SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Rule Consistency Analysis September 20, 2007 

Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 

APPENDIX E 

Rule Consistency Analysis for 

Revised Proposed Amendments to Rule 4682 (Polystyrene Foam, 

Polyethylene, and Polypropylene Manufacturing) 

September 20, 2007 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Rule Consistency Analysis September 20, 2007 

Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 

E - 2

RULE CONSISTENCY ANALYSIS FOR PROPOSED AMENDMENTS TO RULE 4682 

I. Requirements of Rule Consistency Analysis 

Pursuant to Section 40727.2 of the California Health and Safety Code, prior to adopting, 

amending of a rule or regulation, the District is required to perform a written analysis 

that identified and compares the air pollution control elements of the rule amendments 

to Rule 4682 with the corresponding elements of existing or proposed District and EPA 

regulations and guidelines that apply to manufacturers of polystyrene, polyethylene, and 

polypropylene products. The elements that were analyzed are emissions standard, 

monitoring and testing, and recordkeeping and reporting requirements. The analysis is 

discussed below and a summary is presented in the Rule Consistency Table. 

II. Results of Analysis

A. District Rules 

Rule 4682 applies to manufacturers of polystyrene, polyethylene, and polypropylene 

products. No other rule in the District covers the same source category. 

B. Federal Rules, Regulations, and Policies 

1. 40 CFR 60 Subpart DDD (Standards of Performance for Volatile Organic 

Compound (VOC) Emissions from the Polymer Manufacturing Industry) 

40 CFR 60 Subpart DDD establishes requirements for facilities involved in the 

manufacture of polypropylene, polyethylene, polystyrene, and poly (ethylene 

terephthalate) as defined in Section 60.561. The standards cover all equipment used in 

the manufacture of these polymers, beginning with raw materials preparation and 

ending with product storage, and cover all emissions. This subpart also covers control 

equipment used such as incinerators, flares, boilers, absorbers, and condensers. 

The facilities covered by Rule 4682 use these resins as raw materials in their 

manufacturing process, but do no manufacture such material on-site. 

2. Alternative Control Techniques (ACT) Document – Control of VOC Emissions 

From Polystyrene Foam Manufacturing, dated August 1990 

The ACT presents technical information on estimating and controlling VOC emissions 

from the manufacture of polystyrene foam. The ACT addresses the expandable 

polystyrene bead industry, and the extruded polystyrene foam and sheet industries. 

The ACT contains cost effectiveness estimates for different control techniques. 

However, the ACT does not prescribe the specific emission limits that should be used in 

developing a regulation to control VOC emissions from polystyrene foam manufacturing. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Rule Consistency Analysis September 20, 2007 

Final Staff Report with Appendices 

for Revised Proposed Amendments to Rule 4682 

E - 3

Rule 4682 contains specific VOC emissions limits and control system requirements to 

reduce emissions from the manufacture of polystyrene foam. The exact control 

technique is chosen by the operator to meet their manufacturing needs, but choices 

represent the ATC's suggestions. 

3. EPA “Control Techniques Guideline (CTG) Document 

The CTG applicable to SJVUAPCD Rule 4682 is entitled, ``Control of Volatile Organic 

Compound Emissions from Manufacture of High-Density Polyethylene, Polypropylene, 

and Polystyrene Resins'' (EPA-450/3-83-008). This CTG addresses what would be 

representative of Reasonably Available Control Technology (RACT) for the manufacture 

of polypropylene, high-density polyethylene, and polystyrene. The CTG contains 

emission control techniques, emission control costs and emission control analysis. 

The facilities covered by Rule 4682 use these resins as raw materials in their 

manufacturing process, but do no manufacture such material on-site. 

4. EPA Policy on Recordkeeping 

The recordkeeping requirement in Section 6.1 of Rule 4682 is consistent with EPA’s 

policy to keep and maintain records for at least five years. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Rule Consistency Analysis for Proposed Amendments to Rule 4682 S

Final Staff R

for Revised Proposed Ame

E - 4

Summary of Rule Consistency Analysis For Rule 4682 

Requirements Rule 4682 Federal Rules, Regulations, and Policies 

40 CFR 60 Subpart DDD CTG EPA-450/3-83-008 AC

Applicability The provisions of this rule apply to 

any manufacturing, processing, and storage of products composed of polystyrene, polyethylene, or polypropylene 

Manufacture of polypropylene, polyethylene, polystyrene, or poly (ethylene terephthalate). 

Control of Volatile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene Resins 

Expandable pbead industryextruded polysand sheet indu

Emission Limits 1. 2.4 lb of VOC for each 100 

pounds of total material processed, or 2. Use a non-VOC blowing agent, or 3. Control all manufacturing emissions with an approved system and store the finished product in a controlled warehouse for 24 or 48 hours, or 4. Control the manufacturing emissions to obtain an equivalent reduction to that achieved by option 3 

1. Reduce emissions of total organic compounds (minus methane and ethane) (TOC) by 98% wt. or to 20 ppmv, corrected to 3% O2, whichever is less stringent. 2. Polystyrene: TOC not to be > than 0.0072 lb TOC/ton product; or not allow outlet gas stream temperature from each final condenser to exceed –25 oC. 

1. Polypropylene plants using liquid phase processes: 98% wt. reduction or reduction to 20 ppm VOC (reaction, mat’l recovery, and finishing sections). 2. High-density polyethylene plants using liquid phase slurry processes: 98% wt. reduction or reduction to 20 ppm VOC (mat’l recovery section). 3. Polystyrene plants using continuous processes: 0.12 kg VOC/1,000 kg product (mat’l recovery section). 

None 

Exemptions 1. Sections 5.1, 5.2, and 5.3 shall 

not apply to manufacturing and processing operations using polymeric materials containing less than 1% VOC by weight and not using a blowing agent. 

1. Facilities with a design capacity to produce < 1,102 ton/year 2. Certain facilities under a maximum uncontrolled threshold. 3. Facilities with an existing control device. 4. Emergency vent streams. 

None None 

Emission measurement Calculated over a 30-day rolling 

period. 

Performance test data. None None 

Monitoring and Testing Demonstrate continuous operation 

and compliance of the emission control device by maintaining daily records of key system operating and maintenance procedures. 

1. Temperature monitoring device. 2. Flame monitoring device. 3. Flow monitoring indicator. 4. Organic monitoring device. 

None None 

Recordkeeping and reporting 

Maintain records for five years. Maintain records for two years None None