RULE 4682 POLYSTYRENE, POLYETHYLENE, AND POLYPROPYLENE PRODUCTS MANUFACTURING (Adopted May 21, 1992; Amended December 17, 1992; Amended June 16, 1994; Am ended September 20, 2007)

1.0 Purpose

The purpose of this rule is to limit emi ssions of VOC and tric hlorofluoromethane (CFC-11) and dichlorofluorom ethane (CFC-12) from manuf acturing and processing of products composed of polysty rene, polyethylene, or polypropylene and from the storage of VOC blowing agents.

2.0 Applicability

The provisions of this rule shall apply to any manufacturing, processing, and storage of products composed of polystyrene, polyethylene, or polypropylene.

3.0 Definitions

For the purpose of this rule, the following definitions shall apply:

3.1 APCO: as defined in Rule 1020 (Definitions).

3.2 ARB: California Air Resource Board.

3.3 Approved Emission Control System: a ny system used to reduce emissions and consists of a capture and a control de vice, which are approved, in writing, by the APCO. The control system must be maintained and operated in such a manner that meets the following requirements:

3.3.1 The emission capture system shall co llect at least 90 percent by weight of the emissions; and

3.3.2 The control device shall reduce emissions from the emission capture system by at least 95 percent, by weight.

3.4 Blowing Agent: any liquid, or gaseous materi al, including VOCs, that

facilitates the formation of a cellular product from raw polymeric material.

3.5 Controllable VOC Emission Sources: fluff silos or bins, reclaim extruders, condenser devolatizer vents, styrene r ecovery unit vents, and reclaim die hood

exhausts in which materials manufact ured with a VOC blowing agent are processed, or are stored, and from which emissions are vented to the atmosphere.

SJVUAPCD 4682-1 9/20/20073.6 Chlorofluorocarbon (CFC): any chlo rinated fluorinated compound of carbon, excluding chlorodifluoromethane (HCFC- 22), dichlorotrifluoromethane (HCFC123), tetrafluoroethane (HFC-134a), di chlorofluoroethane (HCFC-141b), and chlorodifluoroethane (HCFC-142b).

3.7 EPA: United States E nvironmental Protection Agency.

3.8 Fluff Silo or Bin: a container u tilized for the storage of ground polystyrene foam for recycling.

3.9 Manufacturing Emissions: all emissions of VOC, CFC, or methylene chloride that occur during the manufacturing operati on, quantified before any capture or
control.

3.10 Manufacturing Operation: a production line or lines c onsisting of all steps in the processing of a polymer or resin, from the receipt of raw polymeric material by the manufacturing facility through the fi nal step prior to shipment of the finished product from the manufacturi ng facility, and that results in VOC emissions to the atmosphere. Individua l steps include, but are not limited to: expandable bead storage, finished product storage/aging, extr usion, expansion, softening or annealing, intermediate (pre-puff) storage/aging, decomposition, molding, grinding, and forming.

3.11 Polyethylene (High and Low Density): linear thermoplastic polymers of ethylene with densities from 0.94 gram per cubic centimeter or higher.

3.12 Polymeric Material: a multi-mol ecular compound or mixture of compounds formed by polymerization and consisting essentially of re peating structural units.

3.13 Polypropylene: a high molecular wei ght thermoplastic crystalline polymer of propylene.

3.14 Polystyrene: a thermoplastic mate rial which is a polymer of styrene.

3.15 Raw Material: All polystyrene, pol yethylene and polypropyl ene, and blowing agent used in the manufacturing opera tion, including virgin and recycled polymeric materials.

3.16 Reclaim Die Hood Exhaust: an exhaust hood above reclaim extruder die

intended to remove VOCs which escape from the extruder die.

3.17 Reclaim Extruder: equipment used to reprocess ground polystyrene foam into polystyrene pellets.

SJVUAPCD 4682-2 9/20/20073.18 Reclaim Extruder Vent: the vent or opening through which emissions are expelled from the reclaim extruder.

3.19 Volatile Organic Compound (VOC): defined in Rule 1020 (Definitions).

4.0 Exemptions

The provisions of Sections 5.1, 5.2, and 5.3 shall not appl y to manufacturing and processing operations us ing polymeric materials containi ng less than 1 percent volatile organic compounds by weight, and not usi ng a blowing agent in their process.

5.0 Requirements

Section 5.1 shall be effective until Septem ber 20, 2010 and shall not apply after that

date.

Sections 5.3 through 5.5 shall be effective on and after September 20, 2010.

5.1 No person shall operate controllable VOC emission sources at a polystyrene foam, polyethylene, or polypropylene manufacturing or pr ocessing operation unless one of the following VOC emi ssion reduction methods is provided:

5.1.1 A blowing agent other than a VOC or trichlorofluor omethane (CFC-11) or dichlorodifluoromethane (CFC -12) is exclusively used; or

5.1.2 A system designed to achieve at least 90 percent VOC capture efficiency,

and a thermal oxidizer which abates captured VOC emissions by at least 95 percent by weight; or

5.1.3 VOC emissions are controlled by a method which achieves an emission reduction equivalent to Section 5.1.2 and which does not include the use

of trichlorofluorometha ne (CFC-11) or dichlo rodifluoromethane (CFC12), and is approved by the APCO.

5.2 No person shall place, hold or store any VOC blowing agent in any stationary
tank, reservoir or contai ner having a capacity greater than 200 gallons unless one (1) of the following emission control systems is provided:

5.2.1 The container is a pressure vesse l maintaining a working pressure at all times sufficient to prevent release of VOC emissions to the atmosphere under normal operating conditions; or

SJVUAPCD 4682-3 9/20/20075.2.2 The container is equipped with an emission control device or system which collects and disposes of VOC emissions, and which achieves and maintains a vapor recovery/control e fficiency of at least 95 percent by weight.

5.3 The operator shall not conduct any ma nufacturing operations , as defined in Section 3.0, unless one of the followi ng emission reduction methods is met:

5.3.1 The operator demonstrates, to the sa tisfaction of the APCO, that the total product emissions do not exceed 2. 4 pounds of VOC per 100 pounds of total material processed, calculate d over a monthly period. The total product emissions include emissions from the manufacturing operation, after controls, plus the residual blow ing agent in the finished product.

5.3.2 A blowing agent other than a VOC or trichlorofluorom ethane (CFC-11) or dichlorofluoromethane (CFC -12) is exclusively used.

5.3.3 An approved emission control syst em is installed and operating with manufacturing emissions vented only to the approved emission control system; and emissions from the fi nal manufactured product are to be vented only to the approved emissi on control system for at least:

5.3.3.1 48 hours, in the case of expandable polysty rene molding operations that process more than 800,000 pounds per calendar year of raw material; or

5.3.3.2 24 hours, in the case of all other manufacturing operations.

5.3.3.3 The provision of Section 5.3.3.1 or 5.3. 3.2 are not required for any facility that only manufactur ers polystyrene products and the highest concentration of the blowing agent in the product is 1.8 percent or less by weight, within 15 minutes after the completion of the final processi ng step, prior to any finished product storage. Verification of the concentration shall be demonstrated annually, pursuant to a protocol submitted to the District and subject to approval by the APCO.

5.3.4 The operator demonstrates to th e satisfaction of the APCO that the manufacturing emissions are no greater than the facility emissions which would occur under Section 5.3.3, as calculated according to Section 5.5,

and which does not include the use of trichlorof luoromethane (CFC-11) or dichlorodifluoromethane (CFC-12).

SJVUAPCD 4682-4 9/20/20075.3.5 A control system that meets all of the following requirements shall be deemed as meeting the requirements of Section 5.3.4, unless the APCO

determines that additiona l controls are required.

5.3.5.1 The beads used in manufact uring have an annual-average VOC content of less than 4.2% per weight; and

5.3.5.2 The manufacturing emissions (not including finished product storage emissions) are controlle d with an overall capture and control efficiency of at least 93% by weight.

5.4 Operators subject to the provisions of Section 5.3.1, who exceed the limit based on the monthly calculation, shall be consid ered to have been in violation for each day of that monthly period.

5.5 Facility emissions that would occur under 5.3.3 shall be calculated using the following formula, or other formul a approved by the APCO and EPA:

FE = [1- (0.90 x 0.95)] x [(P1+AS - P2) + (P2 - P3)]

where FE = Facility Emissions for Section 5.3.3

P1 = Amount of VOC in the received material

AS = Amount of VOC added to the material

P2 = Amount of VOC in the finish ed product, measured within 15 minutes after the final processing step, prior to finished product

storage.
P3 = Amount of VOC in the fini shed product after warehousing for 48 hours (for facilities subject to Section 5.3.3.1.1) or 24 hrs (for all others). (P2 - P3) = 0 for products with residual VOC amounts of 1.8 percent or less by weight.

5.6 Compliance Plan

No later than March 20, 2009, operators complying with Section 5.3.1, 5.3.4,

or 5.3.5 shall submit to the APCO a Compliance Plan which includes all necessary information to show the pr oposed method of compliance with the applicable section. Such informati on shall include, but not be limited to:

5.6.1 Potential VOC emissions,

5.6.2 Overall VOC capture and control efficiency of VOC emission control

system,

SJVUAPCD 4682-5 9/20/20075.6.3 Material VOC conten t at relevant manufacturi ng points. The amount of

VOC in the material shall be determin ed using the test method in Section 6.2.4, or other method appr oved by the APCO and EPA.

5.6.4 VOC emission calculation formul a which will be used to show compliance, and

5.6.5 Operational characteristics of th e VOC emission control systems which

will be monitored to show continue d compliance with the applicable

limits.

5.6.6 Any operational or e quipment limitations that are necessary to make the

demonstration enforceable and which will be included as a condition on the appropriate Permit to Operate.

6.0 Administrative Requirements

6.1 Recordkeeping

6.1.1 Any person subject to the provisions of this rule, including exempt facilities, shall maintain records of operation, including but not limited to the amount of material processed, th e equipment used, and the type of the blowing agent used. Records shall be main tained with a minimum monthly totals with the ability to cal culate daily averages in any given

month.

6.1.2 Any person using an emissions c ontrol system as a means of complying with this rule, shall maintain daily records of key system operating and maintenance procedures which w ill demonstrate continuous operation and compliance of the emission cont rol device. Key system operating parameters are those necessary to ensure compliance with VOC emission requirements such as temperature, pressures, and flowrates.

6.1.3 Operators complying with Section 5.3.1 shall maintain records necessary to show compliance with that section and shall, once every month, calculate the daily aver age VOC emissions, based on the records for the preceding monthly period, accordi ng to the approved VOC emission

calculation formula.

6.1.4 Effective on and after September 20, 2007, the opera tor shall keep in the facility all records required to demonstrate comp liance with the requirements of this rule for a minimu m of five years. The records shall be made available at the facility during normal business hours to the APCO, ARB, or EPA. The records shall be submitted to the APCO, ARB, or EPA upon request.

SJVUAPCD 4682-6 9/20/20076.2 Test Methods

Alternative test methods, that are equivale nt to those specified in Sections 6.2.1 through 6.2.4, may be used, provided th at those test methods have been approved in writing by the APCO and EPA.

6.2.1 The control efficiency of the em ission control system shall be determined using EPA Methods 2, 2A , or 2D for measuring flow rates, and EPA Methods 25, 25A, or 25B for m easuring total gaseous organic

concentrations at the inlet a nd outlet of the control device.

6.2.2 The capture efficiency of an em ission capture control system shall be determined according to EPA’s “Gui delines for Determining Capture Efficiency,” January 9, 1995 and 40 CFR 51, Appendix M, Methods 204-204F, as applicable.

6.2.3 EPA Method 18 or ARB Test Me thod 422 for determin ation of exempt compounds and halogena ted blowing agents.

6.2.4 The VOC blowing agent containe d in polymeric materials shall be determined using South Coast Ai r Quality Management District (SCAQMD) Method 306 (Analysis of Pentanes in Expandable Styrene Polymers) or Bay Area Air Quality Management District (BAAQMD) Method 45 (Determination of Butane s and Pentanes in Polymeric Materials).

6.2.5 When more than one test method or set of test methods is specified for any testing, a violation of any requirement of this rule established by any one of the specified test methods or set of test methods shall constitute a

violation of this rule.

7.0 Compliance Schedule

On and after September 20, 2010, operators shall be in comp liance with the applicable provisions of Sections 5.3 thr ough 5.5, unless otherwise noted.

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