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, 2007SAN 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 Safe ty Code, prior to adopting,

amending of a rule or regulati on, 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 element s of existing or proposed District and EPA

regulations and guidelines that apply to manuf acturers 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 present ed 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 requirem ents 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 emissi ons. This subpart also covers control

equipment used such as incinerators, flar es, boilers, absorbers, and condensers.

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

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

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

From Polystyrene Foam Manuf acturing, dated August 1990

The ACT presents technical information on estimating and controlling VOC emissions

from the manufacture of polystyrene foam. The ACT ad dresses the expandable

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

The ACT contains cost effectiveness estima tes for different control techniques.

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

developing a regulation to contro l VOC emissions from polystyrene foam manuf acturing.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 m eet their manufacturi ng needs, but choices

represent the ATC's suggestions.

3. EPA “Control Techniques Gu ideline (CTG) Document

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

Compound Emissions from Manuf acture of High-Density Poly ethylene, 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 polyethyl ene, 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 manuf acture 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 record s for at least five years.SAN JOAQUIN VALLEY UNIFIED AIRPOLLUTION CONTROL DISTRICTAppendix E: Rule Consistency Analysis for Proposed Amendments to Rule 4682 September 20, 2007Final Staff Report with Appendicesfor Revised Proposed Amendments to Rule 4682E - 4Summary of Rule Consistency Analysis For Rule 4682Federal Rules, Regulations, and PoliciesRequirementsRule468240 CFR 60 Subpart DDDCTG EPA-450/3-83-008ACTUS PolicyApplicabilityTheprovisionsof this rule apply toany manufacturing, processing, andstorage of products composed ofpolystyrene, polyethylene, orpolypropyleneManufacture of polypropylene,polyethylene, polystyrene, or poly(ethylene terephthalate).Control of Volatile OrganicCompound Emissions fromManufacture of High-DensityPolyethylene, Polypropylene, andPolystyrene ResinsExpandable polystyrenebead industry, and theextruded polystyrene foamand sheet industriesNoneEmission Limits1. 2.4 lb of VOC for each 100pounds of total material processed,or2. Use a non-VOC blowing agent, or3. Control all manufacturingemissions with an approved systemand store the finished product in acontrolled warehouse for 24 or 48hours, or4. Control the manufacturingemissions to obtain an equivalentreduction to that achieved by option 31. Reduce emissions of totalorganic compounds (minusmethane and ethane) (TOC) by98% wt. or to 20 ppmv, correctedto 3% O2, whichever is lessstringent.2. Polystyrene: TOC not to be >than 0.0072 lb TOC/ton product; ornot allow outlet gas streamtemperature from each finalcondenser to exceed –25 oC.1. Polypropylene plants using liquidphase processes: 98% wt. reductionor reduction to 20 ppm VOC(reaction, mat’l recovery, andfinishing sections).2. High-density polyethylene plantsusing liquid phase slurry processes:98% wt. reduction or reduction to 20ppm VOC (mat’l recovery section).3. Polystyrene plants usingcontinuous processes: 0.12 kgVOC/1,000 kg product (mat’lrecovery section).NoneNoneExemptions1. Sections 5.1, 5.2, and 5.3 shallnot apply to manufacturing andprocessing operations usingpolymeric materials containing lessthan 1% VOC by weight and notusing a blowing agent.1. Facilities with a design capacityto produce < 1,102 ton/year2. Certain facilities under amaximum uncontrolled threshold.3. Facilities with an existingcontrol device.4. Emergency vent streams.NoneNoneNoneEmission measurementCalculated over a 30-day rollingperiod.Performance test data.NoneNoneNoneMonitoring and TestingDemonstrate continuous operationand compliance of the emissioncontrol device by maintaining dailyrecords of key system operating andmaintenance procedures.1. Temperature monitoring device.2. Flame monitoring device.3. Flow monitoring indicator.4. Organic monitoring device.NoneNoneNoneRecordkeeping andreportingMaintain records for five years.Maintain records for two yearsNoneNoneMaintain records forfive years.