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Adopted September 10, 2008 Reg. II, Rule 2.41, Page 1

RULE 2.41 EXPANDABLE POLYSTYRENE MANUFACTURING OPERATIONS

Adopted September 10, 2008

INDEX

100 GENERAL

101 PURPOSE

102 APPLICABILITY

110 EXEMPTION - Non-VOC Blowing Agent

200 DEFINITIONS

201 BLOWING AGENT

202 CERTIFICATE OF ANALYSIS (COA)

203 EMISSION CONTROL SYSTEM

204 EXPANDABLE POLYSTYRENE (EPS)

205 EPS PRODUCTS

206 EPS MANUFACTURING EMISSIONS

207 EPS MANUFACTURING OPERATION

208 LOW PENTANE BEAD

209 MID PENTANE BEAD

210 NON-VOC BLOWING AGENT

211 POLYMERIC MATERIAL

212 VOLATILE ORGANIC COMPOUND (VOC)

300 STANDARDS

301 EMISSION CONTROLS

302 RAW MATERIAL USAGE

303 SOURCE TESTING

304 VIOLATIONS

400 ADMINISTRATIVE REQUIREMENTS

401 COMPLIANCE SCHEDULE

402 EMISSION CONTROL SYSTEM OPERATION AND MAINTENANCE

(O&M) PLANS

500 REPORTING AND RECORD KEEPING

501 REPORTING

502 RECORD KEEPING

600 TEST METHODS AND CALCULATIONS

601 GENERAL

602 FLOW

603 VOC LEAKS

604 CONTROL EFFICIENCY

605 PENTANE CONTENT

606 MOISTURE CONTENT

607 CAPTURE EFFICIENCY
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100 GENERAL

101 PURPOSE: The purpose of this rule is to limit the

emissions of volatile organic compounds (VOCs) from the

manufacturing of expanded polystyrene (EPS) products.

102 APPLICABILITY: The provisions of this rule are applicable

to any facility which manufactures EPS products.

110 EXEMPTION - Non-VOC Blowing Agent: The provisions of this

rule shall not apply to any EPS manufacturing operation

which uses only non-VOC blowing agents.

200 DEFINITIONS

201 BLOWING AGENT: Any liquid, gaseous, or solid material

that facilitates the formation of a cellular product from

raw polymeric material.

202 CERTIFICATE OF ANALYSIS (COA): A written document,

originated by the EPS bead manufacturer, which cites the

blowing agent content (expressed as percentage by weight)

of the EPS bead in a specific manufactured bead lot prior

to shipment from the manufacturer.

203 EMISSION CONTROL SYSTEM: A system for reducing

manufacturing emissions, which consists of a capture

system and a control device.

204 EXPANDABLE POLYSTYRENE (EPS): A lightweight closed-cell

foam which is manufactured in a range of densities.

205 EPS PRODUCTS: Foam products which are manufactured from

a series of processes where raw polymeric materials

containing a blowing agent, such as beads, are expanded

by exposure to steam or other expansion agent and

subsequently molded into final product, such as blocks.

206 EPS MANUFACTURING EMISSIONS: Any VOC emissions which

occur during an EPS manufacturing operation, prior to

capture and control.

207 EPS MANUFACTURING OPERATION: Any EPS production line, or

portion of a production line, which processes raw EPS

bead into final EPS product and which results in VOC

emissions into the atmosphere. Production line processes
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include, but are not limited to: pre-expansion, aging

(pre-puff), and molding. The manufacturing process ends

after the EPS product exits the mold.

208 LOW PENTANE BEAD: An expandable polystyrene bead

containing pentane as a blowing agent with an upper limit

less than 4.0 percent by weight, prior to shipment, as

certified upon delivery by an accompanying bead

manufacturer’s COA.

209 MID PENTANE BEAD: An expandable polystyrene bead

containing pentane as a blowing agent within the range of

4.0 to 5.2 percent by weight, prior to shipment, as

certified upon delivery with an accompanying bead

manufacturer’s COA.

210 NON-VOC BLOWING AGENT: A blowing agent which does not

contain VOCs.

211 POLYMERIC MATERIAL: A multi-molecular compound or mixture

of compounds formed by polymerization and consisting

essentially of repeating structural units.

212 VOLATILE ORGANIC COMPOUND (VOC): As defined in Rule 1.1,

General Provisions and Definitions.

300 STANDARDS

301 EMISSION CONTROLS: All EPS manufacturing emissions shall

be controlled by an emission control system which has a

capture efficiency of at least 90% and a destruction

efficiency of at least 95%. 

302 RAW MATERIAL USAGE: All EPS products shall be

manufactured with either low or mid pentane bead. 

303 SOURCE TESTING: Each EPS manufacturing operation shall

perform a source test to verify compliance with section

301 at least once every 12 calendar months, in accordance

with a District-approved protocol and the test methods

listed in section 600.

304 VIOLATIONS: Failure to comply with any provision of this

rule shall constitute a violation of this rule. The

owner or operator shall be liable for any penalties

assessed in accordance with the California Health and

Safety Code 42400.
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400 ADMINISTRATIVE REQUIREMENTS

401 COMPLIANCE SCHEDULE: Facilities subject to the

requirements of this rule shall demonstrate full

compliance with all provisions by January 1, 2009.

402 EMISSION CONTROL SYSTEM OPERATION AND MAINTENANCE (O&M)

PLANS: The owner/operator shall submit an O&M plan for

the emission control system to the APCO for approval.

The plan shall include procedures for collecting and

recording required data and other information in a form

approved by the APCO. The plan shall also include

procedures and schedules for preventive and corrective

maintenance performed for the purpose of maintaining the

emission control system in proper operating condition.

500 REPORTING AND RECORD KEEPING

501 REPORTING: All records required by this Rule shall be

maintained on site for a period of five years and made

available to the APCO upon request.

502 RECORD KEEPING: Owners and/or operators shall maintain

the following records: 

502.1 EMISSION CONTROL SYSTEM: Daily records of the

operation and maintenance of the emission

control system. These records shall include

key system operating parameters such as

temperatures, pressures, flow rates, and other

measurements to demonstrate ongoing compliance

with section 300.

502.2 RAW MATERIAL USAGE: Daily records of raw EPS

bead processed and the associated blowing

agent content, as specified on the applicable

COA. A copy of each applicable COA shall be

retained.

502.3 FINISHED PRODUCT: Daily records of the amount

of EPS product made, including the approximate

weight and density of each product.

600 TEST METHODS AND CALCULATIONS

601 GENERAL: For the purposes of this Rule, the following
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test methods (or their most recent approved versions) or

calculation methods shall be used, upon review and

approval by the District and EPA. Other test methods

determined to be equivalent and approved in writing by

the District and the EPA may also be used.

602 FLOW: Measurement of air flow and gas flow shall be

conducted and reported in accordance with EPA Reference

Methods 1 and 2, and their subparts.

603 VOC LEAKS: Measurement of VOC leaks shall be conducted

and reported in accordance with EPA Reference Method 21.

604 CONTROL EFFICIENCY: Measurement of VOC concentration for

determining control efficiency shall be conducted and

reported in accordance with EPA Reference Method 25, and

its subparts.

605 PENTANE CONTENT: Measurement of pentane content of

materials shall be conducted and reported in accordance

with SCAQMD Method 306-91.

606 MOISTURE CONTENT: Measurement of moisture content of gas

shall be conducted and reported in accordance with EPA

Reference Method 4.

607 CAPTURE EFFICIENCY: Measurement of capture efficiency

shall be determined by the procedures contained in the

EPA technical guidance document “Guidelines for

Determining Capture Efficiency, January 9, 1995", and EPA

Reference Methods 204 A-F.