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 DISTRICT
SOUTH 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 Requirements.......................................................................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 Code 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 from the Manufacture of Polymeric 

Cellular (Foam) Products has been developed to address the concerns the U.S. 

Environmental Protection Agency (U.S. EPA) expressed when they disapproved the 

September 2007 amendment because of rule deficiencies. 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 complying with paragraph (c)(5) [was 

clause (c)(4)(B)(iii)]. 

2. The rule must clarify that all operational techniques 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 techniques and parameters needed to achieve 

90% collection and 95% destruction to comply with clauses (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 Proposed Amended Rule 1175: 

• Require source testing, approved by the Executive Officer, to demonstrate compliance 

with clauses (c)(4)(B)(i), (c)(4)(B)(ii) and paragraph (c)(5) [was clause (c)(4)(B)(iii)]. 

• Require record keeping to verify that all operational techniques and parameters needed to 

ensure continued utilization of operational techniques 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 Part 82 Subpart G – Significant New 

Alternatives Policy Program. 

• Correct typographical errors associated with Methods of Analysis. 

• Make minor clarifications and editorial corrections to the rule. 

The proposed changes are administrative in nature and are not expected to impact emissions 

or costs. 
CHAPTER 1: BACKGROUND 

INTRODUCTION 

REGULATORY HISTORY 
Chapter 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 emissions from polymeric foam 

manufacturing operations. The specific deficiencies are described below under Regulatory 

History. 

REGULATORY HISTORY 

Rule 1175 was adopted November 3, 1989 and has since been amended three times with the 

last amendment on September 7, 2007. The rule prohibits the use of chlorofluorocarbons 

(CFCs), Volatile Organic Compounds (VOCs) and methylene chloride in polymeric cellular 

foam product operations except for expandable polystyrene 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 emissions to 2.4 pounds of VOC emitted 

per 100 pounds of product produced. 

The September 7, 2007 rule amendment allowed for equivalent emissions collection and 

control by over-controlling the manufacturing emissions, 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 disapproval to the amendment. According to 

U.S. EPA, some rule provisions do not satisfy the requirements 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 complying with clause (c)(4)(B)(iii) 

[revised to be paragraph (c)(5)]. 

2. The rule must clarify that all operational techniques 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 federally enforceable permit such as a Title 

V operating permit. Rule 1175 should also be revised where possible to identify these 

parameters. 

3. The rule must clarify that all operational techniques and parameters needed to achieve 

90% collection and 95% destruction to comply with paragraphs (c)(4)(B)(i) and 

(c)(4)(B)(ii) must be clearly defined and enforceable through a federally enforceable 
Chapter 1: Background Final Staff Report

Proposed Amended Rule 1175 1-2 October 2010 

permit such as a Title V operating permit. Rule 1175 should also be revised where 

possible to identify these parameters. 

U.S. EPA also included recommendations to further improve 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 clarity of the rule.
CHAPTER 2: SUMMARY OF PROPOSED AMENDED RULE 1175 

OVERVIEW

PROPOSED MODIFICATIONS TO RULE 1175 

AFFECTED FACILITIES 
Chapter 2: Summary Final Staff Report

Proposed Amended Rule 1175 2-1 October 2010 

OVERVIEW 

Staff proposes to address the deficiencies identified 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 modified to include previously excluded 

CFCs: chlorodifluoromethane (HCFC-22), dichlorotrifluoroethane (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 unless specifically approved as acceptable 

alternatives under 40 CFR Part 82 Subpart G – Significant New Alternatives Policy Program. 

 

A definition is included for Extruded Polystyrene (XPS) Foam Operations. These operations 

were previously included under Expandable Polystyrene (EPS) Molding Operations even 

though the definition did not adequately describe them. Rather than broadening the 

definition for Expandable Polystyrene Molding Operations, the new definition is included. 

Reprocessed Material has been defined and the definition for Raw Material has been clarified 

to indicated that the use of regrind recycled, scrap 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 District. 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, but 
Chapter 2: Summary Final Staff Report

Proposed Amended Rule 1175 2-2 October 2010 

are not limited to, establishing specific temperatures and pressure limits for aging rooms, 

establishing volumetric flow rates into a control device and requiring a minimum operating 

temperature for the control device. Failure to maintain the control device in good operating 

condition, including conditions imposed by the Executive Officer, will be considered a 

violation of Rule 1175. 

Facilities utilizing control equipment to comply with 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 CFCs has been relocated to subdivision (d) 

to clarify that the prohibition applies to all polyurethane 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 under 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 research and development for foreign 

customers (see Appendix M to Subpart G—Unacceptable Substitutes Listed in the 

September 30, 2004 Final Rule, Effective November 29, 2004). 

Monitoring, Recordkeeping and Reporting Requirements

Records of operations and emission control system parameters shall be maintained for five 

years to maintain consistency with Title V permit requirements. 

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 CODE 

40727 

COMPARATIVE ANALYSIS 

COMMENTS AND RESPONSES 
Chapter 3: Emission Impact Assessment Final Staff Report

Proposed Amended Rule 1175 3-1 October 2010

INTRODUCTION 

Rule 1175 applies to polymeric cellular products manufacturing 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 impacts. 

EMISSION IMPACT ASSESSMENT 

The proposed amendments are administrative in nature and will not impact the emission 

inventory nor result in any emission reductions. 

SOCIOECONOMIC IMPACT ASSESSMENT 

The proposed amendments to Rule 1175 do not significantly affect air quality or emission 

limitations and therefore a socioeconomic impact analysis pursuant to California Health and 

Safety Code Sections 40440.8 and 40728.5 is not required. 

Cost and Cost-Effectiveness

The proposed amendments will not result in additional costs to industry. Source testing and 

record keeping are routinely required in permit conditions applied to control devices. Since 

there is no additional cost and no change in emissions, cost effectiveness is not applicable. 

Incremental Cost-Effectiveness

Under Health and Safety Code Section 40920.6, the AQMD is required to perform an 

incremental cost analysis when adopting a Best Available Retrofit Control Technology 

(BARCT) rule or feasible measure required by the California Clean Air Act. To perform this 

analysis, the AQMD must (1) identify one or more control options achieving the emission 

reduction objectives for the proposed rule, (2) determine the cost effectiveness for each 

option, and (3) calculate the incremental cost effectiveness for each option. To determine 

incremental costs, the AQMD must “calculate the difference 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 less expensive control option.” 

Proposed Amended Rule 1175 addresses administrative issues identified by the U.S. EPA. 

The proposed amended rule does not implement a BARCT 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 significant effect on the environment. 

Staff has reviewed the proposed amendments and, pursuant to CEQA Guidelines § 

15002(k)(1) – Three Step Process, has determined that 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 Notice 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 Angeles, Orange, Riverside, and San 

Bernardino counties. 

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE 

40727 

Health and Safety Code Section 40727 requires that prior to adopting, amending or repealing 

a rule or regulation, the AQMD Governing Board shall make findings of necessity, authority, 

clarity, consistency, non-duplication, and reference based on relevant information presented 

at the hearing. The draft findings are as follows:

Necessity – The AQMD Governing Board has determined that a need 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 to adopt, amend, or repeal 

rules and regulations from Health and Safety Code Sections 39002, 40000, 40001, 40440, 

40441, 40702 and 41508. 

Clarity - The AQMD Governing Board has determined that Proposed Amended Rule 1175 - 

Control of Emissions from the Manufacture of Polymeric Cellular (Foam) Products, is 

written and displayed so that the meaning can be easily understood by persons directly 

affected by them. 

Consistency - The AQMD Governing Board has determined that Proposed Amended Rule 

1175 - Control of Emissions from the Manufacture of Polymeric Cellular (Foam) Products, is 

in harmony with, and not in conflict with or contradictory to, existing statutes, court 

decisions, federal or state regulations. 

Non-Duplication - The AQMD Governing Board has determined that Proposed Amended 

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

Products, does not impose the same requirement as any 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 proper 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, 40440, and 40702. 

COMPARATIVE ANALYSIS 

Health and Safety Code Section 40727.2 requires a written analysis comparing the proposed 

rule with existing federal and AQMD regulations. Federal regulations do not regulate VOC 

emissions from the manufacture of polymeric cellular (foam) products. However, federal 

regulations do prohibit the use of certain ozone-depleting 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 of the CAA required EPA to establish 

the Significant New Alternatives Policy (SNAP) program 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-22 and HCFC-142b have been 

determined to be unacceptable substitutes. HCFC-141b has been determined to be an 

unacceptable substitute in certain foam blowing applications. The proposed rule will 

prohibit the use of all CFCs except those specifically approved under the SNAP program. At 

this time, only the use of HCFC 141b for space vehicle, nuclear, defense and research and 

development for foreign customers has been approved. 

COMMENTS AND RESPONSES 

The following comments and AQMD staff responses were in response to the concerns of 

U.S. EPA staff, from their September 30, 2009 e-mail. 

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

does not explicitly reference these operations as it does polystyrene 

molding and block making operations. Future revisions should clarify 

which requirements also apply to polystyrene foam extrusion. 

Staff Response: A definition for Extruded Polystyrene Molding Operations (polystyrene 

extrusion operations) has been included in the proposed 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 demonstrating 

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 alternative 

compliance option. 

Comment: Note two potential typographical errors in the introductory paragraph of 

section (f). The first sentence references paragraphs (f)(1) through 

(f)(6), although the rule ends with (f)(4). The last sentence reads, 

“...provided the approved alternative method is equivalent 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 paragraph (c)(4)(iii) 

[revised to paragraph (c)(5)], SCAQMD relied on data generated using 

procedures designed to measure emissions from highway vehicles. In 

June 2005, EPA supported an expanded polystyrene block molding 

facility’s plan to complete these tests for a separate purpose, and EPA 

did not expect that the results would be used to support this rule 

amendment. As a result, we strongly recommend that SCAQMD 

reevaluate the compliance option in light of: (a) the small number of 

polystyrene block tests that form the technical basis for the compliance 

option; and (b) a report released in March 2009 by the Alliance of 

Foam Packaging Recyclers and EPS Manufacturers Association, 

entitled “Pentane Emissions Profile for Expanded Polystyrene Foam 

Manufacturing Industry”, which suggests considerably higher 

emissions during block storage. 

Staff Response: According to the Staff Report for the previous amendment 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 reduction benefits when 

compared to the current requirement for capture and destruction of 

manufacturing and 48-hour storage emissions. In addition, the 
Chapter 3: Emission Impact Assessment Final Staff Report

Proposed Amended Rule 1175 3-5 October 2010

pollution prevention element included in the proposed compliance 

option, requiring the use of lower pentane bead will further ensure that 

the proposed alternative provides superior environmental 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 isomers on residual 

pentane content was not considered. Insufficient support data were 

provided to quantify any difference in pentane losses on a weight 

percentage basis due to low pentane or regular pentane beads for like 

applications and product densities.” The District believes that the 

alternative control option combined with lower pentane bead 

requirement will not lead to backsliding. The report cited by U.S. EPA 

does not have any data that contradicts that conclusion 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 will be required to 

submit permit applications for engineering review, source test each 

scenario requested, accept federally-enforceable permits with critical 

operation techniques and parameters incorporated into 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 Raw Material has been 

clarified to include reprocessed material and a definition for 

Reprocessed Material has been included in the proposed rule. 

Comment: The alternative compliance option under (c)(5) should 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 property and limited space and 

the need to process some higher pentane material while processing mostly 

low-to-mid-range pentane material.

Staff Response: The data currently provided to demonstrate equivalence is insufficient 

to make a determination to include shape molding operations under the 
Chapter 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 excluding HCFC-22, 

HCFC-123, HFC-134a, HCFC-141b, HCFC-142b and HCFC-124. 

Therefore the rule allows the HCFCs and HFCs listed above. However, 

the use of HCFC-22, HCFC-124, HCFC-141b and HCFC-142b is in 

conflict with the ban of these chemicals in some foam manufacturing 

applications as U.S. EPA-approved foam blowing agents under the 

SNAP program. We recommend that the District clarifies that Rule 

1175 is not in conflict with Federal requirements on prohibited foam 

blowing agents. 

Staff Response: The proposed rule has been modified to prohibit the use of all CFCs in 

foam operations except those specifically approved under the SNAP 

program. This will provide consistency between Rule 1175 and the 

federal requirements. 

 Comment: The Preliminary Staff Report acknowledges that certain HCFCs are not 

allowed as foam blowing agents by the U.S. EPA. Specifically, 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 an 

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 the use of 

CFCs in expanded polystyrene molding operations and

HCFC in all applications, there is no direct conflict 

between Rule 1175 and federal regulations. 

The above staff analysis may not be entirely accurate (or perhaps 

unclear). The rule prohibits CFCs but specifically allows the use of 

HCFC-22, HCFC-123, HFC-134a, HCFC-141b, HCFC-142b and 

HCFC-124. We suggest that the District provides additional 
Chapter 3: Emission Impact Assessment Final Staff Report

Proposed Amended Rule 1175 3-7 October 2010

clarification on how the rule is not in conflict with U.S. EPA foam 

blowing agent SNAP regulations. 

Staff Response: We concur that the rule language and analysis provided 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 except those 

specifically approved under the SNAP program. This will provide 

consistency between Rule 1175 and the federal requirements.
REFERENCES 
References 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-Protection of Stratospheric Ozone, Subpart GSignificant New Alternatives Policy Program.” Federal Register 59 FR 13147, March 18, 

1994, unless otherwise noted.