### SANJOAQlllN VALLEY UNIFIEDAIR POLLU'TION CONTROL DISTRICT Appendix F: 

### Supplemental Information September20, 2007



# APPENDIX F Supplemental lnformationfor Revised ProposedAmendmentsto Rule 4682 (Polystyrene Foam, Polyethylene, and Polypropylene Manufacturing) September 20,2007

Final Staff Report withAppendices for RevisedProposedAmendments to Rule 4682(Adopted November 3, 1989)(AmendedJanuary 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 includingbut not limited to expandable polystyrene, polystyrene foam extrusion, polyurethane, isocyanurate and phenolic foam operations. All steps of the manufacturingoljeration and the storage of the final product for amaximum of 48 hours are subjectto 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 systemmust be operated subjectto the following provisions: (A) The emission collection system shall collect at least a 90 percent by weight ofthe manufacturing emissions; and 

### (B) The control device shall reduce emissions from the emission collection systemby at least 95 percent, by weight. (2) BLOWING AGENT means a liquid, gaseous or solid material that facilitates the formationof a cellular product from raw polymeric material. (3) CHLOROFLUOROCARBON (CFC) is any chlorinated fluorinated compoundofcarbon, 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) EXEMPTCOMPOUNDS are any ofthe 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 Rule4682Rule 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- 141 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- 11) 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 expandedby exposureto 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 Reportwith Appendices For Revised Proposed 1175-2 Amendmentsto Rule 4682Rule 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 manufactureofpolymeric cellularproducts. (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 calendaryear 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 100lbs ofraw material processed. (3) The owner or operator of any polymeric cellular manufacturing operation, subject to the requirementsof 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 Reportwith Appendices For Revised Proposed 1175-3 Amendmentsto Rule4682Rule 1175(Cont.) (Amended

### May 13,1994) (A) Submit permit applications for the installation of an emission control system within four months of the datethat compliance with suchrequirement 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 systemfor at least: (I) 48 hours, in the case of expandable polystyrene molding operations that process more than 800,000 poundsper calendaryear of raw material; or (11) 24.hours, in the case of all other manufacturing operations. (d) Exemptions (1) Theprovisions of paragraph (c) shall not apply to any: (A) Expandable polystyrene operation that processes less tha. 200 pounds per day ofraw material. (B) Rigid polyurethane operation that processes less than 1,000pounds per day ofraw 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, includingbut not Final Staff Report with Appendices For Revised Proposed 1175

## - 4 Amendmentsto Rule 4682Rule 1175(Cont.) (Amended 

### May 13,1994)
limited to the amount of raw material processed, the equipmentused, 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 complyingwith 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 ofVOC Content The VOC content of materials subject to the provisions of this rule shall be determined by the followingmethods: (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 (DeterminationofExempt 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 fluorinatedalkanes; cyclic, branched, or linear, completely fluorinated ethers with no unsaturations; cyclic, branched, or linear, completely fluorinated tertiary arnineswith no unsaturations; and
Final Staff Report with Appendices For Revised Proposed 1175-5 Amendments to Rule4682Rule 1175

### (Cont.) (Amended 

### May 13,1994) sulfbr-containing perfluorocarbons with no unsaturations and with sulfurbonds 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 amountof each exempt compound. (2) DeterminationofPentanes 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 ofAnalysis 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 ofthe controldevice ofthe 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 establishedby any one of the specified test methods or set of test methods shall constitute a violation of the rule.

Final Staff Reportwith Appendices For Revised Proposed Amendments to Rule4682

### SOUTH COASTAIR QUALITY MANAGEMENTDISTRICT

PRELIMINARY DRAFT STAFF REPORTFOR PROPOSED AMENDED RULE 1175 -

### CONTROL OFEMISSIONS FROM THEMANUFACTURE OF POLYMERIC CELLULAR (FOAM) PRODUCTS June 2007 

### Deputy Executive Officer Planning, Rule Development, andArea Sources Elaine Chang, DrPH 

### Assistant Deputy Executive Officer Planning, Rule Development, andArea 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. -

### SeniorAir Quality Engineer Hubert Wilson -

### Air Quality Analysis and Compliance Supervisor Reviewed By: Edward 

### M. Muehlbacher, P.E. - 

### Program Supervisor Jeri Voge - 

### SeniorDeputy District Counsel

Final Staff ReportwithAppendices for Revised ProposedAmendments to Rule4682SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT GOVERNINGBOARD Chairman: WILLIAM A. BURKE, Ed.D. Speaker ofthe 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 ofRiverside 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 ofLong Beach Cities Representative, Los Angeles County, Eastern Region VACANT Governor's Appointee DENNIS YATES Councilmember, City of Chino Cities Representative, Cities of SanBernardino County EXECUTIVE OFFICER BARRY R. WALLERSTEIN, D.Env.

FinalStaff Report with Appendices for Revised Proposed Amendments, to Rule 4682TABLE OF CONTENTS EXECUTIVE S UMMAR

### Y.

# ............................................................................................................ 1 BACKGRO UND

# ............................................................................................................................. 1 PROCESSDESCRIPTIONAND CONTROLS

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

# ........................................................................................................................ 2 STAFFPROPOSAL

# ......................................................................................................................4 EMISSIONS INVENTORY AND POTENTIAL EMISSIONREDUCTIONS 

# .......................... 5 COST. COSTEFFECTIVENSS. AND INCREMENTAL COSTEFFECTI VENESS

# .............. 6 CALIFORNIA ENVIRONMENTAL QUALITY ACT

# ................................................................. 7



# .................................................................................. SOCIOECONOMIC IMPACTANALYSIS 7



# ...................................................................................................... LEGISLATIVEAUTHORITY 7



# ....................................................................................................................... DRAFT FINDINGS 7 AQMP AND LEGAL MANDATES 

# ........................................................................................... 8



# .............................................................. DRAFT CONCLUSIONSAND RECOMENDA TIONS 

### 8 APPENDIXA: EPS BLOCK TESTINGPROGRAMAND EXAMPLE COMPLIANCE



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

Final Staff Reportwith Appendices for Revised Proposed Amendments to Rule4682Preliminary Draft StaffReport for ProposedAmendedRule 

### 1175
EXECUTIVE SUMMARY Proposed Amended Rule 1175 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 thebeads 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 Reportwith Appendices for Revised ProposedAmendmentsto Rule 4682

### PreliminaryDraft StaffReportfor ProposedAmended Rule 

### 1175 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. Staffhas 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 ormore 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 1millimeter 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 fluidizedbed dryer and then to the aging room, or it may be sent to the agingroom directly.

Final Staff ReportwithAppendices for Revised Proposed Amendments to Rule 4682

### PreliminaryDraft StaffReport for Proposed Amended Rule 11

### 75 Prepuff storage or aging accomplishes threeprimary tasks': Permits surface pentane to disperse, making the pre-puff less heat-sensitive during molding; and Allows moisture to evaporate, producing a dryerprepuff; 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 ofprepuff 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 1175 was originally adopted, low vacuum or compression molding was the norm. This has now been replaced bybatch 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 ofthe 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 aspre-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-eshprepuff, or can be molded into scrap blocks for resale. Regrinding liberates allresidual 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 Amendmentsto Rule4682PreliminalyDraft 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 of48 hour storage and overall emissions are controlled by 85.5 percent. The 2.4 lbs VOC per 100lbs 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 90percent 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 1175 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, andusing 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 ofAnalysis. 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 arange ofpentane 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 ReportwithAppendices for Revised Proposed Amendments to Rule 4682Preliminary Draft StaffReport for Proposed Amended Rule 11

### 75 Add a definition for STORAGE EMISSIONS, for rule clarity to mean emissionsofVOC, 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 1below 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 ofunreacted isocyanate, the catalystused for formingrigid and flexible urethane foamproducts. 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 4682Preliminary Draft StaffReport 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/FOAMPAC

COST, COST EFFECTIVENSS, 

### AND INCREMENTAL COSTEFFECTIVENESS 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 SHEET PRODUCTS

ppp EPS BLOCK XPS THERMOFORMED SHEET PRODUCTS XPS PACKAGING MATERIALS EPS SHAPES EPS PACKAGING MATERIALS

~inal'staff ReportwithAppendices 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 SHEETPRODUCTS 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.oo1 0.001 21.873 10.387 27.601

0.936 0.001 510.359 1.40 522.766 1.43Preliminary Draft StaffReport for Proposed Amended Rule 

### 1175 

### CALIFORNIA ENVIRONMENTAL QUALITYACT Pursuant to State California Environmental Quality Act (CEQA) Guidelines and the AQMD's Certified Regulatory Program (Rule 1lo), 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 Section40440(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 ofnecessity, authority, clarity, consistency, non-duplication, and reference based on relevant information presented atthe public hearing and in the staffreport. 

### 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 allow for other equivalent control options through increased overall efficiency of pentane emissions generated through the manufacturing ofblock 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 1,40440,40702,41508, and 41700, et seq. 

### Clarity 

### - The AQMD Governing Board has determined that the proposed amendment to Rule 1175is written or displayed so that its meaning can be easily understood by the persons directly affected byit. 

### 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 stateregulations.

Final Staff Reportwith Appendices 7. for Revised Proposed Amendmentsto Rule4682PreliminaryDraft Staff Report for ProposedAmended 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), 41508, 41700 (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 orstandard, make an existing emission limit or standard more stringent or impose new or more stringent monitoring, reporting or 'recordkeepingrequirements and therefore is not subject to the comparative analysisprovisions 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 efficiencyof 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.

FinalStaff Reportwith Appendices for Revised Proposed Amendments to Rule4682PreliminaryDraft 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 12hour 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 ofVOCs as pentane was conducted using EPA Method 25A. 

### P Flow, measurements by SCAQMDMethods 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 4682Preliminary Drafi StaffReport for ProposedAmended Rule 1175 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 ofpentane 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 Amendmentsto Rule4682Preliminaiy Draft StaffReport for ProposedAmended Rule 1175 TableA-1: Theoretical ComplianceDemonstration

Final Staff Reportwith 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 Polystyrenein Billet Percent Polystyrenein Bead Minus Water (lb PS/lb Bead) Ib Raw Bead to Make

BilletMinus Water UncontrolledMfg VOC Emissions (lb VOC at

raw bead content) Mfg EmissionsIf 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 Emissionsif Controlled at 85.5% Overall (lb VOC/Billet)

Allowable Emissions (85.5% ControlledMfg



### + 85.5% Controlled Storage)lb VOC/Overall Process Actual Overall Emissions (93% ControlledMfg + Uncontrolled Storage) Ib VOC/OverallProcess

%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 JOAQUINVALLEY UNIFIEDAIR POLLU'I'ION CONTROL DISTRICT Appendix F: 

### Supplemental Information September20, 

### 2007



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F-22 Final StaffReport with Appendices for Revised Proposed Amendments to Rule 4682