SAN JOAQlllN VALLEY UNIFIED AIR POLLU'TION CONTROL DISTRICT 

Appendix F: Supplemental Information September 20, 2007 

APPENDIX F 

Supplemental lnformation for Revised Proposed Amendments to 

Rule 4682 (Polystyrene Foam, Polyethylene, 

and Polypropylene Manufacturing) 

September 20,2007 

Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 
(Adopted November 3, 1989)(Amended January 5,1990) 

(Amended May 13,1994) 

RULE 1175. CONTROL OF EMISSIONS FROM THE MANUFACTURE OF 

POLYMERIC CELLULAR (FOAM) PRODUCTS 

(a) Applicability 

This rule shall apply to polymeric cellular products manufacturing operations 

including but not limited to expandable polystyrene, polystyrene foam extrusion, 

polyurethane, isocyanurate and phenolic foam operations. All steps of the 

manufacturing oljeration and the storage of the final product for a maximum of 48 

hours are subject to the requirements of this rule. 

(b) Definitions 

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

(1) APPROVED EMISSION CONTROL SYSTEM means any system used 

to reduce manufacturing emissions and consists of a collection and a 

control device, which are approved, in writing, by the Executive Officer. 

The control system must be operated subject to the following provisions: 

(A) The emission collection system shall collect at least a 90 percent 

by weight of the manufacturing emissions; and 

(B) The control device shall reduce emissions from the emission 

collection system by at least 95 percent, by weight. 

(2) BLOWING AGENT means a liquid, gaseous or solid material that 

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

(3) CHLOROFLUOROCARBON (CFC) is any chlorinated fluorinated 

compound of carbon, excluding; 

chlorodifluoromethane (HCFC-22), 

dichlorotrifluoroethane (HCFC- 123), 

tetrafluoroethane (HFC- 1 34a), 

dichlorofluoroethane (HCFC-141 b), 

chlorodifluoroethane (HCFC- 142b) 

2-chloro- 1 , 1 , l,2-tetrafluoroethane (HCFC- 124), 

(4) EXEMPT COMPOUNDS are any of the following compounds: 

(A) Group I (General) 

trifluoromethane (HFC-23) 

pentafluoroethane (HFC- 1 25) 

l,l,2,2-tetrafluoroethane (HFC-134) 

tetrafluoroethane (HFC- 1 34a) 

Final Staff Report with Appendices 

For Revised Proposed 

1175 - 1 Amendments to Rule 4682 
Rule 1175 (Cont.) (Amended May 13,1994) 

1 , 1 , 1 -trifluoroethane (HFC- 143 a) 

1,l -difluoroethane (HFC- 152a) 

chlorodifluoromethane (HCFC-22) 

dichlorotrifluoroethane (HCFC-123) 

2-chloro- 1 , 1 ,l,2-tetrafluoroethane (HCFC- 124) 

dichlorofluoroethane (HCFC- 14 1 b) 

chlorodifluoroethane (HCFC-142b) 

cyclic, branched, or linear, completely fluorinated alkanes 

cyclic, branched, or linear, completely fluorinated ethers with no 

unsaturations 

cyclic, branched, or linear, completely fluorinated tertiary amines 

with no unsaturations 

sulfur-containing perfluorocarbons with no unsaturations and with 

sulfur bonds only to carbon and fluorine 

(B) Group I1 

methylene chloride 

1,1,1 -trichloroethane (methyl chloroform) 

trifluoromethane (FC-23) 

trichlorotrifluoroethane (CFC-113) 

dichlorodifluoromethane (CFC- 12) 

trichlorofluoromethane (CFC- 1 1) 

dichlorotetrafluoroethane (CFC- 1 14) 

chloropentafluoroethane (CFC- 1 1 5) 

The use of Group I1 compounds andlor carbon tetrachloride may be 

restricted in the future because they are toxic, potentially toxic, upperatmosphere ozone depleters, or cause other environmental impacts. By 

January 1, 1996, chlorofluorocarbons (CFC), 1,1,1 ,-trichloroethane 

(methyl chloroform), and carbon tetrachloride will be phased out in 

accordance with the Code of Federal Regulations Title 40, Part 82 

(December 1 0, 1 993). 

(5) EXPANDABLE POLYSTYRENE (EPS) MOLDING OPERATIONS 

consist of a series of processes, where polystyrene beads and blowing 

agent are expanded by exposure to steam or any other expansion agent and 

processed through cup, block or shape molding into low-density, closed 

cell, cellular products. EPS products include but are not limited to 

drinking cups, insulation board, packaging material, and ice chests. 

(6) MANUFACTURING EMISSIONS are any emissions of VOC, CFC, or 

methylene chloride that occur during the manufacturing operatiop. 

Final Staff Report with Appendices 

For Revised Proposed 

1175-2 Amendments to Rule 4682 
Rule 1175 (Cont.) (Amended May 13,1994) 

(7) MANUFACTURING OPERATION means every step of the processing of 

a polymeric material from the delivery of the raw material, until the 

storage of the final cellular product. 

(8) RAW MATERIAL means all polystyrene beads, polyurethane, and 

blowing agent used in the manufacture of polymeric cellular products. 

(9) RIGID POLYURETHANE is a closed cell polyurethane, primarily 

manufactured as rigid slabstock, laminated boardstock, field spray foam or 

pour-in-place foam. 

(10) VOLATILE ORGANIC COMPOUND (VOC) is any volatile compound 

of carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic 

acid, metallic carbides or carbonates, and exempt compounds. 

(c) Emission Control Requirements 

(1) Manufacturing Operations, Excluding Expandable Polystyrene (EPS) 

Molding Operations 

(A) By January 1, 1994, each polyurethane operation subject to the 

rule shall discontinue its use of CFCs, VOCs, or methylene 

chloride. 

(B) Each manufacturing operation, excluding rigid polyurethane 

operations shall reduce yearly emissions from its 1988 emissions 

baseline, based on Rule 301 emission fees filing, by 100 percent, 

beginning calendar year 1994. 

(2) Expandable Polystyrene (EPS) Molding Operations 

The owner or operator of an expandable polystyrene (EPS) molding 

operation shall demonstrate, to the satisfaction of the ~xecutive Officer, 

that manufacturing emissions and post-manufacturing emissions, 

assuming all the blowing agent is released from the product, are less than 

2.4 lbs per 100 lbs of raw material processed. 

(3) The owner or operator of any polymeric cellular manufacturing operation, 

subject to the requirements of subparagraph (c)(l) or (c)(2), shall submit a 

plan to the District subject to approval by the Executive Officer's 

designee, that will demonstrate compliance with subparagraph (c)(l) or 

(c)(2). 

(4) The owner or operator of any polymeric cellular manufacturing operation 

that has not achieved the requirements specified in subparagraphs (c)(l), 

(c)(2), or (c)(3) shall: 

Final Staff Report with Appendices 

For Revised Proposed 

1175- 3 Amendments to Rule 4682 
Rule 1175 (Cont.) (Amended May 13,1994) 

(A) Submit permit applications for the installation of an emission 

control system within four months of the date that compliance with 

such requirement was not achieved; and 

(B) Within 12 months of failing to meet the requirements of 

subparagraph (c)(l), (c)(2), or (c)(3), the following provisions 

must be satisfied: 

(i) An approved emission control system is installed and 

operating with all sources of manufacturing emissions 

vented only to the approved emission control system; and 

(ii) Emissions from the final manufactured product are vented 

only to the approved emission control system for at least: 

(I) 48 hours, in the case of expandable polystyrene 

molding operations that process more than 800,000 

pounds per calendar year of raw material; or 

(11) 24. hours, in the case of all other manufacturing 

operations. 

(d) Exemptions 

(1) The provisions of paragraph (c) shall not apply to any: 

(A) Expandable polystyrene operation that processes less tha. 200 

pounds per day of raw material. 

(B) Rigid polyurethane operation that processes less than 1,000 pounds 

per day of raw material. 

(2) , The provisions of subparagraph (c)(4)(B)(ii) shall not apply to any facility 

that only manufactures: 

(A) rigid polyurethane foam; or 

(B) EPS foam and the highest concentration of the blowing agent in 

the cellular product is 1.8 percent or less by weight within 15 

minutes of completion of the manufacturing operation. 

Verification of the concentration shall be demonstrated annually, 

pursuant to a protocol submitted to the District and subject to 

approval by the Executive Officer. 

(e) Recordkeeping 

(1) Any owner or operator subject to this rule or claiming an exemption under 

paragraph (d) shall maintain a daily record of operations, including but not 

Final Staff Report with Appendices 

For Revised Proposed 

1175 - 4 Amendments to Rule 4682 
Rule 1175 (Cont.) (Amended May 13,1994) 

limited to the amount of raw material processed, the equipment used, and 

the type of blowing agent used. Such records shall be retained in the 

operator's files for a period of two years and be available to a District 

representative upon request. 

Owners and/or operators using an emission control system as a means of 

complying with this rule shall maintain daily records of the operation and 

maintenance of the emission control system. These records shall include 

key system operating parameters such as temperatures, pressures, 

flowrates, and other measures to demonstrate compliance with paragraph 

(cI(4). 

(f) Test Methods 

(1) Determination of VOC Content 

The VOC content of materials subject to the provisions of this rule shall 

be determined by the following methods: 

(A) United States Environmental Protection Agency (USEPA) 

Reference Method 24 (Code of Federal Regulations Title 40 Part 

60, Appendix A,). The exempt solvent content shall be determined 

by SCAQMD Method 303 (Determination of Exempt Compounds) 

contained in the SCAQMD "Laboratory Methods of Analysis for 

Enforcement Samples" manual; or, 

(B) SCAQMD Method 304 [Determination of Volatile Organic 

Compounds (VOCs) in Various Materials] contained in the 

SCAQMD "Laboratory Methods of Analysis for Enforcement 

Samples" manual. 

(C) Exempt Perfluorocarbon Compounds 

The following classes of compounds will be analyzed as exempt 

compounds for compliance with paragraph (c), only when 

manufacturers specify which individual compounds are used in 

the coating formulation: 

cyclic, branched, or linear, completely fluorinated alkanes; 

cyclic, branched, or linear, completely fluorinated ethers with 

no unsaturations; 

cyclic, branched, or linear, completely fluorinated tertiary 

arnines with no unsaturations; and 

Final Staff Report with Appendices 

For Revised Proposed 

1175- 5 Amendments to Rule 4682 
Rule 1175 (Cont.) (Amended May 13,1994) 

sulfbr-containing perfluorocarbons with no unsaturations and 

with sulfur bonds only to carbon and fluorine. 

In addition, the manufacturers must identify the test methods 

approved and used by the United States Environmental Protection 

Agency, California Air Resources Board, and the District to 

quantify the amount of each exempt compound. 

(2) Determination of Pentanes in Expandable Styrene Polymers 

The weight percent pentane in expandable polystyrene polymer shall be 

determined by SCAQMD Method 306 (Analysis of Pentanes in 

Expandable Styrene Polymers) contained in the SCAQMD "Laboratory 

Methods of Analysis for Enforcement Samples" manual. 

(3) Determination of Efficiency of Emission Control System 

(A) The efficiency of the collection device of the emission control 

system required in paragraph (c)(4) shall be determined by the 

USEPA method cited in 55 Federal Register 26865 (June 29, 

1990), or any other method approved by the United States 

Environmental Protection Agency, the California Air Resources 

Board, and the District. 

(B) The efficiency of the control device of the emission control system 

required in paragraph (c)(4) and the VOC content in the control 

device exhaust gases, measured and calculated as carbon, shall be 

determined by USEPA Test Methods 25, 25A, or SCAQMD 

Method 25.1 (Determination of Total Gaseous Non-Methane 

Organic Emissions as Carbon) as applicable. USEPA Test Method 

18, or ARB Method 422 shall be used to determine emissions of 

exempt compounds. 

(4) Multiple Test Methods 

When more than one test method or set of test methods are 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 the rule. 

Final Staff Report with Appendices 

For Revised Proposed 

Amendments to Rule 4682 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

PRELIMINARY DRAFT STAFF REPORT FOR PROPOSED AMENDED RULE 

1175 - CONTROL OF EMISSIONS FROM THE MANUFACTURE OF 

POLYMERIC CELLULAR (FOAM) PRODUCTS 

June 2007 

Deputy Executive Officer 

Planning, Rule Development, and Area Sources 

Elaine Chang, DrPH 

Assistant Deputy Executive Officer 

Planning, Rule Development, and Area Sources 

Laki Tisopulos, Ph.D., P.E. 

Planning and Rules Manager 

VOC Rule Development 

Larry Bowen, P.E. 

Written By: William Milner - Air Quality Specialist 

Contributors: Michael Cecconi, P.E. - Senior Air Quality Engineer 

Hubert Wilson - Air Quality Analysis and Compliance Supervisor 

Reviewed By: Edward M. Muehlbacher, P.E. - Program Supervisor 

Jeri Voge - Senior Deputy District Counsel 

Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

GOVERNING BOARD 

Chairman: WILLIAM A. BURKE, Ed.D. 

Speaker of the Assembly Appointee 

Vice Chairman: S. ROY WILSON, Ed.D. 

Supervisor, Fourth District 

Riverside County Representative 

MEMBERS: 

MICHAEL D. ANTONOVICH 

Supervisor, Fifth District 

Los Angeles County Representative 

BILL CAMPBELL 

Supervisor, Second District 

Orange County Representative 

JANE W. CARNEY 

Senate Rules Committee Appointee 

RONALD 0. LOVERIDGE 

Mayor, City of Riverside 

Cities Representative, Riverside County 

GARY OVITT 

Supervisor, Fourth District 

San Bernardino County Representative 

JAN PERRY 

Councilmember, City of Los Angeles 

Cities Representative, Los Angeles County, Western Region 

MIGUEL PULIDO 

Mayor, City of Santa Ana 

Cities Representative, Orange County 

TONIA REYES URANGA 

Councilmember, City of Long Beach 

Cities Representative, Los Angeles County, Eastern Region 

VACANT 

Governor's Appointee 

DENNIS YATES 

Councilmember, City of Chino 

Cities Representative, Cities of San Bernardino County 

EXECUTIVE OFFICER 

BARRY R. WALLERSTEIN, D.Env. 

Final Staff Report with Appendices 

for Revised Proposed Amendments, to Rule 4682 
TABLE OF CONTENTS 

EXECUTIVE S UMMAR Y. ............................................................................................................ 1 

BA CKGRO UND ............................................................................................................................. 1 

PROCESS DESCRIPTION AND CONTROLS ........................................................................... 2 

EPS Molding Operations ........................................................................................................................ 2 

STAFF PROPOSAL ...................................................................................................................... 4 

EMISSIONS INVENTORY AND POTENTIAL EMISSION REDUCTIONS .......................... 5 

COST. COST EFFECTIVENSS. AND INCREMENTAL COST EFFECTI VENESS .............. 6 

CALIFORNIA ENVIRONMENTAL QUALITY A CT ................................................................. 7 

SOCIOECONOMIC IMPACT ANALYSIS .................................................................................. 7 

LEGISLA TIVE AUTHORITY ...................................................................................................... 7 

DRAFT FINDINGS ....................................................................................................................... 7 

AQMP AND LEGAL MANDATES ........................................................................................... 8 

DRAFT CONCLUSIONS AND RECOMENDA TIONS .............................................................. 8 

APPENDIX A: EPS BLOCK TESTING PROGRAM AND EXAMPLE COMPLIANCE 

DEMONSTRA TION ..................................................................................................................... 9 

Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 
Preliminary Draft Staff Report for Proposed Amended Rule 11 75 

EXECUTIVE SUMMARY 

Proposed Amended Rule 1 175 has been developed to provide expandable polystyrene molding 

operations with an alternative compliance option that is superior in terms of emission reduction 

benefits and more cost-effective compared to the compliance options currently available in the 

rule. 

Pentane is a blowing agent impregnated into tiny beads of polystyrene, such that when the beads 

are exposed to steam they will expand at relatively low temperature and pressure to 10 to 40 

times their original volume, or more. These expanded beads become the basis for molding 

operations in which beads are fused together to form architectural construction products, 

packaging materials, or specialty products. 

Facilities engaging in expanded polystyrene (EPS) molding operations are required to 

demonstrate that the volatile organic compound (VOC) emissions (of which pentane is one), 

from delivery of the beads, through all manufacturing steps, as well as fugitive molded product 

storage emissions are less than 2.4 pounds per 100 pounds of raw beads (Rule 1175(c)(2)). 

Alternatively, if a facility cannot demonstrate this limit on a continuous basis, it must control its 

manufacturing operations and its diffuse residual VOC product storage emissions, through the 

first 48-hours of its lifetime, by containing, capturing and destroying the VOCs by 90 and 95 

percent, respectively (Rule 1175(c)(4)). The difficulty of controlling fugitive residual VOC 

within the molded product is that the size of storage areas are large and the release of VOC is 

very small by comparison, as demonstrated by recent emissions testing. 

The proposed amendment has been developed in response to requests from industry for 

additional compliance flexibility, and focuses on recent advances in the low-pentane bead and 

molding technologies. It provides block molding manufacturers, that commit to conduct a 

significant fraction of their molding operations with low-pentane bead, while curtailing the use 

of high-pentane bead, with a more flexible and cost-effective compliance alternative. Under this 

alternative, rather than controlling manufacturing and storage emissions by 85.5 percent as 

required under the current rule, a block manufacturer will be allowed to over control 

manufacturing emissions, in lieu of controlling the less cost-effective storage emissions. The 

proposed overall control efficiency of the manufacturing emissions is 93 percent. This 

alternative will provide compliance flexibility, and pollution prevention, while resulting in 

equivalent or superior environmental benefits, as compared to current rule requirements. 

BACKGROUND 

Rule 1 175, as adopted in 1989 and revised in 1990, controls VOC, chlorofluorocarbon (CFC), 

and methylene chloride emissions from expanded polystyrene foam molders, direct injection 

polystyrene foam extrusion (XPS), polyurethane, isocyanurate and phenolic foam operations. 

All steps of the manufacturing operation and final product storage for the first 48 hours for EPS 

foam molding operations after product manufacture are subject to the requirements of this rule. 

For all other polymeric cellular manufacturing operations, the requirements are the same except 

that ventilation of the fugitive storage emissions is for a 24 hour period, rather than for 48. 

Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 
Preliminary Draft Staff Report for Proposed Amended Rule 11 75 

The focus of Rule 1175 during it original development was to reduce VOC emissions through 

add-on control technology. During rule development, an alternative was included that would 

allow facilities to show compliance on a raw material throughput basis such that the emissions 

from both manufacturing and post manufacturing operations be less than 2.4 pounds of VOC per 

100 pounds of raw material processed, assuming all blowing agent is released from the product. 

This alternative compliance option was initiated through a company that manufactures thinwalled molded EPS drinking cups and bowls and vents its bead expansion and prepuff aging 

process VOC emissions to a boiler for thermal destruction. Their manufacturing operation uses 

EPS beads with a relatively constant pentane content, constant product density, negative air 

pressure on its bead expansion and prepuff aging rooms, and elevated temperature within its 

aging room, while venting both aging room and expansion operations to a thermal control 

device. To provide additional compliance flexibility, and in response to industry requests, this 

alternative compliance option was also extended to all other sectors of the EPS molding industry, 

including the thick-walled shape and block molders. It was understood, however, that the utility 

of this alternative compliance for shape and block molders would be limited because these 

operations produce products having higher residual pentane content in the manufactured product 

than molded EPS cups, due to lower pentane diffusion rates through thicker wall structures, and 

product is manufactured at variable density, depending on its final application. 

One block molding firm proposes to demonstrate equivalent emission collection and control of 

the manufacturing and storage emissions by over-controlling the manufacturing emissions, in 

lieu of controlling their less cost-effective EPS block storage areas, and they formally requested 

the AQMD to amend the rule to provide an equivalent compliance alternative. Staff has worked 

with the manufacturer to ensure the testing protocols and procedures are adequate and meet 

AQMD standards. A rule amendment is proposed to allow demonstration of equivalent 

collection and control of manufacturing and storage VOC emissions. 

PROCESS DESCRIPTION AND CONTROLS 

EPS Molding Operations 

Vendors of EPS bead supply 1,000 pound or more corrugated cartons or bulk fabric meshed bags 

(called gaylords) of pentane impregnated polystyrene beads at various pentane contents 

(typically 3.6 - 6.2 percent by weight). Pentane is the only available blowing agent for 

expandable polystyrene beads. Pentane initially releases when the containers are opened due to 

VOC saturated headspace within the gaylords. The bulk beads are usually top-loaded into feed 

hoppers that supply raw EPS beads to a pre-expander at a fixed rate. Steam, supplied from a 

boiler liberates pentane from the beads and expands the less than 1 millimeter diameter beads to 

pre-established densities depending on initial pentane content, residence time, and 

temperature/pressure profiles applied during pre-expansion. Pre-expansion pentane gas is either 

directly thermally destructed or it can be routed to a large aging room for subsequent thermal 

destruction. The expanded bead is called "prepuff". Fresh prepuff has a lower pentane content 

than unexpanded resin and will have higher moisture content because of steam condensation 

occurring during pre-expansion. As a result, the prepuff is either pneumatically conveyed to a 

fluidized bed dryer and then to the aging room, or it may be sent to the aging room directly. 

Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 
Preliminary Draft Staff Report for Proposed Amended Rule 11 75 

Prepuff storage or aging accomplishes three primary tasks': 

Permits surface pentane to disperse, making the pre-puff less heat-sensitive during molding; 

and 

Allows moisture to evaporate, producing a dryer prepuff; and 

Provides time for air penetration into the prepuff cells, displacing the vacuum created during 

pre-expansion, and firther stabilizes the prepuff. 

There are two primary types of prepuff aging vessels: woven cloth or mesh bags and metal silos. 

Aging times vary but are typically between 3 and 24 hours. Higher initial pentane contents of 

the raw bead generally increase the aging time. The prepuff is now ready for pneumatic 

transport to the block molder or shape molder where steam infises into the process and forms the 

prepuff into the desired shape or block under a vacuum. It should be noted that at the time Rule 

1 175 was originally adopted, low vacuum or compression molding was the norm. This has now 

been replaced by batch high vacuum molders. 

Block and shape molders in the AQMD vent aging room pentane laden air to a boiler, direct 

thermal oxidizer, catalytic oxidizer or a regenerative thermal oxidizer (RTO) for thermal 

destruction of the VOC. Since pentane is approximately 2.5 times heavier than air, it is extracted 

via vents and ductwork at or near floor level throughout the aging room. Other points of the 

process such as pre-expansion of the bead as well as molding operations are also vented to the 

thermal destruction device. 

After molding, EPS products are now ready to be stacked and stored to further age the product 

prior to shipment, or hot wire cutting into insulation board and architectural trim. Rejected 

materials are re-ground and either reintroduced with fi-esh prepuff, or can be molded into scrap 

blocks for resale. Regrinding liberates all residual pentane in the product. 

EPS process emissions occur as figitive emissions in several stages of manufacturing and post 

manufacturing. The first occurs fi-om opening of the gaylord and charging them to the feed 

hoppers, followed by VOC emissions releases at the point of pre-expansion, fluidized bed 

drying, prepuff aging, molding, unloading and storage of the molded product, and cutting and 

regrinding of any recycled material. 

The rate by which pentane is released is significantly higher during the manufacturing phase of 

the process, compared to product storage phase. As a result, most of the facility-wide pentane 

emissions occur during manufacturing phase of the process. While the rate of emissions slows 

down considerably during the post manufacturing phase, emissions that occur during product 

storage can be significant, especially for large throughput facilities. Because manufacturing 

emissions are more concentrated, their control is much more cost-effective, compared to the 

control of figitive storage emissions. During rule development, post-manufacturing emissions 

occurring during the first 48 hours of storage were determined to be significant and that could be 

cost-effectively controlled. 

I Expandable Polystyrene Storage and Handling Safety Guide, 2002 Nova Chemicals Corporation 

~inal Staff Report with Appendices 

3 for Revised Proposed Amendments to Rule 4682 
Preliminaly Draft Staff Report for Proposed Amended Rule 11 75. 

The emission reduction benefit of controlling fugitive pentane emissions that occur during the 

first 48 hours of product storage, was factored into the derivation of the 2.4 pounds of VOC per 

100 pounds of raw bead alternative requirement, and incorporated into Rule 1175(c)(2). The 

figure was derived assuming the process started with a raw bead containing 6 percent pentane, 

which is reduced to 1.8 percent at the end of 48 hour storage and overall emissions are controlled 

by 85.5 percent. The 2.4 lbs VOC per 100 lbs of raw material requirement of Rule 1175 (c)(2) 

was requested by industry and was included in Rule 1175 as an alternative to controlling both 

manufacturing and product storage emissions at a minimum of 90 percent capture and 95 percent 

destruction efficiencies. 

One EPS block molder has proposed a second alternative to the capture and control of both 

manufacturing and storage emissions by over-controlling manufacturing emissions and not 

controlling storage emissions. The company has successfully completed its testing program to 

make this demonstration, and has received conditional approval of its source test at this time. A 

summary of that testing program, as well as an example of theoretical compliance is included as 

Appendix A. 

STAFF PROPOSAL 

Staff proposes to amend Rule 1 175 as follows: 

0. Add an alternative that allows EPS block manufacturers to demonstrate equivalence to 

the collection and control requirement by demonstrating over-control of the 

manufacturing emissions by at least 93 percent, and using at least 60 percent low-pentane 

bead, with the remainder being mid-pentane bead on an annual basis. 

Reinforce that storage emission capture efficiency is defined to be at least 90 percent by 

weight by adding to the definition of an approved control system this minimum 

efficiency in subparagraph (b)(l)(B). 

Add a definition for low-pentane bead to mean those beads that contain less than 4.0 

percent by weight pentane as a blowing agent (as an upper limit), prior to'shipment, as 

certified by an accompanying bead lot manufacturer's Certificate of Analysis. 

Add a definition for mid-pentane bead to mean those beads that contain less than 5.2 

percent by weight pentane as a blowing agent (as an upper limit), prior to shipment, as 

certified by an accompanying bead lot manufacturer's Certificate of Analysis. 

Add a definition for Certificate of Analysis as a written document supplied by the 

manufacturer of bead lots that lists a range of pentane contents, expressed as a percentage 

by weight, prior to shipment. 

Modify the definition of EXEMPT COMPOUNDS by referring to Rule 102 - Definition 

. ofTerms 

Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 
Preliminary Draft Staff Report for Proposed Amended Rule 11 75 

Add a definition for STORAGE EMISSIONS, for rule clarity to mean emissions of VOC, 

CFC, or methylene chloride occurring for a maximum of 48 hours after the polymeric 

cellular product is manufactured. 

Modify the definition of VOLATILE ORGANIC COMPOUND (VOC) by referring to 

Rule 102 - Definition of Terms 

Revise references to rule nomenclature to indicate the correct reference to paragraphs, 

and subparagraphs. 

Clarify emissions control requirement subparagraph (c)(4)(b) to refer back to the 

definition of an approved emissions control system in subparagraphs (b)(l)A), (b)(l)(B) 

or (b)(l)(C), depending on applicability. 

Change the title of subdivision (f) to Methods of Analysis and add an introductory 

paragraph referring and to the appropriate federal, state and local agencies. Add the EPA 

approved capture efficiency test procedures presented in the U.S. EPA technical guidance 

document "Guidelines for Determining Capture Efficiency, January 9, 1995" in 

subparagraph (f)((3)(A). Notwithstanding the test methods specified by the Guidelines, 

any other method approved by the U.S. EPA, CARB, and the SCAQMD Executive 

Officer may be substituted. 

Add Method 25.3 (Determination of Low Concentration of Non-Methane Non-Ethane 

Organic Compound Emissions from Clean Fueled Combustion Sources) so that a control 

device seeing low input or output VOC ppms can be tested accordingly. 

Add other language amendments for clarity and consistency. 

EMISSIONS INVENTORY AND POTENTIAL EMISSION REDUCTIONS 

Table 1 below represents the VOC emissions from all known EPS and XPS foam fabricators in 

the basin, as taken from the emissions annual emissions reporting years of 2000 through 2004. 

In addition, although VOC emissions were reported for blown polyurethane foam, staff has not 

included them because the chemical reaction is swift and should not produce any VOC 

emissions, except for molecules only of unreacted isocyanate, the catalyst used for forming rigid 

and flexible urethane foam products. 

It should be noted that some of the EPS foam block manufacturers listed have since ceased 

molding operations in the AQMD. 

Final Staff Report with Appendices 

for ~evised Proposed Amendments to Rule 4682 
Preliminary Draft Staff Report for Proposed Amended Rule 11 75 

Table 1 

Foam Fabricators 2000 - 2004 Reported Annual Emissions (Tons per Year) 

The proposed amendment should result in no change in emissions since they only offer the 

opportunity for demonstrating equivalent emission collection and control or clarify the existing 

rule. 

COMPANY NAME 

DART CONTA~NER 

PREMIER INDUSTRIES 

PACTIV 

FREE FLOW PACKAGING 

LIFE-LIKE PRODUCTS 

STOROPACK/FOAM PAC 

COST, COST EFFECTIVENSS, AND INCREMENTAL COST EFFECTIVENESS 

The proposed amendments should not result in additional costs to industry. Since there is no 

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

Safety Code Section 40920.6 requires an incremental cost effectiveness analysis when there is 

more than one control option to achieve the emission reduction objective of the proposed 

amendments, relative to ozone formation, CO, SOX, NOx, emissions and their precursors. Since 

the proposed amendment offers only a voluntary option for demonstrating equivalent control of 

pentane emissions occurring during the manufacturing of EPS block product, and does not have 

an emission reduction objective, the Health and Safety Code Section 40920.6 analysis is not 

required. 

FOAM TYPE 

PRODUCED 

EPS CUPS/BOWLS 

AND XPS 

THERMOFORMED 

ppp 

SHEET PRODUCTS 

EPS BLOCK 

XPS 

THERMOFORMED 

SHEET PRODUCTS 

XPS PACKAGING 

MATERIALS 

EPS SHAPES 

EPS PACKAGING 

MATERIALS 

~inal'staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 

STOROPACK INC. EPS PACKAGING 

MATERIALS 

2000 

135.122 

81.189 

41.999 

42.713 

25.134 

28.752 

FALCON FOAM 

ADVANCE FOAM 

FOAM FABRICATORS 

TOPPER PLASTICS 

ELMIDOLCO PACKAGING 

2001 

181.66 

102.566 

39.216 

38.668 

19.62 

9.906 

EPS BLOCK 

EPS BLOCK 

EPS SHAPES 

EPS SHAPES 

XPS 

THERMOFORMED 

SHEET PRODUCTS 

TOTAL (TPY) 

TOTAL (TPD) 

2002 

195.408 

ppppp 

49.586 

7.989 

14.878 

5.084 

2.914 

456.010 

1.25 

2003 

196.975 

19.045 

8.727 

10.845 

6.145 

3.635 

2004 

205.426 

113.404 

40.539 

3 1.972 

30.754 

9.830 

445.233 

1.22 

20.707 

14.062 

10.127 

1.287 

2.546 

110.078 

36.874 

29.076 

55.342 

11.607 

475.199 

1.30 

113.41 

47.323 

24.533 

54.665 

11.826 

23.801 

15.473 

26.100 

1 .oo 1 

0.001 

21.873 

10.387 

27.601 

0.936 

0.001 

510.359 

1.40 

522.766 

1.43 
Preliminary Draft StaffReport for Proposed Amended Rule 11 75 

CALIFORNIA ENVIRONMENTAL QUALITY ACT 

Pursuant to State California Environmental Quality Act (CEQA) Guidelines and the AQMD's 

Certified Regulatory Program (Rule 1 lo), the appropriate CEQA documentation will be prepared 

to analyze any potential adverse environmental impacts associated with PAR 1175. Upon 

completion, the CEQA document will be released for public review and comment, and will be 

available at AQMD Headquarters, by calling the AQMD Public Information Center at (909) 396- 

3600, or by accessing AQMD's CEQA website at: http://www.aqmd.g;ov/ceqa/aqrnd.htn~1, upon 

release. 

SOCIOECONOMIC IMPACT ANALYSIS 

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 Section 40440.8 is not required. 

LEGISLATIVE AUTHORITY 

The California Legislature created the AQMD in 1977 (The Lewis-Presley Air Quality 

Management Act, Health and Safety Code Section 40400 et seq.) as the agency responsible for 

developing and enforcing air pollution control rules and regulations in the Basin. By statute, the 

AQMD is required to adopt an Air Quality Management Plan (AQMP) demonstrating 

compliance with all state and federal ambient air quality standards for the Basin [California 

Health and Safety Code Section 40460(a)]. Furthermore, the AQMD must adopt rules and 

regulations that carry out the AQNIP [California Health and Safety Code Section 40440(a)]. 

DRAFT FINDINGS 

Before adopting, amending, or repealing a rule, the California Health and Safety Code Section 

40727 requires the AQNID to adopt written findings of necessity, authority, clarity, consistency, 

non-duplication, and reference based on relevant information presented at the public hearing and 

in the staff report. 

Necessity - The AQMD Governing Board has determined that a need exists to amend Rule 1 175 

- Control of Emissions from the Manufacture of Polymeric Cellular (Foam) Products, to allow 

for other equivalent control options through increased overall efficiency of pentane emissions 

generated through the manufacturing of block expanded polystyrene. 

Authority - The AQMD Governing Board obtains its authority to adopt, amend, or repeal rules 

and regulations from the California Health and Safety Code Sections 39002, 39650, 40000, 

4000 1,40440,40702,4 1508, and 4 1700, et seq. 

Clarity - The AQMD Governing Board has determined that the proposed amendment to Rule 

1 175 is written or displayed so that its meaning can be easily understood by the persons directly 

affected by it. 

Consistency - The AQNID Governing Board has determined that Proposed Amended Rule 11 75 

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

federal or state regulations. 

Final Staff Report with Appendices 

7. for Revised Proposed Amendments to Rule 4682 
Preliminary Draft Staff Report for Proposed Amended Rule 11 75 

Non-Duplication Rule 1175 does not impose the same requirements as any existing state or 

federal regulations, and the proposed amended rule is necessary and proper to execute the 

powers and duties granted to, and imposed upon, the AQNID. 

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 40440(a) (rules to carry out the Air Quality Management Plan), and 

40440(c) (cost-effectiveness), 4 1508, 4 1700 (nuisance), and Federal Clean Air Act Section 

172(c)(l) (RACT). 

AQMP AND LEGAL MANDATES 

The California Health and Safety Code requires the AQMD to adopt an Air Quality Management 

Plan (AQMP) to meet state and federal ambient air quality standards with the South Coast Air 

Basin. In addition, California Health and Safety Code requires the AQMD to adopt rules and 

regulations that carry out the objectives of the AQMP. Although the goal of Control Measure 

PRC-07 of the 2003 AQMP is to further control VOC emissions from industrial processes and 

could apply to Rule 1175, the proposed amendments do not result in additional emission 

reductions; however the amendments are consistent with AQMP objectives. 

This proposal does not impose a new emission limit or standard, make an existing emission limit 

or standard more stringent or impose new or more stringent monitoring, reporting or 

'recordkeeping requirements and therefore is not subject to the comparative analysis provisions of 

California Health and Safety Code Section 40727.2. 

DRAFT CONCLUSIONS AND RECOMENDATIONS 

Demonstration of equivalent emissions to those required by Rule 1175(c)(4) for EPS block 

manufacturing is possible through over-control of the manufacturing emissions, without 

controlling residual pentane losses of storage emissions through the first 48 hours of block 

storage. Staff recommends a rule amendment to include an option to controlling both 

manufacturing and storage emissions to the extent specified in Rule 1175(c)(4)(B)(i) and (ii) 

provided the manufacturing emissions are controlled by demonstrating an overall efficiency of at 

least 93 percent and low pentane beads are used at least 60 percent of the time on an annual 

basis, with the remainder being mid-pentane. 

Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 
Preliminary Draft Staff Report for Proposed Amended Rule 11 75 

APPENDIX A: EPS BLOCK TESTING PROGRAM AND EXAMPLE COMPLIANCE 

DEMONSTRATION 

An EPS block maker conducted independent tests to quantify residual pentane emissions fi-om 

molded polystyrene block storage (phase 1) as well as quantifying its manufacturing operation 

emissions (phase 2). Both types of tests underwent substantial protocol scrutiny by the AQMD 

and U.S. EPA, and were approved by the AQMD,. The following summarizes the testing 

program. 

In phase 1, a variable temperature sealed SHED chamber test directly measured pentane 

emissions over 48 hours of storage. Several billets of molded polystyrene foam of different 

product densities and raw bead pentane content were manufactured and placed in the SHED 

within one hour of molding. Small volumes of air were extracted at 10 minute intervals and 

analyzed for total hydrocarbons by a flame ionization detector in accordance with EPA Method 

25A and recorded. Previous to block transport, samples of raw bead type and molded block 

polystyrene material were taken and placed in sealed vials for independent analysis of pentane 

content according to Method 306-91 - Analysis of Pentanes in Expandable Styrene Polymers. 

The testing occurred over a nine month period from November 2005, though July 2006 due to 

the scheduling necessary to accommodate 13 individual 48-hour runs in total. 

Phase 2 testing was conducted on August 17 and 18, 2006, to determine the capture and control 

efficiencies of the EPS manufacturing operation. Twelve hours prior to the test, all bags in the 

bag farm were empty, and a predetermined quantity of beads were expanded and aged for 12 

hours so that molding could begin for the 12 hour test the following day. Once testing began, the 

manufacturing line began simultaneously expanding, aging, and molding. As aged bead was 

molded out, fresh prepuff was being filled to aging bags to replace that which was being molded. 

At the end of the test, the same quantity of bead existed in the bag farm, as started with, and 

subject to the same set of aging coiditions, thus completing the cycle. 

The following lists the methods used and approved by the AQMD during the manufacturing 

emissions test. 

> Sampling and analysis of VOCs as pentane was conducted using EPA Method 25A. 

P Flow, measurements by SCAQMD Methods 1.1-2.1. 

P SCAQMD Method 25.1 and 25.3 were conducted simultaneously at the inlet and 

exhaust. 

> Method 2.1 measurements used during periods of instrument calibrations. 

Continuous flow measurements taken using a reference, point and electronic 

temperature and magnahelic readouts logged to a data system. 

> A pentane standard was used on each hydrocarbon analyzer to determine an 

instrument-specific response factor. VOC inlet and outlet emissions were reported 

referenced to this standard. 

> SCAQMD Method 306-91 (Analysis of Pentanes in Expandable Styrene Polymers) 

was used to determine pentane contained in the raw material and in the freshly 

Final Staff Report with Appendices 

9 for Revised Proposed Amendments to Rule 4682 
Preliminary Drafi Staff Report for Proposed Amended Rule 11 75 

molded billets. The total amount of pentane in the molded billet and the amount of 

pentane in the total raw bead used during the cycle were used to calculate the amount 

of pentane available for capture. 

> The RTO combustion chamber temperature was continuously recorded, using the 

circular chart recorder installed on the unit. 

> Differential pressure across the bagfarm containment, as measured by a permanently 

installed very-low pressure transmitter, was logged hourly. 

> Data is integrated over the length of the test to present final collection and capture 

efficiencies. 

To date these tests have been conducted and the results are complete and conditionally approved 

by AQMD Source Testing personnel. Knowing both the fugitive storage emissions fiom the 

SHED test and the overall abatement system efficiency, a comparison of the current Rule 1175 

requirement to control both manufacturing and fugitive storage emissions through the first 48 

hours after molding by capturing 90 percent of fugitive storage emissions and destroying them 

by 95 percent (85.5 percent overall) can be made with the tested manufacturing abatement 

efficiency. 

Table 2 is an example of an equivalence demonstration in theory. The example demonstration is 

tabulated as pounds of VOC emitted per pound of product because there is no approved method 

for determining water moisture content in either the billet or the bead. Without knowing water 

content, the results cannot be expressed in terms of pounds of VOC per pound of raw bead. 

Table A- 1 is a mathematical demonstration only. See following page. 

Final Staff Report with Appendices 

10 for Revised Proposed Amendments to Rule 4682 
Preliminaiy Draft Staff Report for Proposed Amended Rule 11 75 

Table A-1: Theoretical Compliance Demonstration 

Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 

Bead Type 

Billet Density 

Measured Fresh Bead 

VOC (Method 306) 

Measured Fresh Block 

VOC (Method 306) 

Measured 48-Hour 

Shed Losses Per 16' 

Billet (Uncontrolled 

Storage Emissions) 

Measured Starting 

Billet Wt 

lb VOC in Billet 

lb Polystyrene in Billet 

Percent Polystyrene in 

Bead Minus Water (lb 

PS/lb Bead) 

Ib Raw Bead to Make 

Billet Minus Water 

Uncontrolled Mfg VOC 

Emissions (lb VOC at 

raw bead content) 

Mfg Emissions If 

Controlled at 85.5% 

Overall (lb VOCIlb Raw 

Bead to Make Billet) 

Actual Mfg Emissions 

Controlled at 93% 

Overall (Ib VOC/lb Raw 

Bead to Make Billet) 

Storage Emissions if 

Controlled at 85.5% 

Overall (lb VOC/Billet) 

Allowable Emissions 

(85.5% Controlled Mfg 

+ 85.5% Controlled 

Storage) lb 

VOC/Overall Process 

Actual Overall 

Emissions (93% 

Controlled Mfg + 

Uncontrolled Storage) 

Ib VOC/Overall Process 

% Under Rule 1 175 

(c)(4) 

1.00 

3.47% 

1.58% 

0.158 

205.2 

3.24 

201.96 

96.53% 

209 

3.95 

0.57 

0.277 

0.023 

0.60 

0.43 

-27.1% 

High 

Pentane 

1.00 

6.17% 

2.95% 

0.088 

198.0 

5.84 

192.16 

93.83% 

205 

6.59 

0.96 

0.462 

0.013 

0.97 

0.55 

-43.3% 

Low 

1.25 

3.50% 

1.75% 

0.144 

272.1 

4.76 

267.38 

96.50% 

277 

4.85 

0.70 

0.339 

0.021 

0.72 

0.48 

-33.2% 

1.00 

4.42% 

2.92% 

0.269 

200.8 

'5.86 

194.94 

95.58% 

204 

3.06 

0.44 

0.214 

0.039 

0.4826 

0.4828 

0.1% 

Pentane 

1.50 

3.50% 

1.87% 

0.225 

305.4 

5.71 

299.69 

96.50% 

31 1 

5.06 

0.73 

0.354 

0.033 

0.77 

0.58 

-24.5% 

Mid 

1.25 

4.65% 

2.89% 

0.267 

242.9 

7.02 

235.88 

95.36% 

247 

4.34 

0.63 

0.304 

0.039 

0.67 

0.57 

-14.6% 

2.00 

3.47% 

1.64% 

0.260 

396.0 

6.49 

389.51 

96.53% 

404 

7.38 

1.07 

0.517 

0.038 

1.1 1 

0.78 

-29.9% 

Pentane 

1.50 

4.96% 

2.52% 

0.306 

314.0 

7.91 

306.09 

95.04% 

322 

7.86 

1.14 

0.550 

0.044 

1.18 

0.86 

-27.7% 

2.00 

4.30% 

2.51% 

0.286 

404.2 

10.15 

394.05 

95.70% 

412 

7.37 

1.07 

0.516 

0.041 

1.11 

0.80 

-27.8% 
SAN JOAQUIN VALLEY UNIFIED AIR POLLU'I'ION CONTROL DISTRICT 

Appendix F: Supplemental Information September 20, 2007 

This page intentionally blank 

F-22 Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682