PAR 1175 - 1 (Adopted November 3, 1989)(Amended January 5, 1990) (Amended May 13, 1994)(Amended September 7, 2007)

(P roposed Amended

Rule November 5 , 2010 )

PROPOSED AMENDED RULE 1175. CONTROL OF EMISSIONS FROM THE MANUFACTURE OF POLYMERIC CELLULAR (FOAM) PRODUCTS (a) Applicability This rule shall apply to polymeric cellular product s manufacturing operations including but not limited to expandable polystyrene , extruded polystyrene , polyurethane, isocyanurate and phenolic foam operat ions. All steps of the manufacturing operation and the storage of the fina l 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 definit ions shall apply: (1) APPROVED EMISSION CONTROL SYSTEM means any syst em used to reduce manufacturing and storage emissions and c onsists of an emission collection system and a control device, which are a pproved, in writing, by the Executive Officer, that has been demonstrated t o perform and operate according to the following provisions: (A) The emission collection system shall collect at least 90 percent by weight of the manufacturing emissions; and (B) The emission collection system shall collect at least 90 percent by weight of the storage emissions; and (C) 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 fro m raw polymeric material. (3) CERTIFICATE OF ANALYSIS is a written document t hat cites the range of pentanes in expandable polystyrene bead, express ed as the percentage by weight of a manufactured bead-lot, prior to ship ment from the manufacturer. It also contains the name of the man ufacturer, a bead-lot number, and grade and type identifiers, along with a signature of an officer or an officer’s designee of the bead-lot manufactur er. (4) CHLOROFLUOROCARBON (CFC) is any chlorinated flu orinated compound of carbon

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Formatted: Font: Italic Formatted: Font: 11 pt (5) EXEMPT COMPOUNDS (see Rule 102 - Definition of Terms) (6) 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 othe r 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. (7) EXTRUDED POLYSTYRENE (XPS) FOAM OPERATIONS cons ist of a series of processes, where a blowing agent is injec ted into molten polystyrene and upon exit of the extrusion die the blowing agent vaporizes thus expanding the molten resin into foam , where it expands in both thickness and width , and includes directly associated processes that incorporate reprocessed material into XPS products . XPS products include but are not limited to food containers and insulation foams used in the construction of structures for both residential and commercial buildings, such as under concrete slabs, roofing, d ecks, steel and wood framed wall sheathing. ( 8 ) LOW-PENTANE BEAD is an expandable polystyrene bea d containing pentane as a blowing agent with an upper limit less than 4.0 percent by weight, prior to shipment, as certified upon delive ry by an accompanying bead lot manufacturer’s Certificate of Analysis. ( 9 ) MANUFACTURING EMISSIONS are any emissions of VOC, CFC, or methylene chloride that occur during the manufactur ing operation. ( 10 ) MANUFACTURING OPERATION means every step of the p rocessing of a polymeric material from the delivery of the raw m aterial, until the storage of the final cellular product. ( 11 ) MID PENTANE BEAD is an expandable polystyrene bea d containing pentane as a blowing agent within the range of 4.0 to 5.2 percent by weight, prior to shipment, as certified upon delive ry with an accompanying bead lot manufacturer’s Certificate of Analysis. ( 12 ) RAW MATERIAL means all polystyrene beads, polyure thane, reprocessed material and blowing agent used in the manufacture of polymeric cellular products. Deleted: ( Deleted: Amended September 7, 2007 Deleted: )

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Formatted: Font: (Default) Times New Roman, 12 pt Deleted: chlorodifluoromethane (HCFC-22),¶ dichlorotrifluoroethane (HCFC-123),¶ tetrafluoroethane (HFC

- 134a) , Deleted: dichlorofluoroethane (HCFC-141b),¶ chlorodifluoroethane (HCFC-142b)¶ 2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124),

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Formatted: Font: 11 pt Formatted: Font: Italic Formatted: Font: 11 pt (13) REPROCESSED MATERIAL means all regrind trim, s crap or recycled material. ( 1 4 ) RIGID POLYURETHANE is a closed cell polyurethane, primarily manufactured as rigid slabstock, laminated boardsto ck, field spray foam or pour-in-place foam. ( 1 5 ) STORAGE EMISSIONS are VOC emissions occurring for a maximum of 48 hours after the polymeric cellular foam product is manufactured. ( 1 6 ) VOLATILE ORGANIC COMPOUND (VOC) is as defined in Rule 102

. (c) Emission Control Requirements

(1) Manufacturing Operations, Excluding Expandable Polystyrene Molding Operations and Extruded Polystyrene Foam Operations (A) No polyurethane operation subject to th is rule shall use any VOCs. (B) Each manufacturing operation, excluding rigid p olyurethane operations shall reduce yearly emissions from its 1 988 emissions baseline, based on Rule 301 emission fees filing, b y 100 percent, beginning calendar year 1994. (2) Expandable Polystyrene Molding and Extruded Polystyrene Foam Operations The owner or operator of an expandable polystyrene molding operation or an extruded polystyrene foam operation shall demonstrate, to the satisfaction of the Executive Officer, manufacturin g emissions and postmanufacturing emissions, assuming all the blowing a gent is released from the product, are less than 2.4 lbs per 100 lbs of r aw material processed. (3) The owner or operator of any polymeric cellular manufacturing operation, subject to the requirements of paragraphs (c)(1) or (c)(2), shall submit a plan to be approved by the Executive Officer, that demonstrates compliance with paragraph (c)(1) or (c)(2). (4) The owner or operator of any polymeric cellular manufacturing operation that has not achieved the requirements specified in paragraph (c)(1), (c)(2), or (c)(3) shall: (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 Deleted: (

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Deleted: (EPS)Rule 1175 (Cont.) (Proposed Amended November 5, 2010)

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Formatted: Font: Italic Formatted: Font: 11 pt (B) Within twelve months of failing to meet the req uirements of paragraph (c)(1), (c)(2), or (c)(3), the following provisions must be satisfied: (i) An approved emission control system is installe d and operated with all sources of manufacturing emission s collected and reduced according to subparagraphs (b )(1)(A) and (b)(1)(C); this system, including any critical operational techniques and parameters (e.g., minimu m temperature and time in aging/curing areas venting to the control system, if applicable), must be incorporate d in a federally enforceable permit, such as a Title V ope rating permit, as approved by the Executive Officer; and (ii) All sources of storage emissions from the fina l manufactured product are collected and reduced acco rding to subparagraphs (b)(1)(B) and (b)(1)(C) for at lea st: (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 (II) 24 hours, in the case of all other manufacturi ng operations

. ( 5 ) Expanded polystyrene block molding operations may, in lieu of complying with the specific control requirements of clauses (c)(4)(B)(i) and (c)(4)B)(ii), collect and reduce, manufacturing emissions by at least 93 percent overall by weight (the product of captur e and control device efficiencies), provided, at least 60 percent of the annual expanded polystyrene block throughput is manufactured with low-pentane b ead and the remainder with mid-pentane bead. Any owner or operator of a facility who elects to comply using this alternate complianc e method shall demonstrate the requisite 93 percent reduction thro ugh a source test approved in writing by the Executive Officer

. Facilities with a Title V permit shall repeat such demonstration every five ( 5) years. This alternate compliance method, including any critical operation al techniques and parameters (e.g., minimum temperature and time in a ging/curing areas venting to the control system, if applicable), must be incorporated in a federally enforceable permit, such as a Title V ope rating permit, as approved by the Executive Officer. Deleted: ( Deleted: Amended September 7, 2007 Deleted: )

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Formatted: Tabs: Not at 1.25" + 3.3" Formatted: Font: Italic Formatted: Font: 11 pt (6) The owner or operator of a facility utilizing a n approved emission control system shall conduct source testing, to be approved in writing by the Executive Officer, to demonstrate compliance with p aragraphs (c)(2) or (c)(4). Facilities with a Title V permit shall re peat such demonstration every five (5) years. (d) Prohibition of Use No polymeric cellular product operation subject to this rule shall use methylene chloride, or any CFC, unless specifically approved as an acceptable alternative under 40 CFR Part 82 Subpart G – Significant New Al ternatives Policy Program. ( e ) Exemptions (1) The provisions of paragraph (c) shall not apply to any: (A) Expandable polystyrene operation that processes less than 200 pounds per day of raw material. (B) Rigid polyurethane operation that processes les s than 1,000 pounds per day of raw material. (2) The provisions of clause (c)(4)(B)(ii) shall no t apply to any facility that only manufactures: (A) Rigid polyurethane foam; or (B) Expanded polystyrene foam and the highest concentration of the blowing agent in the cellular product is 1.8 percen t or less by weight within 15 minutes of completion of the manuf acturing operation. Verification of the concentration shall be demonstrated annually, pursuant to a written protocol submitted to and approved by the Executive Officer.

( f ) Recordkeeping (1) Any owner or operator subject to this rule or c laiming an exemption under subdivision ( e ) shall maintain a daily record of operations, incl uding but not limited to the amount of raw material processed , the equipment used, and the type of blowing agent used. Such records s hall be retained in the operator's files for a period of five (5) years and be made available to the Executive Officer upon request. (2) Owners and/or operators using an yemission control system as a means of complying with this rule shall maintain daily recor ds of the operation and Deleted: (

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Formatted: Tabs: Not at 1.25" + 3.3" Formatted: Font: Italic Formatted: Font: 11 pt maintenance of the emission control system. These records shall include key system operating parameters such as temperature s, pressures, flowrates, and other measures needed to demonstrate compliance with paragraph s (c)(4) , (c)(5) and (c)(6)

. Such records shall be retained in the operator's files for a period of five (5) years and be made available to the Executive Officer upon request. ( g ) Methods of Analysis All applicable methods of analysis shall be as cite d in paragraphs ( g )(1) through ( g )( 4 ) below, or any other applicable method approved by the Executive Officer, the United States Environmental Protection Agency ( U.S. EPA), and the California Air Resources Board (CARB), provided the approved alternative method is equivalent to those listed below

. (1) Determination of VOC Content The VOC content of materials subject to the provisi ons of this rule shall be determined by the following methods: (A) U.S. EPA Reference Method 24 (Code of Federal R egulations Title 40 Part 60, Appendix A). The exempt solvent content shall be determined by SCAQMD Method 303 (Determination o f Exempt Compounds) contained in the SCAQMD "Laborato ry Methods of Analysis for Enforcement Samples" manual ; or, (B) SCAQMD Method 304 [Determination of Volatile Or ganic Compounds (VOCs) in Various Materials] contained in the SCAQMD "Laboratory Methods of Analysis for Enforcem ent Samples" manual. (C) Exempt Perfluorocarbon Compounds The following classes of compounds will be analyzed as exempt compounds for compliance with subdivision (c), only when manufacturers specify which individual compounds ar e used in the manufacture of polymeric cellular products: 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; and Deleted: (

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Formatted: Font: Italic Formatted: Font: 11 pt sulfur-containing perfluorocarbons with no unsatura tions and with sulfur bonds only to carbon and fluorine. In addition, the manufacturers must identify the U. S. EPA, CARB, and SCAQMD approved test methods used to quantify t he amount of each exempt compound. (2) Determination of Pentanes in Expandable Styrene Polymers The weight percent pentane in expandable polystyren e polymer shall be determined by SCAQMD Method 306 (Analysis of Pentan es in Expandable Styrene Polymers) contained in the SCAQM D "Laboratory Methods of Analysis for Enforcement Samples" manual

. (3) Determination of Efficiency of Emission Control System (A) Capture efficiency specified in paragraph (b)(1 ) or paragraph (c)( 5 ) shall be determined by the procedures presented in the U.S. EPA technical guidance document “Guidelines for Determi ning Capture Efficiency, January 9, 1995”, or U.S. EPA Methods 2 04 A-F. (B) The efficiency of the control device of the emi ssion control system specified in paragraph (b)(1) or paragraph (c)( 5 ) and the VOC content in the control device exhaust gases, measur ed and calculated as carbon, shall be determined by U.S. E PA Test Methods 25, 25A, SCAQMD Method 25.1 (Determination of Total Gaseous Non-Methane Organic Emissions as Carbon), o r SCAQMD Method 25.3 (Determination of Low Concentrat ion of Non-Methane Non-Ethane Organic Compound Emissions f rom Clean Fueled Combustion Sources) as applicable. U. S. EPA Test Method 18, or ARB Method 422 shall be used to deter mine emissions of exempt compounds. (4) Multiple Test Methods When more than one test method or set of test metho ds 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 me thods shall constitute a violation of the rule. Deleted: ( Deleted: Amended September 7, 2007 Deleted: )

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