United States
Environmental Protection
Agency
www.epa.gov/ttn/uatw/foam/foampg.html
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-456/B-98-001
December 1998 (updated 4/27/04)
EPA
Plain Language Guide to the Flexible
Polyurethane Foam Production NESHAP
40 CFR 63, Subpart III
-------
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, NC 27713
December 31, 1998
-------
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.
l
-------
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
Perry 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
Mary 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.
11
-------
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 rule? 4
When do I need to comply? 5
Are any processes exempt? 5
How do I know if I have a covered process? 6
Does this rule apply to fabrication of foam? 6
What are my requirements for slabstock foam? 6
What are my requirements for molded and rebond foam? 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
iii
-------
What reports must I submit?
Contents
13
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 available? 69
Chapter 5 - Complying with requirements for rebond foam
What does the Rebond section cover? 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 I show compliance? 75
iv
-------
Is an inspection checklist available? 75
Contents
Chapter 6 - Calculations and procedures
How do I calculate Hazardous Air Pollutants used (HAPused) 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? 90
If I'm complying with the sourcewide emission limit without using a recovery device,
how do I calculate actual sourcewide HAP emissions? 91
If I'm complying with the sourcewide emission limit using a recovery device,
how do I calculate actual emissions? 92
How can I check my slabstock process for leaks? 95
Chapter 7 - Notification and reporting
What do I have to report and when? 99
How can I change the date my reports are due? 99
Where do I send my reports? 99
Where do I submit my Alternative Program? 100
Can I get example reporting forms? 101
v
-------
Initial Notification Report 101
Application for Approval of Construction or Reconstruction 110
Precompliance Report 115
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 a title 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 help? 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
vi
-------
Figure 3.3 - Option 2, Sourcewide Emission Limit 16
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
vii
-------
Appendices
A - Contents for Subpart III, Final Rule
-------
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 document, 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 Keep informed ofmle changes by checking the
periodically checking the Federal Register Federal Register
and the Code of Federal Regulations
(CFR). You can download Federal
Register notices by going to the Government Printing Office (GPO) website at
www.access.gpo.gov/su_docs/aces/acesl40.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/ttn/uatw). Look under Rules and
Implementation, flexible polyurethane foam, or www.epa.gov/ttn/uatw/foam/foampg.html
• Library Services Office, (MD-35), U.S. EPA, Research Triangle Park, NC 27711, or
www.epa.gov/natlibra/ols.html (limited supply)
1
-------
• National Technical Information Services (NTIS), 5285 Port Royal Road, Springfield,
VA 22161, or 1 -(800)- 553-6847, or www.fedworld.gov/ntis/ntishome.html (NTIS
will charge you a fee for this document)
• National Center for Environmental Publications and Information, l-(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
survey
2
-------
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
Q
1. What type of business do you work for? (check one of the following)
Manufacturing Q Contractor Q Tribe Q Government (specify Federal, State, local)
Other
2. What are your job responsibilities? (check any that apply)
Plant Operator Q Maintenance Q Plant Manager Q Environmental Staff Q
Regulator Q Other:
3. How did you hear about this guidance? (check any that apply)
Co-worker Q EPA TTN via dial up modem Q EPA TTN via the Web Q 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
1
2
3
4
5
N/A
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 this document into our own policy documents.
The format of this document was well organized and easy to understand.
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 Q very useful Q so-so useful Q not useful at all Q
3
-------
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 (RTP) MD-12, Research Triangle Park, NC 27711, or fax (919) 541-2664
4
-------
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
5
-------
http://www.epa. gov/ttn/uatw/188polls.txt.
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 Yourfacility is a major source if it can potentially emit >10 tons
be a major source and not per year of a single HAP or > 25 tons per year of all HAPs.
subject to this rule. If,
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 is
Then you're1...
And must comply ...
on or before 12-27-96
an existing source
by 10/8/01
after 12-27-96
a new source
upon initial startup
'When detennining if a source is new or existing, the General Provisions (40 CFR 63,
Subpart A, §63.2) requires us to use the proposal date of the rule as the cut-off date. In
the case of Subpart III, 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 If your process is exempt, make
, • , .i.ri - x- n -ii sure you document why it's exempt
• exclusively dedicated to iabricating flexible 7 _
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.
6
-------
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 '11 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 these 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 polyurethane foam will fall under a different rule - the
Flexible Polyurethane Foam Fabrication NESHAP. We expect to publish this rule in 2000.
What are my requirements for slabstock foam?
The rules for producing slabstock foam cover the two major uses of HAP in the slabstock
process:
Definition. The rule defines "foam fabrication " as a operation for
cutting or bonding flexible polyurethane foam pieces together or to
other substrates. Typical bonding techniques include gluing, taping,
and flame lamination.
• diisocyanates used as a reactant in making foam
See Chapter 3 for
details about your
compliance options
for slabstock foam
• HAP used as an auxiliary blowing agent (ABA) and for
equipment cleaning
7
-------
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
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.
8
-------
9
-------
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 diisocyanate 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 polyurethane foam that is produced in large
continuous buns that are then cut into the desired size and
shape."
About this Chapter:
Whenever you see "§,'
we are referring to the
section number of the
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."
section in the rule for
more information
rule. You can go to that
Definition. Flexible polyurethane foam process means
"equipment used to produce a flexible polyurethane foam
product. It includes raw material storage; production
equipment and associated piping, ductwork, etc.; and
When you see a
definition, it comes
straight from the rule
Figure 3.1 (on page 9) shows a typical process for producing slabstock foam.
10
-------
Figure 3.1
A Typical Process for Slab stock-Foam Production
ProceEB "Description:
Flexible slab stock-foam ie produced as a large continuous "bun." Raw chemicals are
unloaded into storage vessels. Hie chemicals are then pumped to a mixing head where
ihey are blended and form a reacting chemical mixture. Hie 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 movee into the
foam conveyor tunnel. Hie mixture quickly epreaiie evenly across the tunnel. Hie
foam reaches its maximum height, or 'full rise," about 25 feel 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.
To "Bun" Customers
11
-------
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 fabricationnote 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 the rule, you '11 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 regulatory 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 may be submitted in your Precompliance Report, your Application for
Approval of Construction or Reconstruction, or at any other time. See Chapter 7 for
12
-------
additional information [§63.1305(d), §63.1309(b)]
13
-------
To summarize, your options are as follows:
If...
And you...
Then use the following options ...
For more
information,
see figures...
your slabstock
use multiple
Option 1: comply with §63.1294
3.2, 3.4 and 3.5
foam plant is
HAPs as an
(diisocyanate emissions)
regulated under
ABA and
and
Subpart III
equipment
cleaner
§63.1295 through 63.1298 (emission
point specific limits)
use only one
Option 2: comply with §63.1294
3.3 and 3.4
HAP as an ABA
(diisocyanate emissions)
and equipment
and
cleaner
§63.1299 (sourcewide emission limit)
want to use an
Option 3: comply with §63.1305
Not in table,
alternative
(alternative means of emission
see
means of
limitation)
§63.1305(b)
emission
limitation
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 will 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)]
14
-------
HAP ABA and diisocyanate carbon-adsorption systems used for storage vessels
[§63.1295(c), §63.1303(a), §63.1294(a)]
• 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 jn storage vessels [§63.1303(d)]
• 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)]
• 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.
15
-------
What records must I keep?
For slabstock-production, you must keep one of more of the following types of information:
• 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, with 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
16
-------
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 may
find them useful.
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.
17
-------
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.
18
-------
Figure 3.2
Option 1
Emission Point Specific Limit
See separate PDF file
19
-------
Figure 3.3
Option 2
Sourcewide Emission Limit
See separate PDF file
20
-------
Figure 3.4
Option 1 and 2
Diisocyanate Emissions
see separate PDF file
21
-------
Figure 3.5
Option 1
HAP ABA Equipment Leaks
see separate PDF file
22
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production
And you have
chosen, as your And you are
overall using the According to
It vour emission «• ¦¦ , ¦ fHcsc sections nt*
compliance following control incsc sections 01
point is.... strategy, the... option... Then you must monitor as described below... the rule...
Diisocyanate Emission point Vapor balance Look, listen, and otherwise check for leaks in the vapor-return line each time diisocyanate is §63.1294(a)(l)(i)
storage vessels specific limit unloaded from a tank truck or rail car into the storage tank.
(Option 1 or 2) OR Repair leaks found before the next unloading event. ^ I294(a)(l)(ir
Sourcewide emission
limit
23
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
And you have
chosen, as your And you are
overall using the According to
It your emission compliance following control these sections of
point is.... strategy, the... option... Then you must monitor as described below... the rule...
Carbon-adsorber Measure HAP or organic concentrations in the exhaust-vent stream or outlet stream's exhaust from §63.1303(a)(1)
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
§63.1303(a)(2)
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.
Measure HAP concentration using 40 CFR part 60, Appendix A, Method 18 over at least a 5- §63.1303(a)(3)
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- §63.1303(a)(4)
minute period while the storage vessel is being filled.
You must replace existing carbon with fresh carbon prior to the next unloading event if you detect o^-, 1294(3 Y21
breakthrough.
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 are
using the
following control
option ...
Then vou must monitor as described below
According to
these sections of
the rule...
Transfer pumps
in diisocyanate
Emission point
specific limit
Sealless pump
None
(Option 1 or 2)
OR
Sourcewide emission
limit
Submerged pump
Immerse each pump in bis(2-ethylhexyl)phthalate (DEHP, CAS# 118-81-7), 2(methyloctyl)phthalate §63.1294(b)(2)(i)
(DINP, CAS #68515-48-0), or another neutral oil.
Look at each pump at least once a week to be sure it isn't leaking.
§63.1294(b)(2)(ii)
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(b)(2)(iii)
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.
25
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
And you have
If your emission
point is ....
chosen, as your
overall
compliance
strategy, the . ..
And you are
using the
following control
option ...
Then you must monitor as described below ...
According to
these sections of
the rule...
Other
components in
diisocyanate
service
(Option 1 or 2)
Emission point
specific limit
OR
Sourcewide emission
limit
N/A
None, but if you find a leak, you must make your first attempt to repair it within 5 calendar days and §63.1294(c)
repair it within 15 calendar days unless you have determined that your equipment meets the delay of
repair allowances in §63.1296(f)
HAP ABA
storage vessels
(Option 1)
Emission point
specific limit
Vapor balancing or
carbon-adsorber
Monitor the amount of HAP ABA 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 either a
digital or printed output.
Monitor the amount of HAP ABA added to the storage vessel each time there is a delivery. You
§63.1303(d)
may determine the amount of HAP ABA 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.
The rule also allows you to develop and submit for approval an alternative monitoring plan for
determining the amount of HAP ABA added to the storage vessel. §63.1303(e)(4)
26
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
And you have
chosen, as your And you are
overall using the According to
It your emission compliance following control these sections of
point is.... strategy, the... option... Then you must monitor as described below... the rule...
Vapor balance Look, listen, and otherwise check for leaks in the vapor-return line each time the HAP ABA is §63.1295(b)(1)
unloaded from a tank truck or rail care into the storage tank.
If you detect a leak, repair it by the next unloading event. 1295(b)(2)
27
-------
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 are
using the
following control
option ...
Then vou must monitor as described below
According to
these sections of
the rule...
Carbon-adsorber Measure HAP or organic concentrations in the exhaust-vent stream or outlet stream's exhaust from §63.1303(a)(1)
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
, r- ¦ ¦ ¦ , r- , §63.1303(a)(2)
Instead ol monthly monitoring, you can monitor at the Irequency you ve established dunng the
design analysis as long as the monitoring is performed within 20 percent of the carbon replacement
interval.
Measure HAP concentration using 40 CFR part 60, Appendix A, Method 18 over at least a 5- §63.1303(a)(3)
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- §63.1303(a)(4)
minute period while the storage vessel is being filled.
You must replace existing carbon with fresh carbon prior to the next unloading event if you detect §63.1295(c)
breakthrough.
28
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
And you have
chosen, as your And you are
overall using the According to
It your emission compliance following control these sections of
point is.... strategy, the... option... Then you must monitor as described below... the rule...
HAP ABA Emission point Sealless pump None
equipment leaks, specific limit
pumps
(Option 1) Other types of Monitor each pump quarterly using EPA Method 21 to detect leaks. If you measure an instrument §63.1296(a)(2)(i);
pumps reading of 10,000 parts per million (ppm) or more, you have a leak. §63.1304(a)
days unless you've determined your pump meets the delay of repair under §63.1296(f).
Note: Your first attempt to repair should include tightening ofpacking land nuts and ensuring
the seal flush is operating at it's design pressure and temperature.
29
-------
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 are
using the
following control
option ...
Then vou must monitor as described below
According to
these sections of
the rule...
HAP ABA Emission point
equipment leaks, specific limit
valves
(Option 1)
Valves not
designated as
Unsafe-to monitor
or
Difficult-to-monitor
Monitor each valve quarterly using EPA Method 21 to detect leaks. If you measure an instrument §63.1296 (b)(1);
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 calendar
days unless you have determined that your equipment meets the delay of repair allowances in
§63.1296(f).
Note: Your first attempt to repair should include tightening of bonnet bolts, replacement of
bonnet bolts, tightening gland nuts and lubricating the packing.
§63.1304(a)
§63.1296(b)(2)
Unsafe-to-monitor
valves
Unsafe-to-monitor valves are 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(b)(3)
Difficult-to-monitor
valves
Difficult-to-monitor valves are 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 at
least once every calendar year.
§63.1296(b)(4)
30
-------
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 are
using the
following control
option ...
Then vou must monitor as described below ...
According to
these sections of
the rule...
HAP ABA Emission point
equipment leaks, specific limit
connectors
(Option 1)
Connectors not
designated as
Unsafe-to monitor
or
Unsafe-to-repair
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 later than 3 months after you start using it again.
Whenever you repair a connector, you must monitor it using EPA Method 21 for leaks within 3
months after the repair.
§63.1296(c)(l )(i);
§63.1304(a)
§63.1296(c)(l)(ii);
§63.1304(a)
Unsafe-to-monitor
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
§63.1296(f).
Unsafe-to-monitor valves are those where monitoring could expose personnel to an immediate
danger situation. You must have a written plan for monitoring connectors identified as unsafe-to-
monitor. Monitor and repair leaks according to the written plan, which is at least as soon as
practicable.
§63.1296(c)( 1 )(iii);
§63.1304(a)
§63.1296(c)(3)
Unsafe-to-repair
Unsafe-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-repair.
Monitor and repair leaks according to the written plan, which is at least within 6 months after the
leak was detected.
§63.1296(c)(4)
31
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
And you have
chosen, as your And you are
overall using the According to
It your emission compliance following control these sections of
point is.... strategy, the... option... Then you must monitor as described below... the rule...
HAP ABA Emission point N/A None, unless you see, hear, or smell a leak. If you detect a leak, then you must monitor within 5 §63.1296 (d)(1);
equipment leaks, specific limit days using EPA Method 21. If you measure an instrument reading of 10,000 parts per million §63.1304(a)
pressure-relief (ppm) or more, you have a leak,
devices
If you find a leak, attempt your first repair within 5 calendar days and repair it within 15 calendar 1296(d)(2)
(Option 1) days unless you have determined that your equipment meets the delay of repair allowances in
§63.1296(f).
HAP ABA Emission point N/A None, but you must make sure that a cap, blind flange, plug, or second valve is appropriately sealed, §63.1296(e)
equipment leaks, specific limit except for emergency-shutdown system, at all times when you're not operating, maintaining or
open-ended repairing the system. If your valve or line has a second valve, make sure that the valve on the
valves or lines process fluid end is closed before the second valve.
(Optionl)
32
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
And you have
If your emission
point is ....
chosen, as your
overall
compliance
strategy, the . ..
And you are
using the
following control
option ...
Then you must monitor as described below ...
According to
these sections of
the rule...
HAP ABA
Production line
(Option 1)
Emission point
specific limit,
rolling annual or
monthly compliance
alterative
Recovery device
Monitor the cumulative amount of HAP ABA recovered by the solvent-recovery device each month
using equations 2 and 4.
You must submit a HAP ABA monitoring and recordkeeping program for approval. The program
must contain information found in §63.1303(c)(l)-(5).
§63.1297(e);
§63.1297(e)(1)
§63.1303(c)(6)
(You must make
notification to switch
between the monthly
and yearly
alternatives)
All options other
than recovery device
Continuously monitor the amount of HAP ABA and polyol added at the mixhead when foam is
being poured. For polyol added to the mixhead, you can use pump revolutions or flow rate for 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.
The 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 EPA prior to it's use.
§63.1297(b);
§62.1297(c);
§63.1303(b)
§63.1303(b)(5)
HAP ABA
equipment
cleaning
Emission point
specific limit
NA
None, but you must make sure that you don't use a HAP or HAP-based materials as an equipment
cleaner.
§63.1298
(Option 1)
33
-------
Table 3.1 Monitoring Requirements for Slabstock foam Production (cont'd)
And you have
chosen, as your And you are
overall using the According to
It your emission compliance following control these sections of
point is.... strategy, the... option... Then you must monitor as described below... the rule...
HAP ABA Sourcewide emission Recovery device Monitor the actual and allowable cumulative amount of HAP ABA recovered by the solvent- §63.1299(d);
storage vessels, limit, recovery device each month using Equations 6 and 7 §63.1299(e)(1)
equipment leaks, „¦ ,
1 1 ' rolling annual or
production line, ,¦
and equipment m°n ¦ ^ comP lance You must submit a HAP ABA monitoring and recordkeeping program for approval before you §63.1303(c)(6)
cleaning wish t° begin using the program. The program must contain information found in §63.1303(c)( 1 )-
(5).
(Option 2)
All options other Calculate actual source-wide HAP emissions for a month using Equation 5. Calculate actual §63.1299(c)
than recovery device source-wide HAP emissions for each consecutive 12-month period by summing actual monthly
source-wide HAP emissions for each of the individual 12 months.
§63.1299(d)
Calculate allowable source-wide HAP emissions for each individual month by using equation 6.
Calculate allowable source-wide HAP emissions for a consecutive 12-month period by summing
allowable monthly source-wide HAP emissions for each individual 12 months in the period.
34
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
And you
And vou have
are using
If your emission
chosen, as your
overall
compliance
the
following
control
According to these
sections of the rule
point is ...
strategy, the . ..
option ...
Then you must keep records as described below ...
Diisocyanate storage
vessels
Emission point
specific limit
All options
Keep a list of diisocyanate storage vessels, along with a record of the type of control used for
each storage vessel.
§63.1307(a)(1)
(Optionl or 2)
OR
Sourcewide
emission limit
Vapor
balancing
Dates and times of each unloading event.
Dates and times of each inspection of the vapor-return line.
Dates and times when you detect a leak in the vapor-return line.
Dates and times when you repair a leak in the vapor-return line.
§63.1307(a)(4 )(i)-(iii);
§63.1307(f)
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.
§63.1307(a)(3)(i);
§63.1307(a)(3)(iii)
Carbon-
adsorption —
design
analysis
Record the systems design analysis.
Dates and times when you monitor the system for carbon breakthrough.
Monitoring device reading each time you monitor.
§63.1307(a)(3)(ii);
§63.1307(a)(3)(iii);
§63.1303(a)(2)
monitoring
Date when you replaced the carbon.
35
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If vour emission
point is ...
And you have
chosen, as your
overall
compliance
strategy, the...
And you
are using
the
following
control
option ... Then you must keep records as described below ...
According to these
sections of the rule
Transfer pumps in
diisocyanate service
§63.1307(b)(2)
If you detect a leak, you must record and identify on the equipment the following information: §63.1307(b)(3)(ii)
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
(Option 1 or 2)
sourcewide
emission limit
Instrument and operator identification numbers
Equipment identification number
36
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If vour emission
point is ...
And you have
chosen, as your
overall
compliance
strategy, the...
And you
are using
the
following
control
option ... Then you must keep records as described below ...
According to these
sections of the rule
Other components in
diisocyanate service
Emission point All options List of components in diisocyanate service,
specific limit
§63.1307(b)( 1 )(i)
If you detect a leak, you must record and identify on the equipment the following information: §63.1307(b)(3)(ii)
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
(Option 1 or 2)
OR
Sourcewide
emission limit
Instrument and operator identification numbers
Equipment identification number
37
-------
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
are using
the
following
control
option ...
Then you must keep records as described below ...
According to these
sections of the rule
HAP ABA storage vessels
(Option 1)
Emission point All options A list of HAP ABA storage vessels, along with a record of the type of control used for each
specific limit storage vessel.
§63.1307(a)(2)
Vapor
balancing
Dates and times of each unloading event.
Dates and times of each inspection of the vapor-return line.
Dates and times when you detect a leak in the vapor-return line.
Dates and times when you repair a leak in the vapor-return line.
§63.1307(a)(4);
§63.1307(f)
Carbon-
adsorption
Carbon-
adsorption -
design
analysis
monitoring
Dates 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 device reading each time you monitor.
Date when you replaced the carbon.
§63.1307(a)(3)(i);
§63.1307(a)(3)(iii)
§63.1307(a)(3)(ii);
§63.1307(a)(3)(iii);
§63.1303(a)(2)
38
-------
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
are using
the
following
control
option ...
According to these
sections of the rule
Then you must keep records as described below
HAP ABA Equipment Emission point All options List of components in HAP ABA service. §63.1307(b)( 1 )(ii)
Leaks (e.g. transfer pumps, specific limit
valves, connectors, pressure-
relief devices, and open-
ended lines)
(Option 1)
39
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If vour emission
point is ...
And you have
chosen, as your
overall
compliance
strategy, the...
And you
are using
the
following
control
option ... Then you must keep records as described below ...
According to these
sections of the rule
All options, If you detect a leak, you must record and identify on the equipment the following information: §63.1307(b)(3)(ii)
except
sealless
Instrument and operator identification numbers
Equipment identification number
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
40
-------
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
are 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
specific limit,
rolling annual or
monthly compliance
alterative
All options Record the following daily:
Foam runs, with a list of the grades produced during each run
Amount of polyol added to the slabstock foam production line at the mixhead for each run
(not required for grades of foam where you've designated the formulation limit for HAP
ABA as zero)
Results of the density and IFD testing for each grade of foam produced during each run of
foam (must be recorded within 10 days of production; not required for grades of foam
where you've designated the formulation limit for HAP ABA as zero)
§63.1307 (c)(l)(i)
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 emissions for the month
Total amount of HAP ABA added to the line at the mixhead during the month
§63.1307(c)(l)(ii)
If you're using rolling-annual compliance, also record the following:
Sum of the total allowable HAP ABA emissions for the month and the previous 11
months
Sum of the total actual HAP ABA emissions for the month and the previous 11 months
§63.1307(c)(l )(iii)
41
-------
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
are using
the
following
control
option ...
According to these
sections of the rule
Then you must keep records as described below
Also keep all of the following records: §63.1307(c)( 1 )(iv)
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
42
-------
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
are using
the
following
control
option ...
According to these
sections of the rule
Then you must keep records as described below
HAP ABA Production line Sourcewide limit, All options
(Option 2)
rolling annual or
monthly compliance
alternative
Record the 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 be 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 slabstock foam production line at the mixhead for each run
(not required for grades of foam where you've designated the formulation limit for HAP
ABA as zero)
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 sourcewide HAP ABA emissions for the month
Amounts of HAP ABA in the storage vessel at the beginning and end of the month
43
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If your emission
point is ...
§63.1303 (c)(2)®
§63. 1303(c)(2)(h)
§63.1303(c)(2)(iii)
And you have
chosen, as your
overall
compliance
strategv, the . ..
And you
are using
the
following
control
option ...
According to these
sections of the rule
Then vou must keep records as described below
44
-------
Table 3.2 Recordkeeping Requirements for Slabstock foam Production (cont'd)
If your emission
point is ...
If using rolling-annual compliance, also record the following: §63.1303(c)(2)(iv)
Total allowable HAP ABA and equipment cleaning HAP emissions for the month and the
previous 11 months
Total actual HAP ABA and equipment cleaning HAP emissions for the month and the
previous 11 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(e)(3)
And you have
chosen, as your
overall
compliance
strategv, the...
And you
are using
the
following
control
option ...
According to these
sections of the rule
Then vou must keep records as described below
§63.1307(c)(2)(v) -
(vii)
45
-------
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
are using
the
following
control
option ...
According to these
sections of the rule
Then you must keep records as described below ...
HAP ABA Recovery device Emission point
specific limit
(Option 1 or 2)
HAP ABA Equipment
cleaning
OR
Sourcewide limit
Emission point
specific limit
N/A
N/A
Copy of the monitoring and recordkeeping 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)
Product data-sheet for each equipment cleaner used, including HAP content, in kg of HAP/kg §63.1307 (e)
solids (lb HAP/lb solids).
(Option 1)
46
-------
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
Page
Option
I.
Applicability
38
II.
Diisocyanate storage vessels
39
1 or 2
III.
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
VII.
HAP ABA production line
54
1
VIII.
HAP ABA equipment cleanig 59
1
IX.
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
Q Yes
Q No
polyurethane foam? §63.1290(c)(1)
2
Is your slabstock process devoted solely to research and development
Q Yes
Q No
of new products and processes? §63.1290(c)(2)
47
-------
3 Are your plantwide HAP emissions, as calculated using Equation 1, Q Yes Q No
no more than five tons per year? §63.1290(c)(3)
48
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section II: Diisocyanate storage vessels checklist (Option 1 or 2)
B. Requirements tor Diisocyanate Storage Vessels
Comments
1 Does each diisocyanate storage vessel have a vapor-return line Q Yes Q No
(vapor-balancing system) or a carbon-adsorption system?
§63.1294(a)
For each diisocyanate storage vessel with a vapor-return line, are Q Yes Q No
you visually inspecting for leaks each time diisocyanate is unloaded
from the tank truck or rail car? §63.1294(a)(l)(i)
No. vessels with vapor-
return line:
No. vessels with carbon-
adsorption:
Date of last unloading:
Date of last visual
inspection:
For each diisocyanate storage vessel with a vapor-return line, did Q Yes Q No
you repair any leaks found before the next unloading event?
§63.1294(a) (1) (ii)
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) (2)
Q Yes Q No
For each carbon-adsorption system, do you replace the carbon after Q Yes Q No
you find the breakthrough and before the next unloading?
§63.1294(a) (2)
Date of breakthrough:
Date of Carbon
Replacement:
Date of Next Unloading:
No. vessels with
breathrough:
49
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
c.
Monitoring Requirements for Diisocvanatc 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 vour desian analysis? $63.1303fa)(\).(2)
Q Yes
Q No
No. storage vessels
measured at the carbon
adsorption system:
No. vessels using design
analysis:
2
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)
Q Yes
Q No
Value Method 18:
3
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)
Q Yes
Q No
Value Method 24:
4
For each carbon-adsorption system monitored according to intervals
in a desian analysis, have vou renlaced the carbon at the snecified
interval? §63.1303(a)(2)
Q Yes
Q No
Design's Replacement
Interval:
Last Replacement of
Carbon:
D.
Recordkeeping Requirements for Diisocvanatc Storage Vessels
Comments
1
Do you have a list of diisocyanate storage vessels that includes the
type of control for each storage vessel? §63.130 7(a)(1)
Q Yes
Q No
No. of storage vessels:
No. of controls used:
2
If you're complying with the requirements for diisocyanate storage
vessels usina carbon-adsorDtion. do vou keen the followina records?
§63.1307(a)(3)
• Dates and times when you monitor the system for carbon
breakthrough
Q Yes
Q No
No. vessels using carbon-
adsorption:
• Reading from the monitoring device each time you monitor it
Q Yes
Q No
• Date when your replaced the carbon
Q Yes
Q No
50
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
D. Recordkeeping Requirements tor Diisocyanate Storage Vessels Comments
3 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) (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
4 If you're complying with the diisocyanate storage using a vapor-
return line, do you keep the following records? §63.1307(a) (4),
§63.13070)
• 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
No. vessels using carbon
adsorption:
Q Yes Q No
Q Yes Q No
Q Yes Q No
Q Yes Q No
No. vessels using vapor-
return:
Q Yes Q No
Q Yes Q No
Q Yes Q No
Q Yes Q No
Q Yes Q No
51
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section III: Diisocyanate transfer pump checklist (Option 1 or 2)
E. Requirements tor Diisocyanate Transfer Pumps Comments
1
Is each transfer pump in diisocyanate service either sealless or
submerged? §63.1294(b)
Q Yes
Q No
No. of sealless pumps:
No. submerged pumps:
2
Have you completely immersed each submerged pump in bis(2-
ethylhexyl)phthalate (DEHP, CAS #118-81-7),
2(methyloctyl)phthalate (DINP, CAS #68515-48-0), or another
neutral oil? §63.1294(b) (2) (i)
Q Yes
Q No
Submerging oil used:
3
Do you visually monitor each submerged pump weekly to detect
leaks? §63.1294(b)(2)(H)
Q Yes
Q No
Date last wkly inspection:
4
When you detect a leak from a submerged pump, do you first
attempt to repair it 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 §63.1294(d)?
§63.1294(b)(2)(iii)
Q Yes
Q No
Date Leak Detected:
Date First Attempt at
Repair:
Date Leak Repaired:
No. of pumps with leaks:
5
Does your first attempt to repair a leaking submerged pump include:
tightening of packing gland nuts and checking the seal flush to see if it
is operating at design temperature and pressure?
§63.1294(b)(2) (iii) (B)
Q Yes
Q No
F.
Recordkeeping Requirements for Diisocyanate Transfer Pumps
Complete this section only if you used submerged pumps
Comments
1
Do vou have a list of all submersed transfer Dunros in diisocyanate
service, including the date of installation and type of control?
§63.1307(b)(2)
Q Yes
Q No
No. transfer pumps:
2
For each submersed transfer Dumt) that's leakina. do vou attach to
the equipment a readily visible identification number?
§63.1307(b) (3)(i)(A)
Q Yes
Q No
No. pumps with tags:
3
For each submersed transfer Dumt) that's leakina. do vou remove the
tag only after you've repaired the pump? §63.1307(b)(3)(i)(C)
Q Yes
Q No
52
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
F. Recordkeeping Requirements tor Diisocvanate Transfer Pumps Comments
Complete this section only if you used submerged pumps
4 For each submersed transfer oumc in diisocvanate service, do vou
No. pumps in diisocyante
keep the following records each time you detect a leak
service:
§63.1307(b)(3)(H)
• Instrument and operator identification numbers and the
Q
Yes
Q No
equipment identification number
• Date you detected the leak and dates of each attempt to repair
Q
Yes
Q No
the leak.
• Repair methods applied in each attempt to repair the leak.
Q
Yes
Q No
• Words "above leak definition" if applicable
Q
Yes
Q No
• Words "repair delayed" and the reason for the delay if not
repaired within 15 calendar days. Date you expect to repair the
Q
Yes
Q No
leak if not repaired within 15 calendar days
• Date you repaired the leak
Q
Yes
Q No
• Date you removed the identification
Q
Yes
Q No
53
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section IV: Other diisocyanate components checklist (Option 1 or 2)
G. Requirements tor Other Components 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)
Q Yes
Q 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 vou have a list of all other components in diisocvanate service?
§63.1307(b)(i)
Q Yes
Q No
No. of components in
service:
2
For each other component in diisocvanate service that's leakina. do
you attached to the equipment a readily visible identification number?
§63.1307(b) (3) (i) (A)
Q Yes
Q No
No. components tags:
3
For each other component in diisocvanate service that's leakina. do
you remove the tag only after you've repaired the leak?
§63.1307(b) (3) (i) (C)
Q Yes
Q No
4
For each other component in diisocvanate service, do vou keep the
following records each time you detect a leak §63.1307(b)(3)(H)
• Instrument and operator identification numbers and the
equipment identification number
Q
Yes
Q No
• Date you detected the leak and dates of each attempt to repair
the leak.
Q
Yes
Q No
• Repair methods applied in each attempt to repair the leak.
Q
Yes
Q No
• Words "above leak definition" if applicable
Q
Yes
Q No
• 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
Q
Yes
Q No
• Date you repaired the leak
Q
Yes
Q No
• Date you removed the identification
Q
Yes
Q No
54
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section V: HAP ABA storage vessel checklist (Option 1)
I. Requirements tor HAP ABA Storage Vessels Comments
1 Have you equipped each HAP ABA storage vessel with a vapor Q Yes Q No No. vessels with vapor-
return line (vapor-balance system) or a carbon-adsorption system? return line:
§63.1295(a)
No. vessels with carbon-
adsorption:
2 For each HAP ABA storage vessel with a vapor-return line, is the Q Yes Q No
line connected from the storage vessel to the tank truck or rail car
during each unloading? §63.1295(b)
3 For each HAP ABA storage vessel with a vapor-return line, do you Q Yes Q No Date Last Unloading:
inspect (visual, audible, olfactory, or other detection method) for
leaks each time HAP ABA is unloaded from the tank truck or rail car? Date last visible inspection:
§63.1295(b)(1)
4 For each HAP ABA storage vessel with a vapor-return line, if you Q Yes Q No Date of leak:
found a leak, did you repair it before the next unloading event?
§63.1295(b)(2)
Date Leak Repaired:
Date Subsequent
Unloading:
No. of vessels with leaks:
No. of vessels repaired:
5 For each HAP ABA storage vessel with a carbon-adsorption Q Yes Q No
system, do you route displaced vapors through activated carbon
before discharging into the atmosphere? §63.1295(c)
55
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
I.
Requirements tor HAP ABA Storage Vessels
Comments
6
For each carbon-adsorption system, do you replace the carbon after
you find breakthrough and before the next unloading? §63.1295(c)
Q Yes Q No
Date of breakthough:
Date of carbon replacement:
Date of Subsequent
Unloading:
No. vessels with
breakthrough:
J.
Monitoring Requirements for HAP ABA in. Storage Vessels
Comments
1
Do you determine the amount of HAP ABA in each storage vessel
weekly? §63.1303(d)
Q Yes Q No
Method used:
Date Last Measurement:
2
Do you monitor the amount of HAP ABA in each storage vessel
with a level-measurement device? §63.1303(d)
Q Yes Q No
3
Did you calibrate each level-measurement device initially and then
annually? §63.1303(d)(1)
Q Yes Q No
Date of Annual
Calibration:
4
Unless the level-measurement device is a visually read device, such as
a gauge glass, does the device have a digital or printed output?
§63.1303 (d)(2)
Q Yes Q No
Type of output:
5
If the level-measurement device is a visually read device, does it have
permanent graduated markings to show the HAP ABA level in the
storage tank? §63.1303(d)(3)
Q Yes Q No
K.
Monitoring Requirements for HAP ABA added to Storage Vessels
Comments
1
Do you monitor the amount of HAP ABA added to a storage vessel
by measuring the volume, weight or by an alternative monitoring
program? §63.1303(e)
Q volume
Q weight
Q alternate
No. vessels using volume:
No. vessels using weight:
No. vessels using alternate:
56
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
K.
Monitoring Requirements for HAP ABA added to Storage Vessels
Comments
2
If you measure using volume, do you record the volume of HAP
ABA in each storage vessel before and after each delivery?
§63.1303 (e)(1)
Q Yes
Q No
Date Last Delivery:
Volume before last delivery:
Volume after last delivery:
3
If you measure using the volume of HAP ABA delivered, does your
measurement device follow the requirements outlined in section J of
this checklist?§63.1303(e)(1)
Q Yes
Q No
4
If measuring using volume, is volume flow rate measured using a
device with an accuracy of ±2.0% ? §63.1303(e)(2)
Q Yes
Q No
Device Accuracy:
5
If measuring using volume, did you calibrate your device initially and
at least once every 6 months? §63.1303(e)(2)
Q Yes
Q No
Date Initial Calibration:
Date Last 2 Calibrations:
6
If measuring weight, do you measure by calculating the difference of
the full weight of the transfer vehicle prior to unloading and the
empty weight of the transfer vehicle after unloading? §63.1303(e)(3)
Q Yes
Q No
Date of last transfer:
Wt of last full transfer
vehicle:
Wt of last empty transfer
vehicle:
7
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 aregistered scale technician? §63.1303(e) (3)(i) and (ii)
Q Yes
Q No
No. scales approved by
State:
No. scales approved by
technician:
8
If your using an alternative monitoring program, have you
submitted the plan for approval? Has the plan been approved?
§63.1303 (e)(4)
Q Yes
Q No
Date Plan Submitted:
Date Plan Approved:
57
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
L Monitoring Requirements for Storage Vessels with Carbon-Adsorptio
n
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 vour desian analysis? $63.1303fa)(\).(2)
Q Yes
Q No
No. storage vessels
measured at the carbon
adsorption system:
No. vessels using design
analysis:
2 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)
Q Yes
Q No
Value Method 18:
3 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)
Q Yes
Q No
Value Method 24:
4 For each carbon-adsorption system monitored according to intervals
in a desian analysis, have vou renlaced the carbon at the snecified
interval? §63.1303(a)(2)
Q Yes
Q No
Design's Replacement
Interval:
Last Replacement of
Carbon:
M. Recordkeeping Requirements 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? §63.130 7(a)(2)
Q Yes
Q No
No. vessels using emission
point specific limit:
2 If you're complying with the requirements for HAP ABA storage
vessels usina carbon-adsorDtion. do vou keen the followina 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
Q Yes
Q Yes
Q Yes
Q No
Q No
Q No
No. vessels using carbon-
adsorption:
58
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
M. Recordkeeping Requirements tor HAP ABA Storage Vessels Comments
3 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
4 If you're complying with the HAP ABA storage using a vapor-return
line, do you keep the following records? §63.1307(a)(4),§63.1307(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
No. vessels using carbon
adsorption:
Q Yes Q No
Q Yes Q No
Q Yes Q No
Q Yes Q No
No. vessels using vapor-
return:
Q Yes Q No
Q Yes Q No
Q Yes Q No
Q Yes Q No
59
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section VI: HAP ABA equipment leaks checklist (Option 1)
N. Requirements tor HAP ABA Equipment Leaks Comments
Note: Equipment leak requirements are for transfer pumps, valves, connectors, pressure-relief
devices and open-ended lines
1
Is each pump in HAP ABA service either sealless or monitored for
leaks? §63.1296(a)
if you 're using a sealless pump, skip item 2-4 and go to 5
Q sealless
Q monitored
No. sealless pumps:
No. pumps monitored:
2
Do you monitor each pump quarterly by using Method 21 and
weekly by visual inspection? §63.1296(a)(2) (i),(ii); §63.1304(a)
Q Yes
Q No
Last Quarterly Inspection:
Value Method 21:
3
If you detect a pump leak, do you first attempt to repair it within 5
calendar days and actually repair it within 15 calendar days unless
you've determined your pump meets the delay of repair under
§63.1296(f)? §63.1296(a) (2) (in)
Q Yes
Q No
Date Leak Detected:
Date First Attempt at
Repair:
Date Leak Repaired:
No . of pumps with leaks:
4
Does your first attempt to repair a leaking pump include: tightening
of packing gland nuts and ensuring the seal flush is operating at it's
design pressure and temperature? §63.1296(a) (2)(iii)(B)
Q Yes
Q No
5
Do you monitor each valve quarterly using Method 21?
§63.1296(b)(1); §63.1304(a)
Q Yes
Q No
Last Quarterly Inspection:
Value Method 21:
6
If you detect a valve leak using Method 21, do you attempt to repair
it 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(f)? §63.1296(b)(2)-, §63.1304(a)
Q Yes
Q No
Date Leak Detected:
Date First Attempt at
Repair:
Date Leak Repaired:
No. of valves with leaks:
7
Does your first attempt to repair a leaking valve include: tightening of
bonnet bolts, replacement of bonnet bolts, tightening gland nuts and
lubricating the packing? §63.1296(b)(2)(ii)
Q Yes
Q No
60
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
N. Requirements tor HAP ABA Equipment Leaks Comments
Note: Equipment leak requirements are for transfer pumps, valves, connectors, pressure-relief
devices and open-ended lines
8 For each valve you've designated as unsafe-to-monitor. do vou have a Q Yes Q No No. of unsafe-to-monitor
written plan that requires monitoring as often as possible and repair valves:
of leaks as soon as possible? §63.1296(b)(3)(H)
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)
Date Last Monitored:
Plan Requirements for
Monitoring:
Date Leak Last Detected:
Date Leak Repaired:
Plan Requirements
for Leak Repair:
10 For each valve you've designed as difficult-to-monitor. do vou have a Q Yes Q No No. of difficult-to-monitor
written plan that requires monitoring at least once per calendar year valves:
and repair of leaks as soon as possible? §63.1296(b)(4)(iii)
9 Do you monitor and repair each unsafe-to-momtor valve according to Q Yes Q No
your written plan? §63.1296(b)(3) (Hi) and (iv)
Note: difficult-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 new
source where you have designed <3% of your valves as difficult-
to-monitor. §63-1296@)(4)(i), (ii)^
11 Do you monitor and repair each difficult-to-monitor valve according Q Yes Q No Plan Requirements for
to your written plan? §63.1296(b) (4) (iv) and (v) Monitoring:
Date Last Monitored:
Plan Requirements for Leak
Repair:
Date Leak Last Detected:
Date Leak Repaired:
61
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
N. Requirements tor HAP ABA Equipment Leaks
Note: Equipment leak requirements are for transfer pumps, valves, connectors, pressure-relief
devices and open-ended lines
Comments
12 Do you monitor each connector annually using Method 21?
§63.1296(c)(1); §63.1304(a)
Q Yes Q 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
for leaks within the first 3 months after it's used for HAP ABA
again? §63.1296(c)(1)(H)
Q Yes Q No
Date Connector Opened/Seal
Broken:
Date Connector Monitored:
14 If you've detected a leak, do you monitor the connector within the
first 3 months after its repair? §63.1296(c)(l)(iii)
Q Yes Q No
15 If you detect a connector leaking, do you try to repair it 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(f)?
§63.1296(c)(2)
16 For each connector designated as unsafe-to-monitor. do you have a
written plan that requires monitoring as often as possible and repair
of leaks within 6 months? §63.1296(c)(3), (c)(4)(H)
Q Yes Q No
Q Yes Q No
No. Connectors Opened/Seal
Broke:
Date Leak Detected:
Date Leak Repaired:
Date Leak Monitored:
No. Connectors with Leaks::
Date Leak Detected:
Date First Attempt at
Repair:
No. unsafe-to-monitor
connectors:
Note: unsafe-to-monitor connectors are those that can't be
monitored because personnel would be exposed to an immediate
danger situation. §63.1296(c) (3) (i)
17 Do you monitor and repair each unsafe-to-monitor connector
according to your written plan? §63.1296(c) (3) (ii)
Q Yes Q No
Plan Requirements for
Monitoring:
Date Last Monitored:
62
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
N. Requirements tor HAP ABA Equipment Leaks Comments
Note: Equipment leak requirements are for transfer pumps, valves, connectors, pressure-relief
devices and open-ended lines
18
For each connector desianated as unsafe-to-reDair. do vou repair the
connector as soon as possible but no later than 6 months after you
detected the leak? §63.1296(c)(4)(H)
Note: unsafe-to-reDair connectors are those that can't be repaired
because personnel would be exposed to an immediate danger
situation. §63.1296(c)(4)(i)
Q Yes
Q No
Plan Requirement for Leak
Repair:
Date Leak Detected:
Date Leak Repaired:
19
If you find evidence of a potential leak by visual, audible, or olfactory
detection, do you monitor the pressure-relief device using Method
21 within 5 calendar days? §63.1296(d)(1), §63.1304(a)
Q Yes
Q No
Date Potential Leak Last
Detected:
Date Monitored:
Results Method 21:
20
If you detect a leak a pressure-relief device, do you first attempt
repair it within 5 calendar days and actually repair it within 15
calendar days unless you've determined your pump meets the delay
of repair under §63.1296(f)? §63.1296(d)(2)
Q Yes
Q No
No. pressure-relief devices
with leaks:
Date Leak Detected:
Date First Attempt at
Repair:
Date Leak Repaired:
21
Have you equipped each open-ended valve or line in HAP ABA
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)(i)
Q Yes
Q No
22
Do you keep open-ended valve or line sealed at all times, except
when in use or during maintenance or repair? §63.1296(e) (1) (ii)
Q Yes
Q No
23
For each open-ended valve or line with a second valve, do you close
the valve on the process fluid end before closing the second valve?
§63.1296(e)(2)
Q Yes
Q No
No. valves or lines with
second valve:
24
For each open ended valve or line with a double-block-and-bleed
system, do you keep the bleed-valve or line closed except during
operations that require venting the line between the block-valves?
§63.1296(e)(3)
Q Yes
Q No
No. valves or lines with
double-block-and-bleed:
63
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
O. Record keep ins Requirements tor HAP ABA Equipment Leaks
Comments
1 Do you have a list of transfer pumps, valves, connectors, pressure-
relief devices and open-ended lines in HAP ABA service (components
in service)? §63.1307(b)(1)(H)
Q Yes
Q No
No. of components in
service:
2 For each component in service that's leaking, do you attached to the
equipment a readily visible identification number?
§63.1307(b) (3) (i) (A)
Q Yes
Q No
No. components with tags:
3 For each component in service that's leaking, do you remove the tag
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)
Q Yes
Q No
4 Do you keep the following records for components in service?
§63.1307(b)(3)(H)
• Instrument and operator identification numbers and the
equipment identification number
Q Yes
Q No
• Date you detected the leak and dates of each attempt to repair
the leak.
Q Yes
Q No
• Repair methods applied in each attempt to repair the leak.
Q Yes
Q No
• Words "above leak definition" if applicable
Q Yes
Q No
• 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
Q Yes
Q No
• Date you repaired the leak
• Date you removed the identification
Q Yes
Q Yes
Q No
Q No
64
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section VII: HAP ABA production line checklist (Option 1)
P. Requirements tor HAP ABA Emissions from the Production Line Comments
1 Do you determine compliance with the HAP ABA emission limits Q rolling-annual No. lines using rolling-
from the production line by using a rolling-annual or monthly q mon^j annual:
basis? §63.1297(a) m°n Y
No. lines using monthly:
2 If you switch between the rolling-annual and monthly compliance Q Yes Q No Date switched options:
options, do you make notification 180 calendar days prior to making
the change? §63.1297(a)(3)
Date of notification:
3 If you determine compliance on a rolling-annual basis, and don't
use a recovery 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)
4 If you determine compliance on a rolling-annual basis, and don't Q Yes Q 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)(1)
Value allowable HAP ABA:
Q Yes Q No Value actual HAP ABA:
Value allowable HAP ABA:
If you determine compliance on a rolling-annual basis, and don't Q Yes Q No
use a recovery device, do you use Equation 2 in §63.1297(b) (2) to
calculate allowable HAP ABA emissions on the production for the
12-month period? §63.1297(b)(2)-, §63.1297(c)(2)
Value Equation 2:
If you determine compliance monthly, and don't use a recovery Q Yes Q No
device, do you compare actual HAP ABA emissions to allowable
HAP ABA emissions for each month? Do you determine actual by
using HAP ABA added to the production line at the mixhead?
§63.1297(a) (2)
If you determine compliance monthly, and don't use a recovery Q Yes Q No
device, are actual HAP ABA emissions less than the corresponding
allowable level of HAP ABA emissions for the same month?
§63.1297(c)
If you determine compliance monthly, and don't use a recovery Q Yes Q No
device, do you calculate actual monthly HAP ABA emissions as the
amount of HAP ABA added to the production line at the mixhead?
§63.1297(c)(1)
Value actual HAP ABA:
Value allowable HAP ABA:
Value actual HAP ABA:
Value allowable HAP ABA:
Value actual HAP ABA:
Value allowable HAP ABA:
65
-------
p.
9
10
11
12
13
14
15
16
17
18
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Requirements tor HAP ABA Emissions from the Production Line Comments
If you determine compliance monthly, and don't use a recovery Q Yes Q No Value Equation 2:
device, do you use Equation 2 in §63.1297(b)(2) to calculate
allowable HAP ABA emissions for the month? §63.1297(b)(2)
Except for formulation limits of zero, do you determined a HAP Q Yes Q No No. grades produced:
ABA formulation limit for each grade of foam produced?
§63.1297(d)
Formulation limit value:
Except for formulation limits of zero, for each existing source, do vou Q Yes Q No Value equation 3:
use Equation 3 in §63.1297(d) to calculate HAP ABA formulation
limit? §63.1297(d)(1)
Except for formulation limits of zero, for each new source, do vou use Q Yes Q No Value equation 3:
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? §63.1297(d)(2) (i)
Except for formulation limits of zero, for each new source, do vou use Q Yes Q No Value equation 3:
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 less? §63.1297(d)(2)(H)
Except for formulation limits of zero, for each new source, with a
foam grade density greater than 0.95 pounds per cubic foot and an
IFD greater than 15 pounds, is the HAP ABA formulation limit
zero? §63.1297(d) (2) (iii)
Except for formulation limits of zero, for each new source with a Q Yes Q No Density:
foam grade density greater than 1.40 pounds per cubic foot, is the
HAP ABA formulation limitzero? §63.1297(d)(2)(iv)
Formulation limit:
Except for formulation limits of zero, do you determine the IFD Q Yes Q No Last production start date:
and density for each foam grade within 10 working days of its
production using §63.1304(b)? §63.1297(d)(3)
Last IFD and density
determination:
If you're using a recovery -device and determine compliance on a Q Yes Q 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)
If you're using a recovery -device and determine compliance on a Q Yes Q No Value equation 4:
rolling-annual or monthly basis, do you calculate actual monthly
HAP ABA emissions according to Equation 4 in §63.1297(e)?
§63.1297(e)(1)
Q Yes Q No Density:
Formulation limit:
66
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
P.
Requirements for HAP ABA Emissions from the Production Line
Comments
19
If vou're usina a recoverv-device and determine compliance on a
rolling-annual or monthly basis, have you submitted a HAP ABA
monitoring program for approval? §63.1297(e)(2);§63.1303(c)
Q Yes
Q No
No. recovery-devices used:
Date plan submitted:
Q
Monitoring Requirements for HAP ABA Emissions from the Production Line when a
Recovery Device is Used
SKIP this section if you don't use a recovery device
Comments
l
Have you sent a recovered HAP monitoring and recordkeeping plan in
for approval? §63.1303(c)
Q Yes
Q No
Date Sent:
Date Approved:
2
Does your equipment have a device showing the cumulative amount
of HAP ABA recovered by the solvent-recovery device each month?
§63.1303 (c)(1)
Q Yes
Q No
Last cumulative monthly
value:
3
Has the manufacturer certified the device to be accurate within +/- 2.0
percent? §63.1303(c)(1)
Q Yes
Q No
Device accuracy:
4 Do you measure after fully recovering the HAP ABA (i.e., after Q Yes Q No
separating it from water introduced into the HAP ABA during
regeneration)? §63.1303(c)(2)
R Monitoring Requirements for HAP ABA and Polvol added to the Production Line at the Comments
mixhead
1
Do you continuously monitor the amount of HAP ABA added at the
mixhead when foam is being poured or monitor under an alternative
monitoring program? §63.1303(b) ((l)(i)
Q Yes
Q No
2
When monitoring HAP ABA added, do you measure using flow
rate?§63.1303(b)((l)(ii)
Q Yes
Q No
3
When measuring HAP ABA added, does your monitoring device have
an accuracy to within ±2.0 percent of the HAP ABA being measured?
§63.1303 (b)(3)
Q Yes
Q No
Device Accuracy:
67
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
R Monitoring Requirements for HAP ABA and Polyol added to the Production Line at the Comments
mixhead
4 When measuring HAP ABA added, did you calibrate your measuring Q Yes Q No Date Initial Calibration:
device initially and at least once each month? §63.1303(b)(3)(H)
Date Last 2 Calibrations:
5 Are you measuring HAP ABA at the beginning and end of a run of Q Yes Q No Value last beginning run:
foam for the production of each grade of foam? §63.1303 (b)(4)
Value last end run:
6 Do you continuously monitor the amount of polyol added at the Q Yes Q No
mixhead according to the rule or an alternative monitoring
program? §63.1303(b)(l)(i)
7 If you're monitoring the amount of polyol, are you measuring using Q Yes Q No No. monitoring using
pump revolutions or flow rate? §63.1303(b)(2) revolutions:
No. monitoring using flow
rate:
8 If your monitoring the amount of polyol, does your monitoring device Q Yes Q No Device Accuracy:
have an accuracy to within ±2.0 percent of the HAP ABA being
measured? §63.1303(b)(3)
9 If your monitoring the amount of polyol, did you calibrate your Q Yes Q 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 Q Yes Q 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 Q Yes Q No Date Plan Submitted:
submitted the plan for approval? Has the plan been approved?
§63.1303 (b)(5)
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) Q Yes Q No
68
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
S. Recordkeeping Requirements tor HAP ABA at the Production Line Comments
2 If you're complying using the rolling-annual or monthly
compliance option, do you keep the following production-line records
daily? §63.1307(c)(l)(i)
• 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
• Results of the density and IFD testing for each grade of foam
produced during each run of foam (not required on grades of
foam for which you've designated a zero formulation limit for
HAP ABA)
Q Yes Q No
Q Yes Q No
Q Yes Q No
Q
Yes
Q
No
Q
Yes
Q
No
Q
Yes
Q
No
Q
Yes
Q
No
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)(1)(H)
• 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 grade
produced (not required on grades of foam for which you've
designated a zero formulation limit for HAP ABA)
4 If you're complying using the rolling-annual or monthly
compliance option, do you keep the following records for each
month? §63.1307(c)(1)(iv)
• Calibrations for each device used to measure polyol and HAP
ABA added at the mixhead Q Yes Q ^o
Q Yes Q No
If you're complying using the emission point specific limit, rolling-
annual option, do you keep the following records for each month?
§63.1307(c)(1) (Hi)
• Sum of the total allowable HAP ABA emissions for the month
and the previous 11 months
• Sum of the total actual HAP ABA emissions for the month and Q Yes Q No
the previous 11 months
Q Yes Q No
69
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
T. Recordkeeping Requirements tor 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
If vou're comDlvina usina a recovery device, do vou keen the
following records? §63.1307(d)
• Copy of your monitoring and recordkeeping program for
recovered HAP ABA
Q Yes
Q No
• Certification of the monitoring device's accuracy
Q Yes
Q No
• Records of periodic calibration of the monitoring device
Q Yes
Q No
• Records of parameter-monitoring results
Q Yes
Q No
• Amount of HAP ABA recovered each time you measure it
Q Yes
Q No
70
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section VIII: HAP ABA equipment cleaning checklist (Option 1)
U. Requirements tor HAP ABA Equipment Cleaning
Comments
1 Are your cleaning operations free of HAP or HAP based materials?
§63.1298
Q Yes Q No
V. Recordkeeping Requirements for HAP ABA Equipment Cleaning
Comments
1 Do you have a product data-sheet for each equipment cleaner you
used? Does the product data-sheet include the HAP content, in kg of
HAP/kg solids (or lb of HAP/lb of solids)? §63.1307(e)
Q Yes Q No
Q Yes Q No
71
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section IX: Sourcewide emission limit checklist (Option 2)
W. Requirements tor Sourcewide Emission Limit Comments
Note: This includes emissions from 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
sourcewide allowable limits on HAP ABA emissions? §63.1299
Q annual
Q monthly
2
If you determine compliance on a rolling-annual basis and don't use
a recovery device, are actual sourcewide HAP ABA emissions from
the facility (including storage, equipment leaks, production line, and
equipment cleaning) less than the sourcewide allowable HAP ABA
emissions for each consecutive 12-month period? §63.1299(a)
Q Yes
Q No
Actual sourcewide value:
Allowable sourcewide value:
3
If you determine compliance on a rolling-annual basis and don't use
a recovery device, do you calculate allowable HAP emissions for 12
consecutive months using equation 6? §63.1299(a); §63.1299(d)
Q Yes
Q No
Value Equation 6:
4
If you determine compliance on a rolling-annual basis and don't use
a recovery device, do you use Equation 5 in §63.1299(c) to calculate
the actual, monthly sourcewide HAP emissions? §63.1299(c) (1)
Q Yes
Q No
Value Equation 5:
5
If you determine compliance on a rolling-annual basis and don't use
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)(2); §63.1303(d)
Q Yes
Q No
Last weekly value:
6
If you determine compliance on a rolling-annual basis and don't use
a recovery device, 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)
Q Yes
Q No
Last monthly value:
7
If you determine compliance on a rolling-annual basis and don't use
a recovery device, do you calculate annual emissions by summing the
actual monthly sourcewide HAP emissions for each of the individual
12 months in the period? §63.1299(c) (4)
Q Yes
Q No
8
If you determine compliance on a monthly basis and don't use a
recovery device, do you compare actual HAP emissions for each
month to allowable HAP emissions for that month? §63.1299(b)
Q Yes
Q No
Last actual HAP value:
Last allowable HAP value:
9
If you determine compliance on a monthly basis and don't use a
recovery device, do you use Equation 5 in §63.1299(c) to calculate
actual, sourcewide, emissions? §63.1299(c)(1)
Q Yes
Q No
Value Equation 5:
72
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
W. Requirements tor Sourccwidc Emission Limit Comments
Note: This includes emissions from HAP ABA storage and equipment leaks, HAP ABA
emissions from the production line and equipment cleaning
10
If you determine compliance on a monthly basis and don't use 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)(2); §63.1303(d)
Q Yes
Q No
Last weekly value:
11
If vou don't use a solvent-recoverv device and vou determine
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)
Q Yes
Q No
Last monthly value:
12
If you determine compliance on a rolling-annual or monthly basis
and vou use a solvent-recoverv device, do vou use Eauation 6 to
calculate the allowable HAP emissions for each month? §63.1299(e)
Q Yes
Q No
Value Equation 6:
13
If you determine compliance on a rolling-annual or monthly basis
and vou use a solvent-recoverv device, do vou use Eauation 7 to
calculate actual, monthly, HAP ABA emissions? §63.1299(e)(1)
Q Yes
Q No
Value Equation 7:
14
If you determine compliance on a rolling-annual or monthly basis
and vou use a solvent-recoverv device, have vou submitted a HAP
ABA monitoring program for approval? §63.1299(e)(2); §63.1303(c)
Q Yes
Q No
Submittal date:
Approval date:
X
Monitoring Requirements for Sourccwidc Emissions when a Recovery Device is Used
SKIP this section if you don't use a recovery device
Comments
1
Have you sent a recovered HAP monitoring and recordkeeping plan in
for approval? §63.1303(c)
Q Yes
Q No
Date Sent:
Date Approved:
2
Does your equipment have a device showing the cumulative amount
of HAP ABA recovered by the solvent-recovery device each month?
§63.1303 (c)(1)
Q Yes
Q No
Last cumulative monthly
value:
3
Has the manufacturer certified the device to be accurate within +/- 2.0
percent? §63.1303(c)(1)
Q Yes
Q No
Device accuracy:
4
Do you measure after fully recovering the HAP ABA (i.e., after
separating it from water introduced into the HAP ABA during
regeneration)? §63.1303 (c)(2)
Q Yes
Q No
73
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Y. Recordkeeping Requirements tor 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 Q Yes Q No
• Amount of polyol added to the production line for slabstock q yes Q 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
produced during each run of foam (not required on grades of
foam for which you've designated a zero formulation limit for
HAP ABA)
Q Yes Q No
If you're complying using rolling-annual or monthly compliance
option, do you keep weekly records of the storage tank level?
§63.1303 (c)(2)(h)
3 If you're complying using rolling-annual or monthly compliance
option, do you keep the following records monthly?
§63.1307(c)(2) (in)
Q
Yes
Q No
• List of all foam grades produced during the month
Q
Yes
Q No
• Formulation limit on residual HAP for each foam grade produced
• Total amount of polyol used in the month for each foam grade
Yes
Q No
produced (not required if zero is the formulation limit for HAP
Q
ABA)
• Total allowable HAP ABA and equipment-cleaning emissions for
Q
Yes
Q No
the month
• Total actual sourcewide emissions of HAP ABA for the month
Q
Yes
Q No
• Amounts of HAP ABA in the storage vessel at the beginning and
Q
Yes
Q No
end of the month
• Amount of each delivery of HAP ABA to the storage vessel
Q
Yes
Q No
74
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Y. Recordkeeping Requirements tor Sourcewide Emissions Comments
4 If complying by the rolling-annual or monthly option, do you
keep the following? §63.1307(c)(2)(v) - (vii)
• Records of all calibrations for each device used to measure polyol
added at the mixhead
Q Yes Q No
Q Yes Q No
Records of all calibrations for each device used to measure
amount of HAP ABA in the storage vessel
Written confirmation of State or local approval of scales, or the
registered scale technician's report for all scales used to measure Q Yes Q No
the amount of HAP ABA added to storage vessels
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
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.
Q Yes Q No
Q Yes Q No
Z Recordkeeping Requirements for Sourcewide Emissions when a Recovery Device is Comments
Used
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
recovered HAP ABA
Q
Yes
Q
No
Certification of the monitoring device's accuracy
Q
Yes
Q
No
Records of periodic calibration of the monitoring device
Q
Yes
Q
No
Records of parameter-monitoring results
Q
Yes
Q
No
Amount of HAP ABA recovered each time you measure it
Q
Yes
Q
No
75
-------
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
based on the fluid's average composition, rather than on the individual
VOC in the stream? §63.1304 (a)(2)
Q Yes
Q No
2
If the source stream contains nitrogen, air, or other inerts that aren't
HAP or VOC, do you calculate the average stream response factor on
an inert-free basis? §63.1304 (a)(2)
Q Yes
Q No
3
Do you calibrate the detection instrument before each use on the day
of its use according to Method 21, Appendix A, of 40 CFR Part 60?
§63.1304 (a)(3)
Q Yes
Q No
Date Last Use:
Date Last Calibration:
4
Are calibration gases zero air (less than 10 ppm of hydrocarbon in
air)? §63.1304 (a)(4)
Q Yes
Q No
Calibration gas used:
5
Are calibration gases a mixture of methane and air at a concentration
of about 1,000 ppm for all transfer pumps and 500 ppm for all other
equipment? §63.1304 (a)(4)
Q Yes
Q No
6
If the instrument design allows for multiple concentrations of gas, is
the lower concentration no higher than 2,000 ppm methane and the
higher concentration no higher than 1,000 ppm methane? §63.1304
(a)(4)
Q Yes
Q No
7
Do you monitor when the equipment is in HAP ABA service, with
an acceptable surrogate volatile organic compound that isn't a HAP
ABA, or with any other detectable gas or vapor? §63.1304 (a)(5)
Q Yes
Q No
8
If the instrument used for monitoring doesn't meet the performance
criteria in Method 21, do you adjust readings by multiplying the
average response factor for the stream? §63.1304 (a) (6)
Q Yes
Q No
Value average response
factor:
9
Unless the formulation limit for HAP ABA is zero, do you use
ASTM D3574 to determine the IFD for each grade of foam produced
during each run? §63.1304 (b)
Q Yes
Q No
10
Do you cut each sample of foam from the center of the foam bun?
§63.1304 (b)
Q Yes
Q No
11
Is each sample of foam no larger than 24 inches by 24 inches by 4
inches? §63.1304 (b)
Q Yes
Q No
76
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
Section XI: Reporting Requirements (Options 1 or 2)
BB. Reporting Requirements Comments
1
Did you send in an initial notification form? §63.1306(a)
Q Yes
Q No
Date submitted:
2
Have you applied for approval of construction or reconstruction?
§63.1306(b)
Q Yes
Q No
Date submitted:
3
Did you send in a precompliance report? §63.1306(c)
Q Yes
Q No
Date submitted:
4
Did you send in a notification of compliance status?
§63.1306(d) (4)
Q Yes
Q No
Date submitted:
5
Do you send in semiannual compliance reports no later than 60
days after the end of the 180-day period? §63.1306(e)
Q Yes
Q No
Date end of period:
Date submitted:
6
Do you submit an annual compliance certification? §63.1306(g)
Q Yes
Q No
Date first certification
due:
Date certification
submitted:
7
If you switch from emission point specific limit to sourcewide
limit, or vice versa, did you make notification before changing?
§63.1306(f)
Q Yes
Q No
Date Notification Submitted:
Date Limit
Switched:
8
If you switch from rolling-annual to monthly, or vice versa, did
you make notification before changing? §63.1306(f)
Q Yes
Q No
Date Notification Submitted:
Date Method Switched:
Additional comments:
77
-------
Table 3.3 Checklist for Inspecting Slabstock Foam Plants (cont'd)
78
-------
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
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
Figure 4.1 (on page 67) shows a typical process for molded foam.
What is exempt under this section?
Your molded foam process is exempt if it's devoted exclusively to either of the following
[§63.1290]:
• fabricating molded foam
•c
on
du
cti
ng
re
se
ar
ch
an
Definition. A molded flexible polyurethane 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
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 except in a de
minimis manner."
Definition. Foam fabrication process means "an operation for cutting or bonding flexible
79
-------
Chapter 4 - Complying with requirements for molded foam
d development
80
-------
Figure 4.1
A Typical Process for Molded-Foam Production
Process Description:
Raw chemicds 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. Alter 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.
81
-------
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.
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."
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?
82
-------
None for molded foam production.
83
-------
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
lb HAP/lb solids)
What reports must I submit?
You must submit four types 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)]
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 HAP-based mold-release agent [§63.1300(b)]
• maintain product data-sheets for each solvent you use [§63.1307(g)]
• 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.
84
-------
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
Note: If you answer NO to ALL questions in Section A, you are in compliance with
§63.1300. However, your are still subject to recordkeeping requirements in
§63.1307(g) and (h).
Comments
1
Do you use HAPs as an equipment cleaner to flush the mixhead or
associated piping? §63.1300 (a)
You may use diisocyanates as an equipment cleaner if you follow
procedures in section B. If you use diisocyanates as an equipment
cleaner, complete section B.
Q Yes
Q No
2
Do you use HAPs as an equipment cleaner elsewhere in the process?
§63.1300 (a)
Q Yes
Q No
3
Do you use HAPs as a mold-release agent? §63.1300 (b)
Q Yes
Q No
B.
Flush Cleaning with Diisocyanates
Comments
1
Do you use diisocyanates as an equipment cleaner to flush the
mixhead? §63.1300(a)
Q Yes
Q No
2
Do you use diisocyanates as an equipment cleaner to flush associated
piping? §63.1300(a)
Q Yes
Q No
3
Do you use diisocyanates only during startup or maintenance?
§63.1300(a)
Q Yes
Q No
4
Are diisocyanates contained in a closed-loop system? §63.1300(a)
Q Yes
Q No
5
Do you reuse diisocyanates in production? §63.1300(a)
Q Yes
Q No
C.
Recordkeeping
Comments
1
Do you have product data-sheets for each compound used? 63.1307(g)
Q Yes
Q No
85
-------
Table 4.1 Checklist for Inspecting Molded foam Plants (cont'd)
c.
Recordkeeping
Cum iiK-ii Is
2
Is HAP data available for each compound you use (expressed in kg of
HAP/kg solids or lb HAP/lb solids)? §63.1307(g)
Q Yes
Q No
3
Do you have product data-sheets for each mold-release agent use?
§63.130 7(h)
Q Yes
Q No
4
Is HAP data available for each mold-release agent you use (expressed in
kg of HAP/kg solids or lb HAP/lb solids)? §63.130 7(h)
Q Yes
Q No
D.
Reporting
Comments
1
Did you submit an initial notification? §63.1306(a)
Q Yes
Q No
Date last submitted:
2
Have you applied for approval of construction or reconstruction?
§63.1306(b)
Q Yes
Q No
Date last submitted:
3
Did you submit a notification of compliance status? §63.1306(d)(4)
Q Yes
Q No
Date last submitted:
4
Did you submit an annual compliance certification? §63.1306(g)
Q Yes
Q No
Date last submitted:
Additional comments:
86
-------
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
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 straightfrom the rule
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."
§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
87
-------
88
-------
Figure 5.1
A Typical Process from R^bmirl-Foflm Production
ProceeE Description:
Bulk foam scrap is ground into suitable small pieces. Hie shredded pieces are fiinndcd into a
storage container. The pieces are then loaded into a blend tank, where a binder is added, which
usually is a prepolymer of polyol and diisocyanate. After addition of the catalyst and thorough
mi-Hi-ip the foam/binder mixture is placed in a mold, compressed, and kept compressed dining
curing with heat and steam. After the rebotided-foam is set, it is cut and packaged.
Bulk Foam
Scrap
89
-------
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
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.
90
-------
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 lb HAP/lb solids)
What reports must I submit?
You must submit four types 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)]:
• 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?
91
-------
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.
92
-------
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: If you answer NO to ALL questions in Section A, don't proceed. Your rebond
foam process isn't covered because you don't use EAPs.
1
Do you use HAPs as equipment cleaners? §63.1301 (a)
Q Yes
Q No
2
Do you use HAPs as a mold-release agent? §63.1301(b)
Q Yes
Q No
B.
Recordkeeping
Comments
1
Do you have product data-sheets available for each compound used?
§63.1307(g)
Q Yes
Q No
2
Is HAP data available for each compound use (expressed in kg of
HAP/kg solids or lb HAP/lb solids)? §63.1307(g)
Q Yes
Q No
3
Do you have product data-sheets for each mold-release agent you use?
§63.1307(h)
Q Yes
Q No
4
Is HAP data available for each mold-release agent you use? (expressed
in kg of HAP/kg solids or lb HAP/lb solids)? §63.1307(h)
Q Yes
Q No
C.
Reporting
Comments
1
Did you submit an initial notification form? §63.1306(a)
Q Yes
Q No
Date last submitted:
2
Have you applied for approval of construction or reconstruction?
§63.1306(b)
Q Yes
Q No
Date last submitted:
3
Did you submit a notification of compliance status? §63.1306(d) (4)
Q Yes
Q No
Date last submitted:
4
Did you submit an annual compliance certification? §63.1306(g)
Q Yes
Q No
Date last submitted:
Additional comments:
93
-------
94
-------
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 (HAP^), it may be exempt from the rule [§63.1290(c)(3)], HAPused refers to the amount of
HAP chemicals used, not to HAP emissions.
HAPused 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 HAPused 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 lb/gal
Methylene chloride content of adhesive - 60 weight percent
95
-------
Equation 1 from the Rule:
aifLi-t
X 2000
1
where,
HAP,,
VOLa
-^ABA,i
m
VOL,
D,
'cleanj
cleanj
HAPclean,k
n
VOLadhik
Dadh,k
WTUAParlh V
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
number of HAP ABAs used - 1
volume of methylene chloride used as an equipment cleaner - 100 gal
per year
density of methylene chloride equipment cleaner, 10.4 pounds per gal
HAP content of methylene chloride equipment cleaner - 100 weight
percent
number of HAP equipment cleaners used - 1
volume of adhesive XYZ used - 1,300 gal per year
density of adhesive XYZ - 9.8 pounds per gal (from MSDS)
methylene chloride content of adhesive XYZ - 60 weight percent (from
MSDS)
number of adhesives used - 1
HAP.
utri
_ (625X10.4) + (100X10.4X1.0) + (1,300)P.B)(0.60) _ n s ^
2,000
Therefore, for Example 1, this 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.
96
-------
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 DEF, plus
2,500 gallons of adhesive ABC with the following properties:
Density of adhesive - 10.1 lb/gal
Methylene chloride content of adhesive - 70 weight percent
r 2000
^ 1
where:
Housed
VOLA|,Ai
DaBA.1
m
VOLcleaiy
-^cleanj
HAPclean,k
n
VOL
-^adh.ABC
Dadh,ABC
WT
HAPPAdh,ABC
VOLa,
D
adh,DEF
WT
HAPadh,DEF
o
amount of HAP, excluding TDI 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
density of HAP ABA - N/A
number of HAP ABAs used - 0
volume of HAP used as equipment cleaner -NA
density of HAP equipment cleaner, N/A
HAP 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)
volume of adhesive DEF used - 1,200 gal /yr
density of adhesive DEF - N/A
HAP content adhesive ABC - 0 weight percent
number of adhesives used - 2
97
-------
^ - (PXP) * (D>q»q» + [a,ooo)go.2)(o.70)i- (i,ooqxoxo)] _ 3 ftD,
"¦* 2,000
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
. . ,.r . ,, ., ,. Use Equation 3 to calculate the HAP ABA
emissions (it using the sourcewide compliance
formulation limit
option).
Equation 3 of the rule [§63.1297(d)(1)] 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:
ABAtoa- - 0.25- 16.2{MW>-
7-56y^36'5
where:
ABAjimit = 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.
98
-------
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.
AflW- - 0.25(28)- 19.1(-U- 16.2(1.2)-
7.S6(-Ui-36.S - 3 pph
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 density of 2.1 pcf and an IFD of 30 pounds.
Using Equation 3 from the rule (see above), where:
ABAjimit = 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 -
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(-i)- 16.2(2.1)-
7.56^) 1-36,5 = -9 ppk
Paragraph §63.1297(d)(1) 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
99
-------
an IFD of 30 pounds is 0 parts HAP ABA per 100 parts polyol.
How do I calculate allowable HAP ABA emissions to comply
using the emission point specific limit?
Use Equation 2 to calculate allowable HAP ABA
emissions
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 used, the allowable level
of HAP ABA 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
en^aEovi^ionth 9 £
J= 1
£
z= 1
100
where:
emissai,
m
n
limit;
polyo^
= Allowable HAP ABA emissions from the slabstock affected source
for the month, pounds
= Number of production lines for slabstock foam at the affected source
= 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
= 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 HAP 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.
100
-------
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 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 shown 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 lbs) and foam grade 1540 (density of 1.5 pcf and IFD of 40 lbs). 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:
ABAJimit= - 0.25(30)- 19.1<^>- 16.2(0.9)-
7.56(—) + 36.5 = 5 pph
0.9 ^
Therefore, the HAP ABA formulation for foam grade 0930 is 5 pph.
For foam grade 1540, the calculation is as follows:
101
-------
MAbwt = " 0.25(40)- 19.1C-^>- 16.2(1.5)-
7.56(J_> + 36.5 = - 3 pph
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
em^ssaRov9/)iontk = £
7= 1
r ¦
i= 1
100
Where:
emissauow month = Allowable HAP ABA emissions from the slabstock foam
production source for the month, pounds.
m = Number of slabstock foam production lines.
p0|y0| = Amount of polyol used in the month in the production of foam
grade i on foam-production line j, pounds.
n = Number of foam grades produced in the month on foam production
linej.
limit = HA? 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
102
-------
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:
Allowable HAP ABA emissions from the slabstock foam
production source for the month for foam grade 0930, pounds.
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
For foam grade 1540, where:
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 parts
HAP ABA per 100 parts polyol
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
cm'ssallow,month,0930
m =
polyo^ ~~
limit; =
cm issa) lownion tli. 1540
m =
polyo^ ~~
limit; ~~
103
-------
You have two options on the compliance period you will 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.
104
-------
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 - 2,753.
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 you add at
the mixhead. Determine the latter
amount by monitoring the HAP ABA
pump revolutions or flow rate. Following
emissions for the facility in Example 5.
If you 're not using a recovery device, the actual HAP
ABA emissions are equal to the amount of HAP ABA
added at the mixhead
is an example of how to calculate actual HAP ABA
105
-------
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) would be the actual
HAP ABA emissions for the month (4,420 pounds for our example 5 facility) plus the actual HAP
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.
106
-------
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 use a recovery device, your actual emissions are
equal to the amount of HAP ABA added at the
mixhead minus the amount of HAP ABA recovered.
Use Equation 4 of the rule to calculate actual
emissions.
a recovery device is used.
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 lbs/gal) of methylene chloride at the mixhead and recovered 21,840
pounds (2100 gallons at 10.4 lbs/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:
^actual = ^unc ~
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 recovered. Use
Equation 4 of the rule [§63.1297(e)(1)] to
calculate actual HAP ABA emissions when
107
-------
where:
Actual HAP ABA emissions after control, pounds/month.
Uncontrolled HAP ABA emissions - 26,000 pounds
HAPABArecoverec[ = 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 emissions 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.
108
-------
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.
• 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
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,
Example 8
Assumptions:
Use Equation 6 to calculate allowable
sourcewide limits
6.3.
109
-------
• 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 8 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 complying 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 vessels at the beginning of
the month and at the end of the month.
You will also need the amount of HAP ABA added to each storage vessel during the month.
If you 're not using a recovery device, use Equation 5
to calculate actual emissions
Equation 5 of the rule [§63.1299(c)(1)] 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.
110
-------
Tank 1
Tank 2
Amount of MeCl in tank at beginning of month (lbs)
1,046
80,064
Amount of MeCl in tank at end of month (lbs)
47,300
78,400
Amount of MeCl added to tank (lbs)
50,000
0
Equation 5 from the rule:
where:
PfBactual = T^iktepi -
i
PWEactuaj = Actual sourcewide HAP ABA and equipment cleaning HAP emissions
for a month, in pounds/month.
n = Number of HAP ABA storage vessels - 2.
ST begin = Amount of HAP ABA in storage vessel 1 at the beginning of the
month, 1,046 pounds.
ST,, end = Amount of HAP ABA in storage vessel 1 at the end of the month,
47,300 pounds.
ADD = 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 're usins « recovery device, use Equation 7 to
vessels and subtracting the amount of calculate actual sourcewide HAP emissions
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.
Ill
-------
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.
Tank 1
Tank 2
Amount of MeCl in tank at beginning of month
(lbs)
2,346
40,000
Amount of MeCl in tank at end of month (lbs)
26,832
77,000
Amount of MeCl added to tank (lbs)
40,000
50,000
Lets assume that our example facility recovered 24,250 pounds of methylene chloride in June 2002.
Equation 7 from rule
4_i =
where:
^actual = Actual sourcewide HAP emissions after control,
pounds/month.
n
= z(FTiJbegin ~ ^i^nd + ALDj)
i
Eunc = Uncontrolled sourcewide HAP emissions =
HAPABArecoverecj = HAP ABA recovered, 24,250 pounds/month.
Therefore, the actual sourcewide HAP emissions for June 2002 are 4,264 pounds.
112
-------
To determine whether you are in compliance for the compliance period, compare the actual
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 sourcewide 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.
113
-------
How can I check my slabstock process for leaks?
The EPA Publication, APTI 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://www.epa.gov/oar/oaqps/eog/.
114
-------
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.
Density IFD
Grade (pcf> fibs)
930
0.9
30
1010
1.0
10
1015
1.0
15
1020
1.0
20
1030
1.0
30
1120
1.1
20
1130
1.1
30
1230
1.2
30
1330
1.3
30
1340
1.3
40
1440
1.4
40
1520
1.5
20
1530
1.5
30
1540
1.5
40
1640
1.6
40
1740
1.7
40
1820
1.8
20
1830
1.8
30
1840
1.8
40
1930
1.9
30
1940
1.9
40
>2020
2.5
25
115
-------
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
Density
(pcf)
IFD
(lbs)
HAP ABA
Formulation
Limitation
(pph)
930
0.9
30
5
1010
1.0
10
8
1015
1.0
15
8
1020
1.0
20
7
1030
1.0
30
5
1120
1.1
20
6
1130
1.1
30
4
1230
1.2
30
3
1330
1.3
30
1
1340
1.3
40
0
1440
1.4
40
0
1520
1.5
20
1
1530
1.5
30
0
1540
1.5
40
0
1640
1.6
40
0
1740
1.7
40
0
1820
1.8
20
0
1830
1.8
30
0
1840
1.8
40
0
1930
1.9
30
0
1940
1.9
40
0
>2020
>2.5
>25
0
116
-------
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
Density
(pcf)
IFD
(lbs)
HAP ABA
Formulation
Limitation
(pph)
Amount of
polyol used in
the month
(pounds)
Allowable HAP
ABA
Emissions
(pounds)
930
0.9
30
5
13,300
665
1010
1.0
10
8
6,600
528
1015
1.0
15
8
6,700
536
1020
1.0
20
7
6,500
455
1030
1.0
30
5
13,500
675
1120
1.1
20
6
6,600
396
1130
1.1
30
4
10,000
400
1230
1.2
30
3
16,500
495
1330
1.3
30
1
10,000
100
1340
1.3
40
0
9,500
0
1440
1.4
40
0
10,750
0
1520
1.5
20
1
7,000
70
1530
1.5
30
0
7,500
0
1540
1.5
40
0
20,000
0
1640
1.6
40
0
19,500
0
1740
1.7
40
0
21,000
0
1820
1.8
20
0
9,000
0
1830
1.8
30
0
8,500
0
1840
1.8
40
0
22,000
0
1930
1.9
30
0
10,000
0
1940
1.9
40
0
16,500
0
>2020
>2.5
>25
0
85,000
0
Totals
335,950
4,320
117
-------
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 your 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:
118
-------
• to your EPA Regional Office if your State has not been delegated the authority to
implement and enforce the Flexible Polyurethane Foam Production NESHAP
• 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,
VIII 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 III (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 alternative monitoring program for HAP Auxiliary Blowing Agent (ABA) and polvol
added to the foam production line at the mixhead [§63.1303(b)(5)], and HAP ABA added to
storage vessels [§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).
119
-------
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.
120
-------
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 recovery
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:
Page
• 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.
121
-------
Table 7.1 - Report Due Dates
If you have.
And need to submit a
Then submit the report
before...
Initial Notification Report [§63.1306(a)]
2/4/99
(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 date)
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
Precompliance Report [§63.1306(c)]
10/8/00
(12 months before compliance
date)
Initial Semi-annual Compliance Report
12/2/02 (include information from
[§63.1306(e)]
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 from
initial semiannual compliance report.
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)
An existing Slabstock,
Molded or Rebond plant
plant
addition to the above)
122
-------
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(f)(1),(2)]
180 days before the change takes
effect
(120 days after the effective date)
A new Slabstock,
Molded
Initial Notification Report [§63.1306(a)]
2/4/99 or 120 days after initial
startup or use your construction
or Rebond plant
permit
Application for Approval of Construction or
Reconstruction, if constructing after 10/7/98
(effective date) [§63.5(d)]
As soon as practicable before
construction is planned to start
but no sooner than 10/7/98
(effective date)
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 date) [§63.5(d)]
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)]
240 days after initial startup
Annual Compliance Certification [§63.1306(g)]
Annually - can submit with semi-
annual report
A new Slabstock plant
Precompliance Report [§63.1306(c)]
10/7/00 or 12 months after initial
startup, whichever is later
(These requirements are in
addition to the above)
Initial semi-annual Compliance Report
[§63.1306(e)]
240 days after the notification of
compliance is due
Subsequent semi-annual Compliance Reports
[§63.1306(e)]
240 days after the Initial semi-
annual Compliance Report and
every 60 days after the end of
each 180 day period thereafter
Change in Selected Emission Limit and
Compliance Method [§63.1306(f)(1),(2)]
180 days before the change takes
effect
123
-------
Table 7.2 Reporting Requirements
If you are submitting
an...
Initial Notification
Report
[slabstock, molded and
rebond foam plants]
then submit bv ...
120 days after the
effective date or 120
days after rule applies
to your facility
and include the following information ...
Name and address of owner or operator.
Address (physical location) of the facility.
Compliance date.
Brief description of nature, size, 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 Before construction or Applicant's name and address. §63.1306(b); §63.5(d)
Approval of reconstruction v_
Notmcation ot intent to construct or reconstruct.
Construction or
Reconstruction Address (physical location) of the facility.
Identify the standard you're subject to.
[slabstock, molded and
rebond foam plants] Date y°u 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.
For construction, description of proposed nature, size, design, method of operation and
emission controls and other information under §63.5(d) (2).
For reconstruction, brief description of the facility, parts to be replaced and emission
controls and other information under §63.5(d)(3).
124
-------
Table 7.2 Reporting Requirements (cont'd)
If you are submitting
an...
Precompliance Report
[slabstock foam plants]
then submit In
12 months before
compliance date
and include the following information ..
Whether you'll comply using the emission point specific limit or sourcewide emission limit.
Whether you'll comply on a rolling-annual or monthly basis.
Description of how you'll monitor HAP ABA or polyol added at the mixhead.
Notice of your intent to use a recovery device.
A copy of your program for continuous monitoring and recordkeeping on recovered HAP
ABA, if complying using a recovery device.
If complying with the sourcewide 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)(i)-(iv), if
applicable.
according to these
sections of the rule..
§63.1306(c)
Notification of
Compliance Status
[slabstock, molded and
rebond foam plants]
Within 180 days after
compliance date
List of your diisocyanate storage vessels, and controls used for each.
Type of control used for each transfer pump in diisocyanate service.
If complying with the emission point specific limits:
• List of HAP ABA storage vessels, along with control used for each
• List of pumps, valves, connectors, pressure-relief devices, and open-ended valves or
lines in HAP ABA service
• List of any modifications to equipment in HAP ABA service you've made to
comply with §63.1296
§63.1306(d)
125
-------
Table 7.2 Reporting Requirement (cont'd)
and include the following information ... according to these
sections of the rule...
If you're using rolling-annual compliance, report the allowable and actual HAP ABA §63.1306(e)
emissions (or allowable and actual sourcewide HAP emissions) for each 12-month period
ending on each of the six months in the reporting period (not required for initial semi-annual
compliance report).
If you're using monthly compliance, report allowable and actual HAP ABA emissions (or
allowable and actual sourcewide 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 180 days before a Notify your regulatory agency that you're switching from complying with the emission point §63.1306(f)(1)
Emission Limit change takes effect specific limit to the sourcewide emission limit (or vice versa).
[slabstock foam plants]
Change in Selected 180 days before a Notify your regulatory agency that you're switching from monthly to rolling-annual §63.1306(f)(2)
Compliance Method change takes effect compliance (or vice versa).
[slabstock foam plants]
If you are submitting
an...
Semiannual Compliance
Report
[slabstock foam plants]
then submit by ...
Semiannually no later
than 60 days after the
end of the 180-day
period.
126
-------
Table 7.2 Reporting Requirement (cont'd)
If you are submitting then submit by ... and include the following information ... according to these
an sections of the rule..
Annual Compliance Annually Statement that your facility complies with each applicable requirement of the rule. §63.1306(g)
Certification
[slabstock, molded or
rebond foam plants]
127
-------
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)]:
~ (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):
~ Slabstock flexible polyurethane foam production
~ Molded flexible polyurethane foam production
~ 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)]:
128
-------
Example Initial Notification Report (Cont'd)
5. Identify each point of emission for each Hazardous Air Pollutant (HAP). If you can't 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: ~ Definitive ~ Preliminary
Source ID
Source Location
Source
Description
Operation Performed
6. My plant is a major source of Hazardous Air Pollutants (HAPs) ~ Yes ~ 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 orrebond foam production facilities.
129
-------
End of Initial Notification Form
130
-------
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)]
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
[§64.5(d)(1 )(ii)(A), (C)]:
Owner/Operator/Title
Street Address
City State Zip Code:
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:
131
-------
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)
[§64.5(d)(1 )(ii)(B)]:
~ construct a new major affected source
~ reconstruct a major affected source
~ 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: ~ Definitive ~ Preliminary
132
-------
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: ~ Definitive
~ Preliminary
133
-------
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
134
-------
135
-------
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
136
-------
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 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. Check which compliance option you're choosing for your slabstock facility (check all that apply)
[§63.1306(c)(2)]:
~ Emission point limit described in §63.1293(a) [§63.1306(c)( 1)]
check which option you're choosing [§63.1306(c)(2)]
~ I'll comply on a rolling-annual basis under §63.1297(b)
~ I'll comply on a monthly basis under §63.1297(c)
~ Sourcewide emission limit described in §63.1293(b) [§63.1306(c)( 1)]
check which option you're choosing [§63.1306(c)(3)]
~ I'll comply on a rolling-annual basis under §63.1299(a)
~ I'll comply on a monthly basis under§63.1299(b)
137
-------
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)]:
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:
~ Yes (don't fill out the rest of 4, go to 5)
~ 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)(H)]:
138
-------
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)]:
5. 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:
~ Yes (don't fill out the rest of 5, go to 6)
~ 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)]:
139
-------
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)]:
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)]:
(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)]:
140
-------
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:
~ Yes (don't fill out the rest of 8, go to 9)
~ 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)]:
141
-------
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)(H)]:
(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
142
-------
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
143
-------
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:
~ Yes
~ No
If yes, provide the following information; otherwise, go to 3:
(c1) List your HAP ABA storage vessels, and the type of control you use [§63.1306(d)(3)(i)]:
HAP ABA Storaqe Vessels
Type of control
144
-------
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)(H)]:
Equipment List
Type
~ pump ~ valve ~ pressure-relief device
~ open-ended valve or line ~ connector
~ pump ~ valve ~ pressure-relief device
~ open-ended valve or line ~ connector
~ pump ~ valve ~ pressure-relief device
~ open-ended valve or line ~ connector
~ pump ~ valve ~ pressure-relief device
~ open-ended valve or line ~ 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
~ My affected source for molded foam complies with §63.1300
~ 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
145
-------
Example Notification of Compliance Status (cont'd)
~ My affected source for rebond foam complies with §63.1301
~ My rebond foam processes at the affected source comply with §63.1301
End of Notification of Compliance Status
146
-------
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.
147
-------
Example Semi-Annual Compliance Report (cont'd)
Type of Affected source:
Type of emission limit used:
~ actual HAP ABA emission or ~ sourcewide HAP emissions
Reporting
Period
Reporting
Year
allowable emissions
( units)
actual emissions
( units)
January
February
March
April
May
June
July
August
September
October
November
December
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)],
148
-------
Example Semi-Annual Compliance Report (cont'd)
Affected source:
Type of emission limit used:
~ actual HAP ABA emission or ~ sourcewide HAP emissions
Reporting
Period
Reporting
Year
allowable
emissions
( units)
actual emissions
( units)
January
February
March
April
May
June
July
Auqust
September
October
November
December
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
149
-------
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)(H) 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 ofVapor-
Return Line
Date Leak
Detected
Applicable Section
of Rule
(as indicated above)
Comments
End of Semiannual Report
150
-------
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
151
-------
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 ~ molded foam ~ Rebond foam ~ 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:
152
-------
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(d)(2) of the Act."
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 NESFIAP 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 atwww.epa.gov/ttn/oarpg/t5main.html.
153
-------
How do I change my permit to include this rule?
If you've already been issued a final title 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 effective ^
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 permit
update your title V permit during renewal
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).
2 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 www.epa.gov/ttn/oarpg/t5main.html and
www.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 Provision requirements,
except for notification and reporting are not addressed in this document.
154
-------
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 (www.4cleanair.org) and then the membership directory. 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
Trade Associations representing the flexible polyurethane foam industry are listed below. Trade associations
sometimes have rule information for their members.
Tr;idi' .\ssiii'i;ilinii
Ti'k'phiiiK- #
Addivss
Carpet Cushion Council
(203)637-1312
26 Arcadia Rd., Suite 8
Old Greenwich, CT 06870
Society of the Plastics Industry,
(202) 974-5362
1801 "K" Street
Inc. Polyurethane Division
600K
Washington, DC 20006
Polyurethane Foam Assoc.
(973)633-9044
P.O. Box 1459
Wayne, NJ 07474
155
-------
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.epagov/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
www.epa.gov/ttn/uatw/foam/foampg.html.
• EPA's Applicability Determination Index (ADI) (http://es.epagov/oeca/eptdd/adihtml)
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.epagov/epahome/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://www.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.
156
-------
Table 9.1
EPA Regional Air Division Offices
EPA Region
States Covered
Division Phone and Address
Phone
Home Page
Region 1
CT, ME, MA, NH, Rl
& VT
Office of Environmental Stewardship
(OES)
1 Congress Street, Suite 1100
Boston, MA 02114-2023
(617)918-1510
www. epa. gov/region 1
Region II
NJ, NY, Puerto
Rico & Virgin
Islands
Division of Environmental Planning and
Protection
290 Broadway, 21 st Floor
New York, NY 10007-1866
(212)637-3735
www. epa. gov/region2
Region III
DE, MD, PA, VA,
WV&DC
Air Protection Division, 3AP12
1650 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/region 6
Region VII
IA, KS, MO & NE
Air, RCRA and Toxics Division
726 Minnesota Avenue
Kansas City, KS 66101
(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/region 9
Region X
AK, ID, WA&OR
Office of Air Quality
1200 Sixth Avenue
Seattle, WA 98101
(206)553-1505
www.epa.gov/region 10
157
-------
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 ofFlexible 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.
158
-------
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
www.epa.gov/ttn/uatw/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.
159
-------
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
E
LU
Q.
<
X
Slabstock Foam
Before Regulation a After Regulation
160
-------
Table 10.1
1993 U.S. Slabstock Foam Plant List
SI A II.
COMI'AM
LOCATION
ARKANSAS
CALIFORNIA
DELAWARE
FLORIDA
Foamex (formerly Crain Industries)
Hickory Springs Manufacturing Co.
Ludwig, Inc.
Foamex (formerly Crain Industries)
Foamex (formerly Crain 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.
Fort Smith
Fort Smith
Waldo
Compton
San Leandro
Lathrop
Riverside
Orange
San Bernadino
Fullerton
Commerce
Newark
Miami
Orlando
Miami
GEORGIA
ILLINOIS
INDIANA
IOWA
KANSAS
MARYLAND
Austin Urethane, Inc.
Foamex (formerly Crain Industries)
Foamex, L.P.
Hickory Springs Manufacturing Co.
Woodbridge Foam
Burkart Foam, Inc.
General Foam Corp.
No-Sag Foam Products
Foamex (formerly Crain 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.
Americus
Newman
Conyers
Americus
Lithonia
Cairo
Bridgeview
West Chicago
Elkhart
Indianapolis
Elkhart
Elkhart
Auburn
Elkhart
Fort Wayne
Laporte
Council Bluffs
Newton
Baltimore
161
-------
Table 10.1
Slabstock foam Plant List (cont'd)
SI A II.
COMI'AM
LOCATION
MASSACHUSETTS
MICHIGAN
Crest Foam Industries
Armaly Brands
Plastomer Corp.
Newburyport
Walled Lake
Livonia
MINNESOTA
MISSISSIPPI
General Foam of Minnesota
Hickory Springs Manufacturing Co.
MPI, Inc.
Vitafoam (formerly Olympic Products Co.)
Superior Product Sales, Inc.
Vitafoam, Inc.
St. Paul
Verona
Coldwater
Tupelo
Plantersville
Tupelo
MISSOURI
Foamex (formerly Crain Industries)
Carpenter Company
Foamex, L.P.
Verona
Verona
Verona
NEVADA
NEW JERSEY
NORTH CAROLINA
Universal Urethanes, Inc.
Crest Foam Industries
General Foam Corp.
Foamex (formerly Crain 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.)
N. Las Vegas
Moonachie
East Rutherford
Conover
Conover
Cornelius
Conover
Mount Airy
Mount Airy
Asheboro
High Point
Greensboro
OHIO
Flexible Foam Products
Scottdel, Inc.
Spencerville
Swanton
OREGON
PENNSYLVANIA
Hickory Springs Manufacturing Co.
Foamex (formerly Crain Industries)
Foamex, L.P.
Foamex, L.P.
General Foam Corp.
Portland
Easton
Corry
Eddy stone
West Hazelton
TENNESSEE
Foamex, L.P.
Milan
162
-------
Table 10.1
Slabstock foam Plant List (cont'd)
SI A II.
COMI'AM
LOCATION
Foamex, L.P.
Morristown
Nu-Foam Products, Inc.
Chattanooga
TEXAS
Carpenter Company
Temple
Flexible Foam Products
Terrel
Foamex, L.P.
Mesquite
Texas Fibers Branch 1708
Brenham
VIRGINIA
Carpenter Company
Richmond
WASHINGTON
Foamex (formerly Crain Industries)
Kent
WISCONSIN
Future Foam, Inc.
Middleton
163
-------
Figure 10.1
Slabstock Flexible Polyurethane foam Plants (77 plants)
No. Plant Sites
(per Regional Office):
R6- 8
R7- 5
R8- 0
R9-9
RIO-2
164
-------
Appendix A- Subpart III, final rule
Contents for Subpart III, Final Rule
Applicability
Is my facility regulated under this Subpart?
What is an affected source?
Are any processes exempt?
How do I calculate if HAP„„.a 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 I 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)
165
-------
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? §63.1295(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?
What are the requirements for rolling-annual compliance?
What are the requirements for monthly compliance?
How do I determine the HAP ABA formulation limitations?
What are the requirements for solvent-recovery devices?
§63.1297(a)
§63.1297(b)
§63.1297(c)
§63.1297(d)
§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
166
-------
Contents for Subpart III, Final
What are the compliance options?
What are the requirements for rolling-annual compliance?
Rule
(cont'd)
§63.1299
§63.1299(a)
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?
§63.1303(a)
167
-------
Contents for Subpart III, Final Rule (cont'd)
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(b)
§63.1303(c)
§63.1303(d)
§63.1303(e)
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 information semiannually?
What notifications must I make if I change my slabstock emission limit?
What notifications must I make if I change my 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(f)(1)
§63.1306(f)(2)
§63.1306(g)
168
-------
Contents for Subpart III, Final Rule (cont'd)
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 cleaners?
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(a)
§63.1307(b)
§63.1307(c)
§63.1307(d)
§63.1307(e)
§63.1307(f)
§63.1307(g)
§63.1307(h)
Compliance demonstrations
How do I demonstrate compliance for my slabstock facility? §63.1308(b)
How do I demonstrate compliance for my slabstock facility if I am using emission point specific §63.1308(c)
limitations?
How do I demonstrate compliance for my slabstock facility if I am using sourcewide limitations? §63.1308(d)
How do I demonstrate compliance for my molded source? §63.1308(e)
How do I demonstrate compliance for my rebond source? §63.1308(e)
Delegation of authority
What sections under this Subpart have not been delegated to my State or local agency?
§63.1309
169
-------
Insert copy of rule
(See separate PDF file)
170
-------
TECHNICAL REPORT DATA
1. REPORT NO.
EPA-456/B-98-001
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
The Plain Language Guide to the Flexible Polyurethane Foam Production
NESHAP (40 CFR 63, Subpart III)
5. REPORT DATE
December 1998
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Ingrid Ward, EPA/OAQPS/ITPID/PRG
Janet McDonald, EC/R, Incorporated
8. PERFORMING ORGANIZATION REPORT
NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
ECR
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68D30008
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
13. TYPE OF REPORT 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, carry 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
www.epa.gov/ttn/uatw/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 NESHAP
National emissions standards Compliance
Hazardous air pollutants 40 CFR 63
Flexible Polyurethane Foam Subpart III
Air pollution control
Flexible Polyurethane Foam
Slabstock Foam
Molded
Rebond
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (Report)
Unclassified
21. NO. OF PAGES
216 (hard copy)
-------
20. SECURITY CLASS (Page)
22. PRICE
Unclassified
no cost
------- |