Flexible Polyurethane Foam Production and Fabrication: National Emission Standards for Hazardous Air Pollutants (NESHAP) for Area Sources

Rule Summary

Flexible Polyurethane Foam Fabrication

The final National Emission Standards for Hazardous Air Pollutants (NESHAP) prohibits the use of methylene chloride at foam fabrication operations. Area sources of flexible polyurethane foam fabrication cut or bond flexible polyurethane foam pieces

together or to other substrates, and these pieces are then used in upholstered products such as furniture, cars and trucks and some appliances.

These standards implement Section 112(d) and 112(k) of the Clean Air Act and are based on the Administrator's determination that emissions from the fabrication of flexible polyurethane foam cause or contribute significantly to air pollution which may reasonably be anticipated to endanger public health or welfare. Molded foam, rebond foam, and foam fabrication area source facilities which operate loop slitters must prepare, and keep on file, compliance certifications which certify that the facility is not using the prohibited methylene-chloride based products. The area source plants must also maintain records documenting that the products they are using do not contain any methylene chloride.

Flexible Polyurethane Foam Production:

The final NESHAP reduces the use of methylene chloride at foam fabrication operations. These operations create flexible polyurethane foam used in upholstered products such as furniture, cars and trucks and some appliances. These standards implement Section 112(d) and 112(k) of the Clean Air Act and are based on the Administrator's determination that emissions from the production of flexible polyurethane foam cause or contribute significantly to air pollution which may reasonably be anticipated to endanger public health or welfare.

For slabstock foam production area sources, the rule requires emissions limits and management practices to reduce methylene chloride emissions from the production line, storage tanks, leaking equipment, and equipment cleaning. Emissions limits for methylene chloride used as an auxiliary blowing agent (ABA) are based on a formula which varies based on the grades of foam being produced. Vapor balance systems or carbon beds are required for methylene chloride storage vessels. The management practices require plants to identify and correct leaking pumps and other equipment in methylene chloride service. Specifically, owners or operators must check periodically for equipment leaks (from quarterly for pumps and valves to annual for connectors) using EPA Method 21 (40 CFR part 60, appendix A (pdf) (1,797 KB)). Leaks, which are defined as a reading of 10,000 parts per million (ppm) or greater, must be corrected within fifteen days of when they are detected. The use of methylene chloride to clean mix heads and other equipment is prohibited.