UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Notice of Proposed Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District

Rule 1175, Control of Emissions from the Manufacture of

Polymeric Cellular (Foam) Products

June 13, 2011

Prepared by Mae Wang
Agency: South Coast Air Quality Management District (SCAQMD)

SIP Approved Rules:

SCAQMD Rule 1175, Control of Emissions from the Manufacture of Polymeric Cellular (Foam) 

Products

Originally adopted on November 3, 1989, amended on May 13, 1994, approved on August 25, 

1994, 59 FR 43751.

SJVUAPCD Rule 1020, Definitions 

Originally adopted on 6/18/1992, amended on 1/15/2009, approved on 8/28/2009, 74 FR 44291.

Previously Submitted Versions:

SCAQMD Rule 1175, Control of Emissions from the Manufacture of Polymeric Cellular (Foam) 

Products

Amended on September 7, 2007, submitted on March 7, 2008, disapproved on May 10, 2010, 75 

FR 25775.

Subject of this Technical Support Document:

SCAQMD Rule 1175, Control of Emissions from the Manufacture of Polymeric Cellular (Foam) 

Products

Amended on November 5, 2010, submitted on April 5, 2011

Rule Summary 

Rule 1175 was designed to control emissions of volatile organic compounds (VOC) from 

the manufacturing, processing, and storage of polymeric foam products. The rule essentially 

prohibits the use of chlorofluorocarbons, VOCs, and methylene chloride in operations except for 

expandable polystyrene molding and extrudable polystyrene foam operations. Expandable 

polystyrene molding and extrudable polystyrene foam operations are required to demonstrate that 

VOC emissions do not exceed 2.4 pounds of VOC per 100 pounds of raw materials processed, or 

to install an approved emission control system.

Changes from the previously submitted (9/7/2007) version:

Minor revisions were made to the definitions for “Chlorofluorocarbon (CFC),” and 

“Volatile Organic Compound (VOC).”

The definition for “Raw Material” was revised to include reprocessed material. 

Definitions were added for “Extruded Polystyrene (XPS) Foam Operations” and 

“Reprocessed Material.”
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Section (c)(1) was revised to exclude extruded polystyrene foam operations.

Section (c)(2) was revised to include extruded polystyrene foam operations. 

Section (c)(4)(B)(i) was revised to include additional language specifying that any critical 

operational techniques and parameters must be incorporated in a federally enforceable 

permit. 

Section (c)(4)(B)(iii) was renumbered as (c)(5) and language was added to require a 

source test demonstration, to be repeated every 5 years for federal Title V facilities. 

Section (c)(6) was added to require source testing for emission control systems, to be 

repeated every 5 years for federal Title V facilities. 

Section (d) was added to prohibit the use of methylene chloride or CFC, unless approved 

under 40 CFR Part 82 Subpart G. 

Section (f)(2) was revised to require records to be kept for 5 years. 

Minor revisions were made throughout the rule, including in sections (c)(1), (c)(5), (e), 

(f), and (g), to add clarity or correct numbering or formatting. 

Additional changes from the approved SIP rule (5/13/1994):

The definition for “Approved Emission Control System” was revised to include 

collection of storage emissions.

Definitions were added for “Certificate of Analysis,” “Low-Pentane Bead,” “Mid Pentane 

Bead,” and “Storage Emissions.”

A compliance option was added to the Emission Control Requirements section to allow 

expanded polystyrene block molding operations to collect and reduce manufacturing 

emissions by at least 93% overall by weight, if at least 60% of the block throughput is 

manufactured with low-pentane beads and the remainder with mid-pentane beads. 

The Test Methods section was revised to allow other methods if they are approved by the 

Executive Officer, U.S. EPA, and CARB, and equivalent to the methods listed in the rule.

Additional procedures were added to the Test Methods section for determining capture 

efficiency of emission control systems. 

SCAQMD Method 25.3 was added as an additional method that may be used to 

determine control device efficiency of emission control systems. 
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EPA Evaluation

Generally, SIP rules must be enforceable (see section 110(a) of the Clean Air Act

(CAA)), must require Reasonably Available Control Technology (RACT) for major sources in 

nonattainment areas (see section 182(a)(2)(A) of the CAA), must not interfere with any 

applicable requirement concerning attainment and reasonable further progress or any other 

applicable requirement of the CAA (see section 110(l) of the CAA), and must not modify, in a 

nonattainment area, any SIP-approved control requirement in effect before November 15, 1990 

(see section 193 of the CAA). The SCAQMD regulates an extreme ozone nonattainment area

(40 CFR 81), so Rule 1175 must fulfill RACT as well as CAA section 110(l) requirements. 

Guidance and policy documents that we used to evaluate the submitted rule include the 

following:

1. Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, EPA, May 

25, 1988 (The Bluebook).

2. Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA 

Region 9, August 21, 2001 (the Little Bluebook).

3. “Control of VOC Emissions from Polystyrene Foam Manufacturing” (EPA-450/3-90-020, 

September 1990).

Deficiencies identified in the previously submitted version

The previous version of Rule 1175, amended on September 7, 2007 and submitted to 

EPA on March 7, 2008, was disapproved on May 10, 2010, 75 FR 25775. As discussed in more 

detail in the technical support document (TSD) associated with that action, EPA disapproved the 

earlier version because it did not contain adequate provisions to ensure rule enforceability in the 

following areas:

1. For sources choosing to comply with the new option for expanded polystyrene 

block molding operations, the rule needed to require demonstration through source 

testing that the 93% collection and reduction of emissions is being achieved. 

2. For sources choosing to comply with the new option for expanded polystyrene 

block molding operations, the rule needed to clarify and identify the operational 

techniques and parameters needed to achieve 93% control, and include those 

techniques and parameters in a federally enforceable permit. 

3. For sources with an emission control system designed to meet the 90% collection 

and 95% destruction requirements, the rule needed to clarify and identify the 

operational techniques and parameters needed for compliance and include those 

techniques and parameters in a federally enforceable permit. 
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Evaluation of current version

The currently submitted version, amended on November 5, 2010, contains revisions that 

address the previously identified deficiencies, as well as additional recommendations to improve 

the clarity of the rule. EPA previously determined that the current SIP-approved version of Rule 

1175 adequately implements RACT, partly because the emission limits are generally at least as 

stringent as those in other areas. Since the revised rule does not relax the SIP-approved version 

and continues to be comparable to rules in other areas, we believe that this current version also 

adequately implements RACT. As noted in the Rule Summary section, language was added to 

Rule 1175 to require that techniques and parameters related to operation of emission control 

systems be incorporated in a federally enforceable permit. Source testing requirements were also 

added. These additions address the deficiencies identified in the previous version that was 

disapproved. Therefore, we find that the currently submitted version of Rule 1175 fulfills the 

relevant criteria summarized earlier, including RACT, and it improves the SIP by clarifying 

language and adding definitions, control requirements and test procedures. The rule is generally 

clear and contains appropriate monitoring, reporting, and recordkeeping requirements to ensure 

the emission limits are adequately enforceable. 

EPA Action

SCAQMD Rule 1175 strengthens the SIP and fulfills the relevant Clean Air Act §110 and 

Part D requirements. EPA staff recommends approval of Rule 1175 pursuant to CAA 

§110(k)(3).

Attachments

1. SCAQMD Rule 1175, Control of Emissions from the Manufacture of Polymeric Cellular 

(Foam) Products, amended on November 5, 2010.

2. EPA’s TSD for SCAQMD Rule 1175, amended on September 7, 2007. TSD dated June 

30, 2009.