SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis September 20, 2007

Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 

# APPENDIX B

Emissions Reduction Analysis for Revised Proposed Amendments to Rule 4682 (Polystyrene Foam, Polyethylene, and Polypropylene Manufacturing)

September 20, 2007SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis September 20, 2007

Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 B-2 EMISSIONS REDUCTION ANALYSIS

Rule 4682 (Polystyrene Foam, Polyethy lene, and Polypropylene Manufacturing)

I. SUMMARY

District staff has estimated the VOC emissions reduction from foam manufacturing that would comply with the pro posed VOC emission or control system limits of proposed

amendments to Rule 4682 . All of the Valley foam manufa cturing would be subject to the proposed rule amendmen ts, but due to differ ences in existing control equipment not all would be impacted to the same degree . Some of the facilities may actually already be in compliance with the pro posed VOC emission or control system requirements or would only

have to make minor modifica tions to comply. This appendix identifie s the estimated VOC

emissions reduction and estimated redu ctions for the pr oposed amendments to Rule 4682.

The 2007 Ozone Plan indicated that fo r Polystyrene Foam, Polyethylene, and Polypropylene (S-Ind-6) contro l measure, the 2012 baseline of VOC emissions is 0.39 tons per day and that a reduction of about 0.10 tons of VOC per day (26%) is anticipated upon final implementation. The analysis indica tes that the VOC emissions from foam manufacturing is closer to 1.4 tons VOC / day (2,770 lb VOC/day). Reductions due to the proposed amendments are calculated at 0.4 tons VOC/day (750 lb VOC/day) which is a 28% percent reduction from t he adjusted baseline. Ther efore, although the adjusted baseline is higher than the Plan inventory, the percent reduction still matches the

District's reduction commitment

II. BACKGROUND

This category was listed in the Ozone Rate of Progress Plan as an all feasible measure suggested by the EPA. Amending Rule 4682 is intended to reduce VOC emissions from manufacturing polymeric foam an d foam products by specif ying total VOC emission limits or emission control device requi rements. The two major cat egories of processes in this category are extruded foam oper ations and molded foam operations. Although there are key differences between the two processes, each process basically employs a blowing agent to create spaces in the plastic stru cture and produce a strong, but lightweight material with good thermal insolating properties that is inert to water and grease.

Currently operators have to either use an non-VOC blowing agent; capture and control VOC emissions from certain manufacturing pr ocesses; or demonstrate an equivalence. The proposed amendments increase the stringen cy of those requirements add a fourth compliance option of meeting a specific VO C emissions limit. Sp ecifically, operators would have to comply with one of four rule requirements:SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis September 20, 2007

Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 B-3 1. Limit total uncontrolled VOC emissi ons and residual VOC amounts to more

than 2.4 lb of VOC for each 100 pounds of total material processed, or

2. Use a non-VOC blowing agent, or

3. Control all manufacturing emissions with an approved system and store the finished product in a controlled warehouse for 24 or 48 hours, or

4. Control the manufacturing emissions to obtain an equivalent reduction to that achieved if complying with option 3.

Based on a review of existing permit conditions, emission limits, and material data,

District staff feels that t he proposed limits can be met thr ough the use of VOC capture and control system; modifications to materi als or manufacturing processes; or a

combination of the two.

III. FACILITIES AFFECTED BY PROPOSED RULE AMENDMENTS

In order to determine the VO C emissions reduction from the proposed amendments of this project, District staff identified the number of foam manufacturing facilities that would be affected and pertinent operating characteristi cs of such units. The District’s Permits database was used to identify the units currently under permit. Based on the information in the database, District staff identified 12 fac ilities that could be subject to the proposed

rule amendments. One of t he facilities does not use a VOC blowing agent and would be exempt under Section 4.1. The remaining eleven facilities had some or all of their manufacturing processes and storage area contro lled or limited by permit conditions.

Based on the current operating permits for these facilities, VOC emissions were calculated and are summarized in Table B-1. Because of differences in the way the permits were written, it is not possible to illustrate a specific calculation methodology. In some cases, the permit contain a single, fac ility-wide limit, while in others, the emissions from several permits must be added together . To allow for occasional surges in operations some facilities have a higher permitt ed daily emissions than shown. To make comparisons between facilities possible, however, the annual or quarterly limits were used when available, to reflec t long-term operations and not overestimate emissions.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis September 20, 2007

Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 B-4 Table B-1 Facility VOC Emissions and Residual Summary

Process/Product Potential VOC

Emissions after

Controls(1) Residual VOC(2) Potential Reductions(3)

1 Molded - Cups 250 lb/day 830 lb/day 40 lb/day

2 Exempt - Low VOC N/A N/A

3 Extruded - Sheet Material 50 lb /day 1,300 lb/day 60 lb/day

4 Molded - Containers 50 lb/ day 400 lb/day 20 lb/day

5 Extruded - Food-grade

Products 540 lb/day 1,960 lb/day 100 lb/day

6 Extruded - Sheet Materials 820 lb /day 6,000 lb/day 300 lb/day

7 Molded - Containers 150 lb/ day 860 lb/day 40 lb/day

8 Extruded- Food-grade

Products 1,450 lb/day 5,200 lb/day 260 lb/day

9 Molded - Containers 40 lb/ day 210 lb/day 10 lb/day

10 Molded - Containers 2 lb/ day 2,200 lb/day 110 lb/day

11 Molded - Packaging 270 lb/day 1,200 lb/day 60 lb/day

12 Extruded - Packaging 70 lb/day Not available

Total 3,692 lb/day 1,000 lb/day Adjusted (1) 2,770 lb/day 750 lb/day

(1) "Potential VOC Emissions After Contro ls" represents the pe rmitted VOC emissions from manufacturing processes after all requir ed control requirements and limitations were taken into account. The "Adjusted" controlled emissions is 75% of that total or 2,770 lb VOC/day. This is to account for variations in the actual operations which typically put emissions below the permitted limit s. Individual facilities may be higher or lower than that number, but the 75% should repres ent the industry as a whole.

(2) "Residual VOC" represents the assum ed retained amount of bl owing agent in the product immediately after manufacturing. Both the South Coast and Bay Area air districts

include the residual values when calculating their emissi on limits. Some of these emissions will off-gas in the fi rst 24 to 48 hours after manufactu ring which is the rationale behind the South Coast requiring a mandatory period of controlled storage for finished goods. The remainder of the residual VOC is expected to off-gas during the life of the product.

• Some facilities had a permit condition r equiring a specific residual amount in the finished product. The residual amount will vary depending on the raw material used, the facilities operating temperat ure and humidity, and the type of product produced. Unless specified in the operating permit, a 50% retention rate was applied to the permitted blowing agent tota l. Residual emissions are uncontrolled and therefore much higher than the manufac turing emissions which are typically captured and vented to a control device. Manufacturing operations release roughly half of the initial bl owing agent, but are typically less than 15% of the total

VOC emissions due to the controls.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis September 20, 2007

Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 B-5 • Some facilities had a permit condition limiting the specific amount of VOC in the raw material. Actual material content, for molded products, will vary from 6% to 2.5% VOC depending on the supplier and product. Unless specified in the operating permit, a 5% blowing agent fact or was applied to the permitted raw

material limit to determine the total permitted blowing agen t. Extruders add the blowing agent to the raw material during the extrusion phase so typically their raw material has no VOC, but the 5% mix would also, typically apply.

(3) "Potential Reductions" reflects the approx imate reductions necessary to comply with the proposed rule limit. The specific co mpliance option will be determined by the operator, so a case-by-case analysis is not po ssible. Also, some operators may already be in compliance due to their cu rrent emission controls.

• One of the most cost-effective methods , and therefore the mo st likely compliance option, to reduce VOC emissions is to reduce the amount of blowing agent in the raw material. In that scenario, no additi onal emission controls would need to be

added or maintained and material cost s hould be roughly equivalent to the higherVOC material.

• Reducing the VOC in the raw material would reduce both the manufacturing

emissions and the residual amount. Because the residual VOC content is approximately half of the total VOC cont ent, and is uncontrolled, the impact of reducing the raw material content w ould have the biggest impact on these

emissions.

• Table B-1 reflects the result of a 5% reduction in the residua l VOC content of the final products. This is not to imply that such a reducti on in material VOC content will automatically result in compliance for all sources. Some operations will require a greater material VOC co ntent reduction and others may require emission controls or manufacturing oper ations to comply with the proposed requirements. The 5% assumption is merely a method of estimating potential reductions when the exact operator response is not certain.

• Reducing the raw material VOC content w ould have a relatively less significant impact on the emissions which are captured and controlled. As previously stated, those emissions are only about 15% of the residual amounts so a 5% reduction would only result in a 0.75 % reduction (21 lb VOC/day) in those emissions.

• It may be possible for some operators to add additional controls on currently uncontrolled manufacturing points. The ef fects of such controls would be a

between 80 to 95% reduction in those em issions, but at a higher cost for equipment and operating t han achieved by changing the raw materials.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis September 20, 2007

Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 B-6 This page intentionally left blank.