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 WangAgency: South Coast Air Quality Management District (SCAQM D)

SIP Approved Rule s : S CAQM D Rule 1175

, Control of Emiss ions from the Manufacture of Pol ymeric Cellular (Foam)

Products

O riginally 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 1/15/20 09, 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

A mended on September 7, 2007

, submitted on March 7, 2008, dis approved on May 10, 2010, 75

FR 25775.

Su bject 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 expanda ble polystyrene molding and extrudable polystyrene foam operations. Expandable

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

VOC emissions do not exceed 2.4 pounds of VOC per 100 pound s of raw materials pr ocessed , 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.”3

Section (c)(1) was revised to exclude extruded polystyrene foam operations.

Section (c)(2) w as 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.

Sect ion (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 b e 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.

Mi nor 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 c hanges from the approved SIP rule (5/13/1994) :

The definition for “Approved Emission Co ntrol 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 Requirement s 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

- pent ane beads.

The Test Methods section was revised to allow other methods if they are approved by the Executive Officer, U.S. EPA, a nd 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.4

EPA Evaluation

Generally, SIP rules must be enfor ceable (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 concernin g 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 a n 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

fol lowing:

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

. “Co ntrol 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 enforce ability in the following areas:

1. For sources choosing to comply with the new option for expanded polystyrene block molding operations, t he rule needed to require demonstration through source testing that the 93% collection and reduction of emissions is bei ng 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 techniqu es 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 neede d for compliance and include those techniques and parameters in a federally enforceable permit.5

Evaluation of current version

The currently submitted version, amended on November 5, 2010 , contains revisions that address the previously identified defic iencies, 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 string ent 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 , l anguage was added to

R ule 1175 to require that techniques and parameters related to operation of emission control systems be i ncorporated in a federally enforceable permit . S ource testing requirements were also

added

. These additions address the defic iencies 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 add ing 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

S CAQM D Rule 11 75 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 Polym eric Cellular (Foam) Products, a mended on November 5, 2010.

2. EPA’s TSD for SCAQMD Rule 1175, amended on September 7, 2007. TSD dated June
30, 2009.