AQ_F_1400194_20071113_CMPL_MACT-Corr

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
B. Keith Overcash, P.E,, Director
November 13, 2007
Ms. Crystal Kiser, Chief Financial Officer
Marx Industries Inc
P O Box 826
Granite Falls, NC 28630
Subject: New Compliance Requirements for Flexible Polyurethane Foam Fabrication
Facilities
Marx Industries Inc
Sawmills, Caldwell County, North Carolina
Facility ID No. 1400194
Dear Ms. Kiser:
On July 16, 2007, the US Environmental Protection Agency (EPA) promulgated 40 CFR
Part 63, Subpart 000000 - National Emission Standards For Hazardous Air Pollutants For
Flexible Polyurethane Foam Production and Fabrication Area Sources ("M.ACT Subpart
000000"). A portion of the MACT Subpart 000000 regulation is applicable to any person
who owns or operates a flexible polyurethane foam fabrication facility where adhesives are used
to bond foam to foam or other substrates. To be in compliance with this rule, the following was
required by July 16, 2007:
(e) ff you own or operate a new or existing flexible polyurethane foam fabrication
affected source, you must not use any adhesive containing methylene chloride in a
flexible polyurethane foam,fabricahion process.
Your facility has been identified as being potentially subject to this portion of the rule. A
copy of the rule (40 CFR 63.11414) can be obtained at
h�tp.:// rw.epa.gov/el,acfr40/chat-I.info/chi-toe.htn�. This office requests the following in
reference to this matter:
1. If your facility does not conduct polyurethane foam fabrication where adhesives
are used to bond foam to foam or other substrates, you do not need to respond to
this letter.
1641 Mail Service Center,Raleigh,North Carolina 27699.1641 PTO e
2728 Capital Blvd.,Raleigh, North Carolina 27604 1V ofthCa1 olina
Phone: [phone] FAX [phone] I Internet: www.ncair.org ;VaturallyAn Equal OpportunitylAffirmative Action Employer—30%Post Consumer Fiber

Ms. Kiser
November 13, 2007
Page No. 2
2. If your facility does conduct polyurethane foam fabrication where adhesives are
used to bond foam to foam or other substrates, and you have already eliminated
methylene chloride based adhesives, you do not need to respond to this letter.
You should maintain a compliance statement on site signed by a responsible
official stating methylene chloride based adhesives are not used on site in
polyurethane foam fabrication.
3. If your facility does conduct polyurethane foam fabrication where adhesives are
used to bond foam to foam or other substrates, and you still use methylene
chloride based adhesives, please respond to this letter by January 14, 2008. The
response should describe your operation, how many gallons of methylene chloride
based glue are used per year, and provide a date when compliance with this rule
will be achieved. The response should be mailed to the following address:
Paul Muller, Regional Air Quality Supervisor
N.C. Division of Air Quality
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
After elimination of methylene chloride, you should maintain a compliance
statement on site signed by a responsible official stating methylene chloride based
adhesives are not used on site in polyurethane foam fabrication.
If you have any additional questions in regard to this matter, please contact Mike Parkin
at [phone].
Sincerely,
B. th Overcash, P.E.
cc: Mike Parkin, ARO