Flexible Polyurethane Foam Production 

Presumptive MACT


     There are two primary outputs of the presumptive MACT
process.  The first are the appropriate emission and
implementation requirements for the industry, based on the
available information.  The second is to identify issues that
need to be addressed in the development of the MACT regulation.

I.  P-MACT EMISSION AND IMPLEMENTATION REQUIREMENTS

     The source category covered by the flexible polyurethane
foam P-MACT is any polyurethane foam production facility
(slabstock or molded) that is a major source, or is located at a
major source plant site.  A major source is "any stationary
source or group of stationary sources located within a contiguous
area and under common control that emits or has the potential to
emit considering controls, in the aggregate, 10 tons per year or
any HAP or 25 tons per year of any combination of HAP."  While
emissions from fabrication operations co-located with production
sites are included in the major source determination, fabrication
operations are not covered by the requirements of P-MACT.

Molded Foam P-MACT Emission Requirements

     Table 1 presents the presumptive MACT emission requirements
for molded foam production.



Slabstock Foam Non-ABA P-MACT Emission Requirements

     Table 2 presents the presumptive MACT emission requirements
for non-ABA emission sources at slabstock foam facilities.

Slabstock Foam HAP ABA P-MACT Emission Requirements

     For P-MACT, the allowable HAP ABA emissions for a single
month are determined using the following equation:
where,
emissallow,monthj=Allowable emissions due to use of a HAP auxiliary
               blowing agent for month j, megagrams
polyoli  =     Amount of polyol used in the month in the
               production of foam grade i, megagrams
n  =           Number of foam grades produced in the month
limiti  =      HAP ABA formulation limit for foam grade i, parts
               ABA per 100 parts polyol.  The HAP ABA formulation
               limits are obtained from either Table 3 or
               Table 4.  The IFD and density of the foam will be
               determined using standard industry quality control
               techniques on a sample from the core of the foam
               bun.













The allowable emissions for the 12-month period are calculated
using the following equation:

where,
emissallow,12-month =Allowable emissions due to the use of a HAP
               auxiliary blowing agent for the previous 12-month
               period, Megagrams

     Compliance with the HAP ABA emission requirements is
determined each month, by comparing the allowable emissions for
the previous 12-month period with the actual HAP ABA emissions
for the same 12-month period.  Allowable and actual HAP ABA
emissions are rounded to the nearest megagram, with 0.5 megagrams
rounded up.

     If add-on control (e.g., carbon adsorption, incineration,
etc.) is used to reduce emissions, the emissions after control
will have to be verified using an initial source testing.  In
addition, continuous monitoring will be required to verify that
the device is operating properly.  The P-MACT determination did
not include detailed continuous monitoring requirements.

Rebond Foam P-MACT Emission Requirements

     The emission requirements for rebond foam prohibit the use
of HAP cleaners and HAP-based mold release agents.  The use of
HAP-based adhesives in rebond fabrication are not covered by the
foam production P-MACT.




















General P-MACT Implementation Requirements

     The general P-MACT implementation requirements are shown in
Table 5.
II.  ISSUES IDENTIFIED IN P-MACT PROCESS

     In the P-MACT process, several issues and action items were
identified that the EPA will investigate during the development
of the MACT standard.  These are outlined in the following
section.  The EPA will continue to work on the MACT standard,
with a particular emphasis on resolving these areas identified by
the P-MACT Roundtable.

Small Business Impacts

     A primary issue that needs to be addressed is the economic
impacts of ABA emission requirements on small business.  One
concern is that if the costs of foam became too high because of
the regulation, other materials would be used rather than foam
for some applications.  This would have a greater impact on the
smaller manufacturers.  Some alternatives to using foam listed
were natural fibers, steel coils, polyester fibers, cotton
batting, and styrofoam.  However, none of these materials could
totally replace foam for all applications.

     Why would small businesses have increased costs over the
larger companies?  One reason may be that the development costs
for new technologies would be higher.  Larger companies can
spread the costs over several facilities, while small companies
do not have that ability.  

     The definition of a small business for this industry is
currently defined as any company with 500 or fewer employees. 
The consensus seems to be that this definition may be
inappropriate for this industry, as it is based on the corporate
and/or parent company and not just on the flexible foam
production facility.  Several representatives of the industry
have asked if the definition of a small business could be based
on foam production rather than the number of employees.  In
response, the EPA has the flexibility to define what a small
business is for each industry.  However, the primary use of the
small business determination is for the analysis of detrimental
effects of the regulation on small businesses, and not the
establishment of different emission control requirements for
small businesses.

Other Major Issues and Action Items

     Several other important issues have surfaced that may need
additional clarification.  These issues are listed in the
following.  Action items associated with these issues and data
gaps are also provided below.

    Leakless pump configurations other than canned pumps should
     be allowed.

    There was concern that the HON Subpart H requirements were
     overly complex and burdensome for the slabstock foam
     industry.  The EPA will investigate leak detection and
     repair programs currently being used at foam production
     facilities, and consider such programs in the development of
     MACT.

    Carbon absorbers/canisters should be allowed as an
     alternative to vapor balance for storage tank control.

    Industry claims that there are situations where non-HAP
     cleaners are not acceptable to clean the mixhead and
     associated equipment.

    HAP-based adhesives used at rebond facilities will be
     addressed under EPA's study of foam fabrication operations.

    Industry expressed numerous concerns regarding the
     application of new source MACT requirements.

    P-MACT should require the IFD and density of foam grades to
     be verified using core samples.

    The industry will provide examples of the variation in HAP
     ABA and polyol usage estimates.  Upon receipt of this
     information, the EPA will consider incorporating a factor
     into the definition of a HAP ABA violation that would allow
     actual emissions to exceed allowable emissions (or would be
     incorporated into the calculation of allowable emissions).

    The industry will provide input regarding whether a 12-month
     rolling sum of HAP ABA emissions or a straight monthly
     compliance period is preferred.

    The EPA will attempt to develop an equation that calculates
     HAP ABA formulation limitations.  The results of this
     analysis will be distributed to roundtable members.

    The EPA will investigate current recordkeeping procedures
     used in the industry and attempt to design the recordkeeping
     requirements of the MACT standard to accommodate these
     current procedures.