## Final Staff Report

Proposed Amended Rule 1175 – Control of Emissions from the Manufacture of Polymeric Cellular (Foam) Products

October 2010

Deputy Executive Officer Planning, Rule Development, and Area Sources Elaine Chang, Dr.PH

Assistant Deputy Executive Officer Planning, Rule Development, and Area Sources Laki Tisopulos, Ph.D., P.E.

Planning and Rules Manager Planning, Rule Development, and Area Sources Naveen Berry

AUTHORS: Don Hopps AQ Specialist Mike Morris AQ Specialist

REVIEWED BY: Andrew Lee, P.E. Program Supervisor David Ono Program Supervisor Veera Tyagi Deputy District Counsel II

CONTRIBUTORS: Stephen Jiang AQ Engineer II 

## SOUTH COAST AIR QUALITY MANAGEMENT DISTRICTSOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD

Chairman: WILLIAM A. BURKE, Ed.D. Speaker of the Assembly Appointee

Vice Chairman: DENNIS R. YATES Mayor, Chino Cities of San Bernardino County

MEMBERS:

MICHAEL D. ANTONOVICH Supervisor, Fifth District County of Los Angeles

JOHN J. BENOIT Supervisor, Fourth District County of Riverside

MICHAEL CACCIOTTI Councilmember, South Pasadena Cities of Los Angeles County/Eastern Region

BILL CAMPBELL Supervisor, Third District County of Orange

JANE W. CARNEY Senate Rules Appointee

JOSIE GONZALES Supervisor, Fifth District County of San Bernardino

RONALD O. LOVERIDGE Mayor, Riverside Cities of Riverside County

JOSEPH LYOU, Ph.D. Governor’s Appointee

JUDITH MITCHELL Councilmember, Rolling Hills Estates Cities of Los Angeles County/Western Region

JAN PERRY Councilmember, Ninth District City of Los Angeles

MIGUEL PULIDO Mayor, Santa Ana Cities of Orange County

EXECUTIVE OFFICER:
BARRY R. WALLERSTEIN, D.Env.

## TABLE OF CONTENTS

SECTION PAGE

EXECUTIVE SUMMARY

................................................... .................................................. ES-1

CHAPTER 1: BACKGROUND
Introduction.......................................

................................................... ........................................ 1-1 Regulatory History.................................

................................................... ................................... 1-1

CHAPTER 2: SUMMARY OF PROPOSED AMENDED RULE 1175
Overview...........................................

................................................... ........................................ 2-1 Proposed Modifications to Rule 1175................

................................................... ....................... 2-1 Applicability......................................

................................................... ................................................... .2-1 Requirements.......................................

................................................... ..................................................2 -1 Monitoring, Recordkeeping and Reporting Requirement s.................................................. .....................2-2 Methods of Analysis................................

................................................... ..............................................2-2

CHAPTER 3: EMISSION IMPACT ASSESSMENT
Introduction.......................................

................................................... ........................................ 3-1 Emission Impact Assessment.........................

................................................... ........................... 3-1 Socioeconomic Impact Assessment....................

................................................... ...................... 3-1

Cost and Cost-Effectiveness........................

................................................... ..........................................3-1

Incremental Cost-Effectiveness.....................

................................................... ........................................3-1 Potential Environmental Impacts....................

................................................... ......................... 3-2 Draft Findings under California Health and Safety C ode 40727.......................................... ....... 3-2 Comparative Analysis...............................

................................................... ................................ 3-3 Comments and Responses.............................

................................................... ............................ 3-3

REFERENCES

................................................... ................................................... .....................R-1

### EXECUTIVE SUMMARY

### EXECUTIVE SUMMARY

Proposed Amended Rule 1175 – Control of Emissions f rom the Manufacture of Polymeric Cellular (Foam) Products has been developed to addr ess the concerns the U.S. Environmental Protection Agency (U.S. EPA) expresse d when they disapproved the September 2007 amendment because of rule deficienci es. The specific deficiencies described by U.S. EPA are as follows:

1. The rule must require demonstration, through source testing approved in writing by the Executive Officer, that the systems and techniques in place at a facility achieve 93%
collection and reduction of emissions for source co mplying with paragraph (c)(5) [was clause (c)(4)(B)(iii)].

2. The rule must clarify that all operational techniqu es and parameters needed to achieve compliance with paragraph (c)(5) [was clause (c)(4) (B)(iii)] be clearly defined, enforceable through a federally enforceable permit and identified in Rule 1175, where possible.

3. The rule must clarify that all operational techniqu es and parameters needed to achieve 90% collection and 95% destruction to comply with c lauses (c)(4)(B)(i) and (c)(4)(B)(ii) be clearly defined, enforceable through a federally enforceable permit and identified in Rule 1175, where possible.
Staff proposes the following requirements for Propo sed Amended Rule 1175:

• Require source testing, approved by the Executive O fficer, to demonstrate compliance with clauses (c)(4)(B)(i), (c)(4)(B)(ii) and parag raph (c)(5) [was clause (c)(4)(B)(iii)].

• Require record keeping to verify that all operation al techniques and parameters needed to ensure continued utilization of operational techniq ues used to comply with clauses (c)(4)(B)(i), (c)(4)(B)(ii) and paragraph (c)(5).

• Clarify that the prohibition for methylene chloride and chlorofluorocarbons (CFC) applies to all manufacturing operations subject to the rule excluding those specifically approved as acceptable alternatives under 40 CFR Pa rt 82 Subpart G – Significant New Alternatives Policy Program.

• Correct typographical errors associated with Method s of Analysis.

• Make minor clarifications and editorial corrections to the rule.
The proposed changes are administrative in nature a nd are not expected to impact emissions

or costs.

### CHAPTER 1: BACKGROUND

INTRODUCTION

REGULATORY HISTORYChapter 1: Background Final Staff Report

Proposed Amended Rule 1175 1-1 October 2010 

### INTRODUCTION
In May 2010, U.S. EPA disapproved a revision to the District portion of the State Implementation Plan because of concerns about VOC e missions from polymeric foam manufacturing operations. The specific deficiencie s are described below under Regulatory History.



### REGULATORY HISTORY
Rule 1175 was adopted November 3, 1989 and has sinc e been amended three times with the last amendment on September 7, 2007. The rule proh ibits the use of chlorofluorocarbons (CFCs), Volatile Organic Compounds (VOCs) and methy lene chloride in polymeric cellular foam product operations except for expandable polys tyrene molding and extrudable polystyrene foam operations. The rule controls VOC emissions of expandable polystyrene molding operations and extrudable polystyrene foam operations by either requiring control devices to capture VOC emissions or by limiting emi ssions to 2.4 pounds of VOC emitted per 100 pounds of product produced.

The September 7, 2007 rule amendment allowed for eq uivalent emissions collection and control by over-controlling the manufacturing emiss ions, in lieu of controlling their less costeffective block storage areas. On May 10, 2010, as published in the Federal Register [FR Doc 2010-109121], U.S. EPA announced their disappro val to the amendment. According to U.S. EPA, some rule provisions do not satisfy the r equirements of section 110 and part D of the Clean Air Act. Specifically:

1. The rule must require demonstration, through source testing approved in writing by the Executive Officer, that the systems and techniques in place at a facility achieve 93%
collection and reduction of emissions for sources c omplying with clause (c)(4)(B)(iii) [revised to be paragraph (c)(5)].

2. The rule must clarify that all operational techniqu es and parameters needed to achieve 93% control to comply with paragraph (c)(4)(B)(iii) [revised to be paragraph (c)(5)] must be clearly defined and enforceable through a federa lly enforceable permit such as a Title V operating permit. Rule 1175 should also be revis ed where possible to identify these
parameters.

3. The rule must clarify that all operational techniqu es and parameters needed to achieve 90% collection and 95% destruction to comply with p aragraphs (c)(4)(B)(i) and (c)(4)(B)(ii) must be clearly defined and enforceab le through a federally enforceableChapter 1: Background Final Staff Report

Proposed Amended Rule 1175 1-2 October 2010 permit such as a Title V operating permit. Rule 11 75 should also be revised where possible to identify these parameters.

U.S. EPA also included recommendations to further i mprove the rule that do not affect their current action. In response to their request, AQMD staff has made minor clarifications and
editorial corrections to the rule to enhance the cl arity of the rule.

### CHAPTER 2: SUMMARY OF PROPOSED AMENDED RULE 1175

OVERVIEW

PROPOSED MODIFICATIONS TO RULE 1175

AFFECTED FACILITIESChapter 2: Summary Final Staff Report

Proposed Amended Rule 1175 2-1 October 2010 

### OVERVIEW
Staff proposes to address the deficiencies identifi ed by the U.S. EPA. In addition, the rule will incorporate the administrative recommendations included in U.S. EPA’s technical support document.



### PROPOSED MODIFICATIONS TO RULE 1175
Applicability
A minor clarification is included to make the terms used to describe application operations more consistent. Specifically, the term “Extruded Polystyrene” will be used consistently throughout the rule and associated documentation.

Definitions

The definition for Chlorofluorocarbon had been modi fied to include previously excluded CFCs: chlorodifluoromethane (HCFC-22), dichlorotrif luoroethane (HCFC-123), tetrafluoroethane (HFC-134a), dichlorofluoroethane (HCFC-141b), chlorodifluoroethane (HCFC-142b) and 2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124). All CFCs used in operations subject to Rule 1175 are prohibited unle ss specifically approved as acceptable
alternatives under 40 CFR Part 82 Subpart G – Significant New Alternat ives Policy Program

.

A definition is included for Extruded Polystyrene ( XPS) Foam Operations. These operations were previously included under Expandable Polystyre ne (EPS) Molding Operations even though the definition did not adequately describe t hem. Rather than broadening the definition for Expandable Polystyrene Molding Opera tions, the new definition is included.

Reprocessed Material has been defined and the defin ition for Raw Material has been clarified to indicated that the use of regrind recycled, scra p or trim foam may be included as a raw
material.

Requirements The requirements applicable to Extruded Polystyrene (XPS) Foam Operations have been clarified. The requirements are unchanged but the inclusion of the definition necessitates explicitly referencing the new term in paragraphs ( c)(1) and (c)(2).

Sources subject to Rule 1175 that utilize a control device to comply with the rule are required to obtain a federally enforceable permit from the D istrict. At the time of permit issuance, the Executive Officer, in writing, will impose specific permit conditions reflecting the necessary parameters needed to achieve this level of control. The specific parameters may include, butChapter 2: Summary Final Staff Report

Proposed Amended Rule 1175 2-2 October 2010 are not limited to, establishing specific temperatu res and pressure limits for aging rooms, establishing volumetric flow rates into a control d evice and requiring a minimum operating temperature for the control device. Failure to mai ntain the control device in good operating condition, including conditions imposed by the Exec utive Officer, will be considered a
violation of Rule 1175.

Facilities utilizing control equipment to comply wi th the provisions of the proposed rule will be required to conduct source testing, approved in writing by the Executive Officer, to demonstrate the collection and control efficiency. Such testing is routinely required as part of the permitting process.

The prohibition of using methylene chloride and CFC s has been relocated to subdivision (d) to clarify that the prohibition applies to all poly urethane operations subject to the rule including expandable polystyrene molding operations and extruded polystyrene foam operations. All CFCs used in operations subject to Rule 1175 are prohibited unless specifically approved as acceptable alternatives un der 40 CFR Part 82 Subpart G – Significant New Alternatives Policy Program . This will provide consistency between Rule 1175 and federal requirements. At this time the only use of CFCs approved in foam products is HCFC-141b for space vehicle, nuclear, defense and r esearch and development for foreign customers (see Appendix M to Subpart G—Unacceptable Substitutes Listed in the September 30, 2004 Final Rule, Effective November 2 9, 2004).

Monitoring, Recordkeeping and Reporting Requirement s Records of operations and emission control system p arameters shall be maintained for five years to maintain consistency with Title V permit r equirements.

Methods of Analysis Typographical errors are corrected in subdivision ( g) of the proposed rule. Specifically, the paragraphs referenced shall be (g)(1) through (g)(4 ) rather than (g)(6) which does not exist. Also, the alternative methods must be equivalent to the methods that are listed below, rather than above the lead-in language of the rule.

### CHAPTER 3: IMPACT ASSESSMENT

INTRODUCTION

EMISSION IMPACT ASSESSMENT

SOCIOECONOMIC IMPACT ASSESSMENT

POTENTIAL ENVIRONMENTAL IMPACTS

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY C ODE 40727

COMPARATIVE ANALYSIS

COMMENTS AND RESPONSESChapter 3: Emission Impact Assessment Final Staff Report

Proposed Amended Rule 1175 3-1 October 2010 

### INTRODUCTION
Rule 1175 applies to polymeric cellular products ma nufacturing operations and includes but is not limited to expandable polystyrene, extruded polystyrene, polyurethane, isocyanurate and phenolic foam operations. This amendment is an administrative change request by the U.S. EPA and is not expected to affect emission imp acts.



### EMISSION IMPACT ASSESSMENT
The proposed amendments are administrative in natur e and will not impact the emission inventory nor result in any emission reductions.



### SOCIOECONOMIC IMPACT ASSESSMENT
The proposed amendments to Rule 1175 do not signifi cantly affect air quality or emission limitations and therefore a socioeconomic impact an alysis pursuant to California Health and Safety Code Sections 40440.8 and 40728.5 is not req uired.

Cost and Cost-Effectiveness The proposed amendments will not result in addition al costs to industry. Source testing and record keeping are routinely required in permit con ditions applied to control devices. Since there is no additional cost and no change in emissi ons, cost effectiveness is not applicable.

Incremental Cost-Effectiveness Under Health and Safety Code Section 40920.6, the A QMD is required to perform an incremental cost analysis when adopting a Best Avai lable Retrofit Control Technology (BARCT) rule or feasible measure required by the Ca lifornia Clean Air Act. To perform this analysis, the AQMD must (1) identify one or more co ntrol options achieving the emission reduction objectives for the proposed rule, (2) det ermine the cost effectiveness for each option, and (3) calculate the incremental cost effe ctiveness for each option. To determine incremental costs, the AQMD must “calculate the dif ference in the dollar costs divided by the difference in the emission reduction potentials between each progressively more stringent potential control option as compared to the next le ss expensive control option.”

Proposed Amended Rule 1175 addresses administrative issues identified by the U.S. EPA. The proposed amended rule does not implement a BARC T rule or a feasible measure required by the California Clean Air Act. Thus an incremental cost analysis is not required.Chapter 3: Emission Impact Assessment Final Staff Report

Proposed Amended Rule 1175 3-2 October 2010 

### POTENTIAL ENVIRONMENTAL IMPACTS
CEQA applies only to projects which may have a sign ificant effect on the environment. Staff has reviewed the proposed amendments and, pur suant to CEQA Guidelines § 15002(k)(1) – Three Step Process, has determined th at the proposed amendments to Rule
1175 - Control of Emissions from the Manufacture of Polymeric Cellular (Foam) Products are exempt from CEQA pursuant to CEQA Guidelines § 15061(b)(3) – Review for Exemption. If approved by the Governing Board, a No tice of Exemption (NOE) will be prepared for the proposed project pursuant to CEQA Guidelines §15062 – Notice of Exemption, and mailed to the county clerks of Los A ngeles, Orange, Riverside, and San
Bernardino counties.



### DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY C ODE 40727
Health and Safety Code Section 40727 requires that prior to adopting, amending or repealing a rule or regulation, the AQMD Governing Board shal l make findings of necessity, authority, clarity, consistency, non-duplication, and referenc e based on relevant information presented at the hearing. The draft findings are as follows:
Necessity – The AQMD Governing Board has determined that a n eed exists to amend Rule
1175 - Control of Emissions from the Manufacture of Polymeric Cellular (Foam) Products to address the deficiencies identified by the U.S. EPA

. Authority - The AQMD Governing Board obtains its authority t o adopt, amend, or repeal rules and regulations from Health and Safety Code S ections 39002, 40000, 40001, 40440, 40441, 40702 and 41508.
Clarity - The AQMD Governing Board has determined that Pro posed Amended Rule 1175 - Control of Emissions from the Manufacture of Polyme ric Cellular (Foam) Products, is written and displayed so that the meaning can be ea sily understood by persons directly affected by them.
Consistency - The AQMD Governing Board has determined that Pro posed Amended Rule
1175 - Control of Emissions from the Manufacture of Polymeric Cellular (Foam) Products, is in harmony with, and not in conflict with or contra dictory to, existing statutes, court decisions, federal or state regulations.
Non-Duplication - The AQMD Governing Board has determined that Pro posed Amended
Rule 1175 - Control of Emissions from the Manufactu re of Polymeric Cellular (Foam) Products, does not impose the same requirement as a ny existing state or federal regulation,Chapter 3: Emission Impact Assessment Final Staff Report

Proposed Amended Rule 1175 3-3 October 2010 and the proposed amendments are necessary and prope r to execute the powers and duties granted to, and imposed upon, the AQMD.

Reference - In adopting this regulation, the AQMD Governing Board references the following statutes which the AQMD hereby implements , interprets or makes specific: California Health and Safety Code sections 40001, 4 0440, and 40702.



### COMPARATIVE ANALYSIS
Health and Safety Code Section 40727.2 requires a w ritten analysis comparing the proposed rule with existing federal and AQMD regulations. F ederal regulations do not regulate VOC emissions from the manufacture of polymeric cellula r (foam) products. However, federal regulations do prohibit the use of certain ozone-de pleting substances under section 610(d) of the Clean Air Act (CAA). Specifically, Class I and Class II ozone depleting substances (ODS) including CFCs, halons, carbon tetrachloride and methyl chloroform, methyl bromide and most hydrofluorocarbons (HCFCs). Section 612 o f the CAA required EPA to establish the Significant New Alternatives Policy (SNAP) prog ram to evaluate alternatives to ODS making it unlawful to substitute alternatives that present adverse effects to human health or
the environment where another alternative has been identified that reduces risk and is available. Under the SNAP program HCFC-124, HCFC-2 2 and HCFC-142b have been determined to be unacceptable substitutes. HCFC-14 1b has been determined to be an unacceptable substitute in certain foam blowing app lications. The proposed rule will prohibit the use of all CFCs except those specifica lly approved under the SNAP program. At this time, only the use of HCFC 141b for space vehi cle, nuclear, defense and research and development for foreign customers has been approved

.



### COMMENTS AND RESPONSES
The following comments and AQMD staff responses wer e in response to the concerns of U.S. EPA staff, from their September 30, 2009 e-mai l.

Comment : While Rule 1175 applies to polystyrene foam extru sion operations, it

does not explicitly reference these operations as i t does polystyrene molding and block making operations. Future revisio ns should clarify which requirements also apply to polystyrene foam e xtrusion.
Staff Response : A definition for Extruded Polystyrene Molding Ope rations (polystyrene

extrusion operations) has been included in the prop osed amendments. The proposal also explicitly references provisions applicable to such operations.Chapter 3: Emission Impact Assessment Final Staff Report

Proposed Amended Rule 1175 3-4 October 2010 Comment : Please revise paragraph (c)(2) to clarify whether polystyrene foam

extrusion may include reprocessed material when dem onstrating compliance with the limit of 2.4 pounds VOC per 100 pounds raw material processed.
Staff Response : The definition for Raw Material will specifically include reprocessed

material and paragraph (c)(2) has been clarified to note that Extruded Polystyrene Molding Operations may utilize this alt ernative compliance option.

Comment: Note two potential typographical errors in the intr oductory paragraph of

section (f). The first sentence references paragrap hs (f)(1) through (f)(6), although the rule ends with (f)(4). The las t sentence reads, “...provided the approved alternative method is equiv alent to those listed above,” but we find no methods listed above.
Staff Response: The typographical errors have been corrected.

Comment: In developing the additional compliance option in p aragraph (c)(4)(iii)

[revised to paragraph (c)(5)], SCAQMD relied on dat a generated using procedures designed to measure emissions from highw ay vehicles. In June 2005, EPA supported an expanded polystyrene bl ock molding facility’s plan to complete these tests for a separ ate purpose, and EPA did not expect that the results would be used to su pport this rule amendment. As a result, we strongly recommend that SCAQMD reevaluate the compliance option in light of: (a) t he small number of polystyrene block tests that form the technical bas is for the compliance option; and (b) a report released in March 2009 by the Alliance of Foam Packaging Recyclers and EPS Manufacturers Asso ciation, entitled “Pentane Emissions Profile for Expanded Po lystyrene Foam Manufacturing Industry”, which suggests considerabl y higher emissions during block storage.
Staff Response: According to the Staff Report for the previous amen dment to Rule 1175,

the expanded polystyrene block testing “shows that the alternative compliance option is at a minimum equivalent to the current rule and in most cases is superior in terms of emission redu ction benefits when compared to the current requirement for capture and destruction of manufacturing and 48-hour storage emissions. In ad dition, theChapter 3: Emission Impact Assessment Final Staff Report

Proposed Amended Rule 1175 3-5 October 2010

pollution prevention element included in the propos ed compliance option, requiring the use of lower pentane bead wil l further ensure that the proposed alternative provides superior environm ental benefit.” In the report cited by U.S. EPA, “the type of pentane isomers used in the blowing agent were not identified for the industry data set provided; therefore, the potential effect of the pentane isom ers on residual pentane content was not considered. Insufficient su pport data were provided to quantify any difference in pentane loss es on a weight percentage basis due to low pentane or regular pent ane beads for like applications and product densities.” The District believes that the alternative control option combined with lower pent ane bead requirement will not lead to backsliding. The repo rt cited by U.S. EPA does not have any data that contradicts that conclu sion because it does not address low pentane beads.

Comment : Is it possible for a facility to utilize multiple compliance options to

demonstrate compliance with the rule provisions? Staff Response: A facility may utilize multiple compliance options to demonstrate

compliance. Facilities seeking such alternatives w ill be required to submit permit applications for engineering review, source test each scenario requested, accept federally-enforceable pe rmits with critical operation techniques and parameters incorporated in to the permit and maintain daily records demonstrating compliance.

Comment : Is reprocessed material included as raw material? Staff Response: Raw material does include reprocessed material such as regrind trim,

scrap or recycled materials. The definition for Ra w Material has been clarified to include reprocessed material and a def inition for Reprocessed Material has been included in the propo sed rule.

Comment : The alternative compliance option under (c)(5) sh ould be available to

shape molding operations. Shape molders have similar issues as the block molders do when it comes to product density, inability to construct 48-hour controlled enclosures due to leased propert y and limited space and the need to process some higher pentane material wh ile processing mostly low-to-mid-range pentane material. Staff Response: The data currently provided to demonstrate equivale nce is insufficient

to make a determination to include shape molding op erations under theChapter 3: Emission Impact Assessment Final Staff Report

Proposed Amended Rule 1175 3-6 October 2010

alternative compliance option. Further testing is necessary to establish the collection efficiency of the control equipment and emissions lost during the initial 48 hours of storage. Staff will continue to work with interested parties to determine if the alternative compliance option can be made available to shape molding operations.

Comment: Paragraph (c)(1) prohibits the use of CFCs excludi ng HCFC-22,

HCFC-123, HFC-134a, HCFC-141b, HCFC-142b and HCFC-1 24.
Therefore the rule allows the HCFCs and HFCs listed above. However, the use of HCFC-22, HCFC-124, HCFC-141b and HCFC-14 2b is in
conflict with the ban of these chemicals in some fo am manufacturing applications as U.S. EPA-approved foam blowing agen ts under the SNAP program. We recommend that the District clari fies that Rule 1175 is not in conflict with Federal requirements o n prohibited foam blowing agents. Staff Response: The proposed rule has been modified to prohibit th e use of all CFCs in

foam operations except those specifically approved under the SNAP program. This will provide consistency between Rul e 1175 and the federal requirements.

Comment: The Preliminary Staff Report acknowledges that cer tain HCFCs are not

allowed as foam blowing agents by the U.S. EPA. Sp ecifically, the reports states in part:
Under the SNAP program HCFC-124, HCFC-22 and HCFC-142b have been determined to be unacceptable
substitutes. HCFC-141b has been determined to be a n unacceptable substitute in certain foam blowing applications. With the exception of expanded polystyrene molding operations, Rule 1175 prohibits the use of CFCs. While the rule is silent regarding th e use of CFCs in expanded polystyrene molding operations and HCFC in all applications, there is no direct confli ct between Rule 1175 and federal regulations.
The above staff analysis may not be entirely accura te (or perhaps unclear). The rule prohibits CFCs but specifically allows the use of HCFC-22, HCFC-123, HFC-134a, HCFC-141b, HCFC-142b a nd HCFC-124. We suggest that the District provides ad ditionalChapter 3: Emission Impact Assessment Final Staff Report

Proposed Amended Rule 1175 3-7 October 2010

clarification on how the rule is not in conflict wi th U.S. EPA foam blowing agent SNAP regulations. Staff Response: We concur that the rule language and analysis prov ided were unclear

regarding the use HCFC-22, HCFC-123, HFC-134a, HCFC -141b, HCFC-142b and HCFC-124. The proposed rule has been modified to prohibit the use of all CFCs in foam operations exc ept those specifically approved under the SNAP program. This will provide consistency between Rule 1175 and the federal requi rements.

### REFERENCESReferences Final Staff Report

Proposed Amended Rule 1175 R-1 October 2010 

### REFERENCES
“Disapproval of State Implementation Plan Revisions , South Coast Air Quality Management District.” Federal Register 75:89 (May 10, 2010) p .25775.

Pentane Emissions Profile for Expanded Polystyrene Foam Manufacturing Industry, URS Corporation, March 2009.

Final Staff Report for Proposed Amended Rule 1175 – Control of Emissions from the Manufacture of Polymeric Cellular (Foam) Products, South Coast Air Quality Management District, August 2007.

“Title 40: Protection of Environment, Part 82-Prote ction of Stratospheric Ozone, Subpart GSignificant New Alternatives Policy Program.” Fede ral Register 59 FR 13147, March 18, 1994, unless otherwise noted.