described in
Tables 3. 4. and 5 of this subpart: and
(2) The requirement to submit a
compliance certification annually as
required under § 63.1306(g).
(b) All slabstock affecred sources. For
slabstock affected sources, failure to
meet the requirements contained in
§63.1294 shall be considered a violation
of this subpart. Violation of each item
listed in the paragraphs (b)(l) through
(b)(6) of this section, as applicable, shall
be considered a separate violation.
(1) For each affected source
complying with § 63.1294 (a) in
accordance with §63.1294(a)(l). each
unloading event that occurs when the
diisocyanate storage vessel is not
equipped with a vapor return line from
the storage vessel to the tank truck or
rail car, each unloading event that
occurs wlien the vapor line is not
connected, each unloading event that
the vapor line is not inspected for leaks
as described in §63.1294(a)(l)(i). each
unloading event that occurs after a leak
has been detected and not repaired, and
each calendar day after a leak is
detected, but not repaired as soon as
practicable:
(2) For each affected source
complying with § 63.1294 (a) in
accordance with §63.1294(a)(2). each
unloading event that the diisocyanate
storage vessel is not equipped with a
carbon adsorption system, each
unloading event (or each month if more
than one unloading event occurs in a
month) that the carbon adsorption
system is not monitored for
breakthrough in accordance with
§63.1303(a)(3) or (4). and each
unloading event that occurs when the
carbon is not replaced after an
indication of breakthrough:
(3) For each affected source
complying with §63.1294 (a) in
accordance with §63.1294 (a)(2) through
the alternative monitoring procedures in
§63.1303(a)(2). each unloading event
that the diisocyanate storage vessel is
not equipped with a carbon adsorption
system, each time that the carbon
adsorption system is not monitored for
breakthrough in accordance with
§63.1303(a)(3) or (4) at the interval
established in the design analysis, and
each unloading event that occurs when
the carbon is not replaced after an
indication of breakthrough:
(4) For each affected source
complying with §63.1294(b) in
accordance with §63.1294(b)(l). each
calendar day that a transfer pump in
diisocyanate service is not a sealless
pump:
(5) For each affected source
complying with § 63.1294(b) in
accordance with §63.1294 (b) (2). each
calendar day that a transfer pump in
diisocyanate service is not submerged as
described in §63.1294(b)(2)(i). each
week that the pump is not visually
monitored for leaks, each calendar day
after 5 calendar days after detection of
a leak that a first attempt at repair has
not been made in accordance with
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Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations 54009
§63.1294(b)(2)(iii)(B). and the earlier of
each calendar day after 15 calendar days
after detection of a leak that a leak is not
repaired, or a leak is not repaired as
soon as practicable, each subsequent
calender day (with the exception of
situations meeting the criteria of
§63.1294 (d)):
(6) For each affected source
complying with §63.1294(c). each
calendar day after 5 calendar days after
detection of a leak that a first attempt at
repair lias not been made, and the
earlier of each calendar day after 15
calendar days after detection of a leak
that a leak is not repaired, or if a leak
is not repaired as soon as practicable,
each subsequent calender day (with the
exception of situations meeting the
criteria of §63.1296(0).
(c) Slabstock affected sources
complying with the emission point
.specific limitations. For slabstock
affected sources complying with the
emission point specific limitations as
provided in §63.1293(a), failure to meet
the requirements contained in
§§63.1295 through 63.1298 shall be
considered a violation of this subpart.
Violation of each item listed in the
paragraphs (c)(l) through (c) (17) of this
section, as applicable, shall be
considered a separate violation.
(1) For each affected source
complying with § 63.1295(a) in
accordance with § 63.1295(b). each
unloading event that occurs when the
HAP ABA storage vessel is not equipped
with a vapor return line from the storage
vessel to the tank truck or rail car. each
unloading event that occurs when the
vapor line is not connected, each
unloading event that the vapor line is
not inspected for leaks as described in
§63.1295(b)(l). each unloading event •
that occurs after a leak has been
detected and not repaired, ana each
calendar day after a leak is detected but
not repaired as soon as practicable;
(2) For each affected source
complying with § 63.1295(a) in
accordance with §63.1295(c). each
unloading event that the HAP ABA
storage vessel is not equipped with a
carbon adsorption system, each
unloading event (or each month if more
than one unloading event occurs in a
month) that the carbon adsorption
system is not monitored for
breakthrough in accordance with
§63.1303(a)(3) or (4). and each
unloading event that occurs when the
carbon is not replaced after an
indication of breakthrough:
(3) For each affected source
complying with § 63.1295(a) in
accordance with § 63.1295 (c) through
the alternative monitoring procedures in
§63.1303(a)(2). each unloading event
that the HAP ABA storage vessel is not
equipped with a carbon adsorption
system, each time that the carbon
adsorption system is not monitored for
breakthrough in accordance with
§63.1303(a)(3) or (4) at the interval
established in the design analysis, and
each unloading event that occurs when
the carbon is not. replaced after an
indication of breakthrough:
(4) For each affected source
complying with § 63.1296(a) in
accordance with § 63.1296 (a) (1). each
calendar day that a transfer pump in'
HAP ABA service is not a seal less
pump:
(5) For each affected source
complying with § 63.1296(a) in
accordance with §63.1296(a)(2). each
week that a visual inspection of a pump
in HAP ABA service is not performed.
each quarter that a pump in HAP ABA
service is not monitored to detect, leaks
in accordance with §63.1304(a). each
calendar day after 5 calendar days after
detection of a leak that a first attempt at
repair has not been made in accordance
with §63.1296(b)(2)(iii)(B). and the
earlier of each calendar day after 15
calendar days after detection of a leak
that a leak is not repaired, or if a leak
is not repaired as soon as practicable,
each subsequent calender day (with the
exception of situations meeting the
criteria of §63.1296(0):
(6) For each affected source
complying with §63.1296(b) in
accordance with §63.1296(b)(l) and <2).
each quarter that a valve in HAP ABA
service is not monitored to detect leaks
in accordance with §63.1304(a), each
calendar day after 5 calendar days after
detection of a leak that a first attempt at
repair has not been made in accordance
with §63.1296(b)(2)(ii). and each
calendar day after 15 calendar days after
detection of a leak that a leak is not
repaired, or if a leak is not repaired as
soon as practicable, whichever is earlier
(with the exception of situations
meeting the criteria of § 63.1296(f)):
(7) For each affected source
complying with §63.1296(b)(3) for each
valve designated as unsafe to monitor as
described in §63.1296(b)(3)(i). failure to
develop the written plan required by
§63.1296(b)(3)(ii), each period specified
in the written plan that an unsafe to
monitor valve in HAP ABA service is
not monitored, and each calendar day in
which a leak is not repaired in
accordance with the written plan:
(8) For each affected source
complying with §63.1296(b)(4) for one
or more valves designated as difficult-
to-monitor in accordance with
§63.1296(b)(4)(i) and (ii). failure to
develop the written plan required by
§63.1296(b)(4)(iii). each calendar year
that a difficult to monitor valve in HAP
ABA service is not monitored, and each
calendar day in which a leak is not
repaired in accordance with the written
plan:
(9) For each affected source
complying with § 63.1296(c) in
accordance with §63.1296(c)(l) and (2).
each year that a connector in HAP ABA
service is not monitored to detect leaks
in accordance with §63.1304(a): each
calendar day after 3 months after a
connector has been opened, has
otherwise had the seal broken, or a leak
is repaired, that each connector in HAP
ABA service is not monitored to detect
leaks in accordance with §63.1304(a);
each calendar day after 5 calendar days
after detection of a leak that a first
attempt at repair has not been made.
and the earlier of each calendar day
after 15 calendar days after detection of
a leak that a leak is not repaired, or if
a leak is not repaired as soon as
practicable, each subsequent calendar
day (with the exception of situations
meeting the criteria of §63.1296(0):
(10) For each affected source
complying with § 63.1296(c) (3) lor one
or more connectors designated as
unsafe-to monitor in accordance with
§63.1296(c)(3)(i). failure to develop the
written plan required by
§63.1296(c)(3)(ii). each period specified
in the written plan that an unsafe to
monitor valve in HAP ABA service is
not monitored, each calendar day after
5 calendar days after detection of a leak
of an unsafe-to monitor connector that a
first attempt at repair has not been
made, and the earlier of each calendar
day after 15 calendar days after
detection of a leak that a leak is not
repaired, or if a leak is not repaired as
soon as practicable, each subsequent
calender day (\vith the exception of
situations meeting the criteria of
§63.1296(0):
(11) For each affected source
complying with § 63.1296(c)(4) for one
or more connectors designated as unsafe
to repair, each year that one or more
unsafe-to repair connectors in HAP
ABA service is not monitored to detect
leaks in accordance with §63.1304(a):
each calendar day after 3 months after
one or more unsafe to repair connectors
has been opened, has otherwise had the
seal broken, or a leak is repaired, that
each unsafe-to-repair connector in HAP
ABA service is not monitored to detect
leaks in accordance with § 63.1304 (a):
and the earlier of each calendar day
after six-months after detection of a leak
that a leak is not repaired, or if a leak
is not repaired as soon as practicable.
each subsequent calendar day;
(12) For each affected source
complying with § 63.1296(d) in
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54010 Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
accordance with §62.1296(d)(l) and (2),
each calendar day after the 5 days that
the pressure relief device has not been
monitored in accordance with
§63.1304 (a) after a potential leak was
discovered as described in
§63.1296(d)(l). each calendar day after
5 calendar days after detection of a leak
that a first attempt at repair has not been
made, and the earlier of each calendar
day after 15 calendar days after
detection of a leak that a leak is not
repaired, or if a leak is detected and not
repaired as soon as practicable, each
subsequent calendar day (with the
exception of situations meeting the
criteria of §63.1296(0):
(13) For each affected source
complying with § 63.1296 (e) in
accordance with § 63.1296(e)(l) through
(5). each calendar day that an open-
ended valve or line has no cap. blind
flange, plug or second valve as
described in §63.1296fe)(2). and each
calendar day that a valve on the process
fluid end of an open ended valve or line
equipped with a second valve is not
closed before the second valve is closed:
(14) For each affected source
complying with § 63.1297(a) in
accordance with the rolling annual
compliance option in §63.1297(a)(l)
and (b). each calendar day in the 12-
month period for which the actual HAP
ABA emissions exceeded the allowable
HAP ABA emissions level, each
calendar day in which foam is being
poured where the amount of polyol
added at the mixhead is not monitored
(as required) in accordance with
§63.1303(b)(l)(i). each calendar day in
which foam is being poured where the
amount of HAP ABA added at the
mixhead is not monitored (as required)
in accordance with §63.1303(b)(l)(ii).
each calendar day in a 6 month peiiori
in which the polyol pumps are not
calibrated in accordance with
§63.1303(b)(3)(i), each calendar day in
a month in which the HAP ABA pumps
are not calibrated in accordance with
§63.1303(b)(3)(ii). and each calendar
day after 10 working days after
production where the IFD and density
of a foam grade are not determined
(where required) in accordance with
§ 63.1304 (b):
(15) For each affected source
complying with § 63.1297(a) in
accordance with the monthly
compliance option in §63.1297(a)(2)
and (c). each calendar day of each
month for which the actual HAP ABA
emissions exceeded the allowable HAP
ABA emissions level for that month.
each calendar day in which foam is
being poured where the amount of
polyol added at the mixhead is not
monitored (as required) in accordance
with §G3.1303(b)(l)(i). each calendar
day in which foam is being poured
where the amount of HAP ABA added
at the mixhead is not monitored (as
required) in accordance with
§63.1303(b)(l)(ii), each 6-month period
in which the polyol pumps are not
calibrated in accordance with
§63.1303(b)(3)(i), each month in which
the HAP ABA pumps are not calibrated
in accordance with §63.1303(b)(3)(ii).
and each calendar day after 10 working
days after production where the IFD and
density of a foam grade are not
determined (where required) in
accordance with § 63.1304(b):
(16) For each affected source
complying with §63.1297(a) by using a
recovery device as allowed under
§63.1297(e). the items listed in (c)(16)(l)
or (ii) of this section, as applicable.
(i) If complying with rolling annual
compliance option in §63.1297(a)(l)
and (b). each item listed in (c)(14) of this
section, failure to develop a recovered
HAP ABA monitoring and
recordkeeping program in accordance
with §63.1303(c). and each instance
when an element of the program is not
followed.
(ii) If complying with the monthly
compliance option in §63.1297(a)(2)
and (c). each item listed in (c)(15) of this
section, failure to develop a recovered
HAP ABA monitoring and
recordkeeping'program in accordance
with §63.1303(c). and each instanr ;•
when an element of the program is not
followed.
(17) For each affected source
complying with §63.1298. each
calendar day that a HAP or any HAP
based material is used as an equipment
cleaner.
(d) Slabstnck affected sources
complying with the source- wide
emission limitation. For slabstock
affected sources complying with the
source-wide emission limitation as
provided in §63.1293(b). failure to meet '
the requirements contained in §63.1299
shall be considered a violation of this
subpart. Violation of each item listed in
the paragraphs (d)(l) through (d)(3) of
this section, as applicable, shall be
considered a separate violation.
(1) For each affected source
complying with §63.1299 in accordance
with the rolling annual compliance
option in §63.1299(a). each calendar
day in the 12-month period for which
the actual HAP ABA emissions
exceeded the allowable HAP ABA
emissions level, each calendar day in
which foam is being poured where the
amount of polyol added at the mixhead
.is not monitored (as required) in
accordance with §63.1303(b)(l)(i). each
calendar day in a week in which the
amount of HAP ABA in a storage vessel
is not determined in accordance with
§G3.1303(d). each delivery of HAP ABA
in which the amount of HAP ABA
added to the storage vessel is not
determined in accordance with
§63.1303(e), each calendar day in a 6-
month period in which the polyol
pumps are not calibrated in accordance
with§63.1303(b)(3)(i). and each
calendar day after 10 working days after
production where the IFD and density
of a foam grade are not determined
(where required) in accordance with
§63.1304(b):
(2) For each affected source
complying with § 63.1299 in accordance
with the monthly compliance option in
§ 63.1299(b), each calendar day of each
month for which the actual HAP ABA
emissions exceeded the allowable HAP
ABA emissions level for that month.
each calendar day in which foam is
being poured where the amount of
polyol added at the mixhead is not
monitored (as required) in accordance
with §63.1303(b)(l)(i). each calendar
day in a week in which the amount, of
HAP ABA in a storage vessel is not - •
determined in accordance with
§ 63.1303(d). each delivery of HAP ABA
in which the amount of HAP ABA
added to the storage vessel is not
determined in accordance with
§63.1303(e). and each calendar day in a
6 month period in which the polyol
pumps are not calibrated in accordance
with §63.1303(b)(3)(i). and each
calendar day after 10 working days after
production where the IFD and density
of a foam grade are not determined
(where required) in accordance with
§ 63.1304 (b).
(3) For each affected source
complying with § 63.1299 by using a
recovery device as allowed under
§63.1299(e). the items listed in (d)(3)(i)
or (ii) of this section, as applicable.
(i) If complying with rolling annual
compliance option in §63.1299(a). each
item listed in (d)(l) of this section.
failure to develop a recovered HAP ABA
monitoring and recordkeeping program
in accordance with §63.1303(c). and
each instance when an element of the
program is not followed.
(ii) If complying with the monthly
compliance option in § 63.1299(b), each
item listed in (d)(2) of this section.
failure to develop a recovered HAP ABA
monitoring and recordkeeping program
in accordance with §63.1303(c). and
each instance when an element of the
program is not followed.
(e) Molded and rebond foam affected
sources. For molded and rebond foam
affected sources, failure to meet the
requirements contained in §63.1300
and §63.1301. respectively, shall be
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Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations 54011
considered a violation of this subpart.
Violation of each item listed in the
following paragraphs shall be
considered a separate violation.
(1) For each molded foam affected
source subject to the provisions in
§63.1300(a). each calendar day that a
HAP based material is used as an
equipment cleaner (except for
diisocyanates used to flush the mixhead
and associated piping during periods of
startup or maintenance, provided that
the diisocyanate compounds are
contained in a closed loop system and
are re-used in production):
(2) For each molded foam affected
source subject to the provisions of
§63.1300(b), each calendar day that a
HAP-base material is used as a mold
release agent:
(3) For each rebond foam affected
source subject to the provisions of
§ 63.1301 (a), each calendar day that a
HAP-based material is used as an
equipment cleaner; and
(4) For each rebond foam affected
source complying with § 63.1301 (b).
each calendar day that a HAP based
mold release agent is used.
§63.1309 Delegation of authority.
(a) In delegating implementation and
enforcement authority to a State under
§ 112(d) of the Clean Air Act. the
authorities contained in paragraph (b) of
this section shall be retained by the
Administrator and not transferred to a
State.
(b) The authority conferred in
§63.1303(b)(5) and §63.1305(d) shall
not be delegated to any State.
Appendix to Subpart HI—Tables
For the convenience of the readers of
subpart III, the tables below summarize
the requirements in §§63.1290 to
63.1307. These tables are intended to
assist the reader in determining the
requirements applicable to affected
sources and do not alter an .iffected
source's obligation to comply with the
requirements in §§ 63.1290 to 63. ] 307.
TABLE 1 TO SUBPART III HAP
ABA FORMULATION LIMITATIONS
MATRIX FOR NEW SOURCES (see
§63.1297(d)(2)]
Values in
parts ABA
per
hundred
parts
polyol
Density ranges (pounds per cubic
foot)
0-
0.95
0.96-
1.05
1.06-
1.15
1.16-
1.40
1.41 +
IFD
0-10
11-15
Use Equation 3
16-20
21-25
26-30
31 +
0
TABLE 2 TO SUBPART III—APPLICABILITY OF GENERAL PROVISIONS (40 CFR PART 63, SUBPART A) TO SUBPART
Subpart A reference
§63.1
§63.2
§63.3
§63.4
§63.5
§63.6 (a Hd)
§63.6(e) (1H2)
§63.6(e)(3)
§63.6 (fWfl)
: Applies to
j subpart III
; YES
YES
YES
YES
YES
YES
YES
: NO
.... ' YES
Comment
Except that §63 1(c)(2) is not applicable to the extent area sources are
part III.
Definitions are modified and supplemented by §63 1292.
Owners and operators of subpart III affected sources are not required to
ment a startup, shutdown, and malfunction plan.
not subject to sub-
develop and imple-
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54012 Federal Register/Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations
TABLE 2 TO SUBPART III—APPLICABILITY OF GENERAL PROVISIONS (40 CFR PART 63, SUBPART A) TO SUBPART III.—
Continued
Subpart A reference
§63.6(h)
§63.6 OHJ)
5637
§63.8
§63.9 (aHd)
§639 (eH9)
§639(h)
§63.9(i)-(j)
56310 (a Mb)
§6310(c)
§63.10(d)(1)
§6310 (d)(2H3)
§63 10 (d) (4M5)
§63 10(e)
§6310(0
§6311
§6312
§63 13
§6314
563.15
Applies to
| subpart III
NO
YES
I NO
! NO
YES
NO
NO
YES
YES
NO
YES
NO
YES
NO
: YES
YES
YES
YES
YES
YES
Comment
Subpart III does not require opacity and visible emission standards.
Performance tests not required by subpart III
Continuous monitoring, as defined in subpart A, is not required by subpart III.
Subpart III specifies Notification of Compliance Status requirements.
Except that the records specified in §63.10(b)(2)(vi) through (xi) and (xiii) are not required.
TABLE 3 TO SUBPART III.—COMPLIANCE REQUIREMENTS FOR SLABSTOCK FOAM PRODUCTION AFFECTED SOURCES
COMPLYING WITH THE EMISSION POINT SPECIFIC LIMITATIONS
Emission point
Emission point com-
pliance option
Emission, work.
practice, and equip-
ment standards
Monitoring
Recorc'keeping
Reporting
Diisocyanate storage
vessels
§63.1294(a)
Diisocyanate transfer
pumps
§63.1294(b)
Other components in
diisocyanate serv-
ice §63.1294(c)
HAP ABA storage
vessels § 63 1295
HAP ABA pumps
§63.1296(a):
HAP ABA valves
§63.1296(b):
HAP ABA Connec-
tors §63.1296(c):
Vapor balsnce §63.1294(a)(1) and §63.1294(a)(1)(i) .... §63.1307(3)0) and (4) ; §63.1306(e)(5).
(1)00
Carbon adsorber
i §63.1294(a)(2) §63.1303
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Federal Register /Vol. 63, No. 194/Wednesday, October 7, 1998/Rules and Regulations 54013
TABLE 3 TO SUBPART III.—COMPLIANCE REQUIREMENTS FOR SLABSTOCK FOAM PRODUCTION AFFECTED SOURCES
COMPLYING WITH THE EMISSION POINT SPECIFIC LIMITATIONS—Continued
Emission point
Pressure-reltef d6-
vices § 63.1 296(d)
or lines '
§63.1296(e).
§63.1297.
§63.1298
Emission point com-
pliance option
N/A
N/A
pliance.
Monthly compliance
Compliance Using a
Recovery device.
N/A
Emission, work
practice, and equip-
ment standards
§63.1296(d)and
«J)(2).
5631296(e)
§631297(a)(1)and
(b).
§63 1297(a)(2) and
(c).
S631*>97(aH1) (b)
and (e) for rolling
annual compli-
ance or
§63.1297(a)(2),
(c), and (e) for
monthly compli-
ance.
§ 63 1 298
Monitoring
§63.1 296 (d)(1) and
§63.1304(a).
§63 1303 {b)
§631303 (b)
§631303 (b) and
(c).
Recordkeeping
§63.1307(b)(1)(ii)and(3)
§63.1307 (b)(1)(ii)
S631307(c)(1)
§631307(c)(1)
§63 1307(c)(1) and (d)
§631307(e)
Reporting
§63.1306(e)(4).
§631306(e)(1).
§63.1306(e)(2).
§63. 1306(e)(1) or
(2).
TABLE 4 TO SUBPART
I.—COMPLIANCE REQUIREMENTS FOR SLABSTOCK FOAM PRODUCTION AFFECTED SOURCES
COMPLYING WITH THE SOURCE-WIDE EMISSION LIMITATION
Emission point
Diisocyanate storage
vessels
§63.1294(a).
Diisocyanate transfer
pumps
§631294(b)
Other components in
diisocyanate serv-
ice §63.1294(c)
HAP ABA storage
vessels, equipment
leaks, production
line, and equip-
ment cleaning.
Emission point com-
pliance option
Vapor balance
Carbon adsorber
Carbon adsorber —
alternative mon-
itoring
Sealless pump
Submerged pump ..
N/A
Rolling annual com-
pliance.
Monthly compliance
Compliance Using a
Recovery device.
Emission, work
practice, and equip-
ment standards
§63 1294(a)(1) and
(1)(«)
§631294(a)(2) ..
§63.1294(a)(2)
§63 1294(b)(1)
§63.1294(b)(2)(i)
and (iii).
§ 63 1 294(c)
$631299(3) (c)(1)
through (4). and
(d).
5631299(b) (cXD
through (4). and
(d).
§ 63 1 299(a) (d)
and (e) for rolling
annual compli-
ance or
§63.1299(b), (d),
and (e) for
monthly compli-
ance.
Monitoring
§ 63 1 294(a)(1 )(i)
§631303(a)(1). (3),
and (4).
§63.1303(a)(2). (3)
and (4)
§63.1 294 (b)(2)(ii)..
§ 63 1 294(c)
§ 63 1 303 (b) ex-
, cept(b)(1)(ii). (d),
| and (e)
§ 63 1 303 (b) ex-
. cept(b)(1)(ii), (d).
and (e).
1 § 63 1 303 (b) ex-
i cept(b)(1)(ii)and
| (c).
i
! Recordkeeping
• §63.1307(a)(1) and (4)
§63.1307(a)(1), (3)(i). and
'•• (3)(Hi).
§63.1307(a)(1), (3)(ii). and
(3)(iii).
' §63.1307 (b)(1)(i) and (2) .....
§63.1 307 (b)(1)(i). (2), and (3)
§63.1307 (b)(1 )(i) and (3)
§631307(c)(2)
; § 63 1 307(c)(2)
§63 1307(c)(2) and (d)
I
i
i
I
i
i
Reporting
§63.1306(e)(5)
§63.1306(eK3)
§63.1306(e)(3)
§63.1306(eK4).
§63.1306(e)(4)
§63.1306(e)(H
§63 1306(e)(2)
§63 1306(e)(1) or
(2).
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54014 Federal Register/Vol. 63, No. 194 / Wednesday, October 7, 1998/Rules and Regulations
TABLE 5 TO SUBPART III. — COMPLIANCE REQUIREMENTS FOR MOLDED AND REBOND FOAM PRODUCTION AFFECTED
SOURCES
Emission point
Molded Foam
Equipment cleaning ..
Mold release agent ..
Rebond Foam
Equipment cleaning ..
Mold release agent ..
Emission point com-
pliance option
N/A
N/A
N/A
N/A
Emission, work
practice, and equip-
ment standards
§ 63 1 300(a)
§ 631300{b)
§63 1301 (a)
563 130Ub)
Monitoring
Recordkeeping
§631307(9)
§63.1307 (h)
§63 1307 (g)
§63.1307 (h)
Reporting
[FRDoc. 98-25894 Filed 10-6-98. 8:45 am]
BILLING CODE 6560-SO-P
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TECHNICAL REPORT DATA
1. REPORT NO.
EPA-456/B-98-001
2. 3 RECIPIENTS ACCESSION NO.
4 TITLE AND SUBTITLE
The Plain Language Guide to the Flexible Polyurethane Foam Production
NESHAP (40 CFR 63, Subpart HI)
7. AUTHOR(S)
Ingrid Ward, EPA/OAQPS/TTPID/PRG
Janet McDonald, EC/R, Incorporated
9 PERFORMING ORGANIZATION NAME AND ADDRESS
ECR
i: SPONSORING AGENT':' NAME AND ADDRESS
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
5 REPORT DATE
December 1998
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION' REPORT NO
10. PROGRAM ELEMENT NO
11 CONTRACT/GRANT NO
68D30008
13 TYPE OF RF-ORT AND PERIOD COVERED
Final
14 SPONSORING AGENCY CODE
EPA/200/04
15 SUPPLEMENTARY NOTES
Project Officer is Carolyn Wigington. Mail Drop 13 (919-541-5374)
Work Assignment Manager is Ingrid Ward. Mail Drop 12 (919-541-0300)
16 ABSTRACT
National emissions standards to control emissions of HAP from major sources producing flexible polyurethane
foam were published in Federal Register 10/7/98. 63 FR 53996. This document contains information to help
State and local agencies for air pollution control as well as the regulated community, cam out these standards.
The document summarizes the NESHAP requirements and provides example calculations, inspection
checklists, and example notification and reporting forms. The document also provides information on where to
submit reports, go to for additional help and applicability of foam sources to such things as General Provisions
and Title V. A copy of the rule is provided in hard copy format. An electronic version of this document can be
download at Mint . epa.gov nn uanv foram foampg.html.
17. KEY WORDS AND DOCUMENT ANALYSIS
a DESCRIPTORS
b IDENTIFIERS'OPEN ENDED TERMS c. COSATI
Air pollution Title III Air pollution control
Air pollution control NESHAP Flexible Polyurethane Foam
National emissions standards Compliance Slabstock Foam
Hazardous air pollutants 40 CFR 63 Molded
Flexible Polvurethane Foam Subpart III Rebond
18 DISTRIBUTION STATEMENT
Unlimited
19 SECURITY CLASS (Report; 21. NO. OF PAGES
Unclassified 216 (nard COP>')
155 (UATW)
20. SECURITY CLASS (Page) 22. PRICE
Unclassified no cost
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